f Water

                            DEMONSTRATION  PROJECTS
Ineida Tribe, Wisconsin

letting:  The  Oneida  Tribe  consists  of
pproximately 10,000 Tribal members, nearly
alf of whom live on or near the reservation.
'he  reservation  is  geographically  located
/ithin two counties. Brown and Outagamie,
ear Green Bay. The Tribe owns about one-
ilrd of the area surrounding its public wells.

Yater  Supply:  The  Tribe  operates   8
ommunity water supply wells which range in
epth from 235 to 505 feet.

lydrogeology: The main water-bearing interval
; a confined sandstone aquifer. The aquifer
jcharge area is about 10 miles west of the
jservation. Vertical hydraulic conductivities
i the confining unit are estimated at .00007
jet  per day which suggests that  recharge
ccurs at outcrop areas only.

essons   Learned:  Delineate   wellhead
rotection areas in conjunction with local land
wners and municipalities.

ontact: Steve Loritz
      Environmental Department
      Oneida Tribe of Wisconsin
      P.O. Box 3065
      Oneida, Wl 54155
      (414) 497-5812
Zuni Pueblo, New Mexico

Setting:  The  Zuni  Pueblo  consists  of
approximately 7500 Tribal members. Most live
on or near the reservation. The reservation is
located on 620 sq. mi. in w. New Mexico.

Water Supply: The Pueblo operates 8 public
water supply wells which range in depth from
600 to  865 feet.

Hydrogeology:  The wells  tap two separate
aquifers; one semi-confined and one confined,
both  sandstones  interbedded   with  less
permeable  intervals. The confined  aquifer
recharge area in the Zuni Mountains is about
25  miles away from the main population
center. Recharge to the semi-confined aquifer
may occur  through vertical leakage through
the alluvium  of the  Zuni  river. Vertical
hydraulic conductivities in the semi-confining
unit are estimated at .08 feet per day.

Lessons Learned: Ground water  protection
should  be complemented with surface water
protection activities because of the possibility
that Zuni river water may recharge the semi-
confined aquifer.

Contact: Steve Davis
       Bureau of Indian Affairs
       Zuni Agency
       P.O. Box 368
       Zuni, New Mexico 87327
       (505) 782-5592

Hoopa Valley Tribe, California
Tulalip Tribe, Washington
Setting: The Hoopa Valley Indian Reservation
is located in the rural northeastern portion of
Humboldt County, California. The reservation
consists of approximately 144 square miles
with a population of 2200 people.

Water Supply: Water  is  provided  to the
reservation from a variety of sources. Three
municipal wells representing three well fields
supply an unknown volume of water.

Hydrogeology:  Ground  water  is available
primarily from alluvial aquifers.

Lessons Learned:  The source  inventory
resulted In  the discovery  of  possible
inadequate sanitary  setback distances that
may be  related to Tribal cases of Hepatitis A.

Contact: Collen Goff
        Planning  Department
        Hoopa Valley Reservation
        Loop Road
        P.O. Box 1348
        Hoopa, CA 95546
        (916) 625-4276
Setting:  The  Tulalip Tribe Reservation  is
located near Marysville, WA.

Water  Supply: The Tribe relies solely  on
groundwater except in the southeastern corner
of the reservation.  Public water supply  is
provided by four wells located in the Tulalip
Creek basin. Well pumping rates range from
170 to 225 gallons per minute.

Hydrogeology:  The  aquifer is located at a
depth of about 100 feet. The aquifer saturated
thickness is  about  67  feet with  regional
ground  water flow  to the southeast.  The
aquifer is overlain by a 30 foot thick leaky
confining layer. Vertical hydraulic conductivity
in the confining unit is estimated at. 1 feet per

Lessons  Learned: Capture zones larger than
the 25 year time-of-travel capture lone will
extend  beyond the reservation  boundary.
However, a 25 year capture zone is more than
adequate to protect the water supply. Gravel
mining is a potential source of ground water

Contact: Gillian Middlested
         Environmental Program
        Tulalip Tribes
        7615 Totem Beach Road
        Marysville, WA 98271
        (206) 653-0220

Gila River Indian Community, California

Setting: The Gila River Indian Community is
located near Sacaton, Arizona. The community
includes four contiguous groundwater basins
(A, B, C and D) southwest of Phoenix, AZ.

Water Supply;  The Community uses 27 wells
each pumping at their rated capacity for 2 to
12 hours  per  day, year  round, totalling
approximately  11,000 acre-feet  per year.
Thirteen wells in Basin A are considered Public
Water Supply wells.

Hydrogeology:  Ground water is supplied from
a 1000 foot thick, heterogeneous, arid alluvial
aquifer  in  the  Basin and Range geologic
province. Agricultural pumpage total 138,000
acre feet from 44 wells.

Lessons Learned:  Because of the complex
hydrogeology,  it was necessary to construct
a regional ground water flow model. Individual
wellhead protection  areas  were  delineated
based on the basin wide model results.

Contact: Glenn Stark
        Water Quality Planning
        Gila River Indian Community
        PO Box 370
        Sacaton, AZ 85247
        (602) 562-3203


      Preventing contamination is the key to keeping ground water supplies safe.
Once a drinking water supply becomes contaminated, a tribe is faced with the difficult
and  costly task of installing treatment facilities or locating an alternative source.
Wellhead Protection provides the tribes with an opportunity to protect their drinking
water supplies through local community  planning. The planning program should
include the delineation of wellhead protection areas and the identification and location
of potential sources of contamination.  Other protection activities should include the
management  of the  wellhead protection area  to  minimize  the potential for
contamination and development of a contingency plan to ensure alternate public water
supplies if contamination occurs.

      The case studies described herein illustrate Tribal Wellhead Protection activities
and highlight several concerns Tribes may have in implementing Wellhead Protection.
These concerns include:

1) Ground water recharge or wellhead  protection areas that are located outside the
boundaries of Tribal reservations.

2) Intimate relationship between ground and surface water within the reservation.

3) Difficulties in implementing or enforcing a program in the absence of a Tribal judicial

      The  case study details should  be  useful in assisting Tribes to  develop  a
Wellhead Protection Program under the Safe Drinking Water Act that is tailored to their
unique set of circumstances. Case studies of successful Tribal Wellhead Programs may
include elements that are adaptable to  other Tribal  Programs.

                          Oneida Indians of Wisconsin

                          Wellhead Protection Project
The Reservation Setting
The Oneida Tribe of Indians of Wisconsin is a federally-recognized Indian Tribe consisting
of approximately 10,000 Tribal members, nearly half of whom live on or near the
reservation.  The Oneida Reservation is located near the City of Green Bay in northeastern
Wisconsin (see Figure 1 for location map).  The reservation is geographically located within
two counties, Brown and Outagamie. The Tribe currently owns and controls approximately
5,000 of the 65,000 acres within the reservation. (See Figure 2 for a Tribal ownership map).
The remaining acreage is held by non-tribal members, which makes land use planning and
natural resources management difficult.

The Tribe is organized under a Constitution which delegates decision-maMng power to the
General Tribal Council (GTC).  The GTC consists of all the adult members of the Tribe,
which every three years elects a nine-member Oneida Business Committee to handle day-to-
day decisions of the Tribe.

The Oneida Tribal water systems are operated, maintained, and managed by the Oneida
Utilities Department.  Organizationally, the Utilities Department is within the Public Works
Department which is within the Community Development Division. The Oneida Utilities
Department currently  operates eight (8) community water  supply wells which range in depth
from 235-505 feet.  These wells are located near major centers of Tribal activity.

The aquifer system  in the vicinity of the Oneida Reservation is complex and is comprised of
three aquifers and two confining beds. Most of the high capacity wells tap one or both of the
deep sandstone aquifers which are highly confined throughout the Green Bay and Reservation
areas.     -'          '        '

Wellhead Protection  Project Goals and Objectives

In 1992, the Qneida Tribe became the first Tribe in  USEPA-Region 5 to receive funds to
support a wellhead protection demonstration project.  The Wellhead Protection
Demonstration Project was undertaken to study the community water resources for the
Oneida Nation and to  develop a wellhead protection  program for the Tribe that could prevent
ground water contamination of its public water supply system.

The objectives of the project were to delineate a wellhead protection area for the 8 wells,
identify sources of contamination within the wellhead protection areas, develop a wellhead
protection management plan and possible ordinance,  and to implement a public education

Project Approach and Accomplishments

A Wellhead Protection Coordinator was hired to manage the project for the Tribe within the
Tribe's Environmental, Health, and Safety Department.

The eight wells that serve the long term needs to the community were studied to determine
the locations where "water entered into the appropriate aquifer systems.  The Tribe initially
contracted with the U.S. Geological Survey to model the ground water flow and to delineate
a wellhead protection area for the Tribe's wells.  Since the early 1950*s, the USGS had
undertaken a considerable amount of research to define the ground water system in the Green
Bay Metropolitan area which is adjacent to the Oneida reservation. Through this research,
the hydraulic properties and geometry of the aquifers and confining units underlying the
Oneida reservation were defined and mapped.  As a result, the USGS utilized a three-
dimensional ground water flow model to simulate the aquifer system.  A particle tracking
routine was  used to delineate the geographic areas contributing to the pumping areas. The
result of the USGS delineation identified a recharge area of some 30 square miles which
included land outside the reservation boundaries. The  model also demonstrated that travel
times are on the. order of 1 mile per 500 years and that the contributing areas are large and
located to the- west of pumping area wells and the reservation.  The ground water used by the
Oneida Tribe for drinking water may be over 2000 years old.

Recognizing the difficulty in protecting the land area outside the reservation boundaries, -as
well as large parcels of land owned by non-tribal entities, another approach was taken by the
Tribe to delineate a wellhead protection area. Overall, the Tribe utilized three factors in its
revised delineation. These included:

       •     Portions of the USGS model for the recharge zones for two of the well sites.
       •     A minimum 2500 foot radius around all  of the wells
       •     Portions of the main stem of Duck Creek where losing reaches were possible.

In addition, it seemed appropriate to use whole sections of the Tribal area to eliminate the
difficulty to legally describe. The resulting wellhead protection area consists of 30 sections
of land which encompass the heart of the tribal activity.  The final wellhead protection area
is illustrated in Figure 2.

Man-made features which could contaminate ground water are abundant in the wellhead
protection area. Potential sources of contamination were identified from data drawn from
USGS topographic  maps, the State's Department of Natural Resources  and Department of
Transportation files, along with data and reports in the Tribal Environmental Department.
Internally, data was verified and reviewed by the Tribe's Conservation, Public Works, and
Utilities sections.  Numerous windshield surveys were also taken to confirm: locations of
sources within the WHPA.

The sources of contamination identified range from a sewage disposal pond to auto repair
facilities.  The table below lists the sources found and the number of sites identified.  In
addition, the Tribe developed a map of all the sources identified within the wellhead
protection area utilizing the Tribe's geographic information system.  (Figure 3 illustrates these
potential sources of contamination.)

Potential Source of Contamination               Number of Sites

Underground Storage Tanks                          40 (apprpx.)
Quarries/Sand, Gravel Pits                           17
Manure Storage                                     11
Abandoned Wells              ,                      7
Leaking Underground Storage Tanks (LUSTs)           6
Junkyards                                           4
Cemeteries                                          4
Sludge Spreading                                    2

It was also found that the most widespread potential sources of ground water contamination
are not readily mappable. Agricultural operations "are vast throughout the wellhead protection
area.  Numerous septic disposal systems are also present.  A conservative estimate would
show more than 200 septic systems present with perhaps 1/3 of these in need of repair or
replacement. Currently only four sections of the WHPA are served by the Green Bay
Metropolitan Sewage District.  About four miles of railroad right-of-way cross the northern
portion of the wellhead protection area.  Above and beyond the risks associated with
accidental spills or releases, during the summer months, the edges of the railroad property
are sprayed with a chemical which turns the vegetation from a lush, green to a dead orange-

Under the project, these potential sources of contamination were evaluated and a summary of
measures that could be taken to promote ground water protection was developed.  Figure 4
illustrates the management strategies the Tribe could pursue to better protect its public water
supplies. Both Tribal and civil law approaches are identified in the management strategies

Given the highly confined nature of the wells, the Tribe was particularly concerned with
abandoned wells.  In May, 1994 a Memorandum of Understanding was formed between the
Tribe and the Wisconsin Department of Natural Resources to implement a means to
accomplish sealing of abandoned wells on non-tribal lands within the reservation.  Also, the
Tribe passed a law in September, 1994 which covers proper abandonment procedures for
Tribal lands within the reservation. (Copies of the Memorandum of Understanding and Well
Abandonment Law are attached.)

General ground water education efforts were undertaken in support of the wellhead protection
program.  Informational booklets aimed at school age tribal member were sent to teachers.
Tribal members in key roles in the Tribal Departments (Public Works, Conservation, Tribal
School) were targeted for education and outreach on general ground water protection and the
wellhead protection program. An article on the wellhead protection project was published in
the Tribe's Environmental Services Program newsletter. In addition, the Tribe distributed
hundreds of rain gauges with the inscription "Rain Today - Well Water Tomorrow - Protect
Your Groundwater!"- as a means of promoting the message of ground water and wellhead
protection. This promotional campaign was well received.

The Tribe was surprised to learn that the USGS modelling of its recharge area resulted in a
30 square mile wellhead protection area which was 10 miles west of the reservation and that
the ground water movement was very slow (10-15 feet per year). The use of travel time of
water to wells as a criteria became a moot point.  As a result of the extensive delineation
outside the reservation boundaries  they found the USGS delineation to be unimplementable.
Therefore, the Tribe refined the delineation to cover an area within the reservation

They were also pleased to learn, however, the extent to which their water supply is protected
since their aquifer systems are so highly confined.  It gave them a level of comfort that they
hadn't had before.  Due to the highly confined nature of their system, though, the sources of
greatest concern  are the abandoned wells and they recognized "the need'to aggressively
address those. As a result, the Tribe adopted a well abandonment code.

The Tribe found that a good majority of the potential sources of contamination found within
the wellhead protection area could  be regulated by ordinances already in place which contain
water protection  measures. However,, the Tribal judicial systems have never been created to
enforce these ordinances. In addition, the State siting restrictiolis are utilized by the Tribe.
Those  areas, however, 1200 feet or less around the wells were fairly small areas and were
serving as a norm for what was needed to protect the wells when further protection might be
more appropriate.

The Tribe owns only about 1/3 of  the land within the wellhead protection area. This creates
a lot of difficulty for the Tribe  to implement management on land where Oneida Tribal law
may not have jurisdiction. As a result, the Tribe has learned that they need to involve the
Towns of Hobart and Oneida, within the reservation, to properly implement the program and
to protect the Tribe's wells.

Another surprise to the Project  Coordinator was the limited knowledge and understanding by
the Tribe overall about water resource issues.  This resulted in a lack of interest and
coordination on water issues. Significant plans were underway for Green Bay Metro water
supply planning.  While local governments would usually send high level leaders to the

planning meetings, Oneida would usually send a consultant for the planning department.  As
a result of the Metro area planning, a site is being considered for future wells to support
Green Bay metro needs which would be located within the Tribes reservation.  Efforts are
underway to stimulate interest in water issues by providing Tribal legal staff with water
rights information.  All ground water to the major metro wells must pass under reservation

Bureaucratic structure and rivalry between departments is not unusual in any governmental
system.  Such is the case in the Tribal structure.  The Superintendent of Wells and Septic
Systems is placed within the Department of Buildings and Grounds.  This department exists
separately from the Tribal Utilities Section which operates the pubic water supply wells.
The Environmental, Health, and Safety Department exists as a regulatory vehicle under the
government and business divisions.  As a result, they have found that water quality issues
need to close alignment and cooperation of all the Departments and Sections.

Under their effort to educate the public on the wellhead protection program  or ground water
protection in general, the Tribe found that there were a number of resources out there that
could be used.  Nearly every public interest group (i.e. League of Women Voters) and State
system (i.e. University Of Wisconsin Extension Service) has produced pamphlets, booklets,
or videos on water quality issues. Oneida also felt that the promotional tools worked well.
They had distributed hundreds of rain gauges with the inscription "Rain Today - Well Water
Tomorrow- Protect the Groundwater !•". Other ideas they came up with to promote
groundwater protection included:  sponges to mimic the function of aquifers, straws to
suggest wells lapping the aquifer, and cups embossed with the Tribal slogan.  A good slogan
might be "Keeping the water pure is one of the first laws of life.  If you destroy the  water,
you destroy life".

Lastly, they found that regional cooperation on groundwater resource quantity and  quality is
a must for all people in Northeastern Wisconsin  and the Oneida Tribe has a role of guardian
for all concerned.

Minmopoii* «
  St. Foul*
                                                             TTeZMTX POUNDAFTf

Tribal Ownership
                                           1 Mi    2 Mi
-  March  1994
                                                        TRIBAL  OWNERSHIP
                                                   SOVEROGN NATION OF THE ONEIDA IN WISCONSI
                                                                        FK1TTRF -y

      ua Prr *
 M    H*WWK srawa AC*
 X    wise ONROewnF SIR
•    AMNBOMD wbi. sne
#'S   (JNKmnuND snmae TAWCJ

L Existing Programs
2. Land Use Controls
3. Monitoring
4. Public Education &
a. Clean Sweep -
b. On-sne waste disposal
system (septic! inspections
c. Welt Abandonment
a. Existing Zoning and
b. Land Acquisition
a. Contaminant Survey
b. Water Quality Monitoring
a. Private Well Sampling
b. Public informational
c. Presentation to Business
d. News Releases
e. Informational Materials
distributed to Residents of
f, WHPA Signs
J, Hazardous Waste Awareness
i. School Ace Children
* Hazardous waste collection
and disposal; currently once
per year
• Taiga residents of WHPAs
to participate
* Inspection & maintenance
currently required for system
owners on record.
* ERB currently assists with
* Orders issued to confirmed
failing system owners
WHPA to Notification Oats
* Conduct Public &h>rtti'?B
"•Consider sewer service for
* Well Abandonment Law
of unused wells
* Create well inventory in
.* Review existing law
Discoungc conditional uses
of zoning ckanges that
increase risk
* Provide Business Cotnmtttee
with list of Sign risk land uses
resolution to support wetmead
protection in considering
future variances

* Investigate feasibility of
purdusJiiK additional IffKf or
development rigte
* Update toe Coatstnataoon
Inventoty sod rTffflurt
wmrHhirirt survey quartet Iv
* Contact sampling of
moaitarmg wells as needed
• Coordinate with existing
County program
• Target residents in WHPAs
* Perform at beg imtiiig of
program, and yearly
* Pcffuiui early in program
* Annual spnng meeting as
* Issue early to program
implemefttanont and rciofuit^
sfmally ax npgpt^rv
* Quarterly Environmental
* Materials describing proper
use St. application of
feralizen & pesticides
* Other materials or fact sheets
describing proper use and
disposal of washes, and
protection of private wells
* Post and maintain roadway
Sims at entrance to WHPAs
* Notify and offer guidance to
owners of potential high risk
land uses in WHPAs
* Annually notify RCRA
t e$tiiaiefl tndusuics of
Wellhead Protection Plan
* Participate in scnool
Responsible Department
• Individual Volunteers
* Brown and Outagamie
* Oneida Tribal Utilities
• Tribal Plaamn? Department
* Environmental Resource
Board (ERB)
* Environmental Health
* Tribal DepnoaenB
• Wisconsin DNR-MOU
* Oneida Tribal Uttltoa and
Public Works
* Coustjf Boards
* County Boards of Adjustmeat
* County Planning Deparonest
* Oneida Public Works
* On=ida Tribal taud
ijepai tHK ot
^ OnejdB Utilities
• Enrironmeaal Quality
* Oneida Utilities
* Environmental HeaJth
* Oneida Utilities
•ERB Board
* Oneida Planning Dcparonent
* Onrida Public Utilities
* Oneida Urjlities
* Oneida Utilities
* Wisconsin DNR
•Onrida Farms
• pumamg Deuamutut Sign
•OneMa Utilities
« Wisconsin DNR
* Oneida Utilities
" Envtrontnental Pepara&ent
* Send special mailing to
advertise program annually «
* Annual clean sweep program
* Update database to include
WHPA residents
* Send request for inspection
and matntenaoce
* Request BC to study sewer
service to WHPA
* Create inventory of private
* Updttc well nnncsofy m
CTnfMctkffi with CS! update
* Seal uaMned wdls
* Pronde County Board wit&
list of high rbk Und uses and
dnft rtsotUQOii supporting
* Coraty Board and Tribe
pAiicy fgsoluiitfQ
* Evikttx possible Und or
deygjopcmc rigfai ftcquisiiioii
* oboda tad n»ipe wtier
* Send fficlmg to property
owners in WHPA
* NotJi> rtsideic m WHPA of
COUHEV frocms
* Bold politic inlonntDon
meeciag to present Wellhead
Protection Pin
* fnfofrfafjt^ffl ineetiBgs, 25
• Imnti wrws retenc
* Annul news release updaie

to spring dciii cwccp
biodsiiEs for gcoonl
dissiisstjoa "
• FtbncaieindpCfajiipttiii
* Cofifcigl iBtiling p fgtccted
• Notify/ educaas RCRA
regulated iadusines
* Pronde water plant tours
and incorporate Wellhead
Protectiott Plan topics to

                          MEMORANDUM CF •-TTDERSTAMDING

                                  aBTWEEH Tag

                   Wisconsin Zepartr.ent  rf Natural  Resources

                   The Oneida Tribe cf Indians of Wisconsin

       This Memorandum cf Understanding" !¥OU) between "CnH~WisccnsxnrSBD
 cf Natural Resources and Cneida Tribs cf Indians cf Wisconsin is an agreeme:
 between  the'"two  parties,"  in hopes cf effectively closing ail unused wei,
 within the Reservation  boundaries.   The well closure is  an actual proce:
 which is  usually done by a licensed well driller  or pump installer.  Unus<
 and improperly abandoned wells are a threat  to groundwater quality and c;
 pose  a  danger  to personal  safety.   For the  following document;  the  te:
 "Tribal Land" shall  mean all lands held in fee by the Oneida' Tribe of Indiai
 cf Wisconsin and/or  it's individual members,  and all lands held by the Units
 States cf' America .in trust for  the- Oneida Tribe  of  Indians of  Wiscons;
 -and/or it's  individual members.


      The purpose  of  the  Memorandum of Understanding  {MOU)  is to  formulate
 cooperative procedure between  the. two parties listed.   This procedure  wil
 outline* roles and responsibilities for the proper abandonment of designate
 wells on non-tribal  property within the Oneida reservation boundaries.


      This MOU shall remain in effect for one year 'from the date of execution
 It: is understood that  this MOU  may be terminated''by either.1 party,  upo
 serving a written notice to the other at their principal place, .or business
 not less- than thirty (30) days prior to the  termination date.  Our goal, is t
 develop a  long term.agreement among the parties. This document is assumed t
 be automatically renewed  each  year unless  a ' notice 'of  termination i
 submitted, by either party.


     It is understood by the parties, that  this agreement  in no way waive
 the Sovereign Immunity of  the Oneida Tribe  of Indians  of  -Wisconsin or th
United, States.  This MOU  represents  an -arrangement  between the  partie.
 intended  solely to provide for  the protection of natural  resources on th
Cneida reservation without  regard tc what  the1 jurisdiction of the partie;
r.ight  be  in the aiasence  of  this agreement.  Neither  party intends that thi,
agreement  recognize,  expand cr .restrict  the  jurisdiction that either part-
T,ay have  in it's absence.

                   f^lf? r**tTtr 'OB.'P'T""1""^
     rrcvz.de the DNR.with location descriptions of unused wells on Non-Triba.
                              Crieida  Environmental  Deuarcrsent  aiona'  wic:

     •sxac't  Lcc3.ci.ons are understood.  _£ needed  name,  address, c^c"0 ~uir.bsr
     and r.as will  be  rovided.
     in section  .-7R 112.25 of the Wisconsin Administrative Code.  Supply "
     the  /visconsin  DNR  completed  for:?.  3300-53  "WELL/DRILLHCLE/BOREHGLE
     ABANDONMENT" , upon  the  complete abandonment of unused wells located en
     tricai _and.

I .   , Aid the DNR as  requested to -assist  in coordinating this agreement.


1.    Inform the  Oneida  Environmental  Department  of  unused -well  locations
     within reservation borders, as  they become  known to the DNR.

I.    Contact non-tribal  landowners"" that are reported to  possess  an unused
     well,  to determine  compliance  with Wisconsin Administrative Code,  MR
     112.25, which governs proper abandonment of private water supply wells.

• .    Advise the  well owners on how  to  achieve  compliance with  Wisconsin
     Administrative Code, NR 112.26.

:.    Provide to  the Oneida Environmental  Department completed copies  of form'
     3300-53 upon review by  the'DNR  for  those wells ,on non-tribal  land.

:.    Share  information with the Tribe regarding  any funds available for well

:     Bring  to  the attention  of the Tribe  any related environmental  or health
     concerns  in relation to  these '.veil  closures.
'^eorge -:./
Seqrerary^bf Wisccns:
Department of Natural
.."El DA., "'71   :
?.C. BOX 7921
MAEISCN,' WI 53707

                              WELL ABANDONMENT LAW

 Arricle I. Purpose and Policy
 :-].  The purpose of :his law is to require :he abandonment or upgrading or"ail unused, unsafe or
 noncompiying wells located within the exterior Reservation .boundaries of the Oneida Tribe of Indians
 to prevent contamination of ground water.
 1-2.  The proper abandonment of wells protects public health, safety and welfare by assuring that
 unused, unsafe or noncompiying wells, or wells which may serve as conduits for contamination, or
 wells which may be illegally cross-connected to the municipal water system, are properly abandoned.

 Article H Adoption. Amendment, Repeal
 2-1.  This law may be adopted by the Oneida Business Committee or the Oneida General Tribal
 Council and effective ten (10) working days aner date of adoption.
 2-2.  This law may be amended pursuant to the procedures set out in the Oneida Administrative
 Procedures Act by the Oneida Business Committee or the Oneida General Tribal Council, regardless
 of where the original adoption took place.
 2-3. Should a provision of this law or the application thereof to' any person or circumstances be held
 as invalid, such invalidity shall not affect other provisions of this law which are considered to have
 legal force without the invalid portions.
 2-4. All other Oneida laws, policies, regulations, rules, resolutions, motions and all other similar
 actions which are inconsistent with this policy are hereby repealed unless specifically re-enacted after
 adoption of this policy'.
 2-5. This law shall apply to all Oneida Tribal entities, the Oneida Tribe, members of the Oneida Tribe
 of Indians of Wisconsin who own land within the exterior boundaries of the Reservation of the
 Oneida Tribe of Indians, residents and all entities within the Oneida Utility District and is adopted and
implemented by authority of the Oneida Tribe of Indians of Wisconsin Constitution.

Article EL  Definitions,
3-1. All words used herein shall have their ordinary meaning unless specifically defined within this
3-2. Unless  otherwise stated within this law, the following specific definitions shall apply:
       a.  "Municipal water system" means a system for the provision to the public of piped water
              for  human  consumption when such system has at least 15 service connections or
              regularly serves at least 25 year-round residents owned or operated by a city,  village,
              county, town, town sanitary district or public institution, or a privately owned water
              utility serving any of the above.
       b.  "Noncompiying" means a well or a pump installation which does not meet the provisions
              of NR 112, Wis. Admin. Code.
       c.  "Pump installation" means the pump and related equipment used for withdrawing water
              from  a well including the discharge piping,  the underground connections, pitless.
              adapters, pressure tanks, pits, sampling faucets and well seals or caps.
       d.    "Unsafe" means a well or pump  installation which  produces  water  which is
              bactericiogically  contaminated -cr  contaminated with substances exceeding the

              standards of chs. NR 809 or 140, Wis.. Admin. Code, or for which a Health Advisory
              has been issued.
       e. "Unused" means a well or pump installation which has not been in use for three (3) months
             • prior to the date of the adoption of this Law or has not had a functional pumping
              system for three consecutive,months.
       £  "Well" means an excavation or-opening into the ground made by digging, boring,  drilling,
              driving, or other methods for the purpose of obtaining groiindwater for consumption
              or other use.
    '   g. "Well Abandonment"'means the filling and sealing of a weil according to the provisions
              set out herein or by adoption within this code of §NR 1-12.26, Wis. Admin. Code.

Article IV. Abandonment Required
4-1. All wells located on premises served by .a municipal water system or, regardless of location, are
unused or of noncompiying construction, shall be abandoned in accordance with the terms of this law
and §NR 112.26, Wis. Admin. Code, unless a well operation permit has been obtained from the
Oneida Environmental Health Program within three (3) months of adoption of this law, prior to
opening a well after adoption of this law, or a renewal permit was granted within three months of
expiration of prior permits.

Article V. Well Operation Permit
5-1. The Oneida Environmental Health Program may grant a yearly well operation permit to a private
well owner to operate a well for a period not to exceed fve (5) years, providing the conditions of this
section are met. An owner may request renewal of a well operation permit by submitting information
verifying that the conditions of this section are met.
5-2. The following requirements must be met prior to granting a permit
       a.  A yearly water quality test is performed at the owner's expense.
       b.  The Oneida Environmental Health Program or its agent, may conduct inspections or have
       water quality tests conducted to obtain or verify information necessary for consideration of
       a permit application,-on an annual basis for reverification, or upon request for permit renewal.
       c.   Permit applications and renewals shall be made on  forms provided by the  Oneida
       Environmental Health Program.
5-3. The following conditions must be met for issuance or renewal of a well operation permit.
       &  The well and pump installation meet or are upgraded to meet the requirements of ch. NR
       112, Wis. Admin. Code; and
       b.  The well construction and purnp installation, have a history of producing bacteriologically
       safe water- as verified by sampling histories. No exception to this condition may be made for
       unsafe well, unless the Oneida Environmental Health Program provides the appropriate form
       for the continued use  of the well; and
       c.  There are no cross-connections between the well and pump installation and the municipal
       water-system: and
       d. The proposed use of the well and pump installation will be reviewed on a case by case
                                          2 of 3

 Article VI. Abandonment Procedures
 6-1. All wells abandoned under the jurisdiction of the Oneida Tribe of Indians of Wisconsin shall be
 abandoned according the procedures and methods set out herein and supplemented in §NK 1,12.26,
 Wis. Admin. Code.  Provided that, any notification within the state regulation shall be superseded and
 integrated as reasonable with the notification procedures herein.
 6-2.  Thfi.awneiLQf the vvell,_oijh5.p3vners_ager4li_shal[_nqtiA' the_Oneiaa Environmental Health
 Program at least 48 hours 'prior to the commencement of any well abandonment activities.  The
 abandonment of the well may be observed by the Oneida Environmental Health Program, or its
 designated agent.
 6-3. A well abandonment report will be completed and submitted by the owner's agent, to the Oneida
 Environmental Health Program within 10 days of the completion of the_weil abandonment. The well
 abandonment report form is available from the Oneida Environmental Health Program.
 6-4.  All debris, pump, piping, unsealed liners and any other obstructions which may interfere with-
 sealing operations shall be removed prior to abandonment.

 Article VH. Penalties
 7-1-. Any well owner or agent violating any provision of this law shall be subject to forfeiture of not
 less that S100 nor more than 51,000.  Each day of violation is a separate forfeiture.  Provided that
 each forfeiture be proven individually.
 7-2. Failure to comply with this law within1 ten (10) working days after receiving written notice of
 this violation, the Oneida Tribe may impose a penalty and  cause the well abandonment to be
 performed at the expense of the well owner.
 7-3, The Oneida Environmental Health Program is  authorized to bring all civil forfeiture hearings
 before the Oneida Environmental resource Board as the Original Hearing Body. Provided that notice
 and hearing procedures are conducted as directed by the Oneida Administrative Procedures Act.
 7-4. It shall be a valid defense to any continuing forfeiture that the. weU owner has begun procedures
 to abandon the well and shall be by sworn affidavit that notice has been presented to the Oneida
 Environmental Health Program of approved well abandonment procedure.
 7-5. Appeal from 'any final, written, judgment shall be made within five (5) working days of notice
 and may be made by either party.
 7-6. No forfeitures accumulate after a civil hearing is begun fay filing a request for forfeiture with the
 Environmental Resource Board,
 7-7. Forfeiture collected under this law are  to forwarded to  the Accounts Receivable  Office for
 placement in the General Tribal Funds.

 Article VTjEI. Conflict with Federal Law
 8-1. Should any part of this law be found to be in conflict with federal requirements which  are
required in order that the Oneida Tribe of Indians receive federal funds, the conflicting section of this
law is to be considered inoperative only for the purpose of the particular funding and that particular
conflict.  Provided  that any consideration in regards to federal funding does not undermine  the
purposes and policies of this law: Such conflict  shall not affect the operation of the remainder of this
law in its application to those agencies or department directly affected.
                                          3 of 3


                     BY  Jane Marshall Farris, Hydrologist
                EPA Office of Ground Water and Drinking Water
                             Washington, D. C.


      The EPA Wellhead Protection Program allows States and Tribes to differential
manage source of contamination within delineated wellhead protection areas. The
delineated area may be based on  the hydrogeologic properties of the aquifer or may
be chosen simply by inscribing a circular area surrounding a well. The Zuni case study
is an example  of a delineated  wellhead protection area based  on the hydrogeologic
properties of the aquifer.

      Zuni Pueblo obtains its public water supplies (PWS) from two  aquifers:
sandstones in the Chinle Formation (Triassic Age) and the San Andres- Glorieta aquifer
(Permian Age). PWS wells completed in the Chinle Formation include F1, F2, F3 and
F4 located in the vicinity of the Zuni Village and Z4 and Z7 located northeast of the
village (Straille, 1993). Two PWS wells completed in the San Andres-Glorieta Aquifer
are located in the  Black Rock Community:Black Rock Public Health Service Well - BR
PHS well, and well B4* (Strallie, 1993).  Additionally, the U.S. Geological Survey
(1991) and  Molzen-Corbin and Associates (1991) have  completed studies in the
southern part of the Pueblo and recommended a drill site near Ojo Caliente for two
additional San  Andres-Glorieta aquifer wells.

Delineation Approach for Chinle PWS Wells

      The Chinle  Formation underlies most of the Pueblo lands and is composed of
an upper grayish  to reddish brown mudstone and siltstpne with some interbeds of
lenticular sandstone  (600  feet), about 100 feet of a grayish  to brown sandstone,
conglomerate, siltstone and mudstone shale middle unit (Sonsela Sandstone Bed), and
a lower 600 feet of grayish to reddish to purple  mudstone and siltstone (Orr, 1987).
Lenses of sandstone in the Solsela Sandstone Bed and in the upper part of the Chinle
contain water for  Zuni's PWS at Zuni Village.  Some of these wells penetrate several
sandstone zones (see table 1). Additionally, the Chinle Formation outcrops north of
well Z4 and provides some recharge to the aquifer.

      •     The Chinle Formation is considered  to be a semi-confined porous aquifer
            in the vicinity of Zuni  Village.  The issue of whether the aquifer is
            confined or semi-confined is subject to professional judgement, however,
            overlying saturated alluvium and silty Chinle units could provide some
            leakage  to the sandstones. Abandoned or improperly cased boreholes
            may  provide conduits for contaminants.

      •     There is a small amount of fracturing in the vicinity of the village and
            extensive fracturing in the vicinity of wells  Z4 and Z7 (Tom Crouch,
            Personal Communication). The fracturing increases transmissivities but

           may not significantly affect vertical leakage to aquifers.

           The suggested EPA delineation approach includes: 1) criteria of Time-of-
           Travel; 2) the thresholds for the time-of-travel criteria are 5 and 10 years,
           and the method is  the  EPA semi-analytical flow model  (analytical
           method), WHPA 2.0.  Due to the close proximity of wells Z4 and Z7 to
           a Chinle recharge area, hydrogeologic mapping methods are suggested
           also to delineate the recharge area.

           The EPA WHPA Model 2.0 was  selected to determine  the zone of
           contribution to the well for 5 year and 10 year time frames.  The model
           uses semi-analytical equations to determine the zone of contribution to
           a well or group of wells over a selected time frame and can be used for
           confined, unconfined, and semi-confined porous flow aquifers. Aquifer
           mapping completed by the USGS  (Brennan Orr, 1987) delineates the
           Chinle recharge area  located close to the Z4 and Z7 wells.

           Five and 10 year time-of-travel zones were determined  for wells F1
           through F4, Z4 and Z7. The zones become the wellhead protection areas
           (WHPAs) in which the Pueblo  will seek  to  manage  use of possible
           sources of  contamination. The WHPAs for each well have been drawn
           on the topographic maps.

           Table  1 (attached) lists data  which was input into the model. In the
           absence of data, hydrogeologic  texts were consulted  to input an
           estimated value. Printouts as diagrams of some of the computer runs are

           The Wellhead Protection Program is available for management of known
           contaminant sources for  protection of ground water used for drinking
           water.  The proposed  WHPAs  may  be modified  as additional  data
           becomes available. Additionally, professionals cannot precisely predict
           that no contamination will reach a well over a given time frame in a given
           WHPA. HydrogeologyIs a complex science and professionals rarely have
           data complete enough to thoroughly understand ground water flow and
           contaminant transport mechanisms in an area.
Delineation Approach for San Andres-Glorieta Aquifer PWS Wells

      The  Glorieta  Sandstone  formation  and the  San  Andres Limestone  are
hydraulically interconnected as  one aquifer (as much as  300 feet thick)  due to
fracturing at the Zuni Pueblo (Crouch, 1991, and Orr, 1987).  Recharge areas (outcrop
areas) are located in the Zuni Mountains (mostly northeast of the Pueblo) and along
basalt covered subcrop areas located along the channel of the Zuni River. The aquifer
may be recharged directly by infiltration of precipitation and surface flows across the
outcrop and subcrop areas.  Wells completed in  the aquifer are under  confining
conditions.  Two  main springs which issue from the aquifer, Rainbow Spring and

Sacred Spring, have been developed for irrigation, religious, domestic and recreational
      *     The San Andres-Glorieta Aquifer is  confined aquifer except where it
            outcrops in the Zuni Mountains and in the vicinity of Ojo Caliente. Wells
            drilled in and near Black Rock penetrate the aquifer at depths of about
            800 or 900 feet.  Recent wells drilled south of Zuni Village near Ojo
            Caliente penetrated the aquifer at depths of about 600 to 650 feet.

      *     Besides the fracturing, the San Andres Limestone contains karst features
            including sinkholes and caves. Transmissivities are very large (see Table

      *     The selected EPA delineation approach for the confined aquifer includes;
            1) aquifer  boundaries criteria, 2) thresholds which include the well
            construction zone, well house, fence around the house of 100 feet
            radius, and determination of the existence and extent of all recharge
            areas on the Pueblo, and 3} use of the hydrogeologic mapping method
            for delineation of all recharge areas (already completed by USGS). Basalt
            subcrops along the Zuni River will also be delineated as recharge areas.

      *     The aquifer is considered to be truly confined although wells should be
            properly constructed, properly grouted and should have a concrete pad
            around the  casing to eliminate contaminants running down the wellbore.
            Direction of ground water  flow m very complex and  subject to the
            location of  karst features, faults and fractures in the aquifer.

      *     Recharge areas which are located in unpopulated and undeveloped areas
            (such as the Zuni Mountains) may need few if any management controls.
            Additionally, to test the aquifer as a truly confined aquifer, the Pueblo
            will need to verify that old or abandoned San Andres-Glorieta wells are
            properly plugged or sealed to prevent contaminants from entering them
            and traveling to a pumping well.

      *     Table 2 (attached) lists data which was considered before selecting this
            delineation  approach.  Additionally  USGS was consulted regarding
            location of  the new wells and possible sources of contaminants (Tom
            Crouch, personal Communication).

      *     The Wellhead Protection Program is available for management of known
            contaminant sources for protection of ground water used for drinking
            water.  The proposed WHPAs may be modified as additional data
            becomes available. Additionally, professionals cannot precisely predict
            that no contamination will reach a well over a given time frame in a given
            WHPA. Hydrogeology is a complex science and professionals rarely have
            data complete enough to thoroughly understand ground water flow and
            contaminant transport mechanisms in an area.

TABLE 1; PARAMETERS USED IN EPA Delineation Characterizations
  Triasslc Chinle Aquifer, Zuni Pueblo, West-Central New Mexico
Input VALUE/ Information
Delineation Criteria,
Thresholds and Methods
as described in EPA
Zuni PWS
Triassic 'Chinte FM.t
semi-confined porous
5-10 year Time-of-
semi-analytical method:
and hydrogeologlc
mapping method
(recharge area)
4' Modeled
F1 - 70, F2 - 50
F3 '- 50 F4 - 50
20fV1mi =.004-area
near F1;
190 degrees
about 15% near Zuni
F2 180'»20'; 320-.20';
F3 244,15; 516',40;
F4 61 OTotal depth,
not modeled in area,
some discharge to Zuni
River near Zuni; Chinle
outcrops north of Z4
and Z7
5-10 Years
5-10 Years
.08 ft/day estimate for
overlying muddy
Zuni PWS
Triassic Chinle FM.,
fractured and porous
aquifer near Pinon
Springs Anticline
5- 10yearTime-of-
method: WHPA-
GPTRAC model and
hydrogeologic mapping
method (recharge
2 Modeled
Z4 - 680-780
25% near Z4 and Z7
Z4 210', 90';
Z7 210'? and 90?
not modeled in area,
some discharge to
Zuni River near Zuni;
Chinle outcrops north
of Z4 and Z7
5-10 Years
5-10 Years
.08 ft/day estimate for
overlying muddy

Assumption only - for
conservative estimate:
20 feet
Assumption only - for
conservative estimate:
20 feet
(GPTRAC Model)
X= 4000 Y=3800 F1
X= 3550 Y=2900 F2
X= 4300 Y=7000 F3
X= 2200 Y=6400 F4
X= 2750 Y=2500 Z4
X=2650 Y=2000
RATE, FT**3/day, WELL
1.45gpm=8662.$, r=4
2.80gpm=15,400, r=4.5
3.30gpm=5775, r=3
4.50gpm=9625, r=5
1.  Z4-70gpm=13475,
2.  Z7-190gpm =
36,575, r= 4?
APPROX. F1-22.6
F2 35.4
F3 43.4
F4 flowing
Z4 35.2

   TABLE 2:  PARAMETERS USED IN EPA .Delineation Characterizations
Zuni Pueblo, West-Central New Mexico, Permian San Andres/Glorieta Aquifer
Input VALUE/ Information
Delineation Criteria,
Thresholds and Methods
as described in EPA
Black Rock PWS || Ojo Caliente Area
Permian San Andres/
Glorieta, Confined
criteria/threshold: area
immediate surrounding
well and recharge areas;
methods are
hydrogeologic mapping
and protection at
2 studied
BR PHS 30 - 140
BR3 - 300
938, 237' PHS
810/250' BR3
Ojo Caliente Monocline
may be a barrier to flow
to the Southwest,
recharge in the Zuni
Mts. (Zuni Uplift)
NA/ delineation of
recharge areas and area
close to well
well is properly
constructed, grouted,
proper well pad, well
house and fence around
well to prevent
contamination flowing
from the surface
Permian San
criteria/threshold: area
immediate surrounding
well and recharge
areas; methods are
hydrogeologic mapping
and protection at
2 studied
Proposed new wells:
NewWelM: New
(ZS1 -estimated 16,000
- 24,000 for Fractured
and Karst Aquifer,
ZS2, ZS10, ZS11, ZS13
are Karst,
ZS12 - Fractured
About 609 - 865 (est.
from ZS-1 information)
Ojo Caliente Monocline
may be a barrier to flow
to the Southwest,
recharge in the Zuni
Mts. (Zuni Uplift)
NA/ delineation of
recharge areas and
area close to well
well is properly
constructed, grouted,
proper well pad, well
house and fence around
well to prevent
contamination flowing
from the surface

PUMPING WELL locations
RATE, FP*3/day, WELL
Chinle contains interbeds of siltstone and
mudstone, K of each bed ranges, approximate K =
Both alluvium and Chinle (interbedded siltstones
and sandstones) are overlying to an approximate
depth of 800 - 900 feet below land surface
BR 3 10.1 9.24.1 22b
PHS150gpm= 28,875
BR3 50 gpm = 9625
PHS 279
BR3 168.3
New Well 1 and New
Well 2: 8.19.29
up to 1000gpm
for each well
est. 489


Crouch, Thomas M. 1991. Evaluation of the Bidahochi and San Andres - Giorieta
Aquifers on Parts of the Zuni Indian Reservation, McKinley and Cibola Counties, New
Mexico: U.S. Geological Survey WRIR 89-4192. 48 pages.

Crouch, Thomas M. 1993. Personal Communication. U. S. Geological Survey, New
Mexico District Office, Albuquerque, New Mexico.

Edaakie, Strailie. 1993. Personal Communication. Zuni Water Utilities Administrator.
Zuni Village at Zuni Pueblo, New Mexico.

Freeze, R.A., and Cherry, J.A. 1989. Groundwater: Englewood Cliffs, N.J., Prentiss-
Hall. 604 pages.

Lohman, S.W.  1972, Ground-water Hydraulics: U.S. Geological Survey Professional
Paper 708. 70 pages.

Molzin-Corbin  & Associates. 1991. Pueblo of Zuni, New Mexico, Water System
Evaluation Project, Phase I: Consultant's Report to the Pueblo of Zuni.

Orr, Brennan. 1987. Water Resources of the Zuni Tribal Lands, McKinley and Cibola
Counties, New Mexico: U. S. Geological Survey WSP 2227, prepared in cooperation
with the Pueblo of Zuni, 76 pages, 2 plates.

Salote, Gerald. 1993. Personal Communication. Indian Health Service, Public Health
Service Hospital Environmental Unit, Black Rock at Zuni Pueblo, New Mexico.

U. S. Environmental Protection Agency,  1987, Guidelines for Delineation of Wellhead
Protection Areas: U.S. EPA Office of Ground Water Protection, EPA 440/6-87-010.

U.S. Environmental Protection Agency. 1991. WHPA 2.0, A Modular Semi-Analytical
Model for the Delineation of Wellhead Protection Areas: Contractor's Model/Report for
EPA Office of Ground Water Protection.


                       P.O. Box 1348

                      Hoopa, CA 95546


                        WELLHEAD PROTECTION PROJECT

The Reservation Setting

The Hoopa Valley Indian Reservation is located in the rural northeastern portion of Humboldt
County, California (see Figure 1 for a location map).  The Reservation is square shaped with
sides measuring approximately 12 miles in length.  The Hoopa Valley lies near the center of the
Reservation and is bisected by the Trinity River which  flows into Klamath River near the
reservation's northern boundary.  It is believed that the valley was virtually  carved from the
Klamath Mountains by the Trinity River over geologic time.  Outside of the  valley itself, the
reservation terrain is best described as mountainous, ragged, and heavily forested. This beautiful
valley and surrounding areas has been the home of the Hupa People since time immemorial.

The Hoopa Valley Tribal Council, the official governing body  of the Hoopa Valley Tribe, was
first formally organized under a constitution and bylaws on November 30, 1930.  The Tribal
Council, like any emerging government, has evolved into a state of sophistication. Expanding
from a staff of one in 1967, the Hoopa Tribal Government is now the third largest government
in Hiimboldt County.  Currently tribal operations  employ  over 250 people  in some  30
departments/entities. The Tribal Council consistently seeks ways to better serve its constituency
and the community at large.

The reservation population, according to the Census  1990, is 2,199.   While the Reservation
encompasses over 90,000 acres, the population is concentrated within the approximately 3,500
acre valley floor. Today, as in historic times,, the majority of the populated areas are situated
along the Trinity River on a series of broad terrace -deposits.  There are  six major tributary
streams within the Reservation.  The terrace deposits which form the valley floor are isolated by
either streams flowing into the river or  bedrock, resulting in nine separate fields.  Based  on
limited geological information, the  fields are believed hydraulically independent of each other.

Water is supplied to the reservation population by the  Hoopa Valley Public  Utilities District
(PUD) distribution system, private surface water systems, and private wells.  Currently, the PUD
supplies water to the various fields through a single water system. This single distribution system
has recently been formed by connecting two formerly separate systems on the east and west sides
of the Trinity River.  Primary sources of water for the PUD system are small diversions  on
several major tributary streams and three municipal wells in three separate fields. There are an
unknown number of private surface water systems on minor streams within the Reservation and
over 120 known private wells within the valley floor area.

                                                              FIGURE 1 - LOCATION MAP
                                                      PACIFIC OCEAN
                                                       Humboldt B«y
                                                                    HUMBOLDT COUNTY

 Resource Management

 The Hoopa Valley Tribe is one of the original ten tribes selected for participation in the Federal
 Self-Governance Demonstration Project. This opportunity was viewed as a vehicle for the Tribe
 assume  greater responsibility  for  the  management  of it's natural and cultural  resources.
 Continued participation  in the project has allowed the Tribal Council to  determine  internal
 priorities, redesign certain programs previously operated by the Bureau of Indian Affairs, and
 reallocate resources to more effectively meet the needs of our unique  community. It is felt that
 participation in the Self-Governance Project has served to strengthen  the Tribal commitment to
 the full  assumption  and re-establishment of sovereign  authority in  governing all aspects  of
 reservation resource management. Additionally, the benefit of informed and prudent judgement
 in matters of resource management  and protection  being best made at the local level has been

 The self-governance policy of Tribal administration of resource management as a sovereign state
 coincides with the EPA policy  of promoting self-determination in Tribal management  of
 environmental issues  on Indian lands.  The Hoopa Tribe  has had the  pleasure establishing a
 positive  working relationship with EPA Region IX staff  and becoming actively involved  in
 managing the reservation's water resources through receiving EPA recognition for Treatment  as
 a State and grant funding for the purposes of Section 106 of the Clean Water Act. Initially, the
 Tribal Council found this funding opportunity timely and extremely appropriate.  The 106 grant
 program has since proven very helpful  in assisting the  Tribe in their goal  of providing wise
 stewardship of land and resources. It has also served to assist in understanding and working with
 multi-jurisdictional issues concerning the Trinity and Klamath River basins.  Program funding has
provided a mechanism to pursue the collection of baseline data  necessary for prudent basin
planning. The dual focus of the program has been the  assessment and protection of reservation

Responsibility for management of water resources on the Hoopa Valley  Reservation is  principally
vested with the Hoopa Valley Tribal Council.  Acting under their direction, the Tribal Planning
Department is responsible for overall planning related to maintenance  of clean water supply,
proper disposal of hazardous wastes  and sewage, and protection of the Trinity River within the
Hoopa Valley.   The Hoopa Valley  Public  Utilities District (PUD) distributes water for both
domestic use and irrigation. The Tribal Fisheries Department is concerned with the quantity and
quality of water in the Trinity  River, its tributaries that originate within or  flow through the
Reservation and the  suitability  of that water for the fish species  of  cultural and commercial
interest  to  the Tribe.  The Tribal Forestry Department provides management oversight for
silvicultural activities  which have  the potential  to impact water quality.

Preliminary Wellhead Protection Activities

Initial steps to develop  a Wellhead  Protection (WHP) program were included in the Tribe's
Section 106 program work plans in FY 91 and FY 92. An operational goal of the FY  91 Section
 106 project was to establish preliminary  wellhead protection areas  for  the entire recharge areas

 associated with the three public water system supply wells. The direct field approach was used
 to establish the areas, incorporating no-flow constant head boundaries, stream terrace bedrock
 boundaries,  and topographic divides as ground  water divides.   The preliminary wellhead
 protection areas were clearly based on limited -information which provided, at best, an overview
 of the geologic structure, aquifers, and ground water resources.   Continued  work in FY 92
 provided a general sense of ground water movement in the  three fields containing municipal
 wells, somewhat more detailed  ground water modeling for one field,  and  very  detailed
 information  including  aquifer  constraints, ground  water surface movement,  and chemical
 characteristics in one field.

 General  activities and sources within the Reservation with the potential for contamination were
 listed, based on federal guidelines (General sources of ground water contamination modified from
 EPA Wellhead Protection Programs: Tools for Local Governments; U.S. EPA,  1989c).  Within
 these categories, known and suspected contamination point sources potentially impacting wellhead
 protection areas were  listed.   That inventory  provided an  overview of past  and future
 contamination potential, and the basic information for prioritization of sites, and design of a
 continuing control program.

 Decreasing funding levels and increasing work loads prevented wellhead protection activities from
 being included in the Section 106 program FY 93 work plan.   Without the aid of additional
 funding, WHP would have remained hi the initial stage of development. Fortunately, the Hoopa
 Valley Tribe's application for a Wellhead.Protection Project grant was selected for the award of
 additional FY 93 funds for groundwater activities.

 Wellhead Protection Project Goals and Objectives

 With the area and resource to be considered in the project, a choice had to be made on activities
which could realistically be accomplished.  The choice was to complete limited activities over
a broad area with a concentrated focus on a small area of particular concern.  The project goals
 and objectives were developed accordingly.  The first and foremost goal of the project was to
further the development of elements which contribute to a complete Wellhead Protection Program
for the Hoopa Valley Indian Reservation.  The project objectives are listed below.

    1. Demonstrate utilization of a local resource priority system in the decision making
       process by affording characterization of and focused management on high priority
       areas currently contributing to the public drinking water  supply.

    2. Expand management capability by providing the mechanism for coordinating the
       functions of all Tribal entities which are responsible for protection of ground water

    3. Provide the regulatory structure for protection of ground waters that supply wells
       which contribute water to the local domestic distribution system through ordinance

    4. Reduce the risk to human health by establishing the base level requirements for
       management of potential contamination sources.

    5. Document the Tribe's undertakings,  progress, and problems  encountered  in
       sufficient detail so that this project might serve as a model for other reservations
       or rural  communities with  characteristics similar to the Hoopa Valley Indian
       Reservation and/or the Hoopa Valley Tribe,

    6. Encourage public participation and support for WHP by providing information and
       education on improving management practices and limiting activities which might
       contribute to sources of ground water contamination.

Project Approach and Activities

Initially, the project concept called for hiring  a consultant to complete  much of the proposed
work.  Upon further discussion with EPA Region IX staff, it was determined that it would be
more beneficial  to the Tribe to hire a full time employee for the one year project duration. A
Tribal member, concurrently enrolled, as  a part tune student in the Engineering program at
Humboldt State University was hired as the project coordinator.  This young man, who is actively
involved in cultural and religious ceremonies, brought a culturally sensitive perspective project.
Specific tasks assigned to the project coordinator included:

              -  classification of groundwater resources

              -  comprehensive mapping of contamination sources

              -  delineation of WHP areas for all municipal wells

              -  development of a WHP ordinance

              - public outreach/education

              -  documentation

A resource team consisting of members from the Tribal PUD, Fisheries, Forestry, and Planning
departments was established.  The intent of the resource team approach was to fully utilize all
available/applicable  Tribal expertise.   Responsibilities  of the resource team included the

              - provide technical guidance to the project  coordinator

              -  identify existing studies beneficial to the project

              - decide goals for classification

              - decide goals for delineation

              - define/clarify interaction of Tribal agencies

              - provide recommendations for ordinance development

              - define/develop ordinance enforcement responsibilities

              - determine need for additional management techniques

Tribal Forestry's GIS Technician was also slated for membership on the resource team. All GIS
data capture and mapping functions were scheduled to be completed in-house. A staff turnover
within the Forestry Department near the start of the project prevented the in-house completion
of much of the scheduled GIS work. A consulting firm specializing in GIS services was located
in Eureka, CA; approximately 60 miles away. A contract with Geographic Resource Solutions
was initiated for completion of the planned GIS data capture and mapping.

A "Watershed Approach"  was adopted  early on in the  project.   Surface water  diversions
contributing to the public water supply as well as the  interconnection between reservation's
surface and ground waters indicated the need to classify waters and delineate protection areas
throughout the entire watershed.

Project Outputs and Benefits

The Hoopa Valley Tribe's Wellhead Protection Project was designed to serve as an intermediate
step toward, as well as an integral part of,  a comprehensive local ground water  protection-
strategy.  While  we are fully aware that this  project falls  short of a comprehensive  Wellhead
Protection Program, we feel that we have been successful in achieving the intermediate step
which provides the basis for future development and expansion of wellhead protection activities.
Specific project outputs and associated benefits are the following:

    1. Valley Wide Classification of  Water Resources:

       In accordance with EPA's ground water protection strategy, a differential protection policy
       was adopted with the recognition that different ground waters merit different levels of
       protection.  The classification categories were identified as:  Class I - Special  ground
       waters; Class II - Current or potential sources of drinking water; and Class III - Ground
       water not considered potential sources of drinking water. This classification was expected
       to establish a common goal for preventive and remedial ground water protection activities.
       Given the large number of known wells and the area's geologic characteristics, all ground
       waters were classified as Class II, current or potential sources of drinking water.

   In line with a watershed  approach,  all reservation  streams  were classified with the
   assistance of the Tribe's Hydrologist. Three stream classification categories were utilized:
   Class I Streams - domestic water supplies, known drinking water sources; Class II Streams
   - known irrigation and potential drinking water supplies; and Class III Streams - seasonal
   runs and streams not used for domestic purposes. A GIS layer for the entire watershed
   was completed using this classification system. While not reduced for inclusion in this
   summary, a hard copy of the  mapping could be made  available if requested.   This
   mapping and classification system is currently being used to identify drinking  water
   sources located within forest management planning areas.  Benefits are currently being
   realized in the form of identification and provisions protection of drinking water sources
   within the Tribe's 1995 Timber Sale Planning Area.

2. Location and Mapping of Wells and Septic Tanks:

   A  door-to-door survey was conducted to identify and locate  existing water wells and
   septic tanks within the valley. The number of single family dwellings on the Reservation
   exceeds 840.  Each housing unit was visited and the owner/occupant contacted to identify
   the location of septic tanks and water wells. Copies of all well drilling reports on file
   were obtained to aid in the mapping of comprehensive well data. Separate GIS layers for
   wells and septic tanks were completed.  Transparencies of those layers are provided in the
   back cover pocket of this report.

   This  output has  several associated benefits.  Septic  tanks  and/or areas containing
   concentrations of septic tanks viewed in relation to active drinking water wells presents
   a fairly clear picture of contamination potential and  serves as an indicator of potential
   health hazards.  Several community residents have contacted Tribal environmental staff
   for information regarding individual wells.  The information can and will be utilized as
   a planning tool for siting housing  development projects, septic tank  placement, or
   designing alternative sewage  treatment/disposal facilities.  In recent months, the Tribal
   Health Clinic has treated numerous cases of hepatitis.  Current plans are to conduct an
   analysis of the hepatitis cases with regard to patient usage of drinking water wells located
   in  areas also containing septic tanks.

3. Mapping of Soil Types, Hazardous Waste Sites, and the 100-Year  Floodplain:

   Soil  types and boundaries, as identified in a soil survey conducted by U. C, Davis in
   1976, were used to complete a GIS layer.  This information will be utilized for land-use
   planning purposes.  Certain soil characteristics typically indicate best or desired uses for
   certain parcels within the valley as well as the likelihood of septic tank failure.

   Several hazardous waste sites and areas of potential contamination within the valley have
   been  documented;  The majority  of these sites are  the results of milling and mining
   operations which were conducted in years past.   A detailed inventory of such sites,

   completed under the Tribe's Clean Water Act Section 106 program, has been used to
   complete a GIS layer.  This coverage, when viewed in conjunction with existing wells
   reveals that active  wells  are physically located within or near  known sources of
   contamination. This mapping will provide a current inventory and as such a valuable tool
   for informed WHP decision-making and future development of contingency plans.

   The 100-year floodplain as delineated by the Corp of Engineers was used to complete a
   GIS layer.  This coverage provides information beneficial to land-use planning, housing
   development, and installation of new septic tanks.

   Transparencies of these three  GIS layers are provided in the back cover pocket of this
   report.  Although the scale and detail of the mapping provided herein is greatly reduced,
   they will provide a good overview of GIS capabilities and uses.

4, Delineation of WHP Areas For All Municipal Wells:

   Utilizing information gained from the field investigation, the preliminary WHP areas
   developed  under the Section  106 program were  refined and transferred to the GIS
   database.  This mapping might be viewed separately or overlain with the contamination
   source mapping.  This element constitutes an integral part of WHP.

5. WHP Ordinance Development:

   A Tribal Wellhead Protection Ordinance was drafted through the joint efforts of the
   project coordinator and the management team. The draft ordinance was presented to the
   Tribal Council on 10/16/94 and routed through the Tribe's Legislative Procedures Act
   (LPA).  The LPA allows for review by all Tribal departments/entities,  legal review by the
   Tribal Attorney,  and public comment.   A public hearing on the proposed Wellhead
   Protection Ordinance was conducted on  10/6/94. All comments/suggestions received to
   date have been incorporated into the draft, where appropriate.  A  copy of the WHP
   Ordinance, still in draft form, is included, as Appendix A.  At least one additional public
   hearing on  the revised draft will be  conducted prior to formal action  by the Tribal

   The Wellhead Protection Ordinance, once formally adopted by the Tribal Council, will
   provide the regulatory structure for long-range management and protection of wellhead
   protection areas.  The primary purpose of the ordinance is to promote the health, safety,
   and general welfare of the community by ensuring an adequate quality and quantity of
   drinking water for the residents, uistitutions,  and businesses of the Hoopa Valley Indian

6. Public Outreach/Education:

   Information and education on WHP activities were provided by the project coordinator

through several methods.   Public Service Announcements and call-in programs were
broadcast by the Tribally owned and operated Public Radio Station,  Informational fliers
were posted on community bulletin boards.  Informational brochures were mailed to all
reservation residents. A public hearing was conducted to hear community comments and
concerns regarding the first draft of the WHP Ordinance.

Public support for the WHP program has been encouraged through  an  open flow of
information.  Since public opinion, particularly in our community, can have substantial
impacts on the success or failure of any project, education is considered a vital element
of WHP implementation.

           Appendix A


                                  of the
                          HOOPA VALLEY TRIBE
                           HOOPA, CALIFORNIA
                                TITLE 37
                       HOOPA VALLEY TRIBAL CODE



WHEREAS:  The Hoopa Valley Tribe adopted a Constitution and Bylaws (Tribal
            Constitution) on June 20, 1972, which was approved by the
            Commissioner of Indian Affairs on August 18, 1972, and ratified and
            confirmed by Congress on October 31, 1988 in Section 8 of Public Law
            100-580, and amended  on June 19, 1990 and, by tribal law, the
            sovereign authority of the Tribe over the matter described herein is
            delegated to the Hoopa Valley Tribal Council, acting by law;  and

WHEREAS:  The Tribal Council has concluded that it is necessary to exercise tribal
            authority over wellhead protection within the exterior boundaries of the
            Hoopa Valley Indian Reservation, and over other activities in order to
            protect fundamental tribal ceremonial, property interests, water quality,
            and the public health and safety; and

WHEREAS:  Pursuant to the review process set forth in the Legislative Procedures
            Act Section 6.3, the Council concludes that it is now appropriate to
            enact said Ordinance on a permanent basis,  following public hearing,
            and as revised in light of departmental comments and legal review
            developed during the review process.

THEREFORE BE IT NOW ORDAINED THAT: Pursuant to  Section 6.3 of the
            Legislative Procedures Act, and the tribal constitutional and legal
            authorities recited herein, the Tribal Council hereby enacts the attached
            Wellhead Protection Ordinance, in order to protect the fundamental
            tribal values identified in Section 37.0 thereof and the Tribe's sovereign
            governmental authority.

ORDINANCE No.:  3-94                                                 DRAFT
BE IT FURTHER ORDAINED THAT: The Tribal Council hereby reaffirms its intent
             that the provisions of this Ordinance be enforceable against all persons
             and businesses residing  or operating within the exterior boundaries of
             the Hoopa Valley Indian  Reservation  and on all land whether trust, fee,
             or otherwise,

BE IT FURTHER ORDAINED THAT: It shall be the policy of the Tribe and its
             authorized entities and departments to vigorously enforce the provisions
             of this Ordinance exclusive of other inconsistent laws.

37.0.1  Short Title. This Ordinance shall be known as the Wellhead Protection
       Ordinance of the Hoopa Valley Tribe,

37.0.2  Findings. The Tribal Council hereby finds that wellhead protection is a pro-
       active approach to managing public groundwater supplies focusing on
       preventing contaminants from entering recharge areas to public water supply
       wells.  Protecting  wellheads involves:  knowing the location and boundaries of
       the recharge area; identifying any potential sources of contamination in the
       recharge area; controlling those potential sources to prevent the release of
       contaminants; and, controlling future land use in the recharge area to prevent
       activities which are known to threaten  groundwater quality.

37.0.3  Purpose. The purpose of this Ordinance is:

       A.  To promote the health, safety, and general welfare of the community by
          ensuring an adequate quality and quantity of drinking water for the
          residents, institutions, and businesses of the Hoopa Valley  Indian

       B.  To preserve and protect existing and potential sources of drinking water

       C.  To conserve the natural resources of the Hoopa Valley; and,

       D.  To prevent temporary and permanent contamination of the environment.

37.1   SCOPE

       The provisions of this Ordinance shall apply to all wellhead protection areas
       within the exterior boundaries of the Reservation, to all persons and

       businesses on the Hoopa Valley Indian Reservation, to all land.trust or fee,
       and to all activities in areas with the potential to affect water quality, public
       health and safety, and other fundamental interests of the Tribe.


37.2.1  Aquifer means any geologic formation capable of yielding a significant amount
       of potentially recoverable water.

37.2.2  Impervious Barrier means any material or structure on, above, or below the
       ground that does not allow precipitation or surface water to penetrate directly
       into the underlying surface,

37.2.3  Mining means any activities designed for the extraction of minerals.

37.2.4  Recharge Area means areas that collect precipitation  or surface water and
       carry it to aquifers.  Recharge areas may include areas designated as Zone 1.

37.2.5  Toxic or Hazardous Material means any substance or mixture of physical,
       chemical, biological, or radiological characteristics posing a significant threat to
       water supplies or other hazards to human health if such substance or mixture
       were discharged to land or water on the Hoopa Valley Indian Reservation.
       Toxic or hazardous materials include, without limitation, synthetic organic
       chemicals, petroleum products, heavy metals, radioactive or infectious wastes,
       acids and alkalis, and all substances defined as toxic or hazardous by the
       Environmental Protection Agency's federal  regulations, and is to also include
       such products as solvents and thinners  in quantities greater than those
       associated with normal household use.

37.2.6  Zone 1 means a  100 to 400 foot protective radius around public supply wells.
       The size of the protective radius depends on the approved yield of the well.
       The Tribe will use EPA-approved standard  zoning radii of 100 ft.  for 1,000
       gallons per day (gpd); 200 ft. for 5,000 gpd; 300 ft. for 20,000 gpd; 400 ft. for
       wells pumping 100,000 gpd or more.


       For the purpose of this Ordinance, there are hereby established within the
       exterior boundaries of the Hoopa Valley Indian Reservation certain
       groundwater protection areas, consisting of aquifers and/ or recharge areas
       which are delineated on a map. This map is at a scale of 1 inch to 1,000 ft.
       and is entitled "Wellhead Protection Overlays" created in 1994.  This map is
       hereby made a part of the Hoopa Valley Wellhead Protection Ordinance
       (bylaw) and is on file at the Hoopa Valley Planning  Department and at the

       U.S. E.P.A. Region IX Office.


       If the, location of the Wellhead Protection Zone 1 in relation to a particular
       parcel is in doubt, resolution of boundary disputes shall be through the Hoopa
       Valley Realty Department in conjunction with the Hoopa Valley Planning

       Disputants shall be afforded notice and an opportunity to be heard after prima
       facie showing by the Tribe as to the prohibited activities occurring in the
       Wellhead Protection Zone 1,  the burden of proof shall be upon the owner(s) of
       the land in question to show where the boundary should property be located.
       At the request of the owner(s), the Hoopa Valley Tribe may engage a
       professional engineer (civil or sanitary), hydrologist, geologist, or surveyor to
       determine more accurately the boundaries of the Zone 1 with respect to
       individual parcels of land, and may charge the owner(s) for all or part of the
       cost of the investigation.


       In the Wellhead Protection Zone 1 the following regulations shall apply:

37.5.1  Permitted Uses. The following uses are allowed within the Zone 1, provided
       that all necessary special permits, orders, or approvals required by the Hoopa
       Valley Tribe are obtained:

       A.  Conservation of soil, water, plants, and wildlife;

       B.  Outdoor recreation, nature study, boating, fishing, and hunting where
          otherwise legally allowed;

       C.  Foot, bicycle and/or horse paths, and bridges;

       D.  Normal operation and maintenance of existing water bodies and dams.
          Splash boards, and other water control, supply, and conservation devices;

       E.  Maintenance, repair, and enlargement of any existing structure, subject to
          Section B (prohibited uses) and Section C (special permitted uses);

      F.  Reside, ,tial development, subject to Section B (prohibited uses) and
          Section C (special permitted uses);

       G.  Farming, gardening, nursery, conservation, forestry, harvesting, and
          grazing, subject to Section B (prohibited uses) and Section C (special

          permitted uses);

       H. Construction, maintenance, repair, and enlargement of drinking water
          supply related facilities such as, but not limited to, wells, pipelines,
          aqueducts, and tunnels.

37.5.2 Prohibited Uses. The following uses are prohibited within a Zone 1;

       A. Landfills and open dumps;

       B. Storage of liquid petroleum products, except the following:

          i.  Normal household use, outdoor maintenance, and heating of a
             structure, .such items are propane tanks for heating, gas cans for lawn
             or yard equipment, automobile maintenance products, small  quantities
             of paint and thinner, and other such similar items;

       C. Landfilling of sludge or septic system waste;

       D. Storage of chemicals unless such storage, including loading areas, is within
          a structure designated to fully contain any accidental spills;

       E. Storage of animal manure  unless covered or contained in accordance with
          tribal regulations, as may be from time to time adopted, or, in the absence
          of tribal regulations, the specifications of the United States Soil
          Conservation  Service, found in volume  7 of the Code of Federal

       F. Automobile graveyards and junkyards;

       G. Installation of new private or public cess pools or septic tanks. However,
          the following activities are allowed:

          i.  The replacement or repair of an existing treatment works that will not
             result in a design capacity greater than the design capacity of the
             existing treatment works;

          ii.  The replacement of existing .subsurface sewage disposal system(s) with
             wastewater treatment works that will -not result in a design capacity
             greater than the design capacity of the existing system(s);

       H. Industrial and commercial uses which discharge processed wastewater
          directly to septic tanks;

       I.  Storage of commercial fertilizers, as defined in the Hoopa Valley Tribal

          Code, unless such storage is within a structure designed to fully contain
          any accidental spills;

       J.  The use of septic system cleaners which contain toxic or hazardous
          chemicals,  as defined by EPA guidelines;

       K.  The application of pesticides, including herbicides, insecticides, fertilizers
          fungicides,  and rodenticides, for non-domestic or non-agricultural uses in
          accordance with Tribal Forest  Managements Plans, as may, from time to
          time, be adopted.

37.5.3 Uses and Activities Requiring a Special Permit The following uses and
       activities are permitted only upon the issuance of a special permit by the
       departments which comprise the Hoopa Valley Special Permit Granting

       A.  Enlargement or alteration of existing uses that do not conform to the
          Wellhead Protection Ordinance;

       B.  The application of fertilizers for non-domestic or non-agricultural uses.
          Such applications shall be made in a manner so as to minimize adverse
          impacts on  groundwater, to the 'satisfaction of the Special Permit Granting
          Authority, due to nutrient transport, deposition, and sedimentation;

       C.  Those activities that involve the handling of toxic or hazardous materials in
          quantities greater than those associated with normal household use,
          permitted in the Zone 1 (except as prohibited under Section B) such
          activities shall require a special permit to prevent contamination of

       D.  The construction of dams or other water control devices,  ponds, pools or
          other changes in waterbodies or courses, created for swimming, fishing, or
          other recreational  uses, agricultural uses, or drainage improvements.  Such
          activities shall not adversely  affect water quality or quantity.


       A.  The Special Permit Granting Authority (SPGA) under this Ordinance shall
          be the Hoopa Valley Planning  Department or other department so
          delegated by the Tribal Council.  Such special permits shall be granted if
          the SPGA determines, in conjunction with the Hoopa Valley Fisheries
          Department, Public Utilities District, and the Water Quality Department, that
          the intent of this Ordinance,  as well as its specific criteria, are met.  The
          SPGA shall not grant a special permit under this section unless the
          petitioner's  application materials include, sufficiently detailed,  information

ORDINANCE No.:  3-94
          to support positive findings in relation to the standards given in tils section.

       B.  One copy of the application shall be furnished by the applicant for each
          department comprising SPGA. Upon receipt of the appropriate number of
          copies of the special nermit application, the SPGA shall transmit one copy
          each to the Water Quality Department, the Public Utilities District, and the
          Hoopa Valley Tribal Fisheries Department, for their written
          recommendations.  Failure by any agency to respond in writing within 35
          calendar days of receipt from the SPGA shall indicate approval and no
          desire to comment by said agency.

       C.  The SPGA may grant the required special permit only upon finding that the
          proposed use meets the following standards, those specified in Section 6 of
          this Ordinance, and any regulations or guidelines adopted by the Tribal
          Council. The proposal must:

          1.  In  no way, during construction or thereafter, adversely affect the
             existing or potential quality of water that is available in the Wellhead
             Protection  Zone 1, and

          2.  Be designed to avoid substantial disturbance of the soils, topography,
             drainage, vegetation,  and  other water-related natural  characteristics of
             the site to be developed.

       D.  The SPGA may adopt regulations to govern design features of projects.

       E.  The applicant shall file a sufficient number of copies of a  site plan and
          attachments with the SPGA. The site plan shall be drawn at a proper scale
          as determined by the SPGA and be stamped by a professional engineer.
          AH additional submittals shaH be prepared by qualified professionals.  The
          site  plan and its attachments s.hall at a minimum include the following
          information where pertinent:

          1. • A complete list of chemicals, pesticides, herbicides, fertilizers, fuels,
             and other potentially hazardous materials to be used  or stored on the
             premises in quantities greater than those associated with normal
             household  use;

          2.  For those activities using or storing such hazardous materials, a
             hazardous materials management plan shall be prepared and filed with
             the hazardous materials coordinator of the Hoopa Volunteer Fire
             Department, fire .chief of the Hoopa Volunteer Fire Department, member
             departments of the SPGA, and the Hoopa Valley Planning/Water
             Quality Department.  The plan shall include:

 ORDINANCE No.: 3-94
             a.  Provisions to protect against the discharge of hazardous materials
                 or wastes to the environment due to spillage, accidental damage,
                 corrosion, leakage, or vandalism, including spill containment and
                 clean up procedures;

             b.  Provisions for indoor, secured storage of hazardous materials and
                 wastes with impervious floor surfaces.

          3.  Proposed down-gradient location(s) for groundwater monitoring well(s),
             should the SPGA deem the activity a potential groundwater threat.

       F.  No special permit shall issue except after public comment.


       Written notice of any violations of this Wellhead Protection Ordinance shall be
       served by the Hoopa Valley Planning Department or department so designated
       by the Tribal Council on the responsible person after detection of a violation.
       Notice to the assessed owner and/or operator of the property shall be deemed
       notice to the responsible person.  Such notice shall specify the requirement or
       restriction violated and the nature of the violation, and may also identify the
       actions necessary to remove or remedy the violations, preventive measures
       required  for avoiding future violations, and a schedule, of compliance. A copy
       of such notice shall be submitted to the Hoopa Tribal Planning/Water Quality
       Department, Hoopa Tribal  Fisheries. Department, and also to the Public Utilities
       District.  The cost of containment, clean-up, or other action of compliance shall
       be borne by. the owner and/ or operator of the premises.  For situations that
       require remedial action to prevent adverse impact to the water resources within
       the Hoopa Valley Indian Reservation, the Hoopa Tribal Planning  Department
       may order the owner and/  or operator of the premises to remedy the violation.
       If said owner and/or operator does not comply with said order, the Hoopa
       Valley Planning Department, in conjunction with Tribal Police will be authorized
       to enter upon such premises under the terms of the special permit or
       otherwise, may act to remedy the violation. The remediation cost shall be the
       responsibility of the owner and/or operator of the premises.


37.8.1  In order to carry out the purposes of this Ordinance, any duly authorized
       representative of the Tribe has the authority to enter and inspect any property,
       premises, or facility involved in any wellhead protection or violation of this
       Ordinance on any lands within the exterior boundaries of the Reservation.
       Such inspection may include:

       A.  Obtaining samples of soil, rock, vegetation, air, water, or other substances

ORDINANCE No.:  3-94
          deemed necessary;

       B,  Setting up and maintaining monitoring equipment for the purpose of
          assessing compliance with applicable regulations, or health or safety

       C.  Photographing any equipment, sample, activity, or environmental condition.


       if any provision of this Ordinance or its application to any person or
       circumstance is held invalid, the remainder of the Ordinance or application of
       its provisions to other persons or circumstances shall not be affected, and to
       this end, the provisions of this Ordinance are severable.


       Nothing in this Ordinance shall be interpreted as a waiver of the Tribe's
       sovereign immunity from unconsented lawsuit, or as authorization for a claim
       for monetary damages from the Tribe.


I, the undersigned, as Chairman of the Hoopa Valley Tribal Council, do hereby certify;
that the Hoopa" Valley Tribal Council is composed of eight (8) members of which
	(J were present, constituting a quorum, at a Regular Meeting thereof, duly and
regularly called, noticed, convened, and held on this	f  th) day of
	, 1995; that this Ordinance was duly adopted by a vote of	(_) in
favor,	(J opposed, and	(J abstaining;  and that since its approval this
Ordinance has not been rescinded, amended, or modified in any way.

DATED THIS   TH DAY OF __	., 1995.
                                      DALE RISLING, SR., CHAIRMAN
                                      HOOPA VALLEY TRIBAL COUNCIL
          MARLA McLEOD

                         HAZARDOUS WASTE SITES


                            100 YEAR FLQQDPLAIN

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               Prepared for:

               Tulalip Tribes
          Environmental Program
          7615 Totem Beach Road
          MarysviUe, WA 98271
               Prepared by:

 Science Applications International Corporation
     606 Columbia Street N.W., Suite 300
           Olympia, WA 98501
           Contract No GCB - 330
      SAIC Project No. 01-1099-05-3210
                June 1994

                         TABLE OF CONTENTS



     2.1   THE WHPA MODEL  	  4
     2.3   SIMULATION RESULTS	,	10
     2.5   SUMMARY	17

     3.1   OWNERSHIP AND LAND USE . . .	 18


     5.1   MINING PRACTICES	 23
     5.3   SUMMARY  	-.	'	28




                            LIST OF TABLES

Table 1  Input Parameter Values Used in WHPA Models	  7
Table 2. Well-Specific Input Values for WHPA Modules	 . . .  9
Table 3  Sensitivity Analysis: Influence of Input Parameters on Capture Zone	15
Table 4  Land Uses and Associated Potential Pollutants	,	19
Table 5  Sources and Associated Pollutants from Gravel Mining Operations	25
Table 6  Sources and Associated Pollutants from Gravel Processing Operations  	27
Table 7  Cost Estimates to Evaluate Optimum Septic Tank Densities	33

                         TABLE OF CONTENTS (cont'd)
                              LIST OF FIGURES

Figure 1 MWCAP Module Steady-State Wellhead Protection Area	11
Figure 2 GPTRAC Module 10-year Time-Dependent Zone of Contribution  ........  13
Figure 3, GPTRAC Module 25-year Time-Dependent Zone of Contribution  ........  14
Appendix A Sensitivity Analysis - Zones of Contribution for Maximum and Minimum Values
      of a Given Parameter

Appendix B Best Management Practices and Mitigative Measures

Appendix C Glossary

                                1.0 INTRODUCTION

The  U.S. Environmental Protection Agency's (EPA's) Wellhead Protection  Program was
legislated under the 1986 amendments to the Safe DrinMng Water Act (SDWA).  The program
requires public water supply purveyors in partnership with local jurisdictions, water users, and
interested parties to develop a program to protect current and future underground drinking water
supplies.  The program requires delineation  of land surface areas that contribute recharge to
public supply wells.   These are called zones  of contribution.  The program  also requires
regulation of the land uses within those zones to eliminate or reduce  the  potential  for
contaminant sources to adversely affect local ground water quality.

The  Wellhead Protection Program establishes a partnership among federal, state  or tribal, and
local jurisdictions.  In Washington State, five major components comprise the WHP program
including the following elements:

       •      Delineate the wellhead protection area for each well or wellfield;
       •      Identify and locate potential sources of groundwater contamination  within
              the wellhead protection area;
       *      Reduce  the likelihood that potential contaminant sources will pollute the
              drinking water supply by preparation of a management plan;
       *      Provide a contingency plan for the  provision of alternate  sources of
              drinking water in the event that  contamination does occur; and
       •      Include  public participation while the  program is developing.

Determination of a wellhead protection area comprises two phases: a  technical phase and a
policy phase.  The first is a hydrogeologic delineation of the zone of contribution for a well or
wellfield.  (See  Glossary  for definition of zone of contribution.)  The second is a  policy
statement of the amount of land area within the zone of contribution and surrounding potential
recharge area to include in a wellhead protection area.  This project delineated the zone of
contribution for Wellfield Number 1 to provide the Tulalip Tribes the technical information
necessary to  establish a wellhead protection  area.   Specifically, the following  tasks were
performed for this project:

       •     Delineation  of a  zone of contribution  for  a four-well  field (Wellfield
              Number 1) in the Tulalip Creek Basin;

       •     Identification  of potential pollutant  sources  within the zone of
             contribution and a broader recharge area;

       *     Development  of mitigative  measures or  Best Management Practices
             (BMPs) for the identified sources;

       *     Evaluation of the impacts of gravel mining  operations on groundwater
             quality and suggested management practices  and  mitigative measures to
             reduce the contribution of pollutants from gravel mining operations should
             such an operation be located within the wellhead protection area;  and

       *     Examination of tools available to estimate nitrogen loading from septic
             systems in the recharge area,

The delineation of the zone of contribution for the wells included a review of the data obtained
from Tulalip Reservation records, a U.S. Geological Society (USGS) Report  (Drost, 1983), and
a receni: USGS study (Thomas, pers. comm.) to obtain the necessary hydrogeologic data.  An
analytical flow model was utilized to simulate three  scenarios,  including steady-state (infinite
time),  10-year, and 25-year times of travel to the well.  (See the Glossary in Appendix C for
definition of "time of travel".)  The results of the delineations are provided in Section 2.0.

Identification of the potential pollutant sources included a site visit to identify sources within and
adjacent to the zones of contribution and a discussion with tribal representatives of potential
future land uses within the 25-year time of travel. The information obtained during the source
identification is presented in Section 3.0.

Section 4.0 provides a discussion of Best Management Practices (BMPs) and mitigative measures
that can assist the Tulalip Tribes in managing the activities within!the wellhead protection area.

Section 5.0 of this report describes potential impacts of gravel mining activities on groundwater
quality and measures that can be taken to protect groundwater. Currently,  tribal representatives
are investigating the commercial viability of gravel sources on tribal land. No specific site has
been identified, and no business has been named to mine the gravel.

Since septic tanks are a potential source of groundwater pollution and all the residences near the
zone of contribution  rely on septic systems for domestic waste disposal, methods of estimating
their cumulative effect on the aquifer are reviewed in Section 6.0. Nitrogen, a constituent of

wastewater from septic tanks, is used as an indicator parameter to assess the impact of multiple
septic systems on the aquifer because it provides a conservative estimate of relative degradation
of groundwater quality. Nitrogen loading models can be used  to establish an optimum septic
tank density  that minimizes groundwater  quality degradation  and still meets  development
interests.  Section 6.0 also estimates costs to prepare a nitrogen loading model for a delineated
wellhead protection area.

Section 7.0 lists the conclusions and recommendations resulting from the wellhead protection
area project for the Tulalip Tribe.

There are three Appendices that supplement the written material in this report.  The zones of
contribution for maximum and minimum values of a given parameter simulated during the model
sensitivity analysis are depicted in Figures A-l through A-12 located in Appendix A. Appendix
B provides the Best Management Practices (BMPs) and mitigative measures for groundwater
protection. The BMPs are intended to be removed, reproduced, and distributed as educational
tools.  A glossary of specialized terms used in the report is found in Appendix C.  The lay
reader is directed to the Glossary as  terms are identified in the text.

EPA developed the Wellhead Protection Area model (WHPA model) to assist water purveyors
in delineating wellhead protection  areas.   Section 2.1 describes  the two modules within the
WHPA model used for delineation of the wellhead protection area for the four wells within
Wellfield Number 1 on the Tulalip Reservation.  Sections 2.2 through 2.5 describe the input
parameters to each of the modules of the WHPA model, the simulation results delineating zones
of contribution for Wellfield Number 1, a sensitivity analysis for  the various input parameters
used, and a summary, respectively.

Wellfield Number 1 is comprised of four water supply wells in close proximity to each other.
The delineation of the most realistic zone  of contribution would thus be facilitated by using an
analytical flow model that can account for interference between the four wells.  The WHPA
model is an analytical flow model developed by the EPA to be used to assist technical staff with
the task  of zone of contribution  delineation and  ultimately development of the wellhead
protection area. Implementation of a numerical flow, model requires detailed hydrogeologic data,
but can provide the ability to model complex hydrogeologic interactions if the added cost is
warranted.  Since the zones of contribution delineated using the WHPA model did not intercept
either fork of the Tulalip Creek, a  numerical flow model was not deemed necessary to assess
vertical flow components from partially penetrating conditions.


The primary objective of the Wellhead Protection Area model developed by the EPA is to assist
technical staff with the task of wellhead protection area delineation.  This section describes the
assumptions inherent to the WHPA  model, the two modules of the WHPA model, Multiple Well
Capture Zone (MWCAP) and General Particle Tracking (GPTRAC), and the respective purposes
and assumptions inherent to each module.

Two major assumptions common to all computational modules of the WHPA model are:  1) flow
in the aquifer is horizontal; and  2)  flow in the aquifer is at steady-state.  Temporal variations
in sources and sinks (e.g., non-continuous pumping) are not considered steady-state conditions.
Thus, the WHPA model is most  applicable to continuously pumped water supply wells.  Other
assumptions common to the two modules include the assumptions that all wells and stream
boundaries are fully penetrating, and that  there is no vertical component of flow  (i.e., flow is
not three-dimensional).

The WHPA model assumption that all stream boundaries are fully penetrating is the most likely
assumption to be violated and may lead to unrealistic predictions.  Natural streams are nearly
always only partially penetrating and often have a clogging layer of the fine-grained material that
underlies the stream bed.  Because the model assumes the stream boundary is fully penetrating,
the capture zone predicted by the model expands in width along the stream, but does not extend
beyond the stream. In reality, because the stream may be only partially penetrating, the actual
capture zone may extend beyond the stream.  In addition, the model assumes that flow from the
stream is constant, that is, not affected by a zone of reduced hydraulic conductivity established
by the sediment layer of the stream bed. Because the stream boundary acts as a source of water
to the well, the capture zone is smaller than a  capture zone not influenced by stream inflow.
Thus,  a stream, such as Tulalip Creek, acts as a condition that limits the size of the capture
zone.  However,  the assumption that Tulalip Creek is fully  penetrating may exaggerate the
condition and predict a smaller capture zone than actually exists.

The  MWCAP module of the WHPA model can be  used to delineate a capture zone based  on
either steady-state or time-dependent conditions.  Steady-state zones of contribution are defined
as the surface or subsurface area surrounding a pumping well that suppEes groundwater recharge
to the well over an infinite period of time.  This type  of capture zone forms an open-ended shape
in the upgradient direction due to the fact that, given enough time,  any particle of water
upgradient of the well, within the zone of contribution boundaries will eventually travel to the
well.  This zone  of contribution could be limited by a groundwater divide (see Glossary for
definition).  The steady-state assumption is the most environmentally conservative type of de-
lineation and thus covers the largest  area.

Time-dependent capture zones can be delineated using either the MWCAP or the GPTRAC
modules and depict a zone of contribution within a  given time limit.  Capture zone periods of
10 and 25 years  are recommended  for zone of  contribution delineations.  In general, time-
dependent capture zones are considered less environmentally conservative (enclose smaller areas)
than steady-state capture zones. Time-dependent capture zones can approach the size and shape
of a steady-state solution when the time interval is very large.

In this study,  two modules of the WHPA model, the MWCAP and GPTPvAC modules,  were
used to analyze the hydrogeologic system at Tribal Wellfield Number 1. MWCAP was used to
assess the influence of the nearby  Tulalip Creek. Although multiple wells within a study area
may be specified, MWCAP assumes that the wells operate independently of one another.  Conse-
quently, increased drawdown due to interferences of multiple  wells pumping simultaneously is
ignored in MWCAP.

The GPTRAC module accounts for interferences produced by multiple pumping wells and ac-
commodates a wider range of aquifer  and  boundary conditions  than  the other modules.
GWPRAC can only predict time-dependent capture zones.  GPTRAC provides for simulation
of the impacts of a semi-confined aquifer on the zone of contribution that is not available in the
MWCAP module (see Glossary for definition of semi-confined).  Only time-dependent zones of
contribution can be accounted for in GPTRAC.  Because GPTRAC can  account for the effects
of well interferences and semi-confined conditions, GPTRAC was selected to delineate a more
realistic time-dependent zone of contribution for the conditions present at Wellfield Number 1.


The hydrogeologic parameters used to delineate the zone of contribution for Wellfield Number
1 and the sources of these data are listed in Table 1.  Table 2 displays data for each well in the
wellfield reported in  Water Resources of the  Tulalip Indian Reservation,  Washington (Drost,
1983).  The four wells in Wellfield Number 1 are designated Well #4, Well #5, Well #6, and
Well #7 by the Tulalip Reservation.  These designations will be used in this report. The well
numbering  system  used by the USGS in the State of Washington designates these same wells
30/4-10L2, 30/4-10L3, 30/4-10L4, and 30/4-10L5, respectively.  These well designations con-
tain the township, range, section, 40-acre tract within that section, and serial number.

The parameters in Tables 1 and 2 are based on the best available information and professional
judgement. The groundwater flow direction and hydraulic gradient were determined using the
water levels reported by Drost (1983) and in  personnel communication (Thomas, 1993).  The
most recent water levels taken at the Tulalip Reservation were measured in 1992 by USGS per-
sonnel using a steel tape.  Using the six 1992  water levels in selected wells in the north central
portion of the Reservation, a south southwesterly flow direction and a gradient of 0.0156 were
determined. A potentiometric surface (see Glossary for definition)  based on all twenty water
levels from non-pumping weHs taken during the 1970's showed a southward groundwater flow
from the northern reservation border changing to a southwestward flow in the vicinity of the
Tulalip Wellfield Number 1.  The overall flow direction and gradient determined from the 1970
potentiometric surface concurred with those determined from 1992 data.

A step drawdown pump test was conducted in Well #7 in June 1988 by  Carpenter Drilling.  In
this type of test, the pump rate is increased incrementally in a series  of steps, and the headless
hat occurs at each pumping rate a water flows through the well screen is calculated.  Cooper
and Jacob's form of the Theis equation (Todd, 1980) and the least squared method of analysis,
were used to calculated the aquifer transmissivity (see Glossary for definition) resulting from the
purnp test.

                                     Table 1
Minimum x-coordinate of
study area
7 1/2 minute maps
Maximum x-coordinate
of study area
15,840 ft
71/2 minute maps
Minimum y-coordinate of
study area
7-1/2 minute maps
Maximum y-coordinate
of study area
15,840 ft
7-1/2 minute maps
Largest allowable step
Suggested in the WHPA Handbook,
Blandford and Huyakorn,  1991.
Transmissivity of the
1116 ft2/day
Estimated using a step drawdown test
for Well #7 and the lithology along
with Anderson & Woessner, 1992;
Freeze & Cherry, 1979; and Todd,
Regional hydraulic gradi-
0.0156 ft/ft
Estimated using USGS, 1992 ground-
water elevation data from pers. comm.
Thomas, 1993 and water levels from
1969 to 1982  from  Drost, 1983.
Bearing of ambient
groundwater flow
249 degrees
Estimated using USGS, 1992 ground-
water elevation data from pers. comm.
Thomas, 1993 and water levels from
1969 to 1982 from Drost, 1983.
Aquifer Porosity
Estimated based on the lithology and
Anderson and Woessner, 1992; Freeze
and Cherry, 1976; and Todd, 1980.
Aquifer saturated thick-
ness in vicinity of
Wellfield #1
Average thickness of sand Unit #5
according to borehole logs from Drost,
Associated boundary type
Fully penetrating stream boundary's
effect on the zone of contribution for
Wellfield #1 was model tested.

Table 1 (Continued)
Capture zone type option
Time values associated
with time-related capture
Number of pathlines to
be computed
Flag indicating if capture
zone boundary is plotted
GPTRAC-specific data:
Aquifer type
Confining bed hydraulic
Confining bed thickness
Area! recharge rate
steady state and
3,650 and 9,125

0.1 ft/day
0.0017 ft/day
Both capture zone types were simulat-
Suggested times (10- and 25-year) in
the WHPA Handbook, Blandford and
Huyakorn, 1991.
Visual inspection
Visual inspection

Borehole Logs in vicinity of Wellfield
#1 from Drost, 1983.
Estimated based on the hydraulic con-
ductivity of the aquifer and lithology
and values from Anderson &
Woessner, 1992; Freeze & Cherry,
1979; and Todd, 1980.
Borehole Logs in vicinity of Wellfield
#1 from Drost, 1983.
Reported recharge is 7.4 inches/year in
a 4-square mile recharge area from
Drost, 1983.

                   Table 2
X-Coordinate (Feet)
Y-Coordinate (Feet)
Total Well Depth (Feet)
Screened Interval (Feet)
Screened Length (Feet)
Well Radius (Feet)
Pump Rate: Ft3/day (gpm)
Saturated Thickness at Well
Perpendicular Distance from
left fork of Tulalip Creek
Orientation of Stream
Boundary from N-S (Degrees)
Perpendicular Distance from
the right fork of Tulalip Creek
Using Nearest Reach (Feet)
Orientation of Stream
Boundary from N-S (Degrees)
Perpendicular Distance from
the right fork of Tulalip Creek
Using Line Through Middle of
Meanders (Feet)
Orientation of Stream
Boundary from N-S (Degrees)
32,535 (170)
43,061 (225)
32,535 (170)
86 - 101

The calculated transmissivity was 1,116 ft2/day, which is within the range of values found in the
literature for aquifers with  similar lithologies.  Porosity  (defined in Glossary) was estimated
using the literature values for similar materials (Anderson and Woesser [1992],  Freeze and
Cherry [1976], and Todd [1980]).

From an evaluation of the borehole logs for the wells in Wellfield Number 1 and the USGS
cross section F-F' (Drost,  1983), the average saturated  thickness of the Unit 5 aquifer was
determined to be 67 feet in the vicinity of the wellfield.  The aquifer thickens to the north
reducing the size of the capture zone in that area.  Therefore,  using an average thickness of 67
feet would overestimate the capture zone size.  The borehole logs and cross-section evaluation
was used to confirm the presence of a semi-confining layer (leaky) of an approximate thickness
of 30 feet as identified by Drost (1983). These semi-confined conditions were simulated in the
GPTRAC module. The pump rates for the four wells in Wellfield Number 1, provided by Tom
Gobin of the Tulalip Reservation staff (pers. comm,, 1993), are estimates for pumping rates that
occur 10 to 15 hours per day.  In the model, these pumping rates were applied over a 24-hour
period.  Therefore, the simulated capture zone size will be larger than the actual capture zone
for the four wells pumping  fewer hours per day.


The MWCAP and GPTRAC modules of the WHPA model are sensitive to the hydrogeologic
parameters and other factors used in the simulations.  Two complicating factors affect the use
of the WHPA model for zone of contribution delineation in Wellfield Number 1. First,  all wells
in the wellfield pump intermittently.  The estimated pumping period is 10 to 15 hours  a day to
maintain the  volume of the holding tank at  a minimum  of 50 percent capacity.  The model
predictions, however, are based on a 24-hour pumping period (i.e., continuous pumping). As
a result, the WHPA model simulations in all scenarios depict greater areas of contribution than
actually contribute to the well.  Secondly, two stream boundaries that are not fully penetrating
exist in proximity to the Tulalip water supply wells, the effects of which are discussed in Section

The MWCAP module was used to simulate the steady-state .zone of contribution for each well
in Wellfield Number 1, as  shown in Figure 1. The delineation for the steady-state zone of
contribution is the largest area simulated, and shows the source of water for each well pumping
individually.  Combined these individual zones of contribution represent the most environmental-
ly protective area that is simulated herein.

Well #4

Well #5

Well #6

Well #7
                        Figure 1

                     (MWCAP Module)

The MWCAP module was also used to determine the potential impact of a fully-penetrating
stream in the location of the Tulalip Creeks. MWCAP permits the input of the stream boundary
angle from north-south and the distance from each of the pumping wells.  When MWCAP was
run for all simulations for either fork of Tulalip Creek, it was determined that the stream bound-
aries do not substantially impact the shape or size of the zones of contribution. Unless the water
level or potentiometrie surface in Wellfield Number  1 declines in the future, or the total well
discharge  increases,  stream flow is not part of the  water supply drawn from this wellfield.
Thus, use of tMs simulation demonstrated that the creeks exerted no influence on the capture
zone due to the orientation of the capture zone.

The effects of well interference from the four pumping wells are not negligible since the cones
of depression (see Appendix C for definition) overlap. GPTRAC accounts for well interference
and, therefore, was used  to delineate time-dependent zones of contribution for a 10- and a 25-
year time of travel. TMs module also takes into account the upper semi-confining unit (i.e., the
Unit 4 till and Unit  2 silt and clay interbeds identified by the  USGS in  cross section F-F'
[1983]).   The 10-year zone of contribution is depicted in  Figure  2 and represents  the least
environmentally  protective approach based on the shorter time frame.  Figure 3 presents; the
time-dependent simulation for a 25-year time of travel.  The colors represent the influence of
each individual  well, taking  into consideration well interference.  The 25-year delineation
(Figure 3) is the recommended zone of contribution for Wellfield Number 1, because it is more
environmentally  protective.


Most of the hydrogeologic parameters used in the model affect the size and shape of the zone
of contribution to some degree. A sensitivity analysis was performed using a range of values
for each parameter for which some uncertainty about the exact value of the parameter exists.
Simulations were run using a reasonable minimum  and maximum value for each parameter
tested; and except for the parameter being tested, all other parameter values were held constant.
The  results are  shown  in Table 3 and Figures A-l through A-12  in Appendix A.   The
implications of the sensitivity analyses are discussed  in this  section.

The minimum total well discharge was derived by multiplying the volume pumped in 10 hours
at the average pumping rates by 0.417 (10 hours/24  hours).  To simulate increased pumping,
the well discharges from two hypothetical wells (designated  well #8 and well #9)  were added
to the total discharge,  increasing the pumping rate by 170 and 225 gallons  per  minute,
respectively. The simulations run with a minimum and maximum well discharge are shown in

                       TULALIP INDIAN
               Well #4
               Well #5
               Well #6
               Well #7
                                          Figure 2
                                   .::'.-• (GPTRAC Module)

                  Figure 3

              (GPTRAC Module)


Well Discharge (Total)
Hydraulic Gradient
Confining Layer Thickness
Confining Layer Hydraulic
Effective Porosity
62,997 ft3/day
5 feet
'0,01 ft/day
Thinner but only slightly
shorter in length.
Shorter and wider (egg-
shaped); zone of influence
of each well is increased.
Shorter and much wider;
zone of influence of each
well is increased.
Thinner and slightly short-
er; zone of influence of
each well is decreased.
Thicker and slightly longer;
zone of influence of each
well is increased.
Longer (velocity increase),
same width.
226,788 ft3/day
2000 ftVday
100 feet 	
1.0 ft/day
Thicker, but only slightly longer.
Extends to the northern «
reservation boundary and is *
slightly thinner; zone of influence
of each well is decreased.
Longer and slightly thinner; zone
of influence of each well is
Thicker and slightly longer; zone
of influence of each well is
Thinner and slightly shorter; zone
of influence of each well is
Shorter (velocity decrease), same

Figures A-l and A-2, respectively. As the pumping rate of the well increases, the zone of con-
tribution will increase in all directions.

Figure A-3 shows the effect of reduced transmissivity (i.e.,  each well draws from a broader
area).  An increase in the transmissivity, as shown in Figure A-4, would decrease the width of
the zone of contribution size, because the well would derive more water from each unit of the
aquifer in the zone of contribution.  Thus,  the zone of contribution increases in length with
increased transmissivity.

Likewise, an increase in the groundwater gradient would decrease the width and lengthen  the
zone of contribution.  The results of using a minimum and maximum hydraulic gradient in  the
sensitivity analysis are shown in Figures A-5 and A-6. As depicted in Figures A-3 through A-6,
accurate data for transmissivity and hydraulic gradient are critical to an accurate delineation of
the zone of contribution.  Under steady-state conditions, an increase in the hydraulic gradient
would increase the seepage velocity and the ambient flow rate.  Increases in the seepage velocity
or the flow rate  would alter the location and orientation of the pathlines.

Decreasing the thickness or  increasing  hydraulic conductivity  of the semi-confining unit would
affect the zone  of contribution in the same way.  The simulations showing maximum and
minimum thickness  of the  semi-confining  unit are shown in Figures A-7 and  A-8.   The
simulations showing the minimum and maximum semi-confining unit hydraulic conductivity are
shown in Figures A-9 and A-10, respectively. The zone of contribution is made larger by either
an increase in the thickness (Figure A-8) or a decrease in the hydraulic conductivity (Figure A-9)
of the semi-confining unit.  Decreasing the thickness of the semi-confining unit (Figure A-7) or
increasing  its hydraulic conductivity  (Figure A-10) would simulate the  conditions of  an
unconfined aquifer.

Steady-state zones of contribution are not dependent upon porosity or thickness.  For the time-
dependent zones of contribution, porosity and aquifer thickness do not affect the position or
orientation of the pathlines.   However, porosity and thickness do  affect the velocity  of
groundwater flow along each pathline. Therefore, decreases in porosity (Figure A-ll) or aquifer
thickness parameters would increase  the groundwater  velocity resulting in a longer (more
environmentally protective) zone  of contribution.   The  simulation run with  the maximum
porosity, depicted in Figure A-12,  again shows no change in  width but a shorter zone of

2.5    SUMMARY

Steady-state,  10-year, and 25-year time of travel simulations were"performed and analyzed for
Wellfield Number 1 zone of contribution delineation. The most environmentally protective zone
of contribution, the steady-state capture zone, extends beyond the reservation property. Figure
1 depicts the source of water for each individual well.  The zone of contribution delineated in
the steady-state model extends beyond the reservation property.  The Tribes may determine that
a steady-state zone of contribution is not practical  to regulate.

Because GPTRAC accounts for the effects of well  interference in the wellfield, GPTRAC was
used to delineate the time-dependent zones of contribution for the Wellfield Number 1.  Because
of the smaller zone of contribution defined, the 10-year zone of contribution (Figure  2) is not
as protective of the water supply as the  25-year  zone of contribution.  The  25-year zone of
contribution shown in Figure 3 is recommended for use as the delineated wellhead protection
area for Wellfield Number 1. The 25-year delineation provides a greater measure of protection
than the smaller, 10-year zone of contribution.  Unlike the steady-state zone, the 25-year zone
of contribution is of limited area! extent, and activities within the area are distinctly manageable.

                             3.0 POLLUTANT SOURCES
The following section presents the results of a site visit conducted to inventory potential pollutant
sources within the delineated zone of contributions depicted in Figures 1 through 3 for the four
wells located in Wellfield Number 1 of the Tulalip Reservation.  The site visit indicated that
very few visible potential sources were identified within the delineated areas.  A small gravel
pit was identified approximately one mile northeast of the wellfield.  The area in the vicinity of
Mary Shelton and Fryberg Lakes are areas of potential concern because of light residential use.
Potential sources of contaminants include: septic wastes, lawn and garden chemical applications,
and indiscriminate dumping of solid and household hazardous wastes.  In addition, recreational
use of the lakes  (i.e., boating or  fishing) could contribute petroleum products to  the list of
potential pollutant sources.  Because so few sources exist within the zone of contribution, other
potential sources that are considered within a broader recharge area are discussed.


Land ownership within the area  of interest (legal sections 1, 2, 3, 10, and 11) includes Trust
Property (tribal ownership) and Individual  Property  (individual tribal member ownership),
nontribal homeowners, and the City of Everett.  The City of Everett property currently remains
inactive.   However, the  city has proposed that this property be used for land  application of
sewage sludge. This proposed land use met with great public opposition, and consequently, the
sludge application proposal has not been implemented.

The primary land use within this area is forestry. Initial cuttings of trees, mainly evergreens
occurred in the 1920s to  1930s.  Seedlings of maple, douglas fir, and cedar were then planted
in the logged area.  These species  are not currently being logged in the area.


The land uses described above were evaluated and the potential pollutants associated with these
activities were inventoried as  part of the site visit.  Table 4 provides a list of the potential
pollutants of concern by land use.

                    Table 4
Household Activities
Septic Systems
Auto Care/Repair
Lawn and Garden
Illicit Dumping
Lake Recreational Activities
Gravel Mining
household cleaners
• nitrates
bacteria and viruses
household cleaners
household hazardous waste
fecal coliform
oils and greases

Homes in the vicinity of Mary Shelton and Fryberg Lakes operate on individual septic tank and
drainfield systems.  These septic systems are considered the primary potential pollutant source
in the recharge area.  Estimated septic  tank densities  located  within  the  25-year zone of
contribution range from zero to 0.23 septic tanks per acre.  Future development could increase
the density in a portion of the zone of contribution to 0.44 tanks/acre. Land to the northwest
of the 25-year zone of contribution has an  estimated average septic tank  density of 0.85 tanks
per acre.  Septic tank densities in this area have the potential to increase to 1.23 septic tanks per
acre, if the land is not subdivided further than indicated on the current zoning map.

In  addition,  appEcations  of lawn  and  garden chemicals (pesticides  and herbicides)  by
homeowners are considered a potential contaminant source.  Home automotive repair activities
such as changing of oils and antifreeze were observed at several locations within the recharge
area. Typical contaminants associated with these activities include:  oils,  gasoline,  degreasers,
brake  fluid, and antifreeze.  Although no evidence  was observed during the site visit,
indiscriminate dumping of household hazardous waste (bleaches, cleaners, paint, etc.) is known
to occur in similar residential areas. Illicit dumping may also occur within the protection zone.

Activities on the lake that could contribute pollutants to the groundwater include motorized boats
used for fishing, bank fishing, and other recreational activities.  Oil and  gasoline products are
the potential pollutants from the motorized activities.  Fecal coliform bacteria contributed to the
lakes from  swimming and  other human  and animal activities  may  be  entering  the aquifer
depending on  the depth and type of sediments in the lakes.

Forestry activities, notably  the aerial application of the herbicide Roundup® used to control
salmonberry and elderberry growth were identified during the site visit.  Application of 1-1/2
quarts Roundup® in 10 gallons of water per acre occurred  in the northwest corner of legal
Section 11.  This area borders the delineated'wellhead areas.  This application occurred  five
years ago and  has not been reapplied in the  area.  While Roundup® has not been applied within
the delineated wellhead protection area for  over 10 years, these activities  are  also listed on the
potential contaminant source inventory.

                      4.0 BMPs AND MITIGATIVE MEASURES
Best Management Practices (BMPs) and mitigative measures are presented below according to
type of activity.  The activities that represent the greatest potential for pollution of the drinking
water source are, in large part, nonpoint pollutant sources.  As  with most nonpoint source
poEutants, the potential sources are not introduced to the environment through an industrial or
municipal pipeline.  Instead, actions taken by individuals and under the individual's control
create pollutant sources. The cumulative impact of these nonpoint sources can affect a drinking
water supply.   Because of the dispersed nature of and individual responsibility for nonpoint
sources  of pollution,  the major controlling mechanisms include land use planning and  an
awareness of all potential contributors.

Land use planning and regulation can control  the activities of commercial  and industrial
businesses that may be located within a wellhead protection area.  However, land use planning
cannot control the actions of individuals.  Education is the key to pollution prevention at the
individual level. Heightened individual awareness can enhance behavioral modifications. The
BMPs provided in Appendix B are intended to be used as educational tools. Because they are
provided in the appendix, the BMPs can be easily removed, copied, and provided in a public
forum, or can be used to  develop  brochures, logos, and buttons in campaigns  to raise public
consciousness.  In areas of primarily residential land use, such as in the case of the delineated
25-year zone of contribution,  education that leads to environmentally sound practices  at the
individual level is a primary method of groundwater pollution prevention.

The BMPs in Appendix B are presented in priority order based on the potential for the category
of activity  to degrade the quality of the drinking water.  Because the predominant land  use in
the recharge area is residential, the aquifer will be most affected by the cumulative practices of
all  the residents.  Thus, implementation of the BMPs for residential areas are  considered the
highest priority for  implementation.  Changing the practices of residents is likely to have the
greatest long-term impact on the introduction of contaminants to the aquifer.  Protection of the
area immediately surrounding the wellfield is considered critical to the short-term protection of
the water supply. The BMPs for protection of the wellhead immediately follow those that apply
to residential areas.

Implementation of BMPs for transportation corridors and stormwater drains  can diminish the
potential impacts of individual spill incidents on the groundwater quality.  Thus these BMPs,
while important, are of a lesser priority than those for households and wellhead areas.


Because forestry  activities that can cause contamination of the groundwater are regulated by
federal  statute, the forestry BMPs were given  a lower priority.   Forest practices such as
application of pesticides are regulated by the Federal Insecticide, Fungicide, and Rodenticide Act
(FDFRA), landowners can be encouraged to develop and implement Integrated Pest Management
(EPM) plans to reduce the need for pesticide application.

The location of the lakes outside of the 25-year time of travel and the large volume of water in
the lakes, reduces the importance of implementation  of the BMPs  applicable  to recreational
activities on lakes.

The Tulalip Reservation may be the location of a commercially  viable source of gravel, and
mining operations may be proposed.  Gravel mining may have an adverse impact on the quality
of the groundwater downgradient of the mine, particularly if mining occurs below  the water
table.  Mining has been documented to increase the turbidity and concentrations of inorganic
constituents in downgradient, wells.  Depending on the associated  activities such as concrete or
asphalt  batch plant processes,  vehicular  traffic  and maintenance,  other pollutants  can
inadvertently be introduced  to the groundwater.  Section 5.0 describes  impacts and presents
options  for establishing BMPs and mitigative measures to prevent groundwater pollution from
future planned or unplanned mining operations.

Land  use planning can control the type of  septic systems  and the  density of septic systems
installed.  In Thurston County, for example, a loading model was used to assess the optimum
density of septic systems that could be installed over the protected recharge area to maintain the
current  concentration of nitrate in the groundwater (Colder, 1990).   The density proposed and
ordained in  Thurston  County was one septic  system for  five acres, based on  technical
justification (Golder, 1990).  Such justification would be required for the specific conditions of
the wellhead protection program for the Tulalip Reservation. Section 6.0 discusses methods for
establishing optimum septic tank density in areas where groundwater protection is a concern.

The potential impacts to groundwater quality and quantity as the result of gravel mining vary
widely. The degree of impact depends on the size and type of mining operation as well as the
associated activities that take place on site.  To evaluate these environmental effects, each gravel
mining operation should be viewed as the sum of the environmental effects of the component
activities.  The following section provides a summary of various types of gravel mining practices
and mining processing and discusses direct and post mining effects to water resources.  This
section also presents  mitigative measures (including treatment technologies) and BMPs that can
be used to  reduce potential impacts to groundwater as  a result of mining  and associated


The three basic types of gravel mining operations are defined on the basis of their relationship
to the water table. They include:  dry pit mining, wet pit mining, and dredging.  Dredging is
not generally practiced in northwestern Washington and, therefore, is not discussed.

In dry pit mining, gravel  is extracted above the water table.  When gravel excavation is well
above the water tables (and associated activities such as vehicle maintenance or concrete batch
processing plants do not occur on site) the risk of groundwater contamination and impacts to
quantity is relatively low.  However,  the protective overburden is removed, and  these excavated .
areas can be sensitive to the introduction of contaminants.   But because dry pit  mining is
generally  limited to a process of loading unconsolidated materials, the associated activities do
not pose  serious  risk of introducing  contaminants.  A high  potential  risk of groundwater
contamination occurs when solid wastes are deposited at abandoned open pit gravel mines. The
types of wastes  typically found at  these sites vary widely and include wood waste, liquid
industrial waste, paint waste, demolition materials,  and household wastes.  Leachate from these
wastes can infiltrate through soils and degrade groundwater quality.  Management practices such
as limiting access to the area can reduce the risk of groundwater contamination.  Filling in the
pit with  clean  inert substances after mining is completed  would also minimize groundwater

Wet pit mining involves the excavation of gravel below the water table. In wet pit mining, the
gravel is normally excavated using either a drag-line or drag scraper.   The main portion of the
excavator is located above the water and only a bucket enters the water. Potential contaminants


that could be introduced as a result of this mining process and their sources are provided in
Table 5.

Groundwater turbidity may be increased due to physical disturbance of the  aquifer materials
during mining.  Turbidity may also be increased by incidental generation of highly turbid runoff
due to erosion of disturbed areas. The turbid water can enter the ground-water either by direct
discharge into exposed groundwater or by  infiltration through coarse materials.   Sediment
clogging of the aquifer media by turbid waters is a key factor in determining how far gravel
mining-related turbidity will  travel  through an aquifer.  Sediment clogging is an important
mechanism in reducing the hydrologic connection between the mining operations and the aquifer
system.  Mining should be started at the downgradient side of the deposit.  This will preserve
the clogging layer as mining proceeds upgradient. Development of the clogging layer can be
enhanced by early reclamation of the downgradient face of the excavation to increase vegetative

One risk of excavating into an aquifer is the potential for destroying the hydrologic barrier
(confining layer) that separates aquifers. If such a barrier is destroyed,  the  water in the two
aquifers can mix, potentially affecting the water quality or water levels in both aquifers.

When a lake is formed by excavating gravel out of the aquifer, a shift in the local groundwater
levels can result.  Groundwater levels immediately adjacent to the pit will be lowered at the
upgradient end  of the lake and raised at the  downgradient end of the lake.  The magnitude of
the impact can be approximated by multiplying one-half the length of the lake by the local
groundwater gradient.  In addition, gravel removal from below the water table can cause short-
term decreases in the groundwater level in proportion to the volume of gravel removed. After
mining has ceased, one beneficial effect is to increase the storage capacity in the area of the lake
(Landberg, 1982).   Thus, more water can  be extracted from wells near the lake with less
drawdown in the water table because of the large amount of water available in the lake.

Water chemistry effects have been studied by various researchers such as  Rasmussen  (1985),
Perjes (1982), Kothari (1985) and Perry (1986). These authors concluded that the mere presence
of a  lake resulting from previous gravel  mining operations did  not necessarily degrade
groundwater quality.  The authors determined that lake water generally has a higher pH,  and
lower alkalinity, calcium and magnesium hardness, iron and manganese, and total dissolved

                              Table 5

Spills or leaks from equipment and storage
Seepage from working face
Storm water runoff from disturbed areas,
Stripping and digging operations
Runoff form overburden, waste piles, and stock
Dust suppressing activities that generate runoff
or infiltration
Dust suppression
Oils and grease
Hydraulic fluid
Suspended solids
*Source: Ecology, 1993

solids concentrations than water from upgradient and downgradient wells.  The changes in the
water quality of the groundwater exposed as lake water result from oxidation reactions due to
exposure to air and biological processes.   However, if contaminants are allowed to enter this
water during or following  mining,  the lake  can  serve  as a conduit to the hydrologically
connected groundwater.


Associated activities such as concrete or asphalt batch processing, truck washing, equipment
maintenance, and spills and leaks of oils, grease, fuels and hydraulic fluid from tanks and other
equipment can potentially infiltrate soils and impact groundwater resources.  These associated
activities are discussed in this subsection.

Concrete batch  plants sometimes associated with  gravel mining  operations produce  process
wastewater with a  pH typically in the range of 11  to  12  (Ecology,  1993).   Some cement
additives contain constituents that have a high biochemical oxygen demand or  high nitrate
concentrations  and can  result in  these contaminants reaching  groundwater.  Storm  water
discharges from  concrete batch  plants can also introduce  these  same contaminants into  the
groundwater. Gravel processing equipment and trucks require routine cleaning, lubrication and
general maintenance.  Potential  contaminants  that could be introduced as a result of gravel
processing operations and their associated contaminant sources  are provided in Table 6.

Treatment technologies for wastewater generated in concrete batch plants typically include the
use of settling basins, ponds, or clarifiers (sometimes in conjunction with flocculation) for the
removal of suspended solids.  Skimming of the pond surfaces or oil/water separators are used
for removal of oil and grease. Sulfuric acid addition often provides pH adjustment.

Asphalt batch plants are potential sources of hydrocarbon contamination of both groundwater and
surface water.  Asphalt batch facilities that use  a wet scrubber to reduce air emissions discharge
suspended solids and oil and grease to a cooling and  settling ponds.   Unlined ponds  can
adversely affect groundwater quality by allowing  wastewater  to  infiltrate without treatment.
Trucks  are cleaned and  maintained  onsite using solvents or detergents and may present the
potential for diesel fuel to be spilled.  If this water is not directed to a lined treatment  pond, it
may collect and percolate into groundwater,  or it may mix with other process wastewater.

                                     Table 6

                          PROCESSING OPERATIONS*
Spills, leaks from equipment and storage tanks
Maintenance shop
Asphalt batch plant (scrubber water)
Drive-through truck washers
    Oils and grease
    Hydraulic  fluid
Concrete batch plant mix water
Cement bagging operations
Concrete truck wash water
Concrete batch plant wash water
      pH increase
    Dissolved solids
Residue from blasting
Concrete batch plant
Cement bagging operation
Stormwater runon/runoff
Asphalt batch plant scrubber water
Concrete truck wash water
washing, screening or crushing rock
discharge from settling ponds
    Suspended solids
Concrete batch plant mix water
Concrete truck wash water
Cement bagging operations
Concrete admixtures with:
     dissolved solids
Source: Ecology, 1993;

Treatment technologies for asphalt batch plants typically include the use of settling ponds for
suspended solids removal.  Skimming of the pond  or  oil/water separators can be used for
removal of oil.  Treated wastewater can also be recycled.

Vehicle washing should occur over paved areas and wastes generated should be treated in a lined
sedimentation basin prior to discharge.   Vehicle  maintenance should also be performed  over
paved areas where drips and spills can be easily contained.   Vehicles that are stored onsite
should have drip pans placed beneath them to collect any fluids.

5.3    SUMMARY

In summary, gravel mining and associated activities can adversely affect groundwater  quality.
Gravel mining, in general, poses moderate risks to groundwater quality and quantity (Thurston
County, 1990).  Each minirtg operation has a different set of mining and processing activities
associated with it. Therefore, the potential impacts to groundwater from an operation must be
determined by examining the" specific activities at  a facility. Each associated activity can have
different effects on the groundwater quality and requires careful  consideration about the most
appropriate  management practices  and  treatment technologies.   To: minimize the  risk of
groundwater quality degradation, oversight  of project design and approval  should  include
assessing the activities and requiring treatment technologies appropriate to the activities at the

Regulatory oversight should continue during operations to ensure practices minimize the potential
for groundwater contamination.   The oversight could include groundwater monitoring during
operations and following closure to provide detection and early intervention should contamination

The Tulalip Reservation currently relies solely on groundwater as the source of drinking water
(except in the southeast corner of the  reservation).  In sparsely populated areas septic tanks
provide a sanitary  and  economical means  for  disposing of domestic sewage.   Extensive
development can make reliance on septic tanks as the only means of domestic sewage disposal
impractical if the water quality of the aquifer is to be protected.  In an effort to better protect
the groundwater resources of the Tulalip Reservation, the density of septic tanks in use should
be monitored and possibly limited. This chapter provides an approach for estimating the septic
tank density for an given area that would preclude degradation of the groundwater quality in the
uppermost aquifer at the Tulalip Reservation.


The antidegradation policy is a provision in the Ground Water Quality Standards (Chapter 173-
200  Washington  Administrative  Code  [WAC]) that is legislatively  mandated  for  state
groundwater in the Water Pollution Control  Act (Chapter 90.48 Revised Code of Washington
[RCW]).  While these policies and standards do not apply to tribal groundwater,, the Tulalip
Tribe may choose to implement  parallel laws and policies.  The  purpose of the state waste
quality law is to protect and maintain existing and future groundwater quality, by allowing the
absolute  minimum  level  of degradation.   The  antidegradation policy goes beyond  merely
preventing the violation of the drinking water standards or other numeric criteria. This policy
prohibits degradation of groundwater quality unless  two specific conditions are met.  First, a
discharge to the ground must meet the state technology-based standard of "all known, available,
and reasonable methods of prevention, control, and treatment." Second, the activity potentially
causing the water quality degradation must be determined to be in the overriding public interest.
If these conditions are met, the antidegradation policy places a restrictive cap on the level of
degradation allowed (i.e., the numeric  criteria).

According to Kimsey (1992), the Washington  Department of Ecology (Ecology) received
numerous requests from local governments, developers and consultants for guidance in designing
onsite domestic disposal systems which would be in compliance with the Ground'Water Quality
Standards.  Ecology responded with an options paper that listed various alternatives.  The
Department of Health (Health) recommended  that a committee comprised of representatives from
Health, Ecology, and local health districts be  assembled. The Ground Water and Septic Systems

(GWASS) Committee was organized to determine how onsite sewage disposal systems could be
managed to meet the intent of the antidegradation policy in the Ground Water Quality Standards.


The options paper provided the following alternatives to protect groundwater from contamination
by septic systems:  1)  hook-up to a regional sewer system, 2) use alternative onsite systems
which provide additional biological and chemical treatment, 3) use alternative onsite systems
which are nondischarging, and 4) establish a density requirement that controls the mass loading
of contaminants to the subsurface (Kimsey, 1992). If conventional septic systems are the method
of onsite sewage disposal, then population density is the most important factor in controlling
groundwater contamination  from that source.  In other words, controlling the number of septic
tank systems in a given area based on the mass loading of contaminants from residential areas
is  the easiest and  most comprehensive method of protecting groundwater quality from the
cumulative impacts of conventional septic systems.

Major  contaminants of concern in domestic wastewater  include nitrogen species, pathogenic
microorganisms, metals and organic compounds (although there are many others).  Nitrate is
often selected as the indicator parameter to evaluate the relative impacts on groundwater quality.
Nitrate is  extremely mobile due to a high solubility; it is anionic in form and is non-reactive,
therefore, nitrate is  an environmentally  conservative estimate (an indicator of worst  case
conditions) of the  relative degradation  of the water quality of the aquifer.  Nitrate is also a
contaminant of interest because elevated  concentrations above  the 10  milligrams per liter of
nitrate-nitrogen federal and  state maximum contaminant level can cause methemoglobinemia in
infants (see Glossary for discussion of disease).  Excessive ingestion of nitrate may also cause
cancer in adults.

Nitrogen contamination of groundwater resulting from onsite sewage disposal systems depends
upon the density of households, the contaminant loading in the wastewater discharged, local soils
and  geology, the depth of the aquifer, the direction  and  rate of groundwater flow,and the
ambient concentration of nitrate in groundwater.  Nitrate contamination is extremely difficult to
remediate, and therefore, groundwater protection is important.

Computer models can be used to determine relative impacts of domestic sewage on groundwater
quality,  Random-Walk is  one numerical model that can  be  used to simulate  contaminant
transport including the effects of advection, dispersion, and the reactions of chemical constituents

in groundwater.  Statistical models can also be utilized to estimate reasonable nitrogen loading
based on average parameters and associated uncertainty values.

By  examining mass loading in septic tank wastewater in a series of contaminant transport
simulations, Ecology  attempted to determine the area necessary to meet the intent of the
antidegradation policy in the Ground  Water Quality Standards (Kimsey, 1992). The Random
Walk computer modeling program was used as a predictive tool by Ecology to estimate the area
necessary to assimilate contaminants from septic tank systems, and thus, the area necessary  to
protect the  groundwater  quality.  By assuming average conditions statewide, Ecology was able
to apply the model results to the majority of situations found across  the state.   Degraded
groundwater in  this model  is  defined  as an increase  in  ambient nitrate concentration  in
groundwater of 2 milligrams of nitrate-nitrogen per liter (mg NO3-N/L), or the level which
would cause an exceedance of the criterion (10 mg NO3-N/L) whichever is more stringent. The
area necessary to assimilate contaminants released  from an onsite sewage system based on the
degree of contaminant loading and site conditions was calculated and a set of curves was plotted
(Kimsey, 1992). Knowing the existing water quality and site conditions, these curves can be
used to determine the minimum land area requirements for a site (Kimsey, 1992).

Thurston County examined potential sources of nitrate including  septic systems in the recharge
area of McAllister Springs  (Colder,  1990).   The purpose of the study  was to  develop a
hydrogeologic understanding of the McAllister Springs Geologically Sensitive Area and  to
determine the relationship between land use and groundwater quality. A statistical analysis  of
groundwater data was performed and nitrogen loading  from land use activities including septic
systems, lawn fertilizers, agriculture and stormwater runoff was analyzed.  The nitrogen loading
from septic tanks was determined to be minor in comparison to the loading from agricultural
activities (Golder, 1990). Septic tank loading was estimated at 45 mg/L NO3-N with an average
per capita  wastewater production rate of 45 gallons  per day (Golder, 1990).  The Thurston
County study resulted in establishment of a limit of one residence (septic system) per five acres.
While these data may be useful, an optimum septic tank density would  need  to consider site-
specific conditions and other land uses within a wellhead protection area.


Based on the delineated 25-year zone of contribution, a septic tank density analysis is not
recommended for protection of Wellfield Number  1.  However,  an analysis of this  type would
be useful for the protection of private well owners in the vicinity.  The site conditions including
location, climate,  land  use,  hydrology,  geology, hydrogeology, and  potential contaminant


sources found within a wellhead protection area provide the framework for a septic tank density
analysis to protect groundwater quality.   All  existing  groundwater quality  data  should  be
evaluated  for baseline geochemistry, trends,  and contaminants of concern.   Demographic
indicators such as housing density and average number of persons in each household should be
studied.  For the reasons discussed in Section  6.2, nitrate is a good indicator parameter for
evaluating potential degradation of groundwater quality from septic tank sewage disposal.  A
statistical analysis  of the nitrate data for years prior to and following additional development
should be performed.   Nitrogen loading from  septic tank  wastewater disposal  activities
upgradient of Wellfield  Number 1  can  be estimated.   The curves for  average nitrate
concentration versus nitrogen mass developed using Random Walk (Kimsey,  1992) can be used
to estimate the minimum land area  requirements between  septic tanks.  If a more detailed
analysis is warranted, an analytical or numerical groundwater flow and/or contaminant transport
model may be warranted.


The tasks and associated  estimated costs for establishing an optimum septic tank density are
presented under two options in Table 7. Please note these are estimates only.   Both options
include sampling to develop baseline nitrate data. In the first, these data are  used to implement
the Kimsey  (1982)  approach  to  establish  a septic tank density based on typical aquifer
characteristics. The second option would utilize the nitrate data as input to a numerical flow
model with contaminant transport capabilities such as Random Walk.

All of the tasks described may not need to be performed.  The location and gathering  of the
available data could be performed or facilitated by the Tribal representatives. The collection of
field and laboratory data would be dependent on the amount and quality of the existing data.
The actual scope  of the  project  would  need  to be determined in collaboration with  Tribal

                          Table 7

Project Management
Locate, gather, and evaluate existing nitrate
data. (Sources include USGS and Supply well
Ascertain need for additional data
Sample 12 wells four times each over a one
year period for nitrate-nitrogen
Implement Kimsey approach with statistical
Write draft and final reports.

Project Management
Locate, gather, and evaluate existing nitrate
data. (Sources include USGS and Supply well
Ascertain need for additional data
Sample 12 wells four times each over a one
year period for nitrate-nitrogen
Perform Random Walk or similar model
Write draft and final reports.



This project identified  zones of contribution for the Tulalip  Wellfield  Number 1.   The
delineation depicts three capture zones based on MWCAP and GPTRAC modules of the EPA
WHPA model.  The first scenario includes use of MWCAP for a steady-state capture zone
(Figure 1). The GPTRAC module was used to predict time-related capture zones for a 10-year
time of travel (Figure 2) and a 25-year time of travel (Figure 3).

The most environmentally protective capture zone (the protection zone that covers the largest
area) is the steady-state capture zone depicted in Figure 1.  However, because the capture zone
extends beyond the Tribal boundary, it is not practical to regulate activities within it.  Since the
GPTRAC module accounts for the effects of multiple well interferences in the wellfield, this
module was utilized to delineate the time-dependent zones of contribution.  Figure 2 depicts the
least environmentally protective  zone of contribution, the GPTRAC  10-year time of travel
scenario.  The 25-year zone of contribution, depicted in Figure 3, is the more environmentally
protective time-dependent capture zone and does not seem to be economically prohibitive. While
the 25-year time of travel is recommended as a wellhead protection area, the final decision for
the extent of a wellhead protection area is a policy decision, based on careful consideration of
technical merits of the various scenarios  and the needs and interests  of the Tulalip Tribes,

Sources of potential pollutants comprise primarily residential  activities.  Activities that may
adversely effect the groundwater quality include: inappropriate disposal of household chemicals
and solid waste,  automotive repair, lawn and garden activities, and  septic systems.   Other
sources of potential pollutants can come from poor management of wellhead areas, transportation
corridors, stormwater disposal, and forestry practices.

BMPs were developed for the types of pollutant sources identified. These BMPs were designed
to be used in educational  campaigns.   Pages of BMPs in Appendix B can be withdrawn,
reproduced,  and used as they are presented;  or the information can be used in brochures or on

Mitigative measures are presented  that may be implemented should a commercial source  of
gravel be developed in the Wellhead area. Gravel mining and associated activities can adversely
affect groundwater quality. The potential impacts to groundwater from an operation  must be
determined by examining the specific activities employed at a facility.   Useful technologies
include collection of wastewater and runoff and diversion into lined settling ponds.  Machinery
and vehicular repairs should be performed over an impervious surface and wastewater directed
to an oil/water separator.


Section 6.0 describes methodologies to establish an optimum septic tank density in the wellhead
protection area and provides an estimated cost to perform an optimum density study.

                                8.0 REFERENCES
Anderson, M.P.  and Woessner,  W.W.  1992.    Applied  Groundwater  Modelling
      Simulation of Flow and Advective Transport, Academic Press, Inc.

Banton,  D. and Kenrick, M.  1990.   The Thurston County Health Department on
      Hydrogeologic Evaluation of McAllister Springs Geologically Sensitive Area,
      Golder Associates, September 10, 1990.

Blandford, T.N. and Huyakorn, P.S. 1991.  WHPA - A Modular Semi-Analytical Model
      for the Delineation  of Wellhead  Protection  Areas.  Prepared  for the  U.S.
      Environmental Protection Agency, March 1991.

Carpenter Drilling, 1988. A Pump Test Analysis using Jacob's Form of Theis Equation
      and Least Squares Method.

Drost, B.W., 1983.  Water Resources  of the Tulalip Indian Reservation Washington,
      U.S.   Geological Survey, Water-Resources Investigations. Open-file Report 82-

Ecology. 1993.   Draft General Permit Fact Sheet for  Process  and Storm Water
      Associated with Gravel Operations, Rock Quarries, and Similar Mining Facilities
      Including Stock Piles of Mined Materials, Concrete Batch Operations and Asphalt
      Batch Operations.  Department of Ecology, Olympia, Washington. August 18,

Freeze,  R.A., and Cherry, I.A. 1979.  Groundwater. Prentice-Hall, Inc., Englewood Cliffs,
      New Jersey.

Gobin, T. 1993. Tulalip Reservation. Personal communication with Kerry Schwartz, Science
      Applications International Corporation. 1993.

Golder Associates, Inc. 1990.  Hydrogeologic Evaluation of McAllister Springs  Geologically
      Sensitive Area. Prepared for Thurston County Health Department. September 10,1990.

Kimsey, M. 1992.  Ground Water and Onsite Sewage Disposal Systems: Establishing Density
      Criteria to Protect Ground Water  Quality, Washington  State Department of Ecology,
      Water  Quality Program, December 3, 1992.

Kothari, N. 1985.  Evaluation of Gravel  Extraction on Groundwater Movement and Quality.
      South Dakota State University M.S. Thesis.

Landberg, J. 1982. Hydrogeological Consequences of Excavating Gravel Pits Below the Water-
      table in Glaeiofiuvial Deposits. Chalmers University of Technology, Gotenborg, Sweden
      and University of Gotenborg Doctor of Philosophy Thesis.

Mulla, D. J.,  Hermanson, R. E., and Maxwell, R. C. Undated.  Pesticide Movement in Soils-
      Groundwater Protection. Washington State Cooperative Extension Publication Number
      EB1543.  College of Agriculture and Home Economics Washington State University,
    '  Pullman, Washington.

Perjes, T. 1982.  Hydrogeological and Environmental Analysis of the Relationship Between
      Surface Mining and Riverine Water Wells. International Mine Water Association First
      Conference (Budapest, Hungary. April 19-24.

Perry, M. L.  1986.  Impacts of Large-Scale Gravel Excavations, Precipitation and Runoff on
      Groundwater Movement and Quality. South Dakota University M.S. Thesis.

Rasmussen, J. R. 1985.  Seasonal Effect of Large-scale Gravel Excavation on Groundwater
      Quality. South Dakota State University M.S. Thesis.

Revised Code of Washington,  Chapter 90.48 RCW.  Water Pollution Control Act.

Thomas, B. 1993.  U.S. Geological Survey, Washington. Personal communication with Kerry
      Schwartz, Science Applications International Corporation. 1993.

Thurston County. 1990.  The Direct and Cumulative Effects of Gravel Mining on Ground Water
      within Thurston County, Washington, public review draft.  Ground Water Management
      Program, Environmental Health Division, Thurston County Public Health and  Social
      Services Department.

Todd, D.K., 1980, Groundwater Hydrology. John Wiley & Sons, New York, New York,

Washington Administrative Code, Chapter ,173-200 WAC.  Ambient Water Quality Standards
      for Ground Waters of the State of Washington.

Well #4

Well #5

Well #6

Well 87
                        Figure A-1


wall #4
Well #5
Welt 86
Well #8
Well #9
                         Figure A-2

Well #4
Well #5
Well #6
Well #7
                        Figure A-3


Well #5

Well #6

Well «7
                        Figure A-4


Well #4

Well #5

Well #6

Well #7
                        Figure A-5


  Wei! #4
  Well «5
  Well #6
- Wait #7
                          Figure A-6

Well #4
Well #5
Wei! #6
Well #7
                        Figure A-7

                      TULAL1P INDIAN
              Wei! #4

              Well #5

              Well #6
              Well #7
                                       Figure A-8

                         25-YEAR OF CONTRIBUTION SENSITIVITY

                      TULALIP INDIAN
              Well #4

              Well »5

              Well #6
              Well 87
                                        Figure A-9

                        25-YEAR ZONE OF-CONTRiBUTION SENSITIVITY
                           ANALYSIS - MINIMUM CONFINING LAYER
                                 HYDRAULIC CONDUCTIVITY

Wall its
Well #6
Well #7
                       Figure A-10


               TULALIP INDIAN

        Weil #4
 	  Well #5

        Well #6

        Well #7
                              Figure A-11


                      TULALIP INDIAN
              Wei! #4
              Wei! #5
              Wai! #6
              Well #7
                                     Figure A-12



     Leave grass clippings on lawn to release nutrients as they decay.

     Fertilize lawn with fertilizer that is time-released.

     Apply water only when the weather does not provide enough natural
     moisture.  Apply enough water to .soak roots (not more than an inch
     per week even in the dry season).

     Aerate lawn twice per growing season.

     De-thatch lawn when thatch exceeds 1/2-inch thickness.


     Apply fertilizer to .match plant and soil needs. (Test soil to determine
     fertilizer needs.)

     Read the label of fertilizer before you buy it.


     Time fertilizer application to match the garden needs.


     Do not over water following fertilizer application.  Nitrates can be
     leached to the groundwater.




          Time plantings  so that plants peak at a time when the pest
          population does not peak

          Recognize pests and remove the pests when their populations are

          Prune infested plant parts- and remove from area.

          Remove insects by hand.

          Establish barriers such as plant collars, wire mesh or tanglefoot
          to prevent access to pests.

          Solarize soil (Place two layers of clear plastic sheeting over soil
          in hottest time of year. Allow soil to absorb heat and kill fungus
          and insect larvae for 4 to 8 weeks.)


     Plant companion plants that deter plant predation.

     Use pheromone traps or sticky traps to remove pests.

     Select plants adapted to the northwest climate.

     Rotate crops from year to year using different plant families in
     different garden locations.


     Insecticidal soaps are relatively non-toxic to the environment.
     Mineral-based chemicals are less toxic than botanical pesticides.

     "Use the appropriate pesticide to remove the pest.

     PESTICIDE (See Table 4-1  for examples)

     Read the label of pesticide before you buy it.

     FOLLOW  label  directions.  DO  NOT  OVER

' • ..-• - . • 	
(half-life < 30 days)
Aldicarb (Temik®)
Alachlor (Lasso®)
Butylate' (Sutan®)
Dicamba (Banvel®)
Metalaxyl (Apron®)

Moderately Persistent
(half-life > 30 days but < 100 days)
Atrazine (AAtrex®)
Carbofiiran (Furadan®)
DCPA (Dacthal®)
Glyphosate (Roundup®)
Metribuzin (Sencor®)
Pronamide (Kerb®)
Simazine (Prineep®)
Terbacil (Sinbar®)
Triallate (Fargo®)
Trifluralia (Treflan®)
, (half-life > 100 days)
Bromacil (Hyvar®)
DBCP (Nemagon®)
Dieldrin (AJvit®)
Diuron (Karmex®)
Picloram (Tordon®)

• -t^:T^;v',yu;y;:^nt^x5;5r;.^;5n»^
(coefficient* < 30)
Aldicarb (Temik®)
Carbofuran (Furadan®)
Dicamba (Banvel®)
Metalaxyl (Apron®)
Picloram (Tordon®)

Moderately Mobile
(coefficient > 30 but < 300)
AlacMqr (Lasso®)
Atrazine (AAtrex®)
Bromacil (Hyvar®)
DBCP (Nemagon®)
Metribuzin (Sencor®)
Simazine (Princep®)
Terbacil (Sinbar*)

(coefficient > 300)
Butylate (Sutan®)
DCPA (Dacthal®)
Dieldrin (Alvit®)
Diuron (Karmex®)
Glyphosate (Roundup®)
Pronamide (Kerb®)
Triallate (Fargo®)
Trifluralin (Treflan®)
* Source:  Mulla, DJ. et al. Undated.
a     Coefficient = Mobility coefficient as defined in Mulla, D.J. et al. (Undated) is an expression
      of the tendency to move with water through the soil media.  The higher the coefficient the
      lower the mobility.

Do not mix chemical pesticides over pervious ground or within
100 feet of a well.

During mixing do not place end of hose into mixing container,
because water can siphon back into well.

Mix only the amount of pesticide needed.  Do not dispose of
excess pesticide to septic system, within 100 feet of a well, near
a water course, or to pervious  ground.   Dispose of excess
pesticide in  appropriately labeled container  on a Snohomish
County Hazardous Waste Collection Day.

Store chemical pesticides under a roof, away from precipitation,
and away from extreme temperature changes.

BE PREPARED  FOR A SPILL.  Keep kitty litter  or other
absorbent available.

In the event-of a spill:

      Stop the source of the spill.
      Contain the spill  with sorbent.
      Cleanup the sorbent and contaminated soils.


    Use non-toxic products for cleaning in households. Less-toxic product
    substitutions can include:
Dish of vinegar or lemon juice
BaMng soda
Baking soda and toothbrush
BaMng soda
Cornstarch paste
Vinegar (2 tablespoons per quart of
Air Freshener
Scouring Powder
Tile cleaner
Toilet bowl cleaner
Stain Rentdver
Glass cleaner

    Store chemicals indoors.

    Re-use paint thinner by allowing paint solids to settle in closed
    container and slowly pouring off upper layer of thinner.

These BMPs and mitigative measures apply to private as well as community
wells. The area immediately surrounding each well is a potential pathway for
pollutants to enter the groundwater.


      Ensure well is properly sealed at the surface.

      Properly seal abandoned wells.

      If well is greater than  15  years old, use a downhole video
      camera to assess integrity.


      Do not mix,  store, or  apply pesticides, herbicides  or other
      chemicals within 100 feet of the well.

      Do not wash vehicles pr equipment within 100 feet of well head.

      Direct stormwater away from the wellhead.

      Protect the well from unauthorized entry with fencing.

     Allow moisture from small quantities of latex paint to evaporate, then
     dispose of cans in a garbage can or landfill.

     For spills of chemicals to ground,

           Stop the source of the spill immediately
           Control spill using absorbent such as kitty litter
           Remove contaminated sorbent and soils
           Dispose of contaminated absorbent and soils in trash


     Store solid waste in appropriate trash bins and dispose of at a

     Recycle as much as possible




     Do not flush materials that are difficult to decompose (e.g., hair, baby
     diapers, tampons, cigarette butts) into the septic system.

     Install water-saving  devices to reduce  the amount of wastewater

     Balance water use activities evenly over a week to reduce the hydraulic
     loading to the septic system. For example, do not wash several loads
     of laundry,  run the dish washer, and discharge a bath tub all within a
     short period of time.

     Pump septic tank every 3 to 5 years.  In the interim inspect to ensure
     sludge has not accumulated to more than one-third the depth.

     If a garbage disposal is used, pump the septic more frequently than
     once every 3 to 5 years.

     Maintain accurate inspection and tank pumping records.

Protect the drainfield.   Encourage grass to  grow over the
Don't allow soils over drainfield to become compacted by using area
to graze large animals, store heavy equipment,  or as a patio.  Do not
cover drainfield with impermeable surface such as plastic or paving.


Divert stormwater from roofs and runoff away from drainfield.


     In the event of a spill in the vicinity of the well:

         Eliminate source of spill.
         Confine spill and direct away from wellhead.
         Clean up spill with absorbent.
         Excavate contaminated soils


Storm drains can function to directly recharge the aquifer or surface waters.
Care should  be taken to ensure that  wastes are  not inadvertently or
intentionally disposed of to storm drains. A public education campaign can
serve to heighten awareness in the community.


     Stencil  all drains with signs that  state: DO NOT  POUR

     Develop and maintain grassy swales for stormwater designed for
     10-year storm event, where feasible


     An integrated pest  management  plan should be  developed  and
     implemented for forestry practices.

     Ensure any pesticides applied to forest lands  are applied by
     certified pesticide applicators.

     Ensure pesticides are applied at times and frequencies specified
     on the label and at application rates no greater than specified on
     the label.

     During tree harvesting,  use equipment that will result in the least
     compaction of soil as possible.

     Replant the area quickly.

                       BMPS FOR

     Prepare a spill plan for petroleum products being transported
     across highway in the recharge area.

     Delegate specific spill responders and an emergency coordinator and
     train them.

     Coordinate with local spill response agencies before a spill.

     Purchase and provide easy access to spill response equipment
     such as absorbent pads and booms for spills.

     Provide the local population with emergency phone numbers to
     report spill events.

     Contain and  confine spill.  DO NOT WASH SPILLS DOWN WITH
     WATER.  Remediate as quickly  as possible.

Lakes located in the recharge zone of an aquifer can serve as windows for
entry of pollutants from the lake into the groundwater.  Care should be taken
to minimize the addition  of such  pollutants as diverse as  oils,  aquatic
pesticides, and bacteria from human or animal use.

      Prepare a spill plan for motor fuel spills on lakes.

      Designate a spill coordinator and spill responders.

      Provide training for spill responders.

      Provide local population with emergency phone numbers to  report

      Post emergency numbers in boat launching areas and marinas.

      Purchase and provide easy access to sorbentpads and booms for spills
      on the lake.

      Control and contain spill with sorbent pads.

      Remediate spills as quickly  as possible.

Alkalinity - the amount of carbonate or hydroxide of usually lithium, sodium, potassium,
rubidium, cesium,  or francium, the aqueous solution of which is characteristically basic
in reactions.

Anionic - negatively charged  chemical species that attract positive ends of the water

Aquifer - rock or soil in a subsurface formation that is sufficiently permeable and
saturated to yield significant quantities of water to wells.

Aquitard - a confining layer that slows but does not prevent the flow of water to or from
an adjacent aquifer; a leaky confining layer.

Best Management Practices (BMPs) - suggested methods of implementing an activity or
set of activities that provide a greater degree of protection for the resource.

Biochemical  Oxygen Demand (BOD) - the amount of dissolved oxygen required by
bacteria to decompose organic material under aerobic conditions; the BOD is considered
a useful expression of pollutant loads.

Cone of Depression - a depression of the groundwater table surface or the potentiometnc
surface that has the shape of an inverted cone and develops around a well that is being

Confining Layer  - a hydrogeologic unit of impermeable or distinctly less permeable
material bounding one or more aquifers, an aquitard.

Dovragradient - in the direction of groundwater flow.

Drawdown - effect of pumping that extends a given distance radially from the well, with
the radius  a function of well  construction, pumping  rate  and duration, and aquifer

Groundwater - water contained in the interconnected .pores below the ground surface and
in the saturated zone.

Recharge - water that percolates down from the land surface through the unsaturated zone
to the water table.

Semi-confined Layer - aquifers that lose or gain water through adjacent less permeable

Steady-state Zone of Contribution - the surface  or subsurface area  surrounding a
pumping well that supplies groundwater recharge to the well over an infinite period of

Suspended Solids - undissolved particles that are carried with the flow of water, greater
in diameter than 50 angstroms and removable by filtration.

Time of Travel - the time required for a particle of water or a contaminant to move in the
saturated zone from a specific point to a well.

Time-dependent Zone of Contribution - the surface  or subsurface area surrounding a
pumping well that supplies groundwater recharge to the well over a set period of time.

Transmissivity - the rate at which water is transmitted through a unit width of the aquifer
under a unit hydraulic gradient.

Turbidity - a measure of water clarity based on the amount of total solids (dissolved  and
suspended) in water.

Unconfined Aquifer - conditions in  which the  upper  surface  of the zone of saturation
forms the water table.

Upgradient - in the opposite direction of groundwater  flow.

Water Table - the top surface of the water saturated zone or potentiometric surface in an
unconfined aquifer.

Well Discharge - the volume of water pumped from a well in a certain time period.

Wellfield - an area containing two or more wells.

Wellhead - the location where a well enters the ground. Usually a pump is mounted on
top of the wellhead inside of a well house.

Wellhead Protection Area (WHPA) - the surface and subsurface area through which
contaminants are likely to move toward and reach a water well or wellfield.

Zone of Contribution (ZOC) - the area surrounding a pumping well that contributes water
to the wel.

       Gila River Indian Community
Comprehensive Wellhead Protection Strategy
                 Prepared for

         Gila River Indian Community
         Water Quality Planning Office
                 Prepared by:

           Lee Wilson & Associates
                 October 1994

                                    Section 1
                      Wellhead Protection  Strategy
                            Executive Summary


A Wellhead Protection (WHP)  Strategy  has been developed to provide the Gila River
Indian Community (GRIC) with analysis of the existing groundwater conditions, concepts
relevant to WHP for GRIC, and a  specific set of steps for implementation of a WHP
Ordinance. In particular, the strategy has the goal of developing an effective management
tool integrated into GRIC's existing structure  which  GRIC can use to protect  their sole
source of drinking water:  groundwater pumped from wells.

The scope of the present WHP Strategy  effort is to  address the drinking water wells in
Basin A.  Basin A contains the largest concentration of drinking water wells and potential
contaminant sources (see Attachment L). Given the limited funding available to GRIC, this
represents a useful start, and once implemented, allows a quick expansion to address the
rest of GRIC (Basins B,  C, and D).  New wells will also be evaluated with the same

WHP was selected by GRIC as a beginning to its water quality management efforts because
it is an extremely efficient focusing of efforts on only the most pressing  threats to public
health at GRIC.  Only the wells used for drinking water supply, the areas on the ground
which can lead to contaminating them, and contaminants that have a high likelihood of
reaching the wells are addressed. This is far more cost effective than the more common
regulatory approach of regulating all areas and all contaminants. More complete  regulation
can be pursued in the future, but WHP places the first several lines of  defense hi place
quickly, and within the current administrative structure at GRIC.
                           Thresholds and Criteria

The standards for groundwater to be protected at GRIC were identified hi an earlier report
to EPA,  which became part of EPA's report to Congress: the 1992 Community Water
Quality Assessment under Section 305[b] of the Clean Water Act.   A key finding of
GRIC's 305[b] report was that the Community decided to benefit from the huge investment
made by  EPA in evaluating risk from various chemicals in drinking water and adopted the
federal Safe Drinking Water Act (SDWA) Maximum Contaminant Levels (MCLs).  The
one exception  was that GRIC  reinstituted an older,  more stringent fluoride standard to
protect children's teeth from mottling.

The criteria selected by GRIC for WHP was the time of travel to the selected wells.  The
closest zone to the well,  Zone 1, was defined as a fixed radius of 200 feet which was
assumed  to have a essentially immediate travel to the well. Zone 2 was defined as the zone
PHX\SWE34780Vll\EXEC_SUM.wp5                1-1

of groundwater which would travel to and be pumped up by the well in a 5-year period
(the expected length of time at GRIC to replace a well).  The final zone, Zone 3, was
defined as the 40-year time of travel zone (the likely service life of a well at GRIC).

The wells selected for protection were those wells within Basin A which were public water
supply wells under the definition of such from the SDWA: 15 service connections and/or
25 people served at least 60 days per year which would use the water, at least partially, for
drinking.  Thirteen such weUs in Basin A were identified by GRIC Water Quality Planning
Office (WQP) and were carried through the entire WHP Strategy development process.
                              WHPA Delineation

The delineation of the time of travel zones was a difficult effort because of the complex
geology beneath GRIC and the dynamic groundwater flows which change with time from
agricultural, season pumping and  river recharge  events.   First, an overall groundwater
budget was .developed for GRIC.   Then a computer simulation was developed from the
water budget which compared the simulated groundwater levels to  over 100 water level
measurements made in wells across GRIC.  Next, small quantities of groundwater, called
particles  were tracked in specialized computer  simulations of the groundwater system
beneath GRIC from the sources  of water  to  the wells of interest.   The areas  in the
simulation containing aU of the small quantities of groundwater which ended up at a well
after a set period of time defined the time of travel zones.  The 5- and 40-year time of
travel zones allowed the definition of Zones 2 and 3 around each of the 13 wells in Basin
                        Contaminant Source Inventory

A preliminary inventory  of potential contaminant sources  was made  in and around the
zones defined as  above.  Irrigated fields were found in each zone, as were laterals for
delivery of irrigation water.  More than 20 septic tanks and more than 20 industrial or
commercial  loading/use areas were found or thought to exist in WHPAs.  Highways,
roads, or railroads; and active or abandoned wells were the next most common potential
sources found. A preliminary ranking of the potential contaminant sources at GRIC in
Basin A in  the vicinity of the Wellhead Protection Areas (WHPA) began with sewage
treatment facilities, because of the potential for pathogens to move from older, pre-IHS5
systems.  Next likely would be solvent and fuel storage tanks associated with commercial
and industrial facilities.  Other rankings are possible, but pathogens,  solvents, and fuels
were judged  to  represent the  highest hazard  to  the WHPAs  among the  potential
contaminants and  sources reviewed here.
PHX\SWE34780UI\EXEC_SUM.wp5                1-2

                           Management Approaches

Two management approaches identified for  WHPAs in GRIC  were regulatory and non-
regulatory. Regulatory approaches included:

       *      Laws and regulations
       *      Permits
       *      Standards
       •      Monitoring
       •      Enforcement

and typically use either land use controls  (which  specify the means)  or performance
standards (which specify the desired end result). Non-regulatory approaches included:

       •      Policy statements
       *      Studies
       *      Action plans
       •      Data collection
       •      Education programs
       *      Technical assistance
       *      Best management practice promotion
       *      Special programs

Land ownership  and zoning were compared with  the WHPAs  delineated in this project.
Most of the WHPAs contain some allotted lands  which will require communication and
approval  from allottees to promote various proposed programs.  Most of the WHPAs
comprise  agricultural  or open  land  zoning,  which should make  for  a  simple WHP
implementation program.  Some commercial zoning is found in WHPAs which requires a
balancing of requirements.

There  were numerous individuals consulted for the federal, state, non-GRIC tribal and
other entity programs relevant to GRIC.  The more successful  programs in Spokane,
Washington, and the  Santa  Clara Pueblo, provided useful  ideas for GRIC's program
development. The many land use, sanitation, and environmental programs already worldng
at GRIC  provide a  framework  within  which WHP can be implemented  at  minimal
additional cost.
                       Contingency Planning Concepts

A wellhead contingency plan sets  forth the response of a water system to a specific
contamination  event which poses a serious  immediate or long-term threat to the water
supply; it provides for protection of public health and continuing provision of an adequate
water supply.  (Contingency plans also may deal with other threats to water service, such
as natural disasters and terrorism.)
PHXVSWE347SOU 1\EXEC_SUM -wpS                1 -3

 If a GRIC well were to be contaminated, potential responses would fall into the following

       •      When there is some indication, of pollution (e.g. routine monitoring observes
              an elevated level of a contaminant, or there is a known pollutant release
              from a spill or facility), it is sometimes sufficient to expand a monitoring
              program.   Expanded  monitoring  can  involve  a greater  frequency  of
              measurements  (e.g.  at a  public  supply  well),  testing  for  additional
              parameters and/or  drilling  of  special monitoring  wells  (e.g. between a
              pollution source and a public supply well).

       •      When  pollution is observed,  either  at a  source  or at a  well,  aquifer
              remediation (clean-up) is often an option.

       •      If monitoring  demonstrates that a well is contaminated to an unacceptable
              level, and  aquifer  clean-up  is not a viable  option  (at  least not in the
              short-term), then there are  essentially two choices:    install a  treatment
              facility to clean up the water produced by the well; or use a different water
              supply to  supplement  (blend)  or  replace  the contaminated well, on a
              temporary  or permanent basis.  Analysis  of the  problem  and the best
              solution will depend on the site-specific aspects  of the pollution.

In general, the third category is the  most critical for contingency planning, since if a well
is producing badly contaminated water, there will be  an immediate need to provide a
potable supply.  Each emergency will differ as to  time and form, and options such as
clean-up, treatment or replacement can only be analyzed in the context of site-specific data.
The option selected by GRIC in any given case would vary depending on the circumstances
of the particular situation.
                  Water Quality Monitoring Considerations

There are five primary approaches that can be taken to groundwater quality monitoring of

             At the public water supply well
             At the boundary of the WHPA
             At point sources
             At non-point sources
             At non-specific locations

Monitoring at the public water supply well addresses the critical point of use, but allows
widespread contamination of the WHPA prior to detection, and, because monitoring can
PHX\SWE34780\11 \EXEC_SUM.wp5                 1 -4

not practically be conducted continuously, this approach could inadvertently allow use of
contaminated water from the well for some time prior to detection.

Monitoring at the boundary of the WHPA addresses outside influences on the WHPA and
allows for natural  processes to attenuate contaminants before they reach the well, but it
doesn't address  internal  sources  and  is  subject  to  uncertainty in the delineation of  the
WHPA and changes in the WHPA should conditions change in the future.

Monitoring at point sources  is the standard method implemented  by federal and state
agencies (see RCRA for example) for  protecting  groundwater.   It is  effective if  the
monitoring system  is properly designed, constructed, and implemented, but is costly to  the
facility and leads to difficulties in defining a significant difference  between natural  (or
background) concentrations and potential releases.

Monitoring at non-point sources has the same advantages and disadvantages as monitoring
at point sources, with the additional disadvantage that there is rarely a facility operator to
conduct the monitoring.  However, existing wells  can often be used  for this  type of

Monitoring at non-specific locations has the ability to detect unanticipated sources.  A
drawback to this is that  identification of placement rationale  (other than blanket or grid
coverage) is difficult to develop.

Section 12 describes a  specific monitoring plan developed for the WHPAs in  Basin A
which  balances the considerations above and the limited financial resources  available to
                                Proposed Actions

Part IV presents the action plan for wellhead protection at GEIC.  Section 10 outlines a
proposed  ordinance for the Wellhead Protection  Program and  Section 11  discusses
individual elements of the ordinance.  Part TV" also proposes  specific management actions
for groundwater monitoring (Section 12), development of a contingency plan (Section 13)
and implementation of the Wellhead Protection Program (Section 14).

We have purposely not developed the ordinance to its fuE extent until the major proposed
elements of the ordinance can  be reviewed and commented on  by the Tribe and  other
parties and individuals.   Once the major elements  have been accepted by the Tribe, the
Water Quality Planning Office will proceed with development of the detailed ordinance.

Proposed Wellhead Protection Ordinance

The GRIG is  fortunate  in having in place a  strong foundation  for the  WHP program.
Because of this, the Water Quality Planning Office can achieve wellhead protection through
PHX\SWE347S0\ll\EXECJ5UM.wp5                1-5

the coordination  and expansion of the existing regulatory programs,  by means of:  1)
developing  and  implementing  a wellhead  protection ordinance; 2)  establishing  and
integrating "WHP sensitive overlay zones into other zoning; and  3) regulating potential
contaminant sources by imposing Activity Protection Assurance Requirements,

The critical concept in Wellhead Protection is to eliminate or reduce pollution sources
within WHPAs, which are the areas that contribute flow to public supply wells. There are
three zones for each well:

       •      Zone 1 is the area in the immediate vicinity of the well (within 200 feet),
              where a contamination event could effect the water withdrawn from the weE
              within a year or less;

       •      Zone 2 is the area representing a 5-year travel time to the well, and extends
              hundreds to thousands of feet from each well; and

       •      Zone 3  is the 40-year travel time  area, which can extend several miles
              upgradient from a well.

Within the designated WHPA sensitive overlay zones, high risk land uses would be banned
and activities posing a moderate or low risk would be regulated to reduce the potential for
aquifer contamination.  The level of risk is  determined by the types and quantities of
regulated substances, used by the activity.   The regulations would involve Activity
Protection  Assurance  Requirements,   such  as:    requirements for the preparation  of
Emergency Preparedness Plans and/or Hazardous Substance Management Plans; use of
Best Management Practices (BMPs) in the construction and operation of a facility; specific
performance standards for  facility construction and operation; inspection and monitoring
requirements,  and other regulations as  deemed necessary.  The requirements would  be
designed to be more protective in Zones 1 and 2 than in Zone 3, more stringent for higher
risk uses than for lower risk uses, arid more stringent for new uses than for existing uses.

Prohibited activities would  be addressed in the process of reviewing land use actions and
other permits.

Groundwater standards are accepted here as  current federal MCLs  plus the older fluoride
standard to protect children's teeth.

Because  they  are primarily industrial use wells, the WHPAs for  the Lone Butte wells,
Firebird Lake well,  and Tribal Farms wells have less restrictive requirements.

There are two major categories of potential, contamination that do not lend themselves to
the approach described above - agriculture, and spills and illegal dumping.

       *      To  reduce the potential for pollution from agricultural uses the Tribe would
              establish a public education program and monitoring program; and it would
PHX\SWE34780UI\EX£C_SUM.wp5                1-6

              ensure that wellhead protection concerns are reflected in the groundwater
              management plan being developed for the pesticide program.

       *      To address spills  and illegal  dumping  the Tribe has outlined a series of
              non-regulatory measures that would be implemented by the Tribe to reduce
              the incidence of illegal dumping such as establishing a telephone hotline.
              The Tribe is also proposing development of an ordinance, review of the
              emergency  response plan  to assure  wellhead protection  concerns  are
              reflected  in that  document,  and  developing  guidelines  on remediation
              strategies and standards for common types of spills so that response actions
              can be taken swiftly.

In addition to the establishment of WHPA zones, the regulation of uses within those zones,
and the provisions for special uses, the Water Quality Planning Officer would implement
other WHP actions such as reviewing current well  construction standards; developing
guidelines  on  how to  deal with specific types of contaminant  events  and establishing
standards for effective remediation; preparing a comprehensive contingency plan to deal
with a loss of supply; establishing and implementing the groundwater monitoring strategy;
and developing a public education program,

Proposed Groundwater Quality Monitoring Plan

Given the  financial constraints on  the GRIC, three levels of mbnitoring are proposed,
which represent differing levels of cost and protection.  The Water Quality Planning office
will  recommend to the  Tribal Council that  the Level 3 monitoring be implemented and
acted upon, preferably during Fiscal Year 1995.

Level 3 consists of monitoring water  pumped from each of 13 WHPA wells for:  Field
Parameters on a monthly basis;   Volatile Organics and Purgeable Aromatics, Fluoride,
Nitrate, and Pathogenson a quarterly basis; Pesticides, Herbicides, and Trace Metals on an
annual basis; Radioactivity, and Polynuclear Aromatic Hydrocarbons on an every 4 year
basis.  We estimate 80 person-days per year and $35,000 per year is needed for this level.
Monitoring of the jnew wells will be on the same schedule and for the same parameters as
for the WHPA wells in Level 2 described above.  The new monitoring  wells would  be
located to test for:  the potential for contamination from sources along the Gila River; the
potential for contamination from canals or from irrigation deep percolation; and potential
point-source contamination. Estimated installation costs for these 4 wells totals $50,000.
Increased annual monitoring costs due to adding these 4 wells is $10,000.
                 Actions for Contingency Plan Development

EPA has developed guidelines for contingency planning for public water supplies.  The
plan will not be a blueprint for particular actions as such (since  each emergency is
different), but rather a clear  procedure for coordinating a response to different types of
PHX\SWE34780\I 1 \EJCEC_SUM .wpS                1 -7

 events, in order to ensure that the correct actions are taken quickly.  The tasks outlined by
 EPA and presented in this strategy report cover such items as:

       *      Formation of a planning committee;

       *      Assessment of the water supply situation;

       *      Assessment of the potential sources of contamination;

       •      Assessment of replacement water supply options;

       •      Identification of  local logistical  support-personnel, equipment, chemicals,
              technical services;

       *      Designation of the lead decision makers; and

       •      Identification of financial resources.

WHP Implementation

Implementing the WHP management strategy requires four major steps; developing policy;
legally  establishing the program;  establishing  the administrative structure to make the
program work; and initiating program activities.  The recommended strategy can be put in
place using existing management authorities and structures and should not entail a great
investment of tribal resources, except for additional personnel.

Policy Development.  The  first step in implementing a successful WHP program at GRIC-
is consensus-building within the community.  As part of this study public meetings  have
been   held  to  discuss  WHP concepts  and methods  and  the  Tribe's   proposed
recommendations for a WHP program at GRIC.  Next, the WQP Office will need to work
with the staff and Tribal Council to establish tribal policy  on WHP.  Assuming there is
tribal consensus to pursue WHP, the issues to be addressed include:  whether to implement
the program under Tribal authority or whether to implement the program through EPA;
whether to implement it through regulation or policy; and whether to adopt, modify,  drop
or add to aspects of the recommended strategy.

Legal Considerations.  Once Tribal policy is established,  the WQP officer will need to
work with the Tribal attorney  and, as needed,  technical staff (primarily  representatives
from  other Tribal offices) to draft the specific ordinances and regulations.

Administrative Structure.  The main  considerations in establishing the administrative
framework for the WHP program  are to clarify the role of the Water Quality Planning
office and other offices, identify the costs and staffing needs of the. program, and identify
funding sources.
f>HX\SWE34780\ll\EXEC_SUM.wp5                1-8

The WHP program will be centered in the Water Quality Planning Office, which will be
responsible for establishing and supervising the program; planning; coordinating with other
tribal  offices and other  entities;  advising the Tribal  Council on  wellhead protection
concerns; acquiring funding; maintaining wellhead protection program records and reports;
ongoing training and research; and special studies.   The efforts of the WQP Office  will
need to be coordinated  closely with the staff of other tribal offices, particularly the Land
Use Planning Office; Hazardous Materials Office; Pesticide Control Office; and the Tribal
Environmental  Health Service Office.  In addition, the WQP Office will also need to
coordinate with federal, state and local governments.

It is anticipated that the major costs incurred for the program will be limited to the costs of
additional staff and the groundwater monitoring program.  It is probable that the WHP
program will require the addition of one or two more staff persons.  The Tribe would need
to budget about $31,500 - $33,000 per year/person plus the overhead costs associated with
the positions (insurance, telephone, supples, etc.) which could increase the salary costs by
60  percent or more.  The costs for the monitoring program  will depend on the level of
monitoring, selected by the Tribe which, as described above, would range between $10,000
and $45,000 per year plus,  for Level IE,  capital  costs of $50,000.   Federal and state
resources can be used  to he.lp implement the WHP program.   A management strategy
which  emphasizes  a  coordinated management approach, such as recommended here,  and
which  builds  on. past federal  funding  efforts, may  increase  the  Tribe's  ability to
successfully apply  for the  limited funds.

Program Initiation.  The WHP  program  can be  implemented in phases as the Tribe
develops the policies and regulations, staffing and other resources  required to put the
program in  place.   A recommended approach is provided below which can be modified
based on decisions made during the review of the proposed WHP Program.

First the emphasis is  on implementing those aspects of the wellhead protection management
strategy which provide the most protection for the least amount of effort and which address
the sources  which pose the greatest potential for contamination of the aquifer.  Phase I
would  Be initiated concurrently with establishing the administrative framework for WHP.

Phase  I

       *     Create WHPA sensitive overlay zones around each public supply well

       *     Prohibit all  new high risk uses from locating in WHP zones

       *     Place a moratorium on moderate and low risk uses locating in WHP zones
PHX\SWE34780\ll\EXEC_SUM.wpS                1-9

Phase II
Phase M
Phase IV
              Incorporate the regulations/policies of the WHP program into the Land Use
              Action Review process and other application reviews

              Incorporate WHP  considerations  into the  Hazardous Materials Office's
              inspection program (including leak detection  at existing facilities)

              Develop conditions of approval for moderate and low risk uses and initiate
              review and approval of moderate and low risk uses requesting location in a

              Evaluate risks associated with older sewage treatment  plants and appropriate
              monitoring or remediation actions

              Develop "cook-book" procedures for remediation of transportation spills and
              incorporate into tribal emergency response plan.

              Establish  tribal  regulations and  work  with neighboring jurisdictions to
              implement measures recommended to reduce the incidence of illegal spills

              Incorporate WHP concerns into the GRIG Pesticide Code and the inter-tribal
              model code which are currently being developed

              Establish the groundwater  monitoring plan
             Work  with  existing,  non-conforming  uses  in  industrial  parks  and
             transportation centers to achieve compliance with the WHP program

             Develop  education program on  BMPs for  agriculture and  on-site septic
             Work with existing nonconforming uses (other than those addressed in Phase
             ffl) to bring them into compliance with the regulations

             Review existing tribal standards and guidelines for groundwater protection to
             ensure they reflect WHP concerns

             Develop  additional public education programs, such as one to explain the
             safe use, handling  and disposal of common household and  commercial
             products  which pollute groundwater
PHX\SWE34780\11 \EXEG_SUM.wp5

Ongoing efforts  include  updating  and maintaining the threats inventory;  managing the
monitoring program; coordinating with tribal, federal, state and other entities; supporting
state and federal efforts to increase management of materials in transit; and as funds are
available, developing the  contingency plan, and special studies as needed.

Finally,  it is felt  that the  key to a useful program is informed  review and  update.
Therefore it is  proposed that the  WHP program and its provisions be reviewed on a
three-year cycle of review and update.

The  management   strategy  outlined  here   emphasizes  prevention   of  groundwater
contamination, an approach which is far more effective and less costly than dealing with
problems once they occur.  This  strategy  is supplemented by provisions for site-specific
monitoring as needed and the overall monitoring program recommended in Section 12, and
by the strengthening of current response and remediation efforts.

By prohibiting high-risk activities,  and placing Activity Protection Assurance Requirements
on moderate and low risk Regulated Substances, the chances for the water supply to be
contaminated  are  sharply reduced.   By  imposing appropriate controls  on contaminant
sources developers and others are not  unduly restricted in their choice of locations, yet
water supplies are substantially protected,

The program can be implemented with current tribal management authorities and structures
and should require  a relatively modest investment of tribal resources except for additional
staff.   The approach  should strengthen GWC's ability to successfully compete for federal
PHX\SWE347SO\n\EXEC_SUM,wi>S                1-11


 The detailed technical foundation  of the WHP Strategy  comprises  specification  of
 thresholds and criteria for WEDP, hydrogeologic and water use data compilation, literature
 review, water budgets, groundwater flow modeling, and particle tracking.  The details are
 provided in Part H for those readers wishing to examine the technical basis for the WHPA
PHX\S\VE34780\! I\i940.wp5

                                      Section 2
             Wellhead Protection Criteria and Thresholds


This section describes the important first step of deciding what,  specifically, we want to
protect rather than all groundwater resources. The decisions presented here form the basis
for all of the technical work described in later sections.

Around any well, such as the public and non-public supply wells in the Community, there
is an area, where, if contamination occurs, it will be drawn into the well after some period
of time.  Such  an area is called a "wellhead protection area."   If we protect against
contamination in that area, then the well is protected from contamination.

A concept for the delineation of these areas is needed which takes into account the local
groundwater conditions and amount of water pumped from the wells.  The first step in
wellhead protection area delineation is selecting the criteria for wellhead protection.  The
next step is selecting increments of the criteria.

EPA has identified five criteria, shown in the following table, that may be used in wellhead
protection area mapping. The table shows how these criteria were evaluated for GRIG.
Table 2-1
Analysis of Wellhead Protection Criteria

Travel Time
Physical Boundaries
Assimilative Capacity
From well
Around well
To well
Soil & Aquifer
Excessive area to protect
Excessive area to protect
Essentially the entire GRIC
The  criteria for wellhead protection  at GRIC will  be the  time-of-travel for potential
contaminants moving through the groundwater system to the  selected wells.  Use of this
PHX\SWE34780\1 I\1806.wp5

 criteria focuses wellhead protection activities on only those activities which can affect the
 quality of pumped water during the time periods of interest.  The time periods of interest
 are called thresholds, and they are related to  the Community's ability to do something
 about contamination should it occur.

 Because we have  selected time-of-travel as the criterion  at GBIC,  the thresholds for
 wellhead protection  are time-related  and,  because of  the  physical  characteristics  of
 groundwater flow to wells, result in increasing wellhead  protection area sizes with time.
 Three thresholds will be used for this project.  The first threshold is related to immediate
 or emergency  events.   In the first threshold, the conservative  assumption is that the
 contaminants would enter the well immediately. A threshold of 200 feet is selected for the
 first threshold.

 In the second  threshold, consideration is given to the time  required  to  detect and do
 something about a release  of contaminants.   For the. conditions at GRIC, a  period  of
 5 years is selected as the typical period from detection of contamination to replacement of
 the affected well.

 In the third and final threshold, consideration is given to the  time that a typical well would
 be in  service.   In  other words,  it is desired  that a well remain free of contamination
 throughout its service life.  For the conditions at GMC,  a period of 40 years is selected as
 the typical period of useful life for a production well.
PHX\SWE34780\mi806.wp5                     2-2