Fact Sheet: What to Expect During a Public Water System Inspection

Fact Sheet - What to Expect During a Public Water System Inspection (pdf) (431.7 KB, September 2024, EPA 305F24001)

The Public Water System Supervision or PWSS program is designed to protect human health by ensuring the safety of drinking water. PWSs are often inspected by states, territories, and Tribes. However, under the Safe Drinking Water Act or SDWA, EPA also has authority to inspect these systems. This fact sheet informs public water system owners and operators about what they can expect before, during, and after an EPA inspection.

Why is EPA inspecting my system?

EPA oversees the national drinking water program and has inspection authority at all PWSs. In areas where a state, territory, or Tribe has EPA approval to implement SDWA (otherwise known as primary enforcement authority), EPA may still perform inspections separate from the primacy agency. EPA primarily conducts inspections of PWSs for the following reasons:

To collect information to evaluate the system’s compliance with SDWA and primacy agency drinking water requirements;
To collect information to evaluate whether a system poses a public health risk to a community by providing unsafe drinking water to consumers;
To follow-up on previous inspections, sanitary surveys, or enforcement actions;
In response to a citizen complaint; or
To assist a primacy agency, when requested.

Will I receive notice that EPA is conducting an inspection of my system?

EPA will provide the PWS with written notice explaining the purpose of the inspection. Written notice may be handed to the PWS staff when EPA arrives on site or sent via mail or email at any time prior to the inspection.

EPA understands that an inspection of the PWS will require staff time and participation, and the EPA inspector will try to avoid disrupting operations. It is important, if possible, to have key PWS personnel available during the inspection to help the EPA inspector conduct the inspection as efficiently as possible.

How do I know if the person who comes to my system is an EPA inspector?

Image of PIV badge inspector credentials — Figure 1. Example EPA Inspector Credential

EPA issues inspector credentials to federal employees, contractors, or others acting lawfully on EPA’s behalf. Upon arrival, an inspector will show their credential or a letter of authorization in place of credentials to the PWS staff. The credential lets the PWS staff know that the inspector is authorized to conduct the inspection under SDWA. Figure 1 shows an example of an EPA inspector credential issued to EPA staff. Non-EPA staff that may have an inspector credential include contractors; state, territory, or tribal staff; or Senior Environmental Employees. System operators can see an example of an EPA inspector credential issued to non-EPA staff on the EPA website. If an inspector does not present their EPA credential, the PWS staff should ask to see it. The credentialed inspector may be accompanied by one or more support staff, inspectors-in-training, or contractors. EPA may also be accompanied by primacy agency staff, who may assist with the inspection and any potential follow up.

What happens during an EPA PWS inspection?

SDWA authorizes EPA to conduct inspections at reasonable times such as normal business hours. Upon arrival, the EPA inspector will ask permission to conduct the inspection. If the inspector is denied entry, EPA may get a search warrant and the inspector may return to the system with law enforcement officials to conduct the inspection. Depending on the scope of the inspection and the size of the PWS, the inspection could take between a few hours to multiple days.

Activities that may occur during an EPA PWS inspection include an opening conference, facility walkthrough, sampling, records review, and closing conference, as shown in Figure 2. The facility walkthrough, sampling, and records review may occur in a different order than listed in Figure 2.

SDWA PWSS Inspection Activities — Figure 2. Example SDWA-PWSS Inspection Activities

Opening Conference

EPA inspections begin with an opening conference between the inspector and key system staff. During the opening conference, the EPA inspector and system staff discuss the purpose of the inspection, the PWS’ right to make confidential business information claims, the schedule of inspection activities, and system management and operations. The EPA inspector may provide or establish an agenda for the inspection before the inspection occurs or during the opening conference. However, the scope and schedule of the inspection can change during the inspection. For example, the EPA inspector may adjust the focus of the inspection based on new information or onsite observations. Good communication during the opening conference and throughout the inspection is essential for the EPA inspector to understand all operations of the PWS and results in a more successful and collaborative inspection. EPA encourages PWS staff to discuss their questions or concerns with EPA during the inspection.

Facility Walkthrough

After the opening conference, the EPA inspector conducts a facility walkthrough. During the facility walkthrough, the EPA inspector evaluates areas and operations of the PWS, including but not limited to, sources, treatment, distribution, and storage. The EPA inspector may also look at the function, condition, and maintenance of equipment such as groundwater wells, surface water intakes, chemical pumps, flocculation basins, filters, booster stations, storage tanks, and other assets. The EPA inspector asks questions about management and operations and the areas visited and takes notes and photographs. EPA encourages PWS staff to take their own notes during the facility walkthrough and ask questions.

Sampling

The EPA inspector may sample raw or treated drinking water during the inspection. If the EPA inspector takes samples, they will explain the reasons for sampling, what types of samples will be taken, and the types of analyses that will be conducted. EPA follows established national standard sampling and analysis protocols, which EPA provides upon request by the system. The EPA inspector may be able to provide extra bottles and collect split samples if the system wants to perform their own analysis separately from EPA. However, EPA encourages the PWS to provide its own bottles if it wishes to conduct split samples. If the system chooses to analyze their split samples, the system selects a laboratory of their preference and pays any associated costs for the analyses. Potential variations in sample storage and handling, laboratory analytical methods, or temporal variations in the sample concentrations may result in different results for sample analyses.

The EPA inspector may also ask to observe the sampling practices of the PWS, such as where and how the PWS takes required compliance samples. The EPA inspector may record continuous monitoring equipment readings and ask to review calibration and equipment maintenance records and procedures.

Records Review

The EPA inspector may request documents before, during, or after the inspection. Documents requested may include, but are not limited to, monitoring plans and schedules, sampling logs, operations and maintenance manuals, standard operating procedures, monthly operating reports, maps of the water distribution system, storage tank cleaning and inspection records, and other records pertaining to SDWA or primacy program drinking water requirements. The EPA inspector may also ask for a list of certified operators and their certification numbers. The EPA inspector may ask the PWS to send the documents to EPA in electronic format or by a specific date. If the PWS cannot produce the documents electronically or by a given deadline, the PWS must contact the EPA inspector to discuss alternative options. The inspector may arrange to review some documents onsite.

Closing Conference

At the end of the inspection, the EPA inspector conducts a closing conference with PWS staff. The EPA inspector reviews key observations and any areas of concern identified during the inspection. However, any areas of concern provided by the inspector are preliminary in nature. The EPA inspector does not make the determination of compliance or noncompliance at the time of the inspection. The closing conference is also an opportunity for the EPA inspector and PWS staff to discuss the next steps after the inspection. The EPA inspector provides their name, phone number, and information on how to reach other key regulatory contacts to PWS staff. EPA encourages PWS staff to contact the EPA inspector after the inspection with any questions about the inspection or follow-up activities.

What happens after the inspection?

After the inspection, the EPA inspector may contact the system if they need more information or clarification on anything discussed during the inspection. Occasionally, the EPA inspector returns on a future date to collect samples or gather additional information. Typically, the EPA inspector sends the system an inspection report approximately 60-90 days after the inspection. The inspection report details the observations and areas of concern made by the EPA inspector. If EPA determines the PWS violated SDWA or primacy agency drinking water requirements based on the inspection report, EPA and/or the primacy agency may take an enforcement action. The PWS may receive a notice of enforcement action from EPA weeks or months after receiving the inspection report.

For More Information

To learn more about federal drinking water requirements, please refer to the federal regulations or contact your state drinking water authority or your EPA Regional Office. Additionally, the following resources are outlined in the table below: