US ENVIRONMENTAL PROTECTION AGENCY
Drinking Water Branch (3WP22)
841 Chestnut Building
Philadelphia, PA 19107
215-566-5779
I -A. A. -A. J
SOURCE WATER ASSESSMENT AND PROTECTION
PROGRAMS:
What's It All About?
What is the quality of my drinking water?
Can I protect the quality of my drinking water?
How can I get involved?
version November 17, 1997
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The Assessment and Protection of
Sources of Drinking Water:
What's It All About?
Description of Key Terms
Key terms are found throughoutthis document in bold italics. Descriptions of the Key terms are included on Page
22
Why Now?
The Safe Drinking Water Act (Act) was reauthorized on August 6, 1996. Prior to 1996, the Act primarily regulated
the treatment and distribution of drinking water from public water systems. With the 1996 reauthorization, the Act
now requires States to develop a source water assessment program (assessment program) and encourages States
to develop a source water protection program (protection program) that includes management measures to prevent
pollution (see Box 1). The US Environmental Protection Agency, or EPA, has been charged with developing the
guidance that will assist States as they develop their assessment program and protection program. These new
programs and the guidelines produced by EPA are described in more detail below. To receive a full copy of the
State Source Water Assessment and Protection Programs Final Guidance (Guidance), please call the Safe Drinking
Water Hotline at 1-800-426-4791 or access EPA's home page at www.epa.gov/ogwdw/swp/swappg.html
Purpose of this document
This document has several objectives'
1) At your home, school, or work, you probably drink water that comes from a public water system. This
document will help you understand the type of information that will be available to you once the assessment
program is completed and how you can use the information to assist your water supplier in protecting your
drinking water source.
2) You may have been asked to serve on your State's advisory committee or you may attend a State public
workshop on the assessment program If so, this document gives you information on EPA's assessment
requirements so that you can evaluate your State's assessment program. See advisory committee on
page 6 .
3) Finally, you may own a business or conduct an activity within the source water protection area that may
be considered a potential source of contaminationlhat could contribute contaminantslo the drinking water.
If so, you may be asked by the community or the public water system to reduce the chance that those
contaminants will reach the drinking water source. This document will help you understand what activities
could be listed as a significant potential contaminant source and provides several contacts to obtain more
information on reducing the threat of contamination (see page 13).
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Box 1. Required vs. Encouraged
Required - The Safe Drinking Water Act requires every State with
regulatory authority for drinking water Public Water Systems to
develop an assessment program. In addition, the Safe Drinking Water
Act lists elements that States must include in their assessment
program submittal. For example, the Safe Drinking Water Act requires
States to form advisory committees to assist in the development of the
assessment program. Without these elements, the EPA cannot
approve the State program.
Encouraged - While the Safe Drinking Water Act does not explicitly
mandate that each State develop a source water protection program,
the EPA believes that Congress intended for States to actively protect
drinking water sources from contamination. A protection program is
strongly encouraged to meet this intent Minimally, the State must
describe in the submittal if a State protection program will be
developed and how the program will link with existing protection
efforts
What is a Source Water Assessment Program?
Every State (if directly responsible for regulating public water suppliers) must develop and implementan assessment
program The purpose of the assessment program, as defined by Congress, is for "the protection and benefit of
public water systems " As interpreted by EPA, this means that States, or the State's delegated entity, must develop
an assessment program that will provide enough information about your drinking water source so that you, your
community, and your public water system can take action to prevent contamination of your drinking water source.
The assessment program requires States to take an initial 'snapshot' or assessment of all ground water and
surface water drinking water sources and identify activities in the source water protection area that could potentially
degrade the water quality. Each State must conduct the following activities for the assessment program:
I. Delineation of the Source Water Protection Area - Basically, defining the land area surrounding a surface
or ground water drinking water source through which contaminants could move and reach the well or
intake.
n. Contaminant Inventory - Locating the land uses and industries within the source water protection area that
could add contaminants to the drinking water source and degrade the quality.
iii. Susceptibility Analysis - Determining the likelihood that a contaminant will reach the intake or drinking water
well in an amount that will impact the public water system's ability to deliver safe drinking water.
iv. Public Access - Insuring that all information collected for the assessment program is available to the public.
Maps must be developed (showing the delineated areas, the location of the existing and potential sources
of contamination, and the results of the susceptibility analysis) and made available to the public.
v. Public Participation - Insuring that the public has an opportunity to provide input into the assessment and
protection programs as they are developed. States must form advisory committees and hold public
workshops around the State to gather input on the assessment and protection programs.
These five elements are required to be part of the State's assessment program However, States have some
discretion in determining how each of these elements are 'fleshed out'. Table 1 on page 15 lists the components
that States need to include (or an equivalent alternative) in the assessment program submittal.
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The Source Water Protection Program (SWPP)
State Source Water Protection Programs
In the State's assessment program submittal to EPA, States will need to describe whether they will be developing
a protection program and if they will be undertaking protection activities such as those described below. States are
also asked to describe how the information collected through the assessment program will be used to further
pollution prevention efforts. While the assessment program is mandatory, States are not required to develop their
own protection program. *
A State source water protection program could provide guidelines or requirements to local communities to assist in
protecting their drinking water. Local protection efforts could be promoted by having State representatives speak
at board or community meetings, by providing educational materials to assist community members, and/or by
providing technical assistance. Also, a State protection program could provide financial resources in the form of
grants or loans to communities to assist in protection efforts. These are just a few examples.
* Please note. Since 1986, States are required to have a wellhead protection program to protect ground water sources of drinking water. The
result is that States must have a program that protects ground water sources of dnnking water but until now they have not been required to have
a program that protects surface water sources of drinking water The Source Water Protection Program will protect all sources of dnnking water.
Local Source Water Protection Programs Generally, while a State may provide guidance and assistance, the active
protection of drinking water is the responsibility of the people who drink the water working in coordination with their
public water supplier Local protection efforts are the key to protecting drinking water supplies. Several examples
of local efforts that local community members have undertaken to protect drinking water are described on page 10.
Don't Reinvent the Wheel
Depending on the State, the activities required for an assessment program - delineations, contaminant inventories,
susceptibility analyses - may have already been completed. If so, States may use this existing information. Data
that is needed in order to conduct assessment activities, may be available from many different federal, state, and
local agencies. In such cases, the assessment program can serve as an opportunity for the State to gather this
existing data into one place in order to map the information and make it available to the public.
Advisory Committees
The State must form at least one advisory committee to assist the State in developing its assessment program. The
committee(s) must have members that can evaluate the technical and the policy portions of the assessment program
as described below:
technical members - to provide input on the State's technical feasibility and effectiveness of the assessment
program and protection program.
• citizen members - to evaluate the assessment program and protection program for appropriateness and
desirability.
In addition, States must try to obtain representation on the committees from a wide cross section of stakeholders.
If you are serving on a committee, your job is to evaluate the State's draft assessment program to determine if the
program will
result in "the protection and benefit of public water systems" and whether enough information will be provided for
each source water protection area so that local community members and water supply utilities can develop and
undertake protection efforts.
The time and financial resources available to each State to conduct the assessment program must be taken into
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consideration Short time frames and limited financing may require States to prioritize the areas that will receive
more in-depth work. For example, States may require a different level of effort for the largest public water systems,
serving the most people, compared to the smallest public water systems. As a committee member, you may be
asked to evaluate the priorities that the State has proposed (see Box 2).
I n the assessment program submittal to EPA, States will need to describe the committee(s) advice regarding the Key
Issue Questions (see Boxes 3 - 8, page 17) The State will also need to include a responsiveness summary
showing how public comments were used in developing the assessment program.
Box 2. Factors to Consider When Prioritizing
These factors may be considered by States when prioritizing which
types of systems or areas of the State will receive more detailed
assessments than others.
Type and extent of threats - Some areas may be more vulnerable to
contamination than others.
Type and Size of PWS - Some systems, based on type or size, may
require more detailed assessments than others. For example, a State
may decide that public water systems (PWSs) that serve a large
number of people may need more detailed assessments, or, that
smaller PWSs, with fewer resources and, potentially more risk, may
need more detailed assessments.
Objectives - Assessments could be varied according to the program
objectives. For example, areas where future protection efforts will be
undertaken may require more detailed assessments.
Time Frame
States have a limited amount of time to develop and implement the assessment program, (see Figure 1) Program
submittals are due to EPA by February 1999. All assessment program activities must then be completed within 3/4
years. As discussed previously, given the short time frames, States may need to vary the level of effort that will be
undertaken.
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Figure 1 - Time Frame for Source Water Protection Program
EPA Final
Guidance
available
8/6/97
SWAP by
February 1999
States submit
review
disapprove/
resubmit
approve
~
SWAP
implementation
over next 3 1/2 years
- complete by
May 2003
Ongoing SW protection
efforts by local
community
£
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State Revolving Loan Fund
The Drinking Water State Revolving Loan Fund or SRF is an exciting addition to the SDWA. This new fund is
available to each State with primary responsibility for regulating the public water systems. Federal funding is
available every year between the years 1997 - 2003, as long as a 20% match is provided by the State. From this
combined State and Federal fund, a State can provide low interest loans to public water systems to improve the
treatmentand distribution of drinking water. In addition, several 'set-asides' were added whereby a State can take
a percentage of the fund for other activities, including source water assessment and protection.
Source water funding is available to States for the
assessment program
source water protection/source water petition program
purchase of land or conservation easements
wellhead protection program
protection program administration or technical assistance
Benefits of SWAP and SWPP
Two benefits immediately stand out from conducting assessment and protection programs. The first benefit is a
more secure and safe drinking water supply for yourself and for future generations especially if the information
collected during the assessment program is used to protect the drinking water source.
The second benefit is the opportunity to reduce some of the costs associated with treating and distributing drinking
water If the results of the assessment program indicate that the drinking water source is adequately protected from
contamination, the public water supplier and the consumer may be able to save money by having to collect and
analyze fewer water quality samples, in addition to obtaining other types of regulatory relief.
The Protection of Drinking Water: Local Examples
New Castle County, Delaware
The Water Resources Agency for New Castle County originated with the establishment of a Water and Sewer
Management Office by New Castle County in the late 1960s. In addition to this Water and Sewer Office, the City
of Newark, the City of Wilmington, and New Castle County with support from the US EPA formed a Water Quality
Management Program in 1974. The Agency is governed by a Policy Board which meets bimonthly and directs all
program activities. There are also two committees which help in the decision making process The Water Resources
Advisory Committee is comprised of citizens of varying interests with backgrounds and expertise that offers public
input to Agency's operations. The other committee is the Water Resources Technical Coordinating Committee which
provides for technical coordination and cooperation. It is includes representatives of water utilities and local, State,
and regional organizations directly or indirectly involved in water resources management.
Because the NCC has had its share of Superfund sites and closed wells due to contamination, County leaders knew
that ground water needed to be protected. When the Delaware Geological Survey (DGS) completed mapping
Delaware's ground water recharge areas, NCC utilized this information to determine which sensitive areas required
the greatest protection. Through negotiations with developers regarding typical land-use activities, ordinances were
developed to provide WHP for the future protection of public drinking water supplies. These Water Resource
Protection Area Overlay Zone Ordinances did not occur at the expense of economic growth but through land
management measures that protect ground water quality and ensure compatible uses of the water supply. The result
is that through WHP there is further protection of the drinking and ground water resources of about 300,000 citizens,
and ground water resources of about 300,000 citizens.
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City of Williamstown, West Virginia
In 1991 Williamstown was selected as the first community in West Virginia to institute a WHP program. Chosen
because Williamstown has overlapping jurisdiction of state regulatory agencies concerned with groundwater, an EPA
grant supported the WHP efforts of the Williamstown Planning Team. A WHPA map was produced and potential
contamination sources were identified. Many local citizens supported the project. The Wlliamstown Women's Club
surveyed businesses and residences within the WHPAs to determine what activities were taking place that could
potentially impact the excellent ground water quality. The surveys found several underground storage tanks (USTs)
and discovered that chemical lawn treatments had been applied throughout the delineated area. The West Virginia
Division of Environmental Protection removed contaminated soils from a leaking UST and the West Virginia
Department of Agriculture worked with chemical applicators to ensure that best management practices (BMPs) were
utilized. Although a river runs through the city, Williamstown is dependent upon ground water. Local WHP
ordinances that restrict activities which potentially could contaminate ground water will benefit 3,095 residents.
Town of Fincastle, Virginia
The Town of Fincastle, in cooperation with the County of Botetourt, sought to protect the town's water supply by
developing an inventory of possible sources of contamination and delineating a WHPA for each of the town's wells.
Existing regulationson land-use were evaluated and recommendations were developed to reduce potential risks to
the water supply. The potential impacts of transportation related spills on US 220, which passes through the
WHPAs, were considered during the developmentof land-use management measures. Local involvementand public
education were a part of the Town's ground water protection effort. The project was completed under budget,
requiring less than the $10,000 that had been Federally allocated. This project is an example of a "low-tech," low
cost, no-nonsense approach that can be effective in getting a quality WHP program off of the ground.
Mars Area School District, Pennsylvania
The idea of the Mars Project was to create a self-sustaining wellhead protection program for PA schools that have
their own water supply. The Program would be student driven with both curricular and extra-curricular aspects.
Water industry experts from the local community would donate their time to train and assist students in the various
aspects of hydrology, water monitoring, public education, and water resource management. The initial year would
consist of designing the actual wellhead protection plan. Each subsequentyearwould havea specific goal to further
advance the overall objective of protection of the school's wells.
A group of high school student volunteers assembled and divided into 4 main groups, based on their field of interest.
The 4 groups were: (1) the wellhead protection group, (2) the public relations group, (3) the elementary training
group, and (4) the middle school training group. The WHPP group worked with the hydrogeologists, PA Rural Water
Association and PA DEP to assess and map the various potential contamination sources around the school's wells.
They also assisted in the developmentof the written plan and presented the plan to the school board, local officials
and general public. The public relations group was responsible for press releases, developing and distributing 6,500
public information pamphlets, and developing a short video clip for the students. The elementary and middle school
groups were responsible for developing and implementing lessons for all the 3rd grade classes and 7th and 8th
grade science club, respectively. The purpose of this was not only to educate the younger students, but also to
create a "pool" of students that would later become part of the project when they reached high school. The initial
year of the project was funded in part by a grant for the EPA Region III. Callery Chemical Co. (Mine Safety
Appliance) provided copies of the public information pamphlet. Moody & Associates of Meadville, PA and Acer
Engineering of Lancaster, PA provided technical assistance and training on the wellhead protection plan.
For More Information
USEPA Source Water Contacts
Drinking Water Branch (3WP22)
841 Chestnut Building
Philadelphia, PA 19107
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Contacts
Teresa Halverson
Dale Long
Barbara Smith
215-566-5823
215-566-5779
215-566-5786
State Source Water Contacts
Delaware
John Barndt
Ground Water Section
Delaware Department of Natural Resources and Environmental Control
Division of Water Resources
PO Box 1401
Dover, DE 19903
phone: 302-739-4793
fax: 302-739-2296
email: jbarndt@dnrec.state.de us
Maryland
John Grace
Water Supply Program
Water Management Administration
2500 Broening Highway
Baltimore, MD 21224
phone: 410-631-4167
fax: 410-631-3157
Pennsylvania
Joseph Lee
Division of Water Supplies, 11th Floor
PA Department of Environmental Resources
400 Market Street
PO Box 8467
Harrisburg, PA 17105-8467
phone: 717-772-4018
email: lee.joseph@a1.dep state.pa.us
Virginia
Jerry Peakes
Department of Water Supply Engineering
Virginia Department of Health
1500 East Main Street
PO Box 2448
Richmond, VA 23218
phone: 804-371-2882
fax: 804-786-5567
email gpeaks@vdh.state.va us
West Virginia
Paul Daniels
West Virginia Department of Health
Environmental Engineering Division
815 Quarrier Street
Charleston, WV 25301
phone: 304-558-2981
fax- 304-558-0691
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For Written Information
The following is a brief list of sources from which more information can be obtained.
Office of Ground Water and Drinking Water Publications, EPA 810-B-96-001, June 1996, Call NCEPI @ 513-891-6561
Pollution Prevention Directory,
for a copy call 202-260-1023
USEPA Small Business Assistance
1-800-368-5888
National Resource, Conservation and Recovery Act Hotline
1-800-424-9346
National Agriculture Compliance Assistance Center
913-551-7207
Table 1. Brief Summary of the Requirements to States on the SWAP
To obtains free copy of the entire USEPA State Source Water Assessment and Protection Programs Guidance, please call the
Safe Drinking Water Hotline @ 1-800-426-4791.
Each State is statutorilv
reauired to:
Each State needs to:
Public Participation
• Convene a technical advisory
committee and a citizens
advisory committee (or one
committee)
• Ensure broad representation
on its advisory group(s)
• Provide adequate opportunity
to various groups to
participate on the advisory
committee(s)
• Describe the committee's
advice regarding program
development questions
• Conduct public hearings
workshops, or focus
groups, etc.
• Provide opportunities for
general public involvement,
by various means
• Provide a summary of how
the State responded to all
substantive public comments
SWAP Approach
• Conduct assessment
programs for the
"protection and benefit of
PWSs"
• Submit assessment
programs to the
appropriate Regional
Administrator by February
1999 (within 18 months
after EPA publishes final
guidance)
• Describe the approach the
State will take to implement
a assessment program
• Describe whether the State
plans to implement a
protection program
• Describe how a
assessment program will
link with existing protection
program
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• Delineate boundaries of
• For ground water systems,
the assessment areas
use delineation methods in
using all reasonably
accordance with EPA
available hydrogeologic
accepted guidelines for
and other information
WHP
• Include recharge areas that
are not adjacent to or
surrounding the well
• For surface water, delineate
the entire watershed area
upstream of any intakes or
diversion structures, up to
the State's borders
• Conduct a contamination
• Indicate what "contaminants
source inventory
of concern" its assessment
program will address
• Conduct an inventory for
• Include a clear description
raw water contaminants
of the sources of
regulated under SDWA,
contamination (or
and Cryptosporidium
categories of sources)
• Choose an approach for
determining which types of
potential sources are
significant
• Indicate what types of
potential sources of the
contaminants of concern will
be considered "significant"
• Conduct a susceptibility
• Define "susceptibility
determination
determination"
• Describe how the results of
susceptibility determination
will contribute to the
protection and benefit of the
PWSs
Conduct assessment
programs for the
"protection and benefit of
PWSs"
Describe how it will
delineate source water
protection areas, conduct
and inventory of
contamination sources, and
conduct a susceptibility
determination for that part of
a boundary river, the Great
Lakes, or multi-State rivers
that are within the State's
borders
Exert the maximum
practical effort to ensure
interstate coordination for
assessments
Making the Results of Assessments Available to the Public
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• Ensure the results of the
assessments are made
available to the public in
an understandable manner
• Make the results of the
assessments available in an
expeditious manner
• Make available all the
information collected during
each assessment, when
requested
• Create maps which include
the delineated area and
sources of contamination
described in the inventory
Implementing the Chosen SWAP
• Complete the assessments
• Describe the timetable for
in the approved timetable
implementing and
completing the
assessments within the
State
• Indicate whether the State
wants an extension (of up to
18 months)
Key Issue Questions for Advisory Committees
These questions, taken from the Guidance, have been included to assist the advisory committee members in
evaluating the State's proposed assessment program. States must describe in their submittal to EPA the
committee's advice developed from the key issue questions.
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Box 3
Public Participation:
Key Issues for Advisory Committee(s)
1. Should the State do more to provide adequate opportunity for
stakeholder groups to participate in development of the program?
If so, how?
2 Should the State do more to receive recommendations from both
technical and citizen's perspectives?
3. What should the State do for ongoing public participation in
implementing assessments once the State's assessment
program is approved7
Box 4
State's Strategic Approach:
Key Issues for Advisory Committee(s)
1 Has the State done an initial review of all data sources
available and determined the scope of the need for
additional information7
2. What level of exactness/detail should be achieved by each
assessment to be considered "complete?"
3. Should the level of assessment provide for the protection
and/or benefit of the public water supply(s)?
4. What should be the basis for differential levels of
assessments to be completed for different public water
supplies or categories of public water supplies9 System type
or size7 Preliminary information about the existence of
threats? Other?
5 How will the State assessment program be coordinated
among various environmental and other State programs
(e.g., PWSS, water quality, water resources, agriculture, land
use, information management, geologic)?
6 How would the State's assessment program lead to State
watershed approaches and link to wellhead and other
protection programs?
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Box 5
Delineation, Source Inventory, and Susceptibility: Key Questions
for the Advisory Committee(s)
1. What delineation method and criteria will be used for
systems, using ground waters? Where shall recharge areas
not be included and why?
2. What contaminants that are not currently regulated by EPA
should be part of the State's assessment program program?
3. Should the State segment source water protection areas for
more focused source inventories? What should be the basis
for such segmentation?
4. How should the State define and identify significant potential
contamination sources and how should the State undertake
their inventory within source water protection areas?
5. How will the results of the susceptibility analysis be
characterized?
Box 6
Boundary Waters, Multi-State Rivers, and the Great Lakes:
Key Issues for Advisory Committee(s)
1. What agreement should the State maintain or initiate with
other States, tribes, or nations to gain more complete and
consistent source water assessments?
2. What contingency plans should be pursued?
3. What coordination/facilitation activities should the State
request of EPA?
4. Are compatible and complimentary assessments being done
in watersheds shared with other States and countries?
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Box 7
Making the Results of Assessments Available to the Public: Key
Issues for Advisory Committee(s)
1.
What should be included in the results of the assessments,
what should be the format of an understandable report on
results, and when should the results be made available?
2.
How and when should the State make available all the
information collected during each assessment when
someone requests it?
3.
. What type of maps should be developed to display the
results of the assessments9
4
How and when should the State make public all information
collected during each assessment for a PWS(s)?
5.
How should the State or delegated entities provide wide
notification of the availability of the results and other
information collected?
Box 8
State Program Implementation:
Key Issues for Advisory Committee(s)
1.
What should be the timetable for State assessment program
program implementation?
2.
How much should the State spend on assessment program
program development and implementation, and should the
resources come from the DWSRF and/or other resources?
3.
Should the State delegate aspects of the assessments? If
so, to whom9 Should funding be provided to delegated
entities?
4.
How should State agencies coordinate with each other and
with other State, federal, and local stakeholders when
implementing assessment programs7
5.
How and what should the State report to EPA regarding
assessment program implementation?
6.
When and how should the State update assessments?
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Description of Key Terms
Contaminants - Listed in the Guidance as "contaminants of concern" they include all the raw water (before
treatment) contaminants regulated under the Safe Drinking Water Act and the protozoa Cryptosporidium.
Contaminant sources - These are the human activities that have contaminants that could degrade water quality
associated with them such as waste water treatment plants, urban runoff, dry cleaners, underground storage tanks,
agriculture, etc.
Delegated entity - States may require or allow other entities - public water systems, local agencies, etc. - to
perform some or all of the assessment activities, as State law allows.
Drinking water source - The ground water or surface water that is used for drinking water by a public water system.
Note: The assessment program does not address individual or private wells.
Ground water - Generally, water found under the land surface.
Intake - The point at which a public water system withdraws water from a surface water body. After water is
withdrawn, it is typically treated then enters the distribution system where it goes to homes, etc for consumption.
Significant potential contaminantsource- From the long list of contaminantsources, States need to decide which
are potentially significant and could degrade the quality of the source water. If significant, it should be inventoried.
To help decide if significant or not, two methods are allowed: (1) consider all land uses and businesses, which store,
use, or produce a contaminant of concern, as significant; or (2) for large source water areas, segment the area.
Some contaminants may be of greater concern in the segments closest to where the water is withdrawn (prior to
treatment) then those segments located farther away. For example, a septic system (nitrates, bacteria) may be
important close to a well; however, located farther away, it may not affect the quality of the water withdrawn from the
well and may not need to be inventoried.
Public water system - A system, publicly or privately owned, that supplies drinking water to at least 25 individuals
or has 15 service connections.
Source water protection area - The land area surrounding a surface or ground water drinking water source through
which contaminants could move and reach the well or intake. The contaminant source inventory, the susceptibility
analysis, and any protection activities are focused on the source water protection area.
Stakeholders - Anyone that may be affected by this assessment program or drinks water supplied by a public water
system. Included are the general public, industry, health agencies, vulnerable populations (very old, very young,
people with HIV/AIDS), agriculture, water utilities, and environmental groups among others.
Surface water - Generally, the water found on the surface of the land - reservoirs, lakes, rivers, streams (and the
water associated with them).
Watershed - The land or surface area from which water drains to a lake, river, stream, or ocean. A line can be
drawn around this area within which the assessment activities would be conducted. For the assessment program,
States must delineate the entire watershed, upstream from the intake, to the State boundary. See Figure 2.
Wellhead Protection Area - The land area around a well, through which water, and contaminants, may move to the
drinking water well. A line can be drawn around this area, within which the contaminant source inventory,
susceptibility analysis, and protection activities would be conducted. See Figure 3.
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Figure 2--Watershed Protection Area
/
/ Reddenfla)
/ -r#1 • ¦'
SSs
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Figure 3-Wellhead Protection Area
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