Ohio: Middletown - Implementation of Multi-

   faceted Wellhead  Protection Plan

   Background

   The City of Middletown in Butler County, Ohio, has a population of 55,000, and its water
   system serves approximately 60,000 customers. Middletown's 13 active production wells
   tap the Great Miami Buried Valley Aquifer at depths ranging from  40 to 120 feet and
   have a total production capacity of approximately 25 million gallons per day (mgd). The
   water treatment plant is currently rated to treat 13.5 million gallons per day, but a
   filtration rate study is almost completed which increases the treatment rate to 20 mgd.
   There are a wide variety of land uses in the area, including residential, light industrial,
   commercial, and heavy industrial. Several large industrial sites are located in the vicinity
   of the city's wellfield, including a steel mill and a paper manufacturer.

   Middletown was prompted to begin its source water protection effort in 1991 by two
   events. The first development was the discovery of volatile organic compounds (VOCs)
   in the city's ground water sources. Second, the Ohio Environmental Protection Agency
   initiated a requirement that water suppliers in vulnerable areas undertake wellhead
   protection to gain approval for system improvements.

   Priority Contamination Threat

   Middletown's priority contamination threat is from volatile organic compounds (VOCs) in the
   town's ground water sources.

   Local Involvement and Developing the Protection  Plan

   In 1993, Middletown was awarded a grant by the U.S. EPA to develop an educational
   public outreach program that addressed source water protection.  Two components of
   the outreach program were created to reach a wide segment of the population more
   effectively. The first component included development of educational materials geared
   for adults and high school students, which were presented at schools, rotary group
   meetings, and other events. The other component targeted development of educational
   resources and activities geared for students at the fourth grade level. These materials
   were provided to elementary schools in the city.

   In addition, the city convened a ground water protection committee to develop a
   management plan for the Middletown Wellhead Protection Program (WHPP). The
   committee included residents of Middletown, city staff, and representatives from the
   Sorg Paper Company and other local businesses. This committee directed the
   development of all elements of the management plan, including recommendations on
   zoning issues and development of a hazardous waste collection program. During the
   initial consideration of a zoning overlay (discussed below), the city held several meetings
   with local companies for input and feedback.

   Management Measures
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   Implementation of management measures to control priority potential contaminant
   sources (PCSs) is a State of Ohio requirement. The city identified one confirmed source
   of contamination that resulted in development of a plume of contamination within the
   one- to five-year time-of-travel (TOT) zone to the wellfield. TOT is the distance from the
   production well through which it would take contamination in the ground water one to five
   years to flow. The city also identified a total of 23 high- priority and 61 medium- priority
   potential sources of contamination in the vicinity of the water supply.

   Middletown's Wellhead Protection Plan, approved  by the Ohio Environmental Protection
   Agency in 1997, includes delineation of a wellfield  protection area, public outreach
   methods, and a management plan for the city's water resources.  The Wellhead
   Protection Plan formed the basis for Middletown's  Source Water Protection Plan
   required under the 1996 amendments to the Safe  Drinking Water Act. The management
   plan laid out several techniques to reduce the risk  to the aquifer by the identified
   potential sources of contamination. These methods included preparation of zoning
   overlays to aid in city planning, annual inspections of PCSs by the health and/or fire
   department, prohibitions to keep trains  and  trucks  away from the wellfield, review of
   building permits, underground storage tank reporting and upgrades,  implementation of a
   hazardous waste collection program, notification signs marking  the five-year TOT, and
   closing of dry wells in locations where storm sewers were available. These activities are
   being implemented gradually.

   Regulations that will apply within a zoning overlay  district are in early stages of
   development, but it is anticipated  that the overlay district will correspond to the wellfield
   protection area delineated by the  WHPP. It is proposed that existing businesses and
   industries within the one-year time-of-travel to the  wellfield will be subject to the
   provisions of the management plan, such as annual or biannual inspection of PCSs and
   compliance with Best Management Practices (BMPs).  It is possible that in the future,
   certain types of businesses may be prohibited from the area within the zoning overlay
   district; however, the city would prefer to work cooperatively with existing and potential
   businesses to reach a mutually acceptable arrangement through the implementation of
   BMPs that would provide first-rate protection to the city's sources of drinking water.

   Contingency Planning

   As part of the management plan,  a contingency plan has been developed for use in the
   event that the city's water supply is threatened or compromised. The plan will be
   activated if certain contaminant concentrations are detected above Preventive Action
   Limits (PALs) in monitoring wells or production wells during routine monitoring.
   Preventive Action Limits are set percentages (determined by the Ohio EPA) of the
   federal Maximum Contaminant Level (MCL) for each contaminant. Wth this system,
   problems can be identified and addressed before contamination reaches unhealthy
   levels. The plan will also be activated in the event  of an emergency within the wellhead
   protection area that threatens water quality. If a PAL is exceeded during routine
   monitoring, the water supplier will retest the water. If the water sample exceeds the PAL
   in the retest, the water supplier will notify the EPA  and begin an investigation to locate
   the source of contamination so that prompt action  can  be taken to avoid a public health
   threat.
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   In the event that there is a hazardous materials spill in the vicinity of the city's wellfield,
   the Middletown Fire Department will respond. The fire department is trained to use
   cleaning methods that will prevent the contamination from being washed into the soil and
   subsequently into the aquifer. For example, within the wellfield protection area, the fire
   department would not use liquids in a cleanup effort.

   Measuring Program Effectiveness

   In addition to the required federal and state regimen of water quality analyses performed
   on production wells, Middletown conducts routine monitoring of ground water quality at
   several monitoring wells twice a year. When the monitoring wells indicate that the plume
   of contamination discovered in the 1990s has migrated,  a new monitoring well will be
   installed to track the change in position. This policy will help monitor the progress in the
   cleanup of the existing plume and identify the future path of the contamination in time for
   preventative measures to be taken. Middletown's closed landfill also has its own network
   of monitoring wells that are sampled on a regular schedule. Sampling results from the
   landfill wells are submitted to the water system to provide additional information on the
   ground water in the city's aquifer.

   For further information, contact:

   David J. Duritsch Jr., PE, CPM
   Engineering & Environmental Services Director
   City of Middletown
   (513)425-7960

   daved@ci.middletown.oh.us
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