1 

2 

3 

4 Sanitary Survey Guidance Manual for Ground Water 

5 Systems (Draft) 

6 

7 

8 EPA 815-D-07-006 

9 November 2007 

10 Draft 
1 

2 
November 2007 Sanitary Survey i Draft for Discussion

Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 DISCLAIMER 

2 

3 

4 This manual provides guidance on how to conduct a sanitary survey of public water 

5 systems served solely by ground water sources. The U.S. Environmental Protection Agency 

6 believes that a comprehensive sanitary survey is an important part of helping water systems 

7 protect public health. 

8 

9 The statutory provisions and EPA regulations described in this document contain 

10 legally binding requirements. This guidance is not a substitute for applicable legal 

11 requirements, nor is it a regulation itself. Thus, it does not impose legally-binding 

12 requirements on any party, including EPA, States, or the regulated community. While 

13 EPA has made every effort to ensure the accuracy of the discussion in this guidance, the 

14 obligations of the regulated community are determined by statutes, regulations, or other 

15 legally binding requirements. In the event of a conflict between the discussion in this 

16 document and any statute or regulation, this document would not be controlling. 

17 

18 Interested parties are free to raise questions and objections to the guidance and the 

19 appropriateness of using it in a particular situation. 

20 

21 Although this manual describes suggestions for complying with GWR 

22 requirements, the guidance presented here may not be appropriate for all situations, and 

23 alternative approaches may provide satisfactory performance. 

24 

25 Mention of trade names or commercial products does not constitute an EPA endorsement 

26 or recommendation for use. 

27 

28 Comments regarding this document should be addressed to: 

29 

30 Michael Finn 

31 U.S. EPA Office of Ground Water and Drinking Water 

32 Standards and Risk Management Division 

33 1200 Pennsylvania Avenue, N.W. 4607M 

34 Washington, DC 20460 

35 Finn.Michael@epa.gov 

36 202-564-5261 

37 202-564-3767 (facsimile) 
November 2007 Sanitary Survey ii Draft for Discussion

Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 ACKNOWLEDGMENTS 

2 

3 

4 

5 
November 2007 Sanitary Survey iii Draft for Discussion

Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 CONTENTS 

2 

3 

4 Exhibits .......................................................................................................................................... vi 

5 Acronyms...................................................................................................................................... vii 

6 

7 1. Introduction and Scope of This Manual .........................................................................1-1 

8 1.1 Ground Water Rule (GWR) Requirements..........................................................1-2 

9 1.2 Overview of Sanitary Surveys .............................................................................1-6 

10 1.3 Minimum Elements of the Sanitary Survey.........................................................1-8 

11 

12 

13 2. Other Drinking Water Regulations and PWS Requirements.......................................2-1 

14 2.1 Definition of PWS................................................................................................2-1 

15 2.2 Safe Drinking Water Act (SDWA)......................................................................2-2 

16 2.2.1 National Primary Drinking Water Regulations (40 CFR Part 141)...............2-2 

17 2.2.2 National Primary Drinking Water Regulations Implementation 

18 (40 CFR Part 142)..........................................................................................2-3 

19 2.2.3 Code of Federal Regulations..........................................................................2-4 

20 2.2.4 Source Water Assessment and Protection Program (SWAPP) and 

21 Wellhead Protection Program (WHPP) .........................................................2-4 

22 2.2.5 Total Coliform Rule (TCR) ...........................................................................2-5 

23 2.2.6 Lead and Copper Rule ...................................................................................2-5 

24 2.2.7 Stage 1 Disinfectants and Disinfection Byproducts (D/DBPs) .....................2-6 

25 2.2.8 Stage 2 Disinfectants and Disinfection Byproducts (D/DBPs) .....................2-6 

26 2.2.9 Inorganic and Organic Chemicals..................................................................2-7 

27 2.2.10 Radiological Contaminants............................................................................2-7 

28 

29 3. Preparing for the Survey..................................................................................................3-1 

30 3.1 Contact and Location ...........................................................................................3-1 

31 3.2 Planning the Sanitary Survey...............................................................................3-2 

32 3.2.1 Resources Needed..........................................................................................3-2 

33 3.2.2 Personal Safety...............................................................................................3-3 

34 3.2.3 Logistics.........................................................................................................3-3 

35 3.3 Inventory of System Facilities .............................................................................3-4 

36 3.4 File Review Elements ..........................................................................................3-6 

37 3.4.1 Previous Sanitary Surveys .............................................................................3-7 

38 3.4.2 Source Water Assessments ............................................................................3-7 

39 3.4.3 Compliance and Enforcement History...........................................................3-8 

40 3.4.4 Monitoring Plans............................................................................................3-9 

41 3.4.5 Consumer Confidence Reports (CCR) ........................................................3-10 

42 3.4.6 Other Required Submittals...........................................................................3-10 

43 3.4.7 Total Coliform Rule (TCR) History ............................................................3-11 

44 3.4.8 Variance and Exemptions ............................................................................3-12 

45 3.4.9 Correspondence............................................................................................ 3-12 

46 

47 4. Field Survey.......................................................................................................................4-1 

48 4.1 Logistics...............................................................................................................4-2
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1 4.2 Sources.................................................................................................................4-3

2 4.2.1 Well Construction ..........................................................................................4-3 

3 4.2.1.1 Surface Features.................................................................................4-5 

4 4.2.1.2 Subsurface Features ...........................................................................4-8 

5 4.2.1.3 Driller’s Logs................................................................................... 4-10 

6 4.2.1.4 Typical Defects ................................................................................4-10 

7 4.2.2 Potential Sources of Contamination.............................................................4-11 

8 4.2.2.1 Wellhead Protection Program (WHPP) ........................................... 4-12 

9 4.2.2.2 Source Vulnerability Assessment .................................................... 4-12 

10 4.2.2.3 Abandoned Wells.............................................................................4-13 

11 4.2.3 Source Quantity and Capacity .....................................................................4-13 

12 4.2.4 Confirm Well Locations ..............................................................................4-16 

13 4.2.5 Source Water Transmission .........................................................................4-16 

14 4.2.6 Site Security................................................................................................. 4-17 

15 4.2.7 General Housekeeping.................................................................................4-18 

16 4.2.8 Cross Connections ....................................................................................... 4-19 

17 4.3 Treatment ...........................................................................................................4-19 

18 4.3.1 Treatment Plant Schematic/Site Plan...........................................................4-20 

19 4.3.2 Capacity of Treatment Facilities..................................................................4-21 

20 4.3.3 Chemicals and Chemical Feed Systems ...................................................... 4-22 

21 4.3.3.1 Liquid Chemical Feed Systems .......................................................4-22 

22 4.3.3.2 Dry Chemical Feeders (Volumetric and Gravimetric).....................4-23 

23 4.3.4 Disinfection..................................................................................................4-26 

24 4.3.4.1 Dosage and Residual........................................................................4-26 

25 4.3.4.2 Chlorine and Water..........................................................................4-27 

26 4.3.4.3 Gas Chlorination ..............................................................................4-31 

27 4.3.4.4 Liquid Hypochlorination.................................................................. 4-34 

28 4.3.4.5 Typical Liquid Chlorine System......................................................4-34 

29 4.3.4.6 Typical Defects ................................................................................4-36 

30 4.4 Distribution System ...........................................................................................4-37 

31 4.4.1 Distribution System Mapping......................................................................4-38 

32 4.4.2 Distribution System Pipe Material and Condition.......................................4-39 

33 4.4.3 Location and Maintenance of Valves ..........................................................4-41 

34 4.4.4 Design and Construction Standards.............................................................4-42 

35 4.4.5 Maintaining Adequate Pressure ................................................................... 4-44 

36 4.4.6 Response to Water Main Breaks..................................................................4-45 

37 4.4.7 Flushing Programs .......................................................................................4-46 

38 4.4.8 Water Quality Monitoring............................................................................4-46 

39 4.4.8.1 Maintaining a Residual .................................................................... 4-47 

40 4.4.8.2 Bacteriological Quality (TCR)......................................................... 4-48 

41 4.4.8.3 Other Water Quality Parameters......................................................4-49 

42 4.4.8.4 Customer Complaints.......................................................................4-49 

43 4.4.9 Cross Connection Control............................................................................ 4-50 

44 4.5 Finished Water Storage......................................................................................4-52 

45 4.5.1 Storage Facility Inventory............................................................................4-53 

46 4.5.2 Capability and Capacity...............................................................................4-56 

47 4.5.2.1 Capability.........................................................................................4-56 

48 4.5.2.2 Storage Capacity ..............................................................................4-58 

49 4.5.3 Design and Construction.............................................................................. 4-58 
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1 4.5.4 Site Security and Sanitary Risks..................................................................4-63 

2 4.6 Pumps................................................................................................................. 4-64 

3 4.6.1 Typical Pumps ............................................................................................. 4-64 

4 4.6.2 Number and Capacity ..................................................................................4-68 

5 4.6.3 Routine Maintenance/Lubrication/Exercise................................................. 4-69 

6 4.6.4 Housing........................................................................................................ 4-70 

7 4.6.5 Site Security................................................................................................. 4-70 

8 4.6.6 Cross Connections ....................................................................................... 4-70 

9 4.7 Emergency Power ..............................................................................................4-71 

10 4.8 Remote Monitoring/Control/Alarms..................................................................4-72 

11 4.9 Monitoring/Reporting/Data Verification ...........................................................4-73 

12 4.10 Water System Management/Operations ............................................................4-75 

13 4.10.1 Organization and Management (TMF Capacity).........................................4-75 

14 4.10.2 Staff Levels .................................................................................................. 4-77 

15 4.10.3 Training........................................................................................................4-78 

16 4.10.4 Revenue........................................................................................................ 4-78 

17 4.10.5 Additional Management Issues....................................................................4-80 

18 4.11 Operator Requirements ......................................................................................4-80 

19 4.11.1 General Operator Requirements ..................................................................4-80 

20 4.11.2 Certification Required Based on Size/Treatment ........................................4-80 

21 4.12 References.......................................................................................................... 4-81 

22 

23 5. Compiling and Reporting the Sanitary Survey Results ................................................5-1 

24 5.1 Sanitary Survey Report........................................................................................5-2 

25 5.2 Sanitary Survey Documentation ..........................................................................5-4 

26 5.3 Categorizing the Findings....................................................................................5-5 

27 5.4 Corrective Action.................................................................................................5-9 

28 5.5 Outstanding Performance................................................................................... 5-10 

29 

30 6. Report Review and Response...........................................................................................6-1 

31 6.1 State Actions ........................................................................................................6-1 

32 6.2 Water System Actions..........................................................................................6-3 

33 

34 

35 Appendices

36 

37 Appendix A Evaluating Ground Water Treatment for Ground Water Rule Compliance 

38 Appendix B Using Sanitary Surveys to Update State Source Water Protection Programs 

39 
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1 EXHIBITS 

2 

3 

4 Exhibit 1.1 Summary of GWR Requirements............................................................................1-3 

5 Exhibit 1.2 Sanitary Survey Frequency for PWSs under the GWR ..........................................1-4 

6 Exhibit 1.3 Sanitary Survey Requirements.................................................................................1-5 

7 

8 

9 Exhibit 3.1 Communication Activities .......................................................................................3-2 

10 Exhibit 3.2 Example Schematic of a Ground Water PWS with Iron Removal Treatment.......3-5 

11 Exhibit 3.3 Records and Retention Period..................................................................................3-8

12 

13 

14 Exhibit 4.1 Major Components of a Typical Groundwater Well...............................................4-4 

15 Exhibit 4.2 Illustrations of a Split Cap and Seal.........................................................................4-6

16 Exhibit 4.3 An Overlapping Exterior Sanitary Well Seal..........................................................4-6 

17 Exhibit 4.4 Top of Casing Illustration for a Well with a Lineshaft Turbine 

18 Pump (left) and a Well with a Submersible Turbine Pump and a Split Cap..........4-7 

19 Exhibit 4.5 Example Schematic Diagram of a Ground Water Treatment Plant...................... 4-21 

20 Exhibit 4.6 Schematic of a Typical Liquid Chemical Feed System ........................................ 4-23 

21 Exhibit 4.7 Breakpoint Chlorination Curve.............................................................................. 4-28 

22 Exhibit 4.8 Example of an Air Gap on a Chemical Feed System............................................ 4-36 

23 Exhibit 4.9 Elevated and Ground Storage Tanks ..................................................................... 4-55 

24 Exhibit 4.10 Typical Hydropneumatic Tank Installation........................................................... 4-56 

25 Exhibit 4.11 Components of a Storage Tank.............................................................................. 4-60 

26 Exhibit 4.12 Types of Pressure Tanks ........................................................................................ 4-61 

27 Exhibit 4.13 Applications for Centrifugal Pumps ...................................................................... 4-66 

28 Exhibit 4.14 Common Centrifugal Pump Types and Components ........................................... 4-67 

29 Exhibit 4.15 Pump Sizing Criteria.............................................................................................. 4-68 

30 

31 

32 Exhibit 5.1 Example of Sanitary Survey Deficiencies...............................................................5-6 

33 

34 

35 Exhibit 6.1 Summary of 40 CFR 142.16(o)(2) – Special Primacy Requirements for 

36 Sanitary Survey Requirements of the GWR............................................................6-2 

37 
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1 ACRONYMS 

2 

3 

4 ANSI/NSF American National Standards Institute/National Sanitary Foundation 

5 ASME American Society of Mechanical Engineers 

6 AWWA American Water Works Association 

7 BFP Backflow Preventer 

8 CCR Consumer Confidence Reports 

9 CFR Code of Federal Regulations 

10 CT Concentration of Residual Disinfectant multiplied by Time of Water Contact 

11 (Detention Time) 

12 DBP Disinfection Byproduct 

13 D/DBP Disinfectants/Disinfection Byproducts 

14 DHS Department of Health Services 

15 DOT Department of Transportation 

16 EPA The United States Environmental Protection Agency 

17 ETV Environmental Technology Verification

18 GAC Granular Activated Carbon 

19 GIS Geographic Information System 

20 GLUMRB Great Lakes Upper Mississippi River Board 

21 GPS Global Positioning System 

22 GREP Generally Recommended Engineering Practice 

23 GWR Ground Water Rule 

24 GWUDI Ground Water Under the Direct Influence 

25 HAA5 Haloacetic Acids 

26 HDPE High-density Polyethylene 

27 HPC Heterotrophic Plate Count 

28 HSA Hydrogeologic Sensitivity Assessment 

29 IDSE Initial Distribution System Evaluation 

30 IESWTR Interim Enhanced Surface Water Treatment Rule 

31 LRAA Locational Running Annual Average 

32 MCL Maximum Contaminant Level 

33 M-DBP Microbial-Disinfectants/Disinfection Byproducts 

34 MRDL Maximum Residual Disinfectant Level 

35 MWCO Molecular Weight Cut Off 

36 NODA Notice of Data Availability 

37 NPDWR Nationa Primary Drinking Water Regulations 

38 NSF National Sanitation Foundation 

39 NTNCWS Non-transient Non-community Water System 

40 O&M Operation and Maintenance 

41 OSHA Occupational Safety and Health Administration

42 OWQP Optimal Water Quality Parameter 

43 PB Polybutylene 

44 PE Polyethylene 

45 PVC Polyvinyl Chloride 

46 PWS Public Water System 
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1 RPZ Reduced Pressure Zone 

2 SDWA Safe Drinking Water Act 

3 SOC synthetic Organic Contaminant 

4 SOP Standard Operating Procedure 

5 SWAPP Source Water Assessment and Protection Program 

6 SWTR Surface Water Treatment Rule 

7 TCR Total Coliform Rule 

8 TDT Theoretical Detention Time 

9 THM Trihalomethane 

10 TNRCC Texas Natural Resource Conservation Commission 

11 TNCWS Transient Non-community Water System 

12 TTHM Total Trihalomethane 

13 UFTREEO University of Florida Training, Research, and Education for Environmental 

14 Occupations 

15 UL Underwriters Labratories 

16 USGS United States Geological Survey 

17 UV Ultraviolet Light 

18 VOC Volatile Organic Contaminant 

19 WFI Water Facilities Inventory 

20 WHPA Wellhead Protection Area 

21 WHPP Wellhead Protection Program 

22 
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1 1. Introduction and Scope of This Manual 

2 

3 

4 This manual provides guidance on how to conduct a sanitary survey of a Public Water 

5 System (PWS) that is served by ground water. A sound sanitary survey program is an essential 

6 element of an effective State drinking water program. Sanitary surveys are a proactive public 

7 health measure that can identify deficiencies in PWSs that could result in contamination of the 

8 public water supply before any contamination occurs. 

9 

10 Sanitary surveys enable States to provide a comprehensive and accurate review of the 

11 components of water systems, to assess the operating conditions and adequacy of the water 

12 system, and to determine if past recommendations have been implemented effectively. The 

13 purpose of the sanitary survey is to evaluate and document the capabilities of the water system's 

14 sources, treatment, storage, distribution network, operation and maintenance, and overall 

15 management to ensure the provision of safe water. In addition, sanitary surveys provide an 

16 opportunity for States to visit the water system and educate operators about proper monitoring 

17 and sampling procedures and to provide technical assistance. They are used to evaluate: (1) the 

18 capability of a drinking water system to consistently and reliably deliver an adequate quality and 

19 quantity of safe drinking water to the consumer; and (2) the system’s compliance with Federal 

20 drinking water regulations. This guidance manual identifies assessment criteria to evaluate 

21 sanitary risks in a typical water system. The manual also describes how to identify significant 

22 deficiencies that are causing, or have the potential to cause, the introduction of contamination 

23 into the water delivered to consumers and, therefore, require corrective actions. 

24 

25 State agencies should use this manual as a tool to ensure that sanitary surveys are 

26 comprehensive, well documented, and meet the primacy requirements. PWS owners and 

27 operators will find hands-on information on operation and management of their drinking water 

28 systems and drinking water well sources. The manual also helps inspectors understand how each 

29 set of Safe Drinking Water Act (SDWA) regulations applies to sanitary surveys. 

30 

31 The overall structure of the guidance manual centers on the four principal stages of a 

32 sanitary survey: planning a sanitary survey; conducting the onsite survey; compiling a sanitary 

33 survey report; and performing follow-up activities including responding to a sanitary survey. 

34 The manual is organized as follows: 

35 

36 • Chapter 1 – Introduction and Scope of This Manual. This chapter provides 

37 background information, explains the Ground Water Rule (GWR) requirements for 

38 sanitary surveys, and discusses the minimum elements of a sanitary survey. 

39 

40 • Chapter 2 – Other Drinking Water Regulations and PWS Requirements. This 

41 chapter provides information on the regulatory context for sanitary surveys. 

42 

43 • Chapter 3 – Preparing for the Survey. This chapter provides guidance as to tasks 

44 that should be carried out in the office before an inspector conducts the field 

45 component of the sanitary survey. 

46 

47 • Chapter 4 – Field Survey. This chapter discusses each of the eight elements of a 

48 sanitary survey that meets the requirements of the GWR. The chapter explains each 
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1 element’s importance for an effective sanitary survey and presents general guidelines 

2 (assessment criteria) for evaluating important components of each element. 

3 Discussions about each element identify the components of high priority that may be 

4 considered significant deficiencies. 

5 

6 • Chapter 5 – Compiling and Reporting the Sanitary Survey Results. This chapter 

7 provides guidelines for compiling and reporting the sanitary survey results as well as 

8 suggestions for keeping adequate documentation of the sanitary survey. 

9 

10 • Chapter 6 – Report Review and Response. This chapter describes the follow-up 

11 actions that should be taken by the water system operator and the State in response to 

12 the findings of a sanitary survey, including those actions that must be taken to correct 

13 any identified deficiencies. 

14 

15 1.1 Ground Water Rule (GWR) Requirements 

16 

17 The GWR applies to public ground water systems (systems that have at least 15 service 

18 connections, or regularly serve at least 25 individuals daily at least 60 days out of the year). The 

19 GWR applies to all PWSs served by ground water except PWSs that combine all their ground 

20 water sources prior to treatment then meet the requirements of Subpart H (Surface Water 

21 Treatment Rule (SWTR)). 

22 

23 Requirements in the GWR include: 

24 

25 • System sanitary surveys conducted by the State with minimum scope and frequency 

26 and identification of significant deficiencies; 

27 

28 • Triggered source water microbial monitoring by systems that do not provide 4-log 

29 treatment of viruses for their ground water sources and have a total coliform (TC)-

30 positive result in samples collected under the Total Coliform Rule (TCR) 

31 requirements for routine coliform monitoring; 

32 

33 • Corrective action by any system with significant deficiencies or fecal indicator 

34 positive source water samples; and 

35 

36 • Compliance monitoring for systems that provide 4-log treatment of viruses for their 

37 ground water sources. 

38 

39 The GWR also requires ground water systems, if directed by the State, to conduct 

40 assessment source water monitoring for ground water sources. The United States Environmental 

41 Protection Agency (EPA) recommends that this assessment monitoring consist of 12 source 

42 water samples analyzed for E.Coli, coliphage or enterococci, as specified by the State. EPA also 

43 recommends hydrogeologic sensitivity assessments (HSAs) for ground water systems drawing 

44 from aquifers susceptible to fecal contamination as a basis for assessment source water 

45 monitoring. If the State chooses to perform HSAs, the GWR requires systems to provide the 

46 State with available information necessary for the State to conduct the HSAs. 

47 

48 A summary of the GWR’s requirements is illustrated in Exhibit 1.1. 
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1 Exhibit 1.1 Summary of GWR Requirements 

2 

3 
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1 Sanitary surveys are required every 3 years for community ground water systems and 

2 every 5 years for non-community ground water systems. This is consistent with the 1998 Interim 

3 Enhanced Surface Water Treatment Rule (IESWTR) for surface water systems. The survey 

4 frequency is shown in Exhibit 1.2. 

5 

6 

7 Exhibit 1.2 Sanitary Survey Frequency for PWSs under the GWR 

8 

System Type Minimum Frequency of Surveys 

Community water system Every 3 years 

Community water system with outstanding 

performance based on prior sanitary surveys OR treats 

to 4-log inactivation of viruses 

Every 5 years 

Non-community water system (both non-transient and 

transient non-community) 

Every 5 years 

9 

10 

11 The key components of the GWR’s sanitary survey requirements include: 

12 

13 • The State must conduct sanitary surveys that address the minimum 8 elements of the 

14 GWR State primacy requirements for all ground water systems. 

15 

16 • The State must have authority to enforce corrective action requirements. 

17 

18 • The State must provide a notice of all significant deficiencies (e.g., those that require 

19 corrective action) to the system within 30 days of identification of the deficiencies. 

20 

21 • Systems must consult with the State and take corrective action for any significant 

22 deficiencies no later than 120 days after receiving written notification of such 

23 deficiencies, or submit a schedule and plan to the State for correcting these 

24 deficiencies within the same 120 day period. 

25 

26 Once a ground water system has been identified as having significant deficiencies, it must 

27 do one or more of the following: 

28 

29 • Eliminate the source of contamination; 

30 

31 • Correct the significant deficiency; 

32 

33 • Provide an alternate source of water; and 

34 

35 • Provide a treatment that reliably achieves at least 99.99 percent (4-log) inactivation or 

36 removal of viruses before or at the first customer. 

37 

38 Exhibit 1.3 provides a flowchart explaining the sanitary survey requirements of the 

39 GWR. 

40 

41 
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1 Exhibit 1.3 Sanitary Survey Requirements 

2 

3 

4 
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1 An inspector should review the previous sanitary survey report and other relevant records 

2 to determine if a system has an outstanding performance designation. Since this designation 

3 affects the required frequency for a survey, it may impact whether that system will be inspected 

4 at the current time. When a system is being inspected, a review of the water system’s file should 

5 be conducted to obtain pertinent information about the physical facility and water quality data 

6 before the actual site visit. 

7 

8 Community water systems that are classified as having outstanding performance are 

9 eligible for having sanitary surveys conducted less frequently than other community systems. 

10 Under the GWR, community water systems must have a sanitary survey performed by the State 

11 at least once every three years with some exceptions. If the State determines that a community 

12 system either treats to 4-log inactivation of viruses or has shown outstanding performance, the 

13 survey frequency may be reduced to at least once every five years. 

14 

15 Each State, as part of its application for primacy, is required to develop a means for 

16 determining whether a system has outstanding performance. A State should have defined 

17 outstanding performance and established certain specifications for determining outstanding 

18 performance. To determine if a system has outstanding performance, the inspector should 

19 review the report from the system’s previous sanitary survey to see if the system was considered 

20 to have outstanding performance then. If the State includes information on outstanding 

21 performance designations in a tracking database, the inspector should check the system’s listing 

22 in the database. The inspector should also examine the State’s records on the facility collected 

23 since the last sanitary survey. The records of interest will depend upon the State’s criteria for 

24 outstanding performance but may include: monitoring data, violation records, and notifications 

25 of changes to the physical facility or the operator personnel. This information will help the 

26 inspector to determine if there are any changes in performance since the previous survey that 

27 indicates the system no longer satisfies the State’s definition of outstanding performance. 

28 

29 

30 1.2 Overview of Sanitary Surveys 

31 

32 In the GWR, a sanitary survey is defined (§141.401(b)) as follows: 

33 

34 “A sanitary survey, as conducted by the State, includes but is not limited to, an 

35 onsite review of the water source(s) (identifying sources of contamination by 

36 using results of source water assessments or other relevant information where 

37 available), facilities, equipment, operation, maintenance, and monitoring 

38 compliance of a public water system to evaluate the adequacy of the system, its 

39 sources and operations and the distribution of safe drinking water.” 

40 

41 Conducting sanitary surveys on a routine basis is an important element in preventing 

42 contamination of drinking water supplies and in maintaining PWS compliance with National 

43 Primary Drinking Water Regulations. EPA recognizes the importance of sound sanitary surveys 

44 as a proactive public health measure helping water systems protect public health. Sanitary 

45 surveys are an opportunity to work and communicate with water systems in a preventive mode. 

46 

47 As stated in the December 1995 EPA/State Joint Guidance on Sanitary Surveys, sanitary 

48 surveys provide an opportunity for State drinking water officials or approved third party 

49 inspectors to establish a field presence at the water system. The surveys also serve to educate the 
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1 operators about proper monitoring and sampling procedures, provide technical assistance, and 

2 inform them of any upcoming changes in regulations. Sanitary surveys also aid in the process of 

3 evaluating a PWS’s progress in complying with Federal and State regulations that require the 

4 improvement of the capabilities of the system to provide safe drinking water. Sanitary surveys 

5 provide the water system with technical and management information regarding the operation of 

6 the system from the water source, through the treatment facilities and the distribution system. 

7 Under the GWR, States direct or approve corrective actions to address public health risk from 

8 significant deficiencies found during sanitary surveys (as well as during other State field visits or 

9 investigations). 

10 

11 The 1995 EPA/State Joint Guidance on Sanitary Surveys lists the following specific 

12 benefits of conducting sanitary surveys: 

13 

14 • Operator education; 

15 

16 • Source protection; 

17 

18 • Risk evaluation; 

19 

20 • Technical assistance and training; 

21 

22 • Independent, third party system review; 

23 

24 • Information for monitoring waiver programs; 

25 

26 • Identification of factors limiting a system’s ability to continually provide safe 

27 drinking water; 

28 

29 • Reduction of monitoring requirements; 

30 

31 • Reduction of formal enforcement actions in favor of more informal action; 

32 

33 • Reduction of oversight by State monitoring and enforcement personnel; 

34 

35 • Increased communication between State drinking water personnel and PWS 

36 operators; 

37 

38 • Provision of contact personnel to notify in case of emergencies or for technical 

39 assistance; 

40 

41 • Improvement of system compliance with State drinking water regulations; 

42 

43 • Identification of candidate systems for enforcement action; 

44 

45 • Identification of candidates for Comprehensive Performance Evaluations; 

46 

47 • Verification of data validity; 

48 
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1 • Validation of test equipment and procedures; 

2 

3 • Reduced risk of waterborne disease outbreaks; 

4 

5 • Encouragement of disaster response planning; and 

6 

7 • Improved system security. 

8 

9 EPA recommends that States work with EPA Regions to use sanitary survey guidance to 

10 improve their sanitary survey programs while still addressing the problems and issues specific to 

11 the State. 

12 

13 

14 1.3 Minimum Elements of the Sanitary Survey 

15 

16 The GWR requires that sanitary surveys address all of the eight elements of the EPA/ 

17 State joint guidance. Each of these elements is described in more detail in Chapter 4. 

18 

19 EPA and the States (through the Association of State Drinking Water Administrators) 

20 issued a joint guidance on sanitary surveys entitled EPA/State Joint Guidance on Sanitary 

21 Surveys (1995). The guidance outlines the following eight elements as integral components of a 

22 sanitary survey: 

23 

24 • Source (Protection, Physical Components and Condition), 

25 

26 • Treatment, 

27 

28 • Distribution System, 

29 

30 • Finished Water Storage, 

31 

32 • Pumps/Pump Facilities and Controls, 

33 

34 • Monitoring/Reporting/Data Verification, 

35 

36 • Water System Management/Operations, and 

37 

38 • Operator Compliance with State Requirements. 

39 

40 

41 

42 

43 
1 2. Other Drinking Water Regulations and PWS Requirements 

2 

3 

4 In addition to specifying maximum contaminant levels (MCLs) or treatment technique 

5 requirements, the Federal drinking water regulations address sampling location, frequency, 

6 recordkeeping and other requirements that should be evaluated during a sanitary survey. This 

7 section provides the basic information for inspectors to determine if a water system is a PWS 

8 subject to EPA regulations. If so, inspectors should be able to recognize requirements from 

9 various provisions of the drinking water regulations. 

10 

11 

12 2.1 Definition of PWS 

13 

14 PWSs are defined as systems for providing water for human consumption through pipes 

15 or other constructed conveyances, if such systems have at least 15 service connections or 

16 regularly serve at least 25 people at least 60 days a year. A system includes any collection, 

17 treatment, storage, and distribution facilities under control of the system operator and used 

18 primarily in connection with such a system, and any collection or treatment facilities not under 

19 such control that are used primarily in connection with such a system. 

20 

21 Three important field determinations made during a sanitary survey are: 

22 

23 • The number of people served by the system; 

24 

25 • The number of service connections; and 

26 

27 • Whether service is provided for at least 60 days a year. 

28 

29 This information determines whether a system meets the definition of a PWS in SDWA 

30 and whether it is subject to the National Primary Drinking Water Regulations (NPDWR). 

31 

32 Although the NPDWR apply to all PWSs, the regulations make a distinction between 

33 community and non-community systems. A further distinction is made between transient and 

34 non-transient non-community systems. 

35 

36 Community water systems serve a residential population of at least 25 people or 15 

37 service connections on a year-round basis. Users of community systems are likely to be exposed 

38 to any contaminants in the water supply over an extended time period and are thus subject to 

39 both acute and chronic health effects. 

40 

41 Non-community systems are either transient or non-transient systems. Non-transient non42 community water systems (NTNCWS) serve at least 25 of the same persons at least 6 months per 

43 year on a regular basis. These systems can expose users to drinking water contaminants over an 

44 extended time period (subjecting users to risks of both acute and chronic health effects), similar 

45 to community systems. Schools, churches and factories would fall under this definition. 

46 Transient non-community water systems (TNCWS) serve short-term users. As a result, the users 

47 are exposed to any drinking water contaminants only briefly. Users are subject to experiencing 

48 acute health effects. Examples are restaurants, gas stations, hotels, and campgrounds. 

49 
1 These distinctions and others, such as the water source and population served, are 

2 important because States may regulate these systems differently. An inspector needs to know the 

3 characteristics of a system to know whether a system is properly classified and, therefore, which 

4 regulations are applicable. The population served also determines sampling frequency in a 

5 number of regulations, including the TCR, Lead and Copper Rule, Stage 1 and Stage 2 

6 Disinfection and Disinfection Byproducts (D/DBP) Rules, and Phase II and V inorganic and 

7 organic chemical monitoring. 

8 

9 Most water system operators will know how many individual service connections they 

10 have within their systems but not necessarily the population served by the system. Some States 

11 will use a factor multiplied by the number of service connections to estimate population. During 

12 the survey, the inspector should determine if the State records on population and number of 

13 service connections are up-to-date. Further evaluation will be needed to determine if changes in 

14 population will affect the system’s status relative to any SDWA requirements. 

15 

16 

17 2.2 Safe Drinking Water Act (SDWA) 

18 

19 Congress enacted the SDWA in 1974. The Act was intended to ensure the delivery of 

20 safe drinking water by PWSs and to protect ground water sources from contamination. 

21 

22 In 1986, Amendments to SDWA were signed into law. These Amendments greatly 

23 expanded the number and type of contaminants to be regulated in drinking water, as well as 

24 strengthened EPA’s enforcement authority. The passage of these Amendments was the result of 

25 heightened concern about the potential contamination of public water supplies by toxic 

26 chemicals and an increase in the number of waterborne disease outbreaks caused by 

27 microbiological contaminants. 

28 

29 In 1996, Congress again amended SDWA. The new law for the first time provides for 

30 State revolving loan funds to improve water systems. It also requires EPA to base regulations on 

31 risk assessment and cost-benefit considerations. The new law requires EPA to identify the best 

32 treatment technologies for various sizes of systems and establish guidelines for operator 

33 certification. Monitoring relief is provided for small systems. Source water protection and 

34 consumer confidence reports are also a part of the new law. 

35 

36 Brief summaries of important drinking water regulations that form the basis for sanitary 

37 surveys of ground water systems are provided in this section. 

38 

39 

40 2.2.1 National Primary Drinking Water Regulations (40 CFR Part 141) 

41 

42 SDWA requires EPA to establish drinking water regulations for contaminants in drinking 

43 water that may have an adverse effect on the public health. These regulations are known as the 

44 National Primary Drinking Water Regulations (NPDWR) and include MCLs or treatment 

45 techniques for over 100 contaminants. Monitoring and testing procedures also are specified. As 

46 mentioned above, the NPDWR apply to all PWSs. 

47 

48 Congress intended SDWA requirements to be implemented primarily by the States. 

49 Therefore, SDWA requires EPA to define the requirements for allowing States to implement and 
1 enforce State regulations in lieu of the Federal regulations. State regulations must be at least as 

2 stringent as the Federal regulations; however, they may also be more stringent. When a State’s 

3 program has been approved by EPA, the State is granted primary enforcement authority 

4 (“primacy”) for its drinking water program. Primacy requirements are codified in 40 CFR Part 

5 142, NPDWR Implementation. EPA may grant a State primary enforcement authority when the 

6 Administrator of EPA determines that a State has met the following requirements: 

7 

8 • Defining a PWS consistent with the definition in SDWA; 

9 

10 • Having adequate enforcement authority and procedures; 

11 

12 • Maintaining an inventory of PWSs; 

13 

14 • Having a systematic program for conducting sanitary surveys of PWSs with priority 

15 given to systems not in compliance with the NPDWR; 

16 

17 • Having a program to certify laboratories that will analyze water samples; 

18 

19 • Having a certified laboratory that will serve as the State’s principal laboratory; 

20 

21 • Having a program to review the design and construction of new or modified systems; 

22 

23 • Having adequate recordkeeping and reporting requirements; 

24 

25 • Having an adequate plan to provide for safe drinking water in emergencies; and 

26 

27 • Having variance and exemption requirements as stringent as EPA’s if the State 

28 chooses to allow variances or exemptions. 

29 

30 In primacy States (all but Wyoming, the District of Columbia, and Tribal lands), PWSs 

31 are subject to State, as well as Federal drinking water regulations. Therefore, whenever a 

32 Federal regulation is cited in this document, the State primacy agency inspector needs to be 

33 aware of the equivalent State regulation as well as any additional State requirements. 

34 

35 

36 2.2.2 National Primary Drinking Water Regulations Implementation (40 CFR Part 142) 

37 

38 States are required by 40 CFR Part 142(c)(7) to report the month and year the most recent 

39 sanitary survey was completed. Similar reports are required for any corrective actions completed 

40 under the GWR, and for any ground water PWSs providing 4-log treatment of viruses. 

41 

42 Section 142.16, Special Primacy Requirements, ensures that States have the legal 

43 authority to enforce and implement the GWR. States describe how they will implement a 

44 sanitary survey program and the other required elements in 40 CFR Part 141. States must 

45 conduct sanitary surveys for all ground water PWSs with a minimum frequency and scope. The 

46 first sanitary survey for community water systems must be completed 6 years after promulgation 

47 of the final rule, or 8 years after promulgation of the final rule for non-community systems. 

48 Subsequent surveys must be conducted every 3 or 5 years, for community systems and non-
1 community water systems, respectively. The GWR allows a 5 year frequency for sanitary 

2 surveys for community PWSs that provide 4-log treatment of viruses or have an outstanding 

3 performance record as determined by the State. 

4 

5 

6 2.2.3 Code of Federal Regulations 

7 

8 All final EPA regulations are published (or “promulgated”) in the Federal Register. 

9 Federal regulations are compiled annually and codified in the Code of Federal Regulations 

10 (CFR). EPA’s regulations are found in Title 40 of the CFR (40 CFR). NPDWR are incorporated 

11 or codified in 40 CFR Part 141, which is divided into subparts and sections for specific 

12 regulatory provisions. For example, coliform monitoring requirements are found in section 21 of 

13 Part 141 (40 CFR 141.21). The CFR is available from the Government Printing Office in 

14 Washington, D.C., and EPA’s regulations can be accessed and downloaded from its Web site 

15 (http://www.epa.gov/epacfr40/chapt_I.info/chi_toc.htm). The EPA Drinking Water Hotline 

16 (800- 426- 4791) provides another easily accessible source of information on SDWA regulations. 

17 

18 

19 2.2.4 Source Water Assessment and Protection Program (SWAPP) and Wellhead 

20 Protection Program (WHPP) 

21 

22 Section 1453 of the SDWA is a requirement for States to develop and implement Source 

23 Water Assessment and Protection Programs (SWAPPs). The SWAPP must delineate the source 

24 water areas for all PWSs in the State, identify the potential sources of contaminants within the 

25 areas, and determine the susceptibility of the water systems to the contaminants. 

26 

27 The Source Water Assessment of a ground water system should be reviewed in the file 

28 review prior to the field survey. The inspector should note the potential sources of 

29 contaminations and review the susceptibility determinations for the ground water source for later 

30 use. During the field survey, the inspector should verify that the inventory of potential sources of 

31 contamination has not changed. 

32 

33 In the final EPA National Guidance on State Source Water Assessment and Protection 

34 Programs, EPA explains that State programs must indicate in their SWAPP submittals that the 

35 delineation of source water protection areas for ground water based systems will be in 

36 accordance with accepted methods for Wellhead Protection Programs (WHPPs) under Section 

37 1428 of the SDWA. These are described in EPA’s publication entitled Guidelines for 

38 Delineation of Wellhead Protection Areas, June 1987. 

39 

40 States are further required to develop WHPPs under Section 1428 of the 1986 

41 Amendments to the SDWA. The WHPPs are to: 

42 

43 • Identify the members of a team to develop and implement the WHPP; 

44 

45 • Delineate a wellhead protection area (WHPA) surrounding the well based on “all 

46 reasonably available hydrogeologic information”; 

47 

48 • Identify all potential sources of contaminants; 

49 
1 • Describe a program to protect the water supply within the WHPA; 

2 

3 • Include contingency plans for providing drinking water in the event of contamination 

4 of the water supply; 

5 

6 • Consider potential pollutant sources for all new wells; and 

7 

8 • State WHPPs provide guidelines and a framework for the development of local, 

9 system-based WHPPs. Many systems have used these guidelines to develop their 

10 own WHPP to address local water protection concerns. 

11 

12 

13 2.2.5 Total Coliform Rule (TCR) 

14 

15 The TCR applies to all PWSs. The sanitary survey requirements of the TCR have been 

16 replaced by newer requirements of the IESWTR (for systems served by surface water or ground 

17 water under the direct influence of surface water) and the GWR (for systems served by ground 

18 water). 

19 

20 The TCR requires that a water system have a written sample siting plan approved by the 

21 State. The inspector should verify that there is an approved plan that is being utilized. The 

22 inspector should also evaluate the plan to determine if it is currently meeting the requirements of 

23 the TCR. The rule requires collecting samples “that are representative of water throughout the 

24 distribution system.” The rule also contains a table that shows the minimum number of samples 

25 required based on population served. In reviewing the sample siting plan, the inspector should 

26 note that more samples than the minimum may be required in order to be “representative.” Some 

27 of the issues to be concerned with are short chlorine contact time to first customer, dead ends, 

28 long residence time in the system, multiple sources, storage tanks, areas of low pressure, biofilm, 

29 and cross- connections. 

30 

31 

32 2.2.6 Lead and Copper Rule 

33 

34 The Lead and Copper Rule requires PWSs to collect tap water samples to determine lead 

35 and copper levels (40 CFR 141.80-.91). The Lead and Copper Rule Minor Revisions of April 

36 2000 and Short-Term Revisions of 2007modified some of the original Lead and Copper Rule of 

37 1991. Large water systems (serving >50,000) are required to optimize corrosion control. Small 

38 and medium water systems (serving ≤ 50,000) that exceed action levels are required to optimize 

39 corrosion control. Inspector reviewing PWSs required to optimize corrosion control should refer 

40 to the Lead and Copper Rule requirements for determining compliance with optimized corrosion 

41 control. EPA has also issued guidance entitled How to Determine Compliance with Optimal 

42 Water Quality Parameters as Revised by the Lead and Copper Rule Minor Revisions (February 

43 2001). It describes how inspectors determine compliance with the optimal water quality 

44 parameter (OWQP) ranges or minimums. Inspectors should also refer to their State’s policy on 

45 OWQP monitoring. 

46 

47 An inspector should verify that the system has completed a site sampling plan in 

48 compliance with sampling location requirements and is monitoring in accordance with that plan 

49 with the required frequency, number and location of samples. Systems using ground water may 
1 reduce source water sampling for the Lead and Copper Rule to once in every 9 year compliance 

2 cycle under certain conditions (40 CFR Section 141.88(e)), and the inspector should verify these 

3 conditions are still being met. 

4 

5 

6 2.2.7 Stage 1 Disinfectants and Disinfection Byproducts (D/DBPs) 

7 

8 40 CFR Part 141, Subpart L, Disinfectant Residuals, Disinfection Byproducts (DBPs), 

9 and DBP Precursors, provides requirements for all community and non-transient non-community 

10 PWSs that add a chemical disinfectant to their water. Portions of Subpart L also apply to 

11 TNCWS that use chlorine dioxide. Components of Subpart L that inspectors must be aware of 

12 include: 

13 

14 • MCLs for disinfection by-products including total trihalomethanes (TTHMs), 

15 haloacetic acids (HAA5), bromated, and chlorite; 

16 

17 • Maximum residual disinfectant levels for chlorine, chloramines, and chlorine dioxide; 

18 

19 • Monitoring plan requirements; and 

20 

21 • Enhanced coagulation and enhanced softening requirements to address DBP 

22 precursors for Subpart H systems with conventional or softening plants. 

23 

24 It should be noted that each system affected by this rule must develop and implement a 

25 monitoring plan. The system must then maintain the monitoring plan and make it available for 

26 inspection by the State and general public (systems serving more than 3,000 people must submit 

27 their plans to the State). The inspector should review the monitoring plan while performing the 

28 sanitary survey. 

29 

30 

31 2.2.8 Stage 2 Disinfectants and Disinfection Byproducts (D/DBPs) 

32 

33 As with the Stage 1 D/DBP Rule, the Stage 2 D/DBP Rule provides requirements for all 

34 community and non-transient non-community PWSs that add a chemical disinfectant to their 

35 water. Stage 2 D/DBP Rule requires these system to meet MCLs as an average at each 

36 compliance monitoring location (instead of as a system-wide average as in Stage 1 D/DBP) for 

37 two groups of DBPs, TTHM and HAA5. 

38 

39 Under the Stage 2 D/DBP rule, systems will conduct an evaluation of their distribution 

40 systems, known as an Initial Distribution System Evaluation (IDSE), to identify the locations 

41 with high DBP concentrations. These locations will then be used by the systems as the sampling 

42 sites for Stage 2 D/DBP rule compliance monitoring. 

43 

44 Compliance with the MCLs for two groups of DBPs will be calculated for each 

45 monitoring location in the distribution system. This approach, referred to as the locational 

46 running annual average (LRAA), differs from Stage 1 D/DBP requirements, which determine 

47 compliance by calculating the running annual average of samples from all monitoring locations 

48 across the system. 

49 
1 The Stage 2 D/DBP rule also requires each system to determine if they have exceeded an 

2 operational evaluation level, which is identified using their compliance monitoring results. The 

3 operational evaluation level provides an early warning of possible future MCL violations, which 

4 allows the system to take proactive steps to remain in compliance. A system that exceeds an 

5 operational evaluation level is required to review their operational practices and submit a report 

6 to their State that identifies actions that may be taken to mitigate future high DBP levels, 

7 particularly those that may jeopardize their compliance with the DBP MCLs. 

8 

9 The compliance schedule for Stage 2 D/DBP requirements is based on system size and 

10 sources used (ground water or surface water). The inspector should verify that the IDSE 

11 requirements have been met, that the system is conducting compliance monitoring according to 

12 an approved plan, and that the system has met the requirements for operational evaluations. 

13 

14 

15 2.2.9 Inorganic and Organic Chemicals 

16 

17 Monitoring requirements for inorganic and organic chemicals are contained in 40 CFR 

18 141.23 and 40 CFR 141.24, respectively. For both groups of contaminants, ground water system 

19 samples are required at each entry point to the distribution system that is representative of each 

20 well after treatment. Inspectors should verify that all sources are appropriately monitored at the 

21 entry point(s). If systems have detected inorganic or organic chemicals, the inspector should 

22 verify that monitoring frequency is appropriate and review any monitoring waivers. 

23 

24 

25 2.2.10 Radiological Contaminants 

26 

27 Monitoring requirements for radionuclides are contained in 40 CFR 141.66. For this 

28 group of contaminants, community ground water systems are required to monitor at each entry 

29 point to the distribution system that is representative of all sources being used under normal 

30 operating conditions. Inspectors should verify that all sources are appropriately monitored at the 

31 entry point(s). 

32 

33 

34 
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Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 3. Preparing for the Survey 

2 

3 

4 In order to conduct an effective and efficient sanitary survey, the inspector must organize 

5 and plan the effort well. Many critical steps are required, beginning with the first phone call to 

6 arrange the onsite inspection and ending with the sustainable correction of sanitary defects. The 

7 survey should be viewed as a cooperative partnership between the primacy agency and the water 

8 purveyor, as both organizations share a common goal of providing safe drinking water to the 

9 public. 

10 

11 

12 3.1 Contact and Location 

13 

14 The inspector must contact the water system owner or operator to explain the purpose of 

15 the sanitary survey; schedule a meeting location, date, and time when key personnel will be 

16 available; and discuss any action that needs to be taken by the water system in preparation for the 

17 survey. Telephone contact followed by a short follow-up notification letter is recommended, with 

18 sufficient time for system personnel to respond to the notice. If the inspector must change the 

19 schedule, it must be done at the earliest possible time. 

20 

21 It is essential that the inspector contact the person directly responsible for the overall 

22 management of the system (e.g. CEO, mayor, water commissioner, utility manager) in order to 

23 obtain cooperation, gather information, coordinate with other departments or agencies, and 

24 transmit the results of the evaluation. 

25 

26 Finally, coordination and communication between the inspector and the primacy agency, 

27 local health department, and water system management personnel are essential in preparing for a 

28 sanitary survey. The inspector needs to work with each of these entities to be properly prepared 

29 for the sanitary survey. Some of the information the inspector should exchange with each of 

30 these entities is listed in Exhibit 3.1. 

31 

32 
November 2007 Sanitary Survey 3-2 Draft for Discussion

Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 Exhibit 3.1 Communication Activities 

2 

Entity Activities 

Primacy agency The primacy agency should provide the inspector with information 

for water systems to consider for sanitary surveys (based on when 

the previous survey was done), past sanitary survey reports, and 

other information in the agency files for the relevant water systems. 

The primacy agency should also provide the inspector with agency 

inspection requirements and guidelines, such as assessment 

criteria, a list of significant deficiencies, and any sanitary survey 

forms used by the agency. 

Local health department The inspector should ask the health department if there have been 

any reported illnesses attributed to drinking water. 

Water system 

management personnel 

The inspector should contact the water system and first determine 

the appropriate personnel for further sanitary survey discussions. 

With the appropriate personnel, the inspector should describe the 

purpose of the sanitary survey and the steps of the survey, 

particularly the onsite inspection (described in Chapter 4). 

Preliminary discussions should also include: 

− a review of previous sanitary survey reports and the system’s 

historical records (including chemical and bacteriological data), 

− correspondence, 

− engineering studies, 

− past violations, and 

− any records that are needed for review but are not available 

from the primacy agency’s files. 

The inspector should also schedule the onsite inspection with the 

water system. 

3 

4 

5 3.2 Planning the Sanitary Survey 

6 

7 In planning the sanitary survey, the inspector needs to estimate the time required to 

8 manage his or her time well. The estimate should include time prior to, and after the onsite 

9 inspection. Although the time required will vary with the complexity of the water system and the 

10 experience of the inspector, a good rule of thumb would be two hours in the office for every hour 

11 in the field. Once onsite, the inspector may identify other priority areas that need more attention. 

12 If so, the inspector should then adjust the onsite schedule accordingly. 

13 

14 

15 3.2.1 Resources Needed 

16 

17 Prior to the onsite inspection, sanitary survey inspectors should ensure that their field 

18 equipment is in good working order. Preventive maintenance is essential for all types of 

19 equipment. Equipment that is broken, dirty, in disrepair, out of calibration, or otherwise 

20 improperly maintained will not provide dependable, reproducible, or accurate data. For best 

21 results, the inspector should follow the manufacturer’s specifications for preventive maintenance. 

22 The inspector also should check expiration dates and keep up with and use current standard 

23 testing procedures and calibration methods. Recommended types of field equipment include but 

24 are not limited to: 
November 2007 Sanitary Survey 3-3 Draft for Discussion

Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 

2 • Hand held colorimeter, portable spectrophotometer, or other mechanical residual 

3 chlorine test kit; 

4 

5 • Accurate pressure gauge; 

6 

7 • Portable Global Positioning System (GPS) equipment; 

8 

9 • Camera with automatic time/date stamp; 

10 

11 • Binoculars; 

12 

13 • Cell phone; 

14 

15 • Small mirror (provides light and allows inspection of areas that are not accessible or 

16 are not in the direct line of sight); and 

17 

18 • Flashlight. 

19 

20 

21 3.2.2 Personal Safety 

22 

23 The sanitary survey planning effort needs to address safety considerations, both for the 

24 field inspector and the system’s operating staff. Safety hazards can include head injuries from 

25 low clearance piping, snake and spider bites, insect stings, electrical shock, chemical exposure, 

26 drowning, confined space entry, noise, lifting injuries, and slipping, tripping, and falling. Prior 

27 to the onsite inspection, the inspector should ensure that personal protective equipment is 

28 available. The most frequently used equipment includes safety hats, goggles, gloves, earplugs, 

29 and steel-toed safety shoes. Respirators and a self-contained breathing apparatus may also be 

30 used in some cases. Sanitary survey inspectors should fully understand their State’s policy or the 

31 system’s procedures on confined space entry and climbing ladders and adhere to the policy or 

32 procedures when conducting the field visit. 

33 

34 

35 3.2.3 Logistics 

36 

37 Contact with the system and planning prior to the field survey should include the logistics 

38 of completing the field survey including but not limited to: 

39 

40 • Scheduling a time and meeting place; 

41 

42 • Directions; 

43 

44 • Contact phone numbers if lost or running late; 

45 

46 • Any security clearances or special access requirements to enter the water treatment 

47 plant or other facilities; 

48 
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Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 • Availability of PWS staff, treatment operator, water quality staff, distribution system 

2 operator, cross connection program etc., to complete the field survey; and 

3 

4 • Budgeting of sufficient time for the onsite visit based on previous experience or 

5 inspections. 

6 

7 

8 3.3 Inventory of System Facilities 

9 

10 Prior to each sanitary survey, the inspector should review available information, going 

11 back at least to the last sanitary survey, concerning the system involved. Information that should 

12 be collected includes the treatment in place, monitoring requirements, the compliance history of 

13 the facility, and the condition of the system during the previous sanitary survey. This 

14 information is used to identify questions to ask and assessment criteria to apply during the onsite 

15 inspection. 

16 

17 A schematic or layout map of the PWS will enable the inspector to obtain a quick 

18 understanding of the complete drinking water system. If possible, prior to the site visit, the 

19 inspector should obtain a schematic or layout drawings of the portions of the facility that will be 

20 evaluated during the survey. The schematic or layout map should start at the source and 

21 continue through the treatment facilities and storage facilities to the distribution system. 

22 

23 The primary purpose of the schematic or layout map is to help the inspector quickly 

24 understand the basic operation of the system. Therefore, it should be drawn in enough detail to 

25 facilitate the inspector’s understanding. A schematic typically provides general information on 

26 the basic system components and the direction of water flow in the system. Water system 

27 schematics should include an identification of source water supply facilities (e.g., well; pumping 

28 station; transmission line), the treatment plant, any booster plants, finished water storage (e.g., 

29 clearwells, elevated and ground storage tanks, pressure zones), the entrance to the distribution 

30 system, any associated facilities (e.g., pumping stations), and any interconnections with other 

31 PWSs. A schematic of a typical PWS is provided in Exhibit 3.2. 

32 

33 
November 2007 Sanitary Survey 3-5 Draft for Discussion

Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 Exhibit 3.2 Example Schematic of a Ground Water PWS with Iron Removal 

2 Treatment 

3 

4 

5 

6 

7 Layout maps are more detailed than schematics and contain more specific information on 

8 the location and orientation of physical facilities. In collecting the layout data, an inspector may 

9 easily obtain the latitude and longitude data of a PWS by using portable GPS equipment. A 

10 water system may have separate layout maps for its treatment plant and distribution system. 

11 

12 For identification purposes, the name and identification number of the PWS, as well as 

13 the date of the sketch, should be included on each schematic and layout map. The dated 

14 schematics and layout maps will help future inspectors identify water system changes. The 

15 schematic and/or map should be current and reflect any changes that have been made since initial 

16 construction of the system and since the last sanitary survey. 

17 

18 Suggested criteria for assessing treatment plant schematic or layout map(s): 

19 

20 Does the drawing(s) show the name of the facility and date of the last modification 

21 made to the drawing(s)? 

22 

23 This will help future inspectors know if and when sanitary survey modifications took 

24 place. Taken together, a chronological set of schematics will help document a system’s history. 

25 

26 Does the schematic or map(s) contain a legend that explains key symbols used in the 

27 drawing(s)? 

28 

29 With the aid of a legend, the inspector will get a better idea about the location of principal 

30 treatment units and appurtenant equipment. The drawing with its legend will provide the 

31 inspector with information useful for determining where to start and end the inspection, as well 
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Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 as areas that the inspector should focus on and inspect in particular detail. It is also helpful if 

2 there is a graph scale for the layout. 

3 

4 Are influent, effluent, and residual disposal points clearly shown on the drawing(s)? 

5 

6 If these points are not shown on the schematic or the layout map during the onsite 

7 inspection, the inspector should add sketches for these points to the drawing(s) or use a separate 

8 sheet and have inspection comments adjacent to the sketches. 

9 

10 Does the schematic or map(s) show all the elements of the water system, from source 

11 facilities to the distribution system? Does the schematic or map(s) reflect the actual 

12 water system? 

13 

14 The inspector should review the schematic or map(s) to verify that all elements of the 

15 treatment system are shown and the drawings are complete. During the onsite inspection, the 

16 inspector should compare the drawings to the actual system layout to assess the accuracy of the 

17 drawings. Some systems do not update their maps to reflect system modification or have 

18 incomplete drawings, limiting their usefulness. 

19 

20 

21 3.4 File Review Elements 

22 

23 In order to efficiently determine a system’s compliance with the various regulatory 

24 requirements, the inspector must rely on information available in the State primacy agency office 

25 as well as that gathered in the field. Various reports, correspondence, engineering studies, and 

26 monitoring data for at least the last 5 years are important sources of information for determining 

27 a system’s compliance and are typically available in the office for review and evaluation. 

28 

29 Office files and files provided by the water system owner and operator will provide 

30 insight into the design, construction, operation, maintenance, management, and compliance 

31 status of the facility. The sanitary survey inspector should thoroughly review all pertinent 

32 documents before the onsite inspection in order to fully understand the site-specific issues. The 

33 following subsections describe important types of documentation that the inspector should 

34 review if possible. While not all-inclusive, the following subsections discuss significant types of 

35 information often available. Information to review includes: 

36 

37 • Previous sanitary surveys; 

38 

39 • Source water assessments, wellhead protection plans, source protection information; 

40 

41 • Compliance and enforcement history; 

42 

43 • Required monitoring; 

44 

45 • Consumer Confidence Reports (CCRs); 

46 

47 • TCR compliance history; 

48 
November 2007 Sanitary Survey 3-7 Draft for Discussion

Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 • Waivers and exemptions; 

2 

3 • Water system schematic/layout maps; 

4 

5 • Project reports and construction documents; 

6 

7 • Cross connection control plans; 

8 

9 • Management plan or operations and maintenance plan; and 

10 

11 • Other correspondence about system issues. 

12 

13 

14 3.4.1 Previous Sanitary Surveys 

15 

16 Previous sanitary survey reports provide valuable information on the system’s history and 

17 compliance status. The sanitary survey report includes a record of system treatment processes, 

18 operations, and personnel and their compliance with SDWA requirements. Significant 

19 deficiencies identified in the previous sanitary survey indicate some of the areas the sanitary 

20 survey inspector should focus on during the inspection to determine if they have been corrected 

21 and have not become problem areas again. Review of several previous sanitary survey reports 

22 may reveal a pattern of noncompliance in certain aspects of the system. If so, the inspector 

23 should pay particular attention to these areas during the onsite inspection and ask appropriate 

24 personnel about these problems and how they are being addressed. 

25 

26 

27 3.4.2 Source Water Assessments 

28 

29 An inspector should review the source water assessment and any wellhead protection 

30 plans for a system before the sanitary survey’s field visit. This information will provide the 

31 inspector with a list of potential contamination sources that may require investigation and 

32 possibly revision. The information may also identify source control measures that may require 

33 inspection to determine if they are being implemented. In addition, the source water assessments 

34 will provide valuable information on well integrity and hydrogeologic sensitivity. 

35 

36 During a sanitary survey, the inspector should re-evaluate the system’s source water 

37 assessments to see if they need to be updated. New potential sources of contamination should be 

38 noted. Alternatively, any potential sources of contamination that have been removed should 

39 have their status updated in the source water assessment. For example, if a municipality has 

40 switched from privately owned septic systems to a public sewer system, the inspector should 

41 note this during the survey and update the source water assessment on file. Appendix B provides 

42 guidance regarding how to review and revise source water assessments during the sanitary 

43 survey. 

44 

45 
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1 3.4.3 Compliance and Enforcement History 

2 

3 SDWA and its regulations require self-monitoring and self- reporting by water systems to 

4 show compliance with the regulations. The water system should submit reports to the State on a 

5 regular basis detailing the system operations and identifying any problems encountered during 

6 the month. 

7 

8 An inspector should review all of the operating reports submitted since the last sanitary 

9 survey to ascertain any trends (e.g., changes in water quality, chemical usage, flow rates, or 

10 chlorine residuals) that may help to focus the inspection. Often there is not enough time 

11 available to review all of the reports. Therefore, the inspector should focus on violations or 

12 system problems that either the water system reported to the State or were identified during the 

13 previous sanitary survey. 

14 

15 The consequences of non-compliance can be severe (e.g., compliance orders and 

16 penalties). Errors in information reported to the State can result from ignorance of proper testing 

17 procedures and instruments out of calibration. Data falsification is a rare, but serious, 

18 occurrence. During a survey the inspector should be alert to errors in data, intentional or 

19 unintentional. 

20 

21 There are a number of general recordkeeping requirements specified in 40 CFR 141.33. 

22 In addition, the Lead and Copper Rule (40 CFR 141.91) has specific requirements shown in 

23 Exhibit 3.3. The inspector should verify the availability of these records at the water system 

24 during the sanitary survey. 

25 

26 

27 Exhibit 3.3 Records and Retention Period 

28 

Records to Keep Retention Period

Bacteriological analysis 

Chemical analysis 

Actions to correct violations 

Sanitary survey reports 

Variance or exemption 

Turbidity results 

All lead and copper data 

5 years 

10 years 

3 years 

10 years 

5 years 

10 years 

12 years 

29 

30 

31 Federal regulations require the water system to issue notices to the public when the 

32 system: 

33 

34 • Violates an MCL or treatment technique requirement; or 

35 

36 • Fails to comply with monitoring requirements or analytical method requirements. 

37 

38 All public notices should include: 

39 

40 • A clear, concise, and simple explanation of the violation; 

41 
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1 • A discussion of potential adverse health effects; 

2 

3 • A discussion of any segments of the population that may be at higher risk; 

4 

5 • A list of steps the water system has taken or plans to take to remedy the situation; 

6 

7 • A list of any preventive steps consumers should take; 

8 

9 • Any need for seeking an alternative water supply; and 

10 

11 • The water system’s name and telephone number. 

12 

13 The regulations require that public notice: 

14 

15 • Be displayed in a conspicuous way when printed or posted , 

16 

17 • Not contain overly technical language or very small print, 

18 

19 • Not contain language that nullifies the purpose of the notice, and 

20 

21 • For systems serving a large proportion of non-English speaking consumers, contain 

22 information in the appropriate languages regarding the importance of the information 

23 and where to obtain a translated copy of the notice or assistance in the appropriate 

24 language. 

25 

26 In some cases, depending on the severity of the violation, additional specific 

27 requirements (e.g., including mandatory health effects language in the notice) apply. The public 

28 notices are to be distributed by mail, hand delivered to all consumers served by the water system, 

29 or placed in newspapers widely circulated in the area. Certain violations may also require 

30 announcements on radio and television stations serving the area. (40 CFR 141.32) 

31 

32 State regulations may also require the water system to submit a report to the State or issue 

33 a public notice under certain conditions (e.g., a system is identified as the source of a waterborne 

34 disease outbreak, experiences an unscheduled loss in pressure, or fails to comply with a State 

35 order). If the inspector identified such public notification requirements when preparing for the 

36 onsite visit, the notification’s text and procedure should be reviewed. 

37 

38 

39 3.4.4 Monitoring Plans 

40 

41 EPA drinking water regulations and State equivalents establish minimum 

42 requirements for the contaminants to monitor and acceptable concentrations for each in the 

43 finished water stream. The monitoring frequency, requirements for repeat or follow-up testing, 

44 and sample location are also typically included in the monitoring plans. 

45 
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1 Monitoring plans are required to be prepared for: 

2 

3 • Total coliforms; 

4 

5 • Disinfectant residual; and 

6 

7 • DBPs. 

8 

9 Additional monitoring plans may be prepared for: 

10 

11 • Inorganic chemicals; 

12 

13 • Organic chemicals; 

14 

15 • “Unregulated” chemicals; 

16 

17 • Radionuclides; and 

18 

19 • GWR monitoring. 

20 

21 

22 3.4.5 Consumer Confidence Reports (CCR) 

23 

24 CWSs are required to prepare and distribute a CCR annually as well as submit a copy of 

25 the CCR to the State. As part of the file review, the inspector should review when and how the 

26 CCR was distributed as well as any content issues. Distribution issues include efforts to reach 

27 consumers that are not bill-paying customers and distribution to consecutive systems by 

28 wholesale systems. Content issues include the required language and information for all CCRs, 

29 as well as additional health information required as a result of system-specific violations, 

30 variance, exemptions, or detections of specific contaminants (i.e. nitrate, lead, TTHM, arsenic). 

31 

32 

33 3.4.6 Other Required Submittals 

34 

35 The water system may need to submit project reports or plans and schedules to the State 

36 for approval before any change in equipment installation or construction of any new water 

37 system, water system extension, or improvement, or when requested. The GWR requires that 

38 system consult with the State regarding correction of significant deficiencies. For significant 

39 deficiencies that are not corrected with 120 days of notification by the State, systems must follow 

40 a State-approved plan and schedule 

41 

42 A project report should demonstrate consistency with the State design requirements for 

43 water systems or State direction and should include: 

44 

45 • A project description—Why the project is being proposed, how problems are to be 

46 addressed, the relationship of the project to other system components, and the impact 

47 of the project on system capacity and ability to serve customers. In some States a 

48 project description should contain “a statement of determination” related to the State 
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1 environmental policy act and include source development information and type of 

2 treatment; 

3 

4 • Planning data—General project background with population and water demand 

5 forecasts, how the project will impact neighboring water systems, construction 

6 schedule, estimated capital, and annual operating costs; 

7 

8 • An analysis of alternatives—Description of options and the rationale for selecting the 

9 proposed option; 

10 

11 • A review of water quality—How water quality relates to the purpose of the proposed 

12 project, including analytical results of raw water and finished water quality; 

13 

14 • A review of water quantity—Applicable water rights as they relate to the project; 

15 

16 • Engineering calculations—Sizing justification, hydraulic analyses, physical capacity 

17 analyses, and other relevant technical considerations necessary to support the project; 

18 and 

19 

20 • Design and construction standards—Performance standards, construction materials 

21 and methods, and sizing criteria. 

22 

23 The inspector should review any available project reports for proposed, ongoing, and 

24 recently completed projects at the water system. These reports may describe upcoming activities 

25 that are already planned and may address some of the problems the inspector finds during the 

26 sanitary survey. 

27 

28 

29 3.4.7 Total Coliform Rule (TCR) History 

30 

31 The TCR applies to all PWSs. The TCR requires that a water system have a written 

32 sample siting plan approved by the State. The inspector should verify that there is an approved 

33 plan that is being utilized. The inspector should also evaluate the plan to determine if it is 

34 currently meeting the requirements of the TCR. The rule requires collecting samples “that are 

35 representative of water throughout the distribution system.” The rule also contains a table that 

36 shows the minimum number of samples required based on population served. In reviewing the 

37 sample siting plan, the inspector should ensure that at least the minimum required number of 

38 samples are being collected and that the sampling locations are representative of the distribution 

39 system. Items to be addressed in file review of the TCR history include; 

40 

41 • For larger systems, are TCR samples collected over the entire month and 

42 representative of all sources? 

43 

44 • Does the system have a history of failure to conduct TCR monitoring or failure to 

45 submit TCR monitoring results? 

46 
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1 • If system has a history of coliform detections, has it identified and addressed the 

2 source of the problem? 

3 

4 • Does the system have a history of TCR MCL violations? 

5 

6 • Has the system had TCR acute violations or detections of fecal indicators? 

7 

8 

9 3.4.8 Variance and Exemptions 

10 

11 A review of system files should include a review of any SDWA variances or exemptions. 

12 If the system is currently operating under a waiver or exemptions file review should verify the 

13 following with any needed follow up for the field visit noted. 

14 

15 For systems with variances: 

16 

17 • Are conditions of the variance being met based on the file information? 

18 

19 • Is the system making adequate progress in meeting the variance requirements? 

20 

21 • Is the system still eligible for a variance or should the variance be reviewed? 

22 

23 For systems with exemptions: 

24 

25 • Has the schedule for compliance been met? 

26 

27 • Is the system implementing any required control measures? 

28 

29 • Has the exemption been renewed? 

30 

31 

32 3.4.9 Correspondence 

33 

34 A review of system files should include a review of correspondence between the State 

35 and the system. Items that may be important in completing the sanitary survey and survey report 

36 include: 

37 

38 • Changes in ownership, operation, population served, and service area; 

39 

40 • Changes in sources or treatment or other system modifications; 

41 

42 • Progress in meeting compliance schedules or other required actions; 

43 

44 • Responses to notices of deficiencies or failures to meet monitoring requirements; and 

45 

46 • Other State reports (i.e. annual water statistics). 

47 

48 
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1 4. Field Survey 

2 

3 

4 Previous chapters of this manual have provided a definition of a sanitary survey, the 

5 regulatory framework for conducting a survey, and the critical steps for planning a sanitary 

6 survey. This chapter presents the essential elements for completing the walk through inspection 

7 of an onsite sanitary survey. The onsite sanitary survey includes visiting the water supply source 

8 and source facilities, pump stations, the treatment process, storage facilities, the distribution 

9 system, and sampling locations. One of the most important functions of the onsite portion of the 

10 survey is to determine whether the existing facilities are adequate to meet the needs of the water 

11 system’s customers at all times. Therefore, this visit should include review and verification of 

12 the capability and capacity, construction and operation, and physical condition of the water 

13 system’s facilities. 

14 

15 There are eight elements that are considered essential for review in the proper conduct of 

16 a thorough sanitary survey. These eight elements are listed below: 

17 

18 • Source (Protection, Physical Components, and Condition); 

19 

20 • Treatment; 

21 

22 • Distribution System; 

23 

24 • Finished Water Storage; 

25 

26 • Pumps/Pump Facilities and Controls; 

27 

28 • Monitoring/Reporting/Data Verification; 

29 

30 • Water System Management/Operations; and 

31 

32 • Operator Compliance with State Requirements. 

33 

34 This chapter presents a general description of each element and its importance as part of 

35 the sanitary survey, general guidelines for evaluating important components of each element, and 

36 a discussion of priority components under each element. The order of the eight elements is not 

37 intended to dictate the sequence of survey activities, but to provide a logical division of the 

38 essential elements for a sanitary survey. Each element is divided into components and includes a 

39 discussion of the issues that an inspector should consider when evaluating a particular 

40 component. Guidelines for evaluating the components are provided in the form of a list of 

41 assessment criteria. The assessment criteria identify areas that need to be reviewed during a 

42 sanitary survey. The criteria are intended to help the inspector identify sanitary risks that may 

43 arise due to deficiencies in a particular component. 

44 

45 In conducting the sanitary survey, the inspector should pay particular attention to those 

46 areas where deficiencies would be considered significant and thus warrant prompt corrective 

47 action. This format allows States flexibility in evaluating the components based on system type, 
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1 size, and complexity. The Appendix includes standard forms that can be used to conduct a 

2 survey. 

3 

4 

5 4.1 Logistics 

6 

7 The onsite inspection includes the following parts: 

8 

9 Opening interview 

10 

11 • Introductions. 

12 

13 • Review of the purpose of the sanitary survey. 

14 

15 • Review of the parts of the onsite inspection and the schedule for the inspection. 

16 

17 • Review of the facility layout and location of the well(s) and treatment processes. 

18 

19 • General discussion of basic system information; the condition of the system and its 

20 operation, staffing, and management; whether relevant plans and procedures have 

21 been developed and are adequate. 

22 

23 • Discussion of deficiencies identified in previous sanitary survey reports and any 

24 violations/compliance problems since the last survey; and corrective actions taken 

25 and their effectiveness in addressing the deficiencies and problems. 

26 

27 Access, Transportation and Safety 

28 

29 • Has access to all facilities been arranged? 

30 

31 • Are the appropriate personnel available for the individual system components or 

32 programs? 

33 

34 • Has transportation to the system components been arranged? 

35 

36 • Are there any safety conditions that need to be addressed?(i.e. climbing equipment, 

37 confined space) 

38 

39 Walk through 

40 

41 • Physical inspection of all visible system components. 

42 

43 • Asking questions of appropriate personnel for clarification, to determine the 

44 knowledge of system personnel, and to check information obtained during records 

45 review and other aspects of survey planning and preparation. 

46 

47 • Note taking for documentation and writing up the findings in the sanitary survey 

48 report. 
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1 

2 Organization of findings and documentation 

3 

4 • Filling in any gaps in inspection notes and add detail where needed. 

5 

6 • Completing sanitary survey checklists/forms (if used). 

7 

8 • Clarification of any remaining issues with water system personnel. 

9 

10 • Obtaining any documentation still needed. 

11 

12 • Preparation for closing interview. 

13 

14 Closing interview/debriefing the system on inspection findings 

15 

16 • Presentation of findings, particularly any significant deficiencies, to the water system. 

17 

18 • Informing water system management of next steps (i.e., writing and submitting the 

19 report, corrective action). 

20 

21 

22 4.2 Sources 

23 

24 The water supply source is the beginning of the drinking water system and can be a 

25 source of contaminants, pathogens, and particles. Preventing source water contamination is an 

26 effective way to prevent contaminants from reaching consumers. Source water protection also 

27 helps prevent additional, potentially more costly treatment from being necessary for the removal 

28 of contaminants. 

29 

30 The objectives of surveying the raw water source are to: 

31 

32 • Review the major components of the source to determine reliability, quality, quantity, 

33 and vulnerability; and 

34 

35 • Determine and evaluate data that define the potential for degradation of the source 

36 water quality. 

37 

38 To accomplish these objectives, the inspector needs to review available information on 

39 source water facilities and wellhead protection plans where they exist for a system. In the field, 

40 the inspector should discuss the water supply source with the operator(s) and verify the 

41 information received from the plans with field observations. The following areas should be 

42 reviewed as part of the sanitary survey. 

43 

44 

45 4.2.1 Well Construction 

46 

47 Ground water is drawn from underground aquifers. To get the ground water to the 

48 distribution system, a well is drilled and a pump is usually installed below the water level. A 
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1 major concern in the design of a well is preventing contaminants from entering the aquifer. The 

2 major components of a typical groundwater well are shown in Exhibit 4.1. 

3 

4 

5 Exhibit 4.1 Major Components of a Typical Groundwater Well 

6 

7 ©Arasmith Consulting Resources 

8 (Source: UFTREEO Center, 1998; Used with permission) 

9 

10 

11 Although there are many well drilling techniques, a typical well may be started by 

12 drilling a hole in the ground into a water-bearing aquifer. The drilled hole is supported by solid 

13 casing installed to just below the water table. The well casing is usually made of steel or 

14 polyvinyl chloride (PVC). It should have walls thick enough to meet collapse strength 

15 requirements for its use (Recommended Standards for Water Works, 2003). PVC casing is not 

16 recommended at locations where there is a chance that the overlying soil contains hydrocarbons 

17 that could permeate the casing and contaminate the deeper water being used. 
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1 

2 Screen material is installed below the casing to allow water into the casing while 

3 preventing the migration of sand and silt into the bottom of the well. The screen should be 

4 constructed of corrosion resistant material that is both strong and hydraulically efficient. The 

5 screen’s mesh size should be determined based on a sieve analysis of the formation or gravel 

6 pack materials. The screen should be installed so the pumping water level remains above the 

7 screen under all operating conditions. 

8 

9 Wells are often equipped with submersible pumps and discharge lines that reach down 

10 inside the casing into the water. Some wells have a lineshaft turbine pump mounted on top of 

11 their casings. Depending on the type of well pump being used, the casing will look different and 

12 will be equipped with different kinds of seals and vents. These differences and their potential 

13 deficiencies are described in more detail in section 4.3.1.1. 

14 

15 The well casing is usually surrounded by 1 to 2 inches of neat cement or concrete grout. 

16 The grout fills the annular opening between the casing’s exterior and the edge of the hole drilled 

17 in the ground. Ideally, the annular opening should be large enough to allow a minimum of 1 1⁄2 

18 inches of grout around the casing. 

19 

20 

21 4.2.1.1 Surface Features 

22 

23 The well casing should extend at least 18 inches above the pump house floor and ground 

24 surface. If the location of the well is prone to flooding, the casing and its vent should extend high 

25 enough so they are not submerged during a flood. EPA recommends that, at locations prone to 

26 flooding, the top of the casing should stand at least 3 feet above the 100 year flood level or the 

27 highest known flood elevation (whichever is higher)(USEPA, 2003). 

28 

29 Wells with submersible pumps should be capped and the cap should be sealed so no 

30 water or contamination can enter the well. Seals should fit properly to accommodate all well 

31 appurtenances. If the well is not housed, the well cap should be locked and lightning protection 

32 should be provided. 

33 

34 One type of well seal used with submersible turbine pumps is a sanitary well seal with an 

35 expandable gasket to allow the pump drop pipe, wires and vent to pass through it. This type of 

36 seal, shown in Exhibit 4.2, is typically used in wells housed in a well house. Bolts tighten two 

37 plates together, expanding the gasket material located between the plates. It seals the openings 

38 around the casing, pump drop pipe, the inverted U-type screen vent, and the electrical conduit. 

39 

40 
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1 Exhibit 4.2 Illustrations of a Split Cap and Seal 

2 

3 4 

5 

6 The other type of seal is an overlapping exterior sanitary well seal, illustrated in Exhibit 

7 4.3. It is commonly used in outdoor applications with submersible pumps and pitless adapter 

8 units. The vent is under the lip, and gasket material seals all openings around the casing and 

9 conduit. 

10 

11 

12 Exhibit 4.3 An Overlapping Exterior Sanitary Well Seal 

13 

14 

15 

16 

17 Wells with a lineshaft turbine pump mounted on top of the casing should have a metal 

18 support plate on which a rubber gasket is mounted to provide a sanitary seal. The motor, along 

19 with an attached column and discharge head, is mounted on top of the gasket and support plate. 

20 During the sanitary survey, this kind of well should be checked to ensure there is a rubber gasket 

21 providing a sanitary seal and that the gasket is in good condition. 

22 

23 
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Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 Exhibit 4.4 Top of Casing Illustration for a Well with a Lineshaft Turbine Pump 

2 (left) and a Well with a Submersible Turbine Pump and a Split Cap 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 Well casings should be vented to the atmosphere. For wells with submersible pumps, the 

14 vent should terminate in a downward “U” position, and should be located at or above the top of 

15 the casing. The vent’s opening should be screened with a 24 mesh corrosion resistant screen. 

16 Wells with turbine pumps mounted on top of the casing frequently are vented to the side of the 

17 casing. These vents should be located high enough to prevent water from entering them and 

18 should also be properly screened. 

19 

20 The discharge from the well should have a sample tap with a smooth nozzle to allow for 

21 sampling before the addition of any chemicals or disinfectants and before any treatment step. A 

22 sample of the raw water will allow the water system to test for contaminants that might be 

23 present or any changes in source water quality. 

24 

DISCHARGE LINE

PIPE PLUG

WELL VENT

WIRE MESH

SANITARY SEAL

POWER CABLE 

T

O 

S

DROP PIPE FROM 

SUBM

ERSI

DISCHARGE 

H

E

COLUMN

SANITARY 

WELL 

HOLLOW 

SHAFT 

MOTOR

SUPPORT 
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1 The following are suggested assessment criteria for the surface features of a well: 

2 

3 Is the well properly sealed at the surface? Does the casing extend at least 18 

4 inches above the well slab, floor, or ground surface? Does the well vent 

5 terminate above the maximum flood level with a turned down gooseneck and 

6 corrosion resistant bug screen? 

7 

8 Surface runoff can migrate down the annular space along the outside of the well casing 

9 and contaminate the aquifer. Therefore, all sources of leakage should be plugged to prevent 

10 contamination. The most visible point of leakage is the encasement at the surface. The 

11 construction of the well above the surface should prevent leakage down the outside of the well 

12 casing as well as through the casing cap that is located on top of the casing. By extending the 

13 casing at least 18 inches above the well slab, surface runoff should not be able to enter the 

14 casing. The well casing cap has to be a watertight sanitary seal to prevent water from entering 

15 through it. In addition, the casing vent through the cap should extend above flood level to 

16 preclude surface runoff from entering the well directly and the end of the vent should be 

17 terminated with a downward turned gooseneck and screen to prevent rain and bugs from 

18 entering. 

19 

20 What is the general condition of the piping and valving, the site, and the 

21 electrical system? Do they appear to be well maintained? Does the electrical 

22 system have lightning protection? Can the pump be maintained easily and 

23 the water for the system continually supplied? 

24 

25 As the source for the water system, the well should be in good operational condition to 

26 ensure that a dependable supply of high quality source water will be available at all times. Good 

27 operational condition means that the piping is not leaking or corroded, the valves and controls 

28 are operable, and the electrical system is protected from the elements and is not corroded. The 

29 well site should be graded to prevent ponding of surface water and to direct drainage away from 

30 the wellhead, and the housing and fencing should be properly maintained. Valves and meters 

31 should be fully functional and well maintained to keep out contamination. Personnel should 

32 have sufficient access to these valves for cleaning. The electrical system should be protected 

33 from lightning since the sudden electrical surge caused by lightning striking the wellhead or 

34 nearby may cause the electrical components to burn out. If the electrical components of the well 

35 are not functional, then the well will not operate. The inspector should check for lightning 

36 protection and backup power supplies (see section 4.7 for more information on emergency 

37 power). Ground fault protection is important to protect the operator. 

38 

39 

40 4.2.1.2 Subsurface Features 

41 

42 Because the casing is often the only well feature above ground, it is frequently impossible 

43 to visually inspect much of a ground water supply well and verify that the proper design and 

44 construction methods were followed. The original well construction records (e.g., driller’s log, 

45 material settling data) and records of after-construction modifications to the well, if available, 

46 should be reviewed to verify that the well was properly constructed. The results of inspections 

47 and repair work performed by qualified technicians may provide additional information about the 

48 construction of the well. The inspector should verify that design and construction methods meet 

49 applicable State requirements for wells. 
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1 

2 The following are suggested assessment criteria for the subsurface features of a well: 

3 

4 What is the depth of the well? 

5 

6 The greater the depth of the aquifer used, the less chance there is that surface 

7 contamination will degrade water quality. Deeper aquifers generally have a more consistent 

8 quality of water (EPA, 2003). 

9 

10 How long is the well casing? 

11 

12 Well casing is an important part of proper well construction. The encasement of a well 

13 acts as a barrier to surface water and contamination from other aquifers. It also prevents the bore 

14 hole from collapsing. The well casing houses the submersible pump and its discharge pipe, and 

15 provides a column of water that allows for positive pump suction head. The encasement should 

16 be constructed of either steel or plastic, depending on the depth of the well and local regulations, 

17 and should adhere to the State’s well standards. The encasement should extend up a minimum of 

18 18 inches above the natural ground level or finished floor elevation or two to three feet above the 

19 maximum flood elevation. The encasement should pass through all undesirable water bearing 

20 strata and extend down at least to the depth of the shallowest water bearing strata to be 

21 developed. 

22 

23 Is the annular space around the well casing filled with grout or bentonite 

24 clay? 

25 

26 The annular space around the casing should be filled with a material, such as bentonite or 

27 grout, that will prevent the leakage of water from the surface and intervening water-bearing 

28 layers down the outside of the casing into the aquifer. During the sanitary survey, the inspector 

29 should review the driller’s log, if available, to ensure that the well is grouted to a depth that 

30 prevents any contaminated water from overlying aquifers or the well’s surface from entering the 

31 well water that is being pumped and used. EPA recommends that wells be grouted a minimum 

32 20 foot depth below the surface (USEPA, 2003).

33 

34 What is the screen constructed of? What is the depth of the screen? 

35 

36 The water-bearing aquifer will typically consist of sand and gravel, but could be rock 

37 (e.g., fractured bedrock). A screen allows the maximum amount of water to flow into the well 

38 while preventing abrasive sand and gravel from reaching the pump. The screen should be 

39 constructed of a material that is strong and will not degrade over time due to exposure to water 

40 and surrounding environmental conditions. The material generally chosen for the screen is 

41 stainless steel. Some wells do not have screens because they are unnecessary for certain aquifer 

42 materials (e.g. rock instead of sand/gravel). 

43 

44 Is drawdown measured? Is the pump set below maximum drawdown? 

45 

46 Drawdown is the difference between static water levels and pumping water levels. 

47 Measuring drawdown is important because changes in static water level or drawdown can 

48 indicate problems in the aquifer (declining water levels) or pump. Such changes also can 

49 indicate well encrustation. The operator should regularly measure drawdown and record the 
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1 results. Locating the pump intake below maximum drawdown prevents the pump from running 

2 dry and protects against possible pumping of contamination from upper portions of the water 

3 table. 

4 

5 

6 4.2.1.3 Driller’s Logs 

7 

8 The PWS should have a copy of the well driller’s report that shows the following: 

9 

10 • A casing that penetrates a confining stratum of clay, shale, or otherwise impervious 

11 material; 

12 

13 • The annulus between the drilled hole and the casing is sealed using bentonite clay, 

14 cement slurry, sand-cement grout or other acceptable material; and this seal extends 

15 from the surface down and into the confining strata mentioned above; 

16 

17 • The well is grouted for a minimum depth of 20 feet; 

18 

19 • The well is drilled to a depth greater than 50 feet, or is a driven well; 

20 

21 • The well is located at a distance greater than 200 feet from any surface water; and 

22 

23 • The well has been pump tested in accordance with a reviewed and approved 

24 yield/drawdown test and results clearly determine the porosity and transmissivity of 

25 the aquifer materials. 

26 

27 

28 4.2.1.4 Typical Defects 

29 

30 A well provides a direct conduit from the ground surface to the aquifer. If the well is not 

31 constructed properly, surface runoff and shallower aquifers can contaminate the aquifer tapped 

32 into by the well. 

33 

34 The following paragraphs describe typical well defects. 

35 

36 Casing Too Low 

37 

38 Well casing should extend at least eighteen inches above the floor of the well house or 

39 three feet above the maximum flood level and their vents should be facing downward and 

40 screened (USEPA, 2003). Wells in areas prone to flooding can flood and allow surface water to 

41 wash contaminants into the well. Surface grading, which directs surface runoff toward the well, 

42 can also cause contamination. If the casing is not elevated above the floor and turned downward, 

43 surface water and atmospheric debris can fall into the well and contaminate it. If the well is 

44 housed, the well house should be properly drained so that water does not pool around or near the 

45 well. 

46 
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1 Improper Well Cap 

2 

3 Gaps or holes in the well cap can allow contaminants to enter the well. The well cap 

4 should be welded on or have a threaded cap and should be free of any holes caused by corrosion 

5 (Recommended Standards for Water Works, 2003). EPA recommends that wells be housed and 

6 the well housing be locked and secure. Well caps of wells that are not housed should be locked. 

7 

8 No Sanitary Seal 

9 

10 If a well is not sealed properly, contaminants can enter into the well, either from the 

11 surface or from non-potable aquifers. The top of the casing or pipe sleeve should have a well 

12 cover with a sanitary seal on it. A more detailed description of sanitary seals is provided in 

13 section 4.3.1.1. 

14 

15 Well Not Grouted Properly 

16 

17 The annular casing should be grouted in any area where contaminants might enter the 

18 well, including a minimum 20 foot depth below the surface and through any aquifers that may 

19 contain contaminated water (USEPA, 2003). 

20 

21 Well not properly ventilated 

22 

23 Proper engineering practices require that a well be vented to the atmosphere (Ten States 

24 Standards, 2003) to allow equalization of pressure with the atmosphere and to prevent 

25 accumulation of hazardous gases such as hydrogen sulfide or methane. If such gases are present, 

26 the vent should terminate outside of any well house or confined space. The well vent should be 

27 faced downward and covered with a corrosion resistant mesh to prevent entry of contaminants or 

28 vermin. 

29 

30 Well in pit 

31 

32 Wells should not be placed in pits because pits are prone to flooding that can allow 

33 contaminants to enter the well. Pits are also usually confined spaces; water system operators 

34 entering a pit to tend to their well should be provided with appropriate confined space training. 

35 Preferably, pits should be filled in, a pitless adapter should be installed, and the well casing 

36 should be extended so it rises at least eighteen inches above the ground once the pit has been 

37 filled. 

38 

39 

40 4.2.2 Potential Sources of Contamination 

41 

42 During the field survey, the inspector should verify that the inventory of potential sources 

43 of contamination has not changed and that the susceptibility determinations for the source do not 

44 need revision. New potential sources of contamination and changes in a well’s susceptibility may 

45 require modifications to the water quality monitoring requirements for the source. Appendix B 

46 provides guidance on how to review and revise source water assessments during the sanitary 

47 survey. 

48 

49 
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1 4.2.2.1 Wellhead Protection Program (WHPP) 

2 

3 A WHPP is designed to protect the quality of a water system’s ground water source 

4 by minimizing the impact of activities in the source recharge area as well as the portion of the 

5 aquifer that supplies the system. The main components of a WHPP are delineating the wellhead 

6 protection area, identifying and locating all potential sources of contamination that could impact 

7 the well, and developing and implementing a strategy to manage the wellhead protection area 

8 and protect the ground water source from contamination. 

9 

10 Suggested assessment criteria for wellhead protection include: 

11 

12 Is the aquifer recharge area protected? 

13 

14 Has the water system developed a WHPP that protects the well’s recharge area? The 

15 inspector should learn whether a wellhead recharge area protection plan is in place and being 

16 actively implemented. 

17 

18 What is the size of the protected area and who controls it? 

19 

20 To what extent does the owner of the water system have ownership or control of the land 

21 around the well(s)? Many systems own the land outright and control activity in that way. Other 

22 communities have adopted ordinances or are zoned so that the wellhead area is protected. 

23 During the field survey, the sanitary survey inspector should evaluate how effectively an 

24 established WHPP seems to be preventing contamination of the water supply. 

25 

26 

27 4.2.2.2 Source Vulnerability Assessment 

28 

29 A vulnerability assessment is used to determine the potential for contaminant sources in a 

30 specified area around the well to degrade the public water system's source water quality. The 

31 1996 Amendments to the SDWA require that States determine susceptibility of all their public 

32 water systems to contamination. A susceptibility determination includes consideration of several 

33 factors, including hydrogeologic sensitivity, contaminant source characteristics (e.g., persistence 

34 and mobility of contaminants), contaminant source management and well integrity. A completed 

35 SWAPP susceptibility determination may suffice as the source vulnerability assessment for a 

36 sanitary survey, and can be considered along with vulnerability assessments performed under 

37 monitoring waiver programs, pesticide management plans, or other programs. 

38 

39 Suggested assessment criteria for assessment of source vulnerability include: 

40 

41 Has the hydrogeologic sensitivity of the well been adequately assessed? 

42 

43 The inspector should evaluate what effort has been made to define the water system’s 

44 wellhead area and identify actual or potential sources of contamination within the defined area. 

45 If the well is located in a hydrogeologically sensitive setting, the inspector should evaluate 

46 whether additional source water monitoring may be appropriate. If potential sources of 

47 contamination are identified near the well, the inspector should determine if and how they are 

48 being managed to minimize their potential for contaminating the well, and whether the system’s 

49 source water protection program is protective enough. 
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1 

2 Does the system monitor raw water quality? Does monitoring of raw water quality 

3 indicate an immediate, significant sanitary deficiency? 

4 

5 If a well’s untreated water has tested positive for an indicator of fecal contamination or 

6 for a harmful chemical, the well should not be considered a reliable source. An alternative 

7 source should be actively pursued and developed. 

8 

9 Is the system using the highest quality source available? 

10 

11 A water system should be using the highest quality source water it has available based on 

12 what it knows about its source water quality and the well’s potential for contamination. 

13 

14 

15 4.2.2.3 Abandoned Wells 

16 

17 Wells that are not properly abandoned can create a pathway that allows contamination to 

18 enter an otherwise protected aquifer. Inspectors should ensure that any abandoned test wells and 

19 ground water sources have been properly disconnected and filled. 

20 

21 Suggested assessment criteria for well abandonment include: 

22 

23 Is the system confident that all abandoned wells have been identified? Have they 

24 been properly abandoned? 

25 

26 An abandoned well should be sealed in a manner that restores geological conditions that 

27 existed before the well was installed (Recommended Standards for Water Works, 2003). The 

28 well should be filled, preferably with cement grout or concrete, and sealed to prevent any water 

29 from passing into the aquifer. 

30 

31 

32 4.2.3 Source Quantity and Capacity 

33 

34 One of the most important requirements for any water system is the ability to meet the 

35 water quantity demands of customers at all times. Similarly, when demands exceed the treatment 

36 capacity of the supply, transmission lines, pumps, distribution system piping, or storage 

37 facilities, inadequate flow or pressure in the system can result. Inadequate flow or pressure 

38 affects customers, hinders fire fighting capabilities, and creates opportunities for other liquids to 

39 enter the system through cross-connections and a reduction in positive pressure. 

40 

41 Each State has a guide for estimating the average daily water use per person for various 

42 types of business and residential uses. The values may vary nationally and seasonally due to 

43 frequent lawn watering, swimming pools, industrial and commercial process water, cooling 

44 water and fire fighting. However, if no specific water consumption figures are available, water 

45 consumption estimates can often be found in water supply engineering books such as Water 

46 Treatment Principles and Design (Montgomery, 1985) or the Civil Engineering Reference 

47 Manual (Lindeburg 1997). These books have national averages for per capita demand and also 

48 supply typical factors for peak daily or hourly demands. 

49 
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1 In many places, particularly in arid and heavily populated areas, water conservation is 

2 necessary. Water systems should have a water conservation plan that includes short- and long3 term goals, education plans, water rationing procedures in case of drought, and water 

4 conservation information available to the public. An aggressive water conservation plan can be a 

5 cost-effective alternative to the expansion of water production facilities. 

6 

7 One of the initial steps of the onsite visit should be determining the required capacity of 

8 the treatment facilities. The required capacity should be at least equal to the maximum daily 

9 demand of the water system over the previous several years or as determined by the rules and 

10 regulations of the State primacy agency. EPA recommends that the developed ground water 

11 capacity should equal or exceed the design maximum daily demand when the highest producing 

12 well is out of service. Reviewing the operating records of the plant should provide the maximum 

13 daily demand. Generally, the maximum daily demand occurs during the summer time. 

14 However, there have been situations where the maximum daily demand occurred during hard 

15 freezes in the winter when customers left faucets running to prevent their water pipes from 

16 freezing. Operating records for the last few years should be checked to determine the historic 

17 maximum daily demand. 

18 

For example, using Water Treatment: Principles and Design, 2nd 19 Edition (MWH, 2005): 

20 

21 Average per capita demand = 150 gpcd 

22 Maximum hourly demand = 4.5 times average demand 

23 Design Demand = system population x (150gpcd)x(4.5) = system population x (675 

24 gpcd) 

25 

26 Suggested assessment criteria for evaluating the adequacy of the source water supply are: 

27 

28 If permits are required, is the facility operating within the limits? Are 

29 permits available? 

30 

31 Some States require systems to have operating permits. During the sanitary survey, the 

32 inspector should verify that the amount of water being pumped does not exceed the amount of 

33 water the system is permitted to withdraw. 

34 

35 Does the system have an operational master meter(s)? 

36 

37 Without an operational and calibrated master meter, it is difficult for the water system to 

38 accurately monitor production. With a master meter in place, the system can monitor overall 

39 production and water usage in the system to determine if supply is adequately meeting customer 

40 demand. Data from a master meter, combined with information from service connection meters, 

41 can be used to identify and track trends in water supply, water usage, and unaccounted for water 

42 that may be lost due to distribution system leaks. 

43 

44 How many service connections are there? 

45 

46 The total number of homes and businesses served by the PWS provides the inspector with 

47 an idea of the size of the system. 

48 
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1 Are service connections metered? 

2 

3 The system should have meters in place to monitor overall production and water usage in 

4 the system to determine if supply is adequately meeting customer demand. Data from meters can 

5 be used to identify and track trends in both water supply and usage so that any potential future 

6 shortages can be noticed earlier and additional supplies obtained. 

7 

8 Does the system have interconnections with neighboring systems or a 

9 contingency plan for water outages? 

10 

11 The system should plan for water outages so that water can be restored quickly. 

12 Interconnections should only be made with approved sources. 

13 

14 Does the system have redundant sources? 

15 

16 Emergency supplies should be made available during outages. Many States require 

17 community water systems with ground water supplies to have at least two sources in case one is 

18 lost. 

19 

20 What is the water quantity required to meet the needs of the water system? 

21 

22 The water system should be able to supply an adequate quantity of potable water to meet 

23 the highest anticipated demand of the customers. If not, then areas of the distribution system 

24 may experience little or no pressure due to the lack of water. With the loss of pressure, the 

25 contamination potential of the system is heightened significantly. Knowing the maximum water 

26 demand of the system and the quantity available from the source, a quick determination can be 

27 made of the system’s ability to meet the present and future needs of its customers. In addition, 

28 the water system should plan for the growth of its service area and look ahead to obtaining an 

29 adequate quantity of water to meet any additional future needs. If operating records show 

30 decreasing water quantity over time, the system should be investigating additional supply. 

31 

32 Is the source adequate to meet the current and future expected needs of the water 

33 system, even during times of drought? If not, what other sources are being 

34 investigated to meet the needs? Has the water system developed and implemented a 

35 water conservation plan? 

36 

37 The inspector can verify that an adequate supply is available by checking to see if the 

38 source has ever gone dry or if water has ever had to be rationed because of a shortage of source 

39 water. A water system may have developed a water conservation plan as part of its overall water 

40 system master plan and may already be implementing the water conservation plan regardless of 

41 the adequacy of source water quantity. Implementation of a good water conservation plan can be 

42 a cost-effective alternative to the expansion of water production facilities as a result of increased 

43 demand. If the source water supply appears to be inadequate, the water system should be in the 

44 process of implementing further water conservation measures and/or obtaining an additional 

45 supply. 

46 

47 
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1 4.2.4 Confirm Well Locations 

2 

3 It is important that the well(s) for a PWS be located as accurately as possible. The 

4 well(s) may have been located previously and the inspector need only verify that the location(s) 

5 is correct. The inspector may find that a new well has been constructed since the last inspection, 

6 either authorized or unauthorized, and a previous one has been abandoned and/or plugged. The 

7 inspector should make note of this new condition and advise the system if they should report the 

8 new well to the State. A United States Geological Survey (USGS) 7.5-minute topographic 

9 quadrangle or similar map can be used to plot the location of the water sources. A GPS can be 

10 used to determine the precise location of a well. 

11 

12 The following assessment criteria are suggested for the location of source water facilities: 

13 

14 What is the flood level in the area of the source facility? Can the source 

15 facility be flooded? 

16 

17 The source water supply facilities should be able to operate at all times to produce safe, 

18 potable water to meet the customers’ needs, regardless of the surrounding conditions, either man19 made or natural. The source facility should be able to supply water to maintain an adequate 

20 pressure in the distribution system that, for safety purposes, would provide water for fire 

21 fighting, pressure to keep contaminants out, and meet the basic consumer necessities. If the 

22 source facility is flooded, the ability to supply water to satisfy these demands may be 

23 compromised. Therefore, the flood level and floor elevations should be checked to determine 

24 whether or not the facility can be flooded. 

25 

26 Has the source facility ever been flooded? If so, was the operation of the 

27 source facility impaired? If the source facility has been flooded and 

28 operation not impaired, what is the access to the source facility during a 

29 flood? 

30 

31 Depending on the design of the facility, portions of the plant could have been flooded, yet 

32 it was still able to produce potable water. In this situation, access to the source facility needs to 

33 be maintained to allow for the ingress/egress of personnel and equipment as needed. 

34 

35 

36 4.2.5 Source Water Transmission 

37 

38 Untreated water travels from the source to the treatment plant through a transmission 

39 system of pipes. Some source water facilities are at a considerable distance from treatment 

40 facilities. The transmission lines present a potential opportunity for liquids and materials to both 

41 enter and leave the system. If the raw water is used before it receives treatment, it presents a 

42 sanitary risk and may be unsafe. If the transmission lines are not in good condition, they may 

43 allow contaminants to enter the raw water supply or may cause the supply to be interrupted. 

44 Transmission lines need to be assessed for sanitary risks during the sanitary survey. The 

45 inspector should travel along the raw water transmission lines and speak with the operators to 

46 verify information already obtained from maps and other records about the location of 

47 transmission lines, air release valves, pressure release valves, drain valves, and other pertinent 

48 information. 

49 
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1 Suggested assessment criteria for the raw water transmission lines include: 

2 

3 Do the transmission lines deliver all the raw water directly to the treatment plant? 

4 

5 The transmission lines should not contain connections directly to any customers or to the 

6 distribution system. The inspector should check for any connections that may deliver untreated 

7 water to customers. If there are any connections to customers directly from the transmission 

8 lines, the inspector should check if adequate treatment is being provided. If not, the inspector 

9 should inform the system that the connections present a sanitary risk and should be removed. 

10 

11 Are transmission lines in place that can bypass a treatment plant? 

12 

13 If treatment is required, all raw water should be delivered to the treatment plant and 

14 should not be able to bypass the plant. The transmission pipes should not contain any valves that 

15 could be opened and permit bypassing. Closed valves are generally not considered sufficient to 

16 prevent raw water from bypassing treatment. A physical disconnection of the pipe is more 

17 appropriate. 

18 

19 What are the age and condition of the transmission lines? 

20 

21 If the system relies on a single transmission line, a failure of this line could leave the 

22 system and consumers without water. The inspector should evaluate the potential for failure of 

23 the transmission pipes. If they seem to be in poor condition due to age, deterioration, or natural 

24 events (e.g., weather conditions, earthquakes), the inspector should assess the potential for 

25 failure and subsequent interruptions to the water supply. 

26 

27 Are the transmission facilities redundant? 

28 

29 The inspector should evaluate whether the disruption of a single transmission line would 

30 leave the system without water, and the potential for such a disruption. Under such 

31 circumstances, the inspector should recommend additional transmission lines or an emergency 

32 connection to another water supply. 

33 

34 

35 4.2.6 Site Security 

36 

37 There are numerous ways the water supply for a system can be contaminated or 

38 interrupted. A well’s components can be tampered with or destroyed. A well pump can be 

39 damaged or stolen. Contaminants can be intentionally or unintentionally introduced down the 

40 well casing. Wellheads located near a parking lot or street can be damaged by traffic accidents. 

41 During a sanitary survey, the inspector should review what security is in place to protect each of 

42 the components of the water system. Where appropriate, the inspector should confirm that a 

43 vulnerability assessment of the system has been completed and an emergency response plan has 

44 been developed and is regularly exercised. 

45 
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1 Suggested assessment criteria for evaluating security of the ground water source and its 

2 facility include: 

3 

4 Is the wellhead protected from vandalism and accidents? 

5 

6 The location of the wellhead will dictate the measures required to protect it from 

7 vandalism or physical damage. For instance, a security fence and structurally sound buildings 

8 with locked doors and entry alarms would protect the wellhead from intentional vandalism. 

9 Bollards around the well may be appropriate to protect it from traffic accidents. 

10 

11 Is the area around the wellhead restricted in accordance with primacy agency rules? 

12 

13 Typically, the wellhead is unmanned and may be visited once a shift or once per day. 

14 Therefore, there may be no continuous means to observe all the activities around the wellhead. 

15 Restricting access to the area with fencing and signs will limit the possibility of sabotage or 

16 accidental contamination. 

17 

18 Are transmission lines vulnerable to disasters or terrorism? 

19 

20 Inspectors should evaluate whether transmission lines are exposed to potential destruction 

21 due to terrorism or natural disasters. In those situations where tampering or destruction seem 

22 more possible, the inspector should find out if the system has a plan for responding to such an 

23 interruption of water. 

24 

25 

26 4.2.7 General Housekeeping 

27 

28 The physical condition of the source facility can be a good indicator to the inspector of 

29 how often the facility is visited and how well it is maintained. All critical facilities should be 

30 visited by the operator frequently to determine that all equipment is operating correctly. If the 

31 equipment appears to be in good condition, then the system places value on preventive 

32 maintenance. However, if the equipment does not appear to be in good condition then the 

33 system may not consider preventive maintenance a high priority. The system may have little 

34 money available or allocated for maintenance or inadequate staffing levels to perform 

35 maintenance. 

36 

37 Suggested assessment criteria for evaluating the housekeeping of the source and its 

38 facility include: 

39 

40 How often is the facility visited? 

41 

42 Source facilities should be checked by system personnel frequently based on an 

43 established schedule. The schedule should take into consideration the location and vulnerability 

44 of the source, treatment provided at the source and historical problems with equipment or 

45 vandalism. 

46 
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1 Does the facility appear to be well maintained – grass mowed, equipment 

2 painted, facilities kept clean, etc.? 

3 

4 The appearance of the facility does not directly impact the quality of the water, but it 

5 does provide an indication of the overall amount of maintenance that the facility probably 

6 receives. 

7 

8 

9 4.2.8 Cross Connections 

10 

11 If the well has a blow-off or pump to waste piping the outlet should not be directly 

12 connected to storm or sanitary sewers. The outlets of blow-offs and pump to waste piping should 

13 be protected from flooding and backsiphonage. 

14 

15 

16 4.3 Treatment 

17 

18 The types of treatment processes and facilities used to achieve safe drinking water are 

19 dictated primarily by the quality of the source water and the regulatory requirements that must be 

20 met. Typical ground water treatment processes often contrast sharply with treatment for surface 

21 water sources, because surface water sources are more generally more vulnerable to 

22 contamination by harmful microorganisms such as Giardia and Cryptosporidium. Therefore, 

23 systems that use surface water sources or sources that are ground water under the direct influence 

24 (GWUDI) of surface water usually require treatment methods that will physically remove 

25 pathogens. Examples of these treatment methods include coagulation/flocculation, 

26 sedimentation/clarification, and filtration processes. Additionally, disinfection is required to 

27 inactivate any pathogens that are not physically removed. 

28 

29 Different than surface water or GWUDI of surface water, ground water systems often 

30 have natural filtration through the aquifer material and contain little or no turbidity; therefore, the 

31 physical removal steps noted above may not be necessary. On the other hand, ground water 

32 systems may require treatment to comply with other regulatory requirements (e.g., lead and 

33 copper, nitrate/nitrite, SOCs/VOCs (synthetic organic contaminants/volatile organic 

34 contaminants), radiological contamination, etc.) or other aesthetic water quality contaminants 

35 (e.g., iron, manganese, color, and/or taste and odor). 

36 

37 The sanitary survey inspector should evaluate all water treatment processes in use at the 

38 water system. This evaluation should consider the design, operation, maintenance, and 

39 management of the water treatment plant to identify existing or potential sanitary risks. Water 

40 treatment facilities are the primary means of preventing unacceptable drinking water quality 

41 from being delivered for public consumption. The treatment facilities and processes should be 

42 capable of removing, sequestering, or inactivating physical, chemical, and biological impurities 

43 in the source water and meeting MCL or treatment technique requirements. 

44 

45 For ground water systems, the regulatory requirements of the GWR and Stage 2 D/DBP 

46 Rule place additional demands on the treatment facilities. While some ground water systems 

47 will be installing disinfection as a corrective action to comply with the GWR, those and other 

48 systems will be required to meet the Stage 2 D/DBP Rule’s Initial Distributiin Evaluation and 
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Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 locational TTHM and HAA5 MCL requirements. Ground water systems with disinfection 

2 already in place that are having difficulty complying with the Stage 2 D/DBP Rule should 

3 evaluate current treatment prior to making adjustments to their disinfection practices that could 

4 reduce the level of microbial treatment provided (See the Stage 2 DBP Rule Operational 

5 Evaluation Guidance Manual and the Simultaneous Compliance Guidance Manual for the Long 

6 Term 2 and Stage 2 DBP Rules). The treatment facilities and processes should be evaluated to 

7 determine their ability to meet these regulatory requirements and to provide an adequate supply 

8 of safe drinking water at all times, including periods of high water demand. A sanitary survey of 

9 a treatment facility should 

10 

11 • Analyze all the distinct parts of the treatment process, including but not limited to 

12 disinfection, chemical feed systems, hydraulics, controls, and residuals/wastewater 

13 management. 

14 

15 • Identify features of the water treatment process that may pose a sanitary risk, such as 

16 inadequate treatment, monitoring, or maintenance, lack of reliability, and cross 

17 connections. 

18 

19 The inspector will need to review and consider specific regulations that apply to the 

20 facility, design criteria, plant records, and past inspection reports that may identify previous 

21 compliance problems, in addition to performing the actual inspection of the facility. The 

22 following sections discuss specific portions of common treatment facilities that may be evaluated 

23 during a sanitary survey inspection. 

24 

25 

26 4.3.1 Treatment Plant Schematic/Site Plan 

27 

28 A schematic or site plan indicating the location of the treatment plant, type(s) of 

29 treatment provided, and chemical injection points will enable the inspector to obtain a quick 

30 understanding of the treatment type(s). If possible, the inspector should review any schematics or 

31 site plans prior to the sanitary survey. The schematic/site plan should be drawn in enough detail 

32 to facilitate the inspector’s understanding of the treatment facilities. 

33 

34 Each treatment facility should be assigned a name and identification number. 

35 Additionally, the schematic/site plan drawings should be dated to assist future inspectors in 

36 identifying changes in the water system. The schematic/site plan drawings should be updated 

37 during each subsequent sanitary survey to reflect any changes in the system. 

38 

39 
November 2007 Sanitary Survey 4-21 Draft for Discussion

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1 Exhibit 4.5 Example Schematic Diagram of a Ground Water Treatment Plant 

2 

3 

4 

5 

6 4.3.2 Capacity of Treatment Facilities 

7 

8 One of the initial steps for the inspector will be to determine the required capacity of the 

9 existing treatment facilities. The State primacy agency may have design standards that specify 

10 the capacity requirements for source water supplies and individual treatment units. The existing 

11 treatment facilities should be evaluated to determine if the capacity requirements are met. 

12 

13 The following are suggested assessment criteria to determine the adequacy of the 

14 treatment facility capacity: 

15 

16 What is the design capacity of the treatment units? What is the maximum daily 

17 demand of the system? Given the number of service connections and/or the 

18 population served by the system, is the capacity of the treatment facilities 

19 reasonable? 

20 

21 The design capacity for the treatment units can often be found in the operating records for 

22 the facility. Design and construction documents can also be used to determine capacity. If these 

23 records and documents are unavailable, the inspector will need to discuss with the system’s 

24 operator the purpose of the treatment; the maximum capacity of the treatment units in relation to 

25 the system’s peak demands; and whether adequate treatment is being provided. Based on this 

26 information, the inspector can draw conclusions on whether the treatment facilities can provide 

27 adequate treatment during peak demand periods, or whether expansion plans or upgrades should 

28 be considered. 

29 
November 2007 Sanitary Survey 4-22 Draft for Discussion

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1 If the primacy agency has specific treatment unit capacity requirements, does the 

2 system meet these requirements? 

3 

4 Many primacy agencies have design standards and/or minimum requirements for the 

5 capacities of major treatment units. The inspector will need to compare the system’s existing 

6 treatment capacity with those required by the primacy agency. 

7 

8 Are the treatment facilities capable of meeting the required capacity with the largest 

9 unit out of service? 

10 

11 Treatment facilities will require maintenance, repair, and replacement from time-to-time; 

12 therefore, redundancy should be provided that will allow the system to provide adequately 

13 treated water during these periods. To ensure adequate capacity is available at all times, the 

14 capacity of a major treatment process should be determined with the largest treatment unit out of 

15 service. 

16 

17 

18 4.3.3 Chemicals and Chemical Feed Systems 

19 

20 Chemical feed systems are common to many ground water treatment plants. These 

21 systems can be used to feed treatment chemicals such as disinfectants, oxidizers, corrosion 

22 inhibitors, pH adjustment chemicals, chemicals for sequestration, fluoridation, etc. The types of 

23 chemicals that are used depend on the specific treatment facilities and the objectives of the 

24 treatment processes. Types of chemical feed systems include liquid feed pumps and dry 

25 chemical feed. 

26 

27 

28 4.3.3.1 Liquid Chemical Feed Systems 

29 

30 A typical liquid chemical feed system would include: 

31 

32 • Storage tank to hold the chemical solution; 

33 

34 • A metering chemical feed pump with a suction line extended into the storage tank; 

35 

36 • A discharge line with check valve and an injection valve at the point of application; 

37 and 

38 

39 • A flow-switch to control the metering pump operation. If the flow switch is 

40 automatic, it must be tied to a flow meter or another control sensor. 

41 

42 A typical liquid chemical feed system is shown in Exhibit 4.6. 

43 

44 
November 2007 Sanitary Survey 4-23 Draft for Discussion

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1 Exhibit 4.6 Schematic of a Typical Liquid Chemical Feed System 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 4.3.3.2 Dry Chemical Feeders (Volumetric and Gravimetric) 

36 

37 A typical dry chemical feed system would include: 

38 

39 • A volumetric or gravimetric feeder to meter the dry chemical; 

40 

41 • A mixing tank or solution chamber with a mixer; and 

42 

43 • A gravity discharge line to the point of application. 

44 
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1 The following are suggested assessment criteria for chemical feed systems: 

2 

3 What chemicals are in use? Are the chemicals in use approved for use in drinking 

4 water? 

5 

6 The surveyor should inspect chemical containers and discuss with the operator what type 

7 of chemicals are used and their purpose. The inspector should check that the chemicals in use 

8 carry the NSF or Underwriters Laboratories (UL) markings to ensure the chemicals used 

9 conform to all applicable requirements of NSF Standard 60: Drinking Water Chemicals—Health 

10 Effects. Treatment plant operators may be using compounds are chemicals that are not approved 

11 for drinking water (e.g., household bleach in place of NSF approved sodium hypochlorite). 

12 

13 Are the chemicals in use appropriate for the water system? 

14 

15 The inspector should discuss with the operator and assess whether the chemicals used in 

16 treating the water are appropriate. Water systems may purchase and use chemicals that are not 

17 appropriate for their existing plant or treatment objectives (e.g., the operator may be convinced 

18 by a sales person the chemical product should be used at the plant, when this product may not be 

19 appropriate for the system’s water treatment objectives). 

20 

21 What are the chemical dosages—minimum, average, and maximum? Are the 

22 chemical feed facilities appropriately sized for the dosages in use? 

23 

24 The inspector should ascertain whether the treatment plant has the capacity to apply the 

25 appropriate amount of chemicals at peak demand periods. Often, having chemical feed systems 

26 sized to deliver one hundred and fifty percent of maximum is recommended as a rule-of-thumb. 

27 

28 Where is each chemical applied? 

29 

30 The inspector should examine chemical feed points and note where and how the 

31 chemicals are added, whether the feed points are active or for standby, whether the points of 

32 application are appropriate, and whether the feed points allow for chemical compatibility. Some 

33 chemicals may counteract each other if not properly applied (e.g., if the system was introducing 

34 an oxidant (chlorine) prior to the application of chemicals used for sequestration of iron and 

35 manganese. In this instance, the chlorine would oxidize the iron and manganese before the 

36 sequestering chemicals could work to keep the iron and manganese soluble in the finished 

37 water.) As noted earlier, these points of chemical application should be noted on the system site 

38 plan or schematic. 

39 

40 As a general rule, the inspector should know the application points and feed rates of all 

41 chemicals used in the system’s treatment plants. The purpose of the chemicals must be 

42 understood so that the appropriateness of the feed locations and rates can be evaluated. This may 

43 require the inspector to perform research on the chemicals the system uses either before or after 

44 the sanitary survey. 

45 
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1 What type of chemical feed equipment is used? What is the condition of the 

2 chemical feed equipment? Is chemical feeder redundancy provided? 

3 

4 The inspector should note the type of chemical feed equipment in use and its ability to 

5 feed chemicals on a continuous basis. The equipment must be functional and properly 

6 maintained. For example, with dry chemical feeders the inspector should watch for problems 

7 with “bridging” of the chemical in the hopper. Liquid feeder lines should be checked to see that 

8 they are not clogged. Redundant equipment should be provided and should be of sufficient 

9 capacity to replace the largest chemical feed unit. The inspector should determine if there is a 

10 preventative maintenance program in place and should examine repair records and the system’s 

11 supply of the spare parts and/or redundant equipment. 

12 

13 Is the chemical feed equipment calibrated, and how does the operator determine the 

14 amount of chemicals used? 

15 

16 Calibration should be completed each time a new batch of chemicals is used. The feed 

17 equipment feed rate should be checked at least daily. One method of checking is to use a 

18 graduated cylinder to verify the feed rate on a weekly or monthly basis (e.g. “pump catch”) 

19 

20 Is backflow prevention provided on the water lines used for chemical feed makeup? 

21 

22 All lines supplying water for chemical feed makeup should be equipped with backflow 

23 prevention devices or an air gap to prevent cross-connections and the potential contamination of 

24 potable water. 

25 

26 Is the chemical feed system flow paced? 

27 

28 Pacing the chemical feed pump with flow can be accomplished by a 4-20 mA signal from 

29 a flow recorder, or the system may be tied directly to a pump so that the feeder is activated each 

30 time the pump is operated and there is flow in the line. However, when the chemical feeder is 

31 tied to a pump, it is very important that some type of flow sensing device be used as a fail safe. 

32 The chemical feeder should not be allowed to come on until there is a flow in the pipe. Without 

33 flow control it is possible for a pump motor starter to engage and not start the pump. If the 

34 signal that engaged the starter also starts the chemical feed system, then highly concentrated 

35 chemicals can be fed into the line and received by a customer. 

36 

37 What type of chemical storage facilities are provided? Is the storage area for each 

38 chemical adequate and safe? Is secondary containment provided? Are 

39 incompatible chemicals stored together? 

40 

41 The chemical storage area capacity should be adequate to allow space for free access for 

42 loading and unloading of chemicals. A minimum 30-day supply for chemicals is recommended. 

43 The bulk storage facility should have indicators for chemicals storage levels. The storage 

44 containers should have a convenient method for determining the amount of chemical in each 

45 container. The storage facility should have safeguards against accidental spills, and like every 

46 other treatment space, should have a clean water source under high pressure and a drain for 

47 effective cleaning and decontamination. In the case of some gaseous chemicals, like chlorine, 

48 special ventilation equipment and the availability of Occupational Safety and Health 

49 Administration (OSHA) approved breathing apparatus may be required. Breathing equipment 
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1 and other personnel safety equipment and gear should be stored outside the storage area where 

2 the equipment can be safely accessed. Incompatible chemicals should be stored separately (e.g., 

3 gasoline for maintenance equipment, strong acids should not be stored near chlorites). The 

4 chemicals storage and the storage facility itself should be located so as to not allow a chemical 

5 spill to reach the raw water source, the treated water, or water being treated. In addition, every 

6 container in the storage area should be labeled and every storage area should be labeled to 

7 identify what chemicals supposed to be stored in it. 

8 

9 What is the condition of the building/room where the chemicals and chemical feed 

10 equipment are stored? Is adequate ventilation provided? 

11 

12 The inspector should check to ensure that the interior of the building housing the 

13 chemicals is kept clean and dry. The general condition of the building housing the chemicals is 

14 an indicator of the maintenance standards at the facility. Spills of chemicals can cause unsafe 

15 conditions and/or increase corrosion within the building. Adequate ventilation, heating, and air 

16 conditioning are important in maintaining the sanitary integrity of the building. Equipment used 

17 for controlling and removing dust and vapors should be functional and effective. 

18 

19 

20 4.3.4 Disinfection 

21 

22 The practice of water disinfection has proven to be one of the most important advances in 

23 reducing the incidence of waterborne disease. In this regard, disinfection is an important 

24 corrective action alternative for the GWR. Disinfection is the process of destroying or 

25 inactivating a large portion of the microorganisms in water, with the probability that all 

26 pathogenic bacteria or viruses are destroyed or inactivated in the process. 

27 

28 Chlorination is the most common disinfection method used by water systems in the 

29 United States, because of its proven effectiveness, low capital and operating costs, and its 

30 established history in the water industry. Free chlorine provides a high level disinfection at the 

31 point of application and a measureable residual in the distribution system 

32 

33 

34 4.3.4.1 Dosage and Residual 

35 

36 Dosage: The total amount of chlorine fed into a volume of water by the chlorinator is the 

37 dosage. This value is correctly calculated in milligrams per liter (mg/L); however, mg/L and 

38 parts per million (ppm) are generally interchangeable in water treatment calculations. 

39 

40 Demand: Chlorine is a very active chemical oxidizing agent and combines readily with 

41 certain inorganic substances that are able to oxidize (e.g., hydrogen sulfide, ferrous iron, 

42 manganese, and nitrite), organic impurities, and organic nitrogen compounds. These reactions 

43 use or consume some of the chlorine, and the amount that is used in called the chlorine demand. 

44 The reaction time between chlorine and most organic compounds is long (hours to days); 

45 therefore, the demand is based on time (i.e., the measurable demand at the end of 20 minutes is 

46 less than the measurable demand at the end of one hour of contact, due to the amount of time the 

47 chlorine has to react with the organic compounds). 

48 
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1 Residual: Residual is the amount of chlorine present in the water after a specified period 

2 of time and is measured in mg/L. 

3 

4 Chlorine demand (mg/L) = Chlorine Dose (mg/L) - Chlorine Residual (mg/L) 

5 

6 

7 4.3.4.2 Chlorine and Water 

8 

9 Regardless of the form of chlorination – chlorine gas or hypochlorite – the reaction in 

10 water is essentially the same. Chlorine mixed with water will produce two general compounds, 

HOCl (hypochlorous acid) and OCl- 11 (hypochlorite ion). The measurement of these compounds 

12 is called free chlorine residual. If organic or inorganic compounds, especially nitrogen 

13 compounds, are available, the HOCl will combine with these compounds to produce chloramines 

14 and/or chloro-organic compounds. The measurement of the presence of these compounds in 

15 water is called the combined chlorine residual. 

16 

17 Breakpoint Chlorination: As stated previously, chlorine will react with inorganic and 

18 organic compounds in natural waters. The chlorine will immediately react with (oxidize) iron, 

19 manganese, and nitrites. These chemicals are reducing agents (i.e., substances that are oxidized), 

20 and no residual can be formed until all of the reducing agents are oxidized. As more chlorine is 

21 added, the chlorine will begin to react with organic matter and ammonia to form chloro-organic 

22 compounds and chloramines, resulting in the combined chlorine residual mentioned previously. 

23 With the addition of more chlorine, the residual will decrease due to the oxidation of chloramines 

24 and chloro-organic compounds until chloramines reach a minimum value. Beyond this 

25 minimum point, the addition of more chlorine produces an increasing amount of free residual 

26 chlorine. This process is called breakpoint chlorination. While this process destroys most of 

27 the nitrogen compounds, it does not destroy all of them. Those that remain combine with the 

28 chlorine to produce what is called the irreducible combined residual. 

29 

30 
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1 Exhibit 4.7 Breakpoint Chlorination Curve 

2 

3 

4 

5 

6 Free chlorine + Combined chlorine = Total chlorine: For many systems, this results in 

7 a residual in the distribution system that includes free and combined residuals. The measurement 

8 of both of these residuals together is called the total chlorine residual. The combined residuals 

9 are the primary contributors to taste and odor problems in a system. Below is a table that shows 

10 the threshold of odor of various residuals. It is apparent that free chlorine and monochloramine 

11 (NH2Cl) are likely to produce fewer taste and odor complaints. Note, however, that there is a 

12 maximum residual disinfectant level (MRDL) standard of 4 mg/L for chlorine. 

13 

Compound Threshold of Odor 

Free HOCl 20 mg/L 

Monochloramine (NH2Cl) 5 mg/L 

Dichloramine (NHCl2) 0.8 mg/L 

Nitrogen trichloride (NCl3) 0.02 mg/L 

14 

15 Taste and Odor Considerations: As seen in the table above, taste and odor complaints 

16 primarily result from combined residuals that are formed after enough chlorine is formed to 

17 produce dichloramines (NHCl2) and nitrogen trichloride (NCl3). If a system has a problem with 

18 chlorine taste and odor complaints, it is often recommended that the operator measure both free 

19 and total chlorine residuals. As a rule of thumb, if the free chlorine residual is less than 85 

20 percent of the total, the odor and taste problem is a result of combined residuals. This problem 

21 may be resolved in two ways: 

22 

23 • Remove the precursors that cause the combined residuals; or 

24 
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1 • Increase the chlorine dosage. There may be an insufficient quantity of chlorine 

2 (pound to pound with the organics) to oxidize the organic compounds sufficiently to 

3 avoid the problem. 

4 

5 Germicidal Effectiveness: It is commonly agreed that a free chlorine residual of HOCl 

and OCl- 6 are much more effective as a disinfectant than a combined chlorine residual. 

7 Additionally, the HOCl portion of the free chlorine residual is approximately 100 times more 

effective as OCl- 8 as a disinfectant. The factors important to the germicidal effectiveness of 

9 chlorine are: 

10 

11 • Concentration and Contact Time; 

12 

13 • Water Temperature; 

14 

15 • Water pH; and 

16 

17 • Substances in the water 

18 

19 Concentration and Contact Time: The effectiveness of chlorination and its ability to 

20 destroy or inactivate pathogens is directly proportional to the concentration of chlorine 

21 multiplied by the time the chlorine is in physical contact with the organisms. That is if the 

22 concentration of chlorine is decreased, the contact time must be increased for chlorine to retain 

23 the same germicidal effectiveness. Similarly, if the contact time is decreased, the chlorine 

24 concentration must be increased for chlorine to be effective. To determine if disinfection is 

25 adequate to destroy pathogens, the GWR requires 4-log treatment of viruses using existing CT 

26 tables. CT is measured in milligram-minutes per liter (mg-min/L) and is calculated as follows: 

27 

28 Disinfectant residual concentration in mg/L (C) X contact time in minutes (T) = CT in mg29 min/L 

30 

31 In order to obtain primacy for the GWR, a State must explain the process it will use to 

32 determine that a ground water system achieves at least 4-log treatment of viruses. Many States 

33 will use CT as the foundation for making that determination with respect to disinfection. 

34 Appendix A provides a more detailed explanation of CT and how it should be calculated for 

35 GWSs. 

36 

37 Water Temperature: Other factors being equal, chlorine is more effective as a 

38 germicide at higher water temperatures. At lower temperatures, the destruction of pathogens 

39 tends to happen at a slower rate. 

40 

Water pH: The pH of water determines the ratio of HOCl to OCl- 41 . HOCl is the 

dominant residual at lower pH, while OCl- 42 is the dominant residual at higher pH. This is 

noteworthy, because ground waters often have a relatively high pH, resulting in OCl- 43 being the 

dominant residual. And as stated above, OCl- 44 is much less effective as a germicide than HOCl. 

45 

46 Substances in Water: Chlorine is only effective if it comes in contact with the 

47 organisms to be destroyed; therefore, substances in the water (e.g., sand, dirt, or other impurities) 

48 can “hide” or protect pathogens from contact with the chlorine and reduce the germicidal 
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1 effectiveness of the chlorine. In ground water, this is an issue with systems that pump sand or 

2 have other impurities in the water, and removal of these substances may be required for effective 

3 chlorination. 

4 

5 The following are suggested assessment criteria for assessing chlorine dosages and 

6 residuals: 

7 

8 Does the operator understand the disinfection process? 

9 

10 The operator should be knowledgeable about the disinfection process and the facilities 

11 used at the treatment plant to provide adequate disinfection treatment. The lack of knowledge by 

12 the operator of the disinfection process and the equipment is an indicator that equipment failure 

13 or other problems may not be resolved in a timely manner. 

14 

15 Have there been any interruptions in disinfection? If so, why? 

16 

17 The inspector should assess if there were any interruptions in disinfection and ascertain 

18 what steps have been taken to prevent further interruptions. 

19 

20 What disinfectant residual is maintained? 

21 

22 Records of disinfection residuals leaving the plant and in the distribution system (if 

23 applicable) should be checked. In addition to verifying that there is a proper residual, determine 

24 if the equipment and testing methods are adequate. 

25 

26 Is the contact time between the point of disinfection and the first customer 

27 adequate? 

28 

29 As stated previously, the contact time is the interval in minutes (T) that elapses between 

30 the time when chlorine is added to the water and the time when that same slug of water passes by 

31 the sampling point. A certain minimum period of time, depending on disinfectant residual 

32 concentration (C), water temperature and other factors, is required for completion of the 

33 disinfecting process. The requirements for contact time (T) and disinfectant residual 

34 concentration (C) depend on the pH, temperature and flow rate of the water. These records are 

35 especially important if the system is required to meet the 4-log virus inactivation requirements of 

36 the GWR. 

37 

38 Are the temperature and pH of the water at the point of chlorine application 

39 measured and recorded daily? 

40 

41 The CT value required for proper inactivation of viruses depends on the pH and 

42 temperature of the water. Therefore, some ground water systems may be required to take these 

43 two measurements regularly and perform CT calculations at peak hourly flow. The pH must be 

44 measured with a meter, not with litmus paper or a color comparitor, and the temperature must be 

45 measured with a calibrated thermometer. 

46 

47 The following sections discuss gas and liquid chlorination in more detail. Brief 

48 explanations of the processes and equipment used for each of these disinfection methods are 
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1 described, and potential deficiencies are characterized. Readers are encouraged to refer to 

2 Appendix A for more information on disinfection and removal technologies. 

3 

4 

5 4.3.4.3 Gas Chlorination 

6 

7 Equipment used to feed gas chlorine is designed to work either under pressure or under a 

8 vacuum. A vacuum-operated solution feed chlorinator is by far the most common of the two 

9 types of gas chlorinators. The vacuum-operated chlorinator will only feed chlorine gas when the 

10 equipment receives a vacuum signal. The gas is mixed with water to from a highly concentrated 

11 solution that is fed into the water at the point of application. The pressure-operated gas feed 

12 chlorinator is the other type of chlorinator and this equipment operates under pressure supplied 

13 by the gas and feeds to the point of application. The vacuum operated solution feed chlorinator 

14 offers greater safety in operation of the equipment and in the handling of the chlorine gas; 

15 additionally, these units provide for greater versatility in the application and control of the 

16 chlorine dosage. 

17 

18 The easiest way to tell the difference between a remote vacuum system and a pressure 

19 system is to observe the line leading from the cylinder to the chlorinator. If this line is metal, the 

20 system uses gas under pressure between the cylinder and the chlorinator. If the line is plastic, the 

21 system is a remote vacuum system. Gas is under a vacuum between the cylinder and the 

22 chlorinator. 

23 

24 Gas chlorine is provided in 100 pound and 150 pound cylinders, one ton containers, and 

25 tank cars (55 to 90 tons). These values are the net weight of liquid chlorine in the container. 

26 

27 With gas chlorination, the inspector will need to focus on the reliability and adequacy of 

28 the system to provide disinfection. It should be noted, however, that there are significant dangers 

29 involved with gas chlorination systems. Gas chlorine is classified as a poison gas and an 

30 inhalation hazard by OSHA, EPA, and Department of Transportation (DOT); therefore, review 

31 of safety procedures and inspection of safety equipment is necessary. 

32 

33 Typical Gas Chlorination Facility: The drawing below shows the key points of a gas 

34 chlorination facility. In general, these include: 

35 

36 • Containment of the chlorine, should there be a release or leak; 

37 

38 • Air treatment system so that the exiting air does not exceed 50 percent of the PEL (15 

39 ppm is 50 percent); 

40 

41 • Gas leak alarm system; 

42 

43 • Crash bars on doors; 

44 

45 • Negative pressure in the room when the air treatment system is operating; 

46 

47 • Overhead sprinkler system with a 20-minute capacity; 

48 
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1 • Containment of the air treatment system and sprinkler water; 

2 

3 • Emergency power for the air treatment system; 

4 

5 • Booster pump to provide pressure to the injector; and 

6 

7 • Scales to weigh the cylinders. 

8 

9 The sanitary deficiencies related to Chemical Feed Systems and Disinfection earlier in 

10 this chapter should also be applied to this section. The following are additional suggested 

11 assessment criteria for gas chlorination facilities: 

12 

13 How are leaks detected? At what detection concentration are automatic detectors 

14 set and have they been tested recently? Is the sensor tube for the automatic detector 

15 near the floor level, and is it screened?

16 

17 Automatic chlorine leak detectors should be tested at least monthly. This can be 

18 accomplished by placing a small pan of bleach under the air intake and adding some vinegar. 

19 

20 Are there any cross-connections in the chlorine feed make-up water or injection 

21 points?

22 

23 All service water to operate injectors/eductors should be protected by an appropriate 

24 cross-connection control device. 

25 

26 Is there an alarm tied to interruptions in the chlorine feed?

27 

28 If there is an alarm system, does it work? Low system vacuum and low cylinder pressure 

29 are the two most common alarm systems, and the inspector should ask what would initiate an 

30 alarm. Does the alarm shut down the flow of water or just alert the operator of a malfunction? 

31 

32 Does the system use automation, pace with flow, chlorine residual analyzer, or other 

33 system to adjust feed rates? Does it work?

34 

35 The inspector should determine whether the system provides adequate residual during 

36 high flows and whether the residuals are higher during low flows. It is common to find 

37 automatic equipment that does not work. 

38 

39 Is there more than one cylinder, and are they manifolded with an automatic switch40 over to prevent running out of chlorine?

41 

42 The inspector should determine whether the switch-over devices work. If there is only 

43 one cylinder, determine if the operator shuts off water flow when the cylinder is changed. If not, 

44 then there is an interruption of disinfection. 

45 
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1 Are the cylinders on a working scale?

2 

3 A scale must be used in order to determine the amount of chlorine used each day. In 

4 order to calculate dosage and signal the amount of chlorine remaining in the cylinders, scales 

5 must be maintained and calibrated and kept in working order. Scales often are not working due 

6 to excessive corrosion caused by chlorine, and the inspector should determine if new scales are 

7 needed. 

8 

9 Are the tanks in use a quarter turn open with a wrench in place for quick turnoff?

10 

11 Full feed of 40 pounds per day can be obtained from a cylinder by opening the valve one 

12 quarter of a turn. It is not necessary to open the valve more than what provides the needed flow. 

13 By only opening it one quarter of a turn and leaving the wrench in place, the operator can 

14 quickly shut the cylinder down if there is a release. 

15 

16 Are all cylinders properly marked and restrained to prevent falling?

17 

18 Cylinders should be marked and stored in a manner that clearly indicates which cylinders 

19 are full and which are empty. All cylinders must be restrained two-thirds of the way from the 

20 bottom with a chain that prevents falling. In an earthquake zone they must also be restrained at 

21 or near the bottom. 

22 

23 Is the proper concentration of ammonia available to test for leaks?

24 

25 Use a concentrated ammonia solution containing 28 to 30 percent ammonia as NH3 (this 

is the same as 58 percent ammonium hydroxide or, HN4OH, commercial 260 26 Baume). 

27 Household ammonia is not strong enough to provide reliable indication of a chlorine leak. 

28 

29 What procedures are followed during cylinder changes and maintenance? Has the 

30 utility provided detailed training on handling and changing cylinders? 

31 

32 Check to see if there is a written standard operating procedure (SOP) for maintain 

33 changing cylinders. If not, then there are opportunities for disinfection interruptions as well as 

34 safety concerns. 

35 

36 What is the operating condition of the chlorinator?

37 

38 Gas chlorinators should be disassembled, cleaned, and rebuilt each year. An observation 

39 of the rotameter can provide a clue as to the frequency of cleaning. If it is coated on the inside 

40 with a heavy green or blackish film, the machine is past due for cleaning. 

41 

42 In addition, general appearance can also be a key. Check preventative maintenance and 

43 repair records, and determine that preventative maintenance is routinely performed. Some 

44 indicators of problems for gas chlorination would be valves, piping, and fittings that are 

45 damaged, badly corroded, or loose; no gas flow to the chlorinator; or frost on tank, valves or 

46 piping. 

47 
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1 Is redundant equipment available, and are there adequate spare parts?

2 

3 Disinfection must be continuous. Therefore, standby equipment of sufficient capacity to 

4 replace the largest unit is recommended. Where standby equipment is not available, flow to the 

5 water system should be halted, and critical spare parts should be on hand for immediate 

6 replacement. At a minimum, the system must have spare diaphragms and a set of lead gaskets. 

7 (Lead gaskets should not be reused.) 

8 

9 

10 4.3.4.4 Liquid Hypochlorination 

11 

12 Many facilities have switched to the use of hypochlorination as a safer and easier method 

13 of disinfecting water than gaseous chlorine. The primary disadvantage to liquid chlorination is 

14 the increased annual operating cost over gas systems; however, as a result of new safety and 

15 environmental regulations, the cost of using chlorine gas has continued to rise, making the 

16 hypochlorination systems more common. Systems using hypochlorite should list it in their 

17 hazardous materials inventory and have written procedures for handling, using and responding to 

18 spills. 

19 

20 

21 4.3.4.5 Typical Liquid Chlorine System 

22 

23 There are two forms of hypochlorite that are used in a liquid chlorine system; sodium 

24 hypochlorite (liquid) and calcium hypochlorite (solid). Sodium hypochlorite is more corrosive 

25 and degrades over time. The rate of loss of sodium hypochlorite depends on the strength of the 

26 chemical and the temperature. The chemical deteriorates faster at higher concentrations and 

27 warmer temperatures. If sodium hypochlorite is used, the inspector should determine the amount 

28 on hand and its age. Sodium hypochlorite is also corrosive so equipment should be corrosion 

29 resistant and checked frequently for signs of corrosion. 

30 

31 Calcium hypochlorite is more stable than sodium hypochlorite. It is not as soluble, 

32 however, especially in hard water. Calcium hypochlorite also frequently contains abrasive 

33 material that can lead to more wear on pumps and valves. 

34 

35 The following are suggested assessment criteria for liquid chlorine systems: 

36 

37 Is the disinfectant chemical used appropriately certified? 

38 

39 Chemicals introduced into drinking water should be certified as meeting the standards of 

40 NSF 60 or an equivalent standard. This certification ensures that no impurities are present that 

41 could cause health problems in the consumers of the water. 

42 

43 What is the strength of the chemical feed solution? 

44 

45 In order to achieve the proper dose of chlorine the strength of the solution must be 

46 known. The operators should be familiar with procedures for preparing and testing the solution 

47 and determining the dose. 

48 
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1 Is chemical storage adequate and safe? 

2 

3 It is recommended that systems have a 30 day supply of chemicals on hand to prevent 

4 running out of chemicals and losing disinfection capability. Chemicals should be stored so that 

5 they are safe. Hypochlorite is a strong oxidizer and should be kept away from any combustibles, 

6 especially petroleum products. Liquid storage should have spill containment around it. Proper 

7 safety equipment such as showers, eyewashes, and respirators should be available. 

8 

9 Is equipment operated and maintained properly? 

10 

11 Failure of the feed equipment could result in loss of disinfection. Therefore all 

12 equipment should be well maintained with a regular preventative maintenance schedule. Feed 

13 lines should be checked regularly to make sure they are not clogged. Clear plastic lines should 

14 be replaced if they become opaque. Pump valves, control valves, and injection valves should be 

15 replaced at least once a year. 

16 

17 Is standby equipment available? 

18 

19 If a feed pump fails, the system can lose disinfection capabilities. Therefore, the system 

20 should have at least one backup feed pump. If a valve fails, the system can lose disinfection 

21 capabilities. Therefore, a system should have adequate spare parts on hand to be able to quickly 

22 replace any valves in the chlorine feed system. 

23 

24 What is the pump model? Stroke and speed settings? 

25 

26 The operator should be familiar with the type and model of the chemical feed pumps. 

27 Positive displacement pumps should be used. Chemical feed pumps generally have adjustable 

28 speed and stroke length that help to determine the feed rate. The pump should be able to deliver 

29 the maximum required dose at 85 percent of its maximum speed. Stroke rates should be kept 

30 within the manufacturer’s specified ranges. 

31 

32 Where are they storing their feed solution? 

33 

34 The feed solution should be stored in a covered, chlorine resistant tank. It should be in a 

35 dry clean area and have the appropriate spill containment surrounding it. 

36 

37 How do they make up the chlorine feed solution? 

38 

39 The operator should be familiar with the process for mixing the chlorine feed solution. 

40 Proper safety equipment should be used for preparing the solution including gloves and goggles. 

41 

42 Is the chlorine feed manually or automatically adjusted for flow? 

43 

44 Disinfectant dose will need to be varied depending on flow rate. This can be done either 

45 by manually adjusting the pump or it can be done by hooking the pump to a flow sensor that 

46 adjusts pump rates in proportion to the measured flow rate in the pipe (flow-paced). Chemical 

47 feed should not be turned on if there is no flow. The operator should be familiar with calculating 

48 the required chlorine dose based on flow and determining if the pumps are delivering sufficient 

49 dose. 
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1 

2 Are proper cross connection controls in place for the make-up water? 

3 

4 If finished water is used to provide water for chlorine injection , make up water, or 

5 preparation of chlorine feed solutions, there must be proper cross connection controls to prevent 

6 backflow of the raw water into the finished water lines. This means providing a sufficient air 

7 gap if a hose or faucet is used, or installing the appropriate backflow prevention devices if the 

8 line is piped into the feed facility. Exhibit 4.8 illustrates an appropriate air gap between a water 

9 feed line to a chlorine solution tank and the chlorine solution in the tank. 

10 

11 

12 Exhibit 4.8 Example of an Air Gap on a Chemical Feed System 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 4.3.4.6 Typical Defects 

41 

42 Equipment Calibration 

43 

44 Ensuring proper disinfection requires that the equipment used to determine the required 

45 dose and to measure disinfection efficiency be in proper working order. This includes equipment 

46 such as scales, flow meters, feed pumps, turbidimeters, pH meters, chlorine meters, and 

47 temperature gauges. If this equipment is not calibrated regularly, adequate disinfection cannot 

48 be guaranteed. A good practice is to calibrate chemical feed equipment whenever a new batch of 

Air gap between 

water feed and 

chlorine solution 
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1 chemicals used. Frequent verification of pump feed rate “pump catches” should be part or 

2 regular operator duties. 

3 

4 Adequate Instrumentation and Controls 

5 

6 There needs to enough instrumentation to provide all the information an operator needs to 

7 determine the proper dose is being delivered. These include flow meters, chlorine residual 

8 analyzers, and turbidimeters. In addition these instruments must be properly calibrated and in 

9 working order. The operator should be able to explain calibration procedures for each 

10 instrument and be able to explain how the results of the measurements are used. 

11 

12 Storage 

13 

14 Storage should be located in a clean dry location away from other incompatible 

15 chemicals such as petroleum products. Proper spill containment should be included around 

16 liquid storage facilities. A supply of 30 days of chemical should be on hand at all times. 

17 

18 

19 4.4 Distribution System 

20 

21 The purpose of the distribution system is to convey potable drinking water from the 

22 source to the consumer. A typical water distribution system consists of water mains (usually 

23 metal, plastic, or concrete), various types of control valves, service lines which connect 

24 customers to the water mains, meters, and fire hydrants. Many systems include finished water 

25 storage and pumping stations to increase system pressure or to fill storage facilities. Some 

26 distribution systems are equipped with booster disinfection. 

27 

28 Opportunities are plentiful for contamination of potable water in the distribution system 

29 before it reaches the consumer. Maintenance activities can expose the system to harmful 

30 pathogens. Water system materials themselves can be prone to failure and in some cases can 

31 even leach contaminants into the water. Cross connections and improperly constructed or 

32 maintained valves can contribute to deteriorating water quality. In addition to external 

33 contamination, water quality can naturally degrade in the system as the chlorine residual 

34 decreases and bacteria counts increase. 

35 

36 This section provides guidance for conducting sanitary surveys of water distribution 

37 systems. Note that guidance for surveying finished water storage and pumps are provided in 

38 Sections 4.5 and 4.6, respectively. 

39 

40 The scope of the distribution system survey depends greatly on system size, age, and 

41 extent of documentation of infrastructure as well as operations and maintenance programs. 

42 Because the majority of it is buried, the distribution system survey is more of a paper review and 

43 interviews rather than a visual inspection. The inspector should ask for and review system 

44 schematics, operation and maintenance records, standard operating procedures, construction 

45 standards, and distribution system water quality data. The field portion of the survey should 

46 include a visual inspection of a valves, meters, and backflow prevention devices which are 

47 owned maintained by the water system. For larger systems, the inspector may want to select a 

48 representative number of each type of valve and backflow preventer (BFP) for the visual 

49 inspection. 
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1 4.4.1 Distribution System Mapping 

2 

3 Accurate mapping enables the water system to quickly respond to breaks and other 

4 unexpected events. Accurate mapping also helps the system plan for future improvements and/or 

5 expansion. Typical distribution system components that should be shown on maps include main 

6 water lines, service lines, water meters, blow-offs, fire hydrants, and valves. 

7 

8 Suggested assessment criteria for the distribution system mapping include: 

9 

10 Does the system have an up-to-date map of the distribution system showing all 

11 major features? 

12 

13 The water system should have an up-to-date distribution system map(s) showing the 

14 location and size of all pipelines, valves, blow-offs, service connections, and fire hydrants. The 

15 map should also show pressure zone boundaries, interconnections to other systems, water storage 

16 facilities, pumping stations, and booster disinfection stations. Systems may use one map to show 

17 all major features, or several maps that can be overlaid to give a complete picture of the 

18 distribution system. The inspector should check the date of the last map revision (this may be 

19 included in the title block or map key). Maps should be updated regularly to document changes 

20 or additions to the system. 

21 

22 Are as-built drawings available? 

23 

24 As-built drawings are scaled, construction drawings that show the exact location of 

25 facilities. Accessible as-built records help the water system to perform repairs in a timely 

26 manner. 

27 

28 Does the system have many dead end water lines? 

29 

30 Dead end lines can result in increased water age and subsequent deterioration of water 

31 quality through loss of chlorine residual. In addition, areas served by dead end lines are 

32 susceptible to complete water loss in the event of a break or other maintenance problem. Water 

33 system lines should be looped wherever possible.

34 

35 Is the water system interconnected to another system? 

36 

37 Interconnections can provide an alternative water source in the case of emergencies. 

38 

39 Are chambers or manholes containing valves, meters, or other appurtenances prone 

40 to flooding? 

41 

42 The inspector should visually inspect valves and meters in the distribution system to 

43 evaluate their condition and determine if they are prone to flooding. The inspector should also 

44 inquire if the water system has a regular program for visual inspections of valves and other 

45 appurtenances located in manholes or pits. If a valve or meter is submerged, non-potable water 

46 may enter the distribution system in the event of a pressure drop. Additionally, standing water in 

47 a meter pit can accelerate corrosion. Whenever possible, chambers or manholes containing 

48 valves, meters, or other appurtenances should not be located in areas subject to flooding. 

49 
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1 Are blow-offs connected to sanitary or storm sewers? 

2 

3 A direct connection from a blow-off to a storm or sanitary sewer is considered a cross 

4 connection and public health hazard. 

5 

6 

7 4.4.2 Distribution System Pipe Material and Condition 

8 

9 The major component of a water distribution system is buried piping. Pipe material 

10 should be strong enough to withstand internal water pressure and be non-corrosive. Typical 

11 piping materials for water distribution systems include: 

12 

13 • Cast iron; 

14 

15 • Ductile iron; 

16 

17 • Asbestos cement; 

18 

19 • Steel; 

20 

21 • PVC- pressure class pipe; 

22 

23 • Wood; and 

24 

25 • High-density polyethylene (HDPE) 

26 

27 The inspector should review data on pipe material and age for the entire water system. 

28 Distribution system piping should meet NSF standard 61 or equivalent. 

29 

30 Older water systems in particular can experience a high frequency of water main breaks 

31 and a high volume of leakage in the distribution system. The inspector should request 

32 information on the frequency of water main breaks over the last five to 10 years. The inspector 

33 should also ensure that the water system has a standard procedure for recording information on 

34 water main breaks, including date and location, type of leak or break, pipe type, pipe depth, and 

35 soil condition. The inspector should also request information on estimated water loss in the 

36 distribution system and gather information on any kind of leak detection activities. 

37 

38 Suggested assessment criteria for distribution system material and condition include: 

39 

40 Does the system have PVC pipe manufactured before 1977? 

41 

42 Pre-1977 PVC pipes contain elevated levels of a vinyl chloride monomer, which are 

43 prone to leaching (Permeation and Leaching Issue Paper, USEPA 2002). 

44 
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1 Does the system contain water service lines made of Polytheylene (PE) or Poly 

2 butylene (PB)? 

3 

4 These types of pipes are prone to permeation by diesel and petroleum products 

5 (Permeation and Leaching Issue Paper, USEPA 2002). 

6 

7 Does the system contain any steel pipe that is more than 35 years old? 

8 

9 Steel pipe is typically given a design life of 35 years (USEPA 2003), and can deteriorate 

10 more rapidly if the ground is wet and/or of the soil is acidic. Pinhole leaks in steel pipes can 

11 increase water loss and provide a potential pathway for contamination 

12 

13 Does the system contain lead service lines? 

14 

15 If the water is corrosive, lead service lines can leach a significant amount of lead into the 

16 drinking water. If a water system exceeds the Federal Action Level for lead after installing 

17 corrosion control and/or source water treatment, it is required by the Lead and Copper Rule to 

18 replace at least 7 percent of lead service lines per year. In most cases, the water system is 

19 responsible for the portion of the service line prior to the water meter. 

20 

21 Does the system keep records on water main breaks? How many water main breaks 

22 does the system typically experience in one year? 

23 

24 Water main breaks can result in low or negative pressure in the distribution system and 

25 cause backflow events at unprotected cross connections. Water main breaks increase water loss 

26 and risk of contamination during repair procedures. Systems should periodically review water 

27 main break history to determine if there symptomatic problem in a portion of the system or with 

28 one type and/or age of water pipe. 

29 

30 Does the water system have a leak detection program? 

31 

32 Detecting and repairing leaks is important not only from a water efficiency standpoint, 

33 but also to protect public health. The USEPA Distribution System White Paper, “The Potential 

34 for Health Risks from Intrusion of Contaminants into the Distribution System from Pressure 

35 Transients” notes the following: 

36 

37 Efforts to reduce distribution system pipeline leakage are beneficial not only from a 

38 water conservation standpoint, but also to minimize the potential for microbial intrusion 

39 into potable water supplies. Leaks are not simply a loss of revenue for a water utility, but 

40 the leak is a potential pathway for contamination. The public health benefits of leak 

41 control should be recognized and encouraged. Repair of leaking sewer lines should 

42 similarly be a top priority, not only to minimize the occurrence of pathogens near 

43 drinking water pipelines, but to reduce these sources of contamination being transported 

44 to groundwater supplies and receiving streams, particularly under wet weather 

45 conditions. 

46 

47 Water systems should have a system for estimating leaking on an annual basis, an annual 

48 goal for amount of water loss, and a response program if that goal is not met. Typical goals range 
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1 from 10 to 20 percent depending on age of the system, length of pipe, topography, and other 

2 factors. 

3 

4 Does the system have a cleaning and lining or pipe replacement program? 

5 

6 Water systems should have a plan in place to replace and/or clean and line aging water 

7 pipe. Large systems may have capital improvement or asset management plans. This is 

8 particularly important for systems that experience a high frequency of main breaks or high water 

9 loss in the distribution system.

10 

11 

12 4.4.3 Location and Maintenance of Valves 

13 

14 Valves are a critical component of the distribution system. Isolation valves allow for 

15 routine maintenance or emergency repairs of distribution system piping. Altitude valves maintain 

16 storage tank levels and other control valves are used for pressure and hydraulic control in 

17 distribution systems. Common valves are described below. 

18 

19 • Isolation valves are used to isolate a portion of the distribution system for repairs. 

20 Gate and butterfly valves are the most common. 

21 

22 • Air valves are used to expel air pockets from within pipelines, which can increase 

23 flow and reduce pressure. Typical kinds of air valves are air relief, air release, and air 

24 vacuum valves. 

25 

26 • Pressure reducing valves (PRV) are used to reduce or maintain pressure in a portion 

27 of the system. 

28 

29 • Altitude valves provide for automatic filling of tanks and reservoirs. 

30 

31 Accurate records and diligent valve exercising and maintenance can minimize service 

32 disruption and water quality impacts from main breaks and emergencies. 

33 

34 Suggested assessment criteria for location of valves include: 

35 

36 Are valves inventoried and accurately located on distribution systems maps or in 

37 another form (i.e. GIS)? 

38 

39 Accurate inventories and locations allows for rapid response and reduced service 

40 disruption in the event of a main break or other emergency. Some utility valve programs include 

41 marking the valve box so that it can be easily located in the field. 

42 

43 Are there enough valves to isolate distribution system zones and storage and 

44 pumping facilities? 

45 

46 The inability to isolate a pressure zone or storage facility in an emergency can lead to 

47 supply pressure losses and water quality degradation in larger parts of the distribution system. 
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1 The American Water Works Association (AWWA) publication “Criteria for Valve Location and 

2 System Reliability” (2007) should be considered as a reference. 

3 

4 Are isolation valves maintained and exercised on a regular basis? 

5 

6 Maintenance and exercise helps ensure that valves will remain operational and that 

7 damaged or inoperable valves are repaired or replaced. Generally, valves in the system should 

8 be operated through a full cycle (closed then opened to the original position) at least once per 

9 year. Larger systems may prioritize valve maintenance and exercise to ensure that more critical 

10 valves receive frequent attention. Large valves that are prone to breakage may need special 

11 procedures. Maintenance should include any manufacturer recommended maintenance (e.g., 

12 repacking seals) and cleaning out the valve box or pit. 

13 

14 Does the system maintain records of valve maintenance and exercise programs? 

15 

16 The system should record maintenance activities for each valve in their system. Records 

17 should include the number of turns needed to open and close the valve and the date that the valve 

18 was exercised. 

19 

20 How does the system confirm operation of automatic PRVs? 

21 

22 The failure of a PRV to reduce pressure can result in water main or service line breaks. If 

23 the system has automatic PRVs, the inspector should confirm that the devices are working 

24 properly. One way to do this is to check the pressure upstream and downstream of each PRV. 

25 The downstream pressure should be lower. If it is not, ask the system operator to open a fire 

26 hydrant downstream and observe the reaction of the pressure across the valve. 

27 

28 Are valves in confined spaces? 

29 

30 Large valves are often in vaults, which are considered confined spaces. If operators need 

31 to enter a confined space to observe or operate the valve, they should follow a written confined 

32 space entry procedure and use gas monitoring equipment. Inspectors should not enter confined 

33 spaces during the survey without confined space training and proper equipment. 

34 

35 

36 4.4.4 Design and Construction Standards 

37 

38 The use of design and construction standards ensures that distribution system pipes and 

39 appurtenances will operate effectively. Design and construction standards typically specify 

40 minimum pipe size, design flow, fire flow, location of water pipe relative to other utilities 

41 (particularly sanitary sewers), right-of-way limits, valve selection and design, fire hydrants, 

42 meters, pipe material, minimum cover or depth of bury requirement, and installation 

43 requirements. An important component of the design standard is a requirement to disinfect new 

44 water lines before placing them into service. 

45 

46 Water systems may have their own, in-house standard or may refer to construction and 

47 design standards published by AWWA or the Great Lakes – Upper Mississippi River Board 

48 (GLUMRB) of State and Provincial Public Health and Environmental Managers (commonly 

49 referred to as “Ten States Standards”). NSF standard 61 is commonly referenced by water 
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1 systems. This standard applies to products that come into contact with drinking water including 

2 pipes, fittings, and valves. Inspectors should verify that a system is following an NSF 

3 certification program or equivalent for new construction of distribution system components. The 

4 AWWA publication, “Design and Construction of Small Water Systems” (1999) can provide 

5 additional information for inspections of small systems. 

6 

7 Many States have their own design and construction standards. Sanitary survey 

8 inspectors should obtain a copy of State standards before going into the field. 

9 

10 Suggested assessment criteria for design and construction standards include: 

11 

12 Does the water system have a design and construction standard? 

13 

14 Many large water systems develop their own design and construction standards. If the 

15 State also has a standard, the inspector should verify that the water system’s standard is 

16 consistent with and at least as protective as the State standard. The design standard should 

17 require that distribution system materials are NSF certified or equivalent. 

18 

19 Is the standard being followed? 

20 

21 The inspector should ask the system how it verifies that design and construction 

22 standards are being followed by both in-house staff and contractors. The system should visually 

23 inspect pipes and appurtenances prior to installation. Qualified water system personnel should 

24 periodically inspection construction activities. To check that the design standard is being 

25 followed, inspectors can compare the current standards to a set of blueprints for recent 

26 construction. 

27 

28 Are pressure and leak tests performed on all new pipe construction? 

29 

30 Pressure tests check the integrity of the piping material following installation. Leak tests 

31 check the integrity of the pipe joints. Both are recommended by Ten State Standards (2003). 

32 The inspector should review the construction standards to determine if these tests are required for 

33 new pipe construction. 

34 

35 Are pipes stored with protective caps? 

36 

37 When pipes are uncovered, they can easily be contaminated with mud, debris, and rain 

38 water. The inspector should determine if the water system requires protective caps for on-site 

39 storage of water pipe. 

40 

41 What method is used to disinfect new water lines? How does the water system 

42 ensure that contractors are following this procedure? 

43 

44 Systems should require contractors and in-house staff to disinfect new water lines using 

45 the procedure outline in AWWA Standard C651-99, “Disinfecting Water Mains” (2005) or 

46 equivalent. The system should meet all State requirements for disposal of highly chlorinated 

47 water. Systems should require a negative bacteriological test result before the main can be 

48 placed into service.

49 
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1 

2 4.4.5 Maintaining Adequate Pressure 

3 

4 Maintenance of positive pressure in the distribution systems is an important step in 

5 preventing distribution system contamination. Pressure is a function of pipe elevation, water 

6 levels within storage facilities, pump settings, and friction losses inside pipes and appurtenances. 

7 Many distribution systems are divided into distinct pressure zones which are typically served by 

8 individual storage facilities and/or pumping stations. Pressure zones are often identified by a 

9 range of operating pressure in units of pounds per square inch (psi) or feet of water. 

10 

11 Suggested assessment criteria for operating pressure include: 

12 

13 Does the system regularly measure pressure in the distribution system? 

14 

15 Pressure in the distribution system varies due to changes in water system demand, tank 

16 levels, and pump settings. Water systems should periodically measure and record system 

17 pressure at key points in their distribution systems (typically points of lowest and highest 

18 elevation). Large systems may use alarms to notify them if pressure drops below a certain level. 

19 The frequency of pressure monitoring depends on the size and complexity of the system. At 

20 minimum, pressure should be measured when chlorine residuals are measured and in response to 

21 customer complaints of low pressure. 

22 

23 What are the maximum and minimum pressures in the system? What is the range 

24 of normal operating pressure? 

25 

26 Distribution systems should generally operate between 50 and 80 psi. Excessive pressure 

27 (greater than 100 psi) may damage consumer facilities and plumbing fixtures. The inspector 

28 should determine if the State requires a minimum operating pressure (35 psi is typical) and if so, 

29 check that the system is always operating above this minimum. System pressure should be at 

30 least 20 psi at all points in the distribution system and at all flow conditions. Pressures below 20 

31 psi can render that portion of the system vulnerable to backflow at unprotected cross 

32 connections, which is serious health concern. 

33 

34 Does the system receive complaints of inadequate pressure? 

35 

36 Customer complaints of inadequate pressure could indicate a problem in the distribution 

37 system. 

38 

39 Does the system operate to minimize pressure surges? 

40 

41 Pressure surges can cause water main breaks and potential intrusion of pathogens where 

42 there are minor leaks or holes in the system. General strategies to reduce pressure surges include 

43 slow valve closure times, avoiding check valve slam, use of surge tanks, pressure relief valves, 

44 and air valves. 

45 

46 
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1 4.4.6 Response to Water Main Breaks 

2 

3 Water main breaks are due to many factors, including freezing and thawing cycles, 

4 corrosion, and soil conditions. Water main breaks open the system to contamination, and 

5 frequent breaks increase the potential for introducing waterborne pathogens into the system. 

6 Although they cannot be entirely avoided, systems should strive to minimize the number water 

7 main breaks. 

8 

9 Suggested assessment criteria for response to water main breaks include: 

10 

11 Are there written procedures for isolating portions of the system and repairing 

12 mains? 

13 

14 Written emergency procedures can reduce the time it takes to isolate a water main break 

15 and make repairs. For a small system, a written plan is very useful for when the regular operator 

16 is not available. 

17 

18 Are adequate repair materials on hand? 

19 

20 The system should have on hand sufficient quantities of disinfectant, repair sleeves, and 

21 other materials needed to repair water main breaks. 

22 

23 What disinfection procedure is used during pipe repairs? 

24 

25 It is critical that systems have a standard procedure for disinfecting and flushing repaired 

26 water lines. The procedure should conform to AWWA standard C651 or equivalent and should 

27 include the following: 

28 

29 • Sprinkling disinfect in the area surrounding the break; 

30 

31 • Swabbing fittings, pipes, and clamps with chlorine; and 

32 

33 • Flushing the line to remove any sediment. 

34 

35 The procedure should include information on safe handling and disposal of disinfectants. 

36 Bacteriological testing should be required and should show negative results before the water 

37 main is placed back into service. The water system should provide adequate training and follow38 up to ensure that maintenance personnel are following the standard procedure.

39 

40 Does the water system maintain a list of critical customers? 

41 

42 Certain customers, such as hospitals and clinics, can be severely impacted by reduced or 

43 shut off water service. The water system should have a list of such customers and should have 

44 plans in place to notify those customers of planned or emergency service changes. 

45 

46 
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1 4.4.7 Flushing Programs 

2 

3 Routine flushing of the distribution system has many benefits. Flushing can remove 

4 accumulated sediment and stagnant water from the system and can reduce disinfectant demand 

5 of pipe surfaces. Flushing can also be used to reduce excessive water age at dead ends. 

6 

7 Flushing programs are typically conventional, unidirectional, emergency, or some 

8 combination thereof. Conventional flushing is achieved by opening hydrants in the distribution 

9 system to remove stagnant water. Unidirectional flushing involves a carefully planned program 

10 to move water in one direction through a pipe by closing valves and opening hydrants. 

11 Unidirectional flushing achieves higher velocities than conventional flushing and is thus more 

12 effective at scouring water mains to remove corrosion products and biofilm. Water systems also 

13 often employ spot or emergency flushing in response to a water quality complaint or sampling 

14 result that is outside of normal operating parameters. 

15 

16 Suggested assessment criteria for flushing programs include: 

17 

18 Does the water system have a procedure to flush the distribution system on a 

19 regular basis? 

20 

21 Most systems should operate hydrants on a regular basis to flush the distribution system. 

22 Typical programs strive to flush the entire system in one to three years. Systems should develop 

23 a flushing program that meets their specific needs. For example, conventional flushing may be 

24 adequate for small systems with plastic piping. Unidirectional flushing programs may be more 

25 appropriate for larger systems with a history of biofilm growth and corrosion of cast iron water 

26 mains. Larger utilities should consider a targeted flushing program that employs more frequent 

27 flushing in areas that routinely experience water quality degradation over time (i.e., increased 

28 bacterial activity). 

29 

30 Does the water system keep up-to-date records on flushing activities? 

31 

32 The water system should keep records on which portions of the distribution system are 

33 flushed each year. Water quality data should also be recorded and evaluated on a regular basis to 

34 assess the effectiveness of the program.

35 

36 

37 4.4.8 Water Quality Monitoring 

38 

39 Water quality monitoring in the distribution system is an essential part of regular 

40 operations. Water systems monitor to comply with various drinking water regulations and may 

41 also conduct supplemental monitoring to track of water quality changes in their system. Most 

42 systems are required to collect a minimum number of samples for bacteriological quality under 

43 the TCR and to assess corrosion in the distribution system under the Lead and Copper Rule. 

44 Surface water and GWUDI of Surface Water systems must demonstrate that they are maintaining 

45 a detectable disinfectant residual in the distribution system. 

46 

47 Monitoring requirements depend on system size, source water (ground, surface, or 

48 GWUDI), and type. PWSs have the most requirements, with typically less monitoring required 

49 for NTNCWS and TNCWS. Because States may require additional monitoring compared to 
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1 Federal rules inspectors should thoroughly review State compliance monitoring requirements 

2 before going into the field. 

3 

4 

5 4.4.8.1 Maintaining a Residual 

6 

7 Under the GWR, systems that provide 4-log inactivation of viruses with a chemical 

8 disinfectant and do not perform triggered monitoring (or that provide 4-log virus inactivation 

9 with a chemical disinfectant as a corrective action) must monitor for and maintain a minimum 

10 disinfectant residual (set by the State) at or before the first customer. Some PWSs may also 

11 maintain a disinfectant residual in the distribution system or be required by State regulations to 

12 maintain a disinfectant residual in the distribution system. Suggested criteria for assessing 

13 disinfectant residual maintenance include: 

14 

15 Does the system meet State requirements for disinfectant residual monitoring and 

16 reporting? 

17 

18 The inspector should ensure that the system collects the required number of samples for 

19 disinfectant residual monitoring and that results meet minimum State requirements. The 

20 inspector should also check that monitoring results are reported to the State on a regular basis.

21 

22 Are measurements throughout the system? 

23 

24 Sampling locations should be located throughout the distribution system. At least one site 

25 should be in the expected area of lowest residual (typically oldest water) to help ensure that a 

26 residual is maintained elsewhere. 

27 

28 Is there a standard procedure for measuring disinfectant residual in the field? 

29 

30 The inspector should review the standard procedure for chlorine residual measurement. 

31 Instructions for sample tap flushing and collection, reagents, and method should be checked. The 

32 inspector should confirm that the field instruments are calibrated as recommended by the 

33 manufacturer. 

34 

35 Are operators regularly trained on this procedure? 

36 

37 The water system should have a program to provide refresher training to current samplers 

38 on a regular basis and comprehensive sampling training for new staff. 

39 

40 What is the disinfectant residual level at the time of the field survey? 

41 

42 The inspector should consider collecting and analyzing one or more samples for 

43 disinfectant residual during the field portion of the survey. Results should be checked against 

44 utility data to evaluate for potential method or data management problems. 

45 

46 
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1 4.4.8.2 Bacteriological Quality (TCR) 

2 

3 All CWSs are required to take a minimum number of samples under the TCR. Smaller 

4 systems may sample once per month, while larger systems typically sample at multiple locations 

5 throughout their distribution system. Many systems also sample for heterotrophic plate count 

6 (HPC) to assess bacteriological water quality. Suggested assessment criteria for bacteriological 

7 monitoring include: 

8 

9 Do TCR sample sites represent water quality throughout the distribution system? 

10 

11 Total coliform samples must be collected at sites throughout the distribution system 

12 according to a written sample siting plan. The inspector should review the plan to ensure that it 

13 meets State requirements. 

14 

15 Does the system collect at least the minimum number of required samples? 

16 

17 The inspector should compare recent sample results to State requirements to ensure that 

18 the system is collecting and analyzing the right number of samples per month. 

19 

20 Are systems using an approved method for TCR sample collection and analysis? 

21 

22 The system should have a written procedure for collecting and analyzing total coliform 

23 samples. The procedure should include instructions for disinfecting the tap and flushing the 

24 water for several minutes to clear out stagnant water from the internal building plumbing system. 

25 Samplers should use appropriate bottles and should wear gloves during sampling. The inspector 

26 should check that the samples are kept refrigerated, do not exceed maximum holding time 

27 requirements prior to analysis, and are analyzed using an EPA-approved method. The system 

28 should also have a program to regularly train samplers on proper procedures. 

29 

30 Does the system follow repeat sample requirements? 

31 

32 The TCR requires all systems to collect repeat samples if a routine sample is total 

33 coliform or fecal coliform positive. Repeat samples must be collected within 24 hours of 

34 learning of the routine positive results. At least three repeat samples must be collected, one at 

35 the original location, one within five connections upstream of the original locations, and one 

36 within five connections downstream of the original location.

37 

38 Does the system experience a high number of total coliform positives or high HPC 

39 counts? 

40 

41 Frequent total coliform positives or high (greater than 500) HPC results may indicate a 

42 problem in the distribution system. If this is the case, the water system should be actively trying 

43 to address the problem. 

44 

45 Has the system had an E.coli or fecal coliform positive sample in the last several 

46 years? 

47 

48 A fecal coliform or E. coli positive sample followed by a repeat positive sample is 

49 considered an acute violation of the TCR and considered a serious public health threat. The 
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1 system should be able to explain the cause of any recent E.coli or fecal coliform positive sample 

2 and should have made changes to system operation or maintenance to minimize the chances of 

3 contamination occurring in the future. 

4 

5 Has the system followed up all TCR-positive samples with source water fecal 

6 indicator samples as required by the GWR? 

7 

8 Any GWS that does not provide 4-log (99.99%) treatment of viruses is required to 

9 respond to a TCR-positive sample by collecting fecal indicator source water samples at all 

10 sources in use when the TCR-positive sample was collected. The inspector should confirm 

11 during the sanitary survey that the appropriate source water samples were collected. 

12 

13 

14 4.4.8.3 Other Water Quality Parameters 

15 

16 Depending on the system’s water quality and treatment, the sanitary survey inspector 

17 should review additional distribution system monitoring that is either required or conducted 

18 voluntarily because it benefits the system’s delivery of safe and potable water. Some additional 

19 distribution system monitoring issues to consider during the sanitary survey include: 

20 

21 • Is the system collecting samples according to its Stage 1 D/DBP monitoring plan? 

22 

23 • Is the system on track with meeting its requirements for the Stage 2 D/DBP Rule’s 

24 IDSE? 

25 

26 • Are lead and copper samples being collected correctly? Additional water quality 

27 parameter testing due to compliance with the Lead and Copper Rule? 

28 

29 • If the system uses chloramines is it monitoring nitrification parameters (i.e., nitrate, 

30 nitrite, ammonia, HPCs)? 

31 

32 

33 4.4.8.4 Customer Complaints 

34 

35 Customers are sensitive to changes in water quality. While sampling is an excellent tool 

36 for monitoring water quality, customers are typically the first to notice an unexpected change. 

37 The inspector should review historical records documenting the nature of the complaint, the 

38 investigation report, and response. Suggested assessment criteria for customer complaints 

39 include: 

40 

41 Does the system keep records of customer complaints and investigation reports? 

42 

43 Customer complaints can alert the system to a water quality issue in the distribution 

44 system. Common complaints include red or rusty water, which could be associated with 

45 corrosion of cast iron mains, cloudy water, and chlorinous odor. Some States require systems to 

46 record the nature of and response to all customer complaints. Large systems should consider 

47 mapping customer complaints to proactively address problems. 

48 
November 2007 Sanitary Survey 4-50 Draft for Discussion

Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 Do frequent or repeat customer complaints indicate a water quality problem? 

2 

3 The water system should address repeated customer complaints in a specific area of the 

4 distribution system through operational changes or manipulating water quality at the treatment 

5 plant. 

6 

7 

8 4.4.9 Cross Connection Control 

9 

10 Plumbing cross-connections, which are defined as actual or potential connections 

11 between a potable and non-potable water supply, constitute a serious public health hazard. There 

12 are numerous, well-documented cases where cross-connections have been responsible for 

13 contamination of drinking water, and have resulted in the spread of disease. All municipalities 

14 with public water supply systems should have cross-connection control programs. Those 

15 responsible for institutional or private water supplies should also be familiar with the dangers of 

16 cross-connections and should exercise careful surveillance of their systems. (USEPA 2003). 

17 

18 In conducting sanitary surveys of non- community water systems the inspector should 

19 note cross connections and the need for protection during the field survey and make the 

20 owner/operator aware of the cross connection and the need for protection. Areas of special 

21 concern in non-community water systems include auxiliary non- potable water supplies, 

22 irrigation and fire suppression systems, chemical or waste processing and manufacturing 

23 processes. Some non-community water systems may also have very complex plumbing systems 

24 (factories, food processing, power plants) and detailed inspections by a cross connection 

25 specialist would identify needed protection. 

26 

27 In conducting sanitary surveys of community water systems the inspector should review 

28 the program with PWS personnel or ask for contact information if the program is managed by 

29 another agency. Items to be addressed in a review of the cross connection program include: 

30 

31 General 

32 

33 Does the system have an active cross-connection control program? 

34 

35 How is the program administered? (In house, by contract with the water supplier 

36 (wholesaler), coordination with a local agency or by another authority?) 

37 

38 Ordinance or Rules of Service 

39 

40 Has the system adopted an enforceable cross-connection control ordinance or rules of 

41 service? 

42 

43 Are users who are in noncompliance with the cross-connection ordinance or rules of 

44 service given written notice to make corrections? What procedures are used when corrections are 

45 not made by users? 

46 
November 2007 Sanitary Survey 4-51 Draft for Discussion

Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 Cross-Connection Surveys 

2 

3 Has the system conducted a survey of users to determine specific cross-connection 

4 control requirements and problems? 

5 

6 Are premises re-evaluated periodically for backflow hazards? If yes, what is the 

7 procedure? 

8 

9 Are new services reviewed to establish the need for backflow protection? If yes, what is 

10 the procedure and who is responsible for review? 

11 

12 Backflow Protection Provisions 

13 

14 How are bulk water users (hydrant meters, water tankers) addressed? Are hydrant meters 

15 equipped with backflow devices and water tankers inspected? 

16 

17 How is backflow protection provided? (premise isolation, internal protection, 

18 combination) 

19 

20 Who is responsible for installation of backflow devices? 

21 

22 If the user is responsible for installation of devices, is a list of approved backflow devices 

23 provided? 

24 

25 Is the installation of approved backflow devices inspected to determine if they have 

26 proper clearance, drainage, and security? 

27 

28 

29 Program Management 

30 

31 Does the system (or the responsible authority) have personnel with expertise and 

32 authority to conduct cross-connection surveys and to carry out the cross-connection control 

33 program? 

34 

35 Device Testing and Maintenance 

36 

37 Are all backflow devices tested on an annual basis? 

38 

39 Who tests the backflow devices? (PWS, water user, other agency) 

40 

41 Who maintains the backflow devices? (PWS, water user, other agency) 

42 

43 Are follow-up inspections conducted to determine compliance with testing and 

44 maintenance requirements? 

45 

46 Does the system (or someone else) maintain installation, inspection, and testing records 

47 for devices? 

48 

49 
November 2007 Sanitary Survey 4-52 Draft for Discussion

Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 4.5 Finished Water Storage 

2 

3 Finished or treated water storage facilities provide the following benefits to the operation 

4 of a distribution system: 

5 

6 • Allow treatment facilities to operate at or near uniform rates, even though the 

7 demands of the system may greatly fluctuate; 

8 

9 • Supply the peak and emergency needs of the system; and 

10 

11 • Maintain an adequate pressure in the system, when designed for that purpose. 

12 

13 Finished water storage facilities also serve an important function in maintaining the 

14 quality of drinking water ultimately received by the consumer. Proper design, operation, and 

15 maintenance of storage facilities are critical to protecting stored water from loss of chlorine 

16 residual, bacteria regrowth, contaminant entry, and other water quality problems. 

17 

18 The objectives of surveying the finished water storage facilities are to: 

19 

20 • Review the design and major components of storage to determine reliability, 

21 adequacy, quantity, and vulnerability; 

22 

23 • Evaluate the operation and maintenance and safety practices to determine that storage 

24 facilities are reliable; 

25 

26 • Recognize any sanitary risks attributable to storage facilities (UFTREEO Center, 

27 1998); and 

28 

29 • Determine the potential for degradation of the stored water quality. 

30 

31 To accomplish these objectives, the inspector should complete the following tasks: 

32 

33 • Review the information available from State and water system files. 

34 

35 • Perform field inspections to verify the file information, to assess the tank’s structural 

36 condition, operational readiness, site security and potential sanitary risks. 

37 

38 • Check that maintenance identified in storage facility inspections has been completed. 

39 

40 • Discuss current operation and maintenance (O&M) procedures with water system 

41 staff including safety procedures. 

42 

43 Safety is an important consideration in conducting field inspections of storage facilities. 

44 Potential safety hazards include confined space issues; exposure to lead during removal of lead45 based coatings; falls or scrapes when climbing the tank; and insect bites. In some cases, the 

46 results of a recent inspection done by a qualified tank contractor may provide the inspector with 

47 the necessary information without climbing the tank. Some States do not allow their staff to 

48 climb water towers, so inspectors may need to rely on information from tank contractor 
November 2007 Sanitary Survey 4-53 Draft for Discussion

Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 inspections, ground level observations, and conversation with water system operators to verify 

2 file information and assess the adequacy and condition of storage facilities. Inspectors who are 

3 expected to climb storage tanks as part of the tank inspection should receive written inspection 

4 procedures and training in appropriate safety procedures (e.g., use of safety belts and cables). 

5 

6 Specific items to be addressed in the sanitary survey are outlined in the sections below. 

7 

8 

9 4.5.1 Storage Facility Inventory 

10 

11 Before going into the field, the inspector should obtain the information available on all 

12 the finished water storage facilities for the water system from the State’s files, including the last 

13 sanitary survey. The State information should include the type, location, age and installation 

14 date, material of construction, storage volume, operating levels and controls. In addition, the 

15 inspector should review applicable regulatory requirements and industry guidance. 

16 

17 Upon arriving at the facility, the inspector should review the available data with system 

18 personnel to determine if the information is current. If there have been any changes, the 

19 inspector should obtain an updated listing of finished water storage facilities, so that they may be 

20 all inspected during the survey. The system may have historical records that can provide 

21 additional information on storage facility design, construction, operation, maintenance and 

22 current physical condition. These records may include as as-built construction drawings, 

23 inspection reports, maintenance records, water quality data, sediment sampling data, operational 

24 data and customer complaint records from the facilities’ service area. 

25 

26 Regulatory Requirements and Industry Guidelines 

27 

28 Design and Construction. Recommended Standards for Water Works (2003) provides 

29 suggested design criteria for tank storage capacity, siting considerations, tank appurtenances and 

30 safety features. 

31 

32 Operations. Regulatory requirements pertaining to tank operations may include operator 

33 certification requirements, water turnover rates, and emergency operating plans. There are no 

34 specific Federal regulatory requirements on water turnover rates in storage facilities, but industry 

35 guidance suggests that a complete water turnover be accomplished every 3 to 5 days (Kirmeyer 

36 et al. 1999). Most States require that a water system maintain an emergency operations plan 

37 which should include emergency operating procedures for storage facilities. 

38 

39 Maintenance and disinfection procedures. There are no Federal regulatory 

40 requirements for tank maintenance or cleaning procedures. Many States recommend adhering to 

41 AWWA Standards, NSF Standard 61, and Recommended Standards for Water Works (2003). 

42 AWWA Standards and guidance that apply to finished water storage facilities include: 

43 

44 • C652 Disinfection of Water Storage Facilities; 

45 

46 • D100 Welded Steel Tanks for Water Storage; 

47 
November 2007 Sanitary Survey 4-54 Draft for Discussion

Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 • D102 Coating Steel Water-Storage Tanks; 

2 

3 • D103 Factory-Coated Bolted Steel Tanks for Water Storage; 

4 

5 • D120 Thermosetting Fiberglass-Reinforced Plastic Tanks; 

6 

7 • G200 Distribution Systems Operation and Management; and 

8 

9 • AWWA Manual M42 Steel Water Storage Tanks 

10 

11 Most States do not recommend a tank cleaning frequency; however some States provide 

12 guidelines such as “as often as necessary,” and “at reasonable intervals.” An AwwaRF guidance 

13 manual suggests that covered facilities be cleaned every three to five years (Kirmeyer et al. 

14 1999). 

15 

16 Some States have environmental regulations that govern discharge of chlorinated water 

17 from storage facilities. Dechlorination of the water may be required prior to disposal. 

18 

19 Water Quality Monitoring. Federal drinking water regulations do not specifically 

20 require the utility to monitor water quality conditions within storage facilities. Most States do not 

21 require routine water quality monitoring within storage facilities, but some States require that 

22 water samples be free of coliform bacteria before a storage facility is returned to service after 

23 maintenance. Industry guidelines such as the AwwaRF guidance manual, Maintaining Water 

24 Quality in Finished Water Storage Facilities (Kirmeyer et al. 1999) recommend monitoring 

25 within the storage facility to assess stored water quality. 

26 

27 Safety. Several OSHA regulations apply to finished water storage facilities: 

28 

29 • OSHA Fall Protection Standards 

30 (http://www.osha.gov/SLTC/fallprotection/standards.html ) 

31 

32 • Lead Exposure in Construction (29CFR1926.62) 

33 http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS

34 &p_id=10641

35 

36 • Confined Space Rule (29 CFR 1910.146) 

37 http://www.osha.gov/SLTC/confinedspaces/standards.html 

38 

39 Types of Finished Water Storage Facilities 

40 

41 There are several types of finished water storage facilities that can be categorized by their 

42 physical shape, dimensions and location. 

43 

44 Clearwells and Other Chlorine Contact Facilities – These storage facilities are usually 

45 considered to be part of the water treatment plant, and not distribution storage. Some utilities 

46 have storage facilities at or near the water treatment plant that serve both as storage and for 

47 achieving disinfection contact time. 

48 
November 2007 Sanitary Survey 4-55 Draft for Discussion

Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 Ground Storage Tanks – Ground storage tanks are used to reduce treatment plant peak 

2 production rates and are also used as a source of supply for re-pumping to a higher pressure 

3 level. If located at a sufficiently high elevation, a pumping station will not be needed and water 

4 can flow by gravity to the distribution system. Ground storage tanks can be below ground, 

5 partially below ground, or constructed above ground level in the distribution system. Concrete 

6 reservoirs are generally built no deeper than 20 to 25 feet below ground surface. Covered 

7 reservoirs may have concrete, structural metal, or flexible covers. 

8 

9 Elevated Storage Tanks - Elevated storage tanks are used to supply peak demand rates 

10 and equalize system pressures. The most common types of elevated storage are elevated steel 

11 tanks and standpipes. A standpipe is a tall cylindrical tank normally constructed of steel, 

12 although concrete may be used as well. It functions somewhat as a combination of ground and 

13 elevated storage. Only the portion of the storage volume of a standpipe that provides the 

14 required system pressure is considered useful storage for pressure equalization purposes. The 

15 lower portion of the storage acts to support the useful storage and to provide a source of 

16 emergency water supply. Many standpipes were built with a common inlet and outlet. Elevated 

17 tanks are generally located at some distance from the pump station in areas having low system 

18 pressures during high water use periods. 

19 

20 

21 Exhibit 4.9 Elevated and Ground Storage Tanks 

22 

23 ©Arasmith Consulting Resources 

24 (Source: UFTREEO Center, 1988; Used with permission)

25 

26 

27 Hydropneumatic Tanks – Hydropneumatic pressure tanks are commonly used by 

28 systems serving fewer than 150 service connections. The main purpose of hydropneumatic tanks 

29 is to prevent excessive cycling of pumps. These tanks should not be used for fire protection. 

30 They contain a fixed volume of air that becomes compressed as water enters the tank. Once the 

31 pressure in the tank has reached a predetermined level (i.e. the cut-out pressure) the pump stops 

32 and the compressed air starts to expand while it pushes the water into the distribution system. As 
November 2007 Sanitary Survey 4-56 Draft for Discussion

Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 the water leaves the tank, the pressure in the tank decreases until it reaches a point where the 

2 pump will be triggered to start again (i.e. the pump-on level) and the cycle is repeated. The cycle 

3 rate is the number of times the pump starts and stops in one hour (typically 10 to 15 cycles per 

4 hour). 

5 

6 

7 Exhibit 4.10 Typical Hydropneumatic Tank Installation 

8 

9 ©Arasmith Consulting Resources 

10 (Source: UFTREEO Center, 1988; Used with permission) 

11 

12 

13 4.5.2 Capability and Capacity 

14 

15 4.5.2.1 Capability 

16 

17 Water systems should have developed and implemented comprehensive programs to 

18 operate and maintain finished water storage facilities. The existence of written procedures and 

19 policies is especially important for storage facilities to facilitate inter-departmental 

20 communications since personnel from several different departments may share responsibility 

21 (e.g. operations, maintenance, engineering, laboratory). The sanitary survey inspector should 

22 discuss the system’s capability for proper operation and maintenance of their storage facility by 

23 confirming the acceptability of the system’s historical records and recordkeeping practices; 

24 inspection program; standard operating practices; maintenance program; and safety program. 

25 

26 Historical Records and Recordkeeping Practices 

27 

28 Inspection Program 

29 

30 Storage facilities and the grounds surrounding them should be routinely inspected to 

31 prevent water quality problems. It is recommended that water utilities have comprehensive 

32 inspections of the structural condition of their storage facilities every 3 to 5 years, including 

33 areas of the facility that are not normally accessible from the ground. A comprehensive 

34 inspection should include a close evaluation of the condition of interior and exterior coatings, 
November 2007 Sanitary Survey 4-57 Draft for Discussion

Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 foundation, ladder, vent, hatch, overflow pipe, screens, cathodic protection system, and the depth 

2 of the interior sediment. 

3 

4 Standard Operating Procedures 

5 

6 Water utilities are encouraged to have written SOPs for operating their system under 

7 normal and emergency conditions. SOPs are an effective way to prevent miscommunication 

8 among staff responsible for different aspects of a system’s operations and management. SOPs 

9 usually include: 

10 

11 • System description with map; 

12 

13 • Facility descriptions; 

14 

15 • Water quality goals; 

16 

17 • Monitoring plan; 

18 

19 • Description of the operations procedures; 

20 

21 • List of responsible parties for each activity; and 

22 

23 • List of emergency contact people (Kirmeyer et al., 1999). 

24 

25 Excessive water age results from under utilization (i.e., lack of flow) and short circuiting 

26 within the reservoir. Distribution system operations staff have two effective tools to reduce water 

27 age: turn the water over on a routine basis and fluctuate the water levels widely (Kirmeyer et al. 

28 1999). In addition to establishing a theoretical turn over rate (i.e. once in 3, 5 or 7 days); the utility 

29 may need to establish a water level fluctuation approach that will turn over a majority of the water 

30 in one continuous operation. This is especially true for storage facilities with common inlets and 

31 outlets such as standpipes. Simply withdrawing 10% or 20% of the volume of a standpipe each 

32 day and immediately refilling could still leave a major portion of storage volume stagnant or 

33 poorly mixed for long periods. Thus, if feasible, it would be advisable to fluctuate the water level 

34 more widely with a target withdrawal of 60% of the volume in one day and then refill it the next. 

35 This must be balanced with the need to maintain adequate pressures and emergency storage. 

36 

37 Maintenance Program 

38 

39 Does the system keep operational and maintenance records for each tank including 

40 cleaning and painting records, and disinfection procedures (per AWWA G200 standard)? 

41 

42 Has the water system established responsibilities and communication procedures regarding 

43 finished water storage facility operation, maintenance, water quality etc.? 

44 

45 Safety Program 

46 

47 Does system follow OSHA and other safety standards for fall protection, confined space 

48 and lead exposure? 
November 2007 Sanitary Survey 4-58 Draft for Discussion

Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 

2 Does the system have a written program and maintain appropriate permits for confined 

3 space entry? 

4 

5 Training Programs 

6 

7 Does system provide appropriate training for inspection and maintenance staff including 

8 training on OSHA standards, use of safety equipment, and handling of disinfection chemicals? 

9 

10 

11 4.5.2.2 Storage Capacity 

12 

13 Storage tank capacities should be adequate to meet the water demands of the system, 

14 should meet applicable State requirements and industry standards, and be consistent with 

15 accepted engineering practice. For example, the total capacity of both ground and elevated 

16 storage tanks could be based on a recommended level of 200 gallons per connection. For 

17 elevated storage tanks alone, a recommended capacity of 100 gallons per connection is often 

18 used. For systems using hydropneumatic tanks instead of elevated tanks, recommended 

19 capacities are 20 gallons per connection with ground storage and 50 gallons per connection 

20 without ground storage. Capacities for pumps and pumping equipment associated with storage 

21 tanks are discussed in Section 4.6. 

22 

23 Suggested assessment criteria for the capacity of storage tanks include: 

24 

25 In case of elevated storage tanks, are tanks properly sized and elevated to 

26 assure adequate pressures throughout the distribution system? 

27 

28 The water tank should be properly sized and elevated to produce pressures of at least 35 

29 psi at the lowest operating level of the tank. Operating pressures in the distribution system should 

30 not be allowed to exceed 100 psi. 

31 

32 Does the system have adequate storage capacity to meet fire flow requirements, 

33 emergency storage requirements, system pressures and other site-specific 

34 conditions? 

35 

36 For systems that do not provide fire protection, the minimum storage capacity should be 

37 equal to the average day demand or lower if source and treatment facilities have sufficient 

38 capacity and standby power to help meet peak demands. 

39 

40 For hydropneumatic tanks, the gross storage capacity should equal approximately ten 

41 times the largest pump capacity. For example, a 2,500 gallon tank would be advised for a system 

42 using a 250 gpm pump. The sizing of the hydropneumatic tank is also affected by chlorine 

43 contact time requirements and the system’s ability to meet maximum demand conditions. 

44 

45 

46 4.5.3 Design and Construction 

47 

48 The inspector should examine the design criteria of the storage tanks to assess their 

49 potential to meet the water demands of the distribution system and retain structural integrity. 
November 2007 Sanitary Survey 4-59 Draft for Discussion

Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 Design and construction standards need to be appropriate for the intended use of a storage tank. 

2 Most small systems use hydropneumatic tanks. 

3 

4 The series of standards used to design tanks with all the necessary components identified is 

5 usually the AWWA D-100 series. The construction material for the tank should also be examined 

6 for structural integrity as well as for any sanitary hazards. For example, opportunistic pathogens, 

7 such as Klebsiella can grow to high levels in wooden storage tanks. Exhibit 4.11 provides a 

8 schematic of the various components of a storage tank. The following is a listing of the minimum 

9 criteria for a treated water storage tank, whether it is a ground or elevated storage tank: 

10 

11 • Roof sloped to prevent standing water; 

12 

13 • No leakage through the roof; 

14 

15 • A lockable access hatch on the roof, with a raised curb (ten States standards type); 

16 

17 • Vent on the roof with openings that face downward, with a fine corrosion resistant 

18 screen; 

19 

20 • Water level measurement device; 

21 

22 • Overflow that terminates above ground with a hinged and weighted flap on the end; 

23 

24 • Inlet and outlet piping located to ensure proper circulation of water (most have a 

25 single common line); 

26 

27 • Drain to remove accumulated silt from the bottom of the tank; 

28 

29 • Access openings on the side (at least 2); 

30 

31 • Access ladder with proper safety equipment; 

32 

33 • Valves on inlet and outlet for isolation; 

34 

35 • Bypass around the tank for maintenance; 

36 

37 • Control system to maintain water level in tank; 

38 

39 • Alarm system for high/low water levels; and 

40 

41 • Ten States standards type “Inverted U” screened vent. 

42 

43 
November 2007 Sanitary Survey 4-60 Draft for Discussion

Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 Exhibit 4.11 Components of a Storage Tank 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 ©Arasmith Consulting Resources 

25 (Source: UFTREEO, 1998; Used with permission) 

26 

27 

28 Suggested assessment criteria for the minimum design components for storage tanks 

29 include: 

30 

31 Does the tank have all the minimum components listed above? Are these 

32 components in good condition? 

33 

34 The inspection items listed above are important for maintaining the structural integrity of 

35 the tank, thereby minimizing contamination of the water. 

36 

37 The minimum design components for hydropneumatic tanks are significantly different than 

38 a ground or elevated storage tank. Hydropneumatic tank systems can use any of several types of 

39 pressure storage tanks. Exhibit 4.12 depicts the various types of pressure tanks available. Most 

40 small ground water systems use vertical tanks like the two on the right side of the exhibit. 

41 

42 
November 2007 Sanitary Survey 4-61 Draft for Discussion

Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 Exhibit 4.12 Types of Pressure Tanks 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 ©Arasmith Consulting Resources 

16 

17 

18 Suggested assessment criteria for the minimum design components for hydropneumatic 

19 tanks include: 

20 

21 Are air/water interface or captive-air (bladder type) hydropneumatic or pressure 

22 tanks operating as designed? 

23 

24 Design features may include: 

25 

26 • Tank is located completely above ground. 

27 

28 • Tank meets American Society of Mechanical Engineers (ASME) standards with an 

29 ASME name plate attached. 

30 

31 • Access port for periodic inspections. 

32 

33 • Pressure relief device with a pressure gauge. 

34 

35 • Control system to maintain proper air/water ratio for the air/interface. 

36 

37 • Air injection lines equipped with filters to remove contaminants from the air line. 

38 

39 • Sight glass to determine water level for proper air/water ratio. 

40 

41 • Slow closing valves and time delay pump controls to prevent water hammer. 

42 

43 Does the tank have all the minimum components as required? Are these 

44 components in good condition? Is the tank capacity adequate? 

45 

46 The inspection items listed above are important for maintaining the structural integrity of 

47 the tank, thereby minimizing contamination of the water. 

48 
November 2007 Sanitary Survey 4-62 Draft for Discussion

Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 Additional criteria to consider during the sanitary survey when evaluating a water system’s 

2 tanks include: 

3 

4 Does the system maintain adequate system pressure? 

5 

6 Is the storage system designed for direct plumbing or floating on the distribution 

7 system? 

8 

9 Do any tanks operate below the system hydraulic grade line? 

10 

11 Do any tanks have stored water age > 7 days? 

12 

13 Are newly constructed facilities inspected and documented on as built drawings? 

14 

15 Are overflow, drain lines and air vents covered and screened to prevent 

16 animal/insect entry? Are they turned downward and terminated at least 2 pipe 

17 diameters above the ground? 

18 

19 Do tanks have design features that allow maintenance to occur? 

20 

21 Can the tanks be isolated from the system? 

22 

23 Is there a bypass line around the tank for maintenance? 

24 

25 Access openings on side of tank? 

26 

27 Separate drain to remove accumulated silt from the bottom of the tank? 

28 

29 Tank drain pipe allows tank to be drained without causing pressure loss in the 

30 distribution system? 

31 

32 Accessible roof hatches? 

33 

34 Are access ladders equipped with proper safety equipment? 

35 

36 Do tanks have design features that prevent contamination from external sources? 

37 

38 All storage facilities covered? 

39 

40 Roof sloped to prevent standing water? 

41 

42 Is roof watertight? Are all pipe and equipment penetrations into the roof 

43 watertight? 

44 

45 Roof hatches - locked; raised curb and a watertight seal. 

46 

47 Are access ladders inaccessible to the public? 

48 
November 2007 Sanitary Survey 4-63 Draft for Discussion

Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 Are valve pits vandal proof? 

2 

3 Ground level elevation of standpipes and reservoirs above the 100 year flood 

4 elevation and placed at normal ground surface? 

5 

6 Drains and overflow pipe are not directly connected to sewers or storm drains? 

7 

8 Do tanks have design features that prevent degradation of water quality? 

9 

10 Inlet and outlet piping located to ensure proper circulation of water? 

11 

12 Is cathodic protection provided for steel tanks? 

13 

14 Has the installation of appurtenances including antennae completed without 

15 damage to tank structure, coatings or water quality? 

16 

17 

18 4.5.4 Site Security and Sanitary Risks 

19 

20 The inspector should assess the site security of the water system to determine the potential 

21 for intruder access. Any potable water storage tank should be enclosed by an intruder-resistant 

22 fence with lockable access gates. In addition, all access hatches should be locked. The inspector 

23 should assess the site security of the water system to determine the potential for intruder access. 

24 To be intruder-resistant, the Texas Natural Resource Conservation Commission (TNRCC) 

25 recommends that the fence around the storage tank be at least six feet tall with three strands of 

26 barbed wire extending outward at a 45 degree angle, and be constructed of wood, masonry, 

27 concrete or metal. 

28 

29 Suggested assessment criteria for site security include: 

30 

31 Is the fence surrounding the tank site intruder-resistant? 

32 

33 Are access hatches locked? 

34 

35 Have there been any incidents at the system’s storage facilities where site security 

36 was breached, accidents occurred, or water quality was compromised? 

37 

38 Are there any tank sites with particular security or vandalism issues? 

39 

40 Do access manholes, buildings and any other structures have locked entry ways? 

41 

42 Are there any potential sanitary hazards within 50 feet of the storage tank (e.g. 

43 sewers, drains, standing water)? If so, what and where are the hazards? (e.g. bird 

44 droppings on tank roofs, evidence of insects or animal activity near vents, drain 

45 pipes; evidence of unauthorized human access to site). 

46 

47 Are there any physical features on or around the site that could damage the tank? 

48 
November 2007 Sanitary Survey 4-64 Draft for Discussion

Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 Is the site well-maintained? 

2 

3 Is there adequate surface drainage around tank? 

4 

5 Is the site subject to flooding? 

6 

7 Are there any structural gaps in the storage facilities that would allow untreated 

8 water or contaminants to enter the storage facility? 

9 

10 

11 4.6 Pumps 

12 

13 In addition to transporting water through the system, pump applications include chemical 

14 feed systems, sludge removal, air compression and sampling (UFTREEO Center, 1998). For a 

15 given application, there could be several viable pumping options. However, there are usually 

16 only one or two types of pumps that will be the best fit for the intended use. In this section, the 

17 prime movers of water will be discussed. There are numerous applications for other types of 

18 pumps in other sections of this document. 

19 

20 The objectives of surveying the pumps/pump facilities and controls are to: 

21 

22 • Review the design, uses, and major components of water supply pumps; 

23 

24 • Evaluate the operation and maintenance as well as safety practices to determine that 

25 water supply pumping facilities are reliable; and 

26 

27 • Recognize any sanitary risks attributable to water supply pumping facilities 

28 (UFTREEO Center, 1998). 

29 

30 

31 4.6.1 Typical Pumps 

32 

33 Before going into the field, the inspector should obtain the information available on all 

34 the pumping facilities for the water system from the State’s files, including the last sanitary 

35 survey. The information on pumping facilities should include the type, location, age and 

36 installation date, and design conditions of the system’s pump(s), pumping facilities, and controls. 

37 

38 In addition, the inspector should review the regulatory requirements for pumps, if any, to 

39 assist in the evaluation of the pumping facilities. The regulatory requirements could include, but 

40 not necessarily be limited to, State rules and regulations, American National Standards 

41 Institute/National Sanitary Foundation (ANSI/NSF) Standards 60 and 61, as well as appropriate 

42 guidance manuals. 

43 

44 Upon arriving at the facility, the inspector should review the available data on pumps 

45 with system personnel to determine if the information is current. If there have been any changes, 

46 the inspector should obtain an updated listing of the pumps used within the system, so that they 

47 may be all inspected during the survey. For most systems, the inspector will either have a list of 

48 pumps or pump data from a previous sanitary survey or have a list supplied by the system 
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1 operator. If a system does not have a pump listing, the inspector should work with the system 

2 operator to develop a new listing so that all pumps may be inspected during the survey. 

3 

4 There are two main classes of pumps used in a water treatment facility. They are positive 

5 displacement pumps and centrifugal pumps. Positive displacement pumps deliver water at a 

6 constant rate regardless of the pressure it must overcome (USEPA 1991). Typical pumps that 

7 can be found in a treatment plant are: 

8 

9 • Helical or Spiral Rotor Pump – This pump consists of a shaft with a spiral surface 

10 that rotates in a rubber sleeve. Water is trapped between the shaft depressions and the 

11 sleeve and is forced to the upper end of the sleeve as the shaft rotates. 

12 

13 • Regenerative Turbine Pump – This pump contains an impeller or a rotating wheel 

14 with fins or little buckets on its outer edge. The rotating wheel is inside a stationary 

15 enclosure (cast). As the wheel rotates at a high speed, it forces water through the 

16 pump cast (also called raceway) at a pressure that is several times that which can be 

17 generated by centrifugal mechanisms (USEPA, 1991). 

18 

19 • Reciprocating Pump – This pump consists of a piston moving back and forth in a 

20 cylinder. As the cylinder is driven back and water is driven into the cylinder, the 

21 intake valve closes and forces the water through the check valve. As the cylinder is 

22 driven forward, the water is discharged through a discharge pipe while the check 

23 valve is closed (USEPA, 1991). 

24 

25 • Positive Displacement Pump – This pump is typically used for online chemical 

26 application (i.e., application of chemicals into pressurized water line). 

27 

28 Centrifugal pumps are used when an even flow rate is needed to meet the demands placed 

29 on it. The operating curve for a centrifugal pump shows that the pumping rate varies with the 

30 discharge pressure of the water at discharge from the pump (i.e., as the discharge pressure 

31 increases, the rate of pumping decreases). 

32 

33 With a rotating impeller (i.e., rotor blade) driven by a power source, such as a motor, a 

34 centrifugal pump increases the velocity of the water and discharges it into the pump casing. In 

35 the pump, the velocity of the water is converted to pressure. Typically, a centrifugal pump has 

36 only one impeller, and it is called a single-stage pump. If more pressure is needed, multiple 

37 impellers or multi-stages are used to generate the necessary discharge pressure at the pump. 

38 Multiple impellers only increase the discharge pressure, not the pumping rate (UFTREEO 

39 Center, 1998). 

40 

41 A centrifugal pump cannot create a negative pressure at the suction inlet to pull water 

42 into the pump, like a self-priming pump. Therefore, the pressure at the impeller must be positive 

43 (i.e., water level is higher than the impeller) in order for the pump to operate. 

44 

45 There are three types of centrifugal pumps that are normally used in a water system for 

46 the many pumping applications: submersible, vertical (lineshaft) turbine, end suction (close 

47 coupled) and split case. The most common application of each pump is provided in Exhibits 

48 4.13 and 4.14 shows some of the types as well as the basic components of a centrifugal pump. 
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Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 

2 The three types of centrifugal pumps are described below: 

3 

4 • Vertical Turbine Pump – This is a multistage centrifugal pump. The pumping unit 

5 must be located below the drawdown level of the water source. A vertical shaft 

6 connects the pumping assembly to a drive mechanism located above the pumping 

7 assembly. The discharge casing, pump housing, and inlet screen are suspended from 

8 the pump base at ground surface. 

9 

10 • Submersible Pump – This is a centrifugal pump driven by a closely coupled electric 

11 motor constructed for underwater operation as a single unit. 

12 

13 • End Suction and Split Case Pumps – These are single-stage pumps. The end 

14 suction pump is a vertically split case pump, while the split case pump is horizontally 

15 split. The advantage of the split case pump over the end suction pump is that it is 

16 easier to open and repair. The advantage of the end suction pump is its lower cost. 

17 

18 

19 Exhibit 4.13 Applications for Centrifugal Pumps 

20 

Application Type of Pump 

Well Pump Submersible or vertical turbine 

Raw Water Pump Submersible or vertical turbine 

Backwash Pump Vertical turbine or split case 

Transfer Pump Vertical turbine, end suction, or split case 

Finished Water Pump Vertical turbine, end suction, or split case 

Booster Pump Split case or end suction 

Sludge Pump End suction 

Backwash Recycle Pump End suction 

21 
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Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 Exhibit 4.14 Common Centrifugal Pump Types and Components 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 ©Arasmith Consulting Resources 

35 (Source: UFTREEO, 1998; Used with permission) 

36 

37 Suggested assessment criteria for the types of pumps include: 

38 

39 What types of pumps are provided for the system? 

40 

41 The inspector should check the types of pumps used by the water system to ensure they 

42 are appropriate for the intended use. Typically, the pump selection is reviewed by the primacy 

43 agency at the time of installation; however, the inspector should confirm that the pump has not 

44 been replaced with another type of pump without approval from the primacy agency. 

45 
November 2007 Sanitary Survey 4-68 Draft for Discussion

Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 Does the information in the files reflect the actual type, number, and capacity 

2 of pumps in the system? If not, is there a potential problem? 

3 

4 If the inspector finds that the actual type, number or capacity of the pumps is different 

5 from the design that was approved by the primacy agency, then the inspector should note the 

6 actual configuration for the sanitary survey report. The operators should be questioned as to why 

7 and when the modification to the pumps took place, and advised to submit the revised plan to the 

8 primacy agency for their review, if necessary. 

9 

10 

11 4.6.2 Number and Capacity 

12 

13 The pump capacity or size required is typically dependent on the application or purpose, 

14 as well as vulnerability of the pump(s). Typically, State rules will specify the sizing criteria for 

15 each critical application. For example, Exhibit 4.15 provides the sizing criteria for different 

16 pump applications used by the TNRCC for many water systems. These criteria are in general 

17 agreement with standard engineering practice. However it should be noted that the criteria for a 

18 PWS depend on the size and type of system. For example, 25 connections would require a 15 

19 gpm pump. 

20 

21 

22 Exhibit 4.15 Pump Sizing Criteria 

23 

Application Sizing Criteria 

Raw Water Pump 0.6 gpm per connection with the largest pump out of service 

Backwash Pump Dependent on filter size 

Transfer Pump 0.6 gpm per connection with the largest pump out of service 

Finished Water Pump Two or more pumps that have a capacity of 2.0 gpm per 

connection, or that have a total capacity of at least 1,000 gpm and 

the ability to meet peak hourly demands with the largest pump out 

of service, whichever is less 

Booster Pump Two or more pumps that have a capacity of 2.0 gpm per 

connection, or that have a total capacity of at least 1,000 gpm and 

the ability to meet peak hourly demands with the largest pump out 

of service, whichever is less 

24 (Source: TNRCC, 1997) 

25 

26 

27 When designing or checking a pumping facility, the maintenance (preventative or 

28 emergency) of the pumps should be anticipated. For instance, a system has two raw water 

29 pumps, and each is sized to pump one-half the capacity of the water treatment facility. If one 

30 pump has to be taken out of service for repairs, then the supply for this system is reduced 

31 substantially. During the summer, when the peak demand typically occurs, this system may not 

32 be able to meet that demand for a time, because of the repairs to the pump. During this time, the 

33 system may experience pressure problems in the distribution system due to an inadequate supply, 

34 which could lead to greater problems, such as backsiphonage. The number of pumps for any 

35 application is an important consideration that cannot be overlooked. In general, there should be 

36 at least two pumps (usually more) for any critical pumping application to allow for maintenance. 

37 
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1 With two or more pumps, how should the capacity of a pump or pumping facility be 

2 determined? The firm capacity of any pumping facility should be determined with the largest 

3 pump out of service to ensure that adequate capacity is available to meet all expected 

4 demand/supply conditions. The firm capacity of a pumping facility is the capacity that is 

5 available at any time assuming any one pump is out of service for maintenance or repairs. The 

6 total capacity of a pumping facility is the sum of the capacities of all associated pumps and is 

7 larger than firm capacity. 

8 

9 Suggested assessment criteria for the capacity of pumps include: 

10 

11 What are the capacities of the pumps? How many pumps are located at each 

12 facility? 

13 

14 The capacity of a pump is sometimes listed on the motor plate along with the horsepower, 

15 motor speed and other pertinent information. The inspector should note the capacity or other 

16 information provided on each pump and compare this information to the approved design for the 

17 pump station. The actual capacity of the pump may be less than the rated capacity as a result of 

18 wear or an increase in the operating head. Actual pump capacity can be measured if an accurate 

19 flow metering device is installed on the pump discharge line. 

20 

21 What is the firm capacity and the total capacity of each pumping facility? 

22 

23 The inspector should confirm that the firm capacity of the pumping facility, or the 

24 capacity of the facility with its largest pump out of service is consistent with the minimum 

25 capacity approved by the primacy agency. 

26 

27 Is priming adequate? 

28 

29 The inspector should ensure that prime waters must not be of a lesser sanitary quality 

30 than that of the water pumped. It should be ensured that there are adequate backflow prevention 

31 devices. When an air-operated ejector is used, the screened intake should draw clean air from a 

32 point at least 10 feet above the ground or other possible sources of contamination. 

33 

34 Are the pumps compliant with State rules? 

35 

36 If the inspector finds that the actual type, number, or capacity of the pumps is different 

37 from the design that was approved by the primacy agency, then the inspector should note the 

38 actual configuration for the sanitary survey report. The operators should be questioned as to why 

39 and when the modification to the pumps took place, and advised to submit the revised plan to the 

40 primacy agency for their review, if necessary. 

41 

42 

43 4.6.3 Routine Maintenance/Lubrication/Exercise 

44 

45 The inspector should ask whether the system has a pump maintenance program and how 

46 it is being implemented. Backup pumps should be exercised routinely and all pumps should be 

47 operational. Pumps should be accessible so they can be properly maintained and repaired 

48 without physically disrupting other elements of the water system. Most well houses will have a 
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1 hatch in the roof or a similar structural arrangement to provide access to the well in case the 

2 submersible pump needs to be removed. 

3 

4 For any wells where contact is made with the water, food grade lubricants should be 

5 used. Many States require lubricants used under such conditions (e.g., oi-lubricated well shaft 

6 bearings, check valves) to be ANSI or NSF-approved. This is not usually a requirement for 

7 lubricants that do not come in contact with the water. All lubricants should be applied according 

8 to manufacturer’s specifications. 

9 

10 

11 4.6.4 Housing 

12 

13 Pumps are found in a variety of buildings including well houses, treatment plants and 

14 booster stations. As part of the sanitary survey, these buildings should be inspected to ensure 

15 they are providing secure physical protection to the pumps. A pumping station should be at least 

16 three feet above flood level, and the land around it should be graded so that surface runoff drains 

17 away from the building. Inside, floor drains should be able to accommodate a large volume of 

18 water due to a pipe break in the building. Below-ground pump stations should be checked to 

19 make sure they are dry and properly sealed so that water cannot seep through walls or enter from 

20 the surface. Dry pits should include a sump and sump pump. Pump stations should be properly 

21 ventilated and electrical controls and motors should not be subject to flooding. 

22 

23 

24 4.6.5 Site Security 

25 

26 Pumping stations and well houses should be secure. Doors and windows should be 

27 locked and no unauthorized entry should be allowed. Any electrical panels, switches and valves 

28 located outside of the building should be secured and within a fenced perimeter. 

29 

30 

31 4.6.6 Cross Connections 

32 

33 When pumps are being inspected during the survey, any situation where there is a 

34 potential for backflow should be identified. Cross connections can be found in 

35 

36 • Water lubricated bearing systems, 

37 

38 • Pump seal water lubrication systems, 

39 

40 • Air/vacuum release discharge lines, and 

41 

42 • Priming lines for suction-lift pumps (USEPA, 2003). 

43 

44 Situations where there is the potential for backflow should be equipped with an air gap or 

45 an approved backflow prevention device. 

46 

47 
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1 4.7 Emergency Power 

2 

3 During a sanitary survey, the inspector should consider whether a system needs auxiliary 

4 power to maintain a reliable source of potable water to its customers. Systems with auxiliary 

5 power units should be exercising them routinely, and operators should have a clear 

6 understanding of what the unit powers and how it is activated. The sanitary survey inspector 

7 should establish whether auxiliary power is triggered manually or automatically, and that the 

8 system has a reliable program in place for switching to the emergency power supply. 

9 

10 Suggested assessment criteria for evaluating emergency power include: 

11 

12 Is auxiliary power needed? 

13 

14 Auxiliary power may be necessary for the continuous operation of a water system. When 

15 assessing whether a system needs auxiliary power, consider how long the system can reliably 

16 continue to provide water when it loses power. Also consider how frequently the system loses 

17 power and the duration of power outages. Systems with limited storage may not be able to 

18 sustain water production for very long. Systems relying on pumps to move water to their 

19 distribution system may not be able to provide sufficient water and maintaining adequate 

20 pressure throughout their distribution systems. 

21 

22 How is it activated? 

23 

24 Auxiliary power should be automatically activated when the primary power supply is 

25 lost. There should be a switch that automatically transfers the load to the auxiliary power unit. 

26 An alarm should notify the operator when the auxiliary power unit is turned on. Although 

27 auxiliary power should be automatically activated, operators should have the capability of 

28 manually operating their generators. 

29 

30 Small ground water systems that do not have generators on site should, at a minimum, be 

31 able to hook up a generator quickly and safely. Pump houses or treatment plants can be wired so 

32 generators can be connected quickly at the time of the power outage. If such an arrangement is 

33 observed during the sanitary survey, information should be gathered about the location of the 

34 generator that would be used during an outage and the system’s plan for responding and 

35 installing the generator in a way that does not result in interruption of service. 

36 

37 What does it supply power for? 

38 

39 The operator should know what steps of water production, treatment and delivery would 

40 be powered by emergency power in the case of a power outage. During the sanitary survey, the 

41 inspector should determine whether the quantity and quality of water needed by the system’s 

42 customers could be maintained and for how long. In addition to the well pump, auxiliary power 

43 should operate any automatic controls and chemical feed systems related to the source that is 

44 being pumped. Lights, heat and ventilation in the pump house and treatment plant should also be 

45 provided with emergency power. 

46 
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1 Where is the fuel tank? 

2 

3 The sanitary survey inspector should locate the fuel tank for the auxiliary power unit and 

4 evaluate if it presents a contamination risk to the well or water that is being stored before or after 

5 treatment. Fuel tanks that are stored above ground should be mounted inside a spill containment 

6 vessel. 

7 

8 Is the unit exercised? 

9 

10 Auxiliary power units should be exercised at least once a week with an operator in 

11 attendance (USEPA, 2003). It is preferred that the unit be tested under a load during the 

12 exercising period, using it as the source of power for any well, treatment and service pumps that 

13 would be powered by the unit under emergency conditions. The system should keep records of 

14 when and how the unit was exercised, including engine and generator gauge readings, and the 

15 inspector should review these records during the sanitary survey. 

16 

17 Is it well-maintained? 

18 

19 Regular maintenance of the auxiliary power unit should be provided according to its 

20 manufacturer’s specifications. If the water system has a preventive maintenance program, the 

21 inspector should ask whether the unit is included in the plan. The inspector should visually 

22 check for signs of leaking fluids or lubricants. Any vents in the building housing the unit should 

23 be screened to prevent animals from entering and to maintain security. The unit should not be 

24 accessible to the public. 

25 

26 

27 4.8 Remote Monitoring/Control/Alarms 

28 

29 Many water systems have some element of remote signaling or operation. Often, a 

30 pressure transducer in a storage tank relays a signal that turns the well on or off when the tank 

31 level reaches a set level. Some alarms with automatic dialing systems notify operators under 

32 emergency conditions. More and more, plants equipped with SCADA systems are being 

33 operated remotely. 

34 

35 The sanitary survey inspector should understand the roles of any remote control 

36 monitoring and alarms at a water system. During the survey, each step of the water system’s 

37 operation should be considered and it should be determined whether the step is carried out 

38 manually or automatically. 

39 

40 Some assessment criteria to consider when reviewing remote monitoring/control/alarms 

41 include: 

42 

43 How are the well pumps controlled? 

44 

45 The inspector should evaluate the control system and determine if it is suitable for its 

46 application. Automatic well pump controls should be equipped with resets and a manual 

47 override switch. Pumps supplying water to the distribution system should be equipped with a 

48 switch that is triggered based on distribution system pressure. 

49 
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1 Are pressure tanks properly plumbed? 

2 

3 Pressure tanks whose primary goal is to control the cycling of pumps should be equipped 

4 with a pressure switch that cycles the pump on and off. In order for this to operate correctly, the 

5 inspector should make sure there is no shut-off valve between the pressure switch and the pump. 

6 If such a valve is closed, the system will call for water and the pump will begin pumping against 

7 a closed valve, most likely damaging the pump. 

8 

9 Are appropriate alarms in place and operational? 

10 

11 Well houses, treatment plants and booster stations should be equipped with alarms to 

12 notify their operators when there is a problem with the pumping, treatment or delivery of the 

13 water. Some of these alarm systems are much more sophisticated than others. The sanitary 

14 survey operator should determine whether the approach a system has to notify its operators in 

15 case of an emergency is sufficient for effectively maintaining the operation of that system. 

16 

17 

18 4.9 Monitoring/Reporting/Data Verification 

19 

20 An important part of any industry that produces a product for the consumer is quality 

21 control. Quality control is a defined method of checking the product to ensure the consumer it 

22 meets or exceeds regulatory requirements as well as their minimum expectations. For the water 

23 industry, quality control consists of monitoring water from the source to the tap with in-house as 

24 well as outside laboratory testing for confirmation. A monitoring plan provides the operator with 

25 data to assist in identifying potential problems and adjusting treatment processes accordingly. It 

26 is important that all water systems create a water quality monitoring plan and document 

27 monitoring results. For most water systems, regulatory requirements, either State or Federal, 

28 dictate the minimum scope of a water quality monitoring plan. 

29 

30 The objectives of surveying the water quality monitoring/reporting/data verification are 

31 to: 

32 

33 • Review the water quality monitoring plan of the PWS for conformance with 

34 regulatory requirements; 

35 

36 • Verify that the water quality monitoring plan is being followed by checking test 

37 results; 

38 

39 • Verify that all in-house testing as well as equipment and reagents being used conform 

40 to accepted test procedures; 

41 

42 • Verify the data submitted to the regulatory agency; and 

43 

44 • Evaluate the procedures an operator follows to identify any problems with the 

45 process, determine the changes needed to correct the problem, and how adjustments 

46 to the process are approved and performed as needed. 

47 
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1 If there are no violations or orders, and the required monitoring data are available, it is an 

2 indication that the water system has accepted its assigned responsibilities and is trying to 

3 complete its duties accordingly. In general, the inspector will only have to verify that all 

4 sampling and monitoring plans are up-to-date based on the latest regulatory changes, if any. In 

5 addition, the inspector will verify that the data reported to the agency are accurate based on the 

6 records kept by the system. Self-monitoring data, monthly operating reports, and daily logs 

7 should be reviewed to determine if data are of questionable quality and to evaluate the potential 

8 for data falsification. 

9 

10 If there are no violations or orders, but the required monitoring data are not available, it 

11 may be difficult to determine if the water system is in compliance with all requirements. 

12 Laboratory results for bacteriological, chemical, and radiological monitoring must be kept for 

13 specific time periods. The inspector should review the records to determine if they are kept for 

14 the required time period in accordance with each regulation. 

15 

16 The inspector should carefully review the compliance plans required as a result of a 

17 violation or by any orders and verify that the plan is being followed by the system. If all the 

18 required monitoring data are not available, the inspector should determine the reason. 

19 

20 Suggested assessment criteria for data collection include: 

21 

22 Are there any violations or orders for the subject system? If so, is there a 

23 compliance plan? If so, what documentation is there to verify compliance? 

24 

25 If the treatment plant has submitted a compliance plan, the inspector should take copies 

26 of the plan to verify that the compliance plan is being properly implemented. 

27 

28 Have the required sampling plans been submitted and approved? If no, 

29 what action is being taken to prepare and submit the plans? 

30 

31 Every water system has to submit a sampling plan to be approved by the State. Such a 

32 plan should include the number of samples for each parameter, where samples are taken, at what 

33 time and frequency, who is the person in charge of taking the samples, how they are going to be 

34 handled, and who is going to analyze them. 

35 

36 Are all the required monitoring data submitted? If so, do the data appear 

37 reasonable? Do the data reported match field log books? 

38 

39 If a plant has complete, up-to-date, reasonable monitoring data, this is an indication that it 

40 is well managed. However, it is still necessary to verify field log books with submitted reports to 

41 rule out any human error in copying the data. 

42 

43 Are records of the monitoring program maintained in an organized and complete 

44 manner? 

45 

46 The results of the monitoring program should be kept in an organized system and should 

47 be accessible for review. 

48 
November 2007 Sanitary Survey 4-75 Draft for Discussion

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1 Additional questions that an inspector should consider during the sanitary survey include: 

2 

3 Are treatment systems monitored (e.g. flows,pressures,tank elevations,pumps) 

4 appropriately? Are treatment adjustments made as a result of monitoring results? 

5 

6 Are records kept of when and how treatment steps are taken and chemical mixtures 

7 (e.g., feed solutions) are prepared? 

8 

9 Does the water system have a preventive maintenance program and records? 

10 

11 Does the system document when repairs are made? 

12 

13 Do they have a system for logging and responding to customer complaints? 

14 

15 

16 4.10 Water System Management/Operations 

17 

18 Management and/or administration is a major factor that affects the performance of a 

19 water system. Management provides the direction, funding, and support that is needed for a 

20 PWS to continually supply safe drinking water. For instance, if management does not 

21 understand the requirements to produce and provide the quality of drinking water demanded by 

22 the consumer, policies may be implemented that hinder the performance of the system and its 

23 ability to provide what the consumer wants. Therefore, management and staff need to work 

24 together to create an environment that facilitates meeting the goal of providing the best possible 

25 quality of drinking water to the consumer. 

26 

27 The objectives of surveying the water system management/operation are to: 

28 

29 • Review the water quality goals and evaluate any plan(s) the system has to either 

30 accomplish or maintain the stated goals; 

31 

32 • Identify and evaluate the basic information on the system, management, staffing, 

33 operations, and maintenance; 

34 

35 • Review and evaluate the plan(s) for safety, emergency situations, maintenance, and 

36 security to maintain system reliability; and 

37 

38 • Evaluate the system’s revenue and budget for drinking water to establish the long39 term viability of meeting water quality goals (UFTREEO Center, 1998). 

40 

41 

42 4.10.1 Organization and Management (TMF Capacity) 

43 

44 The direction of the system is controlled by the system’s management through the 

45 implementation of the budget and policies. During the inspection, the knowledge and experience 

46 of these individuals concerning drinking water should be verified. As an example, if the 

47 individual at the top of the management structure has little or no experience with a water system, 

48 then the implemented budget and policies may reflect that lack of knowledge in determining how 
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1 the system is operated and maintained. If the individual has the knowledge, then the water 

2 system will probably be operated and maintained differently. Therefore, the knowledge and 

3 experience that management has with water systems plays an important role in how a system is 

4 operated and maintained. 

5 

6 Another impact that management can have is on the morale of the personnel. A positive 

7 atmosphere is generated if the management encourages an open dialogue between all levels. 

8 This open communication allows the workers to express their opinion without fear of reprisal. 

9 Encouraging the training and advancement of personnel will also foster a positive morale. 

10 Although, there will be some expenses incurred on the part of the utility, this effort shows that 

11 management wants their employees to gain the knowledge necessary to further their careers. 

12 

13 Suggested assessment criteria for system management include: 

14 

15 What is the management structure, and who are the individuals at the 

16 various levels? What is their experience level with water systems? 

17 

18 If the water system has an organizational chart, the inspector should review the chart to 

19 gain an understanding of the system’s management structure and that individuals are responsible 

20 for the different elements of system operation and management. The system needs to have a 

21 means of clearly indicating to its own staff who has the responsibility for various functions and 

22 who has the authority to make decisions and approve changes to policies, procedures, system 

23 operations, and other areas pertinent to treatment plant performance and water supply quality. 

24 Personnel in positions of responsibility and management should be experienced with and 

25 knowledgeable about drinking water systems and their operation, and have detailed knowledge 

26 about their own system and its performance and needs, as well as the regulatory requirements 

27 that apply to their system. 

28 

29 Does the water system have a planning process? Does the planning process 

30 appear to be implemented? 

31 

32 Water system management should be actively involved in planning for the system. 

33 Efforts should include both short-term and long-range planning horizons. The system should 

34 have a process for developing and updating plans required under applicable regulations, such as 

35 compliance monitoring, source protection, and cross-connection control, as well as other plans 

36 integral to a well-functioning water system, such as annual and long-term budgets, equipment 

37 purchases, and facility expansion. 

38 

39 Does open, effective communication occur between management and system 

40 personnel? 

41 

42 Open, effective communication between management and operations staff is integral to 

43 the achievement of a system’s water quality goals for the production of a reliable, high-quality 

44 water supply. System personnel should have a means of adequately conveying to management 

45 the need for additional equipment and personnel and changes in facility policies and procedures, 

46 and for providing input to budgeting and system expansion plans. Management needs to be 

47 receptive to staff input and committed to seeking it and using it. 

48 

49 
November 2007 Sanitary Survey 4-77 Draft for Discussion

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1 4.10.2 Staff Levels 

2 

3 The inspector should determine if a list of job descriptions for system personnel is 

4 available. The inspector can use this information to assess whether or not the system seems to 

5 have an adequate number of qualified personnel to perform all the necessary work within the 

6 system from operations to maintenance. One indicator of sufficient personnel is that little or no 

7 overtime is required to adequately perform operations and maintenance. The inspector should 

8 also evaluate the relative distribution of personnel between operations and maintenance 

9 positions. If the PWS is operated under contract to a private company, the availability of staff 

10 familiar with the plant should be assessed. To have a well operated and maintained facility, there 

11 should be a good mix of responsibilities and personnel, and personnel should have some cross12 training between operations and maintenance. 

13 

14 Suggested assessment criteria for system staffing include: 

15 

16 Is the number of personnel adequate to perform the work required? 

17 

18 The size of the facility and the types of treatment largely determine what level of 

19 personnel is sufficient. The system should have enough personnel to enable continuous 

20 operation of the treatment plant at all times, including periods when some staff are absent (e.g., 

21 vacations, weekends, holidays). Staff should be able to perform operations and maintenance 

22 tasks regularly with little or no overtime hours. In addition to having an adequate number staff 

23 overall, the system should have staff appropriately assigned to operations tasks and maintenance 

24 tasks. 

25 

26 Is plant coverage adequate given the alarm systems used by the plan? Do 

27 variations in finished water quality when the plant is unattended indicate the 

28 need for additional plant coverage? 

29 

30 During periods when the plant is unattended or treatment processes are monitored by 

31 alarm systems rather than personnel, fluctuations in finished water quality may increase. The 

32 inspector should evaluate whether the system’s personnel and its use of alarm systems are 

33 adequate to promptly address variations in finished water quality. 

34 

35 Do staff have clearly defined responsibilities and the decision making 

36 authority necessary to carry out their responsibilities? 

37 

38 System staff need to clearly understand their responsibilities and have the authority to 

39 make any decisions, such as hiring and scheduling personnel and altering elements of treatment 

40 plan operation (e.g., equipment shutdowns for maintenance, changes to chemical doses), that are 

41 necessary to fulfill their responsibilities in a timely manner. System staff should also sufficiently 

42 understand the responsibilities of other personnel so they know who to approach with issues or 

43 questions. 

44 

45 Is there cross-training required of the individuals within the system? 

46 

47 Some cross-training of employees between operations and maintenance provides the 

48 facility with staffing options during unexpected periods of staff absences (e.g., illnesses) and 

49 times when the work load balance between operations and maintenance shifts. Cross-training 
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1 may also enable staff to better carry out their responsibilities because they have a better 

2 understanding of other aspects of water treatment. 

3 

4 

5 4.10.3 Training 

6 

7 Water system personnel are encouraged to receive training on an ongoing basis. Most 

8 operators are required to obtain continuing education credits in order to maintain their 

9 certification. Operators can also learn from their peers by actively participating in their local 

10 water works association’s conferences and workshops. Inspectors should confirm that operators 

11 know what their continuing education requirements are, and they are encouraged to provide 

12 operators with any information they may have about suitable upcoming classes. 

13 

14 Suggested assessment criteria for adequacy of training include: 

15 

16 Are water system staff prepared and capable of performing their duties? 

17 

18 Staff should understand all compliance requirements including monitoring, 

19 recordkeeping and reporting requirements. Operators should be properly trained so they 

20 understand how they should be running and maintaining their system. Sanitary survey inspectors 

21 should verify that operators have been appropriately trained to run any new kind of treatment 

22 that has been installed. 

23 

24 Are operators receiving the training required for them to maintain their 

25 certification? 

26 

27 The inspector should check that operators understand their continuing education 

28 requirements and that opportunities for satisfying those requirements become available to them. 

29 

30 

31 4.10.4 Revenue 

32 

33 When reviewing the budget and rate structure, one of the most important questions to 

34 consider when determining adequacy is “Is the system a self-supporting utility?” A self35 supporting utility means that the revenues are such that all budgetary requests are met, with some 

36 excess reserves remaining for future improvements or emergencies. These reserves would 

37 normally stay within the utility budget. However, some systems may apply these reserves to 

38 other portions of the overall budget of the city or board. In other words, the water system may 

39 subsidize other departments within the city or board. 

40 

41 After reviewing the budget and revenues to determine if the system is self-supporting, the 

42 budget should be reviewed to determine that there is adequate funding allocated to the 

43 maintenance of the equipment within the system, as well as for providing an adequate number of 

44 personnel to operate and maintain the system properly. Data from other systems may help in this 

45 analysis. In comparing two similarly sized systems, any significant differences between the two 

46 systems can be evaluated to see if they may be part of the reason for any problems being 

47 experienced. 

48 
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1 Suggested assessment criteria for adequacy of revenues/budget include: 

2 

3 Is the system self-supporting? 

4 

5 Water rates should be set at a level such that fees collected adequately cover operating, 

6 maintenance, and replacement costs. If there is an imbalance, the inspector should evaluate how 

7 the imbalance may be impacting the system’s performance and its ability to provide a reliable 

8 supply of high-quality water. 

9 

10 Is there money to provide the appropriate maintenance and to support the 

11 number of personnel to operate the system correctly? 

12 

13 System funding needs to adequately support facility operation and maintenance, and 

14 should include funding for an appropriate level of staff that are properly trained. Funds need to 

15 be budgeted for future expenses such as equipment purchases and facility expansion, as well as 

16 current expenses associated with staff salaries and training, electricity, chemical stocks and 

17 equipment replacement parts, and other day-to-day expenses. The system should have a method 

18 for prioritizing its needs so that funds are expended on the most essential items first. The 

19 inspector should ask operations and maintenance staff about its procedures for and past 

20 experiences with obtaining needed supplies, equipment, and staff to determine if staff encounter 

21 difficulties due to budget problems. The system should have a reserve or sinking fund where 

22 excess revenues are held and accumulated for use on future purchases and improvements and 

23 emergencies. 

24 

25 Does the water system subsidize other departments within the city or board? 

26 If so, is funding that is returned to the water utility sufficient to meet 

27 operation and maintenance requirements and address future growth? 

28 

29 To assess this, the inspector should interview personnel that are responsible for the water 

30 system budget, ask operator about plant funding, and examine the budget. 

31 

32 How does this system compare to others? 

33 

34 If the inspector has financial data on other systems, comparisons can be made that may 

35 aid in determining the adequacy of a system’s budget/revenues. 

36 

37 Are financial reserves available to the system if it needs to make significant changes 

38 to its treatment or infrastructure? Does the system have a Capital Improvement 

39 Plan? 

40 

41 The inspector should ask whether the water system has a plan to address long-term 

42 infrastructure upgrades and new regulatory requirements. 

43 

44 
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1 4.10.5 Additional Management Issues 

2 

3 The sanitary survey inspector should learn the status of other management issues that are 

4 related to the water system as it seems appropriate. Additional questions that should be 

5 considered include: 

6 

7 Is overall security effectively maintained for the water system? 

8 

9 Has the system prepared a vulnerability assessment? Do they have an Emergency 

10 Response Plan that is exercised regularly? 

11 

12 Does the system have a systematic repair and replacement program for the 

13 components of its source, treatment plant, storage and distribution systems? 

14 

15 Is there effective communication between management staff, operations staff and 

16 the regulatory agency? 

17 

18 Are the operational, managerial, and fiscal arms of the water utility working 

19 together in a cooperative manner? If not, are their problems adversely affecting the 

20 treatment and delivery of acceptable drinking water? 

21 

22 Does the system participate in any mutual aid agreements? 

23 

24 

25 4.11 Operator Requirements 

26 

27 4.11.1 General Operator Requirements 

28 

29 The need for qualified professionals to operate and maintain water systems is becoming 

30 increasingly important in the water supply industry. Proper operation and maintenance of a 

31 water system requires staffs that are trained and knowledgeable about drinking water treatment 

32 and distribution. One means of ensuring that system personnel have a certain minimum level of 

33 knowledge is through operator certification. All States are required to have operator certification 

34 programs as a condition of primacy. Each State establishes it own operator certification program. 

35 

36 

37 4.11.2 Certification Required Based on Size/Treatment 

38 

39 States generally require a certain level of operator certification based on the size and type 

40 (community or non-community) of the system and/or the type of treatment, if any, used in the 

41 system. The requirements for operator certification vary from State to State, but they generally 

42 require a certain amount of classroom training, on-the-job training and experience as well as 

43 requirements for continuing education. As an individual advances, the training requirements 

44 increase also. In addition, operator certifications must be renewed after a set time period and the 

45 continuing education requirements must be met for renewal. 

46 
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1 Suggested assessment criteria for operator certification include: 

2 

3 Does the system employ an operator(s) of the appropriate certification 

4 level(s), as specified in State requirements? 

5 

6 A system should have an operator(s) that possesses current certification at the level(s) 

7 specified in State requirements for the size and type of the system and any treatment. The 

8 inspector should verify that the levels and types of certification are still appropriate for the 

9 system (i.e. no new treatment, system has not expanded). The inspector should ask for proof of 

10 certification if it is not openly displayed. 

11 

12 Is the number of operators adequate for the system? 

13 

14 A system should have enough operators to ensure continued reliable operation of the 

15 system. Operator levels should be sufficient to meet daily duties (i.e. rounds, monitoring and 

16 reporting) as well as repairs and preventative maintenance. Operator levels should be sufficient 

17 to meet the needs of the system during off-duty time periods (weekends, vacations etc). For 

18 larger systems or system with treatment plants, the inspector should review the number and 

19 certification level of operators available per shift. If the system has only a part-time operator or 

20 where the operator has additional unrelated duties, the inspector should inquire about the amount 

21 of time spent on water system duties and how the system addresses preventative maintenance, 

22 repairs and emergencies. 

23 

24 Is training provided for new operators, new regulatory requirements or 

25 when new equipment is installed? 

26 

27 The system should provide training for new operators so they become familiar with the 

28 system and their operating responsibilities and regulatory requirements Operators should be 

29 provided with training (or allowed time to pursue training) for new regulatory requirement as 

30 well as operation and preventative maintenance of new equipment. 

31 

32 

33 4.12 References 

34 

35 ANSI/AWWA, 2005. Standard C651/05: Disinfecting Water Mains. 

36 

37 ANSI/AWWA, 2004. Standard G200-04: Distribution Systems Operation and Management. 

38 

39 AWWA, 2007. Criteria for Valve Location and System Reliability. 

40 

41 AWWA, 1999. Design and Construction of Small Water Systems. 

42 

43 American Water Works Association and American Water Works Association Research 

44 Foundation. 1992. Water Industry Database: Utility Profiles. AWWA, Denver, CO. 

45 

46 Great Lakes – Upper Mississippi River Board of State and Provincial Public Health and 

47 Environmental Managers, 2003. Recommended Standards for Water Works. Albany, NY. 

48 
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1 Kirmeyer, G.J., M. Friedman, K. Martel, D. Howie, M. LeChevallier, M. Abbaszadegan, M. 

2 Karim, J. Funk and J. Harbour. 2001. Pathogen Intrusion Into the Distribution System. Denver, 

3 Colo.: AWWARF and AWWA. 

4 

5 Lindeburg, Michael R. 1997. Civil Engineering Reference Manual for the Pe Exam. Sixth 

6 edition. Professional Publications, Inc. Belmont, CA. 

7 

MWH. 2005. Water Treatment Principles and Design, 2nd 8 Edition. Wiley-Interscience. Hoboken, 

9 NJ. 

10 

11 USEPA, 1999. Conducting Sanitary Surveys of Public Water Systems-Surface Water and 

12 Ground Water under the Direct Influence of Surface Water. 815-R-99-016. 

13 

14 USEPA. “The Potential for Health Risks from Intrusion of Contaminants into the Distribution 

15 System from Pressure Transients”. Office of Ground Water and Drinking Water, Washington, 

16 DC. 

17 

18 USEPA, 2003. How to Conduct a Sanitary Survey of Small Water Systems, A Learner’s Guide. 

19 816-R-03-12. 
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1 5. Compiling and Reporting the Sanitary Survey Results 

2 

3 

4 This chapter provides guidelines for compiling and reporting the sanitary survey results 

5 as well as suggestions for keeping adequate documentation of the sanitary survey. The GWR 

6 requires States to notify systems in writing of any significant deficiencies within 30 days of 

7 identifying the deficiency. The State may identify significant deficiencies during the sanitary 

8 survey or during other filed visits or office investigations. The notification, which can include 

9 State direction to take a specific corrective action, can be accomplished by; 

10 

11 • Written notice at the time of the sanitary survey or at the time the significant 

12 deficiency is identified; 

13 

14 • Written notice within 30 days of the sanitary survey or the time when the significant 

15 deficiency is identified; or 

16 

17 • As part of the sanitary survey report, if the report is provided to the system within 30 

18 days of completing the sanitary survey. 

19 

20 The sanitary survey report is a final written report that is used to notify water system 

21 owners and operators of the results of the survey, any deficiencies or recommendations for 

22 improvement, and assists in facilitating corrective action where deficiencies are noted. Final 

23 written reports should be prepared for every sanitary survey in a format that is consistent 

24 Statewide. Once a sanitary survey has been conducted, appropriate documentation is needed for 

25 follow-up activities and for development of reports. Not only does documentation need to be 

26 complete, but the results of surveys should be interpreted consistently from one surveyor to 

27 another. Specifically, as part of documentation and follow-up, the inspector should complete the 

28 following activities: 

29 

30 • Complete documentation and prioritize sanitary risks, including significant 

31 deficiencies that were identified during the onsite investigation; 

32 

33 • Notify the water utility of any variances in the sanitary survey report from that 

34 provided in the oral debriefing at the site; 

35 

36 • Complete the formal sanitary survey report; 

37 

38 • Notify appropriate organizations of the results (e.g., other State or local agencies 

39 affected by survey findings) ; 

40 

41 • Provide options for correcting the deficiencies, including sources of technical 

42 assistance; 

43 

44 • Follow-up on questions asked by water utility personnel and on consultation 

45 regarding selecting corrective actions; and 

46 

47 • Assess whether the system should be considered to have outstanding performance. 

48 
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1 The remainder of this chapter provides additional detail on compiling the sanitary survey 

2 report. Areas addressed include: preparing the sanitary survey report; preparing adequate sanitary 

3 survey documentation; categorizing the findings; developing corrective actions; and determining 

4 outstanding performance. 

5 

6 

7 5.1 Sanitary Survey Report 

8 

9 The sanitary survey report officially communicates the results of the survey to the owners 

10 and operators of the water system. The purposes of the survey report are to: 

11 

12 • Notify the system of the State’s assessment of the system’s condition and overall 

13 compliance; 

14 

15 • Notify the water system owners and operators of system deficiencies; 

16 

17 • Request corrective action under a specified schedule or, if necessary, direct corrective 

18 actions; 

19 

20 • Provide recommendations for improvements; 

21 

22 • Provide a written record for future inspections (including a recommendation on 

23 outstanding performance since this can affect the frequency of future surveys); and 

24 

25 • Provide important information that may be useful in emergencies. 

26 

27 The report can be brief but should be detailed enough to provide the water utility with 

28 sufficient information on what deficiencies exist and what corrective actions are needed. The 

29 survey report should indicate why corrective actions are necessary. Compliance schedules or 

30 requests for a correction date should be included for all deficiencies. The GWR requires a State31 approved compliance schedule for all significant deficiencies that are not corrected within 120 

32 days of being identified by the State. 

33 

34 The survey report provides a record for future inspecting parties and provides technical 

35 information that may be useful during emergency situations. It is also an important tool for 

36 tracking compliance with the SDWA and for evaluating a particular system’s compliance strategy. 

37 The sanitary survey report needs to contain adequate documentation of survey results. Types of 

38 documentation are discussed in Section 5.2. 

39 

40 The report should be completed promptly and reflect the information provided to water 

41 utility personnel at the end of the onsite evaluation. If the written evaluation is different from the 

42 oral debriefing, the water system manager should be notified of such changes. 

43 

44 At a minimum, the survey report should include the following elements: 

45 

46 • Date and time of survey; 

47 
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1 • Name(s) of survey inspector(s); 

2 

3 • Name(s) of those present during the survey, besides the inspector(s); 

4 

5 • A schematic drawing of the system and, where appropriate, photographs of key 

6 system components; 

7 

8 • A statement of system capacity, including source, treatment, and distribution; 

9 

10 • A summary of survey findings, with the signatures of survey personnel; 

11 

12 • A listing of deficiencies based on a regulatory reference; 

13 

14 • A summary of all analyses and measurements done during the sanitary survey; 

15 

16 • Recommendations for improvement, in order of priority, with a timeline for 

17 compliance; 

18 

19 • A copy of the survey form; and 

20 

21 • A recommendation on whether a system has outstanding performance. 

22 

23 The report needs to identify all the deficiencies noted during the inspection. The sanitary 

24 survey report should provide more detailed information when a system has a significant problem 

25 that could affect human health. If the State has not directed corrective action, the report should 

26 also provide options for corrective actions that the system may take to address any significant 

27 deficiencies. As described above, States must provide systems with written notification that 

28 describes and identifies all significant deficiencies no later than 30 days after the significant 

29 deficiency has been identified. Systems must consult with the State within 30 days of the notice (if 

30 the State has not directed corrective action) and take corrective action for any significant 

31 deficiencies no later than 120 days (or earlier if directed by the State) of receiving written 

32 notification of such deficiencies, or submit a schedule and plan to the State for correcting these 

33 deficiencies within the same 120 day period. States must confirm that the deficiencies have been 

34 addressed within 30 days after the scheduled correction of the deficiencies either by a follow-up 

35 field visit or by written notification from the system. 

36 

37 The sanitary survey report should describe the actions that the State will take if the 

38 deficiencies that require action by the system owner/operator are not corrected on schedule. 

39 

40 The State should develop standard language (“boilerplate”) for use in sanitary survey 

41 reports and correspondence with water systems after a sanitary survey. This standard language 

42 includes the text that will not change significantly from report to report. The standard language 

43 should be used, when applicable, to save report preparation time and to maintain uniformity in 

44 correspondence between the State agency and water systems. Standard language could be 

45 developed for sanitary survey report discussions pertaining to each of the eight elements of a 

46 sanitary survey. For example, a State could develop standard language that describes its operator 

47 certification requirements and says whether or not the water system operator(s) meets those 

48 requirements. The inspector would insert the applicable language based on the results of the 
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1 inspection. A State should consider consulting with its legal staff to ensure that the standard 

2 boilerplate language is accurate within its authorities. 

3 

4 

5 5.2 Sanitary Survey Documentation 

6 

7 Adequate documentation of survey results is essential in the sanitary survey process, 

8 especially if the survey may result in corrective or enforcement actions. It is the inspector’s 

9 responsibility to the water system and to the public to provide an accurate and detailed description 

10 of system condition, improper operations or system deficiencies in the sanitary survey report. 

11 Detailed documentation should be recorded in a sanitary survey report and sanitary survey forms. 

12 

13 The suggested minimum documentation for sanitary survey record files includes: 

14 

15 • A cover memorandum or letter with a list of deficiencies, if any, and any pertinent 

16 information and recommended or required actions for the PWS. The list of 

17 deficiencies should identify any significant deficiencies separately and describe the 

18 required action, correction or response by the PWS. Deficiencies uncorrected from a 

19 previous survey or inspection should also be identified separately with the required 

20 action, correction or response by the PWS. Reference to any applicable State or 

21 Federal regulatory provision and State policies should be included with each 

22 deficiency. The items listed below should be included: 

23 

24 - Water system name; 

25 

26 - Water system ID Number; 

27 

28 - Water system location; 

29 

30 - Survey date; 

31 

32 - Surveyor’s name/affiliation; and 

33 

34 - State contact phone number.; 

35 

36 

37 • A completed survey form or checklist for the water system (if used by the State); 

38 

39 • Any necessary additional pages of comments, drawings or sketches, and water 

40 sampling data; 

41 

42 • Any significant changes to the system since the last sanitary survey; 

43 

44 • An accurate map, if not already on file showing the location of the system; 

45 

46 • A summary of the components of the water system. This summary should identify 

47 any modifications made to the system; 

48 
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1 • A listing of system operators, including the certification status; and 

2 

3 • Updated contact information, emergency notification plans etc. 

4 

5 

6 5.3 Categorizing the Findings 

7 

8 While conducting sanitary surveys, inspectors often discover a wide range of problems, or 

9 deficiencies with the ground water system. There is a wide range of risks associated with 

10 significant deficiencies, ranging from those with a significant likelihood of introducing microbial 

11 contamination to the finished water, to those that the continued unaltered operation of the system 

12 poses a serious imminent health threat to the population served. 

13 

14 State drinking water programs should draw on their extensive experience to develop 

15 objective procedures for determining which deficiencies are significant. States, therefore, will need 

16 to establish procedures and criteria for inspectors to use to determine which deficiencies are 

17 significant. The GWR requirement for State primacy agencies defines significant deficiencies 

18 generally as including, but not limited to “defects in design, operation, or maintenance, failure or 

19 malfunction of the sources, treatment, storage, or distribution system that the State determines to 

20 be causing, or have potential for causing, the introduction of fecal contamination into the water 

21 delivered to consumers.” (§142.16(o)) The State’s primacy application for the GWR must define at 

22 least one specific significant deficiency in each of the eight sanitary survey elements. The State 

23 also has to have discretion to identify additional significant deficiencies on a case-by- case or 

24 system-specific basis. Under the GWR, systems must consult with the State regarding corrective 

25 actions for significant deficiencies. States may also prescribe specific corrective actions as well as 

26 require interim corrective measures (e.g. temporary disinfection). Failure to correct significant 

27 deficiencies within 120 days of being notified by the State or in accordance with a State-approved 

28 plan and schedule is a violation of the treatment technique requirements of the GWR and could 

29 result in State or EPA enforcement actions. 

30 

31 Exhibit 5.1 illustrates one possible approach to categorization of some of the common 

32 deficiencies by the degree of their threat to public health. The listing in Exhibit 5.1 includes 

33 examples of deficiencies that may be considered significant public health issues. This list is not 

34 intended to be comprehensive, but serves as a guide to the State for categorizing significant 

35 deficiencies. Other deficiencies could be deemed significant public health issues. 

36 

37 
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Exhibit 5.1 Example of Sanitary Survey Deficiencies1 1 

2 

Finding Minor Moderate Significant

No approved construction drawings X 

Failure to update the water distribution map X 

Stopping work on system improvements X 

Well casing is improperly sealed X 

Application of treatment chemicals not paced to flow X 

Raw water transmission main can bypass treatment X 

Inadequate storage for maintaining distribution system 

pressure 

 X 

System has exceeded the maximum number of service 

connections allowed 

 X 

System not operating in compliance with water system 

plan 

 X 

No auxiliary power available to keep system under 

positive pressure during commonly experienced power 

outages 

 X 

System is not using a certified laboratory X 

Failure to complete required Public Notice X 

Inadequate number of operators X 1 3 This table is for illustrative purposes only and does not represent any Federal or State policy. Additional 

4 potentially significant deficiencies are listed below and should be included as appropriate for each State. 

5 

6 

7 Sanitary surveys serve as proactive public health measure for States. When properly 

8 conducted, sanitary surveys can provide important information on a water systems design and 

9 operations and can identify minor and significant deficiencies for correction before they become 

10 major problems and improve overall system compliance. The following are additional examples 

11 of significant deficiencies organized by each of the eight minimum sanitary elements required 

12 under the GWR. These examples are intended for illustrative purposes only and are not intended 

13 to be all inclusive, or exclusive, of possible significant deficiencies identified by the States. State 

14 experience with specific deficiencies in their systems should be used to address the deficiencies 

15 on a system-specific basis. 

16 

17 Source 

18 

19 • Activities or pollution sources in the immediate well head area that will cause 

20 sanitary risks. 

21 

22 • The well is vulnerable to surface water runoff or in a flood plain. 

23 

24 • The well casing is cracked, not sealed, or is improperly sealed. 

25 

26 • The vent for the well casing is not screened and turned downward. 

27 

28 • Top of casing is not elevated to prevent contamination from flooding or ponding. 

29 
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1 • Well is not secure and susceptible to vandalism and tampering. 

2 

3 • Cross connections to storm drains, sanitary sewers, non potable water supplies, pump 

4 bearing cooling water. 

5 

6 • Unapproved source is being used. 

7 

8 • Non- microbial indicators of well susceptibility to fecal contamination (e.g. MBAS, 

9 chloride, caffeine). 

10 

11 Treatment 

12 

13 • System is not in compliance with applicable treatment technique requirements. 

14 

15 • Inadequate disinfection contact time, disinfectant concentration, disinfectant dose, or 

16 disinfection is not continuous. 

17 

18 • Inadequate application of treatment chemicals, not paced to flow. 

19 

20 • Unapproved treatment chemicals used. 

21 

22 • Lack of treatment process monitoring, failure alarms, or automatic process shutdown. 

23 

24 • Cross connections at chemical tanks, filter backwash, membrane cleaning processes. 

25 

26 • Loss of membrane integrity or lack of monitoring of membrane integrity. 

27 

28 • Auxiliary power is not available, power outages can cause a complete shutdown of 

29 treatment. 

30 

31 • Lack of redundant components. 

32 

33 • Failure to act in an emergency situation. 

34 

35 Distribution and Transmission 

36 

37 • Customers are receiving raw water from the raw water transmission main. 

38 

39 • The raw water transmission main is equipped with a bypass around the treatment 

40 plant. 

41 

42 • Repeated or frequent TCR violations or detections of fecal indicators. 

43 

44 • The TCR sampling plan is not representative of the distribution system. 

45 

46 • The system receives numerous complaints of colored and/or odorous water. 

47 
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1 • Required disinfection residual levels are not met. 

2 

3 • Compliance monitoring is not conducted at the required frequency and locations. 

4 

5 • Pressures in parts of the distribution system fall below 20 psi during periods of high 

6 demand. 

7 

8 • The system is subject to contamination from hazardous cross connections. 

9 

10 • Failure to have a cross connection control program when one is required. 

11 

12 • High leakage rates that pose risks of backsiphonage. 

13 

14 • Inadequate separation between distribution system mains and sewer lines. 

15 

16 Finished water storage 

17 

18 • Inadequate storage to maintain adequate distribution system pressure. 

19 

20 • The tanks vents or overflows are not screened or protected. 

21 

22 • Tanks overflows or drains are subject to flooding. 

23 

24 • Holes or other failures of tank roof or structure, faulty roof, or floating cover 

25 drainage. 

26 

27 • In ground tanks subject to flooding. 

28 

29 • The entry hatch tank is not of the overlapping shoe-box type and is subject to runoff 

30 from the tank roof. 

31 

32 • Cathodic protection covers missing, loose, or not watertight. 

33 

34 • The tanks entry hatch or access ladders are not secured. 

35 

36 • The storage tank has not been inspected for sanitary defects for an extended period of 

37 time. 

38 

39 Pumps, pump facilities, and controls 

40 

41 • Unapproved oil is used for pump lubrication. 

42 

43 • The air/water relief valves are cross connected to the floor drains. 

44 

45 • Auxiliary power needed to keep the system under positive pressure during commonly 

46 experienced power outages is not available. 

47 
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1 • There is a lack of redundant pumps. 

2 

3 • Cross connections to non potable supplies, pump, or generator cooling water. 

4 

5 Monitoring, reporting, and data verification 

6 

7 • The system has been found to be in significant non-compliance for one or more 

8 contaminants. 

9 

10 • Operators are using improper procedures and/or methods when conducting onsite 

11 laboratory analyses. 

12 

13 • The system does not have a compliance or microbial monitoring plan. 

14 

15 • The system is not using a certified laboratory. 

16 

17 • Failure to complete Operational Evaluation Reports. 

18 

19 System management and operation 

20 

21 • System security is inadequate. 

22 

23 • Failure to complete required Public Notice. 

24 

25 • Failure to notify the State of MCL violations or ground water source fecal 

26 contamination. 

27 

28 • Variance or exemption conditions or schedules not met. 

29 

30 • Failure to comply with enforcement actions and compliance agreements. 

31 

32 • System does not have adequate Technical, Managerial of Financial capacity, or 

33 revenue to ensure continued operation. 

34 

35 Operator compliance with State requirements 

36 

37 • The operator is not certified at the level/grade required by the State. 

38 

39 • Inadequate number of operators. 

40 

41 

42 5.4 Corrective Action 

43 

44 If the State determines that a significant deficiency exists in a system subject to the 

45 GWR, corrective action is required. To ensure that the sanitary risks are minimized, the sanitary 

46 survey report should provide the water utility with options or recommendation for correcting 

47 significant defects if the State does not specify corrective actions. 

48 
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1 The GWR requires that those systems notified in writing by the State of significant 

2 deficiencies implement corrective action, including one or more of the following: 

3 

4 • Eliminate the source of contamination, 

5 

6 • Correct the deficiency, 

7 

8 • Provide an alternative water source, or 

9 

10 • Provide a treatment that reliably achieves at least 4-log (99.99%) inactivation or 

11 removal of viruses before or at the first customer. 

12 

13 Once a system has received written notification of a significant deficiency, the system 

14 will then consult with the State regarding corrective action (if the State does not specify 

15 corrective action) within 30 days of the notice. The system must take the appropriate corrective 

16 action no later than 120 days (or earlier if directed by the State) after notification, or submit a 

17 schedule and plan to the State for correcting these deficiencies within the same 120 day period. 

18 The States must then confirm that the deficiencies have been addressed within 30 days after the 

19 scheduled correction of the deficiencies. 

20 

21 Upon receiving the sanitary survey report or other notice of significant deficiency from 

22 the State, PWSs should carefully plan the corrective measures that are to be adopted and 

23 implemented to correct the identified significant deficiencies. There may be a number of 

24 adequate corrective actions or combination of actions that may be applied to a significant 

25 deficiency. The system and the State, must, before proceeding, know that the planned corrective 

26 actions will eliminate the deficiency without creating new sanitary risks or other compliance 

27 problems. For example, if a system replaced a substandard well that was determined by the State 

28 to have a significant deficiency without obtaining the States review and concurrence, the action 

29 could result in another substandard well and a finding of noncompliance with the States 

30 construction and permitting standards. This example and many others often require 

31 modifications that, in many States, must be subsequently reviewed and approved by the State. 

32 Therefore, in all cases the PWS should seek the advice and concurrence of their primacy agency 

33 prior to taking corrective action. 

34 

35 

36 5.5 Outstanding Performance 

37 

38 As noted in Chapter 1, community systems that are classified as having outstanding 

39 performance are eligible for having future sanitary surveys conducted at the less frequent interval 

40 of at least once every 5 years, rather than at least once every 3 years. Based on the findings of a 

41 sanitary survey, an inspector should include in the report a recommendation on whether a system 

42 should be considered to have outstanding performance at the time of the survey. This 

43 recommendation should be based on the State’s specifications for determining if a system has 

44 outstanding performance. Along with the inspector’s recommendation, the report should 

45 include standard State language (“boilerplate”) noting that the recommendation for outstanding 

46 performance status is contingent upon the system continuing to meet the State’s specifications 

47 for that status. 

48 
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1 In general, outstanding performance means that a system is well-operated and managed, 

2 has a good record of performance in past sanitary surveys, and has not had any violations (at 

3 least in recent years). A State’s specifications for outstanding performance may include factors 

4 such as the following: 

5 

6 • No violations of MCLs since the last sanitary survey; 

7 

8 • No violations of monitoring and reporting requirements since the last sanitary survey; 

9 

10 • No violations of primary drinking water regulations during the past 5 years (or similar 

11 time period); 

12 

13 • Past sanitary surveys containing no significant deficiencies; 

14 

15 • Existence of emergency preparedness measures and backup facilities; 

16 

17 • Meeting exceptional performance standards a specified high percentage of the time; 

18 

19 • Expert management of system (e.g., managers are knowledgeable about providing 

20 quality drinking water; low staff turnover; well-established water quality goals); 

21 

22 • Expert operation of the system (e.g., skilled, certified personnel) in adequate 

23 numbers; existence of quality O&M manuals that are used by the staff; adequate 

24 budget and revenues); 

25 

26 • Effective cross-connection program developed and implemented; 

27 

28 • In-house programs applicable to improved system performance; 

29 

30 • Active public outreach programs (e.g., citizen participation committees); 

31 

32 • Stable water source (no interruptions in supply); 

33 

34 • No identified significant risk of future violations or problems (e.g., equipment past its 

35 service life); 

36 

37 • System capacity sufficient to meet anticipated growth; and 

38 

39 • Asset management program and Capital Improvement Plan 

40 

41 As noted above, each State should have its own specifications for determining if a system 

42 has outstanding performance. The State may choose to use some or all of the above factors, 

43 different factors that have been developed by the State, or a combination of both. 

44 

45 
1 
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1 6. Report Review and Response 

2 

3 

4 The previous chapters of this guidance manual described how to prepare, conduct, and 

5 report the results of a sanitary survey. This chapter describes the follow-up actions that should be 

6 taken by the water system operator and the State in response to the findings of a sanitary survey, 

7 including those actions that must be taken to correct any identified deficiencies. The State then 

8 needs to monitor the water system’s implementation of corrective actions to ensure that 

9 deficiencies are resolved. The remainder of this chapter discusses these follow-up actions. 

10 

11 

12 6.1 State Actions 

13 

14 For a State to be granted primacy authority for the GWR, it must submit information to 

15 EPA that the State has met the requirements for a determination of primacy enforcement 

16 responsibility found in 40 CFR 142.16. The special primacy requirements related to sanitary 

17 surveys are summarized in Exhibit 6.1. In addition to meeting minimum scope and frequency for 

18 sanitary surveys, States must have authority to address findings of significant deficiencies. 

19 

20 The GWR requires that the State notify systems findings of significant deficiencies no later 

21 than 30 days after the significant deficiency is identified. Unless the States directs corrective 

22 action or earlier compliance, the system must consult with the State within 30 days and take 

23 corrective action, or be in compliance with a State-approved schedule, within 120 days of being 

24 notified of the significant deficiency. States are required to confirm that the significant deficiencies 

25 have been addressed within 30 days after the scheduled correction of the deficiencies. Deficiencies 

26 of a minor nature may require no more response than to notify the system operator of the violation 

27 and set a time frame for the operator to correct the situation. 

28 

29 For significant deficiencies, the State should inform the system of the deficiency as soon as 

30 possible. Under the GWR, the State may inform the system in writing at the time of the sanitary 

31 survey or identification of the significant deficiency. In severe cases, the significant deficiency 

32 may be such that a boil water notice must be issued to the customers in order to protect public 

33 health. In other cases, other immediate interim measures to protect public health may be needed. 

34 Under the GWR, the State may specify interim corrective measures during the 120 day period the 

35 system is completing final corrections or completing its correction plan and schedule and during 

36 the approved schedule for final correction. The State should inform the system of the time frame 

37 required for a response to the notice of significant deficiencies and the consequences of failing to 

38 respond. In addition to a potential for violation of the GWR and associated enforcement action, the 

39 consequences could include revocation of the operating permit, suspension of the permit until the 

40 deficiency is corrected, and fines or penalties levied against the system operator. When significant 

41 deficiencies require an extended period for correction, a consent agreement, administrative order, 

42 or litigation by the appropriate court may be necessary to ensure correction. The State should make 

43 regular and continued inspections of the facility until all significant deficiencies have been 

44 corrected. 

45 

46 Other State activities include maintaining a tracking system for enforcement. The 1995 

47 EPA/State Joint Guidance on Sanitary Surveys States that the deficiencies disclosed in a survey 

48 must be followed up on to ensure that timely corrective action is taken, especially to correct 
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Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 deficiencies that have the potential to substantially affect public health. States should develop a 

2 program for following up on recommendations made in their sanitary surveys. Computer programs 

3 are useful for sanitary survey tracking and reporting. 

4 

5 

6 Exhibit 6.1 Summary of 40 CFR 142.16(o)(2) – Special Primacy Requirements for 

7 Sanitary Survey Requirements of the GWR 

8 

In addition to the general requirements for sanitary surveys contained in §142.10(b)(2), the special 

primacy requirements for the GWR related to sanitary surveys include the following: 

1) States must conduct sanitary surveys that address the minimum eight sanitary survey 

components no less frequently than every 3 years for community water systems. The initial 

sanitary survey for each community water system must be conducted by December 31, 2012,

and for each non-community water system must be conducted by December 31, 2014. 

2) States may use a phased review process to meet the requirements if all the minimum applicable 

minimum eight sanitary survey elements are evaluated within the required interval. 

3) States may conduct sanitary surveys once every 5 years for community water systems if the 

system either provides at least 4-log treatment of viruses (using inactivation, removal, or a 

State-approved combination of 4-log inactivation and removal) before or at the first customer 

for all its ground water sources, or if it has an outstanding performance record, as determined 

by the State and documented in previous sanitary surveys and has no history of total coliform 

MCL or monitoring violations under §141.21 of this chapter since the last sanitary survey. In 

its primacy application, the State must describe how it will determine whether a community 

water system has an outstanding performance record. 

4) A State must define and describe in its primacy application at least one specific significant 

deficiency in each of the eight sanitary survey elements Significant deficiencies include, but 

are not limited to, defects in design, operation, or maintenance, or a failure or malfunction of 

the sources, treatment, storage, or distribution system that the State determines to be causing, 

or have potential for causing, the introduction of contamination into the water delivered to 

consumers. 

5) States must provide ground water systems with written notice describing any significant 

deficiencies no later than 30 days after the State identifies the significant deficiency. The 

notice may specify corrective actions and deadlines for completion of corrective actions. The 

State may provide the written notice at the time of the sanitary survey. 

6) States must have the authority contained in statute or regulation to ensure that ground water 

systems take the appropriate corrective actions including interim measures, if necessary, 

needed to address significant deficiencies. 

7) States must have the authority contained in statute or regulation to ensure that ground water 

systems consult with the State regarding corrective action(s) 

9 

10 
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1 6.2 Water System Actions 

2 

3 As stated above, the severity of the deficiency in a sanitary survey should dictate the 

4 appropriate response from the water system operator. The GWR requires the system to consult 

5 with the State and complete corrective actions approved by the State or be in compliance with 

6 State-approved schedule for correction for any significant deficiencies within 120 days (or earlier if 

7 directed by the State) of the sanitary survey or other notice of a significant deficiency. The system 

8 operator, upon receipt of the sanitary survey report or notice of significant deficiency, should 

9 prepare a response to address the survey findings that may include deficiencies of varying degrees 

10 of severity. The response should include: 

11 

12 • A statement of the deficiency, including any real or potential impacts to delivered 

13 water quality; 

14 

15 • The approach to correcting the deficiency; 

16 

17 • The time required to correct the deficiency; 

18 

19 • The source of funding, if capital construction is required; 

20 

21 • Measures put in place to prevent the situation from recurring; and 

22 

23 • Additional follow-up actions planned. 

24 

25 The GWR does not change the requirement for a water system to maintain copies of 

26 sanitary survey written reports and correspondence associated with sanitary surveys for a period of 

27 at least 10 years, as specified in 40 CFR 141.33 (c). In addition to this requirement, the water 

28 system should follow any applicable State implementing regulations related to sanitary survey 

29 record keeping. Under the GWR, the presence of a fecal indicator in a source water sample 

30 requires Tier 1 public notice. By notifying the public of source water fecal contamination within 24 

31 hours the PWS will minimize the likelihood of serious public health consequences. This immediate 

32 public notification is also necessary to alert customers to the potential need to obtain alternative 

33 drinking water sources, if necessary. 

34 

35 GWR treatment technique violations are subject to Tier 2 public notification. The GWR 

36 (§141.404) defines treatment technique violations as: 

37 

38 • A GWS with a significant deficiency that does not complete corrective action within 

39 120 days (or earlier if directed by the State) or in accordance with a State-approved 

40 schedule. 

41 

42 • A GWS that detects fecal contamination and does not complete corrective action 

43 within 120 days (or earlier if directed by the State) or in accordance with a State44 approved schedule. 

45 

46 • A GWS that provides 4-log treatment of viruses and does not conduct triggered 

47 source water monitoring under the GWR, is in violation of the treatment technique if 
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1 it fails to provide 4-log virus treatment and the failure is not corrected within 4 hours. 

2 

3 The GWR also requires CWSs to notify the public of any detections of fecal indicators in 

4 their ground water source(s) or of any uncorrected significant deficiencies in the system’s 

5 Consumer Confidence Report. Non-community water systems must notify the public of any 

6 significant deficiencies that are not corrected within 12 months in a manner approved by the State. 

7 Notice of uncorrected significant deficiencies must continue annually for both CWSs and NCWSs 

8 until the significant deficiencies are corrected. 

9 

10 
November 2007 Sanitary Survey A-1 Draft for Discussion

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1 Appendix A 

2 Evaluating Ground Water Treatment for Ground Water Rule Compliance 

3 

4 

5 A.1 Introduction 

6 

7 This appendix provides information to assist States in evaluating ground water treatment 

8 for systems that provide and monitor ground water treatment and do not conduct GWR triggered 

9 monitoring after a TCR-positive or for systems that use ground water treatment as a corrective 

10 action. 

11 

12 Under the GWR, ground water systems that provide at least 4-log (99.99%) treatment of 

13 viruses (through inactivation, removal, or a State-approved combination of inactivation and 

14 removal) and also meet the compliance monitoring requirements of the GWR are not required to 

15 conduct triggered source water monitoring after a routine TCR-positive sample. States may also 

16 approve or require 4-log treatment of viruses as a corrective action for fecal contamination of 

17 ground water sources or as a corrective action for significant deficiencies. 

18 

19 To meet the requirements of the GWR, 4-log treatment of viruses may be accomplished 

20 through inactivation (i.e. disinfection), removal (i.e. filtration) or a State-approved combination 

21 of inactivation and removal. This appendix describes common inactivation and filtration 

22 technologies and their applicability to GWR treatment technique requirements. This appendix is 

23 not intended to be inclusive, or exclusive, of all possible treatment technologies, or combinations 

24 of technologies, to meet the GWR treatment technique requirements. States may approve 

25 alternative treatment technologies, or combinations of technologies, that provide 4-log treatment 

26 of viruses to meet the GWR treatment technique requirements. 

27 

28 

29 A.2 Inactivation of viruses 

30 

31 Inactivation of viruses is accomplished with sufficient disinfectant concentration and 

32 disinfectant contact time for chemical disinfectants or sufficient dose for inactivation with 

33 ultraviolet light (UV). Chemical disinfectants capable of providing 4-log treatment of viruses as 

34 a stand-alone treatment include chlorine, chlorine dioxide, chloramine and ozone. Chemical 

35 disinfection and UV inactivation are discussed separately below. 

36 

37 

38 A.2.1 Chemical disinfection 

39 

40 Inactivation of pathogens, including viruses, using a chemical disinfectant is based on the 

41 CT concept where C is the measured concentration of the chemical disinfectant residual and T is 

42 the contact time between the point of application of the disinfectant and the point where the 

43 disinfectant residual is measured. 

44 

45 C, the concentration of the disinfectant, is measured at or before the first customer 

46 receiving water or the first connection providing water to the public from the system. For a 

47 system using chlorine or chloramine, the residual concentration can be measured with a portable 

48 kit or with a continuous monitor using an EPA approved measurement method. A list of EPA 
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1 approved methods can be found on-line at www.epa.gov/waterscience/methods or from the US 

2 EPA Water Resource Center at (202)-566- 1729 or center.water.resource@epa.gov. Your State 

3 may have a list of approved measurement methods as well. T, the contact time of the 

4 disinfectant, is based on system flow and components. Determining flow and T are discussed 

5 later in this section. 

6 

7 Once C is measured and T is determined from the flow and the size of the system 

8 components, the product CΗ T (CT) is compared to EPA or State information of the CT needed 

9 for the inactivation, through disinfection, of a pathogen. EPA has produced tables of CT values 

10 and your State may have information it uses for this purpose. Exhibits B.1, B.2, and B.3, 

11 respectively, are CT tables for inactivation of viruses by chlorine, chlorine dioxide and ozone 

12 respectively. CT tables for chloramine are not included here because the CT values required for a 

13 4-log inactivation of viruses are not likely to be practical for applications in most ground water 

14 systems. CT values for inactivation of viruses by chloramine can be found in the Guidance 

15 Manual for Compliance with the Filtration and Disinfection Requirements for Public Water 

16 Systems Using Surface Water Sources (USEPA, 1990) and could be used for ground water 

17 systems using chloramines. 

18 

19 For the GWR, if a chemical disinfection system can achieve a CT at least equal to the CT 

20 needed for a 4-log inactivation of viruses for the disinfectant being used, the system is not 

21 required to meet the triggered monitoring requirements of the rule. However, such a system 

22 would have to comply with the treatment and compliance monitoring requirements of the GWR 

23 and any additional requirements set by the State. If approved or required by the State, such a 

24 system would also meet the corrective action requirements of the GWR for fecally contaminated 

25 ground water source or for significant deficiencies. The special primacy requirements of the 

26 GWR require State to specify a minimum disinfectant residual for system using disinfection to 

27 meet the treatment technique requirements of the rule. The CT concept would be used to set this 

28 minimum disinfectant residual. 

29 

30 The following minimum information is needed to determine if a chemical disinfection 

31 system is providing a 4-log inactivation for the purposes of the GWR: 

32 

33 1. C, the measured disinfectant residual at or before the first customer or connection 

34 serving the public. It is measured in mg/l or in ppm. 

35 

36 2. Length (in feet) of each pipe between the point where disinfectant is applied and 

37 the point where it is measured. 

38 

39 3. Size (diameter) of each pipe between the point where disinfectant is applied and 

40 the point where it is measured. The diameter in inches must be converted to 

41 diameter in feet (1 inch=1/12 foot). 

42 

43 4. Volume of water (in gallons) in any storage tanks used to determine CT provided 

44 by the system. 

45 

46 5. Maximum daily flow, in gallons per minute, (gpm) of the system. This could be 

47 as measured by a flow meter, the maximum capacity of the well pump, or another 

48 measurement acceptable to the State. 

49 
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1 The following example illustrate how this information may be used to calculate CT and 

2 to determine if a chemical disinfection system is providing a 4-log inactivation of viruses. 

3 

4 Example A.1

5 

6 The Redwood Road water system serves 4 commercial businesses and a service station. 

7 The water supply is provided by a single well on the property that is operated by a pressure 

8 activated switch. The information supplied with the well pump that was purchased for the 

9 system says it has a capacity of 5 gpm. A hypochlorite solution is injected using a drum of 

10 prepared solution and an injection pump inside the well house. The operator wants to determine 

11 how much virus inactivation the disinfection system provides. 

12 

13 To determine the inactivation the system provides through disinfection, the operator 

14 needs to calculate the CT achieved by the hypochlorination system. 

15 

16 • The operator must determine T, the contact time, from the size of the system=s 

17 components and measure C, the disinfectant residual concentration, at or before 

18 the first service connection. 

19 

20 • The operator knows the well pump has a capacity of 5 gallons per minute (gpm) 

21 from the manufacturer’s information. This is the maximum flow through the 

22 water system. T, the contact time in the system is the volume (in gallons) of the 

23 system divided by the maximum flow. 

24 

25 • The operator knows there is 100 feet of 2 inch pipe between the well house and 

26 the first service connection, the service station. The volume of the pipe in cubic 

27 feet and then in gallons is determined. The volume of the pipe in gallons is 

28 divided by the flow to find the contact time. 

29 

30 The operator measures the chlorine residual at the service station and finds it to be 0.5 

31 mg/l. So, the CT provided by the system is 0.5 mg/ l Η 3.3 minutes = 1.6 mg/l-minutes 

32 

The diameter of the pipe is 2 inches or 2/12 feet. 

The area of the pipe is [π × (diameter2

)]÷4 and π=3.14,or the area is also 

0.785× diameter2

So the area of the pipe is 0.785 × (2/12 feet)2 =0.022 sq.ft. 

The volume of the pipe in cubic feet=100 feet × (0.022 sq. ft.)=2.2 cubic feet 

The volume of the pipe in gallons is 2.2 cubic feet × 7.48 gallons/cubic 

foot=16.4 gallons 

The contact time, T, in the pipe is the volume of the pipe divided by the flow 

T= 16.4 gallons ÷ 5 gpm=3.3 minutes 
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Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 The CT needed for 4-log inactivation of viruses using chlorine is provided in Exhibit B.1. 

The operator has measured the temperature of the water as 10o 2 C and the last chemical analysis 

3 done for the well found a pH of 7.4 for the well water. Looking in Exhibit B.1 the CT for that 

4 temperature and pH for a 4-log inactivation with chlorine disinfection is 6 mg/l-minutes. 

5 

6 To provide 4-log inactivation, the CT provided by the system must be equal to or greater 

7 than the CT required from Table 1 (or the ratio of CT required/CT achieved must be 1.0 or 

8 more). Since the CT provided by the system, 1.6 mg/l-minutes, is less that the CT required from 

9 Table 1 (6 mg/l-minutes), the system does not provide enough CT to achieve 4-log inactivation 

10 of viruses. If the system was required to provide 4-log inactivation or wished to provide it to 

11 avoid triggered monitoring, the CT provided by the system would need to be greater. 

12 

13 

14 A.2.2 Determining Contact Time, “T”, for CT calculations 

15 

16 In determining contact time for flow in pipes, as in the previous example, contact can be 

17 assumed to be equal to the hydraulic detention at a particular flow rate (e.g. plug flow 

18 conditions). However, that is not the case for storage tanks and reservoirs and treatment plant 

19 processes. In these cases, contact time should be determined using tracer studies or using other 

20 methods approved by the State. 

21 

22 Appendix C of the Guidance Manual for Compliance with the Filtration and Disinfection 

23 Requirements for Public Water Systems Using Surface Water Sources (USEPA, 1990) provides 

24 a description of tracer studies and tracer study methods. In general, tracer studies should 

25 represent the range of flow and operational conditions expected in the system and should have 

26 data quality criteria (i.e. % tracer recovered). Tracer chemicals used should be conservative (high 

27 % recovery) and should be acceptable to the State for use in public water supplies. 

28 

29 Ground water systems may not have tracer study data available and conducting tracer 

30 may be beyond the capacity of many ground water systems. States may use other methods to 

31 determine contact time for use in CT calculations and determining minimum disinfectant residual 

32 for GWR compliance purposes. 

33 

34 One alternate method is to use “rule of thumb” fractions representing tracer studies that 

35 have been conducted for various types and geometries of various basins and storage facilities. 

36 Exhibit B.5 presents fractions that can be used under a given set of conditions to estimate contact 

37 time for CT calculation. For a particular tank or process, the baffling factor (also known as the 

38 T10/T ratio) is estimated based on the information available or a conservative assumption is 

39 made if no information regarding the tank is available. The baffling factor is used to reduce the 

40 contact time in the basin for CT calculations. Operating conditions in the basin (i.e. overflow 

41 levels) also need to be considered in determining actual basin volume. Example B.2 presents the 

42 use of baffling factors in determining contact time in a storage tank. 

43 

44 Example A.2 

45 

46 The operator of the Myrtletown water system wants to estimate the contact time in the system’s 

47 single storage tank. The operator has calculated that the minimum capacity of the tank is 11,000 

48 gallons based on the level of the float switch that signals the well pump to turn on and off. The 
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Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 operator has records from the flow meter at the tank outlet and the maximum daily flow over the 

2 past 12 months was 55 gallons per minute. 

3 

4 The storage tank has a single baffle in front of the inlet pipe and the inlet and outlet are located 

5 on opposite sides of the tank. The operator chooses a baffling factor of 0.3. 

6 

7 The theoretical hydraulic detention time in the tank is 11,000 gallons÷55gallons/minute or 220 

8 minutes. Using the baffling factor of 0.3, the estimated contact time in the tank under maximum 

9 flow conditions is 0.3×220 minutes= 60 minutes. 

10 

11 To determine the virus inactivation provided by the Myrtletown system, the estimated 

12 contact time is multiplied by the disinfectant residual measured at or before the first customer to 

13 find the “CT” provided. If the Myrtletown system used chemical disinfection for compliance 

14 with the GWR (either as a corrective action or in lieu of triggered monitoring), the system would 

15 be required to provide a minimum residual level determined by the State using the CT approach. 

16 

17 

18 A.2.3 Setting a Minimum Disinfectant Residual 

19 

20 The GWR requires that the State specify a minimum disinfectant residual, to be met prior 

21 to the first customer, for systems using chemical disinfection to provide virus treatment for their 

22 ground water sources. The minimum disinfectant residual is established using the CT concept. In 

23 setting a minimum disinfectant level, which becomes a compliance criterion for the system, the 

24 following information should be reviewed and considered: 

25 

26 • System configuration and operations (e.g. location of first customer, operation of 

27 storage, bypass of storage); 

28 

29 • The range of operating conditions (e.g. continuous or intermittent, peak flows); 

30 

31 • The range of expected water quality affecting disinfection (e.g. temperature, pH, 

32 disinfectant demand); 

33 

34 • Residual monitoring equipment (e.g. grab sample/portable kit, continuous 

35 monitoring); 

36 

37 • Condition of monitoring equipment, reagents and other supplies, maintenance and 

38 calibration of continuous monitoring equipment; and 

39 

40 • Disinfection system reliability features (e.g. alarms, automatic shutdown) 

41 

42 

43 A.2.4 UV Disinfection 

44 

45 In the proposed GWR (USEPA, 2000) EPA included UV light in the regulatory text as a 

46 stand-alone treatment technology that could provide 4-log virus inactivation. However, data 

47 published subsequent to the GWR proposal indicated that some viruses, particularly 

48 adenoviruses, are very resistant to UV light. The GWR proposal was based on information 
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Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 available at the time of the proposal regarding UV doses required to provide 4-log inactivation of 

2 Hepatitis A Virus (HAV) and the design doses achieved by available UV reactors, which are 

3 lower than the UV doses needed to achieve 4-log inactivation of adenovirus. EPA is concerned 

4 that fecally-contaminated ground water may contain adenoviruses, or other viruses, that are more 

5 resistant to UV inactivation than HAV. 

6 

7 EPA believes that UV reactors must undergo challenge testing to validate the dose level 

8 delivered so that effective treatment is provided in systems using UV disinfection. At present, 

9 EPA is unaware of available challenge testing procedures that can be used to validate the 

10 performance of UV reactors at dose levels needed for a 4-log inactivation of adenovirus. 

11 

12 However, UV technology can be used in a series configuration or in combination with 

13 other inactivation or removal technologies to provide a total 4-log treatment of viruses to meet 

14 this rule’s requirements. The GWR allows States to approve and set compliance monitoring and 

15 performance parameters for any alternative treatment, including UV light or UV light in 

16 combination with another treatment technology, that will ensure that systems continuously meet 

17 the 4-log virus treatment requirements. 

18 

19 UV reactors should undergo validation testing to determine the operating conditions 

20 under which the UV reactor delivers the UV dose required for the virus inactivation level 

21 required. Exhibit B.6 presents a UV dose table for virus inactivation. In general, the operating 

22 conditions determined in validation testing would include flow rate, UV intensity as measured by 

23 a UV sensor and UV lamp status. These operating conditions, as well as any State-specified 

24 monitoring or operating conditions, would be both a part of State approval of an alternative 

25 treatment process that meet the requirement of the GWR and part of compliance monitoring for 

26 an alternative treatment process for GWR compliance. The Ultraviolet Disinfection Guidance 

27 Manual for the Final Long Term 2 Enhanced Surface Water Treatment Rule (EPA 815-R-06-

28 007) (USEPA, 2006a) provides additional information on UV disinfection, planning and design 

29 of UV facilities, validation of UV reactors and start-up and operation of UV facilities. 

30 

31 EPA believes that a UV reactor dose verification procedure for 4-log inactivation of a 

32 range of viruses may be developed in the future. With the future development of UV validation 

33 procedures, it may become feasible for systems to demonstrate that they can achieve 4-log 

34 inactivation of viruses with a single UV light reactor. 
November 2007 Sanitary Survey A-7 Draft for Discussion

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Exhibit A.1 CT Values for a 4 -log Inactivation of Viruses by Free Chlorine 1,2 1 

2 

 Log Inactivation 

 2.0 3.0 4.0 

 pH pH pH 

Temperature (oC) 6-9 10 6-9 10 6-9 10 

0.5 6 45 9 66 12 90 

5 4 30 6 44 8 60 

10 3 22 4 33 6 45 

15 2 15 3 22 4 30 

20 1 11 2 16 3 22 

25 1 7 1 11 2 15 1 3 Guidance Manual for Compliance with the Filtration and Disinfection Requirements for Public Water Systems Using 

4 Surface Water Sources, USEPA, 1990. 5 2 6 Basis for values given in Appendix F, Guidance Manual for Compliance with the Filtration and Disinfection 

7 Requirements for Public Water Systems Using Surface Water Sources, USEPA, 1990.

8 

9 

Exhibit A.2 CT Values for Inactivation of Viruses by Chlorine Dioxide 3,4 10 

11 

Temperature (oC) 

Inactivation <=1 5 10 15 20 25 

2-log 8.4 5.6 4.2 2.8 2.1 1.4 

3-log 25.6 17.1 12.8 8.6 6.4 4.3 

4-log 50.1 33.4 25.1 16.7 12.5 8.4 3 12 Guidance Manual for Compliance with the Filtration and Disinfection Requirements for Public Water Systems Using 

13 Surface Water Sources, USEPA, 1990. 14 4 15 Basis for values given in Appendix F, Guidance Manual for Compliance with the Filtration and Disinfection 

16 Requirements for Public Water Systems Using Surface Water Sources, USEPA,1990.

17 

18 

Exhibit A.3 CT Values for Inactivation of Viruses by Ozone 5,6 19 

20 

Temperature (oC) 

Inactivation <=1 5 10 15 20 25 

2-log 0.9 0.6 0.5 0.3 0.25 0.15 

3-log 1.4 0.9 0.8 0.5 0.4 0.25 

4-log 1.8 1.2 1.0 0.6 0.5 0.3 5 21 Guidance Manual for Compliance with the Filtration and Disinfection Requirements for Public Water Systems Using 

22 Surface Water Source, USEPA, 1990. 23 6 24 Basis for values given in Appendix F, Guidance Manual for Compliance with the Filtration and Disinfection 

25 Requirements for Public Water Systems Using Surface Water Sources, USEPA 1990.

26 
November 2007 Sanitary Survey A-8 Draft for Discussion

Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

Exhibit A.4 Baffling Classifications7 1 

2 

Baffling Conditions Baffling Factor (T10/T) Baffling Description 

Unbaffled (mixed flow) 0.1 None, agitated basin, very low length to width 

ratio, high inlet and outlet flow velocities, 

common inlet/outlet 

Poor 0.3 Single or multiple unbaffled inlets and outlets, 

no intra-basin baffles 

Average 0.5 Baffled inlet or outlet with some intra-basin 

baffles 

Superior 0.7 Perforated inlet baffle, serpentine or 

perforated intra-basin baffles, outlet weir or 

perforated launders 

Perfect (plug flow) 1.0 Very high length to width ratio (pipeline flow) 

perforated inlet, outlet, and intra-basin baffles 7 3 Adapted from Guidance Manual for Compliance with the Filtration and Disinfection Requirements for Public Water 

4 Systems Using Surface Water Sources, USEPA, 1990. 

5 

6 

Exhibit A.5 UV Dose Table for Virus Inactivation Credit8 7 

8 

Log Credit Virus UV Dose (mJ/cm2)

9

0.5 39 

1.0 58 

1.5 79 

2.0 100 

2.5 121 

3.0 143 

3.5 163 

4.0 186 8 9 Adapted from 40 CFR 141.720(d) (USEPA 2006b) 10 9 mJ/cm2 11 = millijoule per centimeter squared 
November 2007 Sanitary Survey A-9 Draft for Discussion

Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 A.3 Removal of Viruses 

2 

3 4-log treatment of viruses to meet the requirement of the GWR may also be accomplished 

4 through removal (i.e. filtration) or a State-approved combination of inactivation and removal. 

5 This section describes common filtration technologies and their applicability to GWR treatment 

6 technique requirements. States may approve alternative treatment technologies, or combinations 

7 of technologies, that provide 4-log treatment of viruses to meet the GWR treatment technique 

8 requirements. 

9 

10 The following are commonly used filtration technologies that provide some level 

11 of virus removal. While these technologies are more commonly used in systems treating surface 

12 water, systems treating ground water (i.e. for iron and/or manganese removal) may also use these 

13 technologies: 

14 

15 • Conventional Treatment; 

16 

17 • Direct filtration; 

18 

19 • Slow sand filtration; and 

20 

21 • Diatomaceous Earth Filtration 

22 

23 When properly designed and operated, these technologies are capable of achieving at 

24 least 1-log removal of viruses (USEPA, 1990) 

25 

26 Membrane filtration technologies provide some level of virus removal and the GWR 

27 includes specific requirements for the use of membrane filters. States may also approve 

28 alternative filtration technologies if those technologies can demonstrate (and monitor to 

29 demonstrate to continuing removal efficacy) removal of viruses. 

30 

31 

32 A.3.1 Membrane Technologies 

33 

34 Membrane technologies used to provide 4-log removal of viruses to meet GWR 

35 requirements must have an absolute molecular weight cut off (MWCO), or an alternate 

36 parameter that describes the exclusion characteristics of the membrane, that reliably achieves at 

37 least 4-log removal of viruses. 

38 

39 Generally, only ultrafiltration, nanofiltration, and reverse osmosis membranes provide 

40 virus removal (USEPA, 2005). Manufacturers of membrane technologies may have performed 

41 challenge or demonstration studies according to State or other protocols to demonstrate virus 

42 removal performance. Manufacturers may have also participated in treatment device certification 

43 programs such as the National Sanitation Foundation (NSF) (http://www.nsf.org) or EPA’s 

44 Environmental Technology Verification (ETV) Program (http://www.epa.gov/etv). Appendix E 

45 of the Membrane Filtration Guidance Manual (USEPA, 2005) provides additional information 

46 on the application of membrane filtration for virus removal. 

47 
November 2007 Sanitary Survey A-10 Draft for Discussion

Guidance Manual for Ground Water Systems Do not Quote. Do not Cite

1 The GWR also requires that membrane technologies used to provide 4-log removal of 

2 viruses to meet GWR requirement be operated in accordance with State-specified performance 

3 requirements and show that the integrity of the membrane is intact. The most accurate method of 

4 demonstrating membrane integrity currently available is direct integrity testing. Continuous 

5 indirect integrity monitoring, using turbidity, particle counts or other surrogate water quality 

6 parameters, may be used to assess membrane integrity on a continuous basis and establish 

7 performance criteria. However, direct integrity testing to demonstrate virus removal may not be 

8 feasible and some methods of indirect integrity monitoring may not have sufficient accuracy to 

9 serve as more than gross measures of membrane integrity for virus removal (USEPA, 2005). 

10 

11 For most ground water sources, turbidity and particles are not likely to be present at 

12 levels high enough to set performance criteria or use in continuous monitoring and States may 

13 need to use other water quality parameters (e.g. TDS, conductivity) or operating parameters (e.g. 

14 transmembrane pressure, flux rate) as performance indicators. Monitoring some parameters may 

15 require laboratory analysis or additional monitoring equipment. As with other treatment 

16 technologies, membranes may be combined with another treatment technology to provide a total 

17 of 4-log treatment of viruses. Combining a membrane technology with chlorine disinfection 

18 would provide multiple virus barriers with a level of redundancy. 

19 

20 

21 A.3.2 Alternative Filtration Technologies 

22 

23 As with membrane technologies, manufacturers of alternative filtration technologies may 

24 have performed challenge or demonstration studies according to State or other protocols to 

25 demonstrate virus removal performance. Manufacturers may have also participated in NSF, ETV 

26 or other treatment device certification programs. The GWR requires that alternative filtration 

27 technologies used to provide 4-log removal of viruses to meet GWR requirement be operated in 

28 accordance with State-specified performance requirements. These performance requirements 

29 could include continuous, indirect measures of performance using water quality parameters (e.g. 

30 TDS, conductivity) as performance indicators. Alternative filtration technologies may be 

31 combined with another treatment technology to provide a total of 4-log treatment of viruses and 

32 additional treatment could provide multiple virus barriers with a level of redundancy. 

33 

34 

35 A.4 References 

36 

37 USEPA, 1990. Guidance Manual for Compliance with the Filtration and Disinfection 

38 Requirements for Public Water Systems Using Surface Water Sources, October 1990 

39 

40 USEPA, 2005. Membrane Filtration Guidance Manual, EPA 815-R-009, November 2005. 

41 

42 USEPA, 2006a. Ultraviolet Disinfection Guidance Manual for the Final Long Term 2 Enhanced 

43 Surface Water Treatment Rule, EPA 815-R-06-007, November, 2006. 

44 

45 USEPA, 2006b. National Primary Drinking Water Regulations: Long Term 2 Enhanced Surface 

46 Water Treatment Rule: Final Rule,71FR 654, January 5, 2006. 

47 

48 
1 

Appendix B Using Sanitary Surveys to Update State Source Water 

Protection Programs 

APPENDIX B: USING SANITARY SURVEYS TO UPDATE STATE SOURCE WATER 

PROTECTION PROGRAMS 

Note: In the examples below, the states use 

the term “Source Water Assessment program”. 

Sanitary surveys (Surveys) can be adapted to 

support source water assessments. Three short 

examples and one extended example are 

presented below. These approaches could be 

utilized by other states wanting to take advantage 

of the Survey process to enhance or update their 

Susceptibility Determinations (SDs). 

Example 1: State of New York 

As part of their agreement with the state, counties 

in the state of New York will collect additional 

information about their PWSs during Surveys and 

site inspections and enter the data into an add-on 

that the state developed for the SDWIS database. 

The Basic Facility Data form was modified for use 

with the Source Water Assessment Program to 

contain state-specific information: contaminant 

history, locations of potential contaminant sources 

and well logs. These data were incorporated into 

assessments as Discrete Contaminant Source 

Public Water Supply Inventory and as sensitivity 

drivers and other information pertinent to overall 

susceptibility. 

Example 2: State of Louisiana 

Sanitarians in the Louisiana Department of Health 

and Hospitals have conducted sanitary surveys 

that have proven useful for updating Source Water 

Assessment Program data. Health and Hospitals 

has access to the Source Water Assessment Program reports and checks them against the information obtained during sanitary surveys. Health 

and Hospitals notifies the Louisiana Department of 

Environmental Quality if there are any errors in the 

report, such as wells that are incorrectly numbered 

or no longer active. Health and Hospitals also notifies Environmental Quality if new wells have been 

drilled, if a system has been closed, or if a new 

system has come online; new systems are added 

to the source water assessment database. 

One Health and Hospitals staff person works with 

Environmental Quality to update the contaminant 

source inventories. This staffer performs the field 

work and then Environmental Quality updates the 

database. Currently, source water areas are 

prioritized for updating based on well-update 

information provided by the Health and Hospitals 

sanitarians, or on a request from such individuals 

and entities as the public, a government agency, 

or a water system. In the future, further 

prioritization would be based on susceptibility to 

contamination (as indicated by Source Water 

Assessment Program data). 

Example 3: State of Michigan 

The Source Water Assessment Score provides a 

susceptibility determination for Michigan’s noncommunity wells. One element of the Score is noncommunity PWS-well construction, maintenance, 

and use, which are determined as part of the 

sanitary-survey process. States, the PWS, or 

Source Water Protection Partners could take 

advantage of this scoring system to re-evaluate 

well integrity as information becomes available 

during the sanitary-survey cycle. 

How-To Manual: Update and Enhance Your Local Source Water Protection 

Assessments 
1