BENEFITS AND COSTS OF PREVENTION:
CASE STUDIES OF
COMMUNITY WELLHEAD PROTECTION
VOLUME 2
DETAILED CASE STUDIES OF
SEVEN COMMUNITIES
Source Water Protection
Business and Economics Series
Report No. 3
November 30, 1995
Office of Ground Water and Drinking Water
U.S. Environmental Protection Agency
Washington, D.C. 20460
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r
Acknowledgements
This project and report were completed under Environmental Protection Agency Contract
No. 68-C4-0011,Work Assignment 1-14 by the CADMUS Group, Ron Bergman, EPA Work
Assignment Manager. Charles Job provided technical direction. This Volume 2 is the report of the
summaries resulting from information provided by officials from the States of Louisiana, Maine,
Massachusetts, Ohio, Pennsylvania, and Washington, and from the communities of Gilbert, LA,
Norway, ME, Dartmouth, MA, Middletown, OH, Gettysburg, PA, Lancaster County, PA, and
Tumwater, WA. Without the cooperation of these officials, this study would not have possible.
EPA expresses its appreciation to them for their assistance. •
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TABLE OF CONTENTS
PART ONE
DETAILED CASE STUDffiS OF SEVEN COMMUNITIES
1. INTRODUCTION .'. .;,......,.,..............;. 1
1.1 Definition of Benefit . :V.........-.-............ 1
1.2 Methodology - 3
1.2.1 Pilot Study ...... '. . . ...... ; 3
1.2.2 Case Study Selection ......; 4
1.2.3 SiteVisits ....................... 5
1.2.4 Assessing Costs and Benefits 5
1.2.5 Preparation of Case Study Reports 6
1.3 Organization ofthis Report ....................:... 6
2. Benefit/Cost Case Study Reports ............
Borough of Gettysburg, Pennsylvania
Eastern Lancaster County, Pennsylvania
Village of Gilbert, Louisiana
Town of Dartmouth, Massachusetts
City of Tumwater, Washington
City of Middletown, Ohio
i " , •.
Town of Norway, Maine
PARTTWO
LESSONS LEARNED
1.6 Introduction, and Overview ......................:... 1
1.1 Contamination Threats 1
1.1.1 Risks from Various Types of Contamination 1
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1.2
1.1.2 Potential Contamination Threats .•'.'....... 2
1.1.3- The Role of Siting ................ 3
Wellhead Protection ..'.:' ,....... ;. .. . .... 4.
2.
1.2.1 Effectiveness of WHPPs . ..-._, '• 4
1.2.2 Other-Factors :....... ... 6
1.2.3. Key WHP Elements . ...................... ... 6
1.2.4 Information Exchange 7
1.2.5 Role of Community Sparkplugs 1 8
1.2.6 Approaches to Contaminant Source Management 8
1.2.7 Difficulty of Adopting WHP Ordinances 11
1.2.8 Transferability of Innovative WHP Strategies 11
1.3 Who Pays? 1:.. '.: ........ 12
1.3.1 Financial Impacts of Contamination 12
1.3.2 Role of Outside Funding for WHP 13
CONCLUSIONS ,.;.•' :....... is
u
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PART ONE
1. INTRODUCTION
•" In 1994, EPA initiated this study of the benefits and costs of wellhead protection (WHP).
The purpose of the study was to compare the cost of local wellhead protection to the cost of
contamination which could have potentially been avoided as a wellhead protection program is crried
out. Additionally, the information is these case studies is intended to assist local decisionmakers
assess the value, cost and feasibility of implementing wellhead protection in their communities.
While the results reported below for the seven communities are neither exhaustive nor statistically
representative of all communities, they do provide an indication and present the potential extent and
range of benefits for a prevention program to protect community drinking water sources. EPA also
was interested in collecting observations on the study communities' experiences in .responding to
contamination incidents and in developing and implementing WHPPs.
Substantial information exists on the direct costs of remediating, treating, or replacing
contaminated drinking water. Some information also is available on the costs of developing and
implementing preventive ground water protection programs. Less information is available on the
indirect costs of unremediated groundwater contamination. These various types of data have not
been systematically compiled, analyzed, and compared, however.
The project development and methodology are presented below. Benefits are considered to
be the possible avoided costs to government and the private sector of remediating contamination and
threats to ground water sources of drinking water for community water systems. Costs are the local,
State, Federal and private sector funds spent for wellhead protection development and
implementation. The seven communities included in this study are:
Borough of Gettysburg, Pennsylvania .
Eastern Lancaster County, Pennsylvania ,
••-'..• Village of Gilbert, Louisiana
, Town of Dartmouth, Massachusetts • >
City of Tumwater, Washington •
. •,-:. City of Middletown, Ohio
Town of Norway, Maine
A detailed analysis of the results of these case studies is reported in: "Benefits and Costs of
Prevention: Case Studies of Community Wellhead Protection; Volume 1; Source Water Protection
Business and Economics Series Report No. 2, .November 30,1995," Office of Ground Water and
Drinking Water, U.S. Environmental Protection Agency, Washington, D.C. 20460.
1
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Benefits and Costs of Prevention
November 30, 1995
1.1 Definition of Benefit
The benefits that individuals and businesses realize from WHP fall into two categories. The
first is the benefit accruing from the use of water as a commodity for drinking, and for agricultural
and industrial purposes. Because markets exist for water, the commodity value usually can be
calculated. The second type of benefits are called resource benefits. They include the benefit of:
(1) being able to'use.groundwater as a resource sometime in the future, (2) having a source of water
for future generations, and (3) knowing the ground water is not contaminated, even if it is not used.
Because markets generally do not exist for resource benefits, they are not usually calculated.
The technique used in this study to measure commodity benefits is known as the avoided
cost method. This technique estimates the costs that would be incurred hi the absence of a WHPP.
Because a WHPP is designed to prevent these costs, they are treated as "benefits" of the program and
are called avoided-cost benefits.
The use of the avoided cost technique is premised on response costs. If ground water may
be contaminated, communities and others that rely on that water can expect, at some point, to incur
costs associated with responding to contamination. The expected value of these costs depends on:
• The cost of actions taken in response to contamination, which generally include
remediating or treating the water, or in cases of severe contamination, developing
alternative water supplies;
• The 'costs of damages that result from the contamination, such as losses in
agricultuiaL crop production or increased industrial production costs; and
• The probability of contamination.
An effective WHPP .will significantly reduce the likelihood of contamination, thereby reducing the
expected cost of contamination responses and damages. If the costs associated with responding to
contamination can be avoided by implementing a WHPP, the avoidance of these costs is regarded
as a quantifiable or tangible benefit. •
The second step in quantifying the benefits and costs of WHP is to assess:
• The cost of developing and implementing the WHPP; and
• The probability that the WHPP will prevent contamination.
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Benefits and Costs of Prevention
November 30, 1995
For purposes of calculating benefits and costs, we assume that a contamination incident has a 100
percent probability of occurring and that the WHPP will be completely effective. We note, however,
in Part 2, that some of the WHPPs have weaknesses which may reduce their effectiveness in certain
circumstances.
This report encompasses the results of five case studies of communities which have
experienced contamination of ground water sources and have implemented WHPPs.1 The objective
of each case study was to quantify, to the maximum extent possible, the costs of responding to
contamination and the costs of developing and implementing the WHPP.
1.2 Methodology
Three broad types of information guided the development of the study methodology and the
selection of case studies:
• Community/public water system (PWS) description (e.g., population, land use
patterns, geology and hydrology, number of wells, and financial and management
characteristics of the PWS);
• History of the contamination incident and WHPP development (e.g., discoyery,
characterization, and response to contamination, and development and implementa-
tion pf preventive measures); and . .
• Cost data (e.g., cost to provide replacement water, aquifer remediation costs, and
costs of developing and implementing a WHPP).
The study team developed a comprehensive list of required data elements within each of the three
categories. The team also identified probable sources of information for each data element (e.g., data
bases, knowledgeable staff, or local/state/federal agencies). The team consulted with EPA staff on
the proposed data element list, and refined the list based upon EPA's input.
1.2.1 PUot Study
The study team conducted a pilot study to validate the proposed case study methodology.
Early in the development of the methodology, the team proposed that two geologically and
socioeconomicaUy similar communities could be studied and compared. One community would
'The study also included two pilot case studies: one each of a community that has experienced contamination and"
a community with a wellhead protection program. ' .
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Benefits and Costs of Prevention
November ,30, 1995
serve as the subject of analysis on the costs and effects of WHP, and another as a "reference"
community from which to compile data on contamination.
To minimize project costs, the study team decided to focus on a pair of communities -within
a few hours' travel by car from Washington, DC. At the recommendation of EPA Region 3 and the
Pennsylvania Department of Environmental Resources, the team selected Gettysburg, Pennsylvania
and four communities in nearby Lancaster County for the pilot study. A well in Gettysburg has been
contaminated by a nearby dry cleaning facility. The four localities hi Lancaster County are co-
developing a regional WHPP. The two communities appeared to be similar enough that then: costs
could be compared. : /
The pilot study validated the proposed methodology for collecting data and demonstrated that
the types of data sought were appropriate. The project team discovered, however, that despite a
similarity in geology, the spcioeconomic differences between the two communities would not permit
an accurate comparison of costs. As a'result of the pilot study, the project team decided that each
subsequent case study would focus on a single community that had experienced a contamination
incident and developed a •WHPP. This would eliminate the tune-consuming step of identifying an
analogous reference community and simplify the analysis.
X.2.2 Case Study Selection
To be certain that the project would be representative of the nation as a whole, the project
team made an effort to include case studies in several geographic regions of the country. The EPA
Work Assignment Manager asked ground water protection and/or drinking water staff hi several
EPA Regional offices to recommended points of contact hi state environmental agencies. Because
state staff often work closely .with local communities on contamination and WHP issues, the project
team consulted with them early hi the case study selection process. The team asked state staff to
recommend communities where:
• The response to a contamination incident is underway and the cost has been
documented reasonably well;
• WHPP development is sufficiently far along to permit estimation of both
development and implementation costs;
• Local staff would be willing to participate hi interviews and assist in gathering cost
data.
The availability of data became a driving factor in the selection of case studies: where
contamination incidents occurred long ago, or were the subject of litigation, reliable or complete data
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Benefits and Costs of Prevention
November 30, 1995
might not be available. Similarly, cases where contamination incidents or WHPP development had
occurred recently would not provide sufficient data on ongoing costs.
State staff typically nominated several potential case study communities in their states. The
project team then contacted local officials in the communities to determine their interest in
.participating in the study, and to request mformation on the contamination incident and the WHPP.
The team reviewed preliminary data on the community, such as recent sanitary surveys, WHP
project reports, or contamination assessments.
The decision to seek communities that had experienced contamination and had developed
a WHPP simplified the analysis, but greatly increased the difficulty of case study selection. The
study team screened several communities that have well-documented contamination incidents, but
are only in the early stages of WHPP development, or vice versa. The study team tried to select
communities that offered the most complete documentation on both contamination and WHP. In
some cases, this meant rejecting communities that offered more complete information on either
contamination or WHP, but not both.
1.23 Site Visits
' " • • •
As indicated in Section 1.2.2, EPA Regional offices and/or state environmental staff provided
the name of a primary contact person (usually the PWS operator) in the communities. Upon
selecting a community as a case study, the project team contacted the PWS operator to schedule a
visit, and to inquire about other appropriate contacts.
The team set up interviews with local, state, or EPA Regional staff involved with either
responding to the contamination or developing the WHPP. These staff included: PWS operators;
state/local health department officials; property, owners, real estate agents, or tax assessors who
would be familiar with the effects of contamination or WHP on property values; consultants and
engineers working with the community on contamination Or WHP; officials at the agency
responsible for aquifer remediation; state drinking water program staff; and private citizens.
The team traveled to the communities to interview these staff in person. By being on-site,
the team was able to interview multiple staff within the same offices, gather decision documents or
project files, and collect background information on the community. The team also visited the
contamination sites and wellfields when possible to establish a visual point of reference.
1.2.4 Assessing Costs and Benefits
While onsite, the project team collected data on the costs of responding to contamination and
developing and implementing the local WHPP. The study team consulted decision documents,
consultant reports, WHPP documents, PWS budgets, equipment invoices, and contract information.
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Benefits and Costs of Prevention
• November 30, 1995
The most problematic costs to identify were indirect costs (e.g., financial effects of
contamination and WHP on businesses and property owners).' None of the incidents has affected a
large geographic area, so the number of potentially affected residences arid businesses is relatively
small. Often, the volume of property transactions would not permit a comprehensive analysis of
effects on real estate values or property salability. Further, aquifer remediation has not begun in
several of the communities (Gilbert, Tumwater, Middletown), so visual clues about contamination
(e.g., air strippers, soil removal) are not present In these communities, the extent of the
contamination may not be apparent, or the incident may not have immediacy for local citizens.
Thus, it may be.too early for indirect effects to manifest themselves. In the few cases where indirect
costs appear to be present, only anecdotal data were available. .
Because many communities are hi the early stages of responding to contamination or
developing their WHPPs, the project team frequently had to estimate out-year costs.. For
contamination incidents, the team relied on preliminary decision documents (e.g., conceptual design
reports) and presented costs of the most likely or preferred remedial scenarios. To estimate ongoing
WHP costs, the team asked knowledgeable staff to estimate the "unit" cost of an element 'of
implementation, such as an inspection or a round of monitoring. Using this information, the team
projected annual WHPP implementation costs. ,.
Based upon the data collected, the team arrayed costs to date (i.e., from the discovery of
•contamination/inception of the WHPP until September 1995) and projected future costs (from
October 1995 to September 2005) into cost spreadsheets. For purposes of comparison, all costs were
adjusted to constant 1994 dollars. Future cost streams were discounted to the present at a 7 percent
annual interest rate. ,
' - ' • : ' *~> ' ,
1.2.5 Preparation of Case Study Reports
The study team developed a prototype case study report format and submitted it to EPA for
review. Based on EPA's comments, the team revised the report format. The reports describe the
community and PWS, the contamination incident, the response to the contamination, the costs of
contamination, the WHPP, and costs of WHP. The case study reports, accompanied by the
benefit/cost spreadsheets, appear as an appendix to this report.
1.3 Organization of this Report
- The remainder of this report is organized as follows:
• Benefit/Cost Case Study Reports contain the summaries of the seven case
communities.
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Benefits and Costs of Prevention
November 30, 1995
Part Two '- Lessons Learned summarizes observations made by the project team
in the course of preparing the case studies and discusses the policy implications of
some of the case study findings.
7
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Benefits and Costs of Prevention
' November 30, 1995
2. BENEFIT/COST CASE STUDY REPORTS
- - -,-.--••. , | - .
The Benefit/Cost Case Study Reports for the seven communities in this study appear below
in the following order:
Borough of Gettysburg, Pennsylvania .
Eastern Lancaster County, Pennsylvania
Village of Gilbert, Louisiana
Town of Dartmouth, Massachusetts
. City of Tumwater, Washington
City of Middletown, Ohio
Town of Norway, Maine
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Contract No. 68-C4-0011
Work Assignment No. 1-14
Benefit/Cost Analysis of Preventing Contamination:
Gettysburg, Pennsylvania
September 30, 1995
Submitted to:
U.S. Environmental Protection Agency
Ground Water Protection Division
Technical and Information Management Branch
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TABLE OF CONTENTS
1.0 COMMUNITY DESCRIPTION . . . 1
1.1 Land Use ... . . ... . . 1
1.2 Geology/Topography 2
1.3 Hydrology/Climate . '. 2
2.0 PWS CHARACTERISTICS . . . . . ....';..:. . . 3
2.1 Wafer Supply . . ..........:....... .:...... 3
2.1.1 .Surface Water Sources 4
2.1.2 Ground Water Sources-. ..-.'." 4
2.2 Financial/Management Characteristics 5
2.3 Population Served 6
3.0 CONTAMINATION I . , ............: : . 6
3.1 Contamination Source . . 6
3.2 Contaminants 8
3.2.1 Contaminants in Soil 8
3.2.2 Contaminants in Ground Water 8
3.3 Effects of Contamination 9
4.0 RESPONSE ACTIVITIES ....... ... .v.........., . 9
4.1 Response to Contamination of the Water Supply 9
4.2 Response to Aquifer Contamination 10
5.0 COSTS OF CONTAMINATION ... . . ..... 10
5.1 Tangible Costs ^. ... 11
5.1.1 Costs to Provide Safe Drinking Water . . — ... 11
5.1.2' Costs to Remediate Aquifer ., .,'-. . 13
5.2 Intangible Costs '.-. . . 16
6.0 CONCLUSION ... ... ........... ... . . . . . 16
7.0 REFERENCES ........ . . 17
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LIST OF EXHIBITS
Exhibit 1 Characteristics of PWS Sources
Exhibit 2 Site Map
Exhibits Cost to Date of Respondmg to Contamination
Exhibit 4 Future Cost of Responding to Contamination: 5-Year Scenario
Exhibits Future Cost of Responding to Contamination: 30-Year Scenario
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BENEFIT/COST ANALYSIS OF PREVENTING CONTAMINATION
GETTYSBURG, ADAMS COUNTY, PENNSYLVANIA
One of the water supply wells in the historic borough of Gettysburg, PA is
contaminated by carcinogenic volatile organic chemicals. The contamination, discovered
during state-required pre-operation water sampling, has been traced to a floor drain inside a
dry cleaning establishment located 600 feet from the well.
As a result of the contamination, the Gettysburg Municipal Authority (GMA) must
conduct extra monitoring and treat the water with an air stripper prior to usage. The
Pennsylvania Department of Environmental Resources (PADER) has listed the dry cleaners
site on its priority list of contaminated sites. PADER intends to install a complex treatment
system that will treat the highly contaminated ground water around the site.
1.0 COMMUNITY DESCRIPTION
The Gettysburg Municipal Authority (GMA) provides drinking water to the borough of
Gettysburg, and portions of the surrounding townships of Straban and Cumberland.1
Gettysburg, the seat of Adams County, is located in south-central Pennsylvania. Its year-
round population is approximately 7,025. Much of the local economy is centered around
agriculture, tourism, and two local colleges.
1.1 Land Use
Gettysburg, located at the junction of several principal routes through Adams County,
has evolved into a relatively busy commercial, institutional, and residential center. In
contrast, much of the rest of the county remains rural in character, consisting of farms,
orchards, open fields, arid woodlands. The population of Adams County is centered hi
Gettysburg: the population density in the borough is 4,391 persons per square mile, in
contrast to the county's overall population density of 149 persons per square mile.
* ' • ' .".•.--•
According to the 1992 U.S. Census of Agriculture, 56 percent of the land in Adams
County is farmland. The county is one. of Pennsylvania's top producers of apples, peaches,
turkeys, and eggs. Agricultural production generates over $123 million in annual revenues.
The Gettysburg National Military Park and Eisenhower National Historic Site draw
more than 1.3 million visitors each year, mostly during the summer months. The two parks
consist of more than 6,000 acres which nearly surround the borough. In 1990, Congress
passed legislation authorizing the National Park Service to acquire additional lands for the
Gettysburg National Military Park. Although both parks pump more than $50 million into the.
local economy each year, the historical nature of the region tends to impede development.
'In Pennsylvania, boroughs, townships, and cities have considerable rulemaking and enforcement powers.
governments have limited authority.
. •' _ 1 - '
County
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Benefit/Cost Analysis of Preventing Contamination: Borough of Gettysburg, Pennsylvania
All new construction must be preceded by archaeological surveys to protect Civil War
artifacts. In addition, Adams County tries to discourage development that would adversely
affect the historical character of the region.
In recent years, extensive commercial .and residential strip development along major
roads has begun to threaten the region's rural character. Recent county planning efforts have
been geared toward encouraging development in community centers and discouraging
development in outlying areas.
• i " - , • • '
1.2 Geology/Topography
Much of Adams County is rolling lowlands, which form a part of the Piedmont
physiographic province known as the Gettysburg Plain. The average elevation of Gettysburg
is approximately 526 feet above mean sea level.
The Gettysburg region is underlain by Triassic sedimentary rocks. These rocks consist;
primarily of relatively nonresistant red shale and sandstone, and minor amounts of limestone.
Intrusions of diabase, or trap rock, are found throughout the sedimentary rock. These
intrusions form ridges and hills within the lowland areas.
1.3 Hydrology/Climate
Adams County is located in two major watersheds tributary to the Chesapeake Bay.
The Susquehanna River watershed drains the northeastern half of the county, and the Potomac
River, watershed drains the southwestern half of the county. Marsh Creek is the only major
body of surface water in the vicinity of Gettysburg.
Much of Gettysburg and Adams County relies oh ground water for drinking. Based
on field observations and geophysical data, two principal ground water flow zones appear to
exist within Gettysburg. Monitoring performed at the J.C. Cleaners site (discussed in Section
3.2) has indicated the presence of a shallow waterbearing zone at a depth of roughly 70 to
105 feet and a deep waterbearing zone at a depth of about 250 to 275 feet. The deep zone
appears to be semi-confined to confined. Within the shallow ground water zone, natural flow
is toward the north; in the deep zone, flow is to the northeast and east. .
Ground water in Adams County is relatively plentiful. Hydrologic investigations have
estimated that in a year with average rainfall, approximately 98 million gallons per day (mgd)
of ground water are potentially available for use within the Triassic waterbearing rocks
underlying the county. Most of the wells in the Gettysburg area exhibit a low-to-moderate
yield. Sandstones and shale aquifers typically have relatively low transmissivity; water is
transmitted through fractures. ,
-2-
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Benefit/Cost Analysis of Preventing Contamination: Borough of Gettysburg, Pennsylvania
The average annual precipitation in Gettysburg is 39 inches, and is evenly distributed
throughout the year. Of this, 24 inches is lost to evapotranspiration, eight inches runs directly
into creeks and streams, and seven inches infiltrate into the ground. Pennsylvania lies within
the temperate climate zone. The average annual temperature in the region is 53 degrees,
ranging from 30 degrees in January to 70 degrees in July.
2.0 PWS CHARACTERISTICS
GMA provides drinking water to Gettysburg, along with portions of Straban and
Cumberland Townships. GMA (PWS ID #7010019) is located within the borough of
Gettysburg, at approximately 39° 49' 27" north and 77° 14' 03" west. GMA operates a
filtration plant at Marsh Creek, eight wells, two primary transmission lines into Gettysburg,
and three storage facilities. '
2.1 Water Supply
GMA relies on a mixed ground water/surface water supply (see Exhibit 1). Fifty-four
percent of its water comes from ground water, and the remaining 46 percent is withdrawn
from Marsh Creek. The average demand on the system is approximately 1.5 mgd during •'
most of the year, rising to about 1.8 mgd during the height of the summer tourism season.
The safe yield of current water sources is about 2.2 mgd. GMA cannot easily connect with
neighboring PWSs because of the distances between communities and the hilly terrain
surrounding Gettysburg.
Tourists and students have traditionally placed seasonal demands on the drinking water
supply. Gettysburg College and the Lutheran Theological Seminary increase the Borough's
population during the school year. In the past, the summer tourism season and the school
year at the local colleges did not overlap; consequently, Gettysburg had a relatively steady
year-round population. In recent years, however, the schools have initiated summer camps
and tourism at the National Parks has extended into the spring and autumn. The combined
factors have increased overall water demand, especially during the' summer.
i '
The Gettysburg region has historically enjoyed high quality surface and ground water.
The water in Marsh Creek is of high quality, except that it sometimes does not meet the
primary drinking water standard for turbidity and the secondary standard for color after heavy
rains. Two of the PWS' eight wells currently are unusable due to hardness (i.e., high
concentrations of calcium chloride), which is GMA's most significant water quality problem.
Although GMA currently has no plans to drill new wells, the PWS would like to have all its
existing wells available to meet demand.
-3-
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Benefit/Cost Analysis of Preventing Contamination: Borough of Gettysburg, Pennsylvania
EXHIBIT 1
Characteristics of PWS Sources
Source
Marsh Creek
Welltfl ;
Well #2
Well #3
Well #4
Well #5
Well #6
Well #7
.Well #8
Depth
' N/A
550
Unavailable
500
655
420
900
Unavailable
Unavailable
Capacity (MGD)
, .96
o
0
.40
.22
- ' .37 '
•43
Unavailable
0
Status
Active
Off-line due to excessive
hardness
Off-line due to chlordane /
contamination ,.
Active
Active
Active . • ' , ,
Active
Active
Off-line due to excessive
hardness
2.1.1 Surface Water Sources
GMA is permitted to withdraw 960,000 gallons per day from Marsh Creek. To
increase the available water supply, the PWS pumps water from Well #1 into the creek at
times of high water flow. Although the water withdrawn from the well is too hard for
drinking, it may be discharged into the creek without adverse effects to aquatic life. The
PWS lets the aquifer recharge while it is withdrawing from the creek. Water is drawn from
Marsh Creek via a 24-inch main and routed through a filtration plant. The water also is
treated for taste and odor. GMA intends to ask the Pennsylvania Department of
EnvironmentaLResources (PADER) for authority to withdraw up to 2 mgd from Marsh Creek.
• 2.1.2 Ground Water Sources
GMA operates eight wells, six of which are currently online. The wells are located in
and around the borough of Gettysburg: some are close to,the Gettysburg commercial center;
others are in outlying areas. The total capacity of currently operating wells is 1.42 mgd. The
wells tap the deep waterbearing zones of the Gettysburg Formation. The ground water
generally is of good quality, but contains high concentrations of dissolved calcium carbonate.
-4-
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Benefit/Cost Analysis of Preventing Contamination: Borough of Gettysburg, Pennsylvania
GMA's eight wells are connected to a central distribution system via 8-inch and 10-
inch water mains. Water from all sources is routed to a central distribution unit prior to
transmission to users. Treatment within the. system consists of disinfection and particulate
removal. .
In 1983 GMA shut Well #2 .down after monitoring indicated the; presence of
trichlofoethene (TCE) and chlordane. Recent testing indicates that the TCE concentration is
0.7 ppb (the MCL is 5 ppb), and chlordane is below detectable levels. GMA currently is
working with PADER to restart this well.
PADER requires PWSs to obtain operating permits for new wells. In 1986 GMA
applied for an operating permit for Well #6. PADER sampled the well and determined that
ground water drawn by the well was contaminated by halogenated volatile organic compounds
(VOCs). The contamination and the response to contamination are described in Sections 3.0
and 4.0.
Well #8 exhibits a continuing hardness problem. Hardness levels were relatively
stable when the well was permitted in July 1992, but recently .these levels have risen sharply.
GMA believes that the cone of depression for the well has interacted with another well.
When GMA stopped pumping at the well, water quality improved. When pumping resumed,
the hardness levels rose again. , .
2.2 Financial/Management Characteristics
GMA, which provides both drinking water and wastewater services, is an independent
authority. Its annual operating budget of $870,000 is funded entirely from user charges.
Each customer pays a flat quarterly fee which depends upon the size of the meter. In
addition to the base charge, GMA has a declining block rate structure for customers whose
usage exceeds specified amounts, which vary depending on the size of the meter. The
average residential water bill is $43 per quarter; the average quarterly residential usage is ..' .
15,000 gallons. Water rates have increased only about 15 percent since 1985.
• •'•?,:•• ,
To fund capital improvements, GMA has adopted "tapping fees" on new residential
and commercial connections. The fee is $1,979 per equivalent daily unit (EDO) of expected
water use. GMA defines an EDU as 250 gallons per day.
,. GMA has approximately $2.5 million in outstanding debt related to it water supply
operations. The borough of Gettysburg backs'GMA debt with its full faith and credit.
-5-
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Benefit/Cost Analysis of Preventing Contamination: Borough of Gettysburg, Pennsylvania
2.3 Population Served
The GMA serves a combined population of 12,200 in Gettysburg, Cumberland and
Straban. The PWS serves the entire population (7,025) of Gettysburg; five percent (250) of
the population of Straban, and 10 percent (550) of Cumberland's population. In addition,
GMA serves a student and tourist population equivalent to about 4,375 permanent residents.
Outside of the borough, most residents rely on private wells. The PWS has 3,105 service
connections, 55 percent of which are commercial, and 45 percent of which are residential.
The PWS also supplies water to the National Parks.
3.0 CONTAMINATION
The primary VOCs present at Well #6 are tetrachloroethene (PCE), trichloroethylene,
(TCE), and 1,2-dichloroethenes (1,2-DCE). GMA's state operating permit for Well #6
requires it to treat the raw water and monitor quarterly for benzene, toluene, xylene, gasoline,
and fuel oil and semi-annually for phenols. Currently the total VOC concentration is 18 ppb;
however, concentrations of up to 56 ppb were indicated as recently as 1990.
3.1 , Contamination Source
GMA first discovered VOC contamination at ij:s Well #6 in 1986, during State-
required pre-operational monitoring. PADER conducted a preliminary search for the source
of contamination at the well in late 1986. It focused on dry cleaners located in the vicinity of
the well because PCE is a solvent commonly used in the dry cleaning process. PADER
identified J.C. Cleaners, located about 600 feet east-southeast of Well #6, as the likely source
of contamination. PADER subsequently determined that a drain located inside the. J.C.
Cleaners building was the source of the .contaminated ground water. "J.C. Cleaners had been
using the drain for legal discharge of wastewater into the Gettysburg sewer system. For
undetermined reasons, the drain failed and leaked wastewater into the soil. On October 8,
1986, PADER issued a Notice of Violation to J.C. Cleaners. In response, J.C. Cleaners
discontinued use of the drain system.
PADER evaluated the J.C. Cleaners site using EPA's Hazard Ranking System (HRS)
for Superfund sites. The site scored 35.68 and has been listed on the Pennsylvania Priority
List of Hazardous Sites for Remedial Response (PAPL), the state equivalent of the National
Priorities List (NPL) under CERCLA. Exhibit 2 is a map Of the area surrounding J.C.
Cleaners.
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Benefit/Cost Analysis of Preventing Contamination: Borough of Gettysburg, Pennsylvania
EXHIBIT 2
Site Map
. • - DW-5
' • .„ (100000)
Legend
-100- Total Halogenated VOCs (Sum ofTetrachloroethene, 1,2-
Dichlorethenes, and Trichloroethene) Contour Intervals
- -100- -Estimated Extent of Total Halogenated VOCs Contour
: ' Interval ,
° Deep Monitoring Wells •
| J.C.Cleaners WeU '
• . ' ' , . ' -7- '-
(17100)
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Benefit/Cost Analysis of Preventing Contamination: Borough of Gettysburg, Pennsylvania
3.2 Contaminants
Between July 1990 and March 1991, PADER conducted a two-phase contamination
assessment at the site. Phase I included a literature review, a site survey, mapping, and a
soil-gas purvey. Phase H included installation of shallow and deep monitoring wells, aquifer
characterization, pump and packer testing, and soil boring characterization. The monitoring.
well network at the site consists of ten shallow monitoring wells and ten intermediate-to-deep
monitoring wells. •
The contamination assessment determined that soil and ground water in the .vicinity of
J.C. Cleaners is contaminated with halogenated VOCs. The contamination is concentrated in
the area immediately around the J.C. Cleaners building. Contaminants are generally moving
to the north in the shallow zone. In the deep ground water zone, pumping from Well #6 is
drawing contamination toward the west and northwest. The shallow and deep ground water
zones exhibit minimal hydrologic connection. PADER's contamination assessment concluded
that a former private well on the J.C. cleaners site may have caused contamination to migrate
from the shallow to the deep ground water zone.
3.2.1 Contaminants in Soil .
Subsurface soil in the immediate vicinity and north of J.C. Cleaners contains PCE,
TCE, and 1,2-DCE. Total contaminant concentrations range from Not Detected to 492 ug/kg.
Near the J.C. Cleaners building, soils appear to be contaminated to the top of the bedrock, a
depth of 6.5 to 7,5 feet.
3.2.2 Contaminants in Ground Water
Contamination in the shallow waterbearing zone is primarily concentrated around the
J.C. Cleaners building. The primary contaminants are PCE, TCE, 1,2-DCE, benzene, and
vinyl chloride. PADER has concluded that the benzene improbably unrelated to the dry
cleaners, but is likely the result of leaks or spills from nearby service stations. The
contaminant plume extends north of Railroad Street, but at significantly lower concentrations.
Concentrations near the J.C. Cleaners building range from 210 ppb to 36,300 ppb. Offsite
concentrations range from not detected to 84 ppb. Contamination in the shallow ground water
zone is moving north toward Stevens Run at an estimated rate of 22.6 feet per year.
TJI the deep waterbearing zone, contamination is concentrated in the immediate vicinity
of the dry cleaners with decreasing levels extending to the west, north, and northeast.
Contaminant concentrations generally increase with depth. Near the J.C. Cleaners building,
contamination extends to a depth of at least 300 feet. The primary contaminants present are
PCE, TCE, and 1,2-DCE. In contrast to the shallow zone, the deep zone does not contain
vinyl chloride and benzene. Concentrations at Deep Monitoring Well #5 (adjacent to the
: •••.•• .. ., -8- •'•-., ' • ' . -.:
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Benefit/Cost Analysis of Preventing Contamination: Borough of Gettysburg, Pennsylvania
building) and at the J.C. Cleaners well are 100,000 ppb and 17,100 ppb, respectively. Offsite !
concentrations range from not detected to 224 ppb. Contamination in the deep zone is being
drawn westward as a result of pumping from GMA Well #6. The estimated rate of
contaminant movement is 54 feet per year. ,
3.3 Effects of Contamination
•Data available from State and local documents and interviews did not reveal any
explicit health or ecological effects associated with the J.C. Cleaners site, other than the
contamination of ground water.
'• • . . - / '
Although there have been no reports of contaminant-related illnesses among the
population served by GMA, exposure to TCE and PCE can have potentially serious health
effects. Both chemicals are carcinogens. Oral exposure to TCE can cause vpmiting,
abdominal pain, and unconsciousness; long-term exposure may damage the liver. Studies on
PCE exposure have linked the contaminant to abnormal effects on the liver, kidney and
central nervous system in humans.
4.0 RESPONSE ACTIVITIES
GMA and PADER are undertaking two distinct activities in response to the
contamination at the J.C. Cleaners site. Since 1987 GMA has ensured safe water by treating
the raw water at Well #6. PADER intends to install a ground water collection and treatment
system to remediate the contamination plume in both waterbearing zones. The system is
currently in the design phase; PADER hopes to begin construction in early 1996. .
Both GMA and PADER have selected air stripping to remove contaminants from the
ground water and PADER will use soil vapor extraction to remove contaminants from the
soil. The following sections describe the specific response actions GMA and PADER are
taking or intend to take. .
4.1 Response to Contamination of the Water Supply
In 1987 GMA installed a treatment system on municipal Well #6 to remove the
halogenated VOCs from raw water. The system consists of. an air stripping tower and
pumping system. According to GMA's monitoring data, the air stripper achieves nearly 100
percent contaminant removal. The treated ground water is mixed with water from other
sources and pumped into the GMA distribution system.
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Benefit/Cost Analysis of Preventing Contamination: Borough of Gettysburg, Pennsylvania
4.2 Response to Aquifer Contamination
On April 11, 1994 PADER filed a Statement of Decision describing its remediation
objectives and selected remedy for the J.C. Cleaners site. PADER's objectives are to:
• Treat contaminated soil in order to prevent further degradation of ground water;
and
' >• Remediate ground water to background levels consistent with the Pennsylvania
Ground Water Quality Protection Strategy. ;
PADER will install a soil vapor extraction system to remove contaminants from the
soil. Ground water recovered during the treatment process will be discharged to the ground
water treatment system and treated onsite.
PADER will use an extraction well to remove the most highly contaminated ground
water nearest the J.C. Cleaners facility. Contaminated ground water will be treated in a low
profile air stripping system with a carbon absorption unit to capture the vapor phase of the
contaminants. The treatment system will be housed in a vacant building on the J.C, Cleaners
site to minimize the aesthetic impact on the surrounding neighborhood. The deep ground
water zone will be remediated first because it is more highly contaminated and because Well
.#6 draws from it.
Treated ground water will be discharged to Stevens Run through a nearby storm sewer.
During the consideration of treatment alternatives, GMA had requested that PADER discharge
treated ground water into its air stripper sump at Well #6. PADER determined that the cost
of constructing a pipeline to the sump was prohibitive. Shallow ground water and the liquid
phase collected from the soil vapor extraction unit would be influenced by surface water and
would have required construction of a filtration system before the water could be used for
drinking. In, addition, the pipeline would have to cross railroad tracks and several major
utility lines; which would add significantly to the cost.
PADER anticipates completing pre-remedial design activities by late 1995. At that
time, PADER will request bids for construction and the first year of O&M. The agency
expects remedial construction to begin in early 1996.
5.0 COSTS OF CONTAMINATION
As of September 1995, the total costs incurred by PADER, GMA, arid the Borough of
Gettysburg is approximately $1.4 million ($1.7 million in 1994 dollars). Although PADER
has not determined the duration of ground water remediation, it estimates O&M costs for both
- 10--
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Benefit/Cost Analysis ofPreventing Contamination: Borough of Gettysburg, Pennsylvania-
five-year and thirty-year treatment scenarios. Expected future costs will be at least $2.26
million to $3.9 million (on a net present value basis),2 depending on the remediation scenario.
5.1 Tangible Costs
Exhibits 3, 4, and 5 are detailed tables listing remediation costs for treatment of Well
#6, and remediation of contaminated soil and ground water at the J.C. Cleaners site. The
following sections summarize these costs.
5.1.1 Costs to Provide Safe Drinking Water
GMA spent a total of $247,013 ($321,117 in 1994 dollars) in capital costs (see Exhibit
3). These costs include $231,732 ($301,252 in 1994 dollars) for designing and constructing
the air stripper, and $15,281 ($19,865 in 1994 dollars) for land acquisition. Since 1987,
GMA's incremental O&M costs for treating Well #6 have been approximately $27,562 (in
1994 dollars). These additional electrical, monitoring, and repair costs represent
approximately two percent of GMA's annual operating budget. ' • .
Electricity is the largest component of O&M costs. The annual cost for electricity at
Well #6 is approximately $25,000 to $28,000. In contrast, the typical cost of electricity for
GMA's other wells is about $15,000. In addition, GMA's state permit for Well #6 requires
that it monitor quarterly for benzene, toluene, xylene, gasoline, and fuel oil; and semi-
annually for phenols. Since 1987 GMA has spent approximately $10,240 ($10,138 hi 1994
dollars), or about $1,280 per year (in 1994 dollars) for this additional monitoring.
GMA has funded both capital and operating costs from its annual operating budget. , „
GMA has recently raised its water rates by five percent, but the increase appears to result
from general cost increases rather than the incremental cost of treating Well #6.
present,value of five-year and 30-year remediation costs are calculated assuming a discount rate of seven percent.
• • ' , ' - 11 - . " •'..••;' -,. ' .
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Benefit/Cost Analysis of Preventing Contamination: Borough of Gettysburg, Pennsylvania
Cost of Responding to
Exhibits
Contamination: Gettysburg,
PA
February 1987 to September. 1995
; -.-.-•..• '-••'.
Item
•
($1994)
Borough of
GMA Gettysburg
PADER
Total
[ProvktehSafeDririkincr Water - '
One-time costs
Engineering/construction of air stripper
Land acquisition
SUBTOTAL:
Incremental operating costs (since 1987)
Monitoring ($1,280 per year) ,
Electricity ($12,000 per year)
Repairs ($1,000 per year)
SUBTOTAL:
,
TOTAL:
i Remediate; Aquifer ~~~ ~
Pre-remediation
Contamination assessment/aquifer characterization
. " Remedial design
Pre-final design , •
Oversight '* •
Monitoring • ' - •
Enforcement • , .
Planning
Program Management
.Administration
TOTAL:
[iTsOTAL COST:
301.252
19,865
$321.117 $0
10,138
9,504
7,920
$27.562 • $0
$348,679 $0 •
,
500
1
$0 $500
$348.679 $500
•
$0
'
$0
$0
1,034,666
128,458
182,950
24,195
11,329
: 223
, 18,847
112
$1,400,780
$1,400^780 ;
301,252
19,865
$321, 1i7
10,138
9,504
7,920
$27,562
$348,679
'•" i
'
1,035,166
128,458
182,950
24,195
11,329
223
18,847
112
$1,401,280
$1i749;959:i
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Benefit/Cost Analysis of Preventing Contamination: Borough of Gettysburg, Pennsylvania
Depending on the duration of remediation, GMA will incur incremental costs of
between $58,500 and'$100,000 (net present value). Electricity would account for about 90
percent of these costs. " , •
5.1.2 Costs to Remediate Aquifer
As of September 1995, PADER has spent at least $1.26 million ($1.4 million in 1994
dollars) for the contamination assessment and the conceptual design of remedial alternatives.
This includes about $1.21 million ($L35 million hi 1994 dollars) in contractor costs and
roughly $0.05 million (in 1994 dollars) in staff costs. The actual staff cost is probably higher
because PADER did not track costs for the J.C. Cleaners site separately prior to 1989.
PADER's conceptual design alternatives report provides estimates of both capital and
O&M costs for the ground water extraction and treatment system and for the soil vapor
extraction system.
• . Capital costs include direct costs (e.g., purchased equipment and construction
materials, equipment and material installation, piping and electrical, buildings,
healing and ventilation, health and safety equipment) and indirect costs (e.g.,
surveying, construction inspection, engineering/design, health and safety, and
administration).
• O&M costs include electrical costs, labor costs for maintenance, maintenance
materials, administration, insurance, taxes, licenses, equipment replacement
costs, trench maintenance, and analytical costs.
PADER projects that remediation of soil and ground water contamination will require
approximately $0.82 million (net present value) hi capital expenditures, depending on the
remediation scenario chosen. Depending on the duration of the remedy, the net present value
of O&M costs between 1995 and 2005 .will be approximately $1.38 million to $1.93 million.
(If remediation takes 30 years, total O&M costs could exceed $3.9 million.) Exhibits 4 and 5
show future costs through September 2005 associated with five-year and 30-year remediation
scenarios, respectively. • ' •
PADER will fund the cost of remediation through its Hazardous Sites Cleanup
Program (HSCP). It is unlikely that the Agency will be able to recover a significant portion
of the remedial costs from J.C. Cleaners. The dry cleaner's only contribution to the cleanup
effort is the use of a room in the building in which PADER will house the air stripper.
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Benefit/Cost Analysis of Preventing Contamination: Borough of Gettysburg, Pennsylv,
•ama
Exhibit 4
Future Cost of Responding to Contamination (Five-year Scenario): Gettysburg PA
October 1995 to September 2005
($1994)
Item QMA PADER Total
.
1 Provide :Safe:Orihkihg Water .• > • ::.::,.]
Incremental operating costs
Monitoring ($1 ,280 per year)
Electricity ($12,000 per year)
Repairs ($1,000 per year)
SUBTOTAL:
liReriwdialeiAquIfer
Capital costs
GW collection
GW treatment
Soil vapor extraction
SUBTOTAL:
O&Mcosts
GW collection '
• GW treatment
Soil vapor extraction
SUBTOTAL:
TOTAL:
{TOTAliiCOSTt
5,248
49,202
4,100
$58,551
$0
$0
$0
$58,551
$0
310,593
: 407,556
105,840
$823,990
179.330
999,296
204,225
$1,382,851
$2,206,841 ,
$2i20S;B4t
$5,248
, $49,202 .
$4,100
$58,551
$310,593
$407,556
$105,840
$823,990
$179,330
'$999,296
$204,225
$1,382.851
$2,206,841
$2.265392
•-•.. • ' \.
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Benefit/Cost Analysis of Preventing Contamination: Borough of Gettysburg, Pennsylvania
.'-••'. . •• • •
Exhibits
Future Cost of Responding to Contamination (Thirty-year Scenario): Gettysburg, PA (1)
October 1995 to September 2005
($1994)
Item GMA PADER Total
^Provide Safe Blinking Water , - \
Incremental operating costs
Monitoring ($1,280 per year) 8,990
Electricity ($12,000 per year) 84,283
Repairs ($1,000 per year) 7,024
SUBTOTAL: $100,297
$0
8,990
84,283
7,024
$100,297
fRertiediate;Aquifer • ' j
Capital costs
• ' GW collection
GW treatment
Soil vapor extraction
SUBTOTAL: . , $0
O&M costs
GW collection
GW treatment'
Soil vapor extraction ' , • ,
SUBTOTAL: ' . $0
' TOTAL: $0
fTOTALCOST: . - ' $100,297 c:! i
Note:
(1 ) Costs represent first 1 0 years of 30-year remediation
310,593
• 407,556
105,840
$823,990 .
185,135
1,547,077
204,225
$1,936,437
$2,760,426
:'::-$2i760!j426::::,! : ,
310,593
407,556
105,840
$823,990
185,135
1,547,077
204,225
$1,936,437
$2,760,426
$2s860;jr23:j
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' Benefit/Cost Analysis of Preventing Contamination: Borough of Gettysburg, Pennsylvania
5.2 Intangible Costs
A local realtor with considerable experience in property assessment indicated that
neither property values nor the salability of properties near J.C. Gleaners have been affected
by the ground water contamination. One explanation is that the site is not well known in the
community. Other factors are the commercial character of the area surrounding the site and
the low turnover of properties. .-..•'
The realtor speculated that, in general, contaminated sites tend to limit the market for
adjacent and/or affected properties. She provided some anecdotal evidence .that federal
Superfund sites in the county may have had limited effects on the market for adjacent
properties. She did not have any hard evidence indicating these effects, primarily because of
the small number of property transactions in the area. The county tax assessor indicated that
no property owners near J.C; Cleaners have challenged their property assessments on the
grounds that the presence of contamination has lowered their property values.
Although GMA provides drinking water to the area around J.C. Cleaners, a few private
wells are present nearby. At least two of these wells, including an inactive well at J.C.
Cleaners, have been contaminated. The project team could not determine whether or not the
other wells were hi active use prior to the contamination incident.
6.0 CONCLUSION
Contamination due to an accident at a common type of business facility caused GMA
and PADER to incur costs which could potentially exceed $5 million. GMA and PADER
have spent nearly $2.26 million (in 1994 dollars) to protect Well #6 and to assess the severity
of the contamination. Between 1995 and 2005, future costs of monitoring, ground water
extraction.and treatment, and soil vapor extraction will total $2.26 million to $2.86 million.
If the 30-year remedial scenario is played out, future costs could approach $4 million.
If Gettysburg had a Wellhead Protection Program prior to 1986, the contamination and
associated costs may have been avoided. A source identification program could 4have
identified the dry cleaner as a potential source of contamination, and could have led GMA to
site the well elsewhere to avoid the contamination. Even if GMA had sited the well, a source
management program that included inspections may have detected the leak early enough to
prevent, or at least minimize, the contamination.
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Benefit/Cost Analysis of Preventing Contamination: Borough of Gettysburg, Pennsylvania
7.0 REFERENCES
Adams County Office of Planning and Development. Adams County Comprehensive Plan.
Prepared by Norman Day Associates. 1990. -
Hartmari, Barbara. Owner, Bigham Realtors. Personal interview, October 19, 1994.
PADER. Contamination Assessment as the J.C. Cleaners Site; Phases I and II. Prepared by
Baker Environmental, Inc. March 1991.
PADER. J.C. Cleaners Conceptual Design Alternatives Project; Volume I. Prepared by
Baker Environmental, Inc. January 1993.
Pine, Eugene. Hydrogeologist, PADER Hazardous Sites Cleanup Program. Personal
interview, October 20, 1994..
Smith, John. Sanitary Engineer, PADER Environmental Cleanup Program. Personal
interview, October 20, 1994. •'•-...'
U.S. EPA, Office of Drinking Water. Health Advisories for 25 Organics PB87-235578,
March 1987.
Watson, James. Manager, Gettysburg Municipal Authority. Personal interview, October 19,
1994. , .
- 17-
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Contract No. 68-C4-0011
Work Assignment No. 1-14
Benefit/Cost Analysis of Preventing Contamination:
Eastern Lancaster County, Pennsylvania
September 30, 1995
Submitted to:
, U.S. Environmental Protection Agency
Ground Water Protection Division
Technical and Information Management Branch
-------
LIST OF EXHIBITS
Exhibit 1 Characteristics of PWS Wells
Exhibit 2 Cost to Date of Wellhead Protection
Exhibit 3 Future Cost of Wellhead Protection
-------
TABLE OF CONTENTS
1.0 COMMUNITY DESCRIPTION ....... ... ..... . . .... l
1.1 Land Use ^ 1
1.2 Geology/ Topography ...............................\ ... ^ . 2
1.3 Hydrology/Climate . . 2
2.0 PWS CHARACTERISTICS . . . . . .>.....,..:.. ... •;.'... 2
2,1 Water Supply ........ , , 3
2.2 Population Served ...... . . . . ., ....-.' 4
3,0 WELLHEAD PROTECTION . . . . . :,........ ... .... .,..,.. 4
3.1 State Requirements for Wellhead Protection 4
3.2 . Local Wellhead Protection Plan . . . v. .' 5
: 3.2.1 Wellhead Protection Area Delineation . . . '..--. . . . 5
3.2.2 Source Identification . '• . - .'.. . . . . . . . , ..... 5
3.2.3 Management Plan ,6
3.2.4 Contingency Plan ...................... \". ; . . . . 6
4.0 COSTS OF WELLHEAD PROTECTION . ............ , 7
1 4.1 Tangible Costs 7
4.1.1 Wellhead Protection Area Delineation Costs 7
4.1.2 Source Identification Costs . . 7
4.1.3 Management Plan Costs .... 9
4.1.4 Contingency Plan Costs ',.' ..... '. ....... 9
• 4.2 ' Intangible Costs .............:............. 9
5.0 , CONCLUSION ...................... ............ ... 11
6.0 REFERENCES . . . . . . . 11
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BENEFIT/COST ANALYSIS OF PREVENTING CONTAMINATION
EASTERN LANCASTER COUNTY, PENNSYLVANIA
Four small communities in eastern Lancaster County, Pennsylvania are co-developing a
regional Wellhead Protection Program. The boroughs of Terre Hill and New Holland and the
surrounding Earl and East Earl townships lie in a relatively undeveloped, agricultural portion
of Lancaster County. The county is currently one of the fastest-developing rural counties in
the nation: residential development is spreading into the county from nearby Philadelphia.
The region was the subject of a pilot test of a Wellhead Protection Area delineation
method known as fracture trace analysis by EPA Region 3 and the Pennsylvania Department
of Environmental Resources. Wellhead protection areas have been delineated and pollution
sources identified in all four communities. The communities have drafted management plans,
but have not yet formally adopted them.
1.0 COMMUNITY DESCRIPTION
Lancaster County is located in southeastern Pennsylvania. Four communities in the
eastern portion of the county are jointly developing and implementing a regional wellhead •
protection strategy. These communities—the boroughs of Terre Hill and New Holland and
the surrounding Earl and East Earl townships—have a combined population of 19,000.
1.1 Land Use
Agriculture is the primary land use in Lancaster County, the most agriculturally
productive non-irrigated county in the United States. According to the 1992 Census of
Agriculture, the total market value of all agricultural products sold by the county was $681
million. Of that income, $77 million was from the sale of crops, including apples, corn, oats,
and potatoes. Livestock and poultry products, primarily chickens, hogs, arid cattle, provided
an income to the county of $604 million.
Industry in the county reflects its agricultural nature: it includes farming equipment
manufacturing and food processing/animal rendering plants. No data are available on the
income from these industries. Over 90 percent of the townships in Lancaster County
(309,000 acres) are zoned for agricultural use.
The region is experiencing less development than much of Lancaster county.
Recently, residential development spreading into the county from nearby Philadelphia has
become a potential concern. The potential for development of farmland for industrial use is
the biggest water quality concern in the region. Of the four jurisdictions comprising this case
study, New Holland has experienced the most development. ,
- 1 •-.
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Benefit/Cost Analysis of Preventing Contamination: Eastern Lancaster County, Pennsylvania
1.2 Geology/ Topography
Eastern Lancaster County is located within the Piedmont physiographic province of the
United States. Terre Hill is located within Triassic Lowlands; the remaining three
communities are situated on lower areas created by more easily eroded rock. .
- - _ /
Terre Hill is underlain by Triassic-age conglomerates, sandstone, arid shales of the
Hammer Creek Formation. New Holland and Earl and East Earl townships are underlain by
the Cambrian-age Elbrook-Zooks Corner dolomite formation. The rock in eastern Lancaster
County is highly fractured; that is, cracks, joints, and faults are'found within the bedrock.
The fracturing, which is manifested by fracture traces, can affect ground water flow patterns.
1.3 Hydrology/Climate
The four communities in the study area are almost completely dependent on ground
water (New Holland maintains a surface water reservoir). Terre Hill's wells draw from the
water bearing zones within the sandstones and conglomerates of the Hammer Creek
Formation. Data on aquifer capacity of the Hammer Creek Formation are not available.
Wells in the other three communities tap the Elbrpok-Zooks Corner dolomite. Aquifer
tests indicate this is one of the lower-yielding aquifers hi Lancaster County. Specific
capacities in the aquifer (the rate of discharge per unit of drawdown), range from 0.04 to 46.0
gallons per foot per minute (gal/ft/min), with a mean specific capacity of 2.5 gal/ft/min. The
.aquifers are confined to semi-confined. As indicated in Section 1.2, the water-bearing
formations are highly fractured. Fractured-rock aquifers are,less homogeneous than porous-
media aquifers, and ground water flow is turbulent and rapid. Flow within these aquifers may
not be predictable using flow models, potentially complicating the process of delineating
wellhead protection areas.
Pennsylvania lies within the temperate climate zone. Average temperatures range from
31 degrees in January to 77 degrees in July. Normal annual precipitation in southeastern
Pennsylvania is approximately 41 inches. '-••'•
2.0 PWS CHARACTERISTICS
Each of the four jurisdictions maintains its own PWS: .
Terre Hill is served by the Terre Hill Borough Water System (PWS ID
#7360119); •
New Holland receives water from the 'New Holland Borough Water Department
• (PWS ID #7360099);
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Benefit/Cost Analysis of Preventing Contamination: Eastern Lancaster County, Pennsylvania
• Earl Township is served by the Western Heights Water Authority (PWS ID .
#7360132); and .
East Earl Township is served by the Blue Ball Water Authority (PWS ,ID
#7360005). .
The four communities and their water systems are closely linked. ,For example, because Terre
Hill lies within a small geographic area, all four of the borough's wells are physically located
hi East Earl Township. At each PWS, drinking water is disinfected and treated for color and
odor prior to distribution. (This is a relatively minimal level of treatment for southeastern
Pennsylvania—for many new water sources, nitrates are a water quality concern.)
2.1 Water Supply
The four communities are almost completely dependent- on ground water. Except in
New Holland, where a portion of the water supply is from the New Holland surface water
reservoir, ground water is the source of all public water. Water quality in the area is good;
nitrate levels are the only water quality concern for most of the wells. However, some wells
hi New Holland have elevated TCE levels which, most likely, are the result of industrial
activity in the area. In general, all four communities have adequate water supplies, although
New Holland and Western Heights anticipate drilling new wells to meet future water needs.
The four PWSs operate a total of eleven, wells. Terre Hill Borough Water System,
which taps the Hammer Creek Formation, has four wells. East Earl Township has three
wells, and New Holland Borough and Earl Township have two wells each. The PWSs at
New Holland, and Earl and East Earl townships tap the Elbrdok-Zooks Corner dolomite
formation. Exhibit 1 below presents data on the depth and daily withdrawal from the wells at
each PWS.
, ' ' ' - / : .
Exhibit 1
Characteristics of PWS Wells
PWS
Terre Hill Borough
New Holland Borough
Western Heights (Earl Township)
Blue Ball Water Authority
(East Earl Township)
Average Depth (feet)
364
242
600
250 .
Withdrawal (gal/day)
32,000 to 92,000
1 million
43,200
162,000
-3 -
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. Benefit/Cost Analysis of Preventing Contamination: Eastern Lancaster County, Pennsylvania
2.2 Population Served
, Approximately 20,000 people live in the four communities; each community maintains
its own PWS. the percentages of the local populations served,by public water, varies from
one community to the next. New Holland, the largest of the four water systems, serves the
entire population of the borough, approximately 4,500 people. The entire population of Terre
Hill Borough (approximately 1,300 people) is connected to public water. The Blue Ball
Water Authority in East Earl Township serves only about 2% of the residents (300 people),
and 4% of the population of Earl Township (approximately 200 people) is served by the
Western Heights Water Authority. The latter three water systems rank at the low end of the
range of PWS sizes in Pennsylvania.
3.0 WELLHEAD PROTECTION
The four municipalities are co-developing a regional wellhead protection strategy.
Each community will implement and enforce a separate ordinance regulating activities in its
wellhead protection area (WHPA), Four separate WHPAs have been delineated, sources have
been identified, and
-------
Benefit/Cost Analysis of Preventing Contamination: Eastern Lancaster County, Pennsylvania
3.2 Local Wellhead Protection Plan
Interest in WHP for eastern Lancaster County began around 1990, when EPA Region
3. wanted to pilot test a WHPA delineation method known as fracture trace analysis. Region 3
chose eastern Lancaster County for the pilot because the area has interesting fractured bedrock
geology and is highly dependent on ground water. The communities have not yet formally
implemented the WHPP (i.e., they have not passed ordinances for managing their WHP As).
3.2.1 Wellhead Protection Area Delineation
Three protective zones have been mapped around the four PWSs' wells. Zone I is a
simple 400 foot fixed radius around each well. Because hydrogeologic information on the
aquifers in eastern Lancaster County is limited, the zone II and III WHPA delineations are
based on local and regional hydrogeologic reports and the PWS water supply reports. Zone
II, the ten-year tune of travel capture zone, was delineated using EPA's WHPA flow model,
Version 2.0. A geological method known as fracture trace analysis was employed to delineate
Zone III. Fracture trace analysis, which involves reviewing aerial photographs to detect
evidence of fractures in rock, accounts for the uncertainties in the Zone II modeling that are
common in the highly fractured rock that is typical in Lancaster County. Specifically, the
WHPA model assumes laminar, or non-turbulent, groundwater flow; however groundwater
flow in fractured rock tends to be turbulent and thus unpredictable by standard models.
3.2.2 Source Identification
Before initiating a property-by-property survey of potential contamination sources in
the WHPA, consultants searched EPA and PADER databases for potential sources. These
databases include the inventory of registered Underground Storage Tanks (USTsj, RCRA-
regulated facilities, and hazardous waste sites identified under CERCLA.
The Lancaster County Planning Commission developed a land use inventory using a
geographic information system (GIS). The GIS provided the communities with a general
understanding of land use patterns in the region and a basis for prioritizing-potential threats
from industrial, commercial, agricultural, and residential land use.
After the database searches and land use inventory were complete, volunteers and local
government officers initiated a door-to-door survey of potential contamination sources. Local
residents' knowledge of present and former land uses in the region was an integral part of the
source identification. For example, the Town Hall building of Terre Hill borough was a
former gas station/truck loading area. The communities entered identifying information on
each source (location, source type, and type of material) into the GIS. The survey identified
119 potential sources of contamination.
-5 -
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• Benefit/Cost Analysis of Preventing Contamination: Eastern Lancaster County, Pennsylvania
3.2,3 Management Plan
At the outset of the wellhead protection effort, the four communities planned to
implement separate but similar overlay zoning ordinances tomanage their WHPAs. Td that
end, the communities wrote individual draft overlay zoning ordinances. Recently, however,
the four communities have chosen to join together and develop a comprehensive zoning
ordinance to impose more active zoning controls within the WHPAs. The communities have
begun to. develop the comprehensive zoning ordinance. Existing municipal agencies in each
jurisdiction, e.g., Board of Supervisors, Planning and Zoning Commissions, and the Water
Authorities, will implement and administer the zoning ordinance.
As part of the management plan, local authorities will issue Wellhead Protection Area
Operating Permits. Permit fees will cover the costs of implementing" and administering the
plan. The permit application would require the subject facility to document that it is
operating in a manner consistent with applicable Federal and state regulations. Implementing
agencies in each jurisdiction will .conduct periodic inspections (probably biannually) to verify
compliance. '•••'..
The ordinances set design standards for new sources and performance standards for
existing sources within the WHPA. For each protective zone, the ordinance lists prohibited
activities. The design standards for new construction emphasize compliance with standards
established under existing federal and State regulations such as CERCLA, the Clean Air Act,
and Pennsylvania's UST regulations. Similarly, the performance standards for existing
sources focus on requiring stricter attention to existing requirements, rather than mandating
new ones.
The management plan will include a public education program. Literature and articles
in community newsletters will discuss the WHPP and opportunities for participation.
Education programs will target homeowners with septic systems, and educate residents on
proper methods for disposing of hazardous household waste. The communities will post road
signs on highways and in residential areas to make people aware of the need to protect
recharge areas.
Since the region is highly agricultural, the education program will also focus on
farmers. The educational literature will explain that by modifying their pesticide application
procedures (e.g., by filling machinery hi designated areas), farmers can prevent spills and
seepage of pesticides into the ground water.
3.2.4 Contingency Plan
-6-
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Benefit/Cost Analysis of Preventing Contamination: Eastern Lancaster County, Pennsylvania
The ordinances will address the need for emergency response and contingency
programs. The contingency program will require the local jurisdictions to develop a spill
cleanup strategy and arrange for contractors to be available to respond to spills. Local.
jurisdictions will coordinate responsibilities among local agencies such as fire departments and
Community-Right-to-Know programs. The water authorities will also develop plans to
interconnect their supply lines to provide alternate water supplies. No contingency plans have
been developed in any of the communities. •
4.0 COSTS OF WELLHEAD PROTECTION
EPA and PADER grants funded most of the costs associated with implementing the
WHPP for eastern Lancaster County. Each community contributed a small match to the
EPA/PADER grants. Once the WHPP is implemented, permitting fees paid by regulated
facilities/activities within the WHPA will fund the program.
4.1 Tangible Costs
As of September 1995, the costs of developing the WHPP for eastern Lancaster
County have totaled $62,000 ($66,180 in 1994 dollars). This amount includes a $30,000
($32,700 in 1994 dollars) EPA Region 3 grant with $12,000 ($13,080 in 1994 dollars) in
community matching funds, and a $20,000 ($20,400 in 1994 dollars)'PADER grant. Exhibit
2 summarizes each agency's costs for developing each component of the WHPP.
4.1.1 Wellhead Protection Area Delineation Costs
WHPA delineation was the most expensive developmental activity. The cost of the
delineation is a function of the local geology and the number of wells. EPA Region 3 and
PADER selected the region for a pilot application of the fracture trace analysis methodology
because of its complex, fractured geology. Most of the EPA grant and the community
matches was spent on the WHPA delineation, according to a consultant who is providing
support to the communities developing the WHPP. No data are available on what percentage
of these funds covered the WHPA delineation.
4.1.2 Source Identification Costs
Source identification accounted for a relatively minor portion of total WHPP
development costs, primarily, because volunteers performed most of the work. However, a
portion of the grant from EPA funded the costs of the GIS development and database searches
conducted prior to the property-by-property survey. . ,
-7-
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Benefit/Cost Analysis of Preventing Contamination: Eastern Lancaster County, 'Pennsylvania
Item
[WHPP:.DevBlopment
WHPA delineation ,
Source identification (1)
Develop management plan
Develop zoning ordinance (2)
Write overlay zoning ordinance
Contingency plan (3)
Public education/outreach (4)
fTOfTAUCOSTi
. Exhibit 2
Cost of Wellhead Protection: Lancaster County, PA
199d to September 1995
($1994) • '
Earl East Earl New Holland TerreHIII . PA EPA
Township Township Borough Borough ' OER , Region 3
•
••• .
3,270 ' 3,270 3,270 , 3.270 : 32,700
„ , ' - 20,400 •
$3270 $3,270; «3i270 $3^270 S20i400: i r :$32.700
Total
:•:•:*•<:••..- I
$45.780
,$0 •
$20,400 :
SO
$0
$0
$0
- • ,$66i1SQi
Notes:
(1)WHPA delineation/source identification costs cannot be disaggregated. . , ,.-...
(2) Management plan/zoning ordinance costs cannot be disaggregated • , ,
(4) Education costs will be negligable
- 8 -
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Benefit/Cast Analysis of Preventing Contamination: Eastern Lancaster County, Pennsylvania
4.1.3 Management Plan Costs
Costs for developing the management plan are reflected in the cost of writing the -draft
ordinances. The ordinances for the eastern Lancaster County jurisdictions utilize language
from ordinances developed by other communities. A $20,000 ($20,400 in 1994 dollars)
Commonwealth grant covered the cost of developing the ordinances for the four communities.
No data are available on the costs of developing a public education program.
If the Lancaster County communities implement their proposed management plans,
much of the ongoing costs for managing the wellhead protection areas will be associated with
periodic inspections of facilities with Wellhead Protection Area operating permits. The
communities' consultant estimates that inspections of the facilities.likely to be permitted under
the management plan would cost approximately $50,000 per year. From 1995 to 2005, the
four communities would incur costs of approximately $351,200 to inspect permitted facilities
(see Exhibit 3). - ,
The most significant cost to business associated with wellhead protection in Lancaster
County will be the costs to farmers associated with modification of procedures for applying
pesticides. No data are available on the number of farmers who would be required to modify
their pesticide application procedures, or the extent and cost of, the necessary modifications.
4.1.4 Contingency Plan Costs .
The communities have not yet developed contingency and emergency response plans,
and no estimates of what these components will cost are available.
4.2 Intangible Costs ,
Since the management plan has not been implemented, it is impossible to quantify the
indirect costs of the WHPP. However, it is possible that implementation of a wellhead
protection program could cause farmland values to decrease, since farmers may no longer be
able to sell their land for industrial use. The impacts on property values in each community
will be interrelated. For example, because Terre Hill's wells are physically located in East
Earl Township, any land use restrictions to protect Terre Hill's wells may impact property
values and tax bases in East Earl Township. On the other hand, wellhead protection programs
may make property attractive for residential development, providing alternative buyers for
farmers who wish to sell their land.
-9-
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Benefit/Cost Analysis of Preventing Contamination: Eastern Lancaster County, Pennsylvania
Exhibits
Future Cost of Wellhead Protection: Lancaster County, PA
October 1995 to September 2005
>
Item
($1994) ,
Earl East Earl New Holland Terre Hill
Township Township Borough Borough
Total
SWHPP Implementation " " |
Inspections of permitted faciiities (1)
Public education/outreach (2)
liTJSifJSE'CO.ST:
Notes:
87,795 87.795 87.795 87,795
$87,795 $87;795 $87t795 , $87i795
$351,179
. $°
• $35ti179;|
f 1) Assumes 1 FTE, or $50,000 per year
(2) Education costs will be negligable
-10-
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Benefit/Cost Analysis of Preventing Contamination: Eastern Lancaster County, Pennsylvania
5.0 CONCLUSION ,
Between 1990 and 1995, EPA Region 3, PADER, and the four communities have paid
$66,180 (in 1994 dollars) to develop a WHPP in eastern Lancaster County. When
implemented, this WHPP will protect eleven wells which supply drinking water to 19,000
people in a 100 square-mile area. The cost per well of the WHPP is approximately $6,000.
The four communities benefitted from EPA and PADER grants. Because the four
WHPAs pverlap and cross jurisdictional boundaries, the communities benefitted by
cooperating and sharing limited resources. •
6.0 REFERENCES
1992 Census of Agriculture, Volume 1, Geographic Area Series, Table 1, County Summary
Highlights: 1992. .
Eastern Lancaster County Wellhead Protection Committee. Management Program for Control
.of Potential Sources of Contamination in Wellhead Protection Areas. February 1992.
Evans, R. Paul. Semi-Analytical Modeling Technique for Wellhead Protection Area
Delineation in Fractured Carbonate Geology, Eastern Lancaster County, Pennsylvania.
Evans, R. Paul. ACER Engineers and Consultants, Inc. Personal interview, October 21,
1994. t
Lee, Joseph. Pennsylvania Department of Environmental Resources. Personal interview,,
October 20, 1994. -
Rissler, Bob. Terre Hill Borough. Personal interview, October 21, 1994.
U.S. Environmental Protection Agency, Environmental Monitoring Systems Laboratory.
Fracture Trace Analysis for Wellhead Protection Area Delineation, East Lancaster County,
Pennsylvania. August 1991.
-11 -
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Contract No. 68-C4-0011
Work Assignment No. 1-14
Benefit/Cost Analysis of Preventing Contamination:
Village of Gilbert, Louisiana
Septembe^ 30, 1995
Submitted to:
U.S. Environmental Protection Agency
Ground Water Protection Division
Technical and Information Management Branch
-------
TABLE OF CONTENTS
1.0 COMMUNITY DESCRIPTION \ . . . 1
1.1 Land Use 1
1.2 Geology/ Topography ." 1
1.3 Hydrology 2
2.0 PWS CHARACTERISTICS ... ....... ..... . . . . 2
2.1 Water Supply ............................. 2
2.2 Financial/Management Characteristics . , .....:..... 3
2.3 Population Served , 3
' ' ' ' ' • ' '
3.0 CONTAMINATION ;....... 3
3.1 Contamination Source 3
3.2 Contaminants 4
3.3 Effects of Contamination 5
4.0 RESPONSE ACTIVITIES ...... :...... .'<•., 6
4.1 Alternative Drinking Water Supplies 6
4.1.1 Shut-down of Well #2 ....:.... . . 1
, 4.1.2 Shut-down of Well #1 ... .......... 7
4.1.3 Construction of Replacement Wells #1A and #2A . .......... 7
4.2 Ground Water Remediation . 8
5.0 COSTS OF CONTAMINATION ............................. 8
5.1 Tangible Costs 8
5.1.1 Costs of Providing Replacement Drinking Water ........... 9
5.1.2 Costs of Remediating Ground Water . ................. 11
5.2 Intangible Costs ................ 13
6.0 WELLHEAD PROTECTION . ................... 13
6.1 State Participation in Wellhead Protection ..........: 13
6.2 Local Wellhead Protection Plan .................. ... .... 14
6.2.1 Wellhead Area Delineation 15
6.2.2 . Source Identification 15
6.2.3 Management Plan . '. ................... .... . ... . . 15
6.2.4 Contingency Plan 16
-------
7.0 COSTS OF WELLHEAD PROTECTION i . . 16
7.1 Tangible Costs . ......... f ............ I ..... 16
7.1.1 Wellhead Area Delineation and Source Identification Costs ..... 16
7.1.2 Management Plan Costs ......../......''."...'..". ........ 18
7:1.3 Contingency Planning Costs ............ '. .18
7.2 Intangible Costs ... . . ... ... ...... ,...../. . . ..... ..... 18
8.0 CONCLUSION .... .,...;.. ,,-. . ... . . •-. 18
9.0 REFERENCES ......;......... ..... . ...... . 19
-------
LIST OF EXHIBITS
Exhibit 1 Water Source Characteristics
Exhibit 2 Site Map ,
f
Exhibit 3 Benzene Concentration Over Time
Exhibit 4 Cost to Date of Responding to Contamination
Exhibit 5 Future Cost of Responding to Contamination
Exhibit 6 Cost to Date of Wellhead Protection
-------
BENEFIT/COST ANALYSIS OF PREVENTING CONTAMINATION
GILBERT, FRANKLIN PARISH, LOUISIANA
The Village of Gilbert, Louisiana, learned in ,1992 that its two public water supply
wells were contaminated with benzene at concentrations far above the Maximum Contaminant
Level (MCL). The contamination was the result of a leaking underground storage tank that
had been removed hi 1987. The Louisiana Department of Environmental Quality is still
determining the extent of the contamination, and remediation has not yet begun.
As a result of the contamination, the Gilbert Water System had to plug its wells and
purchase water from neighboring public water supplies for a year and a half. In 1993, the
community drilled two new wells in another location outside of the village. Within a week of
starting the new wells, manganese levels in one of them exceeded the MCL, and Gilbert
stopped using it. Gilbert has instituted a Wellhead Protection Program for the replacement
wells, banning certain types of businesses within 1,000 feet of the wellheads. The cost to date
of responding to the contamination is approximately 100 times the cost to date of adopting
wellhead protection.
1.0 COMMUNITY DESCRIPTION
The Gilbert Water System (GWS) furnishes drinking water to Gilbert and some
outlying, residences. Gilbert is located in south-central Franklin Parish, in northeast Louisiana.
It is a small community, with a population of fewer than 750. The local economy rests on
agriculture and a nearby cotton gin.
1.1 Land Use
Gilbert is one of many small villages that lie along Route 15, a two-lane state highway
running through northeastern Louisiana, Gilbert, like much of northeastern Louisiana, is
almost exclusively rural. Land in and near Gilbert is used mostly for residential and
agricultural purposes. A cotton gin operates near the center of town. The only other
businesses apparent are retail establishments such as gas stations and a grocery store.
1.2 Geology/ Topography
Gilbert is located on a flat alluvial plain underlain by a sequence of unconsolidated
sediments. The alluvium is quaternary in geologic age. Boreholes and monitoring wells hi
Gilbert indicate that the upper ten feet of the'ground is mostly clay, underlain by a layer of
clayey silt about five feet deep, and then a layer of silty sand about 14 feet deep, followed by
sand and gravel deposits 80-100_ feet thick. The sand and gravel layer is very permeable.
- 1 -
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; ; ; Benefit/Cost Analysis of Preventing Contamination: Village of Gilbert, Louisianal
1.3 Hydrology
- > '
The Mississippi River Alluvial Aquifer (MRAA) is .the only significant aquifer in the
area. The aquifer, which flows generally west, is quite shallow. Lying approximately 22 feet
below the surface, the aquifer recharges/with every rain. As a result, ground water is plentiful
but easily contaminated. The only surface water body close to Gilbert is Deer Creek, a small
creek situated to the east of the village. , . '
2.0 PWS CHARACTERISTICS
GWS (PWS ID #LA1041002) is owned and maintained by Gilbert. GWS maintains
two wells, a pipeline, two elevated storage tanks, and a treatment plant. The treatment plant
is located in the village center. Treatment includes chlorination, softening, and iron and
manganese removal (using potassium permanganate).
2.1 Water Supply
GWS depends wholly on ground water from the Mississippi River Alluvial Aquifer
(MRAA). The aquifer's sand and gravel layer is very permeable, yielding as much as 850
gallons of water per minute. Water from the MRAA is of low quality by nature, according to
the Louisiana Department of Health and Hospitals (LA DHH).
GWS owns two wells (see Exhibit 1), but one (Well #2A) is offline because of
excessive manganese levels. The active well (Well #,1A) pumps at 600 gpm (with a top
capacity of 800 gpm), and provides enough water to serve the village's needs. The PWS
operator expects the well to be an adequate source for ten years. Gilbert uses approximately
95,000 gallons per day.
EXHIBIT 1
Ground Water Sources
Source
Original wells: Well #1
Well #2
Replacements: Well #1A
Well#2A
Average Depth
(feet)
92
96
120
120
Capacity
(MGD)
0
0
800
800
Status
Abandoned
Abandoned
Active
Offline due to excessive
levels of manganese
-2-
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Benefit/Cost Analysis of Preventing Contamination: Village of Gilbert, Louisiana
2.2 Financial/Management Characteristics
Gilbert maintains a single enterprise fund for its water and sewer utilities; separate
data on PWS operations are not available. In the fiscal year ending June 30, 1993', the
fund's total revenues were approximately $10,000, and its total expenditures were
approximately $25,000, resulting in an operating deficit of about $15,000. From time to time,
Gilbert has transferred money into the enterprise fund from other accounts to cover operating
expenses. ,
According to the local Farmers' Home Administration (FmHA) office, Gilbert's
financial problems are due in part to a past reluctance to raise water rates. Gilbert recently
increased its rates, however, and the additional revenue has begun to improve the PWS's
financial status. Rates for water consumers are $8.00 for the first 2,000 gallons, and $2 for
every additional 1,000 gallons. The previous rates were $1.50 for the first 1,000 gallons,
$1.25 for the next 1,000 gallons, and $1 for every 1,000 gallons thereafter.
2.3 Population Served
The population served is slightly over 700 people, with about 250 connections. GWS
serves about 90 percent of Gilbert residents, as well as some households just outside the
village boundaries, m Franklin Parish. The remaining 10 percent of Gilbert residents draw
water from private wells. GWS's largest non-residential customers are the Gilbert High
School, the cotton gin, and the fire department.
3.0 CONTAMINATION
LA DHH, which is responsible for all drinking water monitoring in Louisiana, ,
determined on February 17, 1992 that both of GWS's wells were highly contaminated with
benzene. On April 1, 1992, after laboratory results had been confirmed, GWS notified
residents to stop using the water for all but sanitary purposes.
3.1 Contamination Source
In 1990, Gilbert residents began to complain that their water smelled of gasoline, and
the PWS operator called LA DHH to report the problem. LA DHH conducted tests in
January 1991 and notified the Louisiana Department of Environmental Quality (LDEQ) that
the wells were contaminated with benzene.
Data from FY94 are not available.
-3-
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Benefit/Cost Analysis of Preventing Contamination: Village of Gilbert, Louisiana
LDEQ concluded that the contamination probably resulted from a leaking UST, both
because the soil vapors were consistent with those of unweathered gasoline and because most
contamination incidents in Louisiana can be traced to USTs. LDEQ identified seven
abandoned service stations as possible sources of the contamination. Tests showed that
subsurface soil at one of those abandoned stations, Lachney's Citgo, contained levels of
benzene greater than 1000 parts per million (ppm). The station had closed in 1980, but its
USTs were not removed until 1987. The soil near the station was so saturated that one could
light it with a match.
LDEQ identified Lachney's Citgo as the source of contamination, and it initiated
enforcement action against the owner (see map, Exhibit 2). Mr. Lachney was excused from
financial responsibility by Louisiana courts after he proved an inability to pay mitigation
costs. The expense for exploration and delineation of the contamination has been paid from
the federal Leaking Underground Storage Tank Trust Fund (LUST Trust Fund), administered
by LDEQ's UST Division. The Lachney site is not on the NPL or any similar State list.
T (
3.2 Contaminants
Benzene, a member of the volatile organic contaminant (VOC) group BTEX (i.e.,
benzene, toluene, ethylbenzene, and xylenes), is the prevalent contaminant found at the PWS.
LA DHH also identified trace amounts of the other BTEX constituents at the Lachney site.
On January 14, LA DHH discovered a benzene level of 61.6 ppb in Well #2, but no
contamination in Well #1. The Maximum Contaminant Level (MCL) for benzene is 5 ppb.
In a follow-up test on January 28, LA DHH confirmed the results for Well #2 and found
traces of benzene in the PWS distribution system. At that time, LA DHH asked the PWS to
take Well #2 offline. By October 28 of that year, Well #2 had a benzene level of 430.9 ppb.
In the test that prompted LA DHH to order both wells offline, on February 17, 1992, LA >
DHH found high levels of contamination in both wells and in the distribution system. Well
#1 had a benzene level of 95 ppb, and Well #2 was at 331 ppb. LA DHH found levels in the
distribution system as high as 210 ppb in the north end and 180 ppb in the south end.
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Benefit/Cost Analysis of Preventing Contamination: Village of Gilbert, Louisiana
EXHIBIT 2
Site Map
Exhibit 3 summarizes .monitoring results between fte initial discovery of
contamination and the closure of both wells. Over a one-year period, benzene levels
increased from 61.6 ppb to 331.0 ppb in Well #2, and from Not Detected to 95.0 ppb in Well
#1. Benzene concentrations in the distribution system stayed at or below the MCL until
February 1992.
LDEQ tested soil and soil gas vapors at various locations at and near the Lachney site
and the wellfield. The soil test showed maximum VOC concentrations (1,360,000 ppb) at the
center of the abandoned gas station property, at a depth of 20 to 22 feet. Maximum VOCs
were found in soil gas at depths ranging from 12 to 19 feet. LDEQ found 2.5 feet of free-
phase unweathered gasoline in a monitoring well on the site.
3.3 Effects of Contamination
No health or environmental effects from the contamination have been documented to
date. However, the incident exposed Gilbert residents to benzene at a level many times
greater than the MCL. Some residents may still be drinking contaminated water from private
wells; many well owners are not willing or able to pay for testing.
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. Benefit/Cost Analysis ofPreventing Contamination: Village of Gilbert, Louisiana}
Benzene is a known hematological poison, and has been associated with aplastic anemia, acute
myelomonocytic leukemia, leukemia, depression of the, immune system, and decreased serum
levels. Benzene has been known to cause chromosomal aberrations in exposed persons and is
a carcinogen.2 .
EXHIBITS
Benzene Concentrations Over Time
(ppb)
Date
1-14-91
1-28-91
2-4-91
3-11-91
7-1-91 •
10-28-91
2-1-92
Well#l
ND
Not sampled
ND
ND
Not sampled
ND
95.0
Well #2
61.6
60.6.
122.0
107.0
99.8
430.9
331.0
Distribution
System
Not sampled
0.5
ND
ND-5.0
0.8-1.0
ND
180.0-210.0
4.0 RESPONSE ACTTvTriES
Responses to the contamination have come in phases at the Gilbert site, as State
agencies and the village reacted to the worsening contamination. Early response activities
focused on temporary and then permanent replacement of the water supply; later responses
have addressed cleanup of the aquifer itself.
4.1 Alternative Drinking Water Supplies
After the discovery of contamination in Well #2, LA DHH instructed GWS to stop
using the contaminated well. Later, when benzene appeared in Well #1, LA DHH ordered
that well offline. Gilbert connected to nearby PWSs on an emergency basis, and then drilled
replacement wells.
Health Advisories for 25 Organics, U.S. EPA Office of Drinking Water, PB87-235578, March 1987.
1 ' ' ''.'•' -6- ' ;• .. '.
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4.1.1
Benefit/Cost Analysis of Preventing Contamination: Village'of Gilbert, Louisiana
Shut-down of Well #2
When LA DHH discovered the contamination in Well #2 in January 1991, it instructed
GWS to take the well offline. Well #1 was barely able to fulfill Gilbert's water needs, so the
village planned,to drill another well. The PWS intended to site the new well just 100 yards
south of the original wells, as close to the treatment plant as possible. By drilling the new
well near the old wells, the village could avoid installing a costly pipeline, Gilbert and
LDEQ believed that the contamination in Well #2 was due to a breakdown in the integrity of
the well's surface casing, and the village reasoned that a new well with an intact casing would
be a viable solution to the water shortage. In the meantime, Gilbert applied for, and FrnHA
approved, a $46,695 grant for rehabilitation of its wells. The village also arranged with
LDEQ to establish a wellhead protection program for Well #1 and the planned well.
4.1.2
Shut-down of Well #1
On February 17, 1992, LA DHH determined that the distribution system and both
wells were highly contaminated with benzene. On April 1, 1992, LA DHH sent Gilbert a
letter directing the village to find an alternate source of water or implement adequate
treatment. LA DHH also instructed GWS to notify customers that the water should be used
only for sanitary purposes and not for drinking or cooking. LA DHH required the GWS to
distribute the notice through local radio stations, television stations, newspapers, and water
bills. It also directed GWS to give copies of the newspaper notice to all of its new customers.
After receiving the notice from. LA DHH, the GWS canceled its plans for the new well
and started the process of plugging and abandoning the old wells. It completed the process in
July 1993. To provide its customers with running water, GWS connected to the PWSs of two
neighboring villages, South Bayou Macon and West Winnsboro. GWS purchased water from
these communities for approximately a yearand a half.
4.1.3
Construction of Replacement Wells #1A and #2A
Gilbert initiated an effort to site two replacement wells at a safe distance away from
the contamination. A local hydrogeologist hired by the village proposed a location for the
replacement wells just outside the village limits. LA DHH tested the groundwater quality at
the site. However, for an unknown reason LA DHH did not sample from the depth at which
Gilbert intended to draw water. LA DHH approved the site, Gilbert drilled the two new wells
(Wells #1A and #2A), and connected to the replacement wells in September 1993. About a
week after starting the new wells, GWS found contained excessive levels of manganese in
Well #2A. GWS shut down the well because it could not afford treatment. Well #1A is
sufficient to meet the village's current demand for water.
-7-
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Benefit/Cost Analysis of Preventing Contamination: Village of Gilbert, Louisiana,
4.2 Ground Water Remediation
In late 1993.LDEQ began to characterize the contaminatioh at the Lachney site.
LDEQ awarded a contract to Aquaterra, Inc., for a site assessment, free product recovery, and
a corrective action plan. Aquaterra completed a site assessment/corrective action plan in the
spring of 1994. The report recommended additional delineation of the contamination, and
LDEQ awarded a contract to PPM, Inci hi September 1994. Due to a lack of funding, the
additional delineation has not yet begun.
Aquaterra proposed two remedial alternatives, both involving a Soil Vapor Extraction
(SVE) Pilot Study and Full-Scale SVE Implementation. Alternative I consists of recovering
dissolved gasoline constituents and treating them ex-situ. Alternative II, the recommended
option, consists of removing the phase-separated hydrocarbons, testing and implementing the
SVE system, and conducting air sparging. Aquaterra recommended Alternative II 'on the
grounds that it would be cheaper and safer. Alternative II is the less expensive option
because in-situ treatment requires less equipment. This alternative also is less environmentally
hazardous because it would discharge only to air, whereas Alternative I would discharge both
to air and water. .
5.0 COSTS OF RESPONDING TO CONTAMINATION
Purchasing water, replacing the wells, and cleaning up the aquifer are the primary
costs of responding to ground water contamination hi Gilbert. KThree federal agencies (i.e.,
Department of Housing and Urban Development, EPA, and the Farmers Home
Administration) paid most of the costs of providing alternative drinking water, and all of the
costs of the preliminary contamination assessment. Gilbert paid for the purchase of
emergency drinking water from nearby communities, and it has experienced higher operating
costs for its new wells.
5.1 Tangible Costs
The total costs to date, including those for alternative water supplies and those for
remediation, are approximately $420,000 ($447,000 in 1994 dollars). The FrnHA, the LUST
Trust Fund, and the Department of Housing and Urban Development's Community
Development Block Grant (CDBG) program have provided Gilbert with the funds to connect
with neighboring water systems and to build its new wells. LDEQ, using federal LUST Trust
Fund money, paid for the preliminary assessment of the contamination at and near the
Lachney site. LDEQ anticipates using the Trust Fund to pay for remediation, but it has not
yet secured the funding.
-8-
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Benefit/Cost Analysis of Preventing Contamination: Village of-Gilbert, Louisiana
5.1.1 Costs to Provide Safe Drinking Water
The total costs to date for providing replacement drinking water to Gilbert residents
are approximately $370,000 ($395,000 in 1994 dollars). These costs fall into three categories:
• One-time capital costs (e.g., tying into the South Bayou Macon and West
Winnsboro water systems, plugging the old wells, siting and construction of
new wells);
• One-time non-capital costs (e.g., monitoring contamination in the GWS wells
and distribution system, purchasing replacement water); and
Incremental operating costs (e.g., additional utility and treatment costs
associated with the new well). . ..
See Exhibit 4 for a detailed breakdown of the costs to date of responding to the
contamination.
One-time capital costs for replacement water total approximately $285,712 ($299,998
in 1994 dollars). Federal grants have provided the funds to cover most of these costs. The
LUST Trust Fund reimbursed Gilbert for the $25,043 ($26,295 in 1994 dollars) cost of
linking up to the South Bayou Macon and West Winnsboro water systems. Gilbert applied
for and received a CDBG to pay for $213,974 ($224,6?3 in 1994 dollars) of the cost3 for :
siting and constructing its new wells. The village used its $46,695 ($49,030 in 1994 dollars)
FmHA grant for additional engineering, construction, and legal costs. The FmHA grant also
covered the cost of replacing contaminated filter media and plugging the old wells,
-" One-time non-capital costs for replacement water, total approximately $76,256 ($81 013
in 1994 dollars). Both Gilbert and LA DHH incurred these costs. Gilbert paid $71,843 '
($75,435 in 1994 dollars) to South Bayou Macon and West Winnsboro for emergency water
during the 18 months between the discovery of contamination and the completion of the new
wells. This cost was much greater than the cost would have been if Gilbert had produced its
own water during that period. Gilbert did not adjust its rates to cover the incremental cost.
Much of the $15,000 deficit in Gilbert's FY 1993 enterprise fund can be.attributed to the
increased cost of purchasing replacement water. LA DHH collected nearly 30 water samples
from the wells and the distribution system between January 1991, when it discovered the
contamination, and April 1992, when it shut down both of Gilbert's wells. The state
laboratory in Baton Rouge analyzed the samples for volatile organics. The cost of the
samplmg and analysis was approximately $4,413 ($4,633 hi 1994 dollars):
The exact cost of the wells could not be determined.
- 9 -..
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Benefit/Cost Analysis of Preventing Contamination: Village of Gilbert, Louisia
Exhibit 4 •
Cost of Responding to Contamination: Gilbert, LA
ApriM992 to September 1995
($1994)
Ona-tknacosti
Emacpeney watar supplies
Tia-in to adjacant PWSs
Raplacamant walar
RspUcamantwrts
Enojnaarfiistaxislnictlon of mwwats
LandacquiiWon
PtuggingofoldwalU
NawfBtarmaoTa
Initial monitoring of nsw tvtfis .
Montoring/iddWonal oversight of PWS
SUBTOTAL:
Incnnunta! opmtJng eottt (sine* S«pt«nibsr1993)
EI«tridty(S2SO par month)
T«tophorw(S33pw month)
Additkmileh«nicils ($267 p« month)
SUBTOTAL:
75,435
945
(78,380
26,295
6.300
12,600
6.667
$13.742
S90.122
4.633
«*-833
»
$4.833
$0
$0
$49.030
$0
$49.030
$26J»5
$0
$28^95
184.933
8.715
31.024
.'•
$224,673
$0
$224.873
Frs-rarnaoTaSon
SHaasttssmant and comctiva action plan
Warming, sita assasxmant. final assessment raport
PSH racovary
Coertctiv* action plan
Contractor ovartljM
TOTAL-
9.464
$0
<0
$0
$0
$0
T«I.I
$207,194
$6.71^
$6
$12
$38.8
$6.2501
$S2S|
$6.6671
$13.7421
,$394.7531
$29.201
$9.454 I
$5.245
$Z9?9
$46.898
Lost mwnu* out K>privata«MSs(S200pwmonlh) 5.000
TOTAL- J5.000
*°
$0
.«48.898
$0
$0
$5.000
$5.000
:;:$4a3
••>49.03O;'
$28395 :$224JB73
(1)LouUanaDaparmMntofH*althandHo(pllala • •
(2) Loublana DapanrnM of Envlronmanlal QuaBty
(3) Farmsrt' Homa Adminiiualiuil
(4) US. D^jartmart of Housing and Urban Davatopmtni, Community
Davalopniant Bkxfc Grant
-10-
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'. Benefit/Cost Analysis of Preventing Contamination: Village of Gilbert, Louisiana
Since September 1993, Gilbert's operating costs for providing drinking water have
increased by a total of $8,795, or approximately $550 per month. Because the operating
replacement well is further away from the treatment plant than the old wells, GWS's monthly
telephone4 and electricity costs have increased about $33 and $250, respectively. The new
well has higher lead and manganese levels than the old wells, and GWS must treat the water
with potassium permanganate at a level three times greater than.ithad before, for an
additional cost of about $267 per month.
GWS appears to have borne the only significant indirect costs associated with the •
contamination. Approximately 10-12 residents abandoned public water and drilled private
wells, as a result of the increased water rates. Gilbert's city clerk estimated that this loss of
customers deprives GWS of approximately $200 per month in revenue. Given that the village
collects approximately $10,000 per year in water and sewer rates, this amounts to a .2 percent
drop in revenue. The clerk could not provide information on whether GWS's operating costs
have fallen because of the reduced demand.
5.1.2 Costs to Remediate the Aquifer
Assessing contamination, preparing a corrective action plan, and constructing and
operating ground water and soil treatment systems are the primary costs for remediating
ground water. LDEQ and its contractor, Aquaterra> Inc., have performed a preliminary
contamination assessment and developed a corrective action plan, but have not begun
installation of treatment. LDEQ has spent approximately $44,665 ($46,898 in 1994 dollars)
in contractor and staff effort for these activities. Additional delineation of the contamination
will be required before treatment is installed, at a cost of approximately $9,500 ($9 690 in
1994 dollars).
In its corrective action plan, Aquaterra could not provide an estimate of the
remediation's duration. For purposes of analysis, ten years' of costs have been estimated. Of
the two proposed treatment alternatives, the net present value of the recommended alternative
is estimated at $647,994. See Exhibit 5 for a detailed Breakdown of the estimated costs to
remediate the site. The federal LUST Trust Fund probably will pay for both the additional
delineation and the remediation because Lachney cannot afford to pay for the remediation
costs.
GWS uses a telephone system to control operation of the pumps from the plant In contrast, GWS operated the old
wells manually. , ' '
-11 - •• - '
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Benefit/Cost Analysis of Preventing Contamination: Village of Gilbert, Louisian
Exhibits
Future Cost of Responding to Contamination: Gilbert, LA
October 1995 to September 2005
($1994)
Item
UST
Trust Fund
[Remediate;Aqutfer
Pre-Remediation
Additional contamination delineation
Product Recovery and Ground Water Monitoring
Install product recovery system in MW-2
Product recovery system installation report
System operation, maintenance, and monitoring(l)
Management, technical assistance and reporting
Contingency (10%)
SVE Pilot Study
Installation of manometers
SVE pilot test costs
Analytical costs
Report preparation and final system design
Contingency (10%)
Full-Scale SVE Implementation
, SVE welil installation
SVE equipment installation
Operation and maintenance(l)
Contingency (10%) >
Air Sparge Implementation
Air sparging system implementation
Operation and maintenance(l)
Contingency (10%)
SUBTOTAL:
$9,690
$10,394
$1,907
$179,523
$84,158
$27,598
$3.302
$17.462
$1,377
$7,844
$2,999
$7.089
$14,637
$175,590
$19,732
$26,775
$50.219
. $7,699
$647,994
$647;994i
Note:
(1) Actual duration of remediation is contingent upon achievement of remediation goals.
- 12-
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Benefit/Cost Analysis of Preventing Contamination: Village of Gilbert, Louisiana
5.2 Intangible Costs
Gilbert is a small village in a rural, economically depressed part of Louisiana.
Economic effects of the contamination are difficult to distinguish from the poor economic
condition of the area as a whole. Despite the statewide publicity Gilbert received due to the
contamination, Gilbert's former mayor believes that the contamination has not affected
property values. Further/since few property transfers occur in Gilbert, identifying impacts
on the volume of property transactions is difficult. Village officials believe that no residents
have relocated either their residences and/or businesses in response to the contamination.
The few businesses inGilbert do not appear to have encountered any permanent
impacts from the contamination. They do riot appear to have experienced either increased
costs or reduced revenues. Some businesses may have experienced temporary disruptions in
their water supplies, but the associated costs are probably insignificant.
6.0 WELLHEAD PROTECTION
In January 1991 LDEQ's Ground Water Protection Division contacted Gilbert about
establishing a Wellhead Protection Program (WHPP) after learning about the contamination
from LA DHH. LDEQ intended to educate the community about the causes of the well
contariiination and to establish a contingency plan in case Gilbert lost Well #1. When LDEQ
staff came to Gilbert for a meeting about the proposed WHPP, they found that the remaining
well had become contaminated two days before and that the village was without a source of
water. . 1
LDEQ assisted Gilbert hi compiling an inventory of potential sources and siting the
new wells away from sources. After Gilbert constructed the new wells, LDEQ designated a
new Wellhead Protection Area around those wells. The village, aided by LDEQ, has written
and adopted a management ordinance and a contingency plan. Gilbert completed its
Wellhead Protection Program implementation in October 1993.
6.1 State Participation in Wellhead Protection
Louisiana has an EPA-approved wellhead protection program that is completely
voluntary for communities. The LDEQ Ground Water Protection Division sets minimal
standards for wellhead protection programs, and certifies WHPPs meeting its standards.
Using data from the LA Department of Transportation and Development (DOTD),
LDEQ establishes a vulnerability ranking for PWSs. Larger systems and systems drawing
from shallow and uriconfined aquifeft receive higher rankings. LDEQ visits each community
in order of vulnerability to convince local officials and civic leaders to adopt a WHPP.
- 13-
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Benefit/Cost Analysis of Preventing Contamination: Village of Gilbert, Louisiana
LDEQ performs most of,the work associated with WHPA delineation and source
identification.
LDEQ uses a fixed radius to delineate WHPAs because it lacks the detailed geologic
information necessary to run an accurate hydrogeologic model for each well. It delineates a
two-mile radius around wells drawing from unconflned aquifers, or a one-mile radius around
wells drawing from confined aquifers (which are rare in Louisiana).
LDEQ identifies potential sources of contamination within each WHPA and pinpoints
their locations with respect to the well. When LDEQ finds actual sources of contamination
(such as leaking USTs), it reports the sources to the appropriate State oversight program.
LDEQ then creates a map showing the community, the WHPA, and the potential sources.
Communities use the maps to prevent contamination of existing wells, and to site new wells
in less vulnerable areas. . (
In order to obtain LDEQ approval for then: WHPPs, local communities must adopt
either regulatory (e.g., overlay zoning ordinances, design standards) or non-regulatory (e.g.,
land purchases, public education) management programs. The Ground Water Protection
Division supplies local communities with model ordinances and technical assistance in
choosing.source prohibitions and design standards. To increase public awareness of wellhead
protection, LDEQ has prepared public education materials (e.g., pamphlets and a video) for
use by local governments.
Other State agencies involved hi wellhead protection to a lesser degree are: the
DOTD; the Department of Agriculture and Forestry; the Department of Natural Resources;
the Wellhead Protection Technical Committee, which assists LDEQ in obtaining information
from the other involved agencies; and the Soil and Water Conservation Districts and Water
Conservation Districts. The Ground Water Advisory Group* consisting of representatives
from each agency, coordinates the agencies' wellhead protection efforts.
6.2 Local Wellhead Protection Plan -
In Gilbert, LDEQ delineated WHPAs and identified potential sources for both the
existing wells and the replacement wells. Gilbert drafted a contingency plan and an
ordinance based on models provided by the Ground Water Protection Division. The
contingency plan defines emergency procedures to be carried but in the event of
contamination or a water shortage. The ordinance establishes a ground water protection area •
and prohibits certain activities from occurring within 1,000 feet of the wells. The village is
responsible for the day-to-day management of the wellhead protection program.
- 14-
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, Benefit/Cost Analysis of Preventing Contamination: Village of Gilbert, Louisiana
6.2.1 Wellhead Protection Area Delineation
In Gilbert, LDEQ delineated a'two-mile radius around the wells. According to
LDEQ, such a distance is conservative and overprotective, given the statewide average travel
rates for ground water (50-170 ft/yr). The WHPA should provide Gilbert with enough time
to take appropriate measures if contamination occurs. Where the WHPA boundaries intersect
highways, Gilbert erected signs by the side of the road.
6.2.2 Source Identification
' LDEQ, with the help of Gilbert residents, first performed the source identification
step for GWS's original wells. Older citizen volunteers recalled the locations of long-
abandoned potential sources hi town. LDEQ made a full inventory of the sources and plotted
them on a map of the village. When Gilbert shut-down both wells, LDEQ used the list of
potential sources to help site the replacement wells. After the new wells were installed,
LDEQ revised the list to reflect the new WHPA. The final source inventory identified 27
potential sources of contamination, 13 of which were service stations or garages. The other
sources identified included three cemeteries, two dry cleaners, a small airport, sewage lines
and disposal ponds, and drainage canals. Gilbert received a copy of the inventory and the
map.
6.2.3 Management Plan
Gilbert has not developed a formal management plan for its wellhead protection
program. However, the PWS operator periodically conducts informal activities such as
visiting potential contamination sources. Further, Gilbert has passed a Groundwater
Protection Ordinance establishing a ground water protection area within a half-mile radius of
the wellfield. The ordinance prohibits certain new installations within 1,000 feet of any well.
These installations are as follows:
automobile maintenance and repair,
battery storage and manufacturing,
chemical productions,
dry cleaners,
electroplating,
furniture production,
facilities using USTs,
man-made ponds and retention areas,
medical clinics,
paint facilities,
pest control, and
photo processing.
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Benefit/Cost Analysis of Preventing Contamination: Village of Gilbert, Louisian
In the ordinance, Gilbert resolved to monitor all activities within the WHPA that are
potential sources and to site any new wells "properly."
6.2.4 Contingency Plan
Gilbert formulated a contingency plan to coordinate with existing Hazardous Materials
Response and Civil Defense Plans. The Contingency Plan establishes a priority of water
users in the case of a water shortage or disruption, and it outlines the village's options for
alternate water sources, including neighboring water systems and markets that carry bottled
water. It also describes notification procedures in case of a ground water contamination
emergency.
7.0 COSTS ASSOCIATED WITH WELLHEAD PROTECTION
Gilbert's wellhead protection program has cost approximately $4,580 ($4,666 hi 1994
dollars) to date. Almost all of these costs are salary costs for time LDEQ spent developing
Gilbert's program. LDEQ officials could not provide the exact number of hours spent on the
Gilbert wellhead protection program, so costs are estimated. Gilbert officials are paid only
nominal salaries, so any staff costs for the small amount of time spent developing and
managing the WHPP are relatively insignificant. '
7.1 Tangible Costs -
The initial cost of wellhead protection hi Gilbert was the presentation that LDEQ
made to the community, to convince local officials of the need for a wellhead protection
program. LDEQ and LA DHH spent approximately $438 ($446 hi 1994 dollars) and $123
($125 hi 1994 dollars), respectively, to prepare for and attend the presentation.
7.1.1, Wellhead Area Delineation and Source Identification Costs
According to estimates by LDEQ's Ground Water Protection Division, the staff spent
a total of about $3,282 ($3,347'hi 1994 dollars) preparing a map of both WHPAs, identifying
potential sources, and situating each source on the map. Delineating WHPAs itself did not
require a great investment of time, because each WHPA is a curie with a two-mile radius.
Community volunteers assisted LDEQ in the source identification effort, which minimized
LDEQ's staff time. No private entities incurred costs for these steps. See Exhibit 6 for a
breakdown of the wellhead delineation and source identification costs.
- 16-
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Benefit/Cost Analysis of Preventing Contamination: Village of Gilbert, Louisiana
Exhibits
Cost of Wellhead Protection: Gilbert, LA
April 1992 to September 1995
($1994)
Item
LA
DHH
LA
DEQ(1)
Village
of Gilbert
Presentation to local officials
WHPA Delineation/Source Identification^)
Preparation of WHPA map
Review of existing data on USTs, NPL. RCRA sites/site visits
Management Plan/Source Controls
Adoption of overlay zoning ordinance
Patrols of WHPA , . :
Contingency Plan
Modification of model contingency plan
Public Education/Outreach
• Installation of WHPA signs
125
446
3,347
36
231
231
250
S571
$3.347
. $36
'$250
$231
$231
$250
(1) Distribution of LA DEQ costs is approximate.
(2) Delineation and source identification costs cannot be disaggregated.
(3) Village of Gilbert incurred nominal costs, but they cannot be quantified.
- 17-
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Benefit/Cost Analysis of Preventing Contamination: Village of Gilbert, Louisiand
7.1.2 Management Plan Costs
The only public cost incurred in this step was the time an LDEQ geologist spent to
send Gilbert copies of other cities' management ordinances. The village of Gilbert drafted
and passed the ordinance, but it did not incur significant costs. As noted earlier, village
officials are paid only nominal salaries. See Exhibit 6 for a breakdown of the management
plan costs. .
Implementation consists of informal visits to potential contamination sources by the
PWS operator. These visits cost about $125 per year.
7.1.3 Contingency Planning Costs
LDEQ incurred minor costs for providing Gilbert with some technical assistance in
developing a contingency plan. Gilbert officials were responsible for the body of the work
involved hi writing the contingency plan, but the village incurred no significant costs. See
Exhibit 6 for a breakdown of the contingency planning costs.
7.2 Intangible Costs ;
The WHPP does not appear to have resulted hi any quantifiable indirect costs. The
management ordinance's prohibition against certain new installations with 1,000 feet of the
wells is unlikely to affect property values in that area of town. The wells are located in'a
residential area. Further, the community is in an economic decline, and development
pressures are minimal. As noted in Section 3.3, if a business chose not to move to Gilbert,
it would be difficult to show that the decision was a result of the WHPP and not of the
economic weakness of the village.
8.0 CONCLUSION
To date, the Village of Gilbert has incurred a total cost of $95,122 (hi 1994 dollars)
to respond to contamination of its two wells. The Village continues to incur additional
operating costs of approximately $550 per month at the new wells. In addition, the PWS
loses about $200 per month in revenues as a result1 of customers who have installed their own
wells as a result of the contamination. Assuming that remediation of the aquifer takes five
years, the prevent worth of remediation costs is approximately $455,000 to $520,000,
depending on the remedial alternative chosen.
Gilbert's wellhead protection program cost approximately $4,400 (hi 1994 dollars), or
about $2,200 per well. Because Gilbert has a minimal source management program,
implementation costs are near zero. ,
- 18-
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, Benefit/Cost Analysis of Preventing Contamination: Village of Gilbert, Louisiana
9.0 REFERENCES
', Aquaterra, Inc. Site Assessment and Corrective Action Plan: Lachney Property, Gilbert,
Louisiana. ,
Arnold, David. Operator, Gilbert Water System.. Personal interview, December 9, 1994.
Casanova, Keith L. Environmental Quality Program Manager, Office of Water Resources,
Louisiana Department of Environmental Quality. Personal interview, December 8, 1994.
Fielding, Howard. Geologist, Ground Water Protection Division, Louisiana Department of
Environmental Quality. Personal interview, December 8, 1994.
Gentry, Mary. Geologist, Ground Water Protection Division, Louisiana Department of
Environmental Quality. Personal interview, December 8, 1994.
Ground Water Protection Division, Louisiana Department of Environmental Quality. "BTEX
Contamination of a Public Water SupptyM-rilbert, Louisiana, A Case Study."
Ground Water Protection Division, Louisiana Department of Environmental Quality. Gilbert
Wellhead Protection Program. March, 1990. ,
Griffing, Nelda. Mayor, Village of Gilbert, Personal interview, December 9, 1994.
Guillory, Pat. Assistant Director, Winnsboro District Office, FmHA. Phone interview,
December 29, 1994.
Hahn, Michael. UST Program, Baton Rouge Headquarters, Louisiana Department of
'Environmental Quality. Phone interview, December 13, 1994.
Hill, Jay. Northeast Regional Office, Louisiana Department of Health and Hospitals.
Personal interview, December 9, 1994.
Levey, Linda Korn. Administrator, Ground Water Protection Division, Louisiana
Department of Environmental Quality. Personal interview, December 8, 1994.
Louisiana Wellhead Protection Program, Louisiana Department of Environmental Quality.
Case file.
McManus, Vicki. McManus Consulting Engineers. Phone interview, December 29, 1994.
- 19-
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• • • Benefit/Cost Analysis of Preventing Contamination: Village of Gilbert, Louisiana
Schultz, Oliver. President, Oliver Schultz and Associates. Phone interview, December 28
1994.
Sporl, Philip. UST Program, Northeast Regional Office, Louisiana Department of
Environmental Quality. .Personal .interview, December 9, 1994.
Warbington, Janice. City Clerk, Village of Gilbert. Personal interview, December 9, 1994.
-20-
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Contract No. 68-C4-0011
Work Assignment No. 1-14
Benefit/Cost Analysis of Preventing Contamination:
Town of Dartmouth, Massachusetts
September 30, 1995
Submitted to:
v
U.S. Environmental Protection Agency
Ground Water Protection Division
Technical and Information Management Branch
-------
-------
TABLE OF CONTENTS
1.0 COMMUNITY DESCRIPTION .... ............ . I
1.1 Land Use 1
.'1.2 Geology/ Topography • ••••••••... ^ ......... ^. ^ ... i:. ...... I
1.3 Hydrology/Climate ^. ..^............. i .. ....]. 2
2.0 PWS CHARACTERISTICS . \ 2
2.1 Water Supply .... .... ... ............. '.•'. '. '.'. '.'. .', 3,
2.2 Financial/Management Characteristics ......',.. 3
2.3 Population Served : . . . . ' 4
3.0 CONTAMINATION . . . ... .'. 5
3.1 Contamination Sources . '.....,.' 5
3.2 Contaminants ..... .... ..... ... . . 5
3.3 Effects of Contamination . . . ...... 6
4.0 RESPONSE ACTIVITIES 7. ....'. .....:. 7
4.1 Response to Contamination of the Water Supply at Route 6 Well ....... 7.
4.2 Response to Contamination of the Water Supply at Chase Road Well . . . '. . 7
5.0 COSTS OF CONTAMINATION 8
5.1 Tangible Costs . . . . , . . . . . . , ; 9
5.1.1 Costs to Provide Safe Drinking Water at Route 6 Well . . .'. 9
5.1.2 Costs to Provide Safe Drinking Water at Chase Road Well . 9
5.2 Intangible Costs 12
6.0 WELLHEAD PROTECTION ... ..... ...."......... : . . . . 12
6.1 State Requirements for Wellhead Protection ..........'. ........;,. 12
6.2 Local Wellhead Protection Plan -..''..'... 12
6.2.1 Wellhead Protection Area Delineation . . 13
6.2.2 Source Identification . . . . 13
6,2.3 Management Plan 13
6.2.4 Contingency Plan ..... .14
7.0 COSTS OF WELLHEAD PROTECTION ..;..... . . ; ... ....':.... . , . . 14
7.1 Tangible Costs . , . . 15
' 7,1.1 Wellhead Area Delineation Costs , 15
7.1.2 Source Identification Costs ...;.......... 18
7.1.3 Management Plan Costs . . .................... 18
7.1.4 Contingency Planning Costs . 18
7.2 Intangible Costs . . 18
8.0 CONCLUSION ...../.......,......!....,;.....,...... 19
9.0 REFERENCES ... •../... . . . . . ... . . . 19
-------
LIST OF EXHIBITS
Exhibit 1 Water Source Characteristics
Exhibit 2 Cost to Date of Responding to- Contamination
Exhibit 3 Future Cost of Responding to Contamination
Exhibit 4 Cost to Date of Wellhead Protection
Exhibit 5 Future Cost of Wellhead Protection
-------
BENEFIT/COST ANALYSIS OF PREVENTING CONTAMINATION
DARTMOUTH, BRISTOL COUNTY, MASSACHUSETTS
- Contamination of its drinking water supply prompted the Town of Dartmouth,
Massachusetts to voluntarily undertake an innovative wellhead protection program. Two
separate sources have contaminated two of the town's drinking water supply wells/ The first,
an illegal dumping operation, forced the closure of,the Route 6 well. The second, an old
gravel pit and a clandestine dump, contaminated the town's Chase Road well.
Dartmouth was among the first communities in the country to adopt wellhead
protection. Its wellhead protection plan provides many safeguards intended to protect its
drinking water supply from potential contamination. The town owes the success of its
comprehensive wellhead protection program to the close cooperation among several
departments of the local government. ,
1.0 COMMUNITY DESCRIPTION
Dartmouth is located in Bristol County, in southeastern Massachusetts. The town
consists mainly of residential areas, but it also has commercial, industrial, and manufacturing
areas. Dartmouth has a population of 27,000. The University of Massachusetts at Dartawuth
increases the town's population from fall through spring by about 3,500 students. This
increase is .complemented to some extent by a similarrsize transient summer population of
vacationers. .
1.1 Land Use
The predominant land use in Dartmouth is residential. Dartmouth's population had
remained steady over several decades until around 1985, when the area gained popularity
because of its proximity to Cape Cod. Despite the recent population increase, over 50 percent
of the land in Dartmouth is undeveloped.
" ' * -. s ' '' - " ,.
Most of Dartmouth's commercial facilities are centered in a business district along
Route 6, which runs through the center of town. Commercial uses consist primarily of retail
establishments, restaurants $ and gas stations. The industrial and manufacturing facilities in
Dartmouth include cable and computer manufacturing facilities and a golf equipment
manufacturing plant.
1.2 Geology/ Topography
•;('','. - " .
Elevation in Dartmouth varies from 170 feet above sea level to sea level along the
coast. The topography of the town is characterized by hills and valleys which run from the
northwest to the southeast. Several southward-flowing streams occupy these valleys.
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Benefit/Cost Analysis of Preventing Contamination: Town of Dartmouth, Massachusetts
Dartmouth is underlain mainly by late Precambrian bedrock. The observable bedrock
is the Dedham Granodiorite Formation, with intrusions of a fine-to-medium grained schist.
the bedrock is characterized by a relative hardness and lack of weathering. Principal mineral
constituents of the Dedham Formation are quartz, microcline, and plagioclase.
1.3 Hydrology/Climate
Dartmouth is on the southeastern coast of Massachusetts, bordering Buzzards Bay.
Several southward-flowing streams drain into Buzzards Bay and the Atlantic Ocean. These
include Buttonwood Brook, Paskamanset River, Shingle Island River, Copicut River,
Destruction Brook, Slocums River, and Little River.
Dartmouth relies upon two aquifers for its drinking water. A substantial volume of
ground water is found in the highly permeable surficial deposits. All of Dartmouth's
municipal wells draw ground water from these deposits. A deeper, slow-moving aquifer
within the Dedham Granodiorite is characterized by low porosity and a corresponding low
storage capacity. Most low-yield private wells in Dartmouth tap the bedrock aquifer.
Ground water moves from the upland recharge areas hi northern New Bedford and
central Dartmouth to the lowland discharge areas along the Paskamanset River and the coast.
Natural flow is north to south, with a possible additional west-east gradient. Pumping may
artificially change the direction of flow near some of the wells. '
The aquifers-hi Dartmouth are recharged by surface water. United States Geological
Survey (USGS) studies of eastern Massachusetts indicate that ground water recharge rates
range from 0.75 million to 1 million gallons per day (mgd), per square mile.
Precipitation in Dartmouth averages 41 niches annually, ranging from 2.2 to 4.1 inches
per month. Of this precipitation, 47 percent enters the ground or runs off into surface water
bodies; the remainder is lost to evapotranspiration. The average temperature varies from a
low of about 32 degrees in January to about 72 degrees in July. ' , -
2.0 PWS CHARACTERISTICS
Until 1960, Dartmouth purchased all of its water from the City of New Bedford.
Since then, the Dartmouth Water Division (DWD) has supplied a combination of its own
water and purchased water. The DWD, PWS ID #4072000, is owned and operated by the
town.
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. Benefit/Cost Analysis of Preventing Contamination:- Town of Dartmouth, Massachusetts
2.1 Water Supply
The Dartmouth Water Division relies on ground water and purchased water from the
neighboring city of New Bedford.1 Ground water-in the area historically has been of high
quality. The most significant water quality problem, aside from the contamination incidents,
has been high levels of naturally occurring iron and manganese. -
Dartmouth operates eight sand/gravel wells, seven of which are currently online (See
Exhibit 1). The PWS maintains just over 170 miles of mains, with use measured by 7,924
water meters. The DWD disinfects the water from all of its wells and has installed, corrosion
control measures. Due to the naturally high iron and manganese content of the ground water,
DWD applies iron;and manganese removal at some wells.
Dartmouth's net water consumption in 1993 was just under 2.6 mgd. To meet this
demand, Dartmouth currently purchases 20 percent of its water annually from New Bedford
on demand, mainly during the summer, months, when consumption rates are highest. The
town will probably continue to purchase water in the future, due to the increasing demand of
commercial high-end users and real estate development.
The DWD is currently testing four wells, two of which are scheduled to become
operational in the fall of 1995. Dartmouth is also reviewing several parcels of land in
anticipation of possibly siting an additional two wells. . •
2.2 Financial/Management Characteristics
The Town of Dartmouth, established an enterprise fund for its water and sewer utilities
in its fiscal year 1990.2 The fund is supported entirely by water and sewer fees.- The town
retains revenue associated with water supply and sewerage in this fund.
The Department of Public Works (DPW) determines rates and fees charged for water
consumption. The DPW assesses a minimum annual charge for water ranging from $40 to
$1,520, based on meter size. Above the minimum usage, Dartmouth has an increasing block
rate structure. For each increment of use, the cost per cubic foot of water increases, up to
$29 per 1,000 cubic feet The DPW last changed water rates on July 1, 1992.
DPW assesses a system development charge of $2,000 for each new service
connection. A separate service connection and meter are required for each residential unit, up
i
supply.
, • 2,
New'Bedford 'relies on surface water from a region known as the "Five Great Ponds" for its drinking water
f-" , • • _ '••'.-
The Town's fiscal year runs from July 1 to June 30.
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Benefit/Cost Analysis of Preventing Contamination: Town of Dartmouth, Massachusetts
to four units per building. Any residential building containing more than four units requires a
master meter, and the fees are based on a non-residential system development charge, ranging
from $2,000 for a 1 inch meter to $76,000 for a 10 inch meter.
EXHIBIT 1
Water Source Characteristics
Source
Surface water source, purchased
from New Bedford via Faunce
Corner Pump Station
Chase Rd. A Well
Chase Rd. B Well
Chase Rd. C Well
Chase Rd. D Well
Old West Rd. V-l Well
Old West Rd. V-2 Well
Old West Rd. V-3 Well .
Allen. St. Station
Route 6 Well
Average Depth (feet)
N/A
43.2
38.6
30
41
50
50
52
Inactive3
Inactive11
Withdrawal (gal/year)
Not metered
81,230,000
131,869,000 .
73,573,000
145,028,000
85,389,000
128,277,000
76,750,000
- - . ,
-'
1 Pumping station is an emergency interconnection with New Bedford water supply.
b Inactive due to contamination (see Section 3)
Dartmouth has used bonds and loans hi the past to meet its capital improvement needs.
The DWD has a sufficient balance in its enterprise fund to meet the PWS's operating expense
for over a year. The PWS plans to pay for any future compliance requirements (none are
currently anticipated) by increasing user rates or obtaining grants or loans.
2.3 Population Served
The PWS serves approximately 24,000 (89 percent) of Dartmouth's residents, via
8,300 service connections. The remaining 3,000 residents rely on private wells. The DWD
supplies 49.2 percent of its water to residential users, 32.8 percent to commercial users, 10
percent to municipal users, and 6 percent to industrial users.
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' Benefit/Cost Analysis of Preventing Contamination: Town of Dartmouth, Massachusetts
3.0 CONTAMINATION
Two of Dartmouth's wells were contaminated as a result of two separate incidents. In
1978, the town detected contamination in the Route 6 well from a hazardous waste dumping
operation. In the early 1980s, the town discovered that its Chase Road Well D was
contaminated by an private sand and gravel operation subsequently used as a dump site.
3.1 Contamination Sources
State officials discovered contamination at the Route 6 site in 1978. Responding to
calls from citizens, the Massachusetts Department of Environmental Protection (DEP)3 found
numerous barrels of hazardous waste hi a warehouse 1,000 feet from the operating well.
Debris from various domestic and building activities was scattered around the site. DEP
removed the barrels. Upon returning to the site the next year, DEP found that another 1,000 '
barrels had been dumped in the warehouse. DEP determined that an illegal hazardous waste
dumping operation existed on the premises. Dartmouth successfully sued the owner of the
operation, but recovered only a negligible monetary award.
, The town detected contamination at the Chase Road well during the siting process.
During the well design phase, a caller, noting"the town's signs delineating a "Water Supply
Area," identified the area as an old dump site. The town immediately halted the siting
process and hired contractors to initiate a survey of the area, focusing .on three potential
sources. The first area proved to be clean; at the second location, the town discovered fish oil
waste from a fish processing plant. At the third site, 1,500 feet from the proposed location of
the well, the town found a pond within an abandoned pit containing buried automobiles and
automotive crank .case oil. The town has not taken any enforcement,actions against
responsible parties. V
3.2 Contaminants
After discovering the illegal dumping operation, DEP and the Town of Dartmouth
conducted two rounds of sampling and analysis on the Route 6 well between 1978 and 1980.
The U.S. Environmental Protection. Agency (EPA) collected and analyzed the contents of the
stored drums. EPA's analysis of the drum contents revealed the presence of 2-ethyl hexanal,
toluene, methyl isobutyl ketone, ethyl benzene, butanol, heptanol, trichloroethylene, xylene, 1-:
methoxy-2-propanol, nonyl alcohol, hydrocarbon (7cj, cholorobutane, and propanol.
. DEP's initial sampling of water from the Route 6 well indicated the presence of
chloroform at concentrations of 4.4 to 5.4 parts per billion (ppb), and 1,1 dichloroethylene at
At the commencement of activities at the Route 6 well, DEP was known as the Massachusetts Department of
Environmental Quality Engineering (DEQE). Throughout this report, "DEP" refers to both organizations.
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Benefit/Cost Analysis of Preventing Contamination: Town of Dartmouth, Massachusetts
concentrations of l.O-.to 1.1 ppb. The date of this sampling was unavailable. In 1980, the .
town hired contractors to drill monitoring wells and conduct groundwater sampling and
analysis. Samples taken 380 feet .from the Route 6 well indicated the presence of 1,1,1
trichlorethane (3'.5 ppb), trichloroethylene (2.1 ppb), and tetrachloroethylene (1.7 ppb).
Samples;taken 850 feet from the Route 6 well indicated the presence of five contaminants. In
this sample, trichloroethylene (540 ppb), 1,1,1 trichlorethane (1,250 ppb), and 1,1
dichloroethylene (56.5 ppb) were found in the greatest concentrations.
After discovery of contamination at the Chase Road site, Dartmouth initiated several
surveys of the area to determine the extent and potential effects of the buried auto parts and
oil. Geochemical surveys and samples from monitoring wells detected crank case oil, acetone,
methylethylketone, and 1-1-1 trichloroethylene. The town conducted seismic and resistivity
surveys and located one buried car.
3.3 Effects of Contamination
No documented health effects could be attributed to the contamination incidents. In
faqt, the only reported health effects that could be attributed to water quality are
gastrointestinal* problems from excess manganese in drinking water. This has never been
decisively ascribed to groundwater quality, however.
Although no one has been made ill due to contamination of either the Chase Road or
Route 6 wells, the potential for adverse health effects is real. For example, acetone (found in
the Chase Road well) is readily absorbed into the body via ingestion. The main effects of
acetone exposure are central nervous depression and irritation of the eyes.
The health effects of the contaminants identified hi the Route 6 well include damage to
the brain, heart, lungs, and kidneys. Exposure to 1,1 dichloroethylene may cause central
nervous system depression. Once ingested,, 1,1 tetrachloroethane concentrates in organs with
high levels of fat, including the brain, and may also affect the heart, lungs, liver, and kidneys'.
Long-term oral exposure to TCE may damage the liver. PCE may cause abnormal effects on
the liver, kidney and central nervous system.
No natural resource damage due to the contamination in Dartmouth's wells has been
documented.
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' Benefit/Cost Analysis of Preventing Contamination: Town of Dartmouth, Massachusetts
4.0 RESPONSE ACTIVITIES
i . , '- .
In each contamination incident, EPA, DEP, or the town responded by. conducting
surveys to assess the extent of contamination and. removing the source of the contamination.
4.1 Response to Contamination of the Water Supply at Route 6 Well
After discovery of hazardous materials at the Route 6 site, DEP ordered the town to
remove the well from service. DEP initiated cleanup activities in 1979. DEP dug .an
interceptor trench and two test holes adjacent to the primary disposal area. It stockpiled
drums and debris for future disposal, and removed, aerated; and spread contaminated soil.
The Department removed a total of 1,054 drums, 20,500 gallons of^liquid waste, and 320 tons
of heavily contaminated soil and debris. A large pile of less severely contaminated debris
remains at the site. DEP completed its cleanup in February 1980.
The town collected samples at the site in 1980 to investigate the prospect of siting a
new well. According to the sampling results, the site was still seriously contaminated, despite
the cleanup. DEP also warned the town that the contamination was likely to migrate further
toward the well. 'DEP indicated that it would approve the use of the Route 6 well, provided
that the town sample the well and two nearby monitoring wells monthly for VOCs. The town
decided not to use the well until it had studied the situation further. ,
In 1983, Dartmouth installed a system of 13 monitoring wells to better define the site
hydrogeology and conducted sampling from February through October. Analyses indicated
that aquifer contamination was widespread and locally severe. They also indicated that
pumping the well reversed the ground water's natural flow and tended to direct contamination
towards the well. The town decided not to reopen the well.
In 1991, Dartmouth reexamined the'possibility of using the well in light of advances in
groundwater treatment technologies. The town rejected this course of action after determining
that pumping would draw contamination into the well's cone of influence. DEP informed
Dartmouth that it would not approve reopening the Route 6 well unless the town could prove
that it had exhausted all other sources of water. The town is currently purchasing water from
New Bedford to replace this well.
4.2 Response to Contamination of the Water Supply at Chase-Road Well
After discovering the contamination and investigating the contamination sources near
the Chase Road well, Dartmouth removed the fish oil from the site. To determine the extent
of contamination from the automotive dump site, the town installed monitoring wells,
conducted -seismic surveys, sampled the ground water, and conducted geochemical testing.
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: Benefit/Cost Analysis of Preventing Contamination: Town of Dartmouth, Massachusetts,
The town attempted to remove the buried ear'. Because the car was located close to
the water table, the holes quickly filled with water, preventing extraction of the entire
automobile. The town was able to extract portions of the car, including the engine block.
During the delay in the well siting process, DEP requirements for new wells became
more stringent. The Waste Division of DEP now required Dartmouth to show that the site
was not hazardous and that the town had no further responsibilities to clean up the site.
Dartmouth performed a Phase II Assessment4 and a Risk Assessment and determined that the
site was no longer hazardous. DEP accepted these studies as documentation of the well's
suitability as a drinking water source, and the town resumed siting the well.
The town conducted pump testing at the well to determine whether pumping would
pull the remaining contamination into the well. The pump tests showed that, although the
aquifer around the well was contaminated, none of the contaminants had reached the well.
DEP approved the well hi 1988.
Dartmouth designed the Chase Road pump station to, ensure that its water supply
would not be interrupted by future contamination. As a precautionary measure against
contamination which could potentially migrate toward the well, the pump house contains an
operating state-of-the-art air stripper and greensand filtration plant. It is fitted with excess
piping to allow additional filtration equipment to be installed in a relatively short period of
time in the event that further contamination is discovered. The consultant who designed and
built this plant indicated that the plant has excess treatment capacity, providing "insurance"
against an extended interruption of water supply due to future contamination.
5.0 COSTS OF CONTAMINATION
The total costs of discovery, characterization, cleanup, and water replacement at the
Route 6 and Chase Road wells is $1,334,934 ($1,380,694 in 1994 dollars). At the Route 6
well, the Town of Dartmouth incurred costs totaling $44,000 ($89,760 hi 1994 dollars).
Furthermore, since the closure of the Rpute 6 well, the town has lost revenue from the sale of
water netting $934,838 ($513,687 in 1994 dollars). At the Chase Road well, the town paid a
total of $734,259 ($777,247 in 1994 dollars) to respond to contamination. A $13,000
($15,470. in 1994 dollars) Aquifer Contamination Grant from the Commonwealth helped
defray these expenses. -These costs are described in the sections below.
- • \ • . •
area.
4 , ''.--."-'
A Phase II Assessment is an in-depth quantitative characterization of the hydrogeology and geochemistry of an
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• . • ' Benefit/Cost Analysis of Preventing Contamination: Town of Dartmouth, Massachusetts
5.1 Tangible Costs
Exhibit 2A presents the costs of responding to contamination at the Route 6 Well as of
September 1995; Exhibit 3A presents future costs associated with contamination at the well.
Exhibit 2B presents the costs to September 1995 of responding to contamination at the Chase
Road Well. Between 1995 and 2005, O&M costs associated with contamination at the Chase -
Road Well are presented in Exhibit 3B. '
5.1.1 Costs to Provide Safe Drinking Water at Route 6 Well
Between 1980. and 1991, the Town of Dartmouth spent $44,000 ($89,760 in 1994
dollars) studying the contamination at the Route 6 well and the surrounding aquifer. EPA's
and DEP's expenses associated with analyzing the materials in the drums and onsite cleanup
, activities are unavailable. ,
In addition to incurring the above costs, the town has lost the revenue from sale of
water from the Route 6 well. .Between 1969 and 1978, Dartmouth pumped an average of 81
million gallons per year from the Route 6 well. At a cost of $1,363 per million gallons (the
amount charged by New Bedford), the "market value" of this quantity of water is $110,403
per year. The total loss of water between 1978 and 1995 from the Route 6 well would'
therefore be valued at $1,419,442 (in 1994 dollars).
This figure represents only the value of .the water itself. By purchasing water, the
town did not incur any expenses related to maintaining and operating the well. According to
DWD, the operating cost savings over 17 years at the Route 6 well were $975,755. This
figure is based on the per-gallon electrical, chemical treatment, and labor costs at similar
wells. The net lost revenue due to contamination and closure of the Route 6 well was
$543,476 (in 1994 dollars). From 1995 to 2005, Dartmouth will pay over $389,000 to
purchase replacement water.
5.1.2 Costs to Provide Safe Drinking Water at Chase Road Well
The total costs of responding to contamination at the Chase Road site totaled $734,259
($777,247 hi 1994 dollars). The Phase II assessment cost $75,000 ($89,250 in 1994 dollars)
and the Risk Assessment cost $13,000 ($15,470 in 1994, dollars). The town paid $65,000
($81,250 hi 1994 dollars) for an air stripper tower and a new greensand filtration plant.
Annual air stripper operating costs for electricity, heat, chemicals, and labor associated with
daily inspections are $83,038 (in 1994 dollars). The O&M costs from 1988 to the present
total $591,277 (in 1994 dollars). Between 1995 and 2005, O&M of the air stripper/filtration
plant will total approximately $583,000.
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Benefit/Cost Analysis of Preventing Contamination:' Town of Dartmouth, Massachusetts
Exhibit 2A
Cost of Responding to Contamination at Route 6 Well: Dartmouth, MA
1978 to September 1995
($1994)
Item
One-time costs (1)
Site Cleanup/Monitoring Wells
Analysis of Dumped Drums
SUBTOTAL:
Incremental operating costs
Purchase of Water from New Bedford
Well operating costs (savings)
. SUBTOTAL:
ITOT/OSCOST:" :
Notes:
(1) Massachusetts DEP and U.S. EPA also paid to remove and analyze drums; costs are unavailable
Town of
Dartmouth
Exhibit 2B
Cost of Responding to Contamination at Chase Road Well: Dartmouth, MA
1988 to September 1995
($1994)
•$89,76<|
$89,76
$1,489,443
($975,75
$513,6871
Item
J-rovide sateDrfnKJns*Water:« >^;it *: ;-v.
One-time costs
Phase II Assessment
Risk Assessment
Construct Air Sfripper/Greensand Filtration Plant
SUBTOTAL:
On-going costs . •
Bectricity
Moat
Chemicals
Labor
| SUBTOTAL:
(TOTAL COST: ' • XTT —
Town of Aquifer Contamination
Dartmouth Grant Program
. S73.780 $15,470
- $15,470
$81,250
$170,500 $15,470
$463,512 ' ' •
$8,336
$39.021
$80,407
$591,277
v • $761,777 .,:••:.::.,.•• ;' :$15;470
„„
$89,250
$15,470
$81,250
$185,970
$463,512
$8,336
$39,021
$80,407
$591,277
$777,247]
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Benefit/Cost Analysis of Preventing Contamination: Town of Dartmouth, Massachusetts
_ Exhibit 3A
Future Cost of Responding to Contamination at Route 6. Well: Dartmouth, MA
October 1995 to September 2005
($1994)
Item
Town of.
Ongoing costs
Purchase of Water from New Bedford
Annual well operating costs (savings)
$775.424
($386,100)
- Exhibit 3B .
Future Cost of Responding to Contamination at Chase Road Well: Dartmouth, MA
October 1995 to September 2005 '
($1994)
Item
Town of
Wafer
Ongoing costs
O&M - Air Stripper/Greeosand Filtration Plant
Electricity
' Heat
Chemicals
Labor
$457,235
$8,225
$38,496
$79,317
$583,273;!
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Benefit/Cost Analysis of Preventing Contamination: Town of Dartmouth, Massachusettl
Dartmouth applied for an Aquifer Contamination Grant to clean up the site The town
received a $13,000 grant ($15,470 in 1994 dollars) and paid all other costs with its own
revenues.
5.2 Intangible Costs
. Dartmouth has not seen any effect on its real estate market or experienced any
economic dislocation associated with groundwater contamination. In fact, the construction
rate in Dartmouth has been rising. ,
6.0 WELLHEAD PROTECTION
Wellhead Protection (WHP) in Dartmouth began with the passage of an Aquifer
Protection bylaw in 1980. Dartmouth was among the first communities in the country, and
the first hi Massachusetts, to adopt WHP- Dartmouth's Wellhead Protection Plan (WHPP)
provides for delineation of three protective zones around its wells and a variety of safeguards
intended to protect aquifers from potential contamination.
6.1 State Requirements for Wellhead Protection
The Commonwealth of Massachusetts has implemented WHP via its Source Approval
Regulations (310 CMR 22.21). The Regulations apply to new PWS wells that produce at
least 100,000 gallons per day (gpd). Massachusetts requires delineation of three protection
zones around each water supply well: .
Zone I is a fixed 400 foot radius around each well, of which the PWS must
have "direct ownership or control'." '
Zone II is the aquifer zone that contributes water to the well under the most
severe pumping and recharge conditions that can be anticipated realistically for
a 180-day period without any significant recharge to the aquifer.-
• Zone III consists of the areas where ground water and surface water recharge
Zone II.
EPA formally approved Massachusetts' State Wellhead Protection Program in May, 1990.
6:2 Local Wellhead Protection Plan
Dartmouth first adopted an Aquifer Protection bylaw in 1980, Resident interest in
WHP began as a response to the discovery of contamination at the Route 6 well: The
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Benefit/Cost Analysis of Preventing Contamination: Town of Dartmouth, Massachusetts
wellhead protection areas (WHPAs) are managed through close cooperation among several
departments of the local government.
6.2.1 Wellhead Protection Area Delineation
Three protective zones have been mapped around each of Dartmouth's water supply
wells as a normal part of the well siting process. Zone I areas are simple 400 foot radii
around the wells. The Zone II delineations in Dartmouth were,calculated using the USGS
MODFLOW model or a conceptual model, such as the Theis equation for non-equilibrium
conditions. The final Zone II delineation is based on modeling results and actual pump
testing results. Zone III areas are delineated around the radii of the Zone Us.
6.2.2 Source Identification
A door-to-door survey of potential contaminant sources is not part of the standard
procedure for WHPA delineation in Dartmouth. Rather, DWD relies on inventories produced
by other departments of the town government to identify potential pollutant sources within the
Zone II areas of .its wells. For example, the Fire Chief maintains an inventory of underground
storage tanks, and the Department of Health (DQH) inventories and inspects septic systems.
A 1993 sanitary survey indicates the presence of potential sources of contamination
within the Zone I and II protection areas of Dartmouth's wells. Within the Zone I areas of
six wells are propane storage tanks and access roads. An oil storage tank is located within the
Zone I area of one well. Diesel oil disposal sites are located within the Zone II areas of two
wells. Gravel pits are found within the Zone II areas of three wells. Four wells have
multiple contaminant sources within their Zone I areas; two wells have multiple contaminant
sources within their Zone II areas. Three wells have sources of potential contamination in
both their Zone I and Zone II areas.
6.2.3 Management Plan
Several departments of the town government share management responsibility for the
WHPAs. These include the DWD, the Planning Commission, the Building Commission, and
the DOH. The DWD's day-to-day management of each WHPA consists of daily visits to the
wells and coordination with other departments of the town government. The Planning and
Building Commissions propose and enforce bylaws regulating activities within the protective
zones.
The Planning Commission has authority to propose bylaws for aquifer protection. The
Commission developed a delineation map and' proposed methods to manage Zones I, II, and
III around Dartmouth's wells. For example, the town's 1988 Growth Management Plan
discourages development, which reduces the likelihood of future aquifer contamination. It
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Benefit/Cost Analysis of Preventing Contamination: Town of Dartmouth, Massachusetts
requires minimum lot sizes of two acres for new development in the northern and southern
parts of town. Dartmouth does not provide water or sewer connections to any new
developments in those areas. • .
.Another Planning Commission requirement stipulates that a maximum of 10 percent of
a parcel of property can have impervious cover. This same requirement also mandates best
management practices (such as runoff detention ponds) for parking lots.
The Building Commission implements and enforces the zoning bylaw. The Building
Commissioner reviews building permit applications to determine whether proposed
construction within the protected zones complies with applicable requirements. '
The DOH permits and inspects septic systems in all real estate subdivision plans.
DOH requires a four-foot separation between a septic system and the water table, and a six-
foot separation with an aquifer. The Health Department also has the authority to recommend
new WHP requirements that it deems necessary to protect the health of Dartmouth's residents.
6.2.4 Contingency Plan
- [ - • .
Dartmouth has evaluated the vulnerability of its wells to contamination from
emergency spills, and il-has,,devised extensive contingency plans. When a spill is reported,
the Hazardous Waste Coordinator decides on the action to take and coordinates the cleanup.
This individual is responsible for contacting the Massachusetts DEP to respond to hazardous
'waste incidents when necessary.
Dartmouth's plan focuses on responding to automobile accidents, which pose the most
common threat to ground water. Fire departments respond on the scene with absorbent pads,
which are kept on fire trucks. At each well pump house, a supply of absorbent pads is kept
in stock in case a spill should occur near the well. For larger spills, the town retains
hazardous Waste cleanup contractors. The town currently is investigating the possibility of
equipping police officers with first-response kits, as police officers invariably are the first
officials on site when traffic accidents or other spills occur.
7.0 COSTS OF WELLHEAD PROTECTION
The costs associated with WHP in Dartmouth include the costs of developing
regulations, delineating wellhead protection areas, running the hazardous waste spill response
program, and reviewing activities that might affect WHP As. As of September 1995,
development of the Jown's bylaw and WHPA delineation costs have totaled $145,500
($183,51'0 in 1994 dollars).. The annual costs of WHP in Dartmouth are $154,052.
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' Benefit/Cost Analysis of Preventing Contamination: Town of Dartmouth, Massachusetts
7.1 Tangible Costs
.. In 1980, Dartmouth spent $30,000 ($53,700 in 1994 dollars) to study its ground water
resources before preparing its bylaw. Aside from this initial investment, the costs of
developing regulations arid reviewing applications have been minimal and are recovered by
permit application fees. ' .
Dartmouth's WHPP is financed through the Water Enterprise Fund. The costs to date
of developing and implementing WHP in Dartmouth are presented in Exhibit 4. Annual
management costs through September 2005 are presented in Exhibit 5.
.7.1.1 Wellhead Area Delineation Costs
Dartmouth has delineated eight WHP As as part of the well siting process. According
,to a DWD official, WHP is an integral part of Dartmouth's and Massachusetts' siting
requirements. Thus, separating the costs of WHP A delineation from other well siting costs is
difficult. . '
A former DEP official estimated that 50 percent of the cost of siting a new well is
attributable to the WHP-related components of Massachusetts' new source siting requirements.
This percentage of well siting costs is used to calculate the costs of WHPA delineation at
Dartmouth's wells. •
The total cost of WHPA delineation for Dartmouth's-wells was $115,500 ($129,810 in
1994 dollars), from three different contracts for well siting support. Under the first contract,
Dartmouth Power Associates (DPA) paid $200,000 ($228,000 in 1994 dollars) to site two
wells during the design of an electrical power plant.5 Half this cost, or $100,000 ($114,000
in 1994 dollars), is attributable to WHPA delineation. Under the second contract, Dartmouth
spent $15,500 ($15,810 in 1994 dollars) for the WHP-related components of the well siting,
including field surveying, pump testing, and WHPA modeling. The third contract was for
siting the Chase Road Well. Once the town convinced DEP4hat no contamination problem
existed at the well, DEP allowed Dartmouth to submit the Phase II and Risk Assessment
reports for drinking water source approval. Because the costs of preparing these reports are
included hi Section 5.2 as costs associated with contamination, they are not counted with
WHPA delineation costs. '
DPA gave the wells to the Town to compensate for anticipated heavy water usage.
" . . • -.- - 15- .
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• Benefit/Cost Analysis of Preventing Contamination: Town of Dartmouth, Massach
Exhibit 4
Cost of Wellhead Protection: Dartmouth, MA
1988 to September 1995
($1994)
Item
Develop bylaw
Study- aquifer characteristics '
Identify sources
Develop contingency plan
WHPA Delineation
WHPA Delineation: Contract #1
WHPA Delineation: Contract #2
SUBTOTAL:
JWHPR Implementation
DWD oversight of WHPA since 1988 (2)
Town of
Dartmouth
53,700
15,810
$69,510
$1,042,113
Dartmouth Power
Associates (1) Total
114,000
$114,000
Notes:
m wl^SSr? Wells,aund Gave Them to ^ Town to Compensate for Heavy Water Usage
(2) 5% of DWD annual budget is for WHP management and expenses .
$53,700
$114,000
$15,810
$183,510
$0 $1,042.113
$114JOOQ;'-.: i: >S122Sv623;l
- 16-
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"1.
Benefit/Cost Analysis of Preventing Contamination: Town of Dartmouth, Massachusetts,
Exhibit 5
Future Cost of Wellhead Protection: Dartmouth, MA
October 1995 to September 2005
($1994)
Item
Town of Building Permit
Dartmouth Applicants
Total
On-going costs
Day-to-day Oversight by DWD (1)
Building Commission Oversight (2)
$1.023,687
$58.310
1
$1,023,687
$58,310
$1,023,687
Notes:
(1) 5% of DWD Budget is for WHP Management and Expenses
(2) Assumes $45 to Review a Residential Permit Application and $112.50 to Review a Commercial Permit Application
- 17 -
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Benefit/Cost Analysis of Preventing Contamination: Town of Dartmouth, Massachusetl
7.1.2 Source Identification Costs
As noted earlier, Dartmouth does not have a distinct source identification plan. Costs
associated with source identification cannot be isolated.
7.1.3 Management Plan Costs ,
The annual costs of WHP in Dartmouth are $154,052. WHPA management is an
integral part of the daily activities of several town government departments For example
daily oversight of the WHPP by the DWD accounts for five percent of the Division's total
annual budget of $2,915,000, or $145,750. '
Approximately 45 percent of the Building Commissioner's review of each building
permit application is related to WHP, to check aquifer protection maps for potential aquifer
zone violations. This cost is recovered from permit application fees, which are $100 for
residences ($45 of which is WHP-related), and $250 for commercial applicants ($112.50 of"
which is WHP-related). In 1993, the Building Commission spent $8,302 for WHPA oversight
associated with the issuance of 152 residential building permits and 13 commercial permits."
DOH oversight of the WHPA consists of septic system inspections. Because these
inspections are primarily for the purpose of protecting health, With an "incidental" WHP
benefit, Dartmouth does not categorize the inspection costs as WHP expenses.
7.1.4 Contingency Planning Costs
The town's chief contingency planning expense is for maintaining supplies to respond
to hazardous spills near the wells. This cost is included in the DWD's annual budget for
wellhead protection. A DWD official provided price quotes for the types of absorbent pads
and oil booms that are commonly kept on hand at the pump houses and in fire/police vehicles.
However, it is unclear,how often these supplies are used and must be replaced. An annual
supply cost therefore cannot be calculated.
7.2 Intangible Costs
The only discernible major indirect costs associated with prevention of contamination
in WHP As results from the requirement that the bottoms of septic systems be at least 4 feet
from the water table. This requirement can add $15,000-525,000 to the basic cost of building
a septic system.
Compliance costs associated with regulations under the WHPP have not been
prohibitively expensive. Dartmouth remains an attractive location for development.
Construction rates have remained high, and much land remains for development. The two-
- 18-
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• Benefit/Cost Analysis of Preventing Contamination: Town of Dartmouth, Massachusetts
• acre minimum lot size requirement has not significantly changed the prices .of new homes
within the town. As the town's Planning Director said, "a lot is a lot," regardless of its size.
He indicated that one-acre lots sold for approximately $45.000, and two-acre lots are .selling
for around $50,000. The Planning Board has increased construction permit application fees to
help defray the costs of reviewing plans. ,
8.0 CONCLUSION
Between 1988 and 1995, the Town of Dartmouth has incurred a total cost of
$1,380,694 (in 1994 dollars) 'to. respond to contamination at two of its drinking water wells.
Most of these costs are ongoing: the town continues to pay to purchase water from New
Bedford and to run an air stripper at the Chase Road D well. Contamination at me two wells
cost the town and its'water users $140,769 each year, an average of approximately $70,000
annually per well.
As of September 1995, the total cost of developing Dartmouth's wellhead protection
program is $183,510 (in 1994 dollars). Divided equally among the town's seven active wells,
wellhead protection costs are approximately $26,200 per well. The annual costs of WHP in
Dartmouth are $154,052^ approximately $22,000 per well. . •
Purchasing water to replace the supply lost due to closure of the Route 6 well costs
$57,731 per year; annual air stripper operation costs at the Chase Road D well are $83,038.
When compared to the annual per-well cost of WHP ($22,000) the benefit of prevention is
clear. " ,
9.0 REFERENCES x
1993 Dartmouth Annual Town Report. Dartmouth, MA.
Boyce, Len. Supervisor, Dartmouth Water & Sewer Division. Personal interview, December
14, 1994. . . ' , .
Clement Associates. Chemical, Physical and Biological Properties of Compounds Present.at
Hazardous Waste Sites, Final Report. 1985. ''/
DEP/Division of Water: Supply. 1993 Annual Community Public Water Supply Statistical
Reportt andIdentification Survey<- Dartmouth Water Division. January 1994.
4 • J , -
Department'of Public Works, Town of Dartmouth. Pumping Test Report for New Source
Approval of the. Chase Road Well E-l & E-2 Sites, Dartmouth, Massachusetts. Prepared by '
Woodard & Curran Inc. October 1993.
-19-
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Benefit/Cost Analysis of Preventing Contamination: Town of Dartmouth, Massachusettl
Dusseault, Roland. Personal interview, February 1995.
Henderson, Wendy. Director, Dartmouth Board of Health. Personal interview, December 14,
Hickox, David. Assistant Superintendent. Dartmouth Department of Public Works Personal
interview, December 14? 1994.
Krawczyk, John. Vice President, Fay, Spofford, & Thorndike: Personal interview, December
Massachusetts Department of Environmental Protection. Drinking Water Facts: The
Massachusetts Wellhead Protection Program.
O'Reffly, Michael. Dartmouth Environmental Affairs Coordinator. Personal interview
December 15, 1994. '
Perry, Donald. Dartmouth Planning Director. Personal interview, December 15, 1994.
Planning Board, Dartmouth, Massachusetts. Dartmouth Groundwater Resource Study.
Prepared by Geoscience Associates. July 1980.
Silveira, David. Dartmouth Building Commissioner. Personal interview, December 15, 1994.
U.S. EPA Office of Drinking Water. Health Advisories for 25 Organics PB87-235578
March 1987. . '
-20-
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Contract No. 68-C4-0011
Work Assignment No. 1-14
Benefit/Cost Analysis of Preventing Contamination:
City of Tumwater, Washington
September 30, 1995
Submitted to:
U.S. Environmental Protection Agency
Ground Water Protection Division
Technical and Information Management Branch
-------
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TABLE OF CONTENTS
1.0 COMMUNITY DESCRIPTION . . ... . ... ........ ...... i
1.1 Laid Use .,'"'' 2
1.2 Geology/Topography 2
1.3 Hydrology . .........,......,.; 2
. 1.4 Climate ................... v.. '.'..... • ••••• ^
2.0 PWS CHARACTERISTICS 3
2.1 Water Supply . .. . . .. :...... ' ]•'.'•[. . '.[ 4
2.2 Financial/Management Characteristics . , 4
2.3 Population Served ...... '. ............. ; . . . . , . . . g
3.0 . CONTAMINATION . . . . _/;. 7
3.1 Contamination Source , . 7
3.2 Contaminants ................:................... 7
3.3 Effects of Contamination ................................... g
4.0 RESPONSE ACTiVrnES . . . ............ . . . ...... 9
4.1 Response to Contamination of the Water Supply ...... 10
4.2 Response to Ground Water Contamination ........ 10
5.0 COSTS OF CONTAMINATION . . . . ....., . .... . .... 11
5.1 Tangible Costs . . . . . \ ..'... 11
5.1.1 Costs to Provide Safe Drinking Water 11
5.1.2 Costs to Remediate the Aquifer .,.„...... . . : . n
5.2 Intangible Costs ..-.....,. 14
6.0 WELLHEAD PROTECTION .. .......... . . ... . . 14
6.1 State Requirements for Wellhead Protection . . 14
6.2 Local Wellhead Protection Plan . . . ...... . . 16
6.2.1 Wellhead Area Delineation 16
6.2.2 Source Identification 16
6.2.3 Ground Water Monitoring ...:... 17
6.2.4 Management Plan . ............ 18
6.2.5 Contingency Plan ............ 19
7.0 COSTS OF WELLHEAD PROTECTION . . /.......... ... .... 19
8.0 CONCLUSIONS.. ................... ..:...../....... 22
9.0 REFERENCES ......./............. 22
-------
LIST OF EXHIBITS
Exhibit 1 Ground Water Sources
Exhibit 2 Drinking Water Budget
Exhibit 3 Site Map
Exhibit 4 TCE Concentrations
Exhibit 5 Cost to Date of Responding to Contamination
Exhibit 6 Future Cost of Responding to Contamination
Exhibit 7 Cost to Date of Wellhead Protection
-------
BENEFIT/COST ANALYSIS OF PREVENTING CONTAMINATION
TUMWATER, THURSTON COUNTY, WASHINGTON
On August 3, 1993, the City of Tumwater, Washington detected trichloroethene (TCE)
in Wells #2, #4, and #5 at its Palermo Wellfield. The City immediately shut down .the three
wells and, with the assistance of the Washington State Department of Ecology (WSDOE)
conducted a preliminary field investigation of the contamination. The investigation initially
identified 19 potential sources of contamination in the vicinity of the wellfield. After further
investigation, WSDOE subsequently narrowed the.list down to 13 potential sources and turned
the investigation over to EPA Region 10.
In early 1995 Region 10 concluded Phase I of an Expanded Site .Investigation (ESI)1
and further narrowed the list to four potential sources: a Washington State Department of
Transportation (WSDOT) Materials Laboratory, Southgate Dry Cleaners; Brewery City Pizza
and Tumwater Chevron. In June 1995, the Region began a Phase H ESI, which involved a '
more comprehensive subsurface investigation and an assessment of the feasibility of
remediation. •
Upon discovering the contamination, the City accelerated plans to cqnstruct two new
wells at the George Bush Middle School. WSDOE issued a construction permit for Well #12:
in January 1994 and authorized construction under an existing permit for Well #14 in August
-17 y^T • • • ,
In February 1993, Tumwater applied for and received a $170,500 grant from the State
of Washington's Centennial Clean Water Fund to develop a comprehensive wellhead
protection plan. To qualify for the grant, the City provided a $ 170,500 match for the State
funds. To date, Tumwater has passed three aquifer protection ordinances, conducted a
preliminary delineation of its wellhead protection areas, and developed a preliminary list of
potential sources. The City expects to complete its wellhead protection plan by mid 1996.
As of September 1995 the cost of contamination at the Palermo wellfield is
approximately $797,541. The total cost of wellhead protection plan development is $347,826.
1.0 COMMUNITY DESCRIPTION
The Tumwater Water System (TWS) supplies drinking water to the City of Tumwater
and some unincorporated areas of surrounding Thurston County. Tumwater is a relatively
small city situated in central Thurston County, just southwest of the State capital, Olympia.
The city is located in one of the fastest growing areas of Washington State. In 1992,
"The Palermo Wellfield is CERCLIS '#WA0000026534.
" . ' . .' ' ." -1 -
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Benefit/Cost Analysis of Preventing Contamination: City of Tumwater, Washingt\
Tumwater s population was 10,360. By 1997 the population is expected to reach
approximately 14,350, and by 2011 the population is expected to reach 29,000. The local
economy rests on state government, retail trade, manufacturing, and professional serv ce? A
buS °WP H1? * PSbSt BfeWing C°mpany 1S °ne °f *» Ci*'s most PromTn n7 A
businesses. Pabst operates its own water system.
1.1 Land Use
i*nrf TheTP'edorni1nant land use in Tumwater is' residential, comprising 25 percent of total
land area. Industrial uses comprise 13 percent, public uses comprise 9 percent, commercial
uses comprise 5 percent, and open space comprises 5 percent of the total land area. Despite
recent population increases, almost 35 percent of the land in Tumwater remains undeveloped.
1*2 Geology/Topography
Tumwater, like most of the Puget Sound region, is characterized by glacial deposits
The geology and topography of Thurston County are largely the result of the glacial action'
tiia occurred during the Pleistocene ice age. The local elevation ranges between 200 and 400
feet above mean sea level. The area consists of low hills on the northwest and southeast
separated by a broad, flat plain which runs from the northeast to the southwest. The plain is
cut by the^eschutes River Valley, which runs along the eastern portion, and is bounled by
the Black River drainage to the west •*
Geologic studies indicate that the upper 25 feet of the ground consists of sand and
grave .underlain by a layer of silt and clay about forty, feet thick, followed by a sand and
gTaveUayer 30-135 feet thick. The lowest and oldest geologic unit found under ThursSn
County consists of Tertiary Bedrock. The sand and gravel layers are highly permeable-
ground water is extremely vulnerable to contamination,
1.3 Hydrology
All of Tumwater's ground water resources are developed in unconsolidated sand and
gravel in four aquifers, listed in order of increasing depth:
Quaternary Alluvial - an uncdnfmed gravel aquifer;
, • Vashon Recessional Outwash -- a mostly unconfmed sand and gravel aquifer;
' • Vashon Advance Outwash - a mostly unconfmed sand and gravel aquifer; and
Tertiary-Quaternary Undifferentiated Deposits - a confined sand and gravel
aquifer.
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Benefit/Cost Analysis of Preventing Contamination: City of Tumwater, Washington
The first three of these aquifers are very susceptible to contamination due to their relatively
shallow depth, lack of protective aquitards, and highly permeable surficial soils The
Quarternary Alluvial aquifer is suspected of being hydrologically connected to both the
Deschutes River and the Vashon Recessional Outwash aquifer.
Ground water flows north to northwest in Tumwater. The region's ground water
system is hydraulically isolated and generally does not receive water from the Cascade or
Olympic mountains or other distant locations. Rainfall is the primary source of recharge for
the area's aquifers. Approximately 34 of the 51 inches of precipitation which typically fall
each year infiltrate the ground and recharge ground water.
Water quality in the Quarternary Alluvial and Vashon Recessional Outwash aquifers is
generally good, with low concentrations of dissolved solids. The Vashon Advance Outwash
aquifer tends to be slightly hard, with moderate concentrations of calcium carbonate. In
contrast, water in the Tertiary-Quaternary Undifferentiated Deposits tends to have elevated
levels of manganese, chlorides, and sodium, especially at lower depths.
Three principal surface water drainages exist in the Tumwater area. The Black
Lake/Black River system to the west of the City drains south to the Chehalis River, the
Trosper Lake/Percival Creek system in the north drains north to Capitol Lake and then to
Puget Sound, and the Deschutes River flows north through the City into Capitol Lake.
1.4 Climate
Tumwater enjoys a mild marine climate with moderate year-round temperatures. The
summers are warm and dry, while the winters are wet and mild. About 51 inches of
precipitation fall annually, with the majority falling between November and March.
2.0 PWS CHARACTERISTICS
The City of Tumwater owns and operates TWS.2 The utility's service area covers
approximately 10.7 square miles, and is comprised of four pressure zones. The two lowest
pressure zones serve a relatively flat plain on which most of Tumwater is located, and the
two higher pressure zones serve a hilly area to the west.
2PWS ID SWA5389700.
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Benefit/Cost Analysis of Preventing Contamination: City of Tumwater, Washing*
2.1 Water Supply
networkr * tW° pumping stations' and a distribution
network The City currently does not treat its water, but anticipates having to install
freatment to comply with the Safe Drinking Water Act's Lead and Copper Rule and with the
Washington State Department of Health's disinfection requirements.
TWS has two standby interties with the City of Olympia and has an informal
agreement to obtain water from the Pabst Brewing Company. One of the two Olympia
internes benefits the City of Olympia more than Tumwater, because Tumwater's system
operates at a much higher pressure at that location. Water cannot be transferred to Tumwater
unless the Tumwater system is extremely depleted or unless a booster pump is installed at the
location. At the second Olympia intertie, the pressures are nearly equivalent, and water can
be pumped into either system. During periods of peak demand, Pabst historically has allowed
Tumwater to obtain water via a fire hose connected to a hydrant on the Pabst property.
depends wholly on ground water drawn from three aquifers: Vashon Advance
Outwash, Quarternary Alluvial, and Tertiary-Quarternary Undifferentiated Deposits. Its wells
&fa2H3 Tt0T VP ^S^ Palerm0' P°rt °f °lympia (Ailp0rt)' Ci* Ha"' Bush ^ddle
School, and Trails End. The City of Olympia originally constructed the Port of Olympia
we s to serve its airport. Tumwater annexed the airport area in 1986. Four of Tumwater's
wells are inactive, one is pumping to waste due to contamination, and one is used only as an
t0tal instantaneous caPacitv of me operating wells is 6,265 gallons
2.2 Financial/Management Characteristics
Tumwater maintains a separate enterprise fund for its water utility. In the fiscal year
ending June 30, 19943, the fund's total expenditures were approximately $7.5 million The
city s water budget nearly doubled between FY 1993 and FY 1994. Most of this increase can
be attributed to one-time capital outlays for construction of a new storage tank and two new
wells To fund various drinking water projects, Tumwater raised nearly $5.4 million in
capital by issuing revenue bonds and obtaining loans in FY '93 and FY '94 Exhibit 2
contains a breakdown of the drinking water budget.
3Data from FY95 are not available.
-4-
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Benefit/Cost Analysis of Preventing Contamination: City of Tumwater, Washington
EXHIBIT 1
Ground Water Sources
Capacity (GPM)
Quarternary Alluvial
Quarternary Alluvial
Pumping to waste due to
contamination
Quarternary Alluvial
Quarternary Alluvial
Quarternary Alluvia!
Quarternary Alluvial
Tertiary-'Quarternary
Undifferentiated Deposits
Excessive manganese; emergency
supply only
Quarternary Alluvia]
Port of Olympia
(Airport)
Vashon Advance Outwash
Port of Olympia
(Airport)
Vashon Advance Outwash
Vashon Advance Outwash
Bush Middle School
Vashon Advance Outwash
Port of Olympia
(Airport)
Coarse Grained Glacial
Deposits
Inactive — formation collapsed
during redevelopment
Bush Middle School
Vashon Advance Outwash
Vashon Advance Outwash
Quarternary Alluvial
Active; recommended for closure
-5-
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Benefit/Cost Analysis of Preventing Contamination: City of Tumwater, Washingto\
EXHIBIT 2
Drinking Water Budget
Expenditure !
Capital Outlays
Operating Expenditures (e.g., salaries, 'benefits, supplies,
contract services)
Debt Service '
Contingency Reserve "
TOTAL
FY 1994 Budget
(millions)
$5.90
$1.17
$0.24
$0.15
$7.46
TWS has a two-tier rate structure, consisting of a monthly base rate which varies by
meter size and a consumption charge of $1.15 per one-hundred cubic feet. The average
household in Tumwater pays approximately $16.45 per month for water. Tumwater's rates
are comparable to neighboring communities of similar size.
Tumwater has adopted water system access charges to cover the cost of new
development. These include connection fees and meter installation fees. Connection fees
range from $800 to $154,640, depending on the meter size. Meter installation fees range
from $295 to $1,200.
• 23 Population Served
TWS supplies a population of approximately 13,000 with about 3,347 connections.
The PWS serves all Tumwater residents, as well as some households located in
unincorporated areas of Thurston County. Residential customers account for about 90 percent
of water users in Tumwater. The largest non-residential customers are Columbia Beverage,
the State of Washington4, the Tumwater School District, Louis Kemp Seafoods, and the Tyee
Motor Inn.
Numerous State office buildings are located in Tumwater.
-6-
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_, Benefit/Cost Analysis of'Preventing Contamination: City of Tumwater, Washington
3.0 CONTAMINATION
On August 3, 1993, the City of Tumwater; while conducting monitoring as part of a
comprehensive water quality study, detected trichloroethene (TCE) in Wells #2, #4, and #5 at
the Palermo wellfield. Tumwater took the wells out of production, but continued to pump
them as a safety measure to prevent contaminated ground water from reaching three
unaffected wells. The City is still discharging water from Well #2 into a nearby drainage
slough. Tumwater, the State Department of Ecology, and EPA Region 10 have conducted
investigations of the site to determine the source of contamination.
3.1 Contamination Source
The City and WSDOE conducted a joint field investigation of the contamination
between August 11 and August 22, 1993. Investigators concluded that the most likely source
of TCE in the wells was a dense, non-aqueous phase liquid (DNAPL) in soil below the water
table, somewhere to the west of the wellfield.
Washington's 1989 Model Toxics Control Act requires WSDOE to investigate any
suspected release of hazardous substances and identify "potentially liable persons." WSDOE
identified 19 potential sources, including a dry cleaning establishment, several gas stations, an
illegal dump, and. two Washington State Department of Transportation (WSDOT) facilities.
WSDOE concluded that 13 of these sources required further study and turned the
investigation over to EPA Region 10.
In late 1994 EPA conducted a Phase I Expanded Site Investigation (ESI) of the site,
and narrowed the list of potential sources down to four the Washington WSDOT Materials
Laboratory (where asphalt testing occurred), Southgate Dry Cleaners, Brewery City Pizza
(allegedly the former site of a dry cleaners), and Tumwater Chevron. Exhibit 3 contains a
map of the Palermo wellfield area.
3.2 Contaminants •
' - _ • As part of the initial investigation, the City and WSDOE conducted extensive well
water, ground water, soil'gas, and soil sampling at the site. TCE, a volatile organic
compound (VOC), was the prevalent contaminant found in the PWS wells. TCE was present
in Wells #2, #4, and #5, although it exceeded the Maximum Contaminant Level (MCL) only
in Well #2. The MCL for TCE is 5 parts per billion (ppb). Concentrations in Well #2
ranged between 7 and 15 ppb; in contrast, the highest concentration found in either Well #4
or Well #5 was 3 ppb. Exhibit 4 contains a summary of sampling results for the three wells.
• ' , i -
Limited ground water modelling indicated that pumping from the wellfield altered the
natural ground water flow and drew the contaminant plume into the wellfield. About 600 feet
-7-
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. Benefit/Cost Analysis of Preventing Contamination: City of Tumwater, Washingt
to the west-northwest of the wellfield, ground water samples contained TCE concentrations o
up to 165 ppb. Low concentrations of trans- 1,2-dichloroethene and tetrachloroethene (PCE)
also were detected. Investigators concluded that given TCE's high solubility, the relatively
low concentrations of TCE in ground water indicated that the source was a considerable
distance from the wellfield. They also concluded that the source would persist for many
years and continue to generate a plume. The investigators could not determine if the TCE
was a breakdown product of PCE, or if the two contaminants resulted from separate sources.
Investigators did not detect TCE'in soil samples, but they observed that the soil was
dark-stained, smelled of petroleum, and contained low concentrations of toluene,
ethylbenzene, and xylene. They determined that this contamination was probably associated
with fuel leakage from an automobile and was not related to the contamination present in the
wens. , . • • -
EPA Region 10 conducted ground water and soil sampling at the site during its ESI
In ground water samples, EPA detected TCE at concentrations up to 116 ppb, PCE at
concentrations up to 115 ppb, vinyl chloride at concentrations up to 17 ppb, C-DGE at
concentrations up to 8 ppb, and T-DCE at concentrations up to 2 ppb. In soil samples EPA
detected TCE at concentrations up to 7 ppb, PCE at concentrations up to 42 ppb, vinyl'
chloride at concentrations up to 15 ppb, C-DCE at a concentration of >1 ppb, and T-DCE at a
concentration of nearly 4 ppb. Region 10 also confirmed the presence of TCE in the three
Palermo wells.
33 Effects of Contamination
The study team found no evidence -of health or environmental effects from the
contamination incident. Only one of the contaminated wells had TCE concentrations in
excess of the MCL. Prior to discovering the contamination, TWS routinely mixed the water
produced from the six wells at the Palermo wellfield, so the TCE concentration in the
distribution system probably never exceeded the MCL. The reader should note, however that
the contaminant plume is migrating under a residential neighborhood at a relatively shallow
depth. Evidence indicates that long-term exposure to TCE may damage the liver.5
In the period between the closure of Wells #2, #4, and #5 in August 1993 and
construction of Well #12 in the spring of 1994, Tumwater frequently could not maintain
adequate water pressure in its distribution system for fire control. A serious fire could have
posed a severe threat to public safety.
'Health Advisories for 25 Organic*, U.S. EPA Office of Drinking Water, PB87-235578, March 1987.
• . -8- • ' • "'
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Benefit/Cost Analysis of Preventing Contamination: City of Tumwater, Washington
EXHIBIT 3
Site Map
. \
Capitol
5000
•\BU-
AJ0.7 06.2O)
^
-43.90
^34.00
• ..../M4.2/116 (52.80)
" /*37.2.'12.4
Brewery City
: Cattin's
•'ll (U) .
1.5 <4.6QS:
Southgate
Mall
•' Texaco
: . ;„ ; . \._
Palermo /
Well Bekl
EXHIBIT 4
TCE Concentrations (ppb)
Contaminant
TCE
Date
8/3/93
8/11/93
8/12/93
8/22/93
WeU #2
12.6
15
14
7
Well #4
1.1
2.5
, 3 ,
1
Well #5
1
2 ••-•''
2
• ' 3 :
4.0 RESPONSE ACTTVniES
Upon confirming the monitoring results, Tumwater informed both the Thurston County
Moderate Waste Department and the WSDOE about the contamination. On August 8, 1993,
the town informed the public by holding a press conference. During the following months,
the City, WSDOE, and EPA Region 10 conducted investigations of the contamination.
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Benefit/Cost Analysis of Preventing Contamination: City of Tumwater, Washingtc
4.1. Response to Contamination of the Water Supply
Tumwater responded to .the contamination by immediately taking Wells #2, #4, and #5
out of production, imposing emergency water conservation measures, and investigating
alternative sources of drinking water. At the time of the contamination incident, the City had
two water rights applications before WSDOE. The first was an application for a
supplementary water rights permit to allow construction of an additional well at the Palermo
wellfield. The second was an application to change the authorized points of withdrawal for ,'
several of the Port of Olympia wells. When the contamination occurred, the City amended
the permit application for the additional Palermo water right. It sought instead to construct a
new well at the George Bush Middle School. Due to the water supply emergency, WSDOE
acted rapidly on the amended permit application and issued a construction permit for Well
#12 in January 1994. Tumwater began operating Well #12 in June 1994, and WSDOE issued
a final permit to withdraw 910 gpm in January 1995. In the meantime, WSDOE acted on the
City's Port of Olympia change application by authorizing construction of Well #14 at Bush
Middle School in August 1994. The City recently brought the .Well online.
In 1995, TWS began pilot-scale aeration tests to determine the feasibility of
constructing an air stripper at the Palermo wellfield, so it could put the affected wells back in
• service. Preliminary results show that an air stripper would be very effective.
4.2 Response to Aquifer Contamination
Tumwater's ground water consultant, Pacific Groundwater Group, Inc. (PGG), sampled
the Palermo wells, surface water, ground water, soil gas, and soil to determine contamination
levels and locate the source of the contamination. Based on the results of ground water
modelling, PGG concluded that only Well #2 required continuous pumping to prevent the
possible contamination of the other wells. PGG recommended installation of a monitoring
well in the wellfield to detect possible movement of contamination toward the unaffected
wells. In the meantime, WSDOE identified 19 potential sources of contamination, based on
the sources' location in relation to the wellfield and the historical use of the land. WSDOE
subsequently narrowed the list down to 13 sources.
At this point, Tumwater and WSDOE turned the investigation over to EPA Region 10.
EPA focused on the 13 potential sources, collecting 30 soil gas, 41 ground water, and 34 soil
samples. Based on the results of this sampling, EPA narrowed down WSDOE's list to four
potential sources of contamination: a WSDOT Materials Laboratory, Southgate Dry Cleaners,
Brewery City Pizza, and Tumwater Chevron. Phase JJ of the investigation began in June
1995 and will be completed by the end of 1995. Phase H consists of ground water, soil, and
soil gas sampling at the four suspected sources. EPA estimates that remediation could not
begin until the summer of 1996, at the earliest. The remedy, and the duration of remediation,
have not been determined.
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Benefit/Cost Analysis of Preventing Contamination: City of Tumwater, Washington
5.0 COSTS OF CONTAMINATION
• • • j. t ' . • ' • • • - • ,.-"''•
The total cost of responding to contamination as of September 1995 is approximately
$797,000 (in 1994 dollars). The net present value of expected costs through 2005 is
approximately $915,000, assuming a discount rate of 7 percent. Exhibit 5 summarizes costs
through September 1995, and Exhibit 6 contains expected costs through September 2005.
1 "•'••. - ' • ' - .
5.1 Tangible Costs
Tangible costs consist of the cost to secure alternate sources of drinking water, and the
costs to characterize the aquifer contamination and identify potential sources of
contamination. The City of Tumwater has incurred the costs to provide safe drinking water,
and EPA Region 10 has incurred all but $5,000 of the cost to investigate the contamination.'
5.1.1 Costs to Provide Safe Drinking Water
Tumwater incurred a capital outlay for construction of two new wells and has
experienced increased operating costs for the three remaining wells in the Palermo wellfield.
The total cost for siting and constructing Wells #12 and #14 is approximately $920,000. The
City of Tumwater Comprehensive Water System Plan (September 1992) indicates that Wells
#2, #4, and #5 were in poor condition and were scheduled to be replaced by the end of 1994,
at a total cost of approximately $693,079. Thus, the actual incremental capital cost due to the
contamination is about $226,921. The difference possibly results from the need to construct
transmission lines from Bush Middle School to the distribution system.
Tumwater has increased the frequency of VOC monitoring at the Palermo wellfield, at
an additional cost of $1,470 per month. In the 26 months since the contamination was
discovered, the cost of this increased monitoring totalled $38,220.
5.1.2 Costs to Remediate the Aquifer
As indicated earlier, Tumwater, WSDOE and EPA Region 10 have conducted two
investigations of the contamination at Palermo, at a the total cost approximately $207,000.
The City spent $126,000 and WSDOE spent $5,000 for their joint initial investigation. Phase
I of EPA's ESI cost approximately $76,000, and Phase n cost approximately $325,400.
- 11 -
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Benefit/Cost Analysis of Preventing Contamination: City of Tumwater, Washington
Exhibit 5
Cost of Responding to Contamination: Tumwater WA
August 1993 to September 1995
($1994)
City of
Tumwater
WADeptof
Ecolo
One-time costs
Replacement wells and transmission line
Staff ovecsight/administration
SUBTOTAL
incremental operating costs (since August 1993)
Increased monitoring ($1,470 per month)
SUBTOTAL
TOTAL:
Pre-Remediat'on
• Initial field investigation
Preliminary identification of sources
Expanded Site Investigation: Phase I
Expanded Site Investigation: Phase II
206,921
20,000
$226.921
38.220
$38,220
$265.141
-- • • •
120,000
6,000
$126.000
=$3SI$«lJSBs?,<
$0
$0
$0
5,000
55,000
•;;;:— $5iOOO
.$0
$0
$0
— • • —
76.000
325.400
$401,400
C $401 .400
$206.921
$20.000
$226.921
$38,220
$38,220
$265,141
$120,000
$11,000
$76,000
$325,400
$532,400
. S797i54'|;3
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Benefit/Cost Analysis of Preventing Contamination: City of Tumwater, Washington
Exhibit 6
Future Cost of Responding to Contamination: Tumwater, WA
October 1995 to September 2005
($1994)
Item
City of
Tumwater
One-time costs
Construction of air stripper
Engineering/legal/administrative
SUBTOTAL:
Ongoing costs
Monitoring
Electricity and maintenance
Repumping
SUBTOTAL:
$545,899
$139.750
$685.649
$123.896
$80,771
$24,583
$229,250
$914.8991
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Benefit/Cost Analysis of Preventing Contamination: City ofTumwer, Washingtol
5.2 Intangible Costs
"is chances of
6.0 WELLHEAD PROTECTION
Wat6r re§ulations re<3uire Public water systems (PWSs) to adopt
eS' The Washington-State Department of Health's (WSDOH)
H an H iS resP°nsible
guidance and technical assistance to PWSs.
n iS resP°nsible for establishing WHP requirements and providing
F^vmmg
6.1 State Requirements for Wellhead Protection
Washington officially adopted its wellhead protection (WHP) regulations in July
sto ^ PWSs ta ^ state - re
state'
A delineated wellhead protection area for each well;
An inventory of potential sources of contamination;
A management plan to prevent contamination;
Contingency and spill response plans for responding to contamination; and
ic participation in the WHP planning process.
comptae
Wellhead Protection Areas (WHPAs) must consist of four or five zones:
0 A sanitary control area;
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' Benefit/Cost Analysis of Preventing Contamination: City of Turnwater, Washington
, • Three additional zones based on one-, five-, and ten-year time of travel rates-
and '
• Where appropriate, a larger buffer zone.
The delineation method PWSs must use is based both on system size and on the susceptibility
of the well to contamination. The PWS must submit a Susceptibility Assessment Form as
part of its WHP effort. Based on how WSDOH ranks the susceptibility of the well, it
requires one of the following delineation methods: a calculated fixed radius, an analytically
derived model, hydrogeologic mapping, or a numerical flow/transport model. WSDOH
requires delineation to be completed by July 1995 for systems using the calculated fixed
radius method or by July 1996 for systems using other, more sophisticated delineation-
methods.
WSDOH requires PWSs to conduct an inventory of potential contaminant sources in
their WHPAs. They must compile a list of such sources and notify the appropriate regulatory
agencies and local governments, as well as the owners/operators of the potential sources of
their presence in the WHPA. Jf the PWS fails to do this, it may be held liable in the event of
contamination. WSDOH requires completion of the inventory within one year of the
completion of the delineation process.
The State requires two management components in the WHPP. The PWS must have
both a contingency plan to supply water in the event of contamination and an emergency spill
response plan. Both of these plans must be completed within one year of WHPA delineation.
The WHP process in Washington can help systems obtain susceptibility monitoring
waivers for Phase U/Phase V regulated compounds, and subsequently reduce monitoring costs.
The Wellhead Protection and the Monitoring Waiver processes are closely related: WHPA
delineation and source inventories are principal elements of both programs. By completing
the WHP process, a PWS also completes a large part of the monitoring waiver process. A
typical small to medium PWS can save approximately $5,000 per year in monitoring costs.
The 1990 Washington State Growth Management Act (GMA) requires communities to
identify sensitive areas (e.g., aquifer recharge zones) and pass ordinances to protect them.
The Act also requires WSDOE to designate ground water protection areas. Counties and
cities with high growth rates must develop comprehensive land use plans to protect the
quality and quantity of ground water used for public water supplies; Thurston County
developed the Northern Thurston County Ground Water Management Plan in 1992. The plan
established .guidelines for wellhead protection plans (similar to the more recent State
regulations), and recommended that all major water purveyors establish wellhead protection
plans by 1998. Each of the cities in Thurston County—Tumwater, Olympia, and
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. __ Benefit/Cost.-Anafysis of-Preventing Contamination: City ofTumwater, Washington
Lacey—endorsed the plan. They developed a joint Wellhead Protection and Financial
Management Committee to coordinate their individual WHP efforts.
6.2 Local Wellhead Protection Plan
In February 1993, Tumwater applied for and received a $170,500 grant from the State
of Washington's Centennial Clean Water Fund to develop a comprehensive WHPP To
qualify for the grant, the City provided a $170,500 match for the State funds. The city
contracted with Economic and Engineering Services, Inc, (EES) and PGG to develop the
program. . .
To date, Tumwater has passed three aquifer protection ordinances, conducted a
preliminary delineation of its wellhead protection areas, developed a preliminary list of
potential sources, and ranked the sources according to the threat they pose to Tumwater'-s
wells. The City plans to complete its wellhead protection plan by mid 1996.
6.2.1 Wellhead Area Delineation
PGG used the QuickFlow ground water model to estimate capture zones for six-month
and one-, five-, and ten-year times-of-travel for each of Tumwater's wells. The six-month
one-, five-year time of travel simulation produced three distinct sets of wellhead zones for'the
Palermo,, Bush Middle School, and Port of Olympia wellfields. In contrast, the ten-year zones
nearly coalesced into a single zone. Tumwater has adopted a single WHPA encompassing the
ten-year time-of-travel zones for Palermo, Bush, and Airport wellfields in order to account for
uncertainties in the modelling results.
6.2.2 Source Identification
EES and the City performed a preliminary source identification and developed.an
initial ranking of contaminated sites within the preliminary WHPA. Later in the WHP effort,
the City will conduct a more comprehensive source identification and risk assessment.
In the fall of 1993, EES and the City conducted a "windshield" survey of potential
sources in preparation for completing the Department of Health's Susceptibility Assessment
Form. The form is the basis for determining whether a system will qualify for monitoring
waivers. The survey identified several sources significant enough to warrant follow-up visits
to confirm the nature of the suspected source and inform the property owner of its location in
the WHPA. During the survey, the City also recorded land uses in the WHPA. EES will use
these data to supplement existing land use maps prepared by the City and Thurston County,
, and then incorporate them into a Geographic Information System.
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Benefit/Cost Analysis pf Preventing Contamination: City of Tumwater, Washington
In addition to the windshield survey, EES reviewed several environmental databases
maintained by.WSDOE., These included the Leaking Underground Storage Tank List, the
Confirmed and Suspected Contaminated Sites Report, Superfund Amendments and
Reauthorization Act (SARA) Tier Two Emergency and Hazardous Chemical Inventory Forms
the Underground Storage Tank list, and the Washington Toxics Release Inventory.
EES developed qualitative criteria for ranking the threats posed by these sources
They included:
Contaminant characteristics (e.g., toxicity, mobility, persistence);
Hydrogeologic properties (e.g., aquifer in which the nearest well is screened
travel time to the well);
• Location (e.g., 6-mohth, one-, five-, ten-year time-of-travel zone, Wellhead
Protection Area, above or below ground surface); and
• Extent of known soil and ground water contamination.
EES ranked all confirmed sources of contamination using the criteria. Prior to the conclusion
of the WHP effort, the City will use the criteria to rank all potential sources identified in the
•
The preliminary survey identified several contaminated sites of particular concern.
These include four sites with confirmed ground water and/or soil contamination within the
ten-year time-of-travel zones of Wells #9, #10, and #15. The contaminants present include
petroleum, chlorinated solvents, and phenols. The survey also identified two leaking
petroleum USTs within the five-year time-of-travel zone of the Palermo wellfield.
Using volunteers, the TWS conducted a parcel-by-parcel survey of -potential
contamination sources in the summer of 1995. As of September 1995, analysis of the survey
data has not been completed.
6.2.3 Ground Water Monitoring
.-,;.. ... - ' • v,
Tumwater' s wellhead protection effort includes the development of a ground water
monitoring network. In its monitoring work plan, PGG recommended construction of five
monitoring wells in addition to monitoring wells Tumwater currently operates. The wells will
be located either immediately downgradient of known contamination sites or upgradient of
PWS wells. One of the proposed monitoring wells will be located immediately downgradient
of a Texaco bulk 'fuel facility where a spill occurred (northwest of Wells #9 and #10), and
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. Benefit/Cost Analysis of Preventing Contamination: City of Tumwater, Washington \
i Jf 1°Cat^SOUthe/it of ** Pajerm° ^llfield. PGG also recommended using private
wells further upgradient of Tumwater's wells to monitor nonpoint contamination.
Based on PGG's recommendation, the City is conducting baseline water quality
monitoring in September and October of 1995. The monitoring focuses on VOCs, several
inorganics, phenols (near certain industrial sites), and pesticides (near a Christmas tree farm)
Beyond the baseline monitoring, long-term monitoring probably will consist of annual
monitoring for VOCs and a limited number of inorganics within the five-year time-of-travel
zones. The City will monitor for nonpoint contaminants (e.g., nitrate, iron, and manganese)
in several private wells. 6
The Thurston County Public Health Department has six monitoring wells located in
Tumwater s preliminary WHPA. Currently, the wells are used to monitor ground water
levels; however, the County lacks funding to continue the monitoring effort.
A * u PGG's m°nitoring work plan calls for maintaining data in a format compatible with
data being collected by the Cities of Lacey and Olympia, and by Thurston County By
sharing data, the communities will be able to identify regional ground water quality trends.
6.2.4 Management Plan
EES is developing a management plan for Tumwater's WHPA, which should be
completed in mid 1996. According to the wellhead protection work plan, the management
plan wUl consist of recommendations for land use controls, operating standards for sources
and public education. \ '
Although Tumwater does not yet have a formal management plan, it has previously
undertaken several activities traditionally associated with wellhead protection management
strategies. Pursuant to the GMA, the City developed a Conservation Plan which recommends
that the city adopt ordinances to protect aquifer recharge areas from contamination.
Ordinances 1279 and 1280, passed in August 1991, designate an aquifer protection
overlay zoning district to protect vulnerable aquifer recharge areas in the City The
ordinances prevent the following industries from locating within the district, unless they
demonstrate that new technologies and/or application of best management practices will result
in no additional threat to ground water:
• Chemical manufacture and reprocessing;
• Creosote/asphalt manufacture or treatment;
• Electroplating;
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Benefit/Cost Analysis of Preventing Contamination: City ofTumwater. Washington
Manufacture of flammable or combustible liquids; '.
• Petroleum products refining and reprocessing;
• Wood products preserving; and
• On- and off-site hazardous waste treatment and storage.
Ordinance 1281, also passed in 1991, requires that new development in the City be
designed to eliminate the threat of chemical or biological contaminants' entering ground
water. The Ordinance requires that:
• The public works director develop performance standards for stormwater
retention facilities;
„ • New USTs have liners or double hulls, and release detection systems; and
• Above-ground tanks have impervious containment structures underlying and
surrounding them.
Developers of projects located outside the aquifer protection district may submit an aquifer
protection plan in lieu of meeting the requirements. They must, however, demonstrate that
the plans provide equivalent protection of ground water. -
6.2.5 Contingency Plan
EES will develop contingency and spill response plans. The contingency plan will
analyze alternative source options given existing water rights. The spill response plan will
include proposed enhancements to the city's existing spill response efforts.
7.0 COSTS OF WELLHEAD PROTECTION
Tumwater's Centennial Fund grant application projects that the WHPP will cost
$348,000 (See Exhibit 7). This total includes both consultant costs and the labor costs of city
staff. Consultant .invoices submitted to date indicate that the cost is running slightly lower
than expected.
Tumwater's wellhead protection work plan is divided into six tasks: (1) project
management, (2) establish wellhead protection areas, (3) wellhead inventory/test well
construction,. (4) wellhead protection management strategies, (5) contingency and spill
response plans, and (6) final wellhead protection plan document. The project management
' ' '•' • " ' - 19-" - • .- . ' - . '•••• '
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Benefit/Cost Analysis of Preventing Contamination: City of Tumwater, Washing!
Exhibit 7
Cost of Wellhead Protection: Tumwater, WA
February 1993 to September 1995
($1994)
Item
City of
Tumwater
Centennial Clean
Water Fund
Project Management
Prepare monthly reports
Provide status briefings
SUBTOTAL:
Establish Wellhead Protection Areas
Review existing aquifer characterization data
Review WSDOE databases on potential contaminant sources
Develop a preliminary threat ranking
Prepare work plan for field work
Model preliminary wellhead protection areas
Establish final wellhead protection areas
SUBTOTAL:
Wellhead Inventory/Test Well Construction
Inventory contamination sources
Identify private wells for water quality monitoring
Develop.data system
Construct monitoring wens
Sample ground water
Incorporate sampling data into data system
SUBTOTAL:
Wellhead Protection Management Strategies
Develop plan for public involvement
Establish local wellhead protection committee
Compile information on management strategies used by other PWSs
Develop a pollution prevention plan
SUBTOTAL:
Contingency/Spill Response Plans
. Develop contingency/spill response plans
SUBTOTAL:
Final Wellhead Protection Plan Document
Develop plan document
Transmit to WSDOE
SUBTOTAL:
$26,331
$26,440
$56,693
$20.493
$21.978
$21,978
$26,331
$26,440
$56.693
$20,493
$21.978
$21,978
$52.662
$52,880
$113,386
$40.986
$43.956
$43.956
$173.913
•$J73j»t3:;;;
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- • Benefit/Cost Analysis of Preventing Contamination: City of Turmvater, Washington
task, budgeted at $52,662, includes activities such as monthly reporting and preparing status
briefings for the Tumwater City Council. The remaining tasks are described below: -
• Task #2 includes activities such as reviewing existing aquifer characterization
data, reviewing WSDOE databases on potential contaminant sources,
developing a preliminary threat ranking, developing a work plan for'field work;
modeling preliminary-wellhead protection areas, and establishing final wellhead
protection areas. The budget calls for a total expenditure of $52,880.
• Task #3 consists of comprehensive inventories of contamination sources and
private wells that could be used for water quality monitoring, development of a
data system, construction of monitoring wells, ground water sampling, and
incorporation of sampling data into the data system. According to the work
plan, the cost of these activities is $113,385.
Task #4 calls for developing a plan to involve the public, establishing a .local
wellhead protection committee, compiling information on management
strategies used by other PWSs, and developing a pollution prevention plan.
The work plan projects a total cost of $40,985.
Task #5 calls for developing contingency and spill response plans; the total
cost is estimated to be $17,645.
• Task #6 includes production of the final wellhead protection plan document
and transmitting it to WSDOE and WSDOH.. The work plan calls for a total
expenditure of $23,165. .
Implementation costs are difficult to determine, since the management plan has not
been developed. Other cities in Thurston County have demonstrated a willingness to spend
significant funds to implement their WHPPs. For example, the City of Lacey's draft WHPP
calls for an annual expenditure of about $ 110,000. Thurston County officials expect that
Turhwater's plan will be similar to Lacey's, Given that TWS is about half the size of the
'Lacey PWS, an annual expenditure of about $55,000 is probably realistic.
Because the Tumwater wellhead protection effort is just getting underway, it does not
appear to have imposed any indirect costs on Tumwater residents. In contrast, Tumwater's
aquifer protection ordinances have probably increased costs for proposed construction projects
in the aquifer protection district. Since the ordinances largely restate other federal and state
regulatory requirements, the costs are not attributable to wellhead protection.
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Benefit/Cost Analysis of Preventing Contamination: City ofTumwater, Washing,
'tonl
8.0 CONCLUSIONS
As of September 1995 the cost of contamination at the Palermo wellfield is
approximately $797,541; expected costs through September 2005 are approximately $914 899
ihus, the total, cost of contamination is expected to exceed $1.7 million, or $570,000 per well.
The total cost to develop Tumwater's WHPP is approximately $347,826. Annual
implementation costs are difficult to determine, but they are likely to be in the $55 000 range
Assuming that implementation begins in 1997, the net present value of wellhead protection '
activities through 2005 is approximately $328,400. Thus, total wellhead protection costs are
approximately $676,226, or about $52,017 per well,
9.0 REFERENCES
. Callison, Kathleen. Water Resources Specialist, City of Tumwater. Personal Interview
February 23, 1995.
City of Tumwater. FY1994 Budget, (undated).
City of Tumwater. Centennial Clean Water Fund Grantfcoan Application. February 16,
" • •/•'•• _
City of Tumwater. Water Service Regulations. Chapter 13.04. August 1992. '
N^vemSr ^Engineering Services> ^c- City ofLacey Wellhead Protection Plan (Draft).
Hedges, Jane. Manager, Resources Protection Program, Thurston County Public Health and
Social Services Department. Personal Interview, February 22, 1995.
Jennings, David. Director, Wellhead Protection Program, Washington State Department of
Health. Personal Interview, February 22, 1995.
1990 Session Laws of the State of Washington. Growth Management Act.
1991 Session Laws of the State of Washington. Growth Management Act.
Pacific Groundwater Group. Summary Report: Tricholoroethene Contamination at the
Palermo Well Field, City ofTumwater. September 1993.
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' Benefit/Cost Analysis of Preventing Contamination: City of Tumwater, Washington
Pacific Groundwater Group and Economic and Engineering Services, Inc. Preliminary
Characterization and Proposed. Work Plan: Tumwater Wellhead Protection Program
January 1995. '
Post, Rusty. Washington Department of Ecology. Telephone Interview.
RH2 Engineering, City of Tumwater Comprehensive Water System Plan. September 1992.
Rolluda, Monica. Site Assessment Manager, Hazardous Waste Division, U.S. EPA Region
10. Personal Interview, February 24, 1995.
Roy F. Weston, Inc. Field Operations Work Plan; Soil Gas, Groundwater, and Soil
Sampling; Palermo Well Field Test; Tumwater, Washington, October 1994.
Roy F. Weston, Inc. Trip Report; Soil Gas, Groundwater, and Soil Sampling; Palermo Well
Field ESI. February 2, 1995.
Thurston County Health Department. Northern Thurston County Ground Water Management
Plan. September 1992.
Washington State Department of Ecology. Permit Handbook: Commonly Required
Environmental Permits for Washington State. November 1994.
Washington State Department of Health. Division of Drinking Water. Pesticide Monitoring
Waivers for Public Water Systems. December 1994.
Washington State Department of Health. Division of Drinking Water. Susceptibility
Assessment Survey Packet. April 1994.
Washington State Department of Health. Division of Drinking Water. Group A Public Water
Systems (Chapter 246-290 WAC).
Washington State Department of Health. Wellhead Protection Program. Washington State
Wellhead Protection Program. December 1993. .
Washington State Department of Health. Wellhead Protection Program. Inventory of
Potential Contaminant Sources in Washington's Wellhead Protection Areas. December 1993.
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Contract No. 68-C4-0011
Work Assignment No. 1-14
Benefit/Cost Analysis of Preventing Contamination;
City of Middletown, Ohio
September 30, 1995
Submitted to:
U.S. Environmental Protection Agency
Ground Water Protection E?ivision
Technical and Information Management Branch
-------
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TABLE OF CONTENTS
1.0 COMMUNITY DESCRIPTION i
1.1 Land Use 7. ... ..... ... /" J
1.2 Geology/Topography 1
1.3 Hydrology . .". .............. 2
1.4 Climate . . ........ 2
2.0 PWS CHARACTERISTICS ."; ......... 2
2.1 Water Supply ; .' 3
2.2 Financial/Management Characteristics ........ 4
2.3 Population Served 5
''.... . f ~ ' x •
3.0 CONTAMINATION ....... ... .. . . . . ............... 5
3.1 Contamination Source 5
3.2 Contaminants . ...... ... ........... 7
3.3 Effects of.Contamination ................ 7
4.0 RESPONSE ACTIVITIES ............ 7
4.1 Response to Contamination of the Water Supply 7
4.2 Response to Aquifer Contamination 8
5.0 COST OF CONTAMINATION ........... , k ...... g
5.1 Tangible Costs .. . . g
5.1.1 Costs to Provide Safe Drinking Water ... 11
' 5.1.2 Costs to Remediate the Aquifer . 12
5.2 Intangible Costs . . 12
6.0 WELLHEAD PROTECTION .......... 12
6.1 State Requirements for Wellhead Protection 12
6.2 Local Wellhead Protection Plan :................. 13
6.2.1 Wellhead Protection Area Delineation ... .'v 14
6.2.2 Source Identification ................ 14
6.2.3 Ground Water Monitoring .. . '. 15
6.2.4 Management Plan . 15
6.2.5 Contingency Plan 17
-------
7.0
8.0
9.0
COST OF WELLHEAD PROTECTION
7.1 Tangible Costs ...........
7.2 Intangible Costs
CONCLUSIONS
REFERENCES .
18
18
21 f
21
21
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LIST OF EXHIBITS
Exhibit 1
Exhibit 2
Exhibit 3
Exhibit 4
Exhibit 5
Exhibit 6
Exhibit 7
Water Source Characteristics
Contaminant Concentrations
Site Map
Cost to Date of Responding to Contamination
Future Cost of Responding to Contamination
Cost to Date of Wellhead Protection
Future Cost of Wellhead Protection
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BENEFIT/COST ANALYSIS OF PREVENTING CONTAMINATION
MIDDLETOWN, BUTLER AND WARREN COUNTIES, OIHO
/ • , . • •. ,
w'i .1Ill1985theCityofMiddletown'Ohio began monitoring its production wells for
Volatile Organic Compounds (VOCs), as required by the Ohio Environmental Protection
Agency (OEPA). In the initial round of sampling, VOCs were detected in four of the city's
16 wells. Since 1985, tetracholorethylene (PCE) has been detected continuously in three
we Us, and mtermittently in two others. The City shutdown one well in 1985, and two more
wells in 1988. Investigations by the City and OEPA traced the contamination to AEP Flexo
inc., which manufactured flexographic printing plates between 1984 and 1990 in an industrial
park near the wellfield. OEPA entered into a consent decree with AEP Flexo in July 1993
Pursuant to the decree, AEP Flexo is investigating the extent of the contamination and
undertaking interim measures to halt the spread of contaminants.
Middletown began developing a wellhead protection program (WHPP) .in 1991 as a
result of the contamination incident and an OEPA requirement that water suppliers in
vulnerable areas undertake wellhead protection (WHP) in order to gain approval for water
system improvements. To date, the city has delineated its wellhead protection area (WHPA)
developed a management plan and a public education campaign, conducted source
identification, and prepared draft contingency and groundwater monitoring plans. The public
education effort was funded in part by a $12,000 U.S. EPA demonstration grant/ The City is
in the process of establishing a WHP fee and plans to adopt an overlay zoning ordinance in
1.0 COMMUNITY DESCRIPTION
The City of Middletown is located in southwestern Ohio, about half way between
Cincinnati and Dayton. The PWS is operated by the City of Middletown Department of
Public Works (MDPW). Middletown has a population of approximately 50,000.
1.1 Land Use
Middletown contains a wide variety of land uses, including residential, light industrial
commercial, and heavy industrial. Several large industrial sites, including a steel mill and a '
paper manufacturer, operate in the vicinity of the wellfield.
13 Geology/Topography
Geology in southwestern Ohio is the result of glacial activity. At least two major
episodes of glacial advance and retreat, and drainage from glacial rivers have deposited tills
within the region. Valley fill sediments consist of sand and gravel glacial outwash. Lenses
of ice-deposited clay tills also exist within the sediments underlying the region. Typical
' ' • • -I.-'-' • • '..''..
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Benefit/Cost Analysis of Preventing Contamination: City of Middletown, Ohio
stratigraphy in Butler County consists of 25 to 50 feet of sand/gravel alluvium, underlain by
10 to 40 feet of clay, clay-till, or till. Beneath the till layer is up to 125 feet of outwash
deposits (sand and gravel), which overlie the Ordovician-age shales and limestone bedrock.
The City of Middletown is located on the floodplain of the Great Miami River.
1.3 Hydrology
Ground water resources in the region are dominated by the Great Miami Buried Valley
Aquifer (MBVA) System. This highly productive aquifer system consists of sand and gravel
interbedded with low-permeability tills, which effectively divide the aquifer into lower and
upper producing zones.
At the wellfield, ground water in the shallow aquifer zone flows from north-northwest
to south-southeast, roughly following the bedrock valley walls. In the deeper zone,
groundwater movement is toward the south-southwest (this may be due to pumping from
production wells at .the Sorg Paper Company nearby). The upper aquifer is unconfined; the
lower zone is semi-confined, due to the presence of the leaky confining till layer. Water
levels in the aquifer system mimic the surface elevation. Precipitation recharge to the aquifer
system rn undeveloped areas is about 12 inches per year.
1.4 Climate
The average January temperature in southwestern Ohio is 27 degrees; average July
temperature is 74 degrees. Average monthly precipitation ranges from a low of 1.9 inches (in
October) to a high of 4.0 inches during the summer months,
2.0 PWS CHARACTERISTICS
The Middletown PWS serves the entire city of Middletown and parts of adjoining
Madison, J^emon, Franklin, and Turtle Creek Townships. Treatment consists of lime softening
(to reduce hardness), filtration, and chlorine disinfection. The PWS maintains about 318
miles of mains, ranging from 4 inches to 30 inches in diameter; a reservoir; and three
elevated storage tanks. The wellfield, located along Carmody Boulevard between the
municipal airport and the Great Miami River, has 13 operating wells.
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Benefit/Cost Analysis of Preventing Contamination: City of Middletown, Ohio
2.1 Water Supply
Between 1992 and 1994, the PWS delivered an average of 10.6 million gallons per
day (MOD) to its customers. Flow ranges from about 7.0 MOD in the winter to about 140
MOD during the summer months. Twenty-seven monitoring wells allow the city to monitor
the quality of water entering the well field, including 14 at the periphery and 13 downgradient
.from the Middletown City Landfill. . . .-
Two industrial users operate wells downgradient from the wellfield. Sorg Paper
Company operates four production wells about 1,000 feet to the south of the wellfield, and
Armcp Steel Company operates five production wells 1.5 miles south of the wellfield. '
Middletown's 13 operating wells tap the MBVA, designated by U.S. EPA as a sole
source aquifer system. In the vicinity of the wellfield, the till layer is 25 to 35 feet thick,
dividing, the aquifer into lower and upper producing zones. The 13 wells tap either the '
shallow or the deep zone, and have a combined rated capacity of 21,614 MOD. Water
quality is generally good; however, the water is naturally hard and contains concentrations of
iron and manganese. Substantial evidence indicates'that wells CW-6,,CW-7, CW-12, CW-14,
and CW-16 recharge from the Great Miami River. Exhibit 1 summarizes Middletown's water
source characteristics.
MDPW has identified a potential site for an additional well near the airport and has
submitted pump test data to OEPA for approval. The City hopes that the well will be on-line
by the end of 1995. The PWS's Master Plan calls for three additional wells by the vear
2000. .
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Benefit/Cost Analysis of Preventing Contamination: City of Middletown, Ohio
EXHIBIT 1 . • ' "
Water Source Characteristics
Well Capacity
(gal/day)
2.2 Financial/Management Characteristics
MDPW maintains a separate enterprise fund for its water utility. The PWS's FY 1994
operating budget was approximately $3.1 million. In that year, the City undertook $09
million in capital improvements and retired $3.0 million in debt. Revenue included
approximately $5.2 in customer payments and $3.0 million from bond sales, the fund had a
cash balance of $3.2 million at the end of the year.
• 10i uniform water rate structure. The PWS raised water rates 5 percent
in 1992, 1993, and 1994, and projects that another rate increase will be required in 1997
Water rates are relatively low compared to other southwest Ohio communities. Residential
customers pay an average of $46.10 per quarter, compared to the regional average of $61 79
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; Benefit/Cost Analysis of Preventing Contamination: City of Middletown, Ohio
2.3 Population Served
The PWS serves a population of approximately 60,000 persons in Middletown and
parts of adjoining Madison Township. The PWS has approximately 20,400 service
connections, of which 18,600 are residential, 1,700 are commercial, and 100 are industrial.
3.0 CONTAMINATION
In 1985 Middletown discovered chlorinated VQCs in four of its' wells (CW-1, CW-2,
CW-3A, and CW-4/5) during initial routine monitoring. Between 1985 and 1990,
tetrachlorqethene (PCE) has been detected consistently in three wells (CW-1, CW-2, and CW-
4/5) and occasionally in two other wells (CW-14, CW^18). Exhibit 2 summarizes '
contaminant concentrations for the period. .
EXHIBIT 2
Contaminant Concentrations
Constituent
CW-1
PCE
TCE
C-1.2-DCE
CW-2
PCE
CW-4/5
PCE
TCE
1,1,1-TCA
Concentration (ug/I)
2/27/85
11/26/85
9/4/87
8/29/89
2/9/90
4.6
<1.0
662.0
9.97
33.6 i
3.4
103.0
102.0
30.4
5.3
1.0
314.0
192.6
67.7
'
104.0
64.6
3.1 Contamination Source
MDPW retained CH2M Hill, fiic. to characterize the contaminant plume. Sampling
results identified three possible sources of contamination on Hook Drive: a business in the
Hook Drive Industrial Park, the storm sewer, or the sanitary sewer. The storm sewer drains
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Benefit/Cost Analysis of Preventing Contamination; City of Middletown, Ohio
™ "iea Jf* dischar£es into a Iime P°nd in the vicinity of the wellfield. The
MDPW discharges effluent from is water softening operation to the lime pond, which is
hydrologically connected.to the upper aquifer.
CH2M Hill recommended that the city conduct a soil gas survey and install additional
monitoring wells to further narrow the source of contamination. OEPA subsequently
conducted a soil gas survey, and MDPW installed three additional monitoring wells OEPA
identified AEP Elexo, Inc., a manufacturer of flexographic printing plates located in the
Industrial Park, as the source. Interviews with AEP Flexo employees revealed that numerous
spills had occurred from a distillation unit onsite, and that the liquids were squegeed out a
plant door. Exhibit 3 is a map of the wellfield area.
EXHIBITS
Site Map
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-Benefit/Cost Analysis of Preventing Contamination: City of Middletown, Ohio
3.2 Contaminants
CH2M Hill collected ground water samples in late 1990. PCE concentrations in the
shallow aquifer ranged from 1.3 ug/1 to 96.2, ug/1. In the deep aquifer, PCE was found only
in the vicinity of CW-2. Two shallow borehole samples contained toluene at concentrations
of 2 ug/1 and 3.4 ug/1, but it was not detected in monitoring wells. PCE concentrations were
higher in the northern part of the sampling area and decreased toward the south.
CH2M Hill suggested that the contamination in the deep aquifer could be related to a
problem with the well casing in CW-2, and recommended further investigation. MDPW later
determined that the well*s casing was corroded.
3.3 Effects of Contamination
No evidence of health or ecological effects from the contamination exists. EPA has
classified PCE as a probable human carcinogen. Fortunately, MDPW discovered the
contamination before it entered the distribution system in concentrations above national
drinking water standards.
4.0 RESPONSE ACTIVITIES
Middletown and AEP Flexo (under OEPA supervision) are conducting separate
response activities. Under its consent decree, AEP Hexo is characterizing the contamination
at the site, and has proposed several interim measures to halt the spread of contamination
offsite. Middletown shut down three contaminated wells and has begun siting new wells.
4.1 Response to Contamination of the Water Supply
Upon discovering the contamination, the City shut down Well CW-4/5 in 1985, and
Wells CW-1 and CW-2 in February 1988.. MDPW disconnected both wells from the '
distribution system in March 1990. An investigation determined that CW-2 lacked
mechanical integrity and had allowed contamination to flow from the upper to the lower
aquifer, so MDPW abandoned it; The other two wells have not been abandoned to date. '
- MDPW is in the process of siting two hew production wells, scheduled to come online
before the end of 1997. In the meantime, MDPW has been operating its remaining 13 wells
more frequently to compensate for the loss of the three wells. Some evidence exists that
increased pumping is beginning to draw the contamination toward the other wells. MDPW is
considering at least two options for reversing the plume's migration. One option is to
construct one or two air strippers in the wellfield. A second option is to pump contaminated
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Benefit/Cost Analysis of Preventing Contamination: dry of Middletown, Ohi
The vnr« w M u Sorl>, P/Per Company, where it wotuUbe used to cool equipment.
The VOCs would be removed from the water during the cooling process.
4.2 Response to Aquifer Contamination
As discussed above, MDPW retained the services of CH2M Hill to assess potential
sources of the VOC plume in 1990. In its investigation, CH2M Hill surveyed potential
sources of contamination along Hook Drive, installed monitoring wells, reviewed aerial
photographs of the area surrounding the wellfield, met with city personnel to discuss past .
activities that have occurred near the wellfield, and reviewed .Ohio Department of Natural
Resources records to identify other wells in the vicinity of the wellfield.
AT7t> T7i°EPA'S S0il gaS investisation determined that the source of the contamination was
AEP Hexo, Inc. OEPA entered into a consent decree with AEP Hexo in July 1993 Under
the decree, AEP Hexo is conducting a Focused Site Characterization (FSC) to characterize the
sources of contamination at the site, determine site physical characteristics, develop cleanup
goals, and obtain all other data necessary to design and implement source control interim
actions (SCIAs).
In June 1995, AEP Hexo submitted a draft report to OEPA. The report recommended
soil vapor extraction (SVE) in combination with air sparging as the most appropriate
techno ogies to remediate soil at the site. VOCs would be removed from air emissions from
the soil treatments with carbon absorption units. The proposed SCIAs are currently beine
reviewed by OEPA. Cleanup of the aquifer itself does not appear to be under consideration
at present Because enforcement activities are continuing, the Cadmus project team was
denied access to OEPA files in order to collect more information on the nature of the SCIAs
under consideration.
5.0 COSTS OF CONTAMINATION
5.1 Tangible Costs
Middletown and AEP Hexo have incurred contamination-related costs The City's
costs include the costs of investigating the source of contamination, closing the contaminated
wells, and modifying other wells to allow increased pumping. AEP Hexo's costs include the
costs to investigate contamination, install and maintain SCIAs, and reimburse OEPA for its
oversight costs. Exhibit 4 summarizes the costs of responding to contamination through
September 1995, and Exhibit 5 presents expected future costs through September 2005
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Benefit/Cost Analysis of Preventing Contamination: City of Middletown, Ohio
'.
Cost of Responding to
Exhibits
Contamination: Middletown, OH
"""
December 1990 to September 1995
Item
One-time costs
Reid Investigation of contamination
Well abandonment
Monitoring wellinstallation
Upgrade other wells
Increased monitoring
Litigation
. -.
TOTAL:
Pre-remediation
Reid investigation '
TOTAL:
1 i WIAM. v^uoi: ,,
($1994)
City of AEPFJexo.
Middletown Inc.
342.000
51,000 •
114.000
204,000
16.128
5,100
$732.228 $o
— ~ • —1
0 45.861
$0 $45.861
; $732:228 $45,861 -
Total
' i i ir i i
$342.000
$51.000
$114.000
$204,000
$16,128
$5,100
$732,228
I ,
$45,861
$45.861
$778389!
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Benefit/Cost Analysis of Preventing Contamination: City of Middletown, Ohio]
Exhibits
Future Cost of Responding to Contamination: Middletown, OH
October 1995 to September 2005
($1994)
Item
City of
Middletown
IggfrjagjiSife Drinkfna Water
One-time costs
Well abandonment
• Construction of two new wells
SUBTOTAL:
Potential costs(1)
Construction of air strippers
Electricity
Maintenance
SUBTOTAL:
70,093
122.159
$192.253
280,374
210.707
14.047
$505.128
Nates:
(1) If Middletown chooses air stripper option.
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Benefit/Cost Analysisof Preventing Contamination: City ofMiddletown, Ohio
5.1.1 Costs to Provide Safe Drinking Water
The total cost of the city's response activities through September 1995 is
approximately $655,000 ($732,228 in 1994 dollars). These costs include:
$300,000 ($342,000 in 1994 dollars) forme field investigation of the
contamination; - .
$50,000 ($51,000 in 1994 dollars) fcw plugging well CW-2;
y $100,000 ($114,000 in 1994 dollars) for installation of monitoring wells;
• $200,000 ($204,000 in 1994 dollars) for contamination-related improvements to
the remaining wells;
• $21,600 ($16,128 in 1994 dollars) for additional VOC monitoring1; and
• $5,000 ($5,100 in 1994 dollars) for litigation. •
Between October 1995 and September 2005, MDPW expects to abandon wells CW-1 ''
^™!~4/5™d construct ^o new production wells. If the contamination had not occurred,
MDPW probably would not have to construct new wells until the year 2000. The net present
value of these expected activities is $192,253, assuming a discount rate of 7 percent The
present value of the well abandonment is $70,093 and me net present value of incremental
cost of well construction is $122,159.2
Middletown is considering at least two options to halt the spread of contamination
toward its other wells. The net present value of the air stripper option is approximately
$505,128. The largest component of the total, construction of the air strippers, is $280 374
Operating costs for the air stripper would consist primarily of electricity and periodic '
.replacement of the media. The net present value of these items is $210,707 and $14 047
respectively. . ' '
JMDPW sampled its 13 operating wells for VOCs each quarter, rather than the one
sample required by regulations.
2Defmed as the difference between the present worth of the wells in 1996 and the present
worth of the wells in 2000.
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Benefit/Cost Analysis of Preventing Contamination: City of Middletown, Okie
5.1.2 Costs to Remediate the Aquifer
' ' \
Many of the costs associated with the investigation of the contamination at the AEP
Flexo site cannot be determined. AEP Flexo is conducting a Focused Site Characterization
according to the terms of its consent decree with OEPA. The firm would not provide
Cadmus with information on the cost of these activities. As noted above, the City's
investigation of the contamination cost $300,000 ($342,000 in 1994 dollars). It is reasonable
to assume that AEP Flexo is spending a similar amount in its investigation. OEPA's
oversight costs over the last three years total $44,821 ($45,861 in 1994 dollars). Under the
terms of the consent decree, AEP Flexo is reimbursing the agency for its oversight costs.
5.2 Intangible Costs
In addition to forcing the closure of three public wells, the contamination has raised
fears among business owners in the Hook Drive Industrial Park. For example, a business
owner expressed concern that he would not be able to sell his building because the
contaminant plume extended under his property.
6.0 WELLHEAD PROTECTION
Ohio EPA's Division of Drinking and Ground Waters is the lead agency for
implementing wellhead protection in Ohio. Ohio EPA provides technical guidance and
assistance to PWSs and is also responsible for reviewing local WHP plans. EPA approved
Ohio's Wellhead Protection Program in May 1992.
Wellhead protection is voluntary in Ohio; however, OEPA is requiring WHP as a
condition for approval of water system improvements. To promote interest among
communities, the state offers incentives such as waivers from monitoring requirements to
communities that adopt WHP. If communities demonstrate that there are no hazardous
chemicals in use within a certain radius of the wellhead areas (the radius depends on the
well's pumping capacity), Ohio EPA may issue monitoring waivers.
6.1 State Requirements for Wellhead Protection
Ohio's Ground Water Protection and Management Strategy is comprised of seven
activities to protect ground water resources.
• WHPA delineation. Ohio recommends that communities delineate a five-year
time of travel zone around each well or wellfield, in addition to a one-year
time of travel inner management zone. Ohio's plan recognizes the variety of
geologic settings and available technical and financial resources among
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Benefit/Cost Analysis of Preventing Contamination: City of Middletown. Ohio
communities, and allows a flexible approach to WHPA delineation methods.
Depending on local geology, delineation methods ranging in complexity from a
simple calculated fixed radius to computer models may be used.
• Pollution source inventory. Water purveyors must report an inventory ofall
potential contamination sources as part of their local WHP plans. Ohio EPA
has developed standards and formats for reporting pollutant source data
• Management strategy. Ohio EPA considers establishing-and maintaining a
comprehensive coordinated ground water management plan the most important
element of an effective local WHP plan. Communities' management plans
differ depending on the type of system and the population served. Ohio is
developing a generic "check list" or "fill-in-the-blank" model management plan
which could assist smaller systems in developing an appropriate WHP plan.
• Ground water monitoring. All systems must prepare a monitoring plan that
. assesses, the need for ground water monitoring and, if needed, would provide
early warning of ground water contamination. If purveyors can demonstrate
that no major pollution sources may potentially contaminate groundwater, they
may request a monitoring waiver. .
• Contingency planning. Communities must provide evidence they are prepared
for emergencies and can provide alternative sources of water. Ohio's WHPP
expands upon the requirements of Ohio regulations for PWSs to develop and
maintain contingency plans.
Public involvement/education program. Communities must inform people
who live and work near wellhead areas of the WHP plan and provide them
opportunities for involvement in the WHP planning process
• Protection of new wellfields. Ohio's wellhead protection program directs
communities to protect proposed wells and wellfields. If new wells are needed,
communities must take steps to secure and protect new sites from potential
contamination. Li the future, Ohio EPA may request that water purveyors
submit an estimated WHPA and source inventory as part of new water source
. applications. .
6.2 Local Wellhead Protection Plan
Middletown began its WHPP in 1991 in response to the contamination^incident. i
OEPA made completion of Middletown's WHPP a condition for approval of $3.6 million in
water system capital improvements in 1993. A key element of the effort was the creation in
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Benefit/Cost Analysis of Preventing Contamination: City of Middletown, Ohio\
June 1992 of a wellfield protection committee (WFPC) composed of representatives from the
City of Middletown, and Butler and Warren Counties. The WFPC developed a public
education campaign and a wellfield protection plan.
6.2.1 Wellhead Protection Area Delineation
CH2M Hill collected hydrogeological data for the area around the wellfield, developed
a numerical model, and delineated one- and five-year time of travel zones using the
MODFLOW code. The one-year time-of-travel zone is known as the Inner Management
Zone (IMZ), and the five-year zone is known as the Wellfield Protection Area (WFPA). The
WFPA extends into adjacent Madison Township.
6.2.2 Source Identification
City staff and CH2M Hill conducted a contaminant source inventory in late 1990 and
early 1991. CH2M Hill consulted several databases of potential contaminant sources: a list of
hazardous waste sites maintained by OEPA; the State Fire Marshal's list of USTs; the State
Emergency Response Commission's SARA Title m Right-to-Know notifications; and aerial
photographs of the city. City staff supplemented the database search with a windshield
survey of major roads in the estimated capture area.
The source identification effort located approximately 80 actual and potential sources
within the WFPA. These included several major industrial sites, such as Sorg Paper
Company, Aeronca Aerospace, a former Diamond International Plant, Hook Drive Industrial
Park, several aggregate mines, and the Middletown City Landfill. Commercial sites included
several service stations, auto repair facilities, and dry cleaners; the City's vehicle maintenance
area, and the municipal airport. Several major transportation routes cross the WHPA,
including State Highways 4, 73, and 122; Carmody Boulevard; a CSX railroad line; the Great
Miami River; and the Middletown Hydraulic Canal. .
CH2M Hill staff divided the source list into high and moderate priority categories,
based on the level of threat posed by the source. High priority sites consisted of confirmed
sources of contamination and potential sources with liquid chemical storage exceeding 500
gallons. Three confirmed sources of contamination lie within the one- and five-year thne-of-
travel zones: .
• Middletown city landfill. Shallow groundwater in the shallow aquifer has been
found to contain elevated dissolved solids, high alkalinity, heavy metals, and
1,1-dichloroethane (1,1-DCA). The landfill lies within the five-year time of
travel zone.
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Benefit/Cost Analysis of Preventing Contamination: City of Middletown, Ohio
Sorg Paper Company, The paper company previously operated four USTs
containing a variety of solvents, including methyl ethyl ketone, toluene, naptha
and lactol spirits. A groundwater sample collection from a monitoring well in '
the vicinity of the tanks had a toluene concentration of 0.13 mg/L Part of the
facility lies within the one-year time-of-travel zone.
* AEP Mexo, Inc. The Flexo site falls within the one-year time-of-travel zone.
The WFPA contains a total of 23 high priority sites and 61 medium priority sites. CH2M
Hill noted that the Great Miami River is a potential source of contamination. Because the
river is hydrologically connected to the shallow aquifer, any spill or discharge upstream from
the wellfield has the potential to contaminate it,
As part of keeping the source inventory updated, Middletown is considering a proposal
to forward copies of new building permits and chemical inventory information maintained by
the fire department to the MDPW for sites located within the WHP A.
/ • , . . - k j .
6.23 Ground Water Monitoring
CH2M Hill identified seven high priority areas for ground water monitoring. These
sites have a high potential for contaminating the wellfield because of their close proximity or
the types of chemicals used or stored on the site. They include the Hook Drive Industrial
Park, the municipal airport, the city landfill, and Sorg Paper Company. CH2M Hill
recommended constructing seven additional monitoring wells at five locations immediately
downgradient from the priority source areas. Existing monitoring wells appeared sufficient to
monitor water quality in the vicinity of the municipal landfill and Sorg Paper Company.
6.2.4 Management Plan
In December 1993 the WFPC completed a draft management plan which consists of
the following components:
• Zoning overlays. Different zoning overlays would be created in the IMZ and
in the WFPA. Within the IMZ, the City would adopt the "Intensity of Land
Use Classification" approach developed by the City of Dayton. Each parcel of
land would be assigned a rating on a scale from 1 to 9, based upon the
maximum quantities and types of chemicals used or stored on the site. Data
acquired through inventory forms submitted by the site and annual inspections
would be used to determine the rating. No increase in the hazard ranking
would be permitted. Any land owner wishing to undertake activities which
would result in an increase in the site's ranking would be required to install
additional engineering controls and adopt risk management measures so that the
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Benefit/Cost Analysis of Preventing Contamination: City of Middletown, Ohio\
/ ' •
site remained at the original ranking. Within the WFPA, owners would be
• required to submit inventories of SARA Title IH chemicals stored or used
onsite. In addition, downgradient monitoring may be required. The City
would establish a Risk Management Reserve Fund to provide grants or low-
interest loans to individual businesses to improve or upgrade facilities as
necessary to meet WHP requirements. '
Annual inspections. All sources within both overlays would be inspected
annually by the health and/or fire department. The purpose of the inspections
would be to complete annual chemical inventory forms, to note engineering
controls and risk management practices in use at the facility, and to monitor
compliance with WFP ordinances.
Transportation. Trucks over 5 tons gross weight would be restricted from
using Carmody Boulevard, which runs along the wellfield. In addition, the
speed of trains running through the WFPA on the CSX line would be limited.
Any railroad cars sitting on spurs for more than 72 hours would be considered
"in storage" and fall under the storage facility requirements of the WFPP.
» t
Building permit review. An interjurisdictional permit review committee would
be established to review all building permits in the WFPA. The committee
would consist of members from Middletown, Madison Township, and Franklin
Township. The review would consider the types of activities to be conducted
on the site, the types and quantities of chemicals to be used or stored, and the
safeguards the owner proposed to implement. The committee would deny
permits where the proposed activity would increase the site's hazard ranking.
An increase of more than 5 percent or 25 gallons in chemical storage or use
would constitute a permit modification and automatically trigger a permit
review. The management plan recommends that additional requirements be
developed for septic systems within the IMZ.
Underground storage tank reporting/upgrading. Operators of USTs must
adhere to federal and state UST regulations. The State Fire Marshall is
developing additional requirements for USTs located in WFPAs. The proposed
management plan calls for additional coordination and sharing of information
with the Fire Marshall's office.
Surface water drainage. The management plan recommends that dry wells be
closed wherever storm sewers are available. NPDES permit holders will be
requested to notify the WFPC whenever permit modifications, spills, or
accidental releases occur. The plan recommends that owners of surface
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. [_ Benefit/Cost Analysis of Preventing Contamination: City of Middletown, Ohio
impoundments located within the WFPA be required to close them or monitor
water quality downgradient from them.
• Storage facility requirements. Above-ground storage facilities would be
required to install containment systems (e.g., concrete-liners, berms) within
three years of adoption of the WHP-ordinances.
• Wettfield protection area signs. Signs would be installed along roads and
railroads crossing the WFPA.
• Public education. Middletown received a demonstration grant from the U.S.
EPA to develop a public education program. In March 1993, the MDPW sent
flyers to its customers. The WFPC held two public meetings and developed
adult and elementary school educational materials,
• Regional cooperation. The plan calls for continued cooperation and
coordination with other local jurisdictions, including Madison Township, Butler
County, and Warren County.
• Household hazardous waste disposal program. The City would conduct semi-
annual hazardous waste collection days for residents. The WFPC will attempt
to identify corporate sponsors who could underwrite part of the cost.
The proposed management plan has been given preliminary approval by the Middietown City
Council, although the final ordinances still must be approved. !
6.2.5 Contingency Plan .
either:
CH2M Hill developed a framework for a contingency plan that would be activated if
• Substantial changes in groundwater quality are detected in routine monitoring;
or • . ..;••.'•• . ; • ''.-•• :
• An emergency that could adversely affect ground water quality occurs within
the WFPA.
The first part of the plan would be triggered if MDPW detects contaminant concentrations
above preventative action limits (PALs) in either monitoring wells or production wells. The
PAL is defined as a percentage of the MCL for the constituent (10 percent of the MCL for
VOCs and 50 percent of the MCL for inorganics).
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Benefit/Cost Analysis of Preventing Contamination: City of Middletown, Okie
The framework calls for Middletown to establish an emergency response team
consisting of members from the police and fire departments and MDPW. CH2M Hill
recommended evaluating existing emergency response plans to determine their adaptability to
wellfield emergency response planning.
The City plans to establish an Emergency Response Fund to handle emergencies
which could threaten the wellfield. The Fund will,be capped at $500,000.
7.0 COST OF WELLHEAD PROTECTION
The MDPW has developed substantial data on the start-up and ongoing
implementation costs of its WFPP. Exhibit 6 summarizes the costs of wellhead protection
through September 1995, and Exhibit 7 summarizes expected future costs through September
2005. '
7.1 Tangible Costs
Through September 1995, the City of Middletown spent $95,000 ($98,720 in 1994
dollars) to develop its WFPP, including ,$12,000 ($12,240 from a U.S. EPA demonstration
grant). The delineation and source identification efforts cost approximately $40,000 ($45,600
in 1994 dollars). WFPC activities, including the management plan and the public education
campaign, cost $36,000 ($36,720 in 1994 dollars). The City has spent $10,000 ($11,400 in
1994 dollars) on monitoring wells constructed so far. Miscellaneous WFP activities,
including teacher in-service meetings and presentations, have cost another $5,000 (in 1994
dollars).
Between October 1995 and September 2005, the City plans to install additional
monitoring wells, develop a monitoring database, and conduct sampling and laboratory
analysis. The City also plans to make transfers into its Emergency Response and Risk
Management Funds during the period. The net present value of these activities is
approximately $1.28 million. Implementation activities, such as monitoring and laboratory
analysis, account for $468,144 of the total. The reserve funds account for at least $810,000;
the exact amount will depend on the level of payouts from them.
The WFPP will be financed through a $0.50 monthly service connection charge ($0.25
for senior citizens). Industrial users will pay a 5 percent usage surcharge. The fee is
expected to raise approximately $240,000 per year, which .will be used for operating expenses
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Benefit/Cost Analysis of Preventing Contamination: City of Middletown, Ohio
.Exhibits
Cost of Wellhead Protection: Middletown, OH
February 1985 to September 1995
($1994)
WHPA delineation
Source identification
SUBTOTAL:,
Management plan development
Public education plan development
SUBTOTAL-
11,220
13,260
$45,600
Monitoring well installation
SUBTOTAL
Miscellaneous implementation activities
"SUBTOTAL-
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Benefit/Cost Analysis of Preventing Contamination: City of Middletown, Okie
Exhibit?
Future Cost of Wellhead Protection: Middletown. OH
October 1995 to September 2005
($1994)
Item
City of
Middletow
rcplemehtation
Monitoring/Laboratory Analysis
Emergency Response Fund*
Risk Management Fund*
$468.144
$405,624
$405.624
(1) Approximate; actual expenditures depend upon payouts from Fund.
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Benefit/Cost Analysis of Preventing Contamination: City of Middletown, Ohio
and the reserve funds. When the funds reach their caps, the fee will be reduced to cover
only operating expenses.
7,2 Intangible Costs
With the exception of the proposed requirement that storage areas have containment
structures, each of the elements in Middletown's management plan is a restatement of existing
federal or state regulatory programs, such as the federal UST program. The City estimates
that the number of businesses affected by the storage requirements is minimal, and could not
provide an estimate of the cost to comply. ' ;
MDPW expects that businesses in the WFPP will incur a modest cost to compile and
submit the annual SARA Title m chemical inventories.
8.0 CONCLUSIONS
Past and expected future costs (through September 2005) of responding to the
contamination incident likely will range from approximately $970,000 to $1.48 milliqn (in
1994 dollars), depending upon whether Middletown elects to construct the air strippers. This
does not include costs incurred by AEP Flexo, aside from reimbursement of OEPA oversight
costs. The total cost of the contamination incident probably is considerably higher than the
costs reported in this report. The perrwell cost ranges from $74,615 to $113,846.
Past and expected future costs (through September 2005) for wellhead protection will
total approximately $1.38 million. This includes transfers into the Emergency Response and
Risk Reduction funds. The per-well cost of these efforts is approximately $106,009.
The director of Middletown's WFPP believes that it would have prevented, or at least
mitigated, the contamination incident. He feels that the proposed storage requirements would
have prevented the release of contamination from the AEP Flexo site. If not, annual
^inspections or groundwater monitoring probably would have detected the contaminant release
at the AEP Flexo site before contaminants migrated into the wellfield.
9.0 REFERENCES
City of Middletown. City of Middletown Well Field Plume Study, (draft document) Prepared
byCH2MHill. 1990.
Duritsch, David J. Jr. Assistant City Engineer, City of Middletown, Division of Engineering.
Personal interview, June 29, 1995.
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Martin, Stephen H. Group Leader, Ohio Environmental Protection Agency Division of
Emergency & Remedial Response. Personal interview, June 28, 199?
Middletown Area Wellfield Protection Committee. Draft Report, 1993.
n, Drinking ^ Ground Waters- Guidance
Inventories In Wellhead Protection Areas, (draft
Ohio Environmental Protection Agency. Administrative Order on Consent - AEP Flexo Inc
issued: July 28, 1993; effective: July 28,1993. .•*«.*&*• riexo, inc.
f °teCti0n AgenCy' Divisi°n of E>m^gency and Remedial Response.
invoice for internal audit" April 13, 1995.
Saxe, Heather A. Hydrologist, CH2M Hill. Personal interview, June 29, 1995.
Ground' W^"' ?eOl°gif. Ohio Environmental Protection Agency, Division of Drinking and
Qjround Waters. Personal interview, June 29, 1995. 6
U.S. Environmental Protection Agency. Middletown Wellhead Protection Public Education
Program. Prepared by City of Middletown and CH2M Hill. 1994. ^ucanon
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Contract No. 68-C4-0011
Work Assignment No. 1-14
Benefit/Cost Analysis of Preventing Contamination:
Town of Norway, Maine
September 30, 1995
Submitted to:
U.S. Environmental Protection Agency.
Ground Water Protection Division
Technical and Information Management Branch
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TABLE OF CONTENTS
1.0 COMMUNITY DESCRIPTION 1
1.1 Land Use ;..... . i
1.2 Geology/Topography . . 4 . . . . . . . . . _ . i
1.3 Hydrology/Climate .......................;.... 3
2.0 ,PWS CHARACTERISTICS . . ..' . ... 5
2.1 Water Supply .......,......................,.....[. 5
2.2 Financial/Management Characteristics . 5
2.3 Population Served . . . .......... 5
3.0 CONTAMINATION . . .. .......... 6
3.1 Contamination Source . ,. 6
3.2 Contaminants . . . 7
3.3 Effects of Contamination 8
4.0 RESPONSE ACTIVITIES ... ., : . . . . ... . . 4 ..... g
4.1 Response to Contamination of the Water Supply ....... ; t . . . . . 8
4.2 Response to Ground Water Contamination ....................... 9
4.3 Response to Soil Contamination , . . 9
5.0 COSTS OF CONTAMINATION . . . . ... .... . 10
5.1 Tangible Costs . 10
5.1.1 Costs to Provide Safe Drinking Water . . . .". 10
5.1.2 Costs to Remediate Aquifer .....: .;.... 13
5.2 Intangible Costs ................ ... ...... ; . . . . 13
"•* ' ' - ' '. '
6.0 WELLHEAD PROTECTION ... . . 13
6.1 State Requirements for Wellhead Protection ..-..' ... ... ... 13
6.2 Local Wellhead Protection Plan . . ; . . ............... 15
6.2.1 Wellhead Protection Area Delineation ..... ... . . 15
6.2.2 Source Identification 16
6.2.3 Management Plan 16
6.2.4 Contingency Plan . ...................... . . 17
7.0 COSTS OF WELLHEAD PROTECTION ..... . . . . 17
7.1 Tangible Costs .;.... 17
- 7.2 Intangible Costs . . 20
8.0 CONCLUSION ....... . ...... . . 20
9.0 REFERENCES . . . . . . ....,;.,.. 20
-------
LIST OF EXHIBITS
Exhibit 1
Exhibit 2
Exhibit 3
Exhibit 4
Exhibit 5
Exhibit 6
Exhibit 7
Area map
Geologic Cross Section of the Area Near the Norway Well
Site Map of Contamination
Cost to Date of Contamination :
Future Cost of Contamination
Cost to Date of. Wellhead Protection
Future Cost of Wellhead Protection
-------
BENEFIT/COST ANALYSIS OF PREVENTING CONTAMINATION
NORWAY, OXFORD COUNTY, MAINE
When the town of Norway installed its sole drinking water well in 1965, the Norway
Water District (NWD) could, not anticipate that the hayfields around the well would become a
thriving commercial area with gasoline stations, restaurants and other facilities. Indeed,
commercial development mushroomed during the 1970s and 1980s and, although the Norway
water system superintendent expressed concern over this development, he was powerless to
stop it. In 1988, Norway initiated a wellhead protection (WHP)'study of its well area in an
, attempt to protect its drinking water supply.
In 1990, a gasoline leak from an Underground Storage Tank (UST) at Steve's Country
Store, a gasoline station/variety store, contaminated the aquifer within 300 feet of Norway's"
well. Norway and Maine DEP benefitted from the prior wellhead protection area (WHPA)
delineation and were able to quickly characterize the contamination, shut the well to contain
the contaminant plume, and_remediate; the aquifer within 15 months. ,
1.0 COMMUNITY DESCRIPTION
Norway, Maine is located in Oxford County; the southern part of Norway is nestled
between the towns of Oxford and South Paris. 'The three towns, generally referred to as "the
trirtbwn area," are located in southwestern Maine approximately 15 miles northwest of the '
Auburn-Lewiston area. Exhibit 1 shows the study area. •
«>. ' • . " =J,
1.1 Land Use .
Norway is a predominantly residential town. Approximately 80 percent of Norway's
land is used for residences, with the remainder for commercial and light industrial
development. Commercial and industrial facilities in Norway include a small grocery 'store
and a mill and shoe manufacturer. Little land in Norway remains available for further
development and no expansion of town boundaries is predicted in the future.
Norway's well is located south of Norway within the town limits of Oxford in an area
of heavy commercial development. The most common commercial facilities in that area,
which is adjacent to State Route 26, are gasoline stations and other automotive facilities,
shopping centers, and grocery and convenience stores.
1.2 Geology/Topography
In general, the geology of Maine is characterized by crystalline bedrock covered by a
shallow layer of unconsolidated surface sediments, or overburden. The Norway Water , -
.District's lone well penetrates the Little Androscoggin River Valley aquifer, a glacial sand
f and gravel aquifer measuring approximately 15 square miles in area.
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• Benefit/Cost Analysis of Preventing Contamination: Town of Norway, Maine
flank of an esker.1 This topographic feature outcrops discontinuously along the entire north-
south axis of the Little Androscoggiri River Valley. . • ,
1.3 Hydrology/Climate
Ground water in Maine generally flows the same direction as surface water, from high
to low elevations. These low areas are generally points of discharge into wetlands and other
surface water bodies. The infiltration of precipitation is the most common source of recharge
for Maine's aquifers. In general 10 to 30 percent of Maine's precipitation infiltrates into soil
to become groundwater. At most locations in the Little Androscoggin River Valley, aquifer
recharge is directed vertically downward except near the river.
Near the Norway well, groundwater generally flows from northwest to southeast while
the well is in operation west to east while the well is dormant. As is the case with most
aquifers near active pumping wells, groundwater flow can be significantly altered depending
on pumping rates and well locations. This makes accurate predictions of groundwater flow in
Maine, difficult in such situations.The Little Androscoggin River Valley aquifer discharges
into the Little Androscoggin River west of the tri-town area. Exhibit 2 presents a geologic
cross-section of the aquifer in the vicinity of the Norway well. -
Surface water in the tri-town area drains into the Little Androscoggin River, a part of
the Androscoggin River Basin. The river originates approximately 13 miles to the northwest
of Norway and Lake Pennessewassee. From there, it flows to the southeast between Norway
and South Paris, passes Oxford on the eastern end of town, and drains into the Androscoggin
River almost 15 miles further" downstream near the Aubum-Lewiston area. The Androscoggin
eventually flows into the Kennebec River which empties into Atlantic Ocean near Bath. '
Temperatures near the tri-town area generally range from an average low of 11 .
degrees in January to an average high of 79 degrees in July. Maine experiences cooler
weather then most of the United States and few hot summer days. Due to the cooling of
warm Gulf Stream air by prevailing arctic air currents, winters in Maine are often colder than
other areas of equal latitude. About 44 inches of precipitation fall annually with the most
heavy period lasting from October to April. •
Geological term for a ridge of sand and gravel deposited by a stream flowing in or beneath the ice of a stagnant
or retreating glacier.
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Benefit/Cost Analysis of Preventing Contamination: Town of Norway, Maine
and.gravds5—^--51"1^ — ^-^ °f * giadally reworked
surface to depths between 125
EXHIBIT 1
Site Map
\ Town of
* South Paris
Litcle
» Androscoggih
\River
Maine's topography is dominated by glacially formed terrain, ranging from
?°nS ^ &e WeStem' northwestera' and n°rthern P^ of the State to sea level
iated n her^111 *' S°f u^' The tOWnS °f Norwa^ Oxford> and South M»
located m the southwestern part of the State. The Norway well is situated on the western
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Benefit/Cost Analysis of Preventing Contamination: Town of Norway, Maine
EXHIBIT 2
Geologic Cross Section of the Area Near the Norway Well
SOUTH
200
2000
6000 eoob
HORIZONTAL DISTANCE (leel)
12000 14000
vtftical •laggciauon 20(
ISOp 2000 2500 3000 3500
HORIZONTAL DISTANCE (leel)
4000 4SOO
5000 SSOO
•Mica! tldQg*l«kon tAt
C"r.-V^I oulwash sands and gravels
t'jfi-».'3 Qlacb-marine line sands ana clays
lin
bedrock
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, ' Benefit/Cost Analysis of Preventing Contamination: Town of Norway, Maine
2.0 PWS CHARACTERISTICS
The Norway Water District (NWD) supplies water to approximately 2,000 people, or
40 percent of Norway's population. NWD operates a single well which taps the Little
Androscoggin River Valley aquifer. The well has been in operation since 1965.
2.1 Water Supply
NWD's well is located in the northern part of the adjacent Town of Oxford. The
gravel-^packed well is screened amidst the sand and gravel deposits of the Little Androscoggin
River Valley aquifer. The well is 84 feet deep and encased with 24-inch diameter well
casing. NWD pumps the well at a rate of 620 gallons per minute for eight to twelve hours
each day; although, the well has a maximum safe capacity of 620 gallons per minute for 24
hours. The water system maintains approximately 30 miles of water mains, which range, from
12-inch to one-inch cast ductile iron, asbestos, and galvanized copper lines.
The water produced by the Norway well is somewhat harder than optimum. NWD
treats its raw water with potassium hydroxide to raise the pH; sodium silicate treatment is
used to raise the pH and to coat the 100-year-old and older pipes in its distribution system to
meet requirements of the Lead and Copper Rule (LCR). The water system also fluoridates
and adds sodium hydrochloride. After treatment, NWD supplies,its customers with water that
meets all EPA and Maine Department of Environment Protection (DEP) standards.
The Norway Water District is connected to the water systems of both South'Paris and
Oxford. The three systems rely upon each other as emergency supply sources. For example,
to provide fire flow, Oxford purchases water from NWD through a valve connecting the two'
systems. A similar connection with the South Paris Utility District allowed NWD to provide
uninterrupted service to its customers during a contamination incident (see Section 3.0),
2,2 Financial/Management Characteristics
The Norway Water District's annual operating budget of $200,000 is sustained almost
entirely by the water rates it charges it customers. The usage.rate structure is based upon a
minimum consumption charge of $29.80 per 1,200 cubic feet of water used. ,
To borrow funds or raise water rates, the Public Utility Commission requires that
Norway first expend all of its available funding. The system last applied to adjust its water
rates in February 1995. NWD is currently trying to borrow $500,000 from the Farmers'
Home Administration (FmHA) to fund capital improvements, including an air stripper to treat
for carbon dioxide and which would also reduce radon levels and correct pH without
chemical treatment. . . >
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Benefit/Cost Analysis of Preventing Contamination: Town of Norway, Maine
In addition its to normal operating procedures, NWD operates the Oxford Utility
'District's water system day-to-day.
2.3 Population Served
The Norway Water District serves approximately 2,000 of Norway's residents via
approximately 800 service connections. The remaining residents are served by private wells.
Residential customers account for about 80 percent of water users in Norway. The remainder
is made up of 138 commercial and. nine governmental customers.
3.0 CONTAMINATION
Contamination of Norway's well resulted from a gasoline leak in one of the pumps at
Steve's Country Store, a gasoline station/convenience store located only 600 feet from the
Norway well. Exhibit 3 is a map of the contamination site.
3.1 Contamination Source
In August 1990, a truck accidently hit and knocked over the diesel pump at Steve's
Store. When the NWD operator expressed concern, the station owner assured him that the
pump would be fixed.
Later that month, during a routine UST inspection by the Maine DEP, inspectors
discovered that another pump at Steve's Store was leaking, gasoline into the soil below and
ordered the/aciliry owner to install a monitoring well. Following installation .of the
monitoring well, DEP discovered evidence of groundwater contamination and ordered the
facility to cease operation of its gasoline pumps and advised NWD to shut down its well.
The well remained out of operation for over a year while the spill was remediated.
Prior to the incident, Steve's Country Store was identified among the nine major
contaminant threat facilities in a wellhead protection study. NWD had asked all contaminant
threat facility operators to consider Best Management Practices (BMPs), including upgrading
single-wall underground gasoline storage tank to a safer dual-wall model. At that time, the
owner of Steve's Store agreed to consider the upgrade.
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, CT-6
6
w
•1/1
O
cc
Benefit/Cost Analysis of Preventing Contamination: Town of Norway, Maine
EXHIBITS
Site Map of Contamination
? ,-, St*&. iMAMCU*
2 ° (M-fitor :oc/
/.
r-1 320~-- -'«?/»,.
\ cr-a ** —
580 .-—' =_~
8500 CY
ftp'prox.V
GW Flow
\1WD Pumping
k5 .
• uw-s
NORWAr WATER OEPT
ireaeco
• Gr-9
PROJSCT OCP/OXFORD
R7 :s.
' • MONITORINC wiXL
hydrocarbons Cppb)
12/3/90 ' • '
N
3.2 Contaminants
DEP's laboratory analysis of the soil samples collected near the leaky pump indicated
high concentrations of hydrocarbons. The concentrations were highest in those samples
collected at a depth of about 25 feet, Groundwater samples collected from monitoring wells
.yielded evidence of a dissolved hydrocarbon plume beneath the leaky pump island extending
at least 150 feet toward the Norway well. No methyl tertiary butyl ether (MTBE) was
detected in the Norway well before it was shut down, and. remediation instituted.
The soil vapor extraction (SVE) system installed to help remediate the spill originally
yielded vapors very rich in MTBE. An anti-knock additive of gasoline, MTBE exhibits
chemical and physical properties distinct from those of hydrocarbons. Because it is the most
soluble component of gasoline, it is very difficult to remediate.
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Benefit/Cost Analysis of Preventing Contamination: Town of Norway, Maine
Initial concentrations of MTBE in a monitoring well at the gasoline pump island were
12,000 parts per million (ppm). The contaminant plume was contained to within a fifty-foot
radius of the storage tank. It is believed that at least 600 gallons of gasoline spilled into the
soil. • ' ' ,
3.3 Effects of Contamination
Due to the fact that the NWD was in the process of delineating a wellhead protection
area (WHPA), a great deal of data were available on groundwater flow and aquifer
stratigraphy. This enabled DEP to respond quickly in shutting down the Norway well and
beginning site assessment and remediation. A DEP official also credited the owner -of Steve's
Store with facilitating remediation through cooperation with State and local officials involved
in the cleanup. As a result of this quick response, the customers of the Norway Water
District were spared the potentially serious health effects associated with ingestion of MTBE
and other components of gasoline.
The quick response also mitigated potentially serious ecological damage. According to
a Maine Department of Human Services (DHS) official, nearly all streams in Maine are
gaining (i.e., they are at least partially recharging from aquifers). In this case, the
contamination incident occurred west of the Little Androscoggin River. Because ground
water in the area generally flows west to east, the MTBE could have, contacted and affected
the river and its aquatic organisms. '
4.0 RESPONSE ACTIVITIES
Because Norway had previously initiated a wellhead protection study, a great deal of
data were available on groundwater flow and aquifer stratigraphy in the vicinity of the
Norway well. This enabled DEP, DHS and the Norway Water District to respond quickly in
shutting down the Norway well and beginning site assessment and remediation. Because of
the quick response to the contamination incident, no contamination was detected in the
Norway well.
4.1 Response to Contamination of the Water Supply
Upon receipt of confirmation that samples taken from the monitoring well were
contaminated with MTBE, DEP advised the Norway Water District to shut down its well.
The well remained out of operation for approximately 15 months. While the remedial
operation took place, NWD supplied water to its customers by purchasing water through a
preexisting connection with the Town of South Paris. • :
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- , • - ' Benefit/Cost Analysis of Preventing Contamination: Town of Norway, Maine'
After DEP completed the remedy in 1992, NWD continued to collect samples from the
monitoring Wells. Under an agreement with the Water District, DEP continues to pay to
analyze the samples. The'NWD superintendent estimates that this practice will continue for at
least another year. . '
4.2 Response to Ground Water Contamination
Upon discovery of the leaky gasoline pump at Steve's Store, DEP ordered the owner
to install a monitoring well according to DEP specifications. The facility owner installed a
well without geotechnical supervision from DEP on September 20. Samples from this
monitoring well, sent to a laboratory for analysis, indicated gross gasoline contamination in"
the samples. • , • :-
- ' *
At the time of. discovery, the contamination was only 350 feet from the Norway well.
As part of NWD's ongoing WHP study, hydrogeologists had estimated that groundwater in
the vicinity of Steve's Store would reach the Norway well in fewer than 200 days, based,on
conservative assumptions. DEP immediately began work on assessing the extent of the
contamination and choosing a remediation technique, relying heavily oh wellhead area
delineation data provided by the NWD.
DEP chose pumping and treatment of the contaminated groundwater. The Department
drilled a recovery well and installed a two-foot diameter packed tower air stripper. After
treatment, water was passed through carbon prior to discharge to the Little Androscoggin
River. A series of monitoring wells tracked the progress of the remedy. Additional
monitoring wells and a second recovery well were drilled when it was discovered that the
MTBE plume had migrated beyond the-first recovery well. •
The Norway well was judged safe to reopen in January 1992, and quarterly monitoring
continued. DEP continues to pay for analyses and materials in conjunction with this
monitoring. Due to the precarious nature of the Norway well, DEP, DHS, and the Water
District decided to leave the remediation system on-site and off-line, but hi a state of
readiness should contamination be found in the future. NWD presently conducts routine
quarterly sampling of the monitoring wells and continues to lobby for WHP in the tri-town
area (see Section 6.2 below).
4.3 Response to Soil Contamination
DEP also employed soil vapor extraction (SVE),as, a remedial technique. The agency
installed three monitoring well/vapor points to remediate surface soils and soils near the depth
of the water table. DEP activated the ground water and soil remediation systems in January
1991. DEP initiated monthly sampling .of monitoring wells and tracking of remediation
system influent and effluent at this time as well. .,-•.".
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• Benefit/Cost Analysis of Preventing Contamination: Town of Norway, Mair,
Initially, the amount of contaminant removed through SVE was rather- high. ' As of
August 1991, crude estimates of the amount of gasoline removed from the soil were in the
range of a few hundred gallons. Over time, the rate of contaminant removal' gradually
decreased. • - ,
In August 1991, the USTs and piping ,at Steve's Store were removed and replaced wit
a state-of-the-art double-walled gasoline storage system. The soil extracted during the tank
excavation was stockpiled on impermeable plastic sheets, then disposed.
5.0 COSTS OF CONTAMINATION
The total cost of the contamination incident at Steve's Store was $526,453. This
included $139,1662 to provide replacement drinking water dur,ing the water emergency, and
$396,703 for groundwater and soil remediation. ;
5.1 Tangible Costs
Exhibit 4 provides a detailed accounting of the cost to date of contamination associated
with the 1990 incident. Exhibit 5 presents the estimated future cost of responding to
contamination between 1995 and 2005. .
5.1.1 . Costs to Provide Safe Drinking Water
To protect the health and safety of its customers, the NWt) began purchasing water
from the Town of South Paris. The net cost of this water totaled $133,946. This figure
represents the purchase price of the water minus the normal operating costs that the water
district would have incurred to deliver water to its customers during the duration of the
remedy. DEP asked the NWD to estimate the electrical and chemical costs associated with .
delivering water to its users over a 15-month period, and paid the incremental cost over this
amount. This amount was funded through Maine's Third Party Damage Claim process, an
insurance fund for cleanup of contamination incidents.
DEP continues to pay for quarterly monitoring to ensure that the Norway well remains
contamination-free. The NWD plans to continue submitting samples for as long as DEP is
willing to pay laboratory fees for analysis, probably for one more year. This cost, which as
of September 1995 has totaled $5,220, is paid from a State Groundwater Oil Cleanup -Fund
"Unless otherwise specified, all costs are presented-as 1994 dollars.
* 10-
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Benefit/Cost Analysis of Preventing Contamination: ' Town of Norway, Maine
Cost
•'.-'••
Item
Provide SafeOrinJdno Water
One-time costs ,
•; Purchase Water from 9/90 to 1/93(1 )
SUBTOTAL:
Incremental operating costs
• Post-Remedial Monitoring
SUBTOTAL:
TOTAL:
!Remediate:;Aquifer ~~~
Pre-remediation
Investigation of Spill
Remediation
Install Pump & Treat (P&T) System and
Soil Vapor Extraction (SVE) System
Operations and Maintenance
WQ Monitoring Before/During Remediation (2)
Oversight
TOTAL:
[TOTAL COST; ", ~~'
Exhibit 4
of Responding to Contamination: Norway, ME
August 1990 to September 1995
($1994)
Norway Maine DEP Maine DEP Maine DEP Third
Water District GW Oil Cleanup Bond Fund Party Damage Claim
V f
133,946
S° $0 . $0 $133.946
5,220 ;
$0 .$5,220 $0 , $o
$0 . $5,220 . '- . $0 ' $133,946 ,
' 41,284
153,735
• 136,364
22.104
10,000 33,215
$10,000 $22,104 $364,599 $0
—3
. $133,946
$133,946
$5,220
$5,220
$139,166
- i
$41,284
$153,735
, $136,364
$22 104
$43,215
$396,703
1 — — — • ^d.iu,uuu if^j^eft »jiM-,oaa ifrT 33,S4.6:»; . : • : ''$535;6S&!
(1) Net cost of purchased water minus the operational costs saved due to closure of well for 15 months
(2) Includes.work with DEP on site investigation, remediation, and sample collection during and after remediation. • '
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Benefit/Cost Analysis of Preventing Contamination: Town of Norway, Mainl
Exhibits
Future Cost of Responding to Contamination: Norway, ME
October 1995 to September 2005
($1994)
Item
Ground Water Oil Town of
Cleanup Fund Norway
Total
Incremental operating costs
Post-remedialmonitoring
' 3,096
6.939 $10,035
{TOTAL COST:
$3,096
..$65939 $10.'035l
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Benefit/Cost Analysis of Preventing Contamination: Town of Norway, Maine
funded by a per-barrel import tax on gasoline and heating oil. Based on.DEP and NWD
estimates, the future cost of monitoring paid" by DEP will total $3,096. After DEP
discontinues paying for the monitoring, Norway anticipates that it will probably continue to
(and perhaps be required to) monitor for MTBE on a semi-annual basis for several more
years. This would cost Norway an additional $6,939 (Exhibit 5). '
5.1.2 Costs to Remediate Aquifer
As .of 1995, groundwater and soil remediation cost a total of $396,703. There are four:
components to the remedial process;
• DEP spent $41,284 to investigate the extent and severity of the spill and to
select the appropriate remedy. This, was funded by a bond fund set up by the
State and administered by DEP for responding to contamination incidents.
Installation of the ground water pump and treatment system and the soil venting
system cost $153,735 and $136,364, respectively. Both were funded by the
state bond fund. ,
• During the remedy, DEP monitored water quality at the recovery wells arid
' within the monitoring well network on a monthly basis. This cost a total of
$22,104, paid through Maine's Groundwater Oil Cleanup Fund:
• Oversight of the remedy by DEP staff totaled $33,215, funded by the bond
fund^ In addition, the NWD incurred approximately $10,000 in staff costs for
consultations with DEP and to collect water samples for analysis.
5.2 Intangible Costs
• There is no indication.that the, contamination incident at Steve's Country Store
adversely affected property values or the salability of properties nearby. The greatest
economic impact of the spill was to gasoline sales at the store. Steve's Store was unable to
sell gasoline for almost 15 months while the site was being remediated. This likely reduced
the customer traffic hi the variety store as Well.
6.0 WELLHEAD PROTECTION
Norway initiated its wellhead protection program in 1988, in response to the growing
threat from commercial development around its water well. At that time, Norway also
anticipate that the State of Maine was about to adopt mandatory wellhead protection.
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Benefit/Cost Analysis of Preventing Contamination: Town of Norway, Mai\
6.1 State Requirements for Wellhead Protection
Interest in wellhead protection (WHP) in Maine began in 1987 in response to the •
requirements of the Federal Safe" Drinking Water Act Amendments of 1986. At that time, a
work group made up of State agency staff, water utility representatives, members of the
Maine Municipal Association, and Regional Council representatives began writing a plan to
implement WHP. Maine submitted the final draft of its plan to EPA in August 1989- EPA
approved the .plan in September 1990. Despite 'this early progress, the State Legislature
defeated the bill to authorize the Maine Department of Human Services (DHS) to implement
the Wellhead Protection Program (WHPP). A majority of legislators believed that the-parties
affected by the WHPP did not understand it or recognize its need.
The Legislature instructed DHS to redevelop the Program, and to seek more
involvement of affected parties. Work on the. new Program began in May 1992. DHS staff
sought to involve all interest groups named by the Legislature by assembling a network of
advisory committees to participate in drafting a WHP implementation plan. The latest draft
was produced in November 1994 and is currently being revised based on comments from the
advisory committees. .'...'•••
The main difference between the two plans is that participation in a WHPP would now'
be voluntary. To encourage participation, the DHS would consider waivers of Phase II and
Phase V monitoring requirements for communities that have WHPPs. The' revised version
advised communities seeking to establish a WHPP to include the following elements:
• Wellhead Protection Area (WHPA) Delineation. Depending on the type and
size of the water system, and calculated fixed radius delineation between 380
and 2,500 feet should be established around each well as a WHPA.
Inventory of Potential Contaminant Source Facilities. Participating water
systems should create a list of all potential contamination sources within their
delineated WHP As.
Management. Participating public water suppliers should notify local
governments of WHP As. One or more of the following management
techniques should be employed: information and education; use of existing'
regulatory tools; and capital intensive methods (e.g., extending sewer lines, or
purchasing land in the WHPA).
• Contingency Planning. Water systems should develop a contingency.plan
specifying how, in the event of an emergency, they would supply water to their
customers and contain a spill. This plan should be filed with local
governments, DEP, and all other appropriate government agencies.
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, Benefit/Cost Analysis of Preventing Contamination: Town of Norway, Maine
Throughout the implementation of WHP, DHS would serve as the lead agency in
providing technical assistance and general guidance. By participating,, water suppliers would -
save money through Phase II and Phase V monitoring waivers. A DHS official estimated
that, so far, 50 WHP programs had been reviewed and approved statewide out of 300
submitted applications. The same official credited the incentive of monitoring waivers as the
chief reason behind the level of interest in the program. ,
6.2 Local Wellhead Protection Plan
Interest in wellhead protection in Norway began as a result of concern over the rapid •
commercial development near the town's municipal water supply well during the 1970s and
1980s. Nearly all of the facilities now considered to be contamination threats to the well
were established during this time period. In 1988, the Norway Water District, in order to
better understand grdundwatef processes affecting the town's water supply, retained a
consulting firm to perform a wellhead protection study. This study resulted in the delineation
of a WHPA according to the State of Maine wellhead protection guidelines as they existed at
the time. • ' ..' "
Steve's Country Store was among the nine inajor contaminant threat facilities listed in
the 1988 wellhead protection study. Early in 1990, NWD met with its consultants and
representatives of all contaminant threat facilities, including Steve's Store, to inform them of '
their location with respect to the well and its recently-delineated wellhead protection area.
When Norway requested,voluntary cooperation with Best Management Practices (BMPs),
many facility representatives cooperated by adopting modifications to lower the risk of
contamination from their facilities. "
the visible remedial activity at Steve's Store heightened public concern in Norway
over the safety of the Town's water supply. During 1991, in order to continue funding WHP
implementation and prevent future contamination incidents, NWD applied for and received a
U.S. EPA Wellhead Protection Demonstration Grant. •
With the grant funds, Norway, Oxford, and South Paris drafted a model WHP
ordinance from which they could draft specific ordinances of their own. Management plans
and contingency plans were also drafted. Norway and South Paris have both passed WHP
Ordinances applying to all WHP areas within their town limits. At present, the Town of
Oxford has passed a zoning ordinance which limits new development hi WHP As.
6.2.1 Wellhead Protection Area Delineation
Norway installed six monitoring wells to map groundwater flpw patterns and
delineated WHP As for the well based on these findings. Norway delineated protective zones
WHPA 1 and WHPA 2 based on 200-day and 1,000-day tune of travel limits, respectively.
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Benefit/Cost Analysis of Preventing Contamination: Town of Norway, Mainl
Norway also delineated an inner area of WHPA 1, defined by a 30-day time of travel limit.
WHPA 3 is based on topography and the locations of watershed divides. It consists of areas
of hillsides beyond the edge of the aquifer with the potential to contribute water to the aquifeJ
via surface runoff or groundwater flow. Because its well arid portions of the WHPA lie
outside its jurisdictional limits, Norway recognizes that cooperation between the three towns
vital to effective implementation of wellhead protection practices.
6.2.2 Source Identification
The only contaminant threats in existence when the Norway well was sited in 1965
were two car dealerships with a combined total of six underground storage tanks (USTs) for
motor fuel. There are presently more than ten'contaminant threats within the 1,000-day time
of travel limit for the well. They consist of a shopping center, an industrial park, and several
gasoline stations and convenience stores, including the one at Steve's Store. Eight additional
threats exist in sensitive areas beyond WHPA 3.
6.2.3 Management Plan
. Due to the presence of .a number of potential sources of contamination in the wellhead
protection area in addition to Steve's Store, participants hi Norway opted for fairly strict
control and management through local ordinances.
A Wellhead Protection Ordinance is the primary element of the Management Plan for
the Norway well. It was modeled after a generic wellhead protection ordinance developed as
part of a Wellhead Demonstration Grant Project funded by the U.S. Environmental Protection
Agency (EPA). The generic ordinance was modified to account for Norway's inability to
include parts of the WHPA that lie within the towns of South Paris and Oxford, Town
officials passed the ordinance in the hopes that Oxford and South Paris would adopt similar
wellhead protection ordinances to .protect the remainder of the Norway WHPA. Only South
Paris has succeeded in doing so.
In 1995, Oxford passed a zoning ordinance that identifies wellhead areas in its '
protective zones. Oxford's fire department has instituted a plan to carry absorbent pads for
hazardous waste on fire trucks to contain spills from fuel tanks associated with automobile
accidents. The Oxford fire department also agreed to notify the NWD in the event of. a spill
near the well. •
Norway's ordinance includes several items intended to protect portions of the wellhead
protection area within town limits by providing for the regulation of certain land uses. The
Ordinance also gives the. Code Enforcement Officer certain inspection and monitoring powers
and lists BMPs (to be phased in over time) for existing land uses and facilities: Specific
procedures for appeals and variances are also provided.
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' I - Benefit/Cost Analysis of Preventing Contamination: Town of Norway, Maine
. Norway samples and analyzes water from the six monitoring wells around its water
well. The town currently conducts this sampling every two years,- although should NWD
officials suspect that the well may be in danger of contamination, monitoring may be
conducted at a greater frequency.
Recently, Norway has begun to focus on educating homeowners and businesses about
the steps they can easily or inexpensively take to protect ground water. For example,
residents were asked to store gas cans or other hazardous material containers in a safe place
where they are unlikely to spill or corrode.
Areas outside Norway's town limits, wellhead protection areas for other public wells,
and other groundwater aquifers are not covered by the Ordinance. Homeowner activities are
also, exempt, although they are urged to use BMPs. NWD is in the process of lobbying
Oxford officials to institute mandatory BMPs at facilities in Norway's WHPA. Passage of a
WHP ordinance hi Oxford seems unlikely due to voter sentiment.
6.2.4 Contingency Plan
Because of budgetary constraints, no contingency plan was developed under the
wellhead demonstration grant project. Several recommendations were made, however. In a
contamination emergency, NWD can shut down its well and immediately begin purchasing
water from either or both'of the other two towns.
7,0 COSTS OF WELLHEAD PROTECTION
The-total cost of developing Norway's wellhead protection plan was $100,588.3
Additionally, the town has spent approximately $15,000 between 1988 and 1995 to implement
wellhead protection. A detailed accounting of the cost of developing and implementing WHP
for the Norway well can be found in Exhibit 6.
7.1 Tangible Costs
Norway spent $66,713 to delineate the WHPAs around its well; this figure includes the
cost of drilling the six monitoring wells. Through the EPA Wellhead Demonstration Grant,
Norway identified contaminant threats around its well, developed a management plan, and
wrote its ordinance. The cost of these activities combined was $33,875. In addition to the
$26,500 EPA grant (1993 dollars), this amount included the contribution of funds and in-kind
resources from the Towns of Norway, Oxford* and South Paris in conjunction with the
Androscoggin Valley Council of Governments (AVCOG). •
All costs are given in 1994 dollars unless otherwise specified.
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Benefit/Cost Analysis of Preventing Contamination: Town of Norway, Mainl
Since 1988, Norway has spent $15,127 to implement its WHPP. The NWD
Superintendent estimates that he spends approximately 50 to 60 hours per year maintaining
contact with owners of businesses within the WHPA and with officials in South Paris and.
Oxford. The total cost of this labor is approximately $9,300. Additionally, Norway has
conducted two rounds of sampling at the six monitoring wells. This requires two days of
labor to collect the samples ($416) in addition to laboratory costs (approximately $2,500)'.
The total cost of the two rounds of sampling are approximately $5,832. Between 1995 and
2005, Norway's WHPP implementation costs will total $22,583 (See Exhibit 7).
7r2 Intangible Costs
The indirect -costs associated with Norway's WHPP include costs to businesses or
residences affected by the ordinance. Because Norway is primarily a residential town and
homeowners are. exempt from the BMP requirements Norway imposes on business, there are
no indirect costs associated with Norway's WHPP, It is unlikely that new businesses will
move into Norway's WHPA zones, as the town has little land available for development.
8.0 CONCLUSION
Because of the contamination at the Norway well, DEP and Norway incurred costs of
nearly $536,000. By contrast, the cost of developing the Norway wellhead protection
program was $100,588. '
Although Norway's wellhead protection was fairly costly (considering that only one
well is protected), Norway has already realized a benefit associated with the rigorous
delineation of the vulnerable areas around its well. Had the WHPA data not existed at the
time of the incident, commencement of the cleanup would have been delayed, the plume
would have expanded further, and would ultimately have required a much more extensive
cleanup.
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Benefit/Cost Analysis of Preventing Contamination: Town ofNpryvay, hfaine
Item
Norway
Water District
Exhibits
Cost of Wellhead Protection: Norway, ME
1988 to September 1995
($1994) , '
; ' v
Town of Town of Androscoggin Valley
U-S.EPAMV. Oxford South Paris Council of Govemmants
Total
WHPA Delineation 66,713
Study aquifer characteristics
Construct monitoring wells
WHP Development 1,575
' Source Identification ~
Develop Management Plan
Write Ordinance !
Recommendations for Future Activities
SUBTOTAL: $68,288
27,825
$27.825
1,050
$1,050
1,050
$1,050
2,375
$2,375
$66,713
$33.875
$100,588
NWD Oversight
Monitoring
TOTAL:
$9,295
$5,832
$15,127
$0
$0 . •• s $0
[TOTAL COST;.
$o
$9,295
$5.832
$15.127
$83.415
$27,825
$1,050
$2.375
(1) WHP Demonstratioh'Grant* S001574-01-0
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Benefit/Cost Analysis of Preventing Contamination: Town of Norway, Mai,
Exhibit?
Future Cost of Wellhead Protection: Norway, ME
October 1995 to September 2005
•y ($1994)
Item
Norway |
Water District
NWD oversight
Monitoring
$9,131
$13,457
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. Benefit/Cost Analysis of Preventing Contamination: Town of Norway, Maine
9.0 REFERENCES
Barlow, John W. Manager, Paris Utility District. Personal interview, September il, 1995.
Breale, David. Maine Department of Human Services, Division of Health Engineering,
Drinking Water Program. Personal interview, September 12, 1995. •
Bureau of Hazardous Materials and.Solid Waste Control, Division of Technical Services.
Interim Report Aquifer Remediation, Steve's Store - Oxford. October 1991. ,
MacDonald, David. Superintendent, Norway Water District 'Personal interview, September
11, 1995. ' : ' •••',..•-. •• ,- ' : ,
Maine Department of Environmental Protection. Status Report -January 1991, Steve's Store.
Prepared by Groundwater Technology, Inc. February 1991.
• Maine Department of Environmental Protection. Remediation of Gasoline Contamination In a
Sand and Gravel Aquifer in Oxford, Maine: A Success Story for Wellhead Protection.
October 1991.
Maine Department of Human Services, Division of Health Engineering, Drinking Water
Program. Maine's Wellhead Protection Program. November 1994.
Maine Department of Human Services. The Costs of No Wellhead Protection in Maine, A
Study of the Costs of Cure vs. Prevention: Volume!., November 1993. ^
Maine Department of Human Services. The Costs of No Wellhead Protection in Maine, A
Study of the Costs of Cure vs. Prevention: Volume 2. November 1993.
Norway Water'District. Wellhead and Aquifer Protection Plan'for Norway, Oxford and South
Paris Water Districts, Phase I Report. Prepared by BCI Geonetics, March 1989. • •
» ' ,'!'.''." • ' '
Smith, Rodney. Code Enforcement Officer, Building Inspector, and Plumbing Inspector,
Towns of Oxford and Otisfield. Personal interview, September 11, 1995;
Steve's Store. Oil and Hazardous Materials Report Form (with notes detailing contamination
incident). August 8, 1990.
Swain, Christopher. Environmental Services Specialist, Maine Department of Environmental
Protection, Division of Technical Services, Bureau of Oil & Hazardous Materials Control.
Personal interview, September 12, 1995. ,
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Benefit/Cost Analysis of Preventing Contamination: Town of Norway, Maine
Town of South Paris. Wellhead Protection Ordinance. June 1994.
United States Environmental .Protection Agency. Project Report - Norway, Maine. Prepared
by Hydrosource Associates, Inc. under U.S, EPA Wellhead Protection Demonstration Grant
(Assistance #8001574-01-0). October 1993.
United States Environmental Protection Agency. Final Project Report -Norway, Maine.
Prepared by Hydrosource Associates, Inc. under U.S. EPA Wellhead Protection Demonstration
Grant (Assistance #8001574-01-0). November 1993.
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PART TWO
LESSONS LEARNED
1.6 Introduction and Overview
The experiences of the study communities show that even the most modest WHPP has merit:
communities pay closer attention to threats near their drinking water wells, citizens are educated on
simple, ways to protect water wells, and communities can work together to achieve real goals to
protect the environment. As Chapter 3 indicates, well-for-well, WHP offers relatively inexpensive
insurance compared to the rather significant cost of cleanup.
Aside from the cost-avoided benefits of WHP, certain trends appear across the case studies
that can enlighten community leaders on the true threat to their water supplies and the importance
of protecting them. For example, it is not news-making contamination incidents, but more everyday
type sources such-as dry cleaners and gas stations that most often threaten water quality.
Furthermore, poor planning or inattention to rapid development can foil attempts to protect water
supplies. . .
By studying local experiences with developing, implementing, and maintaining WHPPs, the
project team observed those parts of a WHPP that provide the greatest protection for the resources
spent and where communities often stumble. While every wellhead protection program produces
either a financial, health, or environmental benefit, not every pitfall can be anticipated of prevented.
Some communities have developed innovative approaches to wellhead protection, or have allowed
other communities to benefit from their work.
1.1 Contamination Threats
Although extensive contamination incidents, such as Superfund sites, are often the subject
of headlines in -the news, everyday activities pose the most significant threat to drinking water
.supplies. • ,
1.1.1 Risks from Various Types of Contamination
In two of the six contamination incidents, leaking gasoline storage tanks were at fault. In
Gilbert, a gasoline leak from a UST at an abandoned gas station contaminated soil and ground water.
The UST remained buried for three years after the gas station closed, and in the interim, the tanks
leaked. Contamination in Norway resulted from gasoline leaking from a pump at a gas station.
Dry cleaners, found in nearly every community, also pose a substantial threat. In Gettysburg,
the accidental failure of a drain at a dry cleaning facility contaminated one of GMA's wells. The dry
1
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Benefits and Costs of Prevention
November 30. 1995
cleaning facility had legally disposed of waste to the borough's sewer system until, in 1986, during
State-required pre-operational monitoring, GMA discovered contamination at the well.
In Tumwater, the source of contamination has not been determined, but of the four sites that
are the focus of the contamination investigation, two are current or former dry cleaners, and one is
a gas station. In Middletown, poor housekeeping practices at a relatively small industrial facility
were the source of contamination: staff at a flexographic printing plate manufacturer squeegeed
leaks from a distillation unit out a doorway.
••'
1.1.2 Potential Contamination Threats
While the case studies focus on the devastating effects of a single contamination incident,
the contaminant source identification effort in the subject communities identified up to dozens of
potential threats.
Contaminant source identification often enlightens communities on the multitude of threats
to their drinking water supplies: . . . •
• In Lancaster County, the volunteers and contractors identified 119 contamination
threats. The majority of these were underground storage tanks, and commercial or
suspected hazardous waste storage facilities. In the rural county, the WHP
committee chose not to include agricultural facilities hi the search for threats, as the
farms in the region were well known. The committee instead opted to focus on less
obvious point sources.
• Gilbert's final contaminant source inventory identified 27 potential sources of
contamination, 13 of which were current or former service stations or garages. Other
sources included three cemeteries, two dry cleaners, a small airport, sewage lines and
disposal ponds, and drainage canals.
* * > '
• ' In .Dartmouth, 16 potential sources of contamination were found to exist within the
Zone I and II protection areas of the wells. These include propane storage tanks, an
oil storage tank, diesel oil disposal sites, and gravel pits.
• Middletown located approximately 80 actual and potential sources of contamination
within its WHP A. These included several industrial sites; commercial sites such as
service stations, auto repair facilities, and dry cleaners; and major transportation
routes, including State highways, a railroad line and the Great Miami River.
2.
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Benefits and Costs of Prevention
November 30. 1995
• Norway identified 18 threats to water quality within the zones of contribution or in
the sensitive areas beyond this zone. The threats included gas stations, commercial
'. facilities, automotive facilities, a dump, and a waste treatment plant. .
' Tumwater and Middletown identified actual contamination incidents during their
contamination source identification processes. In Tumwater, the preliminary survey of contaminants
identified several sites of particular concern. These include two leaking petroleum USTs within the
five-year time-df-travel zone of the wellfield. Also identified were a bulk fuel storage depot, a
fiberglass manufacturing facility, and a fisheries maintenance yard.
Three confirmed sources of contamination lie within the one- and five-year time-of-travel
zones of Middletown's wells. They include a city landfill which lies within the five-year tune of
travel zone; a paper company within the one-year time-of-travel zone; and the printing plate
manufacturer that is the subject of the case study within the one-year time-of-travel zone.
1.1.3 The Role of Siting
In the ideal case, the inner protective zones around each drinking water well would be free
of potential contaminants. If the well is sited in a relatively developed area of the community, there
is a significant potential for contamination. '•'.-.
Gettysburg sited its well" in the middle of town, close to several potential sources of
contamination, including dry cleaning facilities. A drain located inside a dry cleaners, through which
the facility was legally discharging wastewater into the Gettysburg sewer system, was the source of
the contaminated ground water. The drain failed and leaked wastewater into the soil. Had
Gettysburg conducted a contaminant source identification around the proposed well site, the results
may have discouraged the GMA from siting the well where it did.
Dartmouth had siting one of its wells, and it was a call from a concerned citizen which
alerted officials of former dumping activity in an abandoned gravel pit. During the well design
phase, a caller, noting the-town's signs delineating a "Water Supply Area," identified the area as an
old dump site. If the town had performed a preliminary inventory of potential contamination sources
before initiating the siting process, they may have chosen to site that well elsewhere.
The majority of drinking water wells in Gilbert, Tumwater, Middletown, and Norway were
sited before WHP. For decades, no safeguards were in place to stop the encroachment of potential
threats to the wellfield area. As the communities grew, so did the contamination threat
Often, water suppliers who sited wells in the 1950's and 1960's could not have anticipated
the development near their wellfields. The wellfields of Gilbert, Tumwater, Middletown, and
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Benefits and Costs of Prevention
November 30, 1995
Norway lie along state roads or interstate highways, which are natural locations for industrial or
commercial development. For example, Gilbert's wells were located in the center of the Village,
near a state highway dotted with gas stations. In Middletown, development encroached on a
wellfield which had existed for over 50 years. As development encroached on Norway's well, sited
in 1965 in a hay field, the water district superintendent was powerless to act upon his concern that
me new gas stations would threaten me town's drinking water supply.
Another aspect of effective well siting is the importance ofgeographically separating wells
as much as possible. By spreading wells over large distances, communities can lessen the possibility
that one contaminant plume can affect a large percentage of its wells. Gilbert, Tumwater, and
Middletown each lost multiple wells as a result of a single contamination incident. In fact,
Tumwater's wells were sited so close together that the city was unable to pump both wells at the
same time. Had the contamination incident in Middletown been slightly north of where it was, for
example, in the Great Miami River, Middletown could potentially lose its entire wellfield.
Siting wells far from each other and from a central treatment plant can be very expensive:
transmission lines connecting outlying wells to treatment facilities can be very costly, especially in
areas of rough terrain. A widely dispersed wellfield can serve as effective insurance against loss of
multiple wells from a single contamination incident, however.
1.2 Wellhead Protection
The six study communities are in various stages of completing their WHPPs. Every
community has delineated its WHPAs, and conducted at least a preliminary contaminant source
identification.1 Three communities (Gilbert, Dartmouth, and Norway) have enacted WHP
ordinances; the other three (Lancaster County, Tumwater, and Middletown) are in the process of
developing them. Three communities (Gilbert, Dartmouth, and Norway) have developed
contingency plans. - •
1.2.1 Effectiveness of WHPPs
* • i
A key step in assessing the benefits of WHP is determining whether the WHPP in place or
under development in each community would prevent a similar contamination incident, or at least
mitigate the effects of contamination on the water system. Whether or not a community has
completed all of the required WHP elements, it is possible to make some observations about the
likely effectiveness of its WHP efforts. As noted in Section 1.0, for purposes of quantifying
potential benefits, the WHPPs are assumed to be 100 percent effective, although the programs cannot
warrant or guarantee such results. In reality, several of the WHPPs have limitations which could
'Dartmouth did not have a distinct source identification effort, but compiled existing data on potential sources.
4 ' ' "•
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Benefits and Costs of Prevention
November 30. 1995
reduce their effectiveness in certain circumstances.
Despite some limitations, all of the WHPPs studied offer some level of protection to ground
water resources. Moreover, they provide other types of benefits to the community. In Dartmouth,
for example, some local officials believe that the most important benefit of WHP is increased
awareness of the need to protect ground water supplies. The identification of potential sources of
contamination alone is of substantial benefit in that it heightens citizen awareness of the vulnerability
of ground water supplies. Further, at least two study communities (Tumwater, Middletown) have ,
listedconfirmed sources of groundwater contamination hi their source inventories.
Lancaster County's WHPP, 'though not complete,, appears likely to be effective at preventing
contamination. The proposed plan includes performance and design standards, and inspections of
potential sources of contamination. In addition, the communities plan to develop a public education
program for agriculture, the most common source of groundwater contamination in the county.
Gilbert's management ordinance focuses on preventing high risk activities (e.g., dry cleaners,
facilities with USTs) from locating within 1,000 feet of its wells. The ordinance does not address
the 27 potential threats currently located in the WHP A, or potential sources of contamination that
may locate outside the 1,000 foot radius, but still within the WHP A. Essentially, the ordinance
protects the Village from certain new contamination sources within the 1,000 foot radius, but still
leaves the community somewhatvulnerable to groundwater contamination.
The leaking UST that caused Gilbert's contamination incident was located about 150 feet,
from the village's wells. Gilbert's ordinance would prohibit the construction of a new gasoline
station at the site, but would not affect an existing gas station! Federal UST regulations provide
Gilbert with some protection against threats from existing USTs. The UST in Gilbert leaked prior
to the promulgation of federal regulations, however.
If a UST leak occurred within the WHPA, Gilbert's WHPP probably would not provide the
village with advance warning of the spreading contaminant plume. Gilbert does not have any
monitoring wells in the vicinity of its wellfield. Thus, once a contamination plume begins migrating
toward the wellfield, it might not be discovered until it enters a well.
In Dartmouth, contamination of one. well was caused by illegal drum storage at a warehouse,
and contamination of a second well was the result of clandestine dumping. A thorough contaminant
source identification effort might identify a clandestine dump, or an illegal drum storage site.
Without routine inspections, however, contamination could develop and not be discovered before
it is too late. Dartmouth does not inspect potentially threatening facilities, other than septic systems,
Because the source of contamination in Tumwater has not been determined and the final
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Benefits and Costs of Prevention
November 30. 1995
WHPP has not been developed, it is difficult to ascertain whether Tumwater's WHPP would prevent
a similar contamination incident.. The city's monitoring well network should provide it with early
warning of an advancing contaminant plume, giving officials time to respond. :
Middletown's WHPP appears likely to prevent a contamination incident similar to the one
that shut down three of its wells. The printing plate manufacturing plant would have been required
to install a containment structure to prevent a release of contaminants from an above-ground storage
unit. Further, jmmial inspections probably would have identified the improper housekeeping
practices at the plant. In the event that both containment structures and inspections failed to prevent.
the release of contaminants, groundwater monitoring likely would have picked up the contamination
plume moving toward the wellfield.
Norway has adopted a WHPP that includes monitoring, permit reviews, land use restrictions,
performance and design standards, and impervious cover restrictions. As part of its WHPP, Norway
monitors water quality bi-annually. Although a regular DEP inspection, rather than WHP-related
monitoring, detected the contamination incident, the availability of the in-place monitoring well
network expedited the remedial process. ,
Norway's WHPA extends into-the nearby town of Oxford, where many potential sources of
contamination are located, including the gas station that caused the contamination incident. Norway
officials have been unable to convince their counterparts in Oxford to adopt an ordinance requiring
Best ManagementPractices (BMPs), however. , .
1.2.2 Other Factors
Even with an ideal WHPP, factors beyond the control of local officials may leave a
community's wells vulnerable to contamination. The Gilbert, Dartmouth, and Norway case studies
offer three examples.
The Louisiana Department of Environmental Quality (LDEQ) has been unable to secure
funding for cleanup of the aquifer in Gilbert. This leads to the observation that communities are
likely to identify existing contamination problems through their contaminant source identification
efforts. If funding is not available to address them, a community will realize little benefit. One
LDEQ official pointed out that wellhead protection may identify more potential sources of
contamination than .were initially perceived. This s observation may also reflect the need to
concentrate on high risk contamination sources first, especially hi resource-constrained
circumstances. • .
As Dartmouth's experience shows, illegal activity may contaminate ground water supplies.
No WHPP can be expected to fully safeguard a community against contamination caused by illegal
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Benefits and Costs of Prevention
November 30. 1995
actions. A WHPP can provide an early warning to local officials before the contamination reaches
the wellfield, however.
Frequently, WHPAs cross political boundaries into other jurisdictions. If the other
jurisdictions do not adopt source controls or other management approaches, the WHPP may not be
effective Most of the potential threats in Norway's WHPA are located in nearby Oxford. Although
Norway has enacted a fairly comprehensive management ordinance, Norway officials have been
unable to convince their counterparts in Oxford follow suit.
1.2.3 Key WHP Elements
. Two of the most important elements in determining the effectiveness of WHPPs appear to
be inspections and groundwater monitoring. Even the most comprehensive management ordinance
can fail if communities do not have the ability to verify that potential sources of contamination are
in compliance. Inspections can identify potential problems before they become groundwater
contamination incidents. In addition, they may serve as a deterrent to illegal activity, such as illegal
storage of hazardous materials.
Monitoring wells located immediately downgradient of potential sources of contamination
and upgradient from PWS wells serve as an early warning in the event contaminants are released into
ground water. If the case study communities had monitoring well networks in place, they might
have discovered the contaminant plumes before they entered the wellfields. With Warning time, the
communities could have taken steps to prevent or, mitigate the contamination incidents.
• *sta '
Gettysburg, Tumwater, and Middletown provide cases in point. Pumping from PWS wells
altered the course of contaminant plumes, drawing contamination toward those wells. With advance
warning, local officials may have been able to alter pumping regimes or construct interceptor wells
to prevent the contamination of the wellfields. If not, they might have constructed treatment
facilities before contaminants reached the wells, possibly reducing the impact on the community.
The importance of monitoring is acutely demonstrated in Norway, even though regular WHP-
related monitoring did not detect the contamination. Because the town discovered contamination
early and reacted immediately, the well was shut down and contamination removed before it spread
beyond the immediate vicinity of the gasoline station. Officials at Maine DEP agree that, had
contamination spread, cleanup would have been far more costly and probably would not have yet
begun. ,
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Benefits and Costs of Prevention
November 30. 1995
1.2.4 Information Exchange
Communities developing WHPPs commonly look toward one another for advice,
information, and technical assistance. Several of the case study communities borrowed approaches
and ideas from other communities, or served as models for their counterparts.
• Dartmouth was the first community in Massachusetts, and one of the first in the
country, to develop a WHPP. Other communities in Massachusetts have looked
toward Dartmouth as a source of information and expertise.2 Dartmouth's ordinance
served as a model for other communities that have subsequently adopted WHP.
• Tumwater is likely to adopt a final WHP plan very similar to the one under
development in nearby Lacey, Washington. To a large extent, this reflects Thurstoh
County's efforts to promote WHP. Tumwater and Lacey have designed their WHPPs
to be consistent with the county's ground water management plan. Tumwater's WHP
budget includes funds to study implementation strategies of other communities.
* '
• The centerpiece of Middletown's source management effort, the "Intensity of Land
Use Classification" approach, was borrowed from nearby Dayton. Dayton is widely
regarded as a WHP innovator in Ohio.
The Pennsylvania Department of Environmental Resources (PADER) has recognized the value of
exchanging information pmong communities. The agency has begun to develop a program to match
communities that have implemented WHPPs with those that a^re interested in developing one.
1.2.5 Role of Community Sparkplugs .
The WHP efforts of several case study communities are led by dynamic, energetic
individuals who are totally committed to their success. In Dartmouth, Tumwater, Middletown, and
Norway, these "sparkplugs" have been key participants since the beginning of the WHP efforts, and
werej' in fact, crucial to getting the effort underway. These individuals have contributed many long
hours to developing their WHPPs, sometimes at their own expense. Their continued commitment
has been especially important over the long run, since it often takes several years to build the
community support necessary to adopt a WHPP. These individuals recognize the importance of
public education and public participation in developing a successful WHPP, and have worked hard
to "get the word out" in their communities. It is difficult to imagine that the WHP efforts would
have come as far without their participation. .
^pon hearing about Dartmouth's WHPP, Tumwater asked the project team to provide the name and telephone
number of Dartmouth's WHPP coordinator.
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Benefits and Costs of Prevention
November 30. 1995
1.2.6 Approaches to Contaminant Source Management
The case study communities have adopted or are considering varied approaches to managing
their contamination sources, reflecting differences in state WHP requirements, contamination threats,
resource availability, and institutional capabilities.
The most common management approaches include site plan reviews, land use restrictions,
performance standards, and design standards. Site plan reviews focus on catching a potential for
contamination before a proposed project is built in the WHPA. Land use restrictions generally focus
on preventing high risk land uses from locating near wells. Performance and design standards
generally restate requirements in federal and state environmental regulations. They target facilities
such as septic systems, stormwater collection facilities, and underground and above-ground storage
tanks. - • ,
Dartmouth, Tumwater, and Middletown appear to favor a more comprehensive, proactive
approach toward WHP. Generally, these communities have more resources available, and more
potential threats to their wells. The existence of a State requirement to undertake WHP probably
also plays a role. Massachusetts and Washington require water systems to develop WHPPs. Ohio
does not have a formal requirement, but the Ohio EPA requires WHP as a condition for approval of
water system improvements. Other factors contribute to the character of their WHPPs. For example,
concerns over the city's rapid growth rate and a general pro-environment attitude among citizens
have spurred Tumwater's interest in WHP.
Gilbert and Norway have adopted more modest approaches, reflecting their smaller size,
regional attitudes about the role of government, fewer resources, fewer potential sources of
contamination, and a lack of a state requirement to undertake WHP. Both communities are located
in undeveloped areas, and generally have fewer potential contamination sources. The Norway
ordinance contains land use restrictions, impervious cover restrictions, and performance standards.
However, the part of the WHPA located hi Norway is mostly residential. The Town of .Oxford,
which contains most of the sources of potential contamination, has not enacted a management
ordinance. Exhibit. 1 summarizes the management tools which have been adopted or are under
consideration in,the communities.
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Benefits and Costs of Prevention
November 30. 1995
The communities of Lancaster County appear tobe an exception to the rule. They plan to.
adopt a relatively proactive WHPP, despite their similarity to Gilbert and Norway. The proposed
WHPP, includes inspections, performance standards, design standards, and a public education
program that focuses on agriculture. It is interesting to note that none of the communities has
enacted the ordinance, perhaps indicating public sentiment for a more modest WHP .approach.
1.2.7 Difficulty of Adopting WHP Ordinances
Aside from Dartmouth, none, of the communities has had much experience implementing
WHP ordinances. Building support for WHP ordinances can be a long, difficult process. The
communities of Lancaster County and the City of Middletown have been working on WHP for
several years, but have yet to adopt management ordinances.
Communities must educate citizens about the need to protect their ground water sources. In
addition, they may have to overcome opposition among various groups in the community. In
Lancaster County, for example, some farmers are opposed to the WHP ordinance because they fear
it may limit their ability to develop their land in the future. In Middletown, it has taken over a year
to convince the City Council to grant preliminary approval for WHPP, despite the contamination
incident. Final approval for a WHP ordinance may not occur until sometime in 1996.
1.2.8 Transferability of Innovative WHP Strategies
Two study communities have included relatively unique elements in then- WHPPs.
Dartmouth's contingency plan goes beyond typical contingency plans; Middletown's management
strategy is similarly innovative.
The Dartmouth contingency plan addresses automobile accidents, which pose the most
common threat to groundwater. Fire departments respond to the scene of an accident with absorbent
pads, which are kept on fire trucks. At each pump house, a supply of absorbent pads is kept in stock
in case a spill should occur near the well. The town is investigating the possibility of equipping
police officers with similar kits, since they frequently are the first responders to accidents.
Although it borrowed the concept from nearby Dayton, Middletown plans to adopt the
innovative "Intensity of Land Use Classification" approach to managing potential contamination
sources with the WHP A. Each source is given a rank based on: (1) the type and quantity of
hazardous chemicals stored or used onsite and (2) engineering controls or risk reduction strategies
in use. Businesses cannot increase their scores. If a business wishes to store or use a higher quantity
of chemicals onsite, it must take steps to mitigate the additional risk. Middletown has created a Risk
Reduction Fund to provide businesses within the WHP A with low interest loans and grants for the
construction of engineering controls to prevent contaminant releases.
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Benefits and Costs of Prevention
November 30. 1995
1.3 Who Pays?
Whether faced with contamination or considering WHP, local governments often look to
regional, state or federal agencies for financial assistance. Communities often pay the cost of
protecting their wells from a contamination incident, although state or federal agencies step hi to
address aquifer cleanups. Communities often avail themselves of state or federal grants to assist
them in developing their WHPPs.
1.3.1 Financial Impacts of Contamination
When contamination is discovered, two parallel sets of responses take place: first, the PWS
acts to protect the safety of its customers; second, the responding agency (usually the state or federal
government) steps in to select, design and implement the aquifer remedy.
Water suppliers usually pay the cost of responding to Contamination hi the wells to continue
providing safe drinking water to their customers. Gettysburg and Dartmouth paid capital and O&M
costs associated with installing and operating air strippers on then: supply wells. Middletown will
likely pay to construct air strippers within the next two years. Gilbert paid the cost of purchased
water, but has been unable to .recoup these costs from its customers. The Turnwater Water System
paid for all of the costs associated with PWS contamination.
When a water supply well is lost to contamination, communities may be forced to purchase
water from neighboring water systems. Often, this water must be purchased at the highest usage
rates charges by the new supplier.
• The Village of Gilbert purchased water from two nearby communities at a higher rate
than it normally charged its customers. The village'did not raise its water usage rates
to compensate for the higher purchase price during the 18-month water emergency.
• Dartmouth increased the portion of its water supplied by New Bedford, for which it
has historically paid the same rate that city charges its commercial users. With the
closure of one well, the town lost the source of 81 million gallons of drinking water
per year. , -
• Norway was also forced to purchase water. Although the Town of South Paris
offered to adjust its rates during the emergency, the Public Utility Commission
would not approve the change. . '
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Benefits and Costs of Prevention
November 30. 1995
The communities of Dartmouth and Norway fortunately were able to access the purchased
water fairly easily. Dartmouth had historically purchased a portion of its water from New Bedford;
Norway used to supply water to South Paris, and the two utilities sell each other water during water
emergencies such as fires. In contrast, the Gilbert Water System was forced to build transmission
lines in order to connect to the neighboring water systems.
State ,or Federal agencies, and ultimately taxpayers, usually pay the cost of aquifer
characterization. In four of the six contamination incidents studied (Gettysburg, Gilbert, Tumwater,
and Norway3), the State paid all or part of the contamination assessment costs. In Middletown, the
PWS paid for initial investigation of the contaminant plume. The owner of the facility responsible
for the contamination is paying for additional investigation of the plume and interim source control
measures. Dartmouth was unique among the case studies in that the town paid all groundwater
cleanup-related expenses. •
The bill for aquifer remediation, usually the most costly element, is often paid by state-or
federal agencies. In Gettysburg, PADER will pay to install and operate an air stripper and soil vapor
extraction system, a remedial effort which may last up to thirty years. This cleanup will befunded
by Pennsylvania's Hazardous Sites Cleanup Program (HSCP). "
Federal and State reserve funds exist to address the relatively common problem of leaking
underground storage tanks. Gilbert and Norway benefitted from the availability of these funds.
Gilbert received funds from the Federal LUST Trust fund, FmHA, and HUD's Urban Community
Development Block Grant for response to PWS contamination. LDEQ has been unable to secure
LUST Trust funds to clean up the aquifer, however. State monies funded soil vapor extraction and
groundwater pumping/treatment in Norway, as well. Maine's Groundwater Oil Cleanup Fund (from
a per-barrel import tax on gasoline and heating oil), financed DEP's cleanup of contamination in
Norway. , -
Responsible parties often do not pay the costs of responding to contamination at the well or
the aquifer; if they do pay, it is usually a small portion of the total cleanup costs. The reason for this
is that most of the responsible parties are small businesses: a gas station and'attached variety store
or a small dry cleaners. These types of businesses do not have the funds to pay for million-dollar
cleanups, and are rarely insured against this type of liability. Even if legal action is taken against
responsible parties, little money is recovered, and much time and money are spent on litigation.
Some States have funding mechanisms in place to provide money for, responding to
Norway's wellhead protection report, funded by an EPA Wellhead Protection Demonstration Grant and funds from
Norway, Oxford, South Paris, and the Androscoggin Valley Council of Governments, was instrumental in expediting
the aquifer characterization.
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Benefits and Costs of Prevention
November 30. 1995
groundwater contamination. Gettysburg, Tumwater, and Norway benefitted from the availability
of these funds. For example, the J.C. Cleaners site in Gettysburg has been listed on the, Pennsylvania
Priority List of Hazardous Sites for Remedial Response (PAPL), the state equivalent of the
CERCLA National Priorities List (NPL).
1.3.2 Role of Outside Funding for WHP
The case studies show that outside funding can provide a critical boost to WHP efforts,
sparking community interest, leveraging local resources, and increasing the scope of feasible WHP
activities. The challenge for communities is in implementing WHP over the long term, since
funding is generally not available for implementation activities. Communities that choose to
implement proactive WHPPs must adopt funding mechanisms, such as permit fees, water use
surcharges, and connection fees.
.The communities of Lancaster County benefitted from a $30,000 grant from EPA Region
3 to delineate WHP As using fracture trace analysis, and a $20,000 State grant to develop a
contaminant source management ordinance., Without the grants, the communities probably would
not have undertaken WHP. Even if they had, the EPA grant probably allowed them to use a more
sophisticated, more accurate delineation method than they might have otherwise chosen.
Although the cost of Gilbert's WHPP is relatively modest, the contribution of staff time by
LDEQ was crucial to its development: The PWS is a one-person operation, and the village probably
would not have undertaken a WHP effort without State assistance. LDEQ staff spent numerous
hours delineating the WHP A, identifying potential sources of contamination, preparing maps, and
providing technical assistance in the development of Gilbert's contingency plan and management
ordinance. .
Tumwater received a $170S000 grant from Washington's Centennial Clean Water Fund, and
provided a 100 percent match. - Although the community would have undertaken WHP to fulfill State
requirements, the grant allowed Tumwater to have a more comprehensive WHP than it might have
otherwise. For example, Tumwater is implementing an ambitious ground water monitoring effort.
Middletown received a $12,000 EPA WHP Demonstration Grant to develop a public
education program. Although the grant was a relatively small part of the WHP budget, it likely
spurred Middletown to develop a more comprehensive and formal public education plan.
Middletown is the only community in the study to develop a WHP curriculum for its schools.
Norway received a $26,500 EPA WHP Demonstration Grant to develop a WHP ordinance
and comprehensive land use plans. The grant spurred two neighboring towns and the local council
of governments to contribute small financial or in-kind assistance. More importantly than the
14
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financial value of the contributions, the grant sparked interest in two communities that otherwise
would have little incentive to implement WHP.
2. CONCLUSIONS
The case studies suggest steps to improve the effectiveness of WHPPs and to encourage local
communities to undertake a WHP effort in the first place. ,
• Encourage communities to review PWS well construction and identify conduits
for contamination within WHPAs. In Middletown, Gilbert, and Gettysburg, casing
failures in PWS wells or faulty .construction in nearby private wells allowed
, contamination to migrate from surficial aquifers to confined or semi-confined deep
aquifers tapped by PWS wells. This suggests that communities should evaluate the
physical conditions of their wells during the WHP effort. In addition, WHPAs could
be analogous to the "Area of Review" concept in the Underground Injection Control
program. Local communities would identify wells in their WHPAs which could
. serve as conduits for contamination. This review could be conducted during the
contaminant source identification effort.
• Facilitate the exchange of. information and ideas among communities.
Mechanisms to consider include a WHP document clearinghouse, a World Wide
Web site, or an electronic bulletin board. EPA currently is developing a Community
Empowerment Kit for WHP. The kit will contain sample management ordinances
and contingency plans, and case studies of successful WHPPs.' The kit could serve
% , as a starting, point for these activities. Some states are initiating programs to
promote information exchange among local communities. For example, the
Pennsylvania Department of Environmental Resources is developing a WHP peer
matching program for communities interested in starting a WHPP. State officials
hope that communities that have experience with WHP will share their observations
and "lessons learned" with target communities.
• . , • Recognize innovative WHPPs. Several state and local officials contacted during
the study stressed the value of formally recognizing innovative or especially
successful WHPPs. Community recognition can encourage local officials to make
the sometimes difficult decisions necessary to protect WHPAs. State officials :in
Louisiana, for example, present a Certificate of Completion to community officials
when they have completed all of the WHP elements. LDEQ staff publicly recognize
local, officials for their efforts hi establishing WHPPs. They encourage local media
to cover each event. ,
• Encourage communities to conduct a simple delineation and preliminary
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Benefits and Costs of Prevention
November 30. 1995
contaminant source identification early in their WHP efforts. Several state and
local officials contacted during the case studies advocated conducting a simple
delineation and contaminant source identification effort to identify the biggest threats
to the groundwater supply. Local officials can use this information to build support
for WHP in their communities. If actual contamination sources are identified in the
preliminary contaminant source identification effort, communities can address them
during the course of .their WHP. efforts. Once the wellhead protection effort is
underway, communities can conduct a more complex delineation and comprehensive
contaminant source identification effort. .
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BIBLIOGRAPHY
Adding Flexibility to Socioeconomic Criteria. Memorandum from ICF, Inc. to OGWP, September
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Ground Water Valuation Program. Ground Water Valuation Case Studies., .
League of Women Voters Education Fund. Protect Your Ground Water: Educating for Action.
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National Rural Water Association. Wellhead Protection Program: Case Studies. (GWTG-01),
1992. .' -. ; ': ' .- ""• • '." ;•'./. . , .'•'..'•••• -,
Options for Revising the Economic Tests of the Ground-water Classification .Guidelines.
Memorandum from ICF, lac. to OGWpW and OPPE, August 24,1987.
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Around Public Wells from Contamination. (GAO/RCED-93-96), April 1993.
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U.S. General Accounting Office. Groundwater Quality: State Activities to Guard Against
Contaminants. (GAO/PEMD-88-5), February 1988.
• ' f- ' ' • '
1 \
U.S. Environrhental Protection Agency, Office of Water. Definitions of the Minimum Set of Data
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Through Wellhead Protection. (EPA 570/09/91-007), May 1991.
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Benefits and Costs of Prevention
November 30. 1995
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Inventories for Public Drinking Water Supplies, Technical Assistance Document. (570/9-91-014),
December 1991.
U.S. Environmental Protection Agency, Office of Water. A Guide for Cost-Effectiveness and Cost-
Benefit Analysis of State and Local Ground Water Protection Programs. (EPA 813-R-93-001),
April 1993. ' ' ;
U.S. Environmental Protection Agency, Office of Water. Wellhead Protection Programs: Tools
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U.S. Environmental Protection Agency, Office of Water. Wellhead Protection: A Decision Maker's
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U.S. Environmental Protection Agency. Minimum Set of Data Elements for Ground Water Quality.
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Virginia Ground Water Protection Steering Committee. Wellhead Protection: A Handbookfor Local
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Virginia Ground Water Protection Steering Committee. Wellhead Protection: Case Studies of Six
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