Chapter 7

Implementation of the Source Water Assessment and Protection Program

7.1 Timetable For Implementing Source Water Assessment and Protection

The 1996 Safe Drinking Water Act Amendments specify that source water assessments must be completed within two years of EPA approval of the state Source Water Assessment and Protection Program Plan. However, Section 1453(b) of the Safe Drinking Water Act Amendments allows the EPA to grant an extension of up to18 months beyond this two year period. Wyoming is requesting this 18-month extension primarily due to budgetary and personnel constraints. Wyoming's implementation schedule reflects a total of 3.5 years after EPA approval of Wyoming's program to complete the assessments. Table 7.1 shows Wyoming's timetable for developing and implementing the Source Water Assessment and Protection Program.

Table 7.1 The Wyoming Source Water Assessment and Protection Program Schedule

October 1997		First Technical/Citizen's Advisory Committee meeting

December 1998		Draft Source Water Assessment and Protection document 
                        available to the public for review and comment

Public meeting before the Water and Waste Advisory Board for Board 
acceptance of the Source Water Assessment and Protection Program

February 1999		Submit Draft Source Water Assessment and Protection 
                        document to the EPA for approval

October 1999		Begin delineation of groundwater source water assessment
                        areas

Prioritize assessments based on public water system type, population served, 
water source, etc.

April 2000		Begin delineation of surface water source water assessment areas

October 2000		Begin contaminant inventory for all public water systems

October 2001		Begin susceptibility analysis for all public water systems

April 2002		Begin development of assessment reports

October 2002		Begin publicizing assessment report availability

May 2003		Complete all source water assessment related tasks

Delineations and contaminant inventories for public water systems using groundwater may commence prior to EPA approval of the Source Water Assessment and Protection program. Procedures used for these tasks have been previously approved by the EPA in the Wyoming Wellhead Protection Program document.

7.2 Financial Resources Available To Complete Assessments

The 1996 Safe Drinking Water Act Amendments allowed states to set aside up to ten percent of their 1997 Drinking Water State Revolving Fund allotment to develop and implement a Source Water Assessment and Protection program. This set-aside provided a one-time-only funding source for a total of $1,255,880. The cost of developing Wyoming's Source Water Assessment and Protection program and completing the assessments may exceed this amount.

In addition to the Source Water Assessment and Protection set-aside, the 1996 Safe Drinking Water Act Amendments authorized a yearly Wellhead Protection set-aside. The Wellhead Protection set-aside may be a source of funding which could be used to complete source water assessments on groundwater systems. Wellhead Protection set-asides may also be used to assist communities in developing and implementing Source Water Protection Plans.

7.3 Primary Responsible Parties

DEQ has limited personnel available to dedicate to the Source Water Assessment and Protection Program. Therefore, DEQ personnel will focus their efforts on program promotion and administration, contract oversight, and public awareness and outreach duties. Contractors will conduct the majority of tasks needed to complete source water assessments. This includes locating public water system wells and intakes, delineating source water assessment areas, conducting contaminant inventories, determining susceptibility, and producing assessment reports. DEQ personnel will oversee the contracts to ensure that end products are consistent with procedures detailed in the final EPA-approved Source Water Assessment and Protection document. DEQ personnel will require regular reports from contractors to ensure that the required quantity and quality standards and product deadlines are met. DEQ will also expect public water systems to make the public aware of assessment report availability.

7.4 Reporting Program Progress To The EPA

Wyoming will submit an annual Source Water Assessment Program report to the EPA to provide information regarding the progress of the source water assessment effort. An annual reporting schedule will facilitate the combination of the Wellhead Protection and Source Water Assessment and Protection Programs. To indicate progress on the Source Water Assessment and Protection program, the annual report will contain summaries of the following information:

7.5 Encouraging Source Water Protection Plans

The development of source water protection plans is not a mandatory part of Source Water Assessment and Protection Program. However, preventing contamination is key to keeping Wyoming's drinking water supplies safe. Once a drinking water supply becomes contaminated, a community is faced with the difficult and costly task of upgrading treatment facilities or locating an alternative drinking water source.

Source water assessments are the necessary first step for developing source water protection plans. The assessments will provide a sound technical basis for future protection measures, but are not themselves an end product. DEQ considers the protection of drinking water resources and the development of source water protection plans to be the long-term goal of the program. To this end, DEQ will write a set of general guidelines patterned after those included in the Wellhead Protection Program. These guidelines will assist public water systems in developing and implementing source water protection plans. The guidelines will also describe the DEQ Source Water Protection Plan approval process.

DEQ may be able to support protection plan activities by providing financial assistance to public water systems. For instance, low- interest loans may be available through the State Revolving Fund program. These monies may be used for the acquisition of land critical to source water protection, the remediation of contaminant sources, or other protection plan development or implementation activities. DEQ and EPA are currently developing a waiver program to provide public water systems that have developed source water protection plans relief from some monitoring requirements.

DEQ has already been advocating long-term protection of drinking water resources through the Wellhead Protection Program. DEQ encouraged the assembly of planning teams made up of local community members. These planning teams develop strategies to manage potential sources of contamination within the wellhead protection areas. The use of similar teams will be promoted with the Source Water Assessment and Protection program to develop source water protection plans.

As indicated in earlier sections, DEQ recommends the regular review and update of the source water assessments. DEQ also encourages the regular review and update of the source water protection plans. Regular reviews help the local planning team constructively deal with new trends, issues, and activities within the community.

The development of contingency plans as part of protection plans is also encouraged. Contingency planning involves the development and implementation of short- and long-term replacement strategies for supplying safe drinking water to the consumer in the event of contamination or physical disruption of the current supply. Local planning teams should also include emergency response procedures as part of the contingency plan. Emergency response procedures are the steps which would be taken following a release of contaminants into the source water.

Local planning teams may request assistance from DEQ while developing protection plans. DEQ will provide assistance to local planning committees to the extent possible given personnel and budgetary constraints.

7.6 Coordination With Other State Programs

Groundwater Pollution Control Program
The DEQ Groundwater Pollution Control Program has information which will be useful for source water assessments. Aquifer sensitivity has been mapped for the entire state. An ongoing survey determining levels of nitrate and pesticides in groundwater is being conducted for each county. Records of spills or releases; cleanups or corrective actions; and other known groundwater contamination sites are also available. Information gained from the source water assessments may assist the Groundwater Pollution Control Program in the development of state management plans for pesticides or other groundwater contaminants.

Nonpoint Source Pollution Program
Nonpoint source pollution results from diffuse sources of pollution. This is in contrast to point sources, where a pollutant discharge can be traced to a single location, like a pipe or outfall. Examples of nonpoint source pollution include road construction, logging, stormwater runoff, agricultural runoff, and urban lot development. Water moving over or through the ground will carry natural and human- made pollutants into rivers, lakes, wetlands, or groundwater. The most common nonpoint source pollutants are sediment, nitrogen, phosphorous, and bacteria.

Nonpoint source pollution is a much larger and more complex problem than point source pollution. Total pollutant amounts and the number, type, and extent of nonpoint sources are usually greater than point sources. Consequently, developing control strategies to meet water quality standards and support designated uses for water bodies can be difficult.

The Clean Water Act Amendments of 1987 authorized Section 319. Section 319 encourages the development of nonpoint source pollution control strategies and provides funding to implement these strategies. Congress appropriated monies to fund Section 319 in 1990.

The goal of the Wyoming Nonpoint Source Pollution program is to reduce or prevent water pollution from diffuse sources. The program is voluntary and encourages the development of pollution control strategies on the local level. The structure and goals of the Wyoming nonpoint source pollution program and the Source Water Assessment and Protection Program are very similar. A portion of the Section 319 grant monies may even be available to develop source water protection plans when significant nonpoint source pollution issues exist within the source water area.

Wellhead Protection Program
The Wellhead Protection Program is the predecessor to the Source Water Assessment and Protection Program. Wyoming's Wellhead Protection Program was approved by the EPA in 1997. Since the Wellhead Protection Program went into effect, three Wyoming public water systems have completed Wellhead Protection Plans. Approximately 30 public water systems are at various stages in the process. These public water systems will have a head start on the source water assessments.

Where a wellhead protection area has been delineated, DEQ will review the delineated area to ensure conformance with the methods described in Chapter 3 of this document and the Wyoming Wellhead Protection Program document. DEQ will also determine if the public water system uses surface water, or if the EPA has determined the groundwater source to be under the influence of surface water. If there is no surface water component to the water source, the wellhead protection area will become the source water area.

DEQ will review and update the contaminant inventory information for public water systems that have completed the contaminant inventory. Some contaminant inventories may need to be expanded where the original wellhead protection area was changed or increased. Susceptibility analyses will be completed for all groundwater public water systems requesting source water assessments. DEQ will encourage public water systems with approved Wellhead Protection Plans to conduct a susceptibility analysis and incorporate the results into their plans.

DEQ encourages the development of wellhead protection plans for public water systems with completed source water assessments. Wellhead protection plans involve the development of management and contingency plans by a committee of affected groups, entities, or individuals. DEQ will assist in this process as needed if asked to do so by public water system representatives.

It is the intent of DEQ to integrate the Source Water Assessment and Protection and the Wellhead Protection Programs. The goal of both programs is to protect drinking water resources. A protection plan developed for either program will have gone through the same process and completed the same steps. Therefore, Wellhead Protection Plans completed after the approval of the Source Water Assessment and Protection Program will serve as Source Water Protection Plans.

Other State Programs
DEQ manages several regulatory programs such as Underground Injection Control, National Pollutant Discharge Elimination System, Stormwater, and Animal Feeding Operation Programs. These programs issue permits for sources of potential pollutant discharges. Information such as the location of the potential discharge and the nature of the contaminant are collected. Consequently, these state programs will be able to provide valuable information to be used during the contaminant inventory process.

These programs will also use information gained in the source water assessment process. As protection plans are developed, DEQ will determine if new permits would conflict with any approved source water protection plan before they are issued. For example, wastewater construction permits may be reviewed and issued individually within Zone 2, rather than issuing a general construction permit. This will help insure that permits for activities which could endanger the source water will be closely scrutinized. DEQ will not issue permits which are in conflict with state approved source water protection plans.

7.7 Coordination With Other State Agencies

DEQ will also pursue partnerships with other state agencies such as the Department of Transportation, Department of Agriculture, Oil and Gas Conservation Commission, and the State Geologic Survey to complete the source water assessments. These partnerships may include monetary or in-kind service matches or other types of collaboration on data exchange and collection.

7.8 Coordination With Federal Agencies

The Environmental Protection Agency
Coordination with the EPA will be ongoing for the Wyoming Source Water Assessment and Protection Program. The EPA will be able to provide technical support by providing data for the delineation, contaminant inventory, and susceptibility analysis steps of the assessments. The EPA maintains databases, such as the Safe Drinking Water Information System database, that will be important in the contaminant inventory step. The EPA also conducts regular inspections of public water systems. The results of these sanitary surveys will be central to the susceptibility analysis step.

The EPA will also play a role in developing and granting monitoring waivers for the state of Wyoming. Monitoring waivers provide a public water system with the opportunity to decrease the costs associated with sampling and testing for some contaminants. Section 1418(b) of the Safe Drinking Water Act Amendments specifies that states with approved Source Water Assessment and Protection programs may adopt `tailored alternative monitoring requirements.' Because Wyoming does not have primacy for its drinking water program, the alternative monitoring program must be developed in cooperation with the primacy agency, or the EPA. The EPA may allow reductions in monitoring frequency for some contaminants. Monitoring waivers can not be granted for microbial contaminants, disinfection by-products, or corrosion by-products.

The EPA is also involved in the development of the Consumer Confidence Report. Source water assessment results must be published in Consumer Confidence Reports beginning October, 1999. Because Wyoming does not have primacy in the drinking water program, the EPA will be developing the reporting format and ensuring that public water systems report assessment information where it is available.

Other Federal Agencies
In 1998, a Federal Multi-Agency Source Water Agreement was signed by ten federal agencies. The purpose of the agreement was to integrate the source water assessment and protection activities of federal, state, tribal, and local entities. The signatory federal agencies agreed to assist with the source water assessment and protection efforts by providing data, and work with state and local representatives to develop appropriate natural resource or water resource management plans.

7.9 Coordination With Native American Tribes

DEQ maintains working relationships with the Native American Tribes within the state. DEQ offered assistance to the Native American Tribes with developing a drinking water protection program similar to the Source Water Assessment and Protection program. DEQ is also willing to exchange information regarding source water areas and potential sources of contamination for source water areas which are close to or cross over Tribal/Non-Tribal property boundaries.

7.10 Coordination With Neighboring States

DEQ maintains excellent working relationships with its neighboring states. During the program development process, DEQ participated in several conference calls involving Montana, North Dakota, South Dakota, Colorado, and Utah. Each state provided updates on the progress of their Source Water Assessment and Protection Program and discussed the approaches used for each step in the assessment process. Idaho will be contacted individually to discuss and compare source water assessment area delineation and contaminant inventory procedures. DEQ also participated in an interstate coordination meeting for the North and South Platte River Watershed which was organized and hosted by Colorado. DEQ will continue to work with neighboring states to exchange information about source water areas which cross over or are located near the Wyoming border.

Chapters
1 | 2 | 3 | 4 | 5 | 6 | 7
Glossary | Acronyms
Appendices
A | B | C | D
Wyoming's Source Water Assessment Guidance Document Contents