Subsection 1428(a)(4) of the SDWA requires each state to:
The underlying objective of WHP is to prevent contamination of the drinking water supply. Therefore, management of contaminant sources is an essential component of WHP. Communities have many tools at their disposal for the management of potential contamination sources. These may include:
Appendix I ("Summary of Wellhead Protection Tools") illustrates a variety of both regulatory and non-regulatory source management approaches, including: their applicability to WHP; legal constraints; and administrative considerations.
Each WHP plan must describe the techniques that will be implemented employed to manage and minimize the threats posed by the contamination sources identified in the Source Inventory (see Section III and Appendix J).
Management Strategies -- Selection Concerns
As part of the WHP plan development process, a host of concerns may arise regarding the selection of the most appropriate management strategies. Thorough consideration of all potential concerns should be given to all prospective management approaches prior to selection to ensure that only the most suitable management controls are implemented. The WHP Management Committee may propose to manage WHPAs in a variety of ways. Factors such as the size of the WHPA, the relative risk posed by the potential and known contaminant sources within the WHPA, the characteristics of the chemicals used, and the source management techniques already in place should be considered when evaluating source management approaches. The WHP Management Committee should address the following questions when selecting management strategies:
Often a mix of management techniques is used to customize WHP management strategies to best fit the unique needs of a particular community's PWS. Also, the management techniques may vary, based upon the WHP Zone under consideration. For example, a PWS might choose to use an educational program to reduce risk in Zone 3, a zoning system to manage Zone 2, and a land purchasing system or zoning ordinances to immediately reduce threats in Zone 1.
As mentioned in Section III, Groundwater Sensitivity maps are very useful in helping to identify those parts of Wellhead Protection Areas where the aquifer is most susceptible, or 'sensitive', to a contaminant release at, or near, the ground's surface. Logically, potential and known contaminant sources within these areas might warrant different management approaches than those applied to areas where the aquifer is not as 'sensitive'.
Many communities find that political boundaries are easier to manage than areas delineated as WHPAs. Consequently, communities are encouraged to establish political boundaries, or WHP 'overlay' districts that coincide with WHPA boundaries. Since many source management strategies are difficult, if not impossible, for communities to implement outside of their own jurisdiction, it is recommended that communities coordinate management plans and activities with county governments to work collectively under a joint management agreement.
"Wellhead Protection Programs: Tools for Local Governments" (EPA 440/6-89-002) should be consulted to more thoroughly assess the ramifications of individual management strategies. This technical assistance document fully describes each management strategy and discusses the limitations, constraints, and legal issues associated with each approach. Examples of the ways in which some communities are using management controls to protect groundwater are highlighted in the text.
The potential and known contaminant source priority ranking established upon completion of the Source Inventory list (see Section III) must be used to assess the reasonable perceived relative degree of risk posed by particular contaminant sources.
Once the relative degree of risk of a contaminant source is established more effective management strategies can be developed, focusing on those sources with the greatest risk, or potential risk, to the drinking water supply. Under this approach, where the level of management is commensurate with perceived risk to the groundwater resource, the highest degree of protection (through management strategies) should be afforded to nearby Zone 1, while Zone 3, farther away from the wellhead, may have a lower degree of management applied. Generally speaking, local regulatory management strategies afford a greater degree of protection, as compared to non-regulatory methods.
'Buffer Zones' for recharge areas lying outside of Zones 1,2 and 3:
The buffer zone is an area up gradient of Zone 3. It can extend outward to include the entire ZOC or may focus on selected areas of concern such as recharge areas or locations where the aquifer may be exposed at, or near, the surface. A buffer zone should be used to provide an area of added protection to the WHPA, particularly to WHPAs for wells and springs developing groundwater from karst, fractured or faulted aquifers. This zone affords important protection to recharge areas beyond the WHPA boundaries, and can provide information on potential and known contaminant sources outside Zone 3 which have released, or have the potential for releasing contaminants into the wellhead protection area.
Analysis may show the need for contingency plans to respond to uncontrolled surface discharges that may travel overland to enter a stream located in or adjacent to the WHPA. It may also identify other non-contiguous critical aquifer recharge areas requiring some from of protection. Table IV-1 illustrates one approach for managing potential contamination sources that may be employed by local governments to protect their drinking water supplies. In this illustration, the stringency, or degree, of management is based upon the perceived risk that a contaminant source might present due to its distance from, or proximity to, the wellhead. In this example, higher rankings illustrate management approaches that typically offer the highest degrees of protection to the wellhead and/or drinking water aquifer and should be considered for areas closest to the well (i.e. Zone 1). Conversely, it is generally reasonable to expect that management approaches can become less stringent as the distance from source(s) to the well increases.
Rank | Zone 1 - Accident Prevention Zone |
Zone 2 - Attenuation Zone |
Zone 3 - Remedial Action Zone |
Recharge Area |
1 | Direct Ownership | Municipal Ordinance/Land Use Agreement |
Municipal Ordinance/Land Use Agreement |
Municipal Ordinance/Land Use Agreement |
2 | Source Prohibition | Source Prohibition | Inspections | Site Plan Review |
3 | Zoning | Zoning | Site Plan Review | Water Quality Monitoring |
4 | Operating and Design Standards |
Operating and Design Standards |
Best Management Practices |
Best Management Practices |
5 | Land Use Agreements | Memoranda of Understanding |
Memoranda of Understanding |
Memoranda of Understanding |
6 | Easements | Public Education | Public Education | Public Education |
Groundwater Monitoring in Wellhead Protection Areas (WHPAs):
Groundwater monitoring in WHPAs is a highly recommended management approach. A good groundwater monitoring program can provide an 'early warning' prior to the arrival of contaminated groundwater at the well. The monitoring wells should be located such that an early warning would provide enough lead time to either intercept the in-coming contamination before it can reach the well, or arrange for an alternate drinking water supply or treatment. The groundwater monitoring program should include periodic monitoring of groundwater for suspected or known contaminants that may be finding their way toward a drinking water supply well.
Groundwater monitoring would also serve as a way to measure the effectiveness of source management strategies. For example, the effectiveness of Best Management Practices (BMP's) implemented for fertilizer and/or pesticide applications to agricultural land could be evaluated with a groundwater monitoring program. Groundwater monitoring is also recommended when WHPA's lie within residential areas to evaluate the effects, if any, on the drinking water aquifer from septic systems, pesticide and fertilizer applications, etc.
To reduce costs, it may be possible to collect groundwater samples from existing wells (i.e., domestic, irrigation, etc.) although monitoring wells also might be needed where there is a need for monitoring but no existing wells are present. The WHP plan may consider the need to have potential contaminant sources that are susceptible to leaks or spills of contaminants conduct self monitoring of groundwater quality.
Developing and Documenting Existing and Proposed Management Strategies:
The 'Potential and Known Source, Hazards, Controls, Assessment, and Management Form' (Form IV-1: Appendix J) is provided as a worksheet to list existing controls and possible management strategies to ensure that potential and known sources identified within the WHPA are adequately managed. Using this Form, the WHP Management Committee should identify existing controls, assess the adequacy of existing controls, and describe management strategies and implementation dates for individual potential and known sources within the WHPA.
A completed 'Potential and Known Source, Hazards, Controls, Assessment, and Management Form' (Form IV-1: Appendix J) must be submitted for each potential and known contaminant source identified on the 'Source Inventory List' (see Section III).
Identification of Existing Local, State and Federal Source Management Authorities:
Table III-2 in the preceding section of this document lists many local, state and federal agencies that have existing authorities for management of certain types of contaminant sources and provides contact telephone numbers for these agencies. State agency responsibilities or authorities for managing specific sources (potential and known) of contamination are further described in Section III ('State Sources of Information'). When appropriate, these agencies may be cited as a component of the PWS's management strategy for a potential and known contamination source.
Federal and state agencies that manage public lands or regulate potential and known contaminant sources within WHPAs will coordinate with local governments to assure adequate management. Federal lands in Wyoming are managed by the U.S. Department of Agriculture, Forest Service; the U.S. Department of Interior, Bureau of Land Management, Bureau of Reclamation and Park Service. The recharge region of many groundwater resources developed as community drinking water supplies for many Wyoming communities often lie in areas under federal agency jurisdiction.
Local Authority to Protect Drinking Water Supplies:
Activities that are undertaken by counties and municipalities to protect drinking water sources or manage WHPAs are grounded in existing state law. Specifically, state statutes listed on Table IV-3 provide authority to counties and municipalities to regulate certain activities for public health, safety and general welfare.
1st Class Cities (2) | Incorporated Towns & Cities (Not 1st Class) | Counties | Water Districts | |
Zoning | 15-1-601 | 15-1-601 | 18-5-105 | |
Regulations Ordinances or Rules |
15-1-103(a)(xxxi) 15-1-103(a)(xli) 15-3-202 15-7-101(a)(ii) 15-7-704 15-7-707(a) 35-11-304 |
15-1-103(a)(xxxi) 15-1-103(a)(xli)
15-7-101(a)(ii) |
18-2-101(a)(vi) 18-5-201 35-11-304 |
35-11-304 |
Inter- Governmental Agreement |
16-1-105 | 16-1-105 | 16-1-105 18-2-101(a)(iv) |
16-1-105 41-10-113(a)(vi) 41-10-113(a)(xi) |
Land Acquisition |
15-1-103(a)(iii) 15-7-101(a)(ii) |
15-1-103(a)(iii) 15-7-101(a)(ii) |
18-2-101(a)(ii) | 41-10-113(a)(xiii) |
To avoid possible confusion, a local WHP plan should identify the agency, board, or government entity with authority and jurisdiction over management strategies involving rules or ordinances. A guideline for developing a drinking water protection (i.e WHP) ordinance is provided in Appendix L.
Copies of any ordinances, memoranda of understanding, permits, and land use agreements and similar source management controls should be appended to the WHP plan.
Sections
1 |
2 |
3 |
4 |
5 |
6 |
7 |
8
Appendices
A |
B |
C |
D |
E |
F |
G |
H |
I |
J |
K |
L |
M |
N |
O |
P |
Q |
R
Wellhead Protection Program Guidance Document Contents
Wyoming Department of Environmental Quality