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What should a small Arizona public water system do when a Level 1 or Level 2 assessment is triggered?

Updated October 4, 2026
Quick Answer

For a public water system serving 1,000 people or fewer, confirm the assessment trigger with its drinking-water authority, arrange the appropriate assessor, investigate sanitary defects and submit the required form. ADEQ’s guidance gives thirty days after learning of the trigger, with agency-approved schedules for defects that cannot be corrected within that period.

Has the authority confirmed an assessment trigger?

This guide follows ADEQ’s assessment factsheet for public water systems serving 1,000 people or fewer. A Level 1 or Level 2 assessment under the Revised Total Coliform Rule is a find-and-fix review of possible sanitary defects: pathways for contamination or failures in protective barriers. Confirm the actual trigger and assessment level with the responsible operator and drinking-water authority.

A single laboratory label should not be used to assign the response without considering repeat samples and compliance history. Preserve the sampling reports and notification dates. The separate positive-coliform response addresses prompt samples and notifications; an assessment does not replace those duties.

Who performs the review?

ADEQ says the system or certified operator typically performs a Level 1 assessment. For Level 2, contact the regulatory agency to determine the qualified assessor. Do not assume that an ordinary plumbing inspection, contractor license or satisfactory repeat sample completes the required assessment.

Obtain the applicable form and submission instructions. The Level 1 form asks for the current microbiological sample-siting plan and supporting documentation. Arrange safe access for qualified personnel; owners should not enter tanks, vaults or other hazardous spaces to fill out a checklist.

What conditions are investigated?

ADEQ identifies five basic review elements: atypical events, distribution operation and maintenance including storage, source and treatment conditions, sampling sites and procedures, and existing monitoring data. Its assessment forms translate those elements into system-specific findings.

Review such matters as pressure-loss events, source or treatment changes, damaged seals, storage openings, cross-connections and sampling-site conditions. Record whether an item has an issue, has no identified issue or is not applicable, with an explanation supported by observations and records. A guessed “no issue” does not establish that an inaccessible component was inspected.

The scheduled sanitary survey is a different regulatory review. Keep its records available if useful, while completing the actual triggered-assessment form.

How are corrective actions and deadlines closed out?

ADEQ’s small-system factsheet gives the system thirty days after learning that the assessment was triggered to complete the assessment, correct defects and submit the form. If a defect cannot be corrected in that period, obtain an agency-approved schedule for the unfinished corrective action. Notify the authority when each scheduled correction is completed.

Assign responsible people, preserve the completed form and document the repairs and verification. A proposed repair is not evidence that it occurred. Failure to complete the assessment or corrective duties can create additional violations and public-notice responsibilities. Confirm the actual deadline and instructions for the event with the agency rather than treating this checklist as an extension.

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