Guidance for Project Activities Involved with Delineation of Wellhead-Protection Areas and Aquifer Vulnerability
OFFICE OF GROUND WATER TECHNICAL MEMORANDUM NO. 00.01
Subject: Guidance for Project Activities Involved with Delineation
of Wellhead-Protection Areas and Aquifer Vulnerability
The purpose of this memorandum is to review appropriate limits of
participation by the U.S. Geological Survey (USGS) in projects that
support source-water assessments, which include delineation of protection
zones around public-supply wells and delineation of aquifer vulnerability.
This memorandum updates guidance provided in Water Resources Division
Memorandum 89.26, which initially established guidance for these types of
projects.
On occasion, agencies with regulatory responsibilities request USGS
assistance in the determination of wellhead-protection areas,
determination of recharge areas, estimation of areas vulnerable to
ground-water contamination, and other similar studies. The work and
products from these studies may be controversial. They have the potential
for being perceived as regulatory and may be viewed as being in
competition with the private sector. The intent of this memorandum is to
clarify the appropriate role of the USGS in undertaking these types of
studies, emphasizing the importance of scientific standards and use of
documented methodologies. This memorandum, however, should not be
construed as any sort of discouragement of USGS involvement in providing
the scientific information needed for ground-water protection programs.
Statutes such as the Safe Drinking Water Act highlight the Nation's
intention to protect the quality of ground-water resources. As the
Nation's principal earth-science agency, it is imperative that the USGS
provides the scientific information needed for such protection programs as
personnel and resources allow.
The mission of the USGS is to provide geologic, biologic, topographic, and
hydrologic information that contributes to the wise management of the
Nation's natural resources and that promotes the safety and well-being of
the public. Thus, providing hydrologic information, including the results
of analytical and numerical modeling applications, to regulatory agencies
charged with responsibilities for wellhead and ground-water protection is
a proper function of USGS. There is a clear distinction, however, between
studies to determine sources of water to wells and aquifers and studies to
determine wellhead protection or source-water protection areas.
Determination of sources of water to wells, the delineation of the
associated areas contributing recharge to wells, or the delineation of
recharge areas for an aquifer are based on scientific hydrologic analysis,
while delineation of wellhead and source-water protection areas are
legal/regulatory functions that reflect political and sociological
considerations. USGS studies must, therefore, emphasize the scientific
analyses and leave the responsibility for designation of an area for
wellhead or source-water protection with the appropriate regulatory
agency.
The scope of USGS studies should include only objective scientifically
based hydrologic and geochemical analyses. Studies on the source of water
to wells and aquifers should include the best possible analysis of the
flow system and provide technical information, such as aquifer properties,
gradients, flow rates, delineations of recharge and contributing areas,
and calculations relative to characteristics of the flow system. Studies
on the occurrence of contaminants or the potential for contaminants to
occur in an aquifer (ground-water vulnerability studies) should also be
supported by field data, such as concentrations of constituents or age
dates based on environmental tracers in addition to information on the
flow system. Indexes of ground-water vulnerability based solely on the
combination of arbitrarily weighted physical attributes (such as, geology,
soils, depth to water) should be avoided because the method is subjective
and virtually unverifiable.
Reports describing the results of these studies should include: (1) a
clearly defined description of the objectives of the report; (2) a
justification of the hydrologic techniques that were applied; (3)
assumptions inherent in the techniques; (4) a detailed assessment of the
methodology used in the hydrologic analysis; and (5) a complete and frank
discussion of the limitations and uncertainty of the methods, data, and
results. Similar guidelines have long been in effect for USGS reports
containing aquifer-test analyses and the application of numerical modeling
techniques. By following these guidelines, personnel working on wellhead
protection and similar-type studies will focus on the hydrologic analyses,
and will provide the appropriate level of documentation required for
Director's approval of their reports.
In summary, there is a role for USGS in studies involving wellhead
protection, ground-water vulnerability, and identification of aquifer
recharge areas. Care must be taken to ensure that our work includes only
the objective scientific analysis and does not include subjective results
based on regulatory considerations. Reports describing the results of
wellhead protection and similar-type studies should include a
justification of the technique and a discussion of the assumptions,
methodology, and limitations of the analyses.
William M. Alley
Chief, Office of Ground Water
Distribution: A, B, S, FO, PO
Regional Ground-Water Specialists, NR, SR, CR, WR
This memorandum supersedes Water Resources Division Memorandum No. 89.26.