United States
Environmental Protection
Agency
Office of
Ground-Water Protection
Washington D.C. 20460
lEPA Developing A State Wellhead
Protection Program
A User's Guide
to Assist State Agencies
Under the Safe Drinking Water Act
-------
Developing A State Wellhead
Protection Program
A User's Guide
to Assist State Agencies
Under the Safe Drinking Water Act
-------
Acknowledgements
Acknowledgements
This document was prepared for the Envi-
ronmental Protection Agency, Office of
Ground-Water Protection (OGWP) by ICF In-
corporated. Mr. Steven Roy of OGWP served
as Task Manager for this project, with assis-
tance from Dr. Norbert Dee and Ms. Wendy
Blake-ColemanofOGWP, and Mr. Christopher
Prins ofOPPE. ICF Incorporated staff who were
principally involved in preparing this document
included: Paul Bailey, John Bendall, Veronica
Pye, Andrew Barnsdale, and Tom Mierzwa who
served as Project Manager.
Marian Mlay
Director
Office of Ground -
Water Protection
-------
Table of Contents
I. Introduction
Purpose of this Technical Assistance Document 1
How this Document is Organized 1
Overview of the Wellhead Protection Program 1
il. Roles and Duties of State and Local Agencies
WHP Program Submission Elements 3
Identify Roles 4
Assign Duties 6
Coordinate Activities 8
III. Delineation of Wellhead Protection Areas
WHP Program Submission Elements 11
Choose Institutional Processes 12
Choose Delineation Criteria 14
Identify Phasing Schedule 16
IV. Source Identification
WHP Program Submission Elements 19
List Source Categories 20
Develop Source Inventory 22
Modify Inventory 24
V. Management Approaches
WHP Program Submission Elements 27
Identify Management Programs 28
Identify Uncontrolled Sources 30
Specify Phasing Criteria 32
VI. Contingency Plan
WHP Program Submission Elements 35
Contingency Planning Process 36
VII. New Wells
WHP Program Submission Elements 39
Siting New Wells 40
VIII. Putting It All Together
Concluding Thoughts 42
Road Map to a WHP Program Submittal 43
Appendix: EPA Regional Ground-Water Representatives
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Introduction
I. INTRODUCTION
The 1986 Amendments to the Safe Drinking
Water Act (SDWA) established a new Wellhead
Protection (WHP) Program to protect ground waters
that supply wells and wellfields that contribute
drinking water to public water supply systems.
Under SDWA Section 1428 each State must prepare
a WHP Program and submit it to EPA by June 19,
1989. Although the law requires that every State
WHP Program must contain specific elements, EPA
recognizes that States should be allowed flexibility
to tailor Program details to best suit their individual
needs and circumstances.
Purpose of this Technical Assistance
Document
This Technical Assistance Document (TAD) is
one of several publications prepared by EPA to
assist States in developing their WHP Programs.
This TAD does not specify approaches that must be
adopted or precise language that must be
incorporated into the Program document submitted
to EPA. Rather, it illustrates ranges of options that
States can choose from as well as examples of the
different approaches that can be taken in developing
each element of their WHP Programs. In no way
does the use of this TAD obviate a State's obligation
to meet the requirements cited in the Guidance for
Applicants for State Wellhead Protection Program
Assistance Funds under the Safe Drinking Water Act,
dated June 1987. The Guidance describes all the
statutory requirements that a State's WHP Program
must meet and discusses, in detail, the elements that
must be included. This TAD is intended as a
complement to the Guidance.
Other Technical Assistance Documents, which
will be made available by EPA on request, address
the technical details of approaches for preparing
individual WHP Program elements. See Appendix A
for a list of EPA contacts to obtain information about
those other support documents.
How this Document is Organized
Each individual chapter addresses a major WHP
Program element, and provides:
A list of the major submittal requirements
associated with the elements that chapter
addresses, drawn directly from the June, 1987
EPA Guidance;
Major messages that a State should consider
while developing that particular point of their
WHP Program;
Graphic Illustrations that show a range of
optional approaches a State might consider in
developing the program element; and
Case study examples that illustrate how a
State might address the element in its WHP
Program.
The "road map" figure at the end of this
document guides the reader through the logical
steps of using the TAD to support the WHP planning
process.
Overview of the Wellhead Protection
Program
Program Elements
A comprehensive Wellhead Protection Program
comprises several distinct and essential elements.
At a minimum, each State's WHP Program must:
Specify roles and duties of State agencies,
local government entities, and public water
suppliers, with respect to the development and
implementation of WHP Programs;
Delineate the wellhead protection area
(WHPA) for each wellhead, as defined in
subsection 1428(e), based on reasonably
available hydrogeologic information on
ground-water flow, recharge and discharge,
and other information the State deems
necessary to adequately determine the WHPA;
Identify sources of contaminants within each
WHPA including all potential anthropogenic
sources that may have any adverse effect on
health;
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Introduction
Program Elements (cont'd)
Develop management approaches which
include, as appropriate, technical assistance,
financial assistance, implementation of control
measures, education, training, and
demonstration projects that are used to protect
the water supply within WHPAs from such
contaminants;
Develop contingency plans for each public
water supply system indicating the location
and provision of alternate drinking water
supplies in the event of well or wellfield
contamination;
Site new wells properly to maximize yield and
minimize potential contamination; and
Ensure public participation by incorporating
processes for appropriate involvement in WHP
Program elements.
Program Philosophy
The design of the WHP Program is based on
EPA's recognition of the need to:
Meet the goals stated in the Safe Drinking
Water Act;
Take into account the diversity of
hydrogeologic settings and sources of
contamination;
Maximize State creativity and flexibility in WHP
Program design and implementation;
Recognize State and local primacy in matters
of land use and water allocation; and
Assist States in achieving comprehensive
ground-water protection.
In order to meet the intent of the WHP Program,
States should design their individual WHP Programs
to:
Meet the State's goals, fit within its institutional
constraints, and address the State's unique
problems;
Take advantage of existing institutional
structures, organizations, authorities, etc.;
Formalize working arrangements and identify
the mechanisms that will be used to
coordinate the activities of all participating
agencies;
Integrate new activities and policies with those
already in place; and
Take advantage of the opportunity presented
by the WHP Program to integrate related
programs and use new approaches for
ground-water protection.
Phasing
The WHP Program has three separate and
distinct phases: First, development of the State's
Program (authorized for FYs 1988 and 1989);
Secondly, submittal of the State's Program (by June
19, 1989) and approval/disapproval by EPA (within
nine months); and third, Implementation of the State
WHP Programs that have been approved (authorized
through FY 1991). During the development phase,
each participating State is expected to prepare a
State WHP Program specifically addressing each
component required for WHP Program approval. All
participating States must submit their WHP
Programs to the appropriate EPA Region for EPA
review no later than June 19, 1989. States whose
WHP Programs are approved would then be eligible
to apply for Federal funds to assist them in their
implementation of the WHP Program. To date, no
Federal funds have been appropriated in support of
this program.
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Roles &
Duties
Identify Rolm
Assign DutlM
Coordinate Actlvltl»»
Chapter II: Roles and Duties
of State and Local Agencies
As specified in Section 1428 of the SDWA and the EPA Guidance
for Applicants, a State WHP Program submittal includes:
Identification of all State or local entities or public water suppliers that have a
role in carrying out the WHP Program, and designation of a lead management
agency
Duties of each participating agency, including those of the lead agency
responsible for overall development and implementation of the program
Mechanisms that have been and will be used to coordinate and integrate
participating State agencies, other State and local entities and appropriate
Federal agencies
MAJOR MESSAGES
Use the State's existing ground-water
protection strategy, existing legal authority,
and organizational structures where possible
as a basis for assigning duties and roles
Integrate functions of the WHP Program and
related State programs (e.g., State planning or
solid waste management)
Create new authority and organizational
capacity only if necessary to fill gaps (e.g.
handle cross media issues)
to
Establish formal mechanisms to coordinate
activities of various jurisdictions (e.g.,
Intra-State, State/Federal, Interstate) in
achieving ground-water protection goals
Be aware of potential conflicts in the goals of
various interests (e.g., between government
entities and public and private water suppliers)
The remainder of this Chapter illustrates the range of available options for identifying roles, assigning
duties, and creating coordination mechanisms, along with case study examples of a State's experience in
preparing these WHP Program elements.
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Range Of Options -for identifying agencies and lead management roles
Possible Participants
! ' "* " ' * »
s ' "- -.-. - < 1
State-Level ' '
Agencies: ,
- State EPA
- Dept. of Public
Health
- Dept. of Natural ^
Resources *
- State Geological
Survey ^
- State Water Board ^
- State Planning ]
Office
- Other State Support^;
Agencies
"" " "
Intergovernmental >
Agencies:
- Regional Planning /
Agencies
- Interstate Compacts ,
Local-Level
Agencies: ;
- Municipal Public '
Works Departments
- Zoning Boards ^
A s ^ ', ? - ^"
Water Suppliers:
- Local Public Water ,4
Entities |
- Private Utilities L
, .' ' '
Other Public
Entities:
- Agriculture
Extension Service
- Special Districts
- Soil & Water Con-
servation Districts
- Groundwater
Districts
- Health Districts
- Universities
Private Sector
Entities:
- Professional
Associations
- Technical Advisory ^
Groups
- Citizen Advisory «
Groups
- User Groups
Functional Categories
"V> * ""*
Administration:
i - Budgeting ^
i - Funding *
i - Data Collection
I - Data Management
- Oversight
Technical Support:
' - QA/Testing
- Research/Evaluation
- Hydrogeology/
Delineation
Regulation:
: - Permitting
i - Enforcement
: - Monitoring
Planning: *
[ - Infrastructure
Development
- Establishing Priorities!
- Water Use/Demand
Service:
i -Supply
-Treatment/
Purification
Role Designation
Criteria
Lead Agency Roles
Based on:
- Policy Responsibility ^
- Program
management
experience
- Coordination
experience
- Budgetary Support f
Support Roles
Based on:
<; - Technical
* specialization
- Available staff
"' - Regional/local
presence
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Roles &
Duties
Identify Roles
I Aolgn Putl««
- for identifying agencies and lead management roles
Coordinate Actlvitiw
Sorting Out Overlapping Roles and
Responsibilities
The State's environmental and natural resource
programs are carried out primarily by two State
agencies: the Department of Environmental
Protection (DEP) and the Department of Water
Resources (DWR). While the DEP had most of the
responsibility for enforcing environmental protection
regulations, the DWR was the primary planning
agency for statewide natural resource matters.
A study by the State's Budget Office found that
between the two agencies there were resources to fill
nearly all the functional roles needed for a State WHP
Program. However, they lacked expertise to provide
technical support for testing water quality of aquifers,
and for the development of fate and transport models
in the WHP delineation process. The Brdget Office
recommended that the State's Geologic Survey
serve this technical support role, due to its
experience and available staff of qualified
hydrogeologists.
The Budget Office also recommended that the
DEP serve as the lead agency for the WHP Program,
based on the strength of its experience and positive
track record in managing Federally-delegated
environmental programs. The DWR would continue
to fulfill its planning role, and the State Geologic
Survey would round out WHP functional roles by
providing technical support.
The agency heads of DEP and DWR convened a
working group of regional and local government
officials to identify implementation and support roles
at those levels. The Working Group reviewed past
"track records" and potential roles, and solicited the
advice of local Soil and Water Conservation
Districts, local Agricultural Extension Agents, and
regional Economic Development Councils.
Additionally, the Working Group sponsored several
public hearings to solicit important views on the
experience and appropriateness of various local and
regional organizations to play roles in the WHP
Program. Based on this review and input from
experienced observers of the local and regional
ground-water scene, the Working Group presented
specific recommendations for lead and support
roles in the WHP Program.
Organizing Multiple State Roles
The State's programs which supported
ground-water protection were limited, and
responsibilities were scattered among several
independent agencies. The Governor appointed a
panel of experts to review the legislative mandates
and institutional pattern of State ground-water
protection activities, and recommend new
arrangements for the State's WHP Program.
At that time, the Department of Public Health
(DPH) was the agency primarily responsible for
overall planning of ground-water protection
activities and for assessing water needs and supply
adequacy at the State level. Regional Planning
Agencies had significant roles as well. Since many
were recipients of federal planning assistance over
the past 10 years, they had developed data bases
and data management capabilities, along with an
extensive knowledge of the infrastructure of the water
supply systems in the region. Local water agencies
had access to management tools for ground-water
protection such as: zoning, erosion control
ordinances, site plan reviews, and contaminant and
source identification.
After determining the functional roles that each of
the agencies played in support of ground-water
protection, the panel observed that some functions,
such as program administration and technical
support, were not being adequately fulfilled. As a
remedy, the panel recommended the creation of a
Division of Ground-Water Protection (DGWP) within
the DPH. Acting on the panel's recommendations,
the Secretary of DPH created this new organizational
unit.
DPH was designated the lead agency for the
WHP Program, with responsibility for developing
policy and overall strategy for ground-water
protection. The DPH was supported by the State
Office of Budget and Administration, which assumed
responsibility for budget development and program
management. The Governor's Intergovernmental
Affairs Coordinator served as a broker between State
and local government interests, and focused
attention on the statewide significance of
ground-water protection efforts. Because of their
access to extensive planning data, the data
management divisions of each Regional Planning
Agency were designated to play support roles.
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Roles &
Duties
Identify Rol»»
Range Of Options -for assigning duties to each participating agency
Assign Duties
CoordliuM AeUvttlM
Duties
' * ~-fv.
Administrative:
- Develop and
Implement Policy
- Develop Budget
* - Perform Oversight
\ - Design Control
;' (Management)
:, Program
: ' rf'T5''- " NX?"t -
Technical:
-Delineate WHPA's
- Assess Risks
Regulatory:
- Issue Permits
- Perform Inspections ''
- Levy Fines
i; Planning:
1 - Project Water I
Demand &*
', *
- Identify Consumption^
Patterns ^
- Plan Infrastructure ^
Research:
I - Investigate New !
Sources of Supply
- Determine Fate and
Transport
- Identify Future
Threats
Service:
- Treat Water
Supplies
- Maintain Supply
Levels
Combinations of
Duties:
- e.g., Combine Risk
Assessments and
New Source Invest-
i igation duties In one
effort
Assignments
Lead Agency:
- Initiate Policy
- Manage Program
- Coordinate Work
Groups
- Develop Budget
- Procure Funding
Support Agencies:
- Perform Technical
Evaluations
- Conduct Outreach
Program
- Report on Inform-
ation Gathering
- Collect Data
Other Groups:
(Universities &
Private Organizations)!
- Collect Data
- Support Outreach
Programs
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Roles &
Duties
Identify Roln
Assign Duties
Examples - for assigning duties to each participating agency
Coordinate Activities
Consolidating Assignments by Areas
of Technical Expertise
Most of the State's current ground-water
protection activities are focused in a single agency,
the Department of Natural Resources (DNR). While
the DNR was designated as lead agency for the
WHP Program, many of the other important functions
were assumed by other State organizations. For
instance, the Office of State Planning was
responsible for water supply infrastructure planning,
the Industrial Site Review Board was responsible for
issuing permits to potentially contaminating
sources, and the Environmental Management
Agency (EMA) was responsible for technical
evaluations of water quality data. To better manage
the WHP Program, the DNR consolidated
assignments of support agencies according to their
particular areas of expertise, thus reducing the
number of organizations directly accountable to
DNR.
The lead agency assigned WHPA delineation to
the Division of Public Water Supply in the EMA,
which coordinated hydrogeological investigations
with the State University and the development of
delineation criteria and methodology with the State's
Geologic Survey. Preliminary source identification
assignments were carried out by staff from the
Industrial Site Review Review Board and
coordinated by the EMA. Source category
development was done by DNR in-house and list
development and refinement were carried out by a
technical working group made up of other State
agency staff and local government staff under EMA's
direction. The development of management
approaches was handled by the DNR with
assistance from an advisory team of local
government officials, water suppliers, and
community groups. Contingency planning was
delegated directly to local private/public water
utilities, but the process was managed under the
supervision of the DNR. New well siting was handled
by the State Planning Office, which drew support
from the State Geologic Survey for technical
expertise.
Assigning Duties by Delegating to
Other Agencies
The State's environmental protection programs
are highly developed. Nearly every form of Federal
assistance and regulatory program available has
been taken on and implemented by the State. The
State's ground-water strategy is the responsibility of
the Water Resources Board (WRB), an umbrella
agency with limited staff resources responsible for
developing environmental and water resource
policy. In designating the WRB as lead agency for
the WHP Program, the State anticipated that a
significant number of duties would be delegated to
other agencies that had sufficient staff resources to
carry out assignments.
As a first step in assigning program
responsibilities, the WRB, assisted by an
independent advisory group of management and
organization specialists from the State University,
developed a strategic management plan. This plan
outlined each WHP program element, the
management process, and the probable tasks
required, and then matched agency staff capabilities
with each task. Next, Memoranda of Agreement
were drawn up to specify duties assigned to each
participating agency in the WHP Program.
A Memorandum of Agreement between the WRB
and the State Geological Survey (SGS) specified that
a technical workgroup would be responsible for
reviewing the delineation criteria and methodology.
The workgroup consisted of representatives from
WRB and SGS, a hydrogeologist from the State
University's Water Resource Center, an industry
representative, and an environmental interest group
representative. Source management plans were
assigned to the WRB in conjunction with the local
Soil and Water Conservation Districts (SWCD).
Specific duties in this joint effort were defined in a
cooperative agreement providing for financial
support from the State Budget Office to support the
WRB, the technical workgroup, and the local
SWCDs.
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Roles &
Duties
Identify RolM
AMlgn Duttos
Range Of Options -for coordinating activities of participating agencies
Coordinate Activities
Identify
Interrelationships
Intergovernmental:
- State/Local
- Between States
- State/Federal
- City/County
- Special District/
Local
o ..Mv f-J?t * " " *
° ^ ^-> irSltr
Interdepartmental:
- Natural Resource/
Health
- Regulatory/Non- *
Regulatory
- Boards/Depart-
ments/Commissions ,
-. f * '
Cross-Media:
- Disposal/Water
Supply
- Land Use/Supply
Infrastructure
,- ,\c;- zt 'A
Public/Private:
- Water Supplies
- Users
_ Infrastructure
Investment
,,...,, ,,,~ ...,,,
?X-,^v.X-
User/Provider:
- Utility Companies/
Customers
- Price/Quality
x ^
Govt./Citizen:
- Service/Fee
Develop Mechanisms
to Coordinate Activities
Administrative:
- Cooperative
Agreement
-Memo of Under-
standing
- Compact
- Contract
Mandates:
-Enabling Legislation
-Executive Order
* -^.''~\ w.' if
Directives:
-Budget Directive
-Legislative Comm.
Directive
'* Organizational:
- Task Forces
-Work Groups
Information
Dissemination:
- Reports
- Newsletters/Media
Informal
Communication:
- Meetings
-Periodic Phone Calls
Use of a Combina-
tion of Approaches:
-e.g., Under a
Memorandum of
Understanding, State
agencies define and
allocate respons-
ibilities, and hold
regular Work Group
meetings to ensure
that budget requests
are made to support
the WH PA Program
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Roles &
Duties
Identify Role*
Aulgn DutlM
Examples - for coordinating activities of participating agencies
Coordinate Activities
Coordinating Management of Existing
Agencies
The State had a wide variety of control measures
in place to manage sources already identified. Many
control measures were under the direction of
separate organizational units, however, and
regulatory programs were uncoordinated and
ineffective. The lead State agency, the Department
of Natural Resources (DNR), was charged with
developing mechanisms to coordinate the activities
of agencies participating in source management
strategies for currently regulated sources.
The Office of Ground-Water Quality within the
DNR formed a policy committee composed of the
directors of the Water Pollution Division and Solid
and Hazardous Waste Control Division and
representatives from other agencies participating in
WHP Program activities. As its first activity, this
committee identified key interrelationships among
agencies responsible for inspection, enforcement,
and performance standards regulating sources
within WHPAs. The committee was supported by
technical staff from the relevant divisions within DNR
by virtue of a budget directive from the Governor. In a
Memorandum of Agreement, agency heads agreed
to allocate staff time for developing WHP policies
and procedures and organizing required public
hearings.
To evaluate progress toward developing more
effective inspection and enforcement operations
within the WHPAs, the Director of the Office of
Ground-Water Quality solicited periodic progress
reports from divisions within the DNR, the
Department of Health, the State EPA, and local
government organizations that were responsible for
inspection and enforcement duties.
The DNR policy committee also sponsored a
review of all agencies' legal and administrative
authority for ground-water protection. The review,
performed by a task force from the State University's
law faculty, analyzed opportunities for consolidation
of authority to create a stronger basis for
coordination and a more effective WHP Program.
Coordinating Intergovernmental
Management of Unregulated Sources
As lead State agency, the Department of Health
(DOH) was responsible for developing mechanisms
to coordinate the efforts of all agencies concerned
with currently unregulated sources. DOH realized
the need for additional coordination of management
efforts for these sources and sought advice on ways
to strengthen it across all levels of government.
Interrelationships among those agencies
concerned with non-regulated sources were studied
by a work group consisting of representatives from
the DOH, the State University's Public Administration
and Law school faculties, the Governor's Office, and
the State EPA. The work group identified a series of
management interdependencies between levels of
government which required coordination and
cooperation to effectively control unregulated
sources. For instance, local Soil and Water
Conservation Districts had access to fertilizer and
pesticide application data which was not collected
by State agencies. In addition, Federal Agencies
that may be subject to State WHP Program
requirements were identified.
Strong local involvement in water supply matters
is a tradition in the State, so the DOH decided that
local governments would take primary management
responsibility for identifying sources not currently
regulated. To support this effort, the DOH hired a
planning consultant "circuit rider," who travelled
throughout the State provided technical assistance
and advice to local agencies on zoning and
development decisions affecting non-regulated
sources. Through the State Public Affairs Office,
which served to inform and coordinate the efforts of
community-based groups, DOH also sponsored a
public information campaign which included
dissemination of fact sheets and slide presentations
on non-regulated sources at public hearings.
DOH and the local agencies agreed to
cooperate through an interagency agreement
whereby WHP management strategies would be
incorporated into local comprehensive plans, which
would be amended to reflect this agreement within
three years. As an incentive to local governments,
small grants were provided to support the
preparation of each WHP plan element.
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I Chaos* Institutional Proems**
Delineation
ChooM D*lin*ation Criteria
Chapter III: Delineation
Identify Phacing Sch*dul*
As specified in Section 1428 of the SDWA and the EPA Guidance
for Applicants, a State WHP Program submittal includes:
The institutional processes used to (a) develop the technical aspects of
WHPA delineation, and (b) implement, monitor, and refine such elements
The choices and rationale for WHPA delineation criteria and criteria
thresholds, including the overall goals that drive the State's selection
The choices and rationale for WHPA delineation methods
The phasing of delineation by major well types, hydrogeologic settings, or
other factors, along with the rationale for such phasing
MAJOR MESSAGES
Delineate WHPAs to protect wells from three
general categories of threats:
1) direct introduction of contaminants in
areas immediately contiguous to wells
microbial contaminants
2)
3)
chemical contaminants
Adopt overall delineation goals consistent with
source management plans
Use multiple zones where appropriate to
match management controls with risk to
well-water quality
Ensure that delineation criteria and criteria
thresholds are given primary importance, then
focus on delineation methodologies
Ensure qualified technical staff are made
available; utilize peer review and technical
workgroups
Ensure that the delineation goals and
methodology are compatible with the WHPA
criteria a'nd thresholds
Compare alternative delineation criteria,
thresholds, and methodologies through case
study analysis to ensure cost-effectiveness
Phase delineation of WHPAs according to
such factors as well yield, hydrogeologic
setting, vulnerability, or contaminant risk
Streamline delineation by initially using
simplified procedures to ensure early
implementation, then subsequently delineate
WHPA boundaries more precisely as soon as
possible to increase protection
Delineate larger WHPAs initially, especially if
simpler methods are used; later, more
sophisticated methods can be used to refine
boundaries to ensure better protection
Include a schedule for phasing delineation to
use technical and financial resources most
efficiently
The remainder of this chapter illustrates the range of available options for institutional processes,
delineation criteria, and phasing, along with case study examples of a State's experience in preparing
these WHP Program elements.
11
-------
Choose Institutional Processes
Delineation
ChooM Delineation Criteria
! Identify Phating Schedule
Of Options -for choosing institutional processes in delineation
Technical Input
From Operational
Elements:
I - Technical Staff in
State Environmental
Agencies
|j - State Geological
Survey
; - State energy and
land use agencies
- Expert Panels
From Research '
Elements: }
- University Water
Resource Centers ''
- State Universities
- Federal Laboratories^
- State Geological "
Surveys ?
-U.S.G.S.
Use a Combination
of Approaches:
-e.g., Expert Panels
review of other
States' approaches
Implementation Tools
Administrative |-
Directive: \,
- Policy Statement
- Executive Order ^
>\ ' ;; '*,
. Guidance: ;,
: - Planning Documents 1^
I - Delineation Guidance^
and Criteria *"
' - Ground-water
Protection Guidance !
Rules:
- State Regulations
- Local Ordinances
and Codes
Use a Combination
of Approaches:
-e.g., an Executive
Order to Encourage
Policy Change in
Local Governments
Methods of Monitoring
& Refining
Coordination
Mechanisms:
- Periodic review
meetings
- Technical Work
Groups
- Periodic Status
Reports
Use a Combination
of Approaches:
- e.g., Periodic
Status Reports of
a Work Group
12
-------
Examp les - for choosing institutional processes in delineation
Identify Ptiwing Schedule
Involving the State University and the
U. S. Geologic Survey
When the State began planning its WHP
Program, the only hydrogeological data available to
the lead agency, the Department of Natural
Resources (DNR), consisted of information on the
locations of the State's public water wells. In
contrast, the State University's Department of
Geology had a significant amount of technical
information on the State's hydrogeologic conditions
which was continuously revised and updated.
Similarly, the State Planning Office had a wealth of
water quality data from previous section 208 studies.
The DNR initially involved several research-oriented
institutions in the delineation process. For example,
the Department of Geology assisted in developing
delineation criteria, thresholds, and methodology.
Then, using data from University-sponsored
hydrogeological studies, the DNR tested the criteria
and thresholds in a variety of hydrogeological area
case studies.
Early in the process the DNR also sought help
from the Water Resource Board, the Waste
Treatment Research Council, the Division of
Environmental Regulation, and local Soil and Water
Conservation Districts. For example, the staff of the
State's Water Resource Board reviewed the
methodology proposed by the Geology Department,
and the District Office of the USGS provided
technical assistance and peer review. To refine the
methodology and resulting WHPA boundaries, the
lead agency asked the State Planning Office and
representatives of local governments to participate
in the review process. This enhanced the local
communities' receptiveness toward the boundaries
delineated for the WHPAs and provided a basis for
local cooperation for the Program's implementation.
The State subsequently entered into a
cooperative agreement with the USGS to perform the
actual delineation of WHPAs over a three-year
period. The lead agency and the USGS agreed to
meet quarterly to monitor and refine the delineation
process.
Involving a Technical Advisory
Committee, Local Governments, and
the Public
Prior to this State's participation in the WHP
Program, the State's lead agency, the Department of
Environmental Protection (DEP), successfully
developed and implemented a ground-water
classification scheme and mapped the State's major
aquifers. The scheme was so well received that
many local governments began to apply it to
develop aquifer protection zones.
The DEP attributed much of the success of its
ground-water classification scheme to the
institutional processes used. Consequently, in
developing delineation procedures for the WHP
Program, the DEP chose to replicate, to the extent
possible, the institutional processes that were
successful in developing its ground-water
classification scheme.
First, the lead agency reconvened the same
Technical Advisory Committee (TAG) that had
assisted in developing the ground-water
classification scheme. The TAG included
hydrogeologic and water use experts from Federal,
State, and regional government agencies, and from
the private sector. The TAG first established goals for
the delineation process, then selected the State's
WHPA delineation criteria and thresholds, and,
finally, developed the methodology used to translate
the criteria into on-the-map WHPA delineation
boundaries.
The DEP adopted regulations that gave
local/regional water authorities responsibility for
protecting public drinking water wells and
delineating WHPAs. The State Public Water
Authority (PWA) was assigned the responsibility for
reviewing and approving all WHPA delineations.
To assist the local Water Authorities, the lead
agency developed and incorporated into a State
guidance manual a systematic approach for
delineating WHPAs. In addition, the lead agency
met with the Water Authorities at regular intervals to
monitor the delineation process being conducted by
each Authority and provided hands-on technical
assistance supplementing that provided by
community groups, counties, and municipalities
within the Authority's jurisdiction.
13
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choo»« institutional proees««T| Range of Options - for choosing delineation criteria and thresholds
Delineation I Choose Delineation Criteria
Mmtlty PhMing Schedule
Delineation Goals
Remedial Action
Zone
Attenuation Zone
Wellfield Manage-
ment
Criteria Thresholds
Distance:
: - 1000S Of ft. tO
2 miles +
Drawdown:
;- 0.1 to 1.0 ft
Time of Travel:
i -<10 to 50 yrs.
Physical
Boundaries:
; - By geology and
! hydrology limits
Assimilative
Capacity:
- By contaminant
standards
Criteria Considerations
Policy
. Considerations: '':
.- Protectiveness
;- Ease of
Understanding
j:- Economy of
Development
i- Economy of
Application /
{- Defensibility «.
5- Application for ]
Phasing
- Relevance to goal
v$» vy. x
Technical
Considerations:
- Ease of criteria
application
- Ease of criteria
^ quantification
\ - Ease of field
verification
' - Consistency with
G-W classes
- Ability to incorporate
physical processes
- Extent of current
use
- Simplicity of data
requirements
- Availability of data "
- Suitability for various
hydrogeologic
settings
- Accuracy
Methods
- Arbitrary Fixed
Radii
- Calculated Fixed
Radii
- Simplified variable
shapes
- Analytic methods
- Hydrpgeological
mapping
- Numerical flow and
transport Models
Use a Combination
of Approaches:
e.g., Combine
hydrogeologic
mapping with
analytical methods
in key sections
14
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Delineation I Choose Delineation Criteria
Examples - for choosing delineation criteria and thresholds
Identify Phasing Schedule
Establishing Wellfield Management for Establishing a Remedial Action Zone
Entire Recharge Areas Around Wellheads
As the lead agency, the Department of
Environmental Protection (DEP) chose as its overall
goal to establish wellfield management areas in
major portions of the current or future
recharge/contribution areas for wells throughout the
State.
Since the State's wellfields draw mostly upon
ground-water obtained from small, valley-fill
aquifers with distinct boundaries, establishing
wellfield management areas resulted in strong,
effective measures to protect these aquifers from
chemical contaminants. Also, given the small size of
the State's aquifers and the State's limited financial
and managerial resources, a wellfield management
approach was relatively economical to implement.
Because of the small size of the State's aquifers
and the large variation in hydrogeologic settings, the
DEP selected physical boundaries as the primary
criterion for delineating WHPAs. This approach was
inexpensive and easy to apply and verify in the field,
easy for the general public to understand, easy to
defend if challenged, yet sufficiently sophisticated to
avoid extensive revisionsresulting from phased
delineation. Since the shallow ground-water flow
system replicated the topography throughout the
State, topographical boundaries were used as the
initial criteria threshold to delineate WHPAs.
Having chosen wellfield management as a
criteria and flow boundary as a threshold, the lead
agency chose topographical mapping as the
technical method to "map" the State's WHPAs.
Because this method could be implemented quickly,
it enabled the State to delineate the majority of its
WHPAs during the development phase of the WHP
Program. Likewise, quick implementation of this
method for areas immediately contiguous to
wellheads allowed them to be readily incorporated
early in delineation.
Finally, as delineation of the State's WHPAs
progressed, the DEP also made use of analytical
flow models to improve and refine the delineation
procedures for its most sensitive wellhead areas.
Through the application of an analytical flow
equation, the degree of contribution of selected
wellfield areas was identified.
As the lead agency for developing and
implementing this State's WHP Program, the
Department of Public Health (DPH) determined that
remedial action zones around each well would be a
primary delineation goal. This would minimize the
likelihood that drinking water supplied by wells
would be exposed to unexpected contaminant
releases.
To meet this goal, DPH chose to enlarge the
buffer zone immediately contiguous to each
wellhead to protect against microbial and direct
contamination. By banning new "high-risk"source
activities in the buffer zone, corrective action
measures could be completed before the
contamination reached wells.
The DPH staff chose time of travel (TOT) as the
criterion to delineate the WHPA boundaries.
Because TOT was easily quantified and more easily
understood, it was well suited to meet delineation
goals. Their rationale indicated that TOT was
especially appropriate since the State already had
enough data on TOT to delineate the WHPAs easily
and economically. The DPH also reasoned that
different degrees of wellhead protection could be
provided by applying different TOT threshold limits to
meet unique regional conditions.
As the state-wide criteria threshold, the DPH
chose to apply a 10-year TOT to delineate WHPAs
for the majority of the State's wells. However, the
DPH adopted other TOT thresholds appropriate for
specific local conditions. For example, the DPH
concluded that using a less protective threshold was
justifiable in selected counties with aggressive
inspection programs that included careful
monitoring of "high risk" activities. On these
grounds, certain counties were able to justify using a
5-year TOT rather than the more stringent 10-year
TOT. Nevertheless, those counties were required by
rule to apply for exemptions from the standard
state-wide 10-year minimum TOT threshold.
In contrast, certain areas of the State required
more stringent measures to meet WHP goals. As a
result of hydrogeologic conditions in some counties,
a longer time was needed to ensure effective
remediation of releases. In those countries, a 15 to
25-year minimum TOT criterion threshold was
required and certain activities were banned.
15
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Delineation
I choose iratitutionai processes i Range of Options - for phasing delineation
ChooM Delineation Criteria
Identify Phasing Schedule
J
Delineation Timing
One-Step:
I - Formally establish
criteria, thresholds
and methods
By Phase:
- Identify WHPAs
generically
- Demonstrate test *
case applications
- Apply risk assess-
ment to establish
priorities
- Determine nature of;
phasing needed
- Establish criteria for
each major or
minor phase
Phasing Considerations
Communal Use Risk:
- Population served
- Pumping rates
Replaceability: ',
- Importance of ;
particular wells
- Number of
consumers served
Extent of Contam-
ination of Ground
Water
Presence and
Extent of Contam-
ination Threats:
- Within WHPAs
- In Surrounding '
Areas
Degree of Aquifer
Confinement
Assurance of
Aquifer Confine- ;
ment
Stringency of
Management
Programs
Stringency of
Regulations
Availability of Staff
and Resources
Refinement
Reappraise or
Improve Boundaries?
of Specific WHPAs
as Needed:
- Apply more sophis-
ticated methods ;
- Reinterpret existing v
methods f
- Reinterpret existing '
data j.
- Collect new data ''
I Adjust Hydrogeo-
logically Deter-
mined Boundaries
to Match Other
Features:
- Governmental
boundaries
- Area zoning bound-
aries
- Roads
- Major topographic
features
16
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Delineation
I chooM in.mutionai PTOOSMS ] Examples - for phasing delineation
\ ChooM Delineation Criteria I
Identify Phasing Schedule
Phasing Delineation Primarily by
Vulnerability
The State selected its Department of
Environmental Conservation (DEC) as the lead
agency to develop and manage its WHP Program.
Given the large number of public wells and large land
area in the state, the DEC believed it was practical to
schedule the delineation of the State's WHPAs in
several phases, based primarily on the vulnerability
of aquifers supplying the wells. The schedule would
enable all of the State's WHPAs to be completely
delineated within 10 years.
To facilitate the delineation of WHPAs, the lead
agency initially used large criteria thresholds and
simplified methods. Once all of the State's WHPAs
were delineated generically, individual boundaries
could be delineated more precisely. WHPAs could
then be reduced in size during the process of
refinement. This approach was based on the
assumption that expanding the boundaries of
WHPAs because they are under-protective would be
more disruptive in the long run than reducing WHPA
size appropriately for the level of protection needed.
The phasing philosophy of the lead agency
made identification of wells located in shallow
aquifers the first priority. Although wells drawing
from shallow aquifers account for only 20 percent of
the State's wells and tend to serve smaller
populations, they comprise the State's most
vulnerable underground drinking water sources. In
addition, they are typically used by smaller rural
communities, which generally lack land use controls
for ground-water protection. The schedule allotted
24 months to complete this first phase of delineation.
The lead agency then targeted wells drawing
upon semi-confined aquifers less than 100 feet deep
for the second phase of delineation. These are the
predominant type of aquifers found in oil producing
areas of the State. Evidence from State records
indicated that there were numerous improperly
plugged exploration wells in these aquifers that
could serve as conduits for the introduction of
contaminants into well waters. A maximum of 48
months was scheduled to complete the second
phase of wellhead delineation.
The last phase required delineating WHPAs for
wells drawing upon confined aquifers deeper than
100 feet. The lead agency's rationale for allowing
this delineation phase to proceed more slowly
stemmed largely from the absence of information
indicating that these wells were exposed to any
immediate threat of contamination. As a
contingency, the lead agency initiated several
special studies to confirm this, and assured that
delineation of WHPAs for these wells be completed
within several years pending new findings from the
study.
Phasing Delineation by Relative Risk to
Population
The State has two basic regions: an upland
region, inward from its coast, and a coastal plain
which extends to its shoreline. The upland region is
sparsely populated, relies on one or more confined
aquifers, and is experiencing development pressure
from leisure homes and recreational communities.
The coastal plain is heavily populated and
industrialized, with numerous aquifers and porous
soils.
Based on factors of communal risk, the lead
agency, the Department of Water Resources (DWR)
decided to delineate WHPAs in the State's coastal
plain first. These wells were highly susceptible to
contamination and served most of the State's
population.
DWR had extensive hydrogeologic information
available on aquifer settings, pumping rates, and
data accumulated during the planning, installation,
and development of the wells serving the large urban
areas on the coastal plain. In addition, regional
characterization of the aquifers serving wells in the
upland area was less thorough than in the coastal
plain. Also, the State's limited technical and
financial resources dictated that delineating WHPAs
in the coastal plain would enable the State to
address the most contaminant-prone WHPAs first.
Following this first round of delineations,
wellfields in the upland area of the State were
delineated. As delineation of the upland region was
taking place, the lead agency initiated a data
collection process in cooperation with a coalition of
rural counties. This data would provide periodic
reports of water needs for the growing demands of
recreation communities in the region.
17
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Source
Identification
Li.tsourc.cat.qori,. | Chapter IV: Source Identification
Develop Source Inventory
Modify Inventory
As specified in Section 1428 of the SDWA and the EPA Guidance
for Applicants, a State WHP Program submittal includes:
List of categories of sources potentially contaminating WHPAs
Procedure for inventorying sources in each WHPA, and a schedule for
completing the inventory process
Procedure for refining, expanding, updating, and verifying inventory of
specific sources of contamination in each WHPA
MAJOR MESSAGES
Use either an existing list or develop a new
list:
o first define the source categories
o then assess whether they belong on the
list
o finally, prepare the list of relevant source
categories
Group source categories (e.g., by location or
degree of risk) to facilitate and prioritize
inventory efforts
Involve knowledgeable State and local
technical staffs in assessing source categories
for inclusion on the list and developing
inventory procedures
Inventory the most important source categories
and/or WHPAs first
The initial inventory can follow or precede
WHPA delineation
Use existing permit and license information to
conduct inventories
Update source category lists and source
inventories as better data or more resources
become available
Utilize local agencies and service group
support whenever appropriate for inventorying
and updating
Inventory information can assist source
management decisions
The remainder of this chapter illustrates the range of available options for listing source categories,
inventorying sources of contamination, and adjusting the inventory, along with case study examples of a
State's experience in preparing these WHP Program elements.
19
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Source
Identification
List Source Categories
Develop Sourc* Inventory
Modify Inventory
Range Of Options -for organizing contaminant source categories
Defining Categories
* > "' , ' -i- '"
\ >*.'#? - . *
Use Existing Lists: ~
-State list(s)
- Other States' lists
- OTA list of sources
- Federal regulatory
categories (e.g.,
Superfund, CWA,
RCRA)
: - Local ordinances,
codes
f
Derive a Source
Category List:
- from existing
contaminant
surveys
s - from monitoring
Information
from review of
manufacturers by
SIC category
from permitting
files
from advice received;
from State technical
experts
from a Delphi
process with
technical experts
Use a Combination
of Approaches:
-e.g., combine
several lists,
or use a list sup-
lemented with an
existing survey
Assessing Categories
' Screening:
- by chemicals stored
or discharged
- by documented
contamination
incidents
"- by major vs. minor
source categories
- by distance to the
wellhead
s - by SIC code
; - by regulatory status
- by risk assessment
,/ '", , , , \'
Modeling:
- of fate and transport ',
by generic hydro-
> geologic setting ',
- of risk by vulnerability'
Use a Combination
of Approaches:
-e.g., combine a
simple screen with a
risk model
Preparing a List
Without further
source category
grouping
r.. _. -^ -. -. ~
Group Source
Categories:
- by risk
- by regulatory status
- by well service area
- by hydrogeologic
., classifications
* - by land use
; designations
- by political
jurisdictions
Use a Combination
of Approaches:
- e.g., combine risk
category within a
grouping by well
service area
20
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Examples - for organizing contaminant source categories
Working From an Existing Source List
and Grouping Categories by Land Use
A State without its own comprehensive inventory
of potential point and non-point sources of
ground-water contamination decided to use an
existing list of source categories as a starting point
for developing its own list of source categories.
Those available included one from a 1984 report by
the Office of Technology Assessment (OTA), titled
Protecting Our Nation's Ground Water from
Contamination, category lists developed by other
States, and lists of source categories already
subject to State or Federal management (e. g.,
Resource Conservation and Recovery Act, Clean
Water Act, and "Superfund"). Because it provided a
well-developed framework that could be easily
modified, the OTA list was chosen.
The lead agency, the Department of Natural
Resources (DNR), reviewed the OTA list, decided
which modifications would best reflect conditions
within the State, and then circulated the modified
OTA list among other State, regional, and local
agencies to ensure that the list contained all
appropriate categories. Source categories not
found within the State, such as injection wells and
underground mining, were deleted from the list, and
other categories, such as grain storage and
pesticide/herbicide distribution facilities, were
added to reflect the major agricultural activities in the
State.
The DNR then organized the list by county, which
is the primary land use management authority in the
State. County technical staffs subsequently
reviewed the list and identified source categories
(such as irrigation return flow, highway de-icing
activities, and point sources such as landfills and
fuel oil storage facilities) associated with various
land uses in their counties. This approach to source
categorization was compatible with standard land
use designations used in county development
planning, and provided a practical framework for
relating wellhead protection to State or local land
use management decisions.
Compiling a New List with State-Local
Cooperation
The State had a well-developed ground-water
management program before undertaking its WHP
Program. Responsibility for ground-water
management was widely distributed among county
and municipal governments, the Regional
Watershed Planning Board, and Special Water
Districts in agricultural regions of the State.
As lead agency, the Office of State Planning
(OSP) sought to develop as detailed a source
category list as possible. OSP planned to use the list
not only for WHP inventories, but also to develop
source management strategies. OSP provided
guidance on the types of sources to be included on
the list, and its staff worked with the State
Department of Health, the Department of Agriculture,
and the Regional Watershed Planning Board to
assemble a preliminary list of source categories.
The list was based on data available from various
State and local water management programs
including aquifer management programs, discharge
and waste permits, remedial action programs, and
ground-water planning studies.
OSP then distributed its preliminary list to all
county and municipal governments and water
districts to allow them to recommend additions or
deletions, as necessary. A technical committee
coordinated by OSP and consisting of county and
municipal staff and technical representatives from
each State agency made sure that all known source
categories that could pose significant contamination
risks were included on the final state-wide list.
21
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Source
Identification
Li«tsourc«crt«gorie« | Range of Options -for procedures to inventory contaminant sources
Develop Source Inventory
Modify Inventory
Inventory Procedures
Use Existing Public
Records:
i - existing surveys
i - completed studies
- maps
- aerial photos
- permits
- licenses
- registrations
- notifications
- tax records
- directories
- regulatory
compliance records
Conduct Surveys:
- mail
- telephone
- windshield
- door-to-door
- sanitary survey
- delegate survey
responsibility to
local governments
or special districts
Enact Notification
Requirements
Use a Combination
of Approaches:
- e.g., combine use
of existing records
with windshield
survey
Inventory Information
General
Information:
-Source owner/
operator, name,
address
-source type,
I.D. No.
-potential
contaminants
-location and size of
source (latitude,
longitude)
-distance to public
water supply well
Additional Data:
- existing manage-
ment controls
- known public health
or environmental
risks
- characteristics of
saturated and
unsaturated zones
Inventory Schedule
Timing:
- start independent ofif
a WHPA delineation -
using estimate of
WHPA criteria ;-;
- Conduct jointly with
WHPA delineation,
adjusting inventory
as delineation
. boundaries are
fixed
' - start after WHPAs >.,
are delineated
v 'f
Approach:
; - perform initial t
screening prior to
conducting detailed ''
inventory
Assign priorities £8
based on potential ,,
contaminants, or
populations served,
or hydrogeologic
settings
Use a Combination
of Approaches:
- e.g., start with a
simple screen, then
add more detail
after delineation is <
completed
22
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Source
Identification
Li«tsourc»c«i6flori«» | Examples -for procedures to inventory contaminant sources
Develop Source Inventory
Modify ktvMitoiy
Using Existing State Information
This State's lead agency for the WHP program,
the Department of Environmental Protection (DEP),
determined that extensive inventory information
already existed within environmental programs for
waste-water discharge, solid waste management,
and well drilling. The information was distributed
throughout several agencies, however, and the data
stored in noncompatible formats. Because of
existing commitments to complete WHPA
delineation, the DEP could not assign its already
over-worked staff to the Source Identification
component of the WHP Program.
Instead, the DEP decided to contract with the
State University to collect and organize the data
available from State and local agencies and fill in
gaps that existed for selected source categories not
subject to regulation (e.g., bulk chemical storage).
As part of this task, the University mailed
questionnaires to various regional agencies and
local governments to identify other sources on the
State category list. In addition, State business
directories and similar listings were
computer-sorted by Standard Industrial
Classification (SIC) code and zip code to locate
other sources of concern. Finally, in order to provide
an additional measure of coverage, the DEP
coordinated a University-organized effort of several
statewide volunteer groups, including the League of
Women Voters and the American Association of
Retired Persons, to conduct door-to-door surveys of
WHPAs in rural areas to determine whether any
sources may have been omitted.
As each WHPA was inventoried, information was
organized into centralized files maintained by the
DEP. This information was made readily available to
local governments, Soil and Water Conservation
Districts, and other State and local agencies through
on-line computer access to the DEP's source
inventory files.
Using Local Resources
In this State, most water management
responsibilities traditionally were delegated to
regional and local government units such as
Regional Planning Agencies, Soil and Water
Conservation Districts in rural areas, and to
publicly-owned water suppliers, public health
agencies, and municipalities in urban areas. Since
these governmental units already knew a great deal
about contaminant sources within their jurisdictions,
the Department of Public Health (DPH), as lead State
agency, assumed the role of coordinating source
inventory efforts by these local agencies.
The DPH developed an inventory approach
based on populations served by each wellhead and
created a standard checklist of information needed.
Each local and regional agency was provided with
guidance from the DPH and given the responsibility
of reviewing existing data sources (e.g., zoning
maps, permits, and licenses). Staff conducted
windshield surveys to gather the balance of the
required data on all WHPAs. The DPH coordinated
activities for any WHPA located in more than one
jurisdiction, and worked directly with local and
regional staffs to ensure that inventory procedures
were cor.ducted correctly and on schedule.
Since this State had not completed its
delineation process, it asked the agencies to identify
well locations and conduct inventories for listed
source categories within a fixed radius around each
wellhead, based on state-specified criteria. Once a
WHPA was delineated, sources within it were
re-inventoried as necessary.
23
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Range Of Options -for modifying and adjusting the source inventory
Expanding Inventory
Refining Inventory Data
Additions to Data:
-Add new information
on existing sources
-Add new sources in
existing categories
-Add newly regulated
source categories
-Include addditional
non-point sources
Convert Data to
More Usable Forms:!
- Standardize data
collection methods
*- Organize data by
user priorities
- Identify specific
contaminants of
concern
"- Convert distances to|
TOT measures
Use a Combination
of Approaches:
- e.g., combine
additional infor-
mation on existing
sources with
inclusion of new
sources
Use a Combination ''
..of Approaches: ::;::
I-e.g., standardize ||
data collection ;|
methods and better ,
specify contaminants;;;!:
Verifying Inventory
Updating Inventory
Data Quality
,: Assurance:
Office-based ven- * %
fication by cross-
checking permit
applications and
renewals or mailing
out questionnaires
Field verification by
performing on-site ^
surveys f
< vftf . f jff
^Improving Existing
Review public
records periodically
Review environ-
mental data bases
for data updates
Perform periodic
surveys
Review periodic
surveys & completed!
studies
Review permit mod-
ifications, renewals,
and denials
Use a Combination \
of Approaches: '
- e.g., combine
permit cross-checks
with an on-site
verification
::. Use a Combination '
.of Approaches:
| e.g., combine \
periodic review of |
records with periodic?1
surveys
-------
Source
Identification
List Source Categories
b
| Develop Some* Inventoiy ]
Modify Inventory
Examples - for modifying and adjusting the source inventory
Using State Permit Systems
This State has a rapidly expanding industrial
base, which includes a wide variety of companies
that make advanced industrial products. Industries
whose activities have a potentially significant impact
on well-water supplies are required to obtain
state-administered permits (e.g., NPDES, RCRA,
etc.) issued by the Department of Water Resources
(DWR). Since the permitting system provides
access to information on these sources, the DWR
selected it as the vehicle for updating and verifying
the inventory.
Existing permits were coded to indicate a
source's location in a WHPA. As permits were
reviewed for renewal, the State verified source status
and characteristics as listed in the WHPA inventory.
Where the State did not issue a new permit, or where
permit conditions changed, the source's status on
the inventory was altered accordingly.
Applicants for new source permits in WHPAs
were required to provide detailed information on
location, proximity to existing wells, and operating
specifications. Permits for these new sources were
flagged for entry into the WHPA inventory. The DWR
staff periodically verified and updated the inventory
by means of computerized access to the permit data
files.
Using Service Group Support At the
Municipal Level
Because local governments and special
districts in developed areas have played important
roles in primary water supply, WHPAs in this State
reflected those jurisdictional boundaries. As lead
agency, the State's Environmental Management
Agency (EMA) relied on local governments for
source data to update its inventory. However, in
remote rural areas, the State had no effective local
government support to update and verify its WHPA
inventory data.
Responsibility for updating and verifying source
inventories in urbanized areas was delegated to
municipalities and special water supply districts.
The EMA developed an approach and timetable for
this procedure. Under this approach, local
governments mailed surveys biennially to
owners/operators of sources included in their WHPA
inventories as part of the real estate tax assessment
notification process. Whenever respondents
reported sources as no longer in operation, they
were dropped from the inventory after a windshield
survey by local officials verified this fact. New
sources were added to the inventory as local
officials reviewed zoning changes, building permits,
and other municipal licenses for potential sources of
contamination.
In rural areas of the State, the State University
Cooperative Extension Service coordinated efforts
to update the inventory. Under EMA supervision,
they recruited knowledgeable local citizens (e.g.,
volunteers from local conservation groups familiar
with the area) and EMA student interns familiar with
ground-water problems to serve as aides in verifying
and updating the inventories. To assure quality
control, Extension Service staff who had taught
courses in ground-water and water quality
management supervised and reviewed the
verification effort.
25
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Management
Approaches
M.ntny Management Program. | chapter Mi Management Approaches
Identity Uncontrolled Sources [
Specify Phasing Criteria
J.
As specified in Section 1428 of the SDWA and the EPA Guidance
for Applicants, a State WHP Program submittal includes:
Identification and Evaluation of all existing Federal, State, or local source
management programs
Identification of Uncontrolled Sources and the rationale for seleptinq
management strategies for these sources
Criteria used by the State if it decides to phase management controls within
WHPAs
MAJOR MESSAGES
Consider locations, institutional settings, and
type of source in the selection of management
approaches
Use a combination of management methods
for adequate source control
Build upon existing management methods and
programs at all levels of government
Select management methods that provide
protection to wellheads
Make use of both prevention and clean-up
approaches, and both point-of-withdrawal and
point-of-use management approaches
Consider both regulatory and nonregulatory
mechanisms to achieve necessary protection
Ensure that currently uncontrolled sources do
not pose health threats within WHPAs
Phase management controls based on factors
such as: hydrogeology, source, type of
wellhead, and population patterns
Consider risk-based criteria in developing
phased management approaches
The remainder of this Chapter illustrates the range of available options for identifying and evaluating
management programs, for identifying uncontrolled sources, and phasing management controls, along
with case study examples of a State's experience in preparing these WHP Program elements.
27
-------
Management
Approaches
Identify Management Programs
Range Of Options -for identifying and evaluating management programs
Identify Source
Management Programs
f ? ' '' f ~~ ?' *\
Regulatory:
- Permit Programs -
- Enforcement
- Zoning ordinances *
- Siting Restrictions "
Non-Regulatory:
- Planning assistance^
- Land acquisition
- Education
- Information
exchange t
- Tax incentives
- User fees <
- Environmental
audits
By Government
Level:
- Federal
- State
- Regional
_ Local
- Special district
Evaluation
Existing
Management
Programs:
- By type of source
controlled
- By program cost
- By staff resources
required
- By problem
significance
By success of
controls
By proportion of
sources covered
Additional
Management
Control Needs:
For uncontrolled
sources
For high-risk
sources
- For especially
vulnerable areas
Use a Combination
of Approaches:
- e.g., By most
significant problem
w/available staff
28
-------
Management
Approaches
Identify Management Programs
Examples - for identifying and evaluating management programs
| Specify Phxtng Criteria |
Established Environmental Programs
at the State Level
An industrialized State manages its own
programs regulating municipal and industrial solid
waste landfills and also has been delegated
responsibility for the entire range of Federal
environmental programs including Underground
Injection Control. The State has a relatively strong
permit and siting program for managing
point-source pollution; nevertheless, some other
program areas were evaluated by State legislative
oversight committees as relatively deficient. For
example, compliance oversight of sources after
permit issuance was sporadic because of very
limited staff resources.
The Governor appointed a special task force to
review and evaluate the State's source management
programs. The Department of Environmental
Protection (DEP) was designated as lead agency
and provided staff support. The task force review
identified deficiencies and ranked them in priority
order. These source management programs were
compared with sources identified in the WHP
inventory. Similarly, managed sources of high
priority were compared with management
approaches employed. The task force review
identified a lack of early awareness of ground-water
contamination as a high priority problem. The review
also revealed that a range of management strategies
was missing from existing State programs, and its
findings created the basis for matching
ground-water protection strategies with ambient
monitoring and compliance monitoring programs.
The task force's evaluation also showed that
several priority problems (e.g., of above ground
storage of petroleum and bulk chemicals) were not
oeing addressed with adequate staff resources, and
as a result, recommended the creation of several
new technical staff positions. This review, along with
information on the roles and duties of organizations
aotentially responsible for wellhead protection, also
nelped to identify City and County Health Boards
which could be delegated responsibility for
inspection and compliance verification. By
delegating these roles to local agencies, and
enhancing the inspection process, the DEP was able
lo maintain the priorities of existing programs and
devote attention to additional ground-water
protection measures.
Supporting Source Control by Local
Government
The State is predominantly rural, with an
agricultural and mining-based economy;
ground-water provides more than half the public
water supply. While State environmental programs
include ground-water discharge permits and aquifer
classification, they do not address mining-related
ground-water contamination and are not
comprehensive for other source categories. The
most critical source problems are municipal landfills
and agricultural chemical storage and use. Many of
these problems occur within WHPAs.
The Department of Water Resources (DWR) was
given lead responsibility for reviewing and
evaluating the State's source management
programs. The DWR assigned a team of staff
analysts to review source management programs at
the State level. Because many source control
programs operate at local levels, the lead agency
provided a small grant to the State Municipal League
for additional staff support to undertake a parallel
review of local level source management throughout
the State. The review revealed an opportunity to
improve source management through state
assistance to monitor agricultural chemical storage
within WHPAs.
The State's Department of Agriculture, in
conjunction with the local USDA extension agents,
provided technical assistance to county
governments to register and monitor large quantities
of agricultural chemicals stored in WHPAs.
To supplement local approaches, the lead
agency contracted with the State Chamber of
Commerce to develop and operate a waste
exchange hotline, and proposed loan guarantee
provisions as incentives to industries within WHPAs
that install new waste minimization technologies.
Additionally, the lead agency sponsored a series of
demonstration projects in selected counties to show
the feasibility of waste reduction and its impact on
ground-water quality. Together, these two
approaches gained support from both the business
community and the citizenry.
29
-------
Management
Approaches
RanC|e Of Options -for identifying uncontrolled sources and management strategies
Identification of
Uncontrolled Sources
.. >
Agriculture: '".
- Fertilizer application '
and storage
- Pesticide application :
and storage
Urban - NPS:
- Used oil
, - Household wastes
- Urban Run-off
Small Business:
- Storage of sources ^
- Process by-products
and residuals
- Waste streams :
Available Strategies
^ , A %i - ^ - S
Technical "
:j Assistance: ';'
\ - Use of lab facilities
'' - Provision of trained '
personnel
^ ^ j.
; Financial
| Assistance:
[ - Grants ^
\ - Reimbursements
- Loan seed money
| - Leveraged funding
from Federal
programs
Control Measures:
| - Permit requirements :
| - Inspections '
I - Performance i
standards
mm&ssm&is. "* **.'
;| Education:
\ - Public Hearings
i - Outreach Pamphlets
^Training:
- Workshops i
| - Courses
: - Certification
programs
L Demonstration
J Projects:
: - Pilot programs
- Selected
demonstration
sites
Use a Combination
;;of Approaches:
- e.g., Trade organ-
ization workshops to
inform industry reps
on cost-effective
control measures
Selection Concerns
Cost:
- Availability of funds ^
- Level of extra cost b>
to existing program^
Expertise Available:""
- Number of tech-
nical staff
- Types of skills ;
Compatibility ;
with Existing
Approaches:
- Presence of I'
applicable !
ordinances and
regulations
- Existence of
organizational (
mandates }
Risk:
- Degree of risk
reduction
- Type of risk
elimination
30
-------
Management
Approaches
ktontity Management Program* |
- for identifying uncontrolled sources and management strategies
Identify Uncontrolled Sources
Sfxclty PhMlng Criteria
Addressing Pesticide and Nitrate
Contamination
Both nitrates and pesticides have been detected
in wells throughout the State. Current local zoning
ordinances do not incorporate controls on land use
based on proximity to public water supply wells, and
agricultural management practices are unregulated
at the local level.
Given that the State's economy has a very
important grain-producing sector and that most
uncontrolled sources are agricultural, the State
recognized the importance of involving its
Department of Agriculture (DOA) in discussions of
the problem. However, it also recognized that
another State agency might be better able to identify
specific sources and develop source management
strategies to protect ground-water. A dual lead
agency arrangement was created between the DOA
and the Division of Environmental Management
(DEM) in the Department of Natural Resources to
investigate suspected sources of agricultural
contamination of ground-water. A review of the
contaminants, their distribution, and associated
activities confirmed that unregulated pesticides and
nitrates were a significant threat to the State's
ground-water. The lead agency team
recommended that legislation be introduced to
require pesticide use by prescription for specific
pesticides that are known to leach into
ground-water. Because of its established
management advisory role on best management
practices (BMPs), the DOA also agreed to develop
guidelines on site-specific fertilizer application
BMPs in WHPAs.
It is expected that several legislative sessions
will be necessary to move this idea of more effective
pesticide and fertilizer management from proposal
to enactment. During that time, the DOA will contract
with the State Association of Soil and Water
Conservation Districts to develop a program for
demonstrating innovative agricultural BMPs and the
use of Integrated Pest Management (IPM) in several
WHPAs. Responsible pesticide management will
emphasize practices that change timing and
application procedures to reduce leaching,
selection of safer pesticides, and alternate crop
production patterns, which require less pesticide.
Addressing Unregulated Small
Business Sources
The State has both light and heavy industrialized
development and urban centers over nearly
three-quarters of its area, but the remaining portion
is a productive agricultural region. Source control
programs in the State are geared to industrial
facilities and feature operating standards and
discharge permits for these sources. Many small
businesses, such as food processors, dry cleaners,
or car washes, are not regulated under the current
home rule authority of counties and municipalities.
These small businesses are widely distributed in
WHPAs throughout the State. The State's small
business community is apprehensive about the
prospect of regulation and not fully aware of the
significant impact their activities have on ground
water.
The State's planning agency, the Department of
Community Development (DCD), has been
designated as lead agency to identify and address
uncontrolled sources and to evaluate potential
management strategies. A small increase in the
budget appropriation for wellhead protection
enabled the lead agency to hire an environmental
planner with ground-water experience and an urban
planner with zoning and development control
experience. Together they formed a team to provide
technical assistance to counties and municipalities
on environmental controls and land use approaches
for small business resulting in improved source
management. Additionally, a series of educational
forums were planned for local business groups such
as Chambers of Commerce and Kiwanis Clubs to
communicate the significance of small business
activity on ground-water quality.
The lead agency provided information in several
ways: local "town meeting" programs via
teleconference through public service television
channels; articles in State business development
publications; and public service advertisements on
radio and television. The lead agency also provided
pass-through financial assistance via water
suppliers to small businesses that were willing to
demonstrate the application of innovative, low-cost
treatment technologies.
31
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Management
Approaches
identity Management Programs] Range of Options - for specifying phasing and schedule criteria
Identity Uncontrolled Sources I
Specify Phasing Criteria
Phasing Criteria
J Degree of Risk:
- Sources of
contamination
- Existing WHPA
contamination
- Population served
in WHPA
- Water supply
dependence
- Vulnerability of
groundwater
Program Priority: *
- RCRA sites
- UST program
- Ground-water
discharge permitting
program J
- Solid waste program-
Implementation
Feasibility:
- Enabling legislation
- Program status
- Financial assistance
available
Use a Combination ''
of Criteria: -'
e.g., Phase man- ',..
agement controls by
RCRA site priority
for densely popu-
lated areas
Schedule Criteria
Timing:
s - Start individual
source management
controls indepen-
dently of delineation
*- Start after WHPAs
are delineated
"^-L^
Approach:
|- Vary phasing by:
- Hydrogeological
setting
- Source
- Type of Wellhead
- Risk
- Environmental
management
method
Use a Combination ',
of Approaches:
|- e.g., Implement
'* management con-
trols first for un-
protected wellheads:
then address high- s
risk sources in vul-
nerable hydrogeo-
logical settings
32
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Management
Approaches
.m»nt programs I Examples - for specifying phasing and schedule criteria
Specify Phasing Criteria
Setting Priorities by Vulnerability
The State had a variety of hydrogeological
settings, but very little detailed information was
available about the functional characteristics (e.g.,
degree of aquifer confinement) of each setting. With
recently acquired staff resources to support source
management through an appropriation from the State
legislature (which mandated that staff be assigned to
source management), a basis to perform risk
assessments and set priorities to phase-in
management controls was needed.
As lead agency, the Department of Public Health
(DPH) worked with other State agencies seeking
management control over these sources. Because
of the nature of reliable and readily available
ground-water data, the DPH used a numerical risk
management system to rank-order the risk of
ground water contamination in each of the State's
hydrogeological settings using expected levels of
source toxicity and volume of material discharged.
Rankings were determined for each source type,
and risk management strategies developed
accordingly. For instance, in light agriculture regions
with few pesticide and fertilizer sources and a
relatively thick unsaturated zone, the priority for risk
management control was low. Where potential high
threat source contaminants, such as underground
storage tanks, were located in relatively high water
tables and extremely porous geologic material, the
priority for risk management was considered high.
In this phasing approach, individual source
management controls were established in those
areas where potential sources were deemed a
threat, and were supported by recently acquired
staff.
Setting Priorities by Source Threat
The State has a predominance of small
community and non-community wells which are
distributed in areas with mixed land uses and a
variety of potentially contaminating sources. The
State has a permit system for most of these sources
but needs a basis to manage risks to ground-water
and set priorities for inspections and new permit
issuance.
The State Department of Environmental
Protection (DEP) has the lead role for issuing
permits. In order to determine where permitted
sources coincided with drinking water supplies
threatened by potentially contaminating sources, the
geographic distribution pattern of permit holders was
overlaid with the pattern of WHPAs. Readily-
available data from these areas included user
populations, well discharge volumes, and the type of
permitted sources. The DEP translated these factors
into a formula expressing the degree of risk posed by
potentially contaminating sources as they would
affect vulnerable water supplies. This formula
became the basis for setting priorities and phasing
management controls.
The risk priorities were used in preparing permit
conditions, increased monitoring, inspections of
compliance, and enforcement actions to ensure
consistent management of sources in areas where
underground drinking water supplies were
vulnerable.
33
-------
petition or
Contingency
Plan
I Contingency Plan Elements
|
| Chapter Vh Contingency Plan
I Implementation
As specified in Section 1428 of the SDWA and the EPA Guidance
for Applicants, a State WHP Program submittal includes:
Definition of "major" public water supplies in the State
Contingency plan for each major public water system in the State including:
short and long-term alternate water supplies, coordination mechanisms, and
financial considerations
MAJOR MESSAGES
Define "major" public water supplies
according to criteria specifically applicable to
the Statee.g., number of registered wells,
population density, patterns of water-use,
responsibility for provision of water supply, or
other factors
Develop both temporary emergency response
and long-term (i.e., permanent) water supply
alternatives
Use existing emergency response frameworks
and State contingency plans wherever
possible, and build upon and enhance these
existing plans as necessary
Identify parties responsible for implementing
plans and mechanisms for coordinating action
Evaluate the financial responsibilities and roles
implied by the provision of both short-term
and long-term water supplies
Set priorities for developing contingency plans
(e.g., emphasize plan development for major
public suppliers)
The remainder of this chapter illustrates the range of available options for defining "major" public water
supplies and preparing contingency plans along with case study examples of a state's experience in
preparing these WHP Program elements.
35
-------
Contingency
Plan
Definition of "Major" Water Supplies
Contingency Plan Elements
Implementation
Range Of Options -for preparing the contingency plan
Responsibility &
Schedule
Define "Major"
Water Supply
Use Criteria Based
On:
\ - Well Registration
i - Population Served
: - Size & staffing of
public water supply
I - Water use patterns
I - Availability of alter-
native sources of
water
Use a Combination '
of Criteria:
e.g., Define "major"
according to number
of well registrations
serving the State's
major urban areas
Contingency Plan
:', Develop Plan
] Elements:
, - Short-term supplies
- new or adjacent
'- Long-term supplies
, - new, adjacent, or
distant
[\- Coordination
mechanisms:
- Local specialized
s; agency
- County water
offices
- Emergency
response teams
- Financial Plan:
- State matching
/ funds
, - Development bonds
v - Special accounts ;
- User fees
Add to Existing
Plan Elements:
- Local public water
supplies provide info
for generic plan
- Individual plans
modified at local
levels
Plans Completed
by: P
- State agencies
- Local water
districts
- Water suppliers
- Local governments
Timing:
- By date of State
WHP program
approval
- For licensing re-
newal of public
water supplies
- As part of approval,"
process for local
development plans
Interim Emergency
Response
- Use current state-
wide plan "?
* X
- Adapt other plans toV
fit emergency water ;'
contingencies
- Require local gov'ts.?*'
to develop short- '/
term emergency
response plans ",,;
Evaluate potential f
emergency response,,
plans .'
36
-------
Definition of "Major" Water Supplies
Contingency
Plan
Contingency Plan Element
Implementation
Examples - for preparing the contingency plan
Generic Plan with Appropriate Local
Modifications
The population in this State resides primarily in
communities of less than 50,000, and is served by
local public water suppliers. The two large urban
centers of 500,000 have long-term and short-term
contingency plans for their public water supplies.
Provision of public water supplies, including the
enforcement of drinking water quality standards and
well registration, is managed at the county level.
Although this State had delineated numerous
WHPAs, only the large urban water supply systems
had their own contingency plans.
As lead agency, the State Emergency Response
Agency (ERA) chose as the criterion for a "major"
water supply the smallest community population for
which contingency plans were already in place.
Accordingly, the State defined "major" water
supplies as those serving at least 500,000 people.
All WHPAs not covered by the plans for "major"
suppliers were covered by a generic statewide water
supply emergency response plan which was
developed following a water supply emergency
several years ago.
The planned distribution mechanism for
emergency supplies of water consisted of a
renewable contract with a major bottling company.
The company operated throughout the State and
could supply bottled water to communities whose
water supplies were contaminated. A stockpile of
equipment available to localities in the event of an
emergency was also maintained by the ERA.
Distribution of this equipment from ERA Regional
Offices was ensured through a Memorandum of
Agreement with the State's Department of
Transportation which would use its truck fleet to
deliver the equipment in an emergency.
This generic contingency plan served all
non-major water suppliers in the State during the first
three years of the WHP Program until they completed
individual contingency plans. To encourage prompt
completion of the plans.the State amended its Public
Water Supply Act to require all public water suppliers
to develop short-term contingency plans within two
years after EPA approval of the State WHP Program.
These short-term plans require that sources of
temporary water supplies be identified and formal
procedures for coordination during emergencies be
established.
Each Public Water Supply Establishes
its own Plan
This State had several large WHPAs serving
predominantly urban communities, and many
suppliers had contingency plans already in place. A
majority of the water supplies serving over 75,000
people and/or pumping 2.5 mg/day had emergency
response plans, and the State used these criteria to
define "major." However, virtually all of the smaller
water systems lacked contingency plans, especially
those in unincorporated areas. In the past several
years two of these communities had experienced
emergencies and were caught without adequate
temporary water supplies.
The Department of Environmental Quality (DEQ)
amended the State regulations applicable to public
water supplies to require all community water
supplies to develop an emergency response plan by
the time of submittal of the State WHP Program.
Each plan had to address temporary water sources,
coordination mechanisms for implementing the plan,
long-term water supply alternatives, and financing
mechanisms. The State also imposed a schedule for
completing contingency plans for all
non-community wells based upon the vulnerability
to contaminant sources of the aquifers in which these
supplies were located. Operating permits for new
community or non-community systems were not
issued by the State unless a contingency plan was
submitted with the permit application to the State.
Additionally, public water supplies were required to
update their contingency plans every five years.
As lead agency, the DEQ hired a technical
advisor as a liaison with local communities to ensure
that contingency plans were developed in
accordance with State regulations. Additionally, the
technical advisor coordinated this effort with the
community emergency planning activities required
under SARA (Title III).
Non-community water supplies were covered
by a generic State plan ensuring the provision of
temporary water supplies from the closest available
source. This plan was funded by a clause in the
State Unincorporated Land Development Act
providing for emergency support to victims of natural
disasters.
37
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New Wells
Slt« N«w W»H«
Chapter VII: New Wells
M«n«g« SOUICM
J.
As specified in Section 1428 of the SDWA and the EPA Guidance
for Applicants, a State WHP Program submittal includes:
Description of the process for managing sources of contamination within
WHPAs for new public water supply wells
MAJOR MESSAGES
Anticipate future supply needs and
contamination threats by delineating and
managing potential water supplies and
potential WHPAs as part of the water supply
planning process
Site new wells properly to maximize well yield
and minimize potential contamination from
sources in the future
Coordinate planning for new wells with other
planning and development activities
Explore the opportunities presented by
planning for new wells to implement alternative
approaches to wellhead protection, even
though infeasible for established WHPAs,
wells, and the communities they serve
Undertake all steps necessary in the
progression from proposal of new wells to
formal WHPA designation and management
Incorporate public participation in the new well
siting process
The remainder of this chapter illustrates the range of available options for siting new wells and describes
examples of a state's experience in preparing this WHP Program element.
39
-------
New Wells
Expand Delineate New WHPA
Site New Wells
Range Of Options -for siting new wells and managing contaminant sources
Manaqe Sources
Delineation
%
Use Existing Delin-
eation Criteria:
I - Distance ;'
i - Drawdown
i - Time of travel
! - Flow boundaries f
: - Assimilative capacity
Use a Combination .;:;
of Approaches:
- e.g., delineate by
source proximity and .
hydrogeological
setting
Siting
Use Existing Water
Supply Planning
Process:
i - USGS studies
: - Water suppliers
survey/use plans
Add Wellhead
Siting to Another
Planning Program
i - Industrial siting ?t
program
: - State comprehensive^
development plan g
- ' ',-. ' &:* .." ' «?
Use a Combination if
of Approaches:
- e.g., plan new well
sites to serve new
growth areas and be*
incorporated into ^
local comprehensive ~
development plans >"
Source Management
Incorporate Into
Current Methods:
- Permit programs
- Siting programs
- Zoning
-, -. f
Create New
Methods:
- Watershed planning
- New supply planning
Use a Combination
of Approaches:
- e.g., plan new well
sites within water-
shed management
plans
40
-------
| Expand Delineate New WHPA
New Wells | Site New Wells
I Manage Sources
Examples - for siting new wells and managing contaminant sources
Extending An Existing WHPA To Cope
With Increasing Demands
Public water suppliers and Public Works
Departments of local governments in this State have
primary responsibility for ensuring the availability of
water supplies. Most of the new water in this State is
supplied from either increased pumping of existing
wells or the addition of a new well into an existing
wellfield. Both of these circumstances caused
changes in the formal boundaries of WHPAs and
increased the potential for future contamination.
As the lead agency, the Office of Water
Resources (OWR), with assistance from the State
Department of Health, had responsibility for
managing the steps required for a new WHPA
designation. The OWR directed local water
authorities to project future water needs and
potential sources of new supply. Local water
authorities must also report any modification to a
well that would result in a change to the boundary of
a WHPA. To aid local water suppliers and ensure
that new wells are sited properly to maximize yield
and minimize source contamination, the OWR
developed a handbook describing the criteria for
development of supplies from new wells and
adjustments in WHPA boundaries.
Public hearings on water development plans
and source management approaches for enlarged
WHPAs were also required by the State. The
extension of source management requirements to
areas not previously designated as WHPAs was of
great concern to businesses in those areas. The
State was able to foster responsible water supply
practices at the local level through a provision for
public participation in the planning process.
Representatives from several local citizens' groups
were nominated by the local water commissioner to
serve on technical and citizens' advisory
committees during the planning and delineation
phases of the WHPA extension process. These
committees provided a channel for public concerns
about the new supply development criteria, source
management standards within WHPAs, future water
supply needs, and the quantity and quality of future
water supplies.
Delineating New WHPAs To Meet
Future Drinking Water Needs
This State experienced rapid growth in both
residential and business development, and it
became clear that not enough attention was being
given to future water supply needs. New businesses
took options on building sites only to discover that
public water supplies were not adequate. A State
legislative committee held hearings and called for
the development of state-wide and regional water
supply strategies by the State Department
Environmental Protection (DEP) in consultation with
the State Department of Health. These strategies
served as a catalyst for the development of
long-term plans to meet projected water demand.
As lead agency, the DEP managed the
delineation process of a new WHPA. The DEP
started by obtaining an assessment of water use and
available water yields across the State. The 1985
National Water Use Inventory compiled by the United
States Geological Survey provided a basis for the
State to extrapolate water use patterns for specific
localities where projected water demands would
pose significant shortages. These assessments
were provided to municipalities and counties as a
basis to develop or modify their water supply plans.
State regulations for municipal and county planning
required that local comprehensive plans incorporate
elements on water supply planning.
Major undeveloped aquifer areas were
designated as potential WHPAs by the DEP because
they were logical sites for future drinking water
supplies. Local planning authorities and zoning
boards identified potential WHPAs. Sources in these
potential WHPAs were identified, inventoried, and
made subject to the same restrictions and permit
conditions as sources within existing WHPAs.
The DEP provided water supply strategies and
detailed water use information to local governments
and required that comprehensive plans identify
projected water supply needs. This approach
allowed local governments to protect future water
supplies from contamination before wells were
actually sited.
41
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Putting it
All Together
Concluding Thoughts
This Technical Assistance Document (TAD)
provides a range of suggestions for States to
develop their Wellhead Protection (WHP) Program
and offers States an opportunity to apply innovative
approaches by focusing on the entire ground-water
resource, rather than on a limited set of sources or
contaminants.
The intention of this document is to identify what
a complete program includes, raise program
planning issues and concerns, provide concrete
alternatives, and show that no single approach is
necessarily best. Using this TAD as a guide
throughout the planning process, States can assess
their existing abilities to protect wellhead areas while
evaluating ground-water quality. By examining the
Case Study Examples provided here, lead agencies
can interpret the organizational and environmental
circumstances in their State, and consider how the
examples provide analogies for building their WHP
Program. Reviewing the graphic Range of Options
for developing WHP Program elements provides
another important opportunity for States to consider
innovative approaches, and combine them in ways
that meet unique State circumstances.
This TAD is provided with the hope that its simple
and straightforward style will make the task of WHP
Program development easier and more creative. For
an overview of the path a State would follow in
preparing its WHP Program, see the "Road Map" on
the facing page.
42
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Putting it
All Together
Road Map to a WHP Program Submittal
Begin by:
Reviewing EPA Guidance for Wellhead Protection
r Reviewing each WHP Program Submission Element
i
n Considering "Major Messages" for each WHP Program Element
i
n Reviewing existing Ground-water Conditions in the State
rj Reviewing the applicability of the Range of Options
for each WHP Element
Interpreting the applicability of the Case Study Examples
Incorporating Program Submission Elements and
Assemble your WHP Program
Complete your
WHP Program:
s TAD by:
combining ap
State conditio
State and Local
Agency Duties
! Chapter II
Delineation of WHPAs
Chapter 111
Source Identification
Chapter IV
\ Management Approaches
1 Chapter V
Contingency Plan
i Chapter VI
New Wells
I Chapter VII
1 State WHP Program
Submission |
43
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Appendix A
EPA Regional Ground-Water Representatives
Robert Mendoza
Ground-Water Management and Water
Supply Branch
Water Management Division
U.S. EPA Region I Room 2113
JFK Federal Building
Boston, MA 02203
FTS: 8-835-3600
ODD: (617)565-3600
Erlece Allen
Office of Ground Water
Water Management Division
U.S. EPA Region VI
1445 Ross Avenue
Dallas, TX 75202
FTS: 8-225-6446
ODD: (214) 655-6446
John Malleck
Office of Ground-Water Management
Water Management Division
U.S. EPA Region II Room 805
26 Federal Plaza
New York, NY 10278
FTS: 8-264-5635
ODD: (212)264-5635
Timothy Amsden
Office of Ground-Water Protection
Water Management Division
U.S. EPA Region VII
726 Minnesota Avenue
Kansas City, KS 66101
FTS: 8-757-2970
ODD: (913)236-2970
Stuart Kerzner
Ground-Water Protection Section
Water Management Division
U.S. EPA Region III
841 Chestnut Street
Philadelphia, PA 19107
FTS: 8-597-8826
ODD: (215)597-2786
Richard Long
Office of Ground Water
Water Management Division
U.S. EPA Region VIII
999 18th Street, Suite 500
Denver, CO 80202-2405
FTS: 8-564-1543
ODD: (303)293-1543
Stallings Howell
Ground-Water Protection Branch
Water Management Division
U.S. EPA Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
FTS: 8-257-3866
ODD: (404)347-3866
Patricia Eklund
Office of Ground Water
Water Management Division
U.S. EPA Region IX
215 Fremont Street
San Francisco, CA 94105
FTS: 8-454-0831
ODD: (415)947-0831
Jerri-Anne Garl
Office of Ground Water (5WG-TUB9)
Water Management Division
U.S. EPA Region V
230 S. Dearborn Street
Chicago, II 60604
FTS: 8-886-1490
ODD: (312) 353-1490
William Mullen
Office of Ground Water
Water Management Division
U.S. EPA Region X
12006th Avenue
Seattle, WA 98101
FTS: 8-399-1216
ODD: (206)442-1216
44
US GOVERNMENT PRINTING OFFICE 1988 - 516-002 - 1302/80250
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