United States
Environmental Protection
Office Of Water
September 1990
A State Wellhead
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


                                        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-Coleman of OGWP, 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

                                                            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

II.  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


     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

     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:

jjfc   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
    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

Overview of the Wellhead Protection

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

 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

 •  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

 •  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

 •  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

•   Meet the State's goals, fit within its institutional
    constraints, and address the State's unique

•   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

•   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.

    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.

Roles &
         1 Identify RO)M
Assign Dutlm
         Coordirurt* Activities
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

   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., to
   handle cross media issues)
                                    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.

Roles &
            Identity Roles
Assign Duties
                       Range Of Options -for identifying agencies and lead management roles
            Coordinate Activities
 Possible  Participants

      - State EPA
      - Dept. of Public
     i- Dept. of Natural
       - State Geological
       - State Water Board
       - State Planning
       - Other State Support!

       - Regional Planning
       - Interstate  Compacts

       - Municipal Public
        Works Departments
       - Zoning Boards
       Water Suppliers:
       - Local Public Water
       - Private Utilities
       Other Public
       - Agriculture
        Extension Service
       - Special Districts
        - Soil & Water Con-1
          servation Districts!
        - Groundwater
        - Health Districts
       - Universities

       Private Sector
      - Professional
      - Technical Advisory
      - Citizen Advisory
       • User Groups
                           Functional  Categories

                                 - Budgeting
                                 - Funding
                                 - Data Collection
                                 - Data Management
                                 - Oversight
                                 Technical Support:
                                 - QA/Testing
                                 - Research/Evaluation
                                 - Hydrogeology/

                                 - Permitting
                                 - Enforcement
                                 - Monitoring
                                 - Infrastructure
                                 - Establishing Prioritie
                                 - Water Use/Demand
Role  Designation
   I Lead Agency Roles |
   i Based on:
   : - Policy Responsibility
   I - Program
   I - Coordination
   I - Budgetary Support

   \ Support Roles
   j Based on:
   i - Technical
   ! - Available staff
   i - Regional/local

 Roles &
           Identity Roles
           Coordinate Activities
Examples - for identifying agencies and lead management roles
Sorting Out Overlapping Roles and

    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 Bi-dget Office
recommended that the  State's Geologic  Survey
serve this technical  support  role,  due  to  its
experience  and  available  staff   of   qualified
    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
                     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.

Roles &
           Identify RolM
Assign Duties
                    ] Range Of Options -for assigning duties to each participating agency
                       I Administrative:

                        - Develop and
                         Implement Policy

                        - Develop Budget
                        - Perform Oversight
                        - Design Control

                        - Delineate WHPA's
                        - Assess Risks

                       \ Regulatory:
                        - Issue Permits
                        - Perform Inspections ]

                        - Levy Fines

                        - Project Water

                        - Identify Consumption
                        - Plan Infrastructure
                        - Investigate New
                         Sources of Supply

                        - Determine Fate and \
                        - Identify Future
                        - Treat Water
                        - Maintain Supply
                        Combinations of
                        -e.g.,  Combine Risk
                         Assessments and
                         New Source  Invest- i
                         igation duties In one i
                                                    Lead Agency:

                                                    - Initiate Policy

                                                    - Manage Program
                                                    - Coordinate Work

                                                    - Develop Budget

                                                    - Procure Funding

                                                    Support Agencies:

                                                    - Perform Technical

                                                    - Conduct Outreach

                                                    - Report on Inform-
                                                     ation Gathering

                                                    - Collect Data
                                                   Other Groups:
                                                   (Universities &
                                                   Private Organizations)!

                                                   - Collect Data

                                                   - Support Outreach

 Roles &
Assign Duties
                               Examples - for assigning duties to each participating agency
           Coordinate Actlvitta
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
    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. Newwell siting was handled
by the State Planning Office, which drew support
from  the  State  Geologic  Survey for  technical
                                     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

    Roles &
               Identity Roles
AMign Dutto
                      Range Of Options  -for coordinating activities of participating agencies
                Coordinate Activities
                                                            Develop Mechanisms
                                                          to Coordinate Activities

                          i - State/Local
                           - Between States
                           - State/Federal
                           - City/County
                           - Special District/

                           - Natural Resource/
                           - Regulatory/Non-
                           - Boards/Depart-
                             ments/Commissions I

                           - Disposal/Water

                           - Land Use/Supply

                            - Water Supplies
                            - Users
                            - Infrastructure

                            - Utility Companies/
                            - Price/Quality

                            Govt. /Citizen:

                            - Service/Fee
                                                  - Cooperative
                                                  -Memo of Under-
                                                  - Compact
                                                  - Contract

                                                  - Enabling Legislation
                                                  -Executive Order

                                                  -Budget Directive
                                                  -Legislative Comm.

                                                  -Task Forces
                                                  -Work  Groups

                                                  - Reports
                                                  - Newsletters/Media
                                                   -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 1
                                                    are made to support'
                                                    the WHPA Program.

 Roles &
           Identify Rol»»
                     Examples - for coordinating activities of participating agencies
           Coordinate Activities
Coordinating Management of Existing

    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
     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.

           ChooM Institutional Pi
           ChooM Delineation Criteria
  Chapter III: Delineation
           Identify Phasing Sctwdute
    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

     2)  microbial contaminants

     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

     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
 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.

                Choose Institutional Processes
                Choose Delineation Criteria
               I Identify Pha»lng Schedule
Range Of OptiO ns  - for choosing institutional processes in delineation
        Technical Input
          From Operational
          - Technical Staff in
           State Environmental;
          - State Geological

          - State energy and
           land use agencies

          - Expert Panels
          From Research
          - University Water
            Resource Centers
          - State Universities
          - Federal Laboratories
          - State Geological
          Use a Combination
          of Approaches:
          - e.g.,  Expert Panels I
            review of other
            States' approaches ;
                                          Implementation Tools
      i Administrative
      • - Policy Statement
      I - Executive Order

      I Guidance:
      | - Planning Documents i
      ; - Delineation Guidance!
        and Criteria

      i - Ground-water
        Protection Guidance i

      I - State Regulations
      i - Local Ordinances
        and Codes
      i Use a Combination
      \ of Approaches:
      |-e.g., an Executive
         Order to Encourage
         Policy Change in
         Local Governments
Methods of Monitoring
       & Refining
       - Periodic review
       - Technical Work
       - Periodic Status
                                             Use a Combination
                                             of Approaches:
                                             -e.g., Periodic
                                              Status Reports of
                                              a Work Group

            Choose Institutional Processes
ChooM D»Hn««tlon Crit«ri«

M«mtty PhMlng Schedute
                       Examples - for choosing institutional processes in delineation
 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
                                      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
                                          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.

                ChooM Institutional Processes I
   Delineation  I Choose Delineation Criteria
Range Of Options -for choosing delineation criteria and thresholds
       Delineation Goals
          Wellfield Manage-
      Criteria Thresholds
         I- 1000s of ft. to
            2 miles +

         1-0.1 to 1.0ft

          Time of Travel:
         i -<10 to 50 yrs.
         i - By geology and
           hydrology limits

          - By contaminant
                                         Criteria Considerations

        - Protectlveness
        - Ease of

       I- Economy of

       I - Economy of

        - Defenslbllity

        - Application for

       j- Relevance to goal


        - Ease of criteria
        - Ease of criteria
        - Ease of field
        - Consistency with
         G-W classes
        - Ability to Incorporate!
         physical processes

        - Extent of current
        - Simplicity of data

        - Availability of data

        - Suitability for various!

        - Accuracy
   Arbitrary Fixed
   Calculated Fixed
  • Simplified variable
  • Analytic methods
   Numerical flow and
   transport Models
i Use a Combination
j of Approaches:

   e.g., Combine
   mapping with
   analytical methods
   in key sections

            Cttoos* Institutional ProoassM
Delineation  I Choose Delineation Criteria
]  Examples - for choosing delineation criteria and thresholds
            Identify Phasing Scrwdute
Establishing Wellfield Management for
Entire Recharge Areas

    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
    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.
                  Establishing a Remedial Action Zone
                  Around Wellheads

                      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
                      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.

 choo»« in.ututionaiproce.se. i  Range of Options - for phasing delineation
I Chooa* Delineation Criteria   I
               Identify Phasing Schedule
      Delineation Timing
         - Formally establish
          criteria, thresholds
          and methods
         By Phase:
         - Identify WHPAs

         - Demonstrate test
          case applications

         - Apply risk assess-
          ment to establish

         - Determine nature of |
          phasing needed

         -Establish criteria for|
          each major or
          minor phase
                          Phasing  Considerations
                                 Communal Use Risk:?
                               I - Population served

                               I - Pumping rates

                               i - Importance of
                                  particular wells

                               ! - Number of
                                  consumers served

                                 Extent of Contam-
                                 ination of Ground

                                 Presence and
                                 Extent of Contam-
                                 ination Threats:

                               i - Within WHPAs

                               i - In Surrounding

                                 Degree of Aquifer

                                 Assurance of
                                 Aquifer Confine-

                                 Stringency of

                                 Stringency of

                                 Availability of Staff
                                 and Resources
                                                                                   \ Reappraise or
                                                                                   i Improve Boundaries
                                                                                   I of Specific WHPAs
                                                                                   i as Needed:
                                                                                    - Apply more sophis-
                                                                                     ticated methods

                                                                                    - Reinterpret  existing

                                                                                    - Reinterpret  existing
                                                                                    - Collect new data
                                                                                   ; Adjust Hydrogeo-
                                                                                   ' logically Deter-
                                                                                   i mined Boundaries
                                                                                   : to Match Other
                                                                                   i Features:

                                                                                    - Governmental
                                                                                    - Area zoning bound-
                                                                                    - Roads
                                                                                    - Major topographic

           ChooM Institutional Process**
Examples -for phasing delineation
Phasing Delineation Primarily by

    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

                 Phasing Delineation by Relative Risk to

                    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
                    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
                    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.

                              Chapter IV: Source Identification
     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 WHP A, and a schedule for
     completing the Inventory process                    :^v
     Procedure for refining, expanding, updating, and verifying inventory of
     specific sources of contamination in each WHP A
                                MAJOR MESSAGES
      Use either an existing list or develop a new
      o   first define the source categories
      o   then assess whether they belong on the
      o   finally, prepare the list of relevant source

      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.

               List Source Categories
Develop Sourc* Inventory
               Modify Inventory
                       Range Of OptiO ns  - far organizing contaminant source categories
     Defining  Categories

         i Use Existing Lists:

         !- State  list(s)
         i-Other States' lists
         j - OTA list of sources
         I - Federal regulatory
           categories (e.g.,
           Superfund,  CWA,
         i - Local  ordinances,
         ! Derive a Source
         i Category List:

          • from existing
          • from monitoring
          - from review of
           manufacturers by
           SIC category
          - from permitting
          - from advice received!
           from State technical f

          - from a Delphi
           process with
           technical experts
         i Use a Combination
         i of Approaches:
         I -e.g., combine
            several lists,
            or use a list sup-
            lemented with an
            existing survey
                         Assessing Categories
                             | - by chemicals stored
                               or discharged
                             | - by documented

                             | - by major vs. minor
                               source categories
                             | - by distance to the
                             ji - by SIC code
                             | - by regulatory status
                             | - by risk assessment


                             | - of fate and transport;
                               by generic hydro-
                               geologic setting

                             | - of risk by vulnerability f
                                              Use a Combination
                                              of Approaches:
                                             I-e.g., combine a
                                               simple screen with a
                                               risk model
Preparing a  List
 i Without further
 i source category
 i grouping

  Group Source
 |-by risk
 | - by regulatory status
 I - by well service area
 I - by hydrogeologic
 f - by land use
 |-by political
                                                                                   Use a Combination
                                                                                   of Approaches:
                                                                                  I -e.g., combine risk
                                                                                    category within a
                                                                                    grouping by well
                                                                                    service area

                                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
    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

    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.

                u«tsouTc«c*»gofi..     |  Range Of Options -for procedures to inventory contaminant sources
Develop Source Inventory
                ModHy Inventory          |
     Inventory Procedures
           Use Existing Public \
         i - existing surveys
         i - completed studies
           - aerial photos
           - permits
           - licenses
           - registrations
           - notifications
           - tax records
           - directories
           - regulatory
            compliance records
           Conduct Surveys:
           - telephone
           - windshield
           - door-to-door
           - sanitary survey
           - delegate survey
            responsibility to
            local governments
            or special districts

           Enact Notification
           Use a Combination
           of Approaches:
           - e.g., combine use
            of existing records
            with windshield
                         Inventory Information
                                -Source owner/
                                 operator, name,
                                -source type,
                                 I.D. No.
                                -location and size of
                                 source (latitude,
                                -distance to public
                                 water supply well
                                                Additional Data:

                                                - existing manage-
                                                 ment controls
                                                - known public health
                                                 or environmental

                                                - characteristics of
                                                 saturated and
                                                 unsaturated zones
Inventory  Schedule
    1 - start independent ofi
       a WHPA delineation I
       using estimate of
       WHPA criteria

       Conduct jointly with |
       WHPA delineation,
       adjusting inventory
       as delineation
       boundaries are
       start after WHPAs
       are delineated

    I Approach:
    i - perform initial
       screening prior to
       conducting detailed i

    i - Assign priorities
       based on potential
       contaminants, or
       populations served,
       or hydrogeologic
                                                                                    Use a Combination
                                                                                    of Approaches:
                                                                                    -e.g., start with a
                                                                                     simple screen, then
                                                                                     add more detail
                                                                                     after delineation is

             Ltat Source CttcgorlM
Develop Source Inventory
             Modify Inventory         \
                     Examples -for procedures to inventory contaminant sources
  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 conducted 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.

                                      Range Of Options -for modifying and adjusting the source inventory
                   Expanding Inventory
Refining Inventory Data
                        Additions to Data:
                        -Add new information I
                         on existing sources
                        -Add new sources in
                         existing categories

                        -Add newly regulated ii
                         source categories
                        -Include addditional
                         non-point sources
      I Convert Data to
      [More Usable Forms:!

      I- Standardize data
        collection methods
      |- Organize data by
        user priorities
      |- Identify specific
        contaminants of
      |— Convert distances tc
        TOT measures
                        Use a Combination
                        of Approaches:
                        -e.g.,  combine
                          additional infor-
                          mation on existing
                          sources with
                          Inclusion of new
      i Use a Combination
      I of Approaches:
      1- e.g., standardize
        data collection
        methods and better
        specify contaminants
                    Verifying  Inventory
  Updating Inventory
                        i Data Quality
                        i Assurance:

                          Office-based veri-
                          fication by cross-
                          checking permit
                          applications and
                          renewals or mailing
                          out questionnaires

                          Field verification  by
                          performing on-slte
                         Use a Combination
                         of Approaches:
                         -e.g., combine
                          permit cross-checks
                          with an on-site
      Improving Existing
      - Review public
        records periodically
      - Review environ-
        mental data bases
        for data updates *
      - Perform periodic

      - Review periodic
        surveys & completed

     |- Review permit mod-
        ifications, renewals,
        and denials
      I Use a Combination
      I of Approaches:
      f- e.g., combine
        periodic review of
        records with periodic

             tlM Source Categories
             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
                  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
                      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.

         Identity Management Program!
         Identify Uncontrolled Souren
         Specify PhMlng Criteria
Chapter V: Management Approaches
   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 selecting
   management strategies for these sources

   Criteria used by the State if it decides to phase management controls within
                             MAJOR MESSAGES
•  Consider locations, institutional settings, and
   type of source in the selection of management

•  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.

                Identify Management Programs
Of Options  -for identifying and evaluating management programs
                          Identify Source
                      Management Programs
                             - Permit Programs
                             - Enforcement
                             - Zoning ordinances

                             - Siting Restrictions


                             - Planning assistance
                             - Land acquisition

                             - Education
                             - Information
                             - Tax Incentives
                             - User fees
                             - Environmental
                            By Government

                             - Federal
                             - State
                             - Regional
                             _ Local
                             - Special district

                   - By type of source

                   - By program cost

                   - By staff resources
                   - By problem
                   - By success of
                   - By proportion of
                    sources covered
                   Control Needs:

                   - For uncontrolled
                   - For high-risk

                  : - For especially
                    vulnerable areas
                                                                  Use a Combination
                                                                  of Approaches:
                                                                  - e.g., By most
                                                                    significant problem
                                                                    w/available staff

             Identify Management Programs
Identify Uncontrolled Sourcm
             Specify PhMlng Criteria
                      Examples - for identifying and evaluating management programs
  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
  being 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
  potentially responsible for wellhead protection, also
  helped 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
  to maintain the priorities of existing programs and
  devote  attention  to  additional  ground-water
  protection measures.
                                      Supporting Source Control by Local

                                          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.

               M.ntnyMai«9tmentProgrMn.|Ranae Qf QptiOHS -for identifying uncontrolled sources and management strategies
Identify Uncontrolled Sources
       Identification  of
   Uncontrolled  Sources

         - Fertilizer application j
          and storage
         - Pesticide application I
          and storage

         Urban - IMPS:
         - Used oil
         - Household wastes
         - Urban Run-off

         Small Business:

         - Storage of sources
         - Process by-product^
          and residuals
         - Waste streams
                            Available  Strategies
                                - Use of lab facilities
                                - Provision of trained
                                - Grants
                                - Reimbursements
                                - Loan seed money

                                - Leveraged funding
                                  from Federal
                                               Control Measures:
                                               - Permit requirements
                                               - Inspections
                                               - Performance
                                               - Public Hearings
                                               - Outreach Pamphlets
                                               - Workshops
                                               - Courses
                                               - Certification
                                               - Pilot programs
                                               - Selected
                                               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
   to existing program

 Expertise Available:!
 - Number of tech-
   nical staff
 - Types of skills

: Compatibility
i with  Existing
i Approaches:
 - Presence of
   ordinances and

 - Existance of

i Risk:
 - Degree of risk

 - Type of risk

ktontlfy Management Programs I  Pvamnlne «.,w» M •       *. « _,
•••••••••i•—•••  examples - for identifying uncontrolled sources and management strategies
Identity Uncontrolled Sources
             Specify Phasing Criteria
 Addressing Pesticide and Nitrate

     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
                                          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.

                Identify Management Programs
Identify Uncontrolled Sources
                Specify Phasing Criteria
                       Range Of Options -for specifying phasing and schedule criteria
                           Phasing  Criteria
                             Degree of Risk:
                             - Sources of
                             - Existing WHPA
                             - Population served
                              In WHPA
                             - Water supply
                             - Vulnerability of
                             Program Priority:

                             - RCRA sites

                             - LIST program
                             - Ground-water
                              discharge permitting!
                              program          ':

                             - Solid waste program!


                             - Enabling legislation

                             - Program status
                             - Financial assistance i
                             Use a Combination
                             of Criteria:
                              e.g., Phase man-
                              agement controls byl
                              RCRA site priority
                              for densely popu-
                              lated areas
                                                                Schedule Criteria
                                                   \- Start individual
                                                     source management \
                                                     controls indepen-
                                                     dently of delineation

                                                   f- Start after WHPAs
                                                     are delineated
                                                  f- Vary phasing by:

                                                     - Hydrogeological
                                                     - Source
                                                     - Type of Wellhead
                                                     - Risk
                                                     - Environmental
                                                    Use a Combination
                                                    of Approaches:
                                                   -  e.g., Implement
                                                      management con-
                                                      trols first for un-
                                                      protected wellheads |
                                                      then address high-
                                                      risk sources in vul-
                                                      nerable hydrogeo-
                                                      logical settings

             Identify Management Program*
Identity Uncontrolled Sources
                     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
                                       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
                                           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

           I Definition of "Major" Water Supplies
         Contingency Plan Element*
                               Chapter VI: Contingency Plan
     As specified in Section 1428 of the SDWA and the EPA Guidance
     for Applicants, a State WHP Program submittai 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
                                               •  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)
•  Define "major" public water supplies
   according to criteria specifically applicable to
   the State—e.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

•  Use existing emergency response frameworks
   and State contingency plans wherever
   possible, and build upon and enhance these
   existing plans as necessary
  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.

               Definition of "Major" Water Supplies
Contingency Plan Elements
                         [Range Of Options  -for preparing the contingency plan
                                                                                  Responsibility &
          Define  "Major"
          Water  Supply
          Use Criteria Based
         [ - Well Registration
         1 - Population Served
         [ - Size & staffing of
           public water supply

         • - Water use patterns
         i - Availability of alter-
           native sources of
          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

                                - Short-term supplies
                                 - new or adjacent
                                - Long-term supplies
                                 - new, adjacent, or

                                - Coordination
                                 - Local specialized
                                 - County water
                                 - Emergency
                                   response teams

                                - Financial Plan:
                                 - State matching
                                 - Development bonds |
                                 - Special accounts
                                 - User fees
                                Add to Existing
                                Plan Elements:
                                - Local public water
                                 supplies provide info.
                                 for generic plan

                                - Individual plans
                                 modified at local
    i Plans Completed
    f by:
     - State agencies
    i - Local water

    I - Water suppliers
     - Local governments
    I Timing:
     - By date of State
       WHP program

     - For licensing re-
       newal of public
       water supplies
     - As part of approval \
       process for local
       development plans
Interim  Emergency
                                                                                      Use current state-
                                                                                      wide plan

                                                                                     -Adapt other plans tol
                                                                                      fit emergency water f

                                                                                     - Require local gov'ts.f
                                                                                      to develop short-
                                                                                      term emergency
                                                                                      response plans

                                                                                     - Evaluate potential
                                                                                      emergency response

Definition ot "Major" Water Supplies

Contingency Plan Elements
Examples -for prepan/^i the contingency plan
  Generic Plan with Appropriate Local

     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
                                      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 witri'the permit application to the State.
                                      Additionally, public water supplies were required to
                                      update their contingency plans every five years.
                                          As lead  agency,  thexDEQ  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

          Expand/DtllMM* New WHPA
New Wells
  Chapter VII: New Wells
          Mwiag* Source*
    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.

   New Wells
                Expand Delineate New WHPA
                Manage Sources

               Use Existing Delin- \
               eation Criteria:
             i - Distance
             i - Drawdown
             I - Time of travel
             | - Flow boundaries
             | - Assimilative capacity!
              Use a Combination
              of Approaches:
              -e.g., delineate by
               source proximity anc
Range Of Options -for siting new wells and managing contaminant sources
         Use Existing Water j
         Supply Planning

        | - USGS studies

        i - Water suppliers
          survey/use plans
                                              Add Wellhead
                                              Siting to Another
                                              Planning Program

                                              - Industrial siting

                                              - State comprehensive
                                               development plan
                                              Use a Combination
                                              of Approaches:
                                             i -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

                                          Create New
                                          - Watershed planning
                                          - New supply planning j
                                                                                Use a Combination
                                                                                of Approaches:
                                                                                -e.g., plan new well
                                                                                 sites within water-
                                                                                 shed management

New Wetls
            Expand Delineate New WHPA
            Site New Wells
Examples - for siting new wells and managing contaminant sources
            Manage 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 needs1; 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.

    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

                                                        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.

 Putting it
All Toqether
Road Map to a WHP Program Submittal
   Begin by:
        rj Reviewing EPA Guidance for Wellhead Protection

        D Reviewing each WHP Program Submission Element

        rj Considering "Major Messages" for each WHP Program Element

        rj Reviewing existing Ground-water Conditions in the State

        D Reviewing the applicability of the Range of Options
           for each WHP Element

           Interpreting the applicability of the Case Study Examples
    Assemble your WHP Program
     with the aid of this TAD by:
   Complete your
   WHP Program:
                             Incorporating Program Submission Elements and
                             combining appropriate Options to meet unique
                             State conditions for each WHP Program Element
                            State and Local
                             Agency Duties
                                Chapter II
                          Delineation of WHPAs
                               Chapter 111
                           Source Identification
                                Chapter IV
                        Management Approaches
                                Chapter V
                            Contingency Plan
                                Chapter VI
                               New Wells
                               Chapter VII
                 State WHP Program

  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
              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
              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
              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
              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
              DDD:  (312)353-1490
Erlece Allen
Office of Ground Water
Water Management Division
U.S. EPA Region VI
1445 Ross Avenue
Dallas, TX 75202

FTS: 8-225-6446
DDD:  (214)  655-6446
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
DDD:  (913)236-2970
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
DDD:  (303)293-1543
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
DDD:  (415)947-0831
William  Mullen
Office of Ground Water
Water Management Division
U.S. EPA Region X
1200 6th Avenue
Seattle, WA 98101

FTS: 8-399-1216
DDD: (206)442-1216
            * TIB. SOTEKHMEHT PMNTMQ OFFICE: 1990 - 717-003 - 1302/28033