United States       Office of         May 1987
         Environmental Protection   Ground-Water Protection   EPA 440/6-87-009]
         Agency         Washington, D.C. 20460
         Office of Water
EPA  Wellhead
        Protection
        Decision-Makers'
        Guide

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Wellhead Protection
A Decision-Makers' Guide
  Perhaps you are a
State legislator, whose
constituents have been
voicing their concerns to
you about the contamina-
tion and closing of their
local water supply wells.
Or maybe you head a
State public health or pollu-
tion control agency and
see a need for better
coordination of your
State's ground-water pro-
tection activities. You
could be chairman of a
local zoning board mak-
ing decisions on future
development and wor-
ried that lack of potable
water will limit the growth
of your town.

  These are the kinds of
problems that the Federal
Wellhead Protection Pro-
gram is meant to help
States solve, and the rea-
son the Program became
part of the Safe Drinking
Water Act Amendments
of 1986. EPA has pro-
duced this booklet to
explain how the Program
works and how your State
can benefit by partici-
pating.
What is Wellhead
Protection?

  Wellhead protection is,
by definition, protection
of the area surrounding a
well. So, first of all, we
should explain what a
"wellhead protection
area" (WHPA) is. By stat-
ute, it is defined as the sur-
face and subsurface
area surrounding a well or
wellfield that supplies a
public water system
through which contam-
inants are likely to pass
and eventually reach the
water well or wellfield.
  WHPA boundaries are
determined based on
factors such as well
pumping rates, time-of-
travel of ground water
flowing to the well, aquifer
boundaries, and degree
of confinement. All of
these hydrogeologic
characteristics have a
direct effect on the likeli-
hood and extent of con-
tamination.

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QROUNDWATER DIVIDE
K                                                          GROUNDWATER
                                                             DIVIDE
   NOTE:

    V  WATER TABLE
                         (A) VERTICAL PROFILE
                                                             PREPUMPING
                                                            WATER LEVEL
                                                            BEDROCK
                                The ground-water
                                surface around a
                                pumping well is
                                pulled down as water
                                is drawn into the
                                well, creating a cone
                                of depression (COD)
                                around the well. The
                                extent of this cone
                                can vary from only a
                                few feet to many
                                miles from the
                                pumping well,
                                depending on
                                hydrogeological
                                factors.  Ground
                                water drawn into the
pumping well is
replaced by ground
water further away,
usually uphill
(upgradient) from the
well. The recharge
area, which may he
limited by physical
or hydrologic
boundaries, may
consist of all or part
of the cone  of
depression as well as
the area from which
the replacing water
comes.

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                      A Well
                      Contamination
                      Incident

                        The problem of ground-
                      water contamination is
                      easy to define. If you pick
                      up a newspaper in many
                      communities, you may find
                      an article describing a
                      ground-water contamina-
                      tion incident and its effect
                      on public water supplies.
                      This is not surprising, since
                      95 percent of rural
                      America and in total about
                      half the U.S. population
                      rely on ground water.

                        These incidents are
                      especially sobering when
                          you realize the amount of
                          time and money needed
                          for clean up. For exam-
                          ple, a leak in a gasoline
                          storage tank in a com-
                          munity in Massachusetts
                          made headlines in 1977
                          when it forced the shut-
                          down of a nearby munici-
                          pal wellfield, disrupting
                          that community's only
                          source of drinking water.
                          When the tank was exca-
                          vated, local officials esti-
                          mated that between
                          2,000 and 3,000 gallons of
                          high-test unleaded gaso-
                          line had  leaked into the
                          ground less than 600 feet
                          from the nearest well in
                          the municipal wellfield.
A wellhead
protection area
(WHPA) can be
established for any
type of aquifer and
can include all or
part of the pumping
well's cone of
depression, the
recharge area and the
surrounding aquifer.
The actual extent of
the areas within
WHPAs will vary
depending upon the
program goals of
individual State
programs and the
hydrogeologic
settings present in
the State.
LEGEND:

 E%% CONE OF DEPRESSION

 r~1 ADDITIONAL RECHARGE AREA
                  (B) PLAN VIEW

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AIRBORNE SULFUR
  & NITROGEN
  COMPOUNDS

-------
                                           Potential Sources of
                                           Ground-Water Contamination
//,/,    ACID RAIN
      RECHARGE TO
                           INDUSTRIAL
                          IMPOUNDMENTS
 •'//,//, /  GROUND WATER AND
     SURFACE WATER
                                                   URBAN
                                                   RUNOFF
\ZARDOUS
 WASTE
UMPSIT
               UNCOVERED
                ROAD SALT
                          GASOLIN
                           SERVICE
                           STATION
                                                    I Infiltration to
                                                    f Ground Water

                                                  Not Drawn To Scale

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EPA has estimated
that 20% of the one
million underground
petroleum storage
tanks may be leaking
and have the
potential to
contaminate water
supplies.
                     To address the problem,
                     the town temporarily pro-
                     vided alternative water
                     supplies, instituted a strict
                     water conservation pro-
                     gram, and began a two-
                     phase clean-up process.
                     The second phase, which
                     began in 1985, consists of
                     pumping and treating the
                     contamination and then
                     recharging the treated
                     water back into the aqui-
                     fer. This second phase will
                     take three to five years to
                     complete and will cost the
                     town $1.1 million; the
                     Massachusetts Depart-
                     ment of Environmental
                     Quality Engineering, $1.2
                     million; the Massachusetts
                     Executive Office of Com-
                     munity Development,
                     $750,000; and the U.S.
                     Department of Housing
and Urban Develop-
ment, $250,000. Many
years of work and a total
cost of $3.3 million is a
high price to pay for a
leak in a gasoline storage
tank.

  This type of story,
though a worst case
example, is repeated in
many States, and the
more we look, the more
problems we seem to
find. For example, in
California, 88 large public
water supply system wells
were closed because of
organic chemical con-
tamination including both
solvents and pesticides.
In Virginia, 27 public com-
munity supplies are on
indefinite "boil water"
notices, and in Iowa, 57

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Pesticide
applications of all
types are one of the
many non-point
sources of
contamination.
                      percent of the wells in allu-
                      vial areas have detecta-
                      ble pesticide residues.

                       It doesn't take too
                      many incidents like these
                      to recognize that cleaning
                      up and treating contami-
                      nation or siting and putting
                      in new wells is a costly
                      process.
                     Threats to Water
                     Supply Wells

                       Across the country, hun-
                     dreds of types of poten-
                     tial sources of ground-
                     water contamination
                     have been identified. The
                     magnitude of the poten-
                     tial problem begins to
                     emerge when you con-
                     sider just a few of these
                     contaminant sources: 23
                     million septic tank systems;
9,000 municipal landfills;
190,000 surface impound-
ments; 280 million acres of
cropland treated with pes-
ticides annually; 50 million
tons of fertilizer applied to
crops and lawns annually;
and over 10 million tons of
dry salt and two million gal-
lons of liquid salts applied
to our highways every win-
ter. These sources do not
always threaten ground-
water supplies, but
always have the potential
to do so, unless man-
aged properly.

  The areas surrounding
water well supplies can
be particularly vulnerable
to these sources of con-
tamination, since
contaminants discharged
within the recharge area
to a pumping well may
be drawn toward that

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Road-side signs in
Europe mark the
boundaries of
•wellhead protection
areas.
well. The proximity of most
public water supply wells
to the populations they
serve, as well as to the
every day activities of the
community, also contribute
to vulnerability. Sources as
diverse as dry cleaners,
septic tanks, industrial
facilities, or road salting
can cause well contamina-
tion.  Contamination
source controls and land
management programs
which address physical,
microbial, and chemical
threats to ground water
are important tools that
can help prevent well
contamination.
Wellhead
Protection
Measures

  Designating protection
areas around drinking
water wells is one way to
protect underground
water supplies. Applica-
tion of this concept is com-
mon in Europe. At least 11
European countries, includ-
ing Germany, Switzerland,
and the Netherlands have
designated zones
around their public water
supplies.  Within these
zones, special controls
are imposed on any
number of potential
hazards.

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                       A growing number of
                     States and municipalities in
                     this country also are begin-
                     ning to create such
                     wellhead protection
                     areas.  To guard against
                     the more persistent chemi-
                     cal threats, wellhead pro-
                     tection areas range any-
                     where from a distance of
                     a few hundred feet to sev-
                     eral miles from wells, The
                     characteristics of the aqui-
                     fers surrounding the wells,
                     the extent of pumping and
                     the vulnerability of the aqui-
                     fer to surface contamina-
                     tion, and the degree of
                     development and activity
                     surrounding the well are the
                     primary criteria by which
                     most States, counties, or
                     municipalities have deline-
                     ated protection areas.
  Management activities
commonly employed
within these protection
areas include:  regulation
of land use through spe-
cial ordinances and per-
mits, prohibition of speci-
fied activities, and acquisi-
tion of land.

  Massachusetts and
Florida are among the
States now using some of
these management tools
to protect public water
supply wells.  Beyond the
obvious public  health rea-
sons, State-wide
Wellhead Protection Pro-
grams make a  lot of eco-
nomic sense, as the
earlier contamination
examples illustrate.
The Baddacock well
in Groton, MA, one
of the oldest public
wells in New
England, is being
protected through a
variety of land use
management
techniques.

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Non-community
wells such as those
in campgrounds, for
example, are also
addressed by the
Wellhead Protection
Program.
The Safe Drinking
Water Act
Amendments
of 1986

  Provisions for wellhead
protection were adopted
as part of the reauthor-
ization of the Safe Drinking
Water Act, signed into law
in June 1986. This legisla-
tion established a nation-
wide program to encour-
age States to develop
systematic and compre-
hensive programs within
their jurisdictions to protect
public water supply wells
and wellfields from con
tamination from all
anthropogenic sources.

  The purpose of the
Wellhead Protection Pro-
gram is to prevent contam-
ination of public water sup-
plies.  The primary goal is
the prevention of prob-
lems as contrasted to cor-
rection of existing situ-
ations.

  EPA's role in the Program
is to provide leadership to
States in efforts to pre-
serve valuable ground-
water supplies that
currently, or may in the
future, serve as sources of
drinking water. This will be
accomplished through
program grants and tech-
nical guidance, not by
imposing another layer of
Federal regulation. The
Federal government is not
given any authority over
water allocation, which is
a State responsibility,  Any
Federal department or
agency with jurisdiction
over any potential source
of contamination identi-
fied by a State under this
Program is subject to the
State's requirements.

  State Wellhead Protec-
tion Programs developed
under this Program are to
address public water sup-
ply wells.  There are
10

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                   currently 187,000 public
                   drinking water well sys-
                   tems, including 47,000 com-
                   munity and 140,000 non-
                   communrry drinking water
                   systems. These include
non-residential facilities,
such as campgrounds
and truck stops, and pub-
lic water wells, which are
those serving more than
25 persons.
Siting and putting
in new wells to
replace contaminated
wells can be a
costly process.

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 Various levels of
 State and local
 government will be
 interacting in the
 development and
 implementation of
 Wellhead Protection
 Programs.
                      The State Role
                      In Wellhead
                      Protection

                        Historically, States
                      have primary responsibil-
                      ity for ground-water man-
                      agement. EPA recog-
                      nizes that they will fashion
                      Wellhead Protection Pro-
                      grams that accommo-
                      date their own unique
                     features and needs,
                     since from State to State,
                     and even within States,
                     hydrogeology varies,
                     sometimes dramatically,
                     as do laws and adminis-
                     trative practices.

                      The Wellhead  Protec-
                    tion Program was en-
                    acted to both enhance
 State programs already
 underway, and to encour-
 age other States to begin
 such protection programs
 by providing financial and
 technical assistance.

  The statute specifies
 that all States will partici-
 pate; however, the EPA
 has no authority to estab-
 lish a Wellhead Protection
 Program if a State
 chooses to forgo action
 on its own. There are no
 EPA sanctions against
States that do not
participate.
12

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  Each State has the
opportunity to design and
implement a Wellhead
Protection Program that
meets broad Federal
guidelines. States have a
lot to gain as they go
about the business of
deciding how best to pro-
tect their ground water.
They will benefit from the
availability of a variety of
technical assistance tools,
and they will have addi-
tional funding to carry out
the protective measures
they decide are
necessary.

Applying  for a
Wellhead
Protection
Program Grant

  What does applying for
a grant involve? Basically,
a State has to supply EPA
with a blueprint of its
Wellhead Protection Pro-
gram.  The Safe Drinking
Water Act Amendments
of 1986 set out the kinds of
information that applicants
must provide by requiring
that six elements be
addressed:

•   Specify the duties of
    State and local
    agencies and public
    water systems in
    developing and
    implementing the
    Program
•  Determine the extent
   of the wellhead pro-
   tection area to be
   used

•  Determine all poten-
   tial anthropogenic
   sources of contam-
   inants which may
   have an adverse
   effect on public
   health in the delin-
   eated wellhead
   areas

•  Describe proce-
   dures to protect
   water supplies from
   such contaminants
   that are present
   within wellhead pro-
   tection areas

•  Include contingency
   plans for the provi-
   sion of alternative
   drinking water sup-
   plies for each public
   water system in the
   event of well or
   wellfield con-
   tamination

 •   Require that all poten-
   tial sources of con-
   tamination within the
   wellhead protection
    area of new public
    water supply wells
    be considered prior
   to construction.
                                                 13

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 Calculation of the
 time it takes for
 contaminants to
 travel from the point
 where they enter the
 ground water to the
 wellhead is one
 method used to
 determine wellhead
protection zones.
                        The Amendments further
                      require an applicant State
                      to demonstrate that public
                      participation was solicited
                      and carefully weighed in
                      the process of formulating
                      a Wellhead Protection
                      Program.

                       As for choosing the way
                     to create a Wellhead Pro-
                     tection Program that
                     includes the above ele-
                     ments, that is left up to the
                     individual State. How-
                     ever, the presumption is
                     that, rather than starting
                     from scratch, States will
 build on Ground-Water
 Protection Strategies and
 existing programs and
 also look to those Federal
 programs with ground-
 water protection
 elements.

 The EPA wants to ensure
 that States have a clear
 understanding of the
 intent of the statutory ele-
 ments  and will be offering
 specific guidance on
 how to establish a
 Wellhead Protection Pro-
 gram that will be eligible
for Federal funding.

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Dade County is one
of many
communities that
have established
Wellhead Protection
Programs.
                     In fact, helping States to
                     develop eligible pro-
                     grams is EPA's main goal
                     as it administers the
                     Wellhead Protection Pro-
                     gram. As described later
                     in this brochure, EPA will
                     also publish a series of
                     informational documents
                     that include examples of
                     programs and provide
                     resource information to
                     help States in developing
                     their own programs.

                     Some Program
                     Features

                       Participants will need to
                     designate a lead manag-
                     ing agency capable of
                     carrying out requirements
                     of the law and of coordi-
                     nating communication and
                     activities among the vari-
                     ous entities that are
involved in public water
administration and
supply.

  A very important pro-
gram activity will be to
determine the roles that
State and local agen -
cies, as well as public
water suppliers, are to
play in developing and
carrying out the State
Wellhead Protection Pro-
gram. Again, the con-
cept of a lead managing
agency is introduced to
ensure implementation
through a coordinated
and well managed
program.

Getting Started

  When it comes to
wellhead protection, par-
ticipating States
obviously will vary in their
                                                                     15

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The roles of the
various participants,
on all levels, is a
very important
component of the
Wellhead Protection
Program
                      needs and goals. Some
                      will have sophisticated sys-
                      tems already in place;
                      others may have tew, if
                      any, existing protection
                      mechanisms.

                        Whether the goal is to
                      upgrade current pro-
                      grams, or just get started,
                      every State has to begin
                      by looking at the same
                      things: the hydrogeology
                      of the State as well as the
                      existing legal and institu-
                      tional apparatus. The lat-
                      ter is especially important
                      to examine in order to get
                      a head start in the plan-
                      ning process, For exam-
                      ple, new laws may be
                      needed to control
                      sources of contamination
                      not previously regulated.
                      What are the steps neces-
sary to get such laws
enacted and imple-
mented and how long will
it take?

  Here is a list of questions
that you might want to
consider as you  begin to
develop a Wellhead Pro-
tection Program in your
State:

•  What is the serious-
   ness and distribution
   of preventable
   well contamination
   problems in the
   State?  Does a signifi-
   cant need exist for a
   State-wide effort to
   control such contami-
   nation?

•  What organizational
   and legal authorities
16

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   already exist and are
   they sufficient to
   implement the type
   and level of
   wellhead protection
   desired on State and
   local levels?

•  What is known about
   the hydrogeology of
   areas where public
   water supply wells
   are located?

•  Whatjurisdictional
   units would be respon-
   sible for, or affected
   by, a WHP Program?
   State Departments of
   Environmental Quality
   or Public Health?
   What about substate
   units, such as special
   purpose districts, or
   public  and private
   water companies?
   Are there local
   jurisdictional units
   and interested
   parties, such as Fed-
   eral agencies with
   public  water supply
   jurisdiction, to con-
   sider?  How do we
   get these groups
   involved?

•  What ground-water
   protection and
   resource manage-
   ment activities are
   already in place at
   the State and local
   levels?  Could they
   be incorporated into
a WHP Program? Are
there Federal and
State programs with
ground-water protec-
tion components that
could be built on and
enhanced?

What kind of adminis-
trative structure is
appropriate? Is there
an existing agency
that can manage the
overall program,
ensuring communicat-
ion among those
involved in program
development?  Or is
a new umbrella
agency needed?
What capabilities
should the managing
agency have?

What technical skills
are needed for defin-
ing wellhead protec-
tion areas, taking
stock of sources, and
analyzing source
risks?

What resources are
available (technical,
managerial, and
financial) to carry out
the program? How
can any gaps be
closed? Is there infor-
mation on existing
inventories and risk
assessment to
use and thus avoid
duplication?
                                               17

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                       Clearly, many factors
                      have to be considered
                      even before the process
                      of identifying sources and
                      developing management
                      strategies can begin.
                      Recognizing the extent of
                      the commitment in time
                      and resources that States
                      will need to earmark for this
                      program, EPA sought
                      ideas from a broad spec-
                      trum of individuals and
                      organizations in the devel-
                      opment of program policy
                      and guidance.

                       EPA consulted Federal,
                      State, and local agencies;
                      environmental groups; and
                      experts in business, indus-
                      try, and academia. State
                      and local representatives,
                      who have sat on technical
                      committees and attended
                      workshops, have helped
                      pinpoint ways that EPA can
                      streamline the program.

                       To help States plan pro-
                      grams eligible for Federal
                      funding, EPA is preparing a
                      series of documents,
                      including a program guide
                      and application package
                      that spells out exactly what
                      a State needs to include in
                      a WHP Program submission
                      for funding. Due out in
                      June 1987, this package
                      also will contain deadlines
                      and funding information,

                       Targeted for publication
                      at the same time, "Guide-
lines for Delineation of
Wellhead Protection
Areas" will outline various
approaches that States
can use to define protec-
tion areas around
wellheads. The docu-
ment specifically
discusses various criteria
mentioned by the statute
that may be used to
define wellhead protec-
tion areas. These include:
distance, drawdown,
time-of-travel, physical
boundaries, and assimila-
tive capacity
approaches. The docu-
ment also discusses a vari-
ety of technical methods
to delineate these areas,
ranging from simple
"cookie-cutter" tech-
niques to the use of
sophisticated computer
models.

  Beginning in the summer
and in the fall, EPA will
issue several other techni-
cal assistance docu-
ments.  The first of these
will illustrate a variety of
ways to put together a
State Wellhead Protec-
tion Program.  Other docu-
ments in the series will be
similar to the one already
issued on management
of septic systems and will
deal with specific topics
pertinent to wellhead pro-
tection.
18

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Grant
Process
Schedule
Federal Funding

  Funding for Federal sup-
port of State WHP Pro-
grams is authorized for
each of the Federal fiscal
years 1987-1991.  Subject
to Congressional appropri-
ation, funds have been
requested in the Pre -i-
dent's Budget for FY 1988.

  The first two years of
funding  are to be
directed toward program
development.  Once a
State program is
approved, the State may
then apply for funds to
implement its program.
EPA cannot fund program
development after June
1989.
  Funds will be allocated
on a matching basis with
EPA matching State funds
at 90 percent for FY 1988,^
the maximum allowable
level, with a 10 percent
Federal matching level
decrease during each of
the subsequent program
funding years, e.g., 80
percent for FY 1989. Assis-
tance funds are for a one-
year budget period and
must be applied for
annually.

  During the develop-
ment phase, States will
design a State WHP Pro-
gram that specifically
describes their Program
and formally designates
a managing agency to
   • June 19,1987
     - Applicants' Guidance and Application Materials can be requested from EPA

   • July 1987-August 1987
     - Training available to State staff by EPA concerning WHP Program and process
       for Assistance Application

   • May 1987-January 1988
     - Application Development di scussion between State staff and Regional
      Office staff

   • January 1988
     - Financial Assistance Appfcation received from States by Regions

     - States needing more time would submit a letter of intent to the Regions
      by this date if they conn ot provide an application

   • January 1988-May 1988
     - Funding arrangements completed
                                                                       19

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                      direct the Program. Many
                      States will probably have
                      a number of agencies,
                      both at the State and local
                      level, which will have
                      responsibility for the vari-
                      ous Wellhead Protection
                      Program activities. The
                      managing agency will
                      have the responsibility of
                      ensuring that these activi-
                      ties are implemented.
                     Summary

                       Wellhead protection is a
                     management process that
                     acknowledges the link
                     between activities that
                     take place in wellhead
                     areas and the quality of
                     the ground-water supply
                     for those wells. It calls for
                     cooperation among the
                     many groups that have a
                     say in the activities that
                     affect wellhead protec-
                     tion areas.
  For some States, the
process already has
begun. For them, Federal
funding and technical
assistance means a
chance to create a more
comprehensive ground-
water protection pro-
gram than they now
have. For States which
are just beginning, here is
an opportunity to build a
solid program from the
start.

  Whatever ground-
water protection phase a
State may be in, the Well-
head Protection Program
is an opportunity to focus
on the needs and goals
of each individual State
and help it meet its water
supply protection goals.
For all of those involved,
there is one underlying
goal, namely to help pro-
vide quality drinking water
for generations to come.
20

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               EPA Regional Ground-Water Representatives
gion I
bert Mendoza
Dter Management Division
ston, MA  02203
S) 8-835-3600
OMM) 617-565-3600


>gion II
ihn S Malleck
ater Management Division
sw York, NY 10278
TS) 8-264-5635
;OMM) 212-264-5635


sgion III
. Thomas Merski
'ater Management Division
liladelphia, PA  19107
TS) 8-597-2786
;OMM) 215-597-2786
Region IV
James S. Kutzman
Ground-Water Protection Branch
Atlanta, GA 30365
(FTS) 8-257-3866
(COMM) 404-347-3866

Region V
Jerri-Anne Garl
Water Division
Chicago, IL 60604
(FTS) 8-886-1490
(COMM) 312-353-1490

Region VI
Don Draper
Water Management Division
 Dallas, TX 75202-2733
 (FTS) 8-255-6446
 (COMM) 214-655-6446


 Region VII
 Timothy L Amsden
 Office of Ground-Water Protection
 Kansas City, KS 66101
 (FTS) 8-757-2815
 (COMM) 913-236-2815
Region VIII
Richard Long
Water Management Division
Denver, CO 80202-2405
(FTS) 8-564-1543
(COMM) 303-293-1543


Region IX
Patricia Eklund
Water Management Division
San Francisco, CA 94105
(FTS) 8-454-0831
(COMM) 415-974-0831


Region X
William A Mullen
Water Management Division
Seattle, WA 98101
(FTS) 8-399-1216
 (COMM) 206-442-1216

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