California Sanitary Survey Preparation Guide

Resource Guide · California

California Sanitary Survey Preparation Guide: What DDW Inspectors Check

California's Division of Drinking Water (DDW) conducts sanitary surveys on a mandated cycle: every three years for community water systems (CWS), every five years for non-transient non-community systems (NTNC). The survey is a comprehensive inspection of your system's physical infrastructure, operational records, and regulatory compliance. Findings are categorized as significant deficiencies, critical deficiencies, or sanitary defects — each with distinct correction timelines and enforcement consequences.

What Is a Sanitary Survey?

A sanitary survey is an onsite inspection conducted by DDW to assess whether your system can reliably deliver safe drinking water. The inspection covers eight primary elements required under California's Title 22 regulations and federal SDWA rules:

Source
Treatment
Distribution system
Finished water storage
Pumps, pump facilities, and controls
Monitoring, reporting, and data verification
System management and operation
Operator compliance with state requirements

For surface water systems, a ninth element — land use — is also evaluated. DDW reviews your SDWIS record, enforcement history, and reported violations before arriving. They already know what your record shows.

Deficiency Categories and Correction Timelines

Type	Definition	Correction window
Critical deficiency	Presents an imminent public health risk. DDW may require a boil-water notice or emergency action.	30 days
Significant deficiency	A condition that, if not corrected, could lead to a public health risk. DDW issues a formal notice and tracks correction status.	1 year
Sanitary defect	A condition that presents a pathway to contamination.	DDW discretion

Failure to correct a significant deficiency within the window generates a separate violation on your SDWIS record. Compliance schedules are available but must be requested and honored.

What DDW Inspectors Evaluate

1. Source

Wellhead protection compliance (no prohibited activities within required setbacks)
Surface water intake condition and screening
Source water monitoring current and complete for system size
Source water assessment documentation on file
4-log treatment documentation for groundwater systems (GWDTR)

2. Treatment

Daily logs, maintenance logs, chemical feed logs current
Disinfection residuals at entry points (CA minimum: 0.2 mg/L free chlorine)
CT calculations documented for surface water systems
PFAS treatment where detections exceed CA thresholds (PFOA/PFOS: 1 ppt)

Common: CT log gaps. Inspectors want the log, not just confirmation treatment is running.

3. Distribution System

Pressure testing and flushing records for the survey period
Valve exercising logs current
Cross-connection control and backflow prevention documented
Lead service line (LSL) inventory filed with DDW (AB 746 + LCRR)
Sampling site plan on file; sites current

LCRI: 10-year replacement deadline January 2037.

4. Finished Water Storage

Tank inspection records (DDW minimum: every 5 years)
Overflow and vent screens intact and functional
Access hatches locked and sealed
Disinfection residual maintained in storage at all times

5. Pumps, Facilities & Controls

Pump station secured against unauthorized access
Emergency power (generator) tested and test log maintained
SCADA systems operational where applicable
Pump maintenance logs current

6. Monitoring, Reporting & Data Verification

All required monitoring on schedule (RTCR, chemical, radiological)
Results reported to DDW within required timeframes
CCR distributed by July 1 each year (2026: include PFAS + LSL data)
Tier 1, 2, and 3 public notices issued within required windows

Most enforcement originates here. RTCR: positive E. coli sample triggers Tier 1 notice within 24 hours.

7. System Management & Operation

Emergency Response Plan (ERP) on file with DDW
O&M manual current and accessible at the system
Operator certification active (CA: T1-T5 treatment, D1-D5 distribution)
Operator of Record (OOR) designation on file with DDW

OOR grade must meet or exceed system classification. Notify DDW on any OOR change.

8. Operator Compliance

SDWIS record reviewed for open violations and compliance schedules
Required reports submitted: survey follow-up, corrective action
Outstanding compliance orders addressed and documented

Before the Survey: 8-Point Preparation Checklist

DDW typically provides advance notice. One to two months before the inspection:

Pull your SDWIS record. Review open violations, previous survey findings, and compliance history.
Verify operator certification is current and the OOR designation is on file with DDW.
Compile monitoring records for the full survey period: TC results, chemical results, entry point residuals.
Confirm your LSL inventory is filed with DDW. If not filed, file immediately.
Review your CCR: distributed by July 1? Does it include PFAS and LSL data?
Inspect distribution documentation: valve exercising logs, flushing records, cross-connection control.
Test your emergency generator and log the test.
Review previous survey findings — significant deficiencies must have documented corrective actions on file.

Check Your Compliance Status Before the Inspector Does

The free lookup at orevant.com shows your current EPA record — open violations, system classification, and compliance history. The $199 compliance scan maps every monitoring requirement that applies to your system, upcoming deadlines from California's DDW program, and PFAS, LCRI, and RTCR obligations by deadline date.

Operators who run a scan before their survey know what the inspector knows before walking through the door.

Check My Water System — Free Run the $199 Compliance Scan

Orevant provides compliance information for reference purposes only. This page is not legal advice. Contact DDW or a licensed engineer for site-specific guidance.

Sources: California Title 22, California Code of Regulations; SWRCB Division of Drinking Water (DDW); US EPA SDWA; EPA PFAS MCLs (final rule, April 2024); Lead and Copper Rule Improvements / LCRR (2024); Revised Total Coliform Rule; California AB 746; EPA Sanitary Survey Guidance (EPA 815-R-99-016).