User's Guide for Source Water Assessment
and Protection at U.S. Army Installations

Part 2 - Guidance for Developing Source Water Assessment
and Protection Programs at Army Installations

CONTENTS

CHAPTER 1: INTRODUCTION

1-1 Purpose

CHAPTER 2: OVERVIEW OF SOURCE WATER PROTECTION REGULATIONS

2-1 Wellhead Protection Program

2-2 1996 Safe Drinking Water Act Amendments

2-3 EPA Source Water Protection Guidance

2-4 State Program Content

2-5 Individual Water Systems - How they fit in

CHAPTER 3: OVERVIEW OF ASSESSMENT AND PROTECTION PLANS

3-1 Purpose of Assessment and Protection Plans

3-2 Integration With Other Laws And Programs

3-3 On-Post versus Off-Post Contamination Threats

3-4 Appropriate and Required Level of Effort

3-5 Steps in the Assessment and Protection Process

CHAPTER 4: DELINEATION OF THE PROTECTION AREA

4-1 Introduction

4-2 Available Resources

4-3 Delineation of surface watersheds

4-4 Delineation of ground water aquifers and recharge areas

4-5 Combined surface and ground water sources

Chapter 5: IDENTIFYING POTENTIAL CONTAMINANT SOURCES

5-1 Introduction

5-2 Data gathering - what to look for

5-3 Identifying potential contamination sources - How to look for it

5-4 Available information sources - where to look

CHAPTER 6: ASSESSMENT OF POTENTIAL CONTAMINANT SOURCES

6-1 Introduction

6-2 Source types and inventory

6-3 Ranking each source

6-4 Performing the assessment

CHAPTER 7: DEVELOPING PROTECTION STRATEGIES

7-1 Introduction

7-2 Building the Project Team

7-3 Defining the problem

7-4 Setting Goals and Identifying solutions

7-5 Implementing Controls

7-6 Measuring Success and Making Adjustments

CHAPTER 8: EMERGENCY CONTINGENCY PLANNING

8-1 General

8-2 Essential Tools

8-3 Vulnerability Assessments

8-4 Disaster-specific Emergency Response Actions

GLOSSARY

REFERENCES

Table of Contents

CHAPTER 1 - INTRODUCTION

1-1 Purpose

Although the major responsibility for completing source water assessments lies with individual State drinking water programs, many states realize they cannot complete assessments for every water system with the resources available, and within the time mandated by the Act. Thus, the Army can demonstrate leadership and a cooperative spirit by working with the states in conducting their own assessments on behalf of the state. In addition, Army installations stand to gain greatly by performing their own assessments and developing protection plans. Reduced monitoring costs, increased awareness of potential contaminants to the water source, proactive participation with state agencies in current and future regulatory planning issues to the benefit of the installation, and enhanced compliance with the Safe Drinking Water Act and other environmental regulations are just a few of the benefits that the Army can realize by performing the assessment and protection programs internally.

Table of Contents

CHAPTER 2 - OVERVIEW OF SOURCE WATER PROTECTION REGULATIONS

2-1 Wellhead Protection Program

Table of Contents

2-2 1996 Safe Drinking Water Act Amendments

Table of Contents

2-3 USEPA Source water protection guidance

Milestones

Table of Contents

2-4 State Program Content.

1. Public Participation. The State program must show how it will achieve public participation in developing it's submittal. Each state must form a technical advisory committee and citizens advisory committee. Public hearings, workshops, or focus groups are also required to provide opportunities for the general public involvement.
2. Approach. The program must outline the specific approach to implement the source water assessment and protection program. States are required to outline how they will delineate boundaries of the assessment areas, conduct contaminant source inventories for raw water contaminants regulated under the SDWA (including Cryptosporidium), and conduct susceptibility determinations. Also they must show how these tasks will be performed for the "protection and benefit of public water systems."
3. Availability of results. The program must make the results of the assessments available to the public. This must be done in an understandable and expeditious manner, making available all information collected during each assessment, when requested.
4. Implementation. The final requirement is for the primacy state to implement the approved SWAP program immediately, and to identify which aspects of implementation the state will delegate, to include the financial capability of the delegates. States must also describe the timetable for implementing and completing the assessments, and indicate if the state needs an extension (of up to 18 months) to complete all assessments.

Table of Contents

2-5 Individual Water Systems - How they fit in

1. Although the major responsibility for completion of source water assessments lies with individual State drinking water programs, many states already realize the challenge of completing assessments for every water system within the state with the resources available, and within the time mandated by the Act. Many states will look to major water suppliers to demonstrate leadership and a cooperative spirit, and work with the states to conduct assessments.
2. Also realizing that the time to complete each assessment is a factor, some states may allow assessments to start before the state plan is approved by the EPA. Communication between the State and the water supplier is critical to the development of a plan that will met the requirements of the state program, whatever the final form. In these cases, the water supplier may be developing guidance and lessons learned for the state to use in conducting the remaining assessments, or even to help shape the form of the state program for submission to the EPA.

CHAPTER 3 - OVERVIEW OF ASSESSMENT AND PROTECTION PLANS

3-1 Purpose of Assessment and Protection Plans

Table of Contents

3-2 Integration With Other Laws And Programs

Programs that can be integrated by states to protect source water include the Water Quality Standards Program, the Clean Water Act State Revolving Fund, the Index of Watershed Indicators, the Nonpoint Source Program, the Total Maximum Daily Load (TMDL) Program, the Clean Lakes Program, wetlands programs, the National Pollution Discharge Elimination System (NPDES) Program, Wellhead Protection Program, and the Sole Source Aquifer Protection Program. Data compiled in support of these programs may be particularly useful in preparing source water assessments. Much of the data is already available in electronic format on the internet from sources such as the US EPA Surf your watershed website [http://www.epa.gov/surf/].

Table of Contents

3-3 On-Post versus Off-Post Contamination Threats

1. On-post threats to off-post sources. For an installation performing a source water assessment for it's own system, the question of information gathering to support other assessments is a valid one. A common sense approach and good neighbor policy is to collect information to support external assessments as similar information is collected to support the internal assessment. The collection of information to support external assessments may be influenced by the amount of extra resources needed to acquire the information, or by guidance from the Primacy authority.
2. Off-post threats to on-post sources. Additional thought must also be given to the level of effort needed to investigate those potential contaminant sources located outside of the installation boundary but impacting the installation water sources. The effort needed will depend in part on the degree to which the sources are geographically located outside the installation. Those installations with major portions of their sources located outside the installation boundary will be forced to rely on external information sources. Most off-post sources of potential contamination will already be known by the primacy authority, but the validity of the information must still be confirmed.

3-4 Appropriate and Required Level of Effort

1. Data-rich versus data-poor environments. The overall level of effort required to conduct an assessment also depends on how much the installation has been previously studied. Large Army installations may have an extensive amount of information relating to on-post activities, thus collection of the data will be relatively easy. Available information will include engineering studies, operational and monitoring records for a variety of activities, and regulatory data and reports. Smaller installations with fewer activities may not have this information available. Regardless of the installation size or amount of data available, it is important to focus data collection efforts on those sources that will yield the most information directly related to classifying potential sources, and which can be done with the least amount of resources and effort.
2. Use of appropriate level of effort based on threat. A second concept useful in focusing the assessment process is to concentrate on those areas closes to the sources, and provide a lesser amount of emphasis on areas further away from the source. This allows for more detailed investigation of those contaminant sources that can affect the water source in the shortest time frame. An example of this method is the conduct of field investigations in the immediate vicinity of wells, coupled with the identification and verification of other contamination sources further away from the wells. Personnel conducting the investigation around the wells perform an intensive survey, attempting to locate any potential threats within a fixed radius of the well (for example, 300 feet) that can quickly contaminate the well. A less intensive desktop, database, and paperwork search for other contamination then identifies potential contaminant sources further away from the well. These sources can affect the well, but would also allow for some warning and contingency action to mitigate the effects. Surface water sources can also be investigated in this manner, focusing on the area nearest the source, with diminishing emphasis as the distance from the source increases.
3. Modular approaches for sub-watershed areas. Similar to focusing on the areas closest to the source as discussed above, another approach using focused resources is to break the entire protection area into sub-areas, and then evaluating each sub-area as a stand-alone area. This method is more suited to surface water sources such as streams or rivers, and particularly suited to large rivers where the watershed drainage area encompasses many sub-drainage areas upstream of the point of withdrawl. The potential threats and level of effort applied to investigate them varies from sub-area to sub-area, allowing the appropriate level of effort based on the proximity of the contamination source to the water source, and the types and severity of potential contamination threats.

3-5 Steps in the Assessment and Protection Process

• Chapter 4. Delineate the protection area. The first step is to define the physical area to be protected. This means identifying the groundwater aquifer and recharge area, or the surface watershed area, or combinations of the two, that make up the water source.
• Chapter 5. Identify potential contamination sources. This step is where the major portion of effort will be dedicated. The quality of this step will ultimately affect the ability of the overall plan in achieving it's intended goals.
• Chapter 6. Rank each potential contaminant source. This step prioritizes the identified potential contaminant sources through use of various criteria and weighting factors to find the most significant potential sources.
• Chapter 7. Develop protection strategies. After the prioritization is completed, strategies for reducing or eliminating the contamination threat must be developed. These often take the form of community action groups, zoning and planning modifications or restriction, and awareness programs.
• Chapter 8. Contingency Planning. This final step addresses how to react to the identified contamination threats should they occur. This involves operational and treatment changes, identification of temporary or alternate water sources, and remediation of the contamination.

CHAPTER 4 - DELINEATION OF THE PROTECTION AREA

4-1 Introduction

Table of Contents

4-2 Available Resources

Installation level resources such as DPW or the Real Property section may already have GIS systems containing various data layers that will be helpful in the delineation and identification phases. Since both DPW and the real property section will play a part both in the assessment and later in the development of protection strategies, their involvement in all phases should be sought. They will be a critical element in making the overall program sustainable and achieving the overall objective of incorporating watershed protection into land use and operational practices.

The fundamental point in this discussion is that there are multiple stakeholders to consider in addressing source water issues and many resources to tap. It is important to seek out any available resources.

Table of Contents

4-3 Delineation of surface watersheds

As source water protection areas for surface water based sources are delineated, the use of buffer or setback zones, time-of-travel zones, or modeling techniques should also be considered to enhance the delineation. Among other benefits to the ecological system, buffer zones can reduce the adverse impacts of runoff on drinking water sources. Time-of-travel calculations facilitate spill- and other emergency response actions, and are of greatest importance where rivers used as commercial transport and wastewater discharges are also drinking water sources. Modeling hydrologic conditions and land use can identify watershed areas with the greatest potential impact on source water quality. Buffer zones, time-of-travel, and modeling are discussed further in Appendix C of the EPA SWAP Final Guidance.

Table of Contents

4-4 Delineation of ground water aquifers and recharge areas

Table of Contents

4-5 Combined surface and ground water sources

Table of Contents

CHAPTER 5 - IDENTIFYING POTENTIAL CONTAMINANT SOURCES

5-1 Introduction

Table of Contents

5-2 Data gathering - what to look for

1. Contaminant source identification. Identifying and assessing every possible contaminant threat is unrealistic, not to mention resource intensive. The best method for identifying contaminant sources is to prioritize the search according to the nature of the source. The EPA Office of Technology Assessment has characterized contaminant sources in six categories:
   1. Sources specifically designed to discharge.
   2. Sources designed to store, treat, or dispose of substances.
   3. Sources designed to retain substances during transport.
   4. Sources that have discharges as a consequence of some planned activity.
   5. Sources that are related to altered flow patterns.
   6. Natural sources that are impacted by human activity.
   Examples of potential contaminant sources are listed in Appendix E of the SWAP Final Guidance. Each category of source is equally important to investigate, but the priority in which to investigate and level of effort given to each category should be based on the particular concerns of the installation. As a result, some categories may receive detailed investigation, and others very little.
2. Factors to consider. There are a number of factors to consider in determining if an adequate contamination source inventory has been accomplished. Most factors are applicable to both surface and groundwater sources, such as the identification of surface/groundwater interaction or areas that might release nutrients or pesticides to groundwater or stormwater runoff. Some factors are suited to surface sources only, such as the identification of steep slopes or erodible clay soils. The SWAP Final Guidance, Appendix F identifies specific factors that states performing the inventories should consider.

5-3 Identifying potential contamination sources - How to look for it

1. Initial contacts and interviews. The installation Environmental Office, or equivalent, should be the first stop on a list of people and organizations to interview for contamination source information. They will have a network of contacts at all levels who will be able to provide a great deal of information and support for your investigation. Likewise, the state regulatory authority should also be visited early in your investigation. Officials from neighboring communities may also be of assistance. The primary purpose of these interviews should be to determine the major contaminant sources categories of concern, and determine how best to focus the investigation effort to identify and quantify them. An effective way to accomplish this purpose may be to have a preliminary meeting with all involved parties to allow the concerns of each entity involved to be heard. Follow-on meetings with individual members of the group should focus on the technical details of conducting the investigation.
2. Maps. Maps are an ideal source of information. Since the delineation of the source water protection area already produced a basemap, all subsequent maps should be integrated on additional data layers. A variety of maps should be available, although some manipulation of scale and detail may be necessary to integrate them with the basemap. An increasing number of maps are available in GIS or other digital form which will simplify the process. Geologic formations, watercourses, and topography should already be part of the basemap. Some of the information used in the delineation process may be useful in identifying contamination source locations. Land use and local planning maps will identify existing or potential agricultural, industrial, and built-up residential areas. Transportation maps should be integrated to display major roads, railways, and ports.
3. Surveys. Surveys can take the form of personal interviews, mailings, windshield tours of specific locations, or walking the areas surrounding the sources. Whatever the form, specific guidance should be provided to those personnel performing the surveys to ensure that the same types of information are gathered for each potential contamination source. The information gathered should be closely scrutinized, so that only the information necessary in assessing the probability and severity of the risk occurring is collected.
4. Questionnaires. Hand delivered or mailed questionnaires are a useful tool for verifying information collected from other means such as computer databases. A major factor to consider with mail type surveys is the number of responses is usually far less than the number of questionnaires mailed.
5. Information searches. Computerized databases that manage environmental monitoring and reporting data are an effective and relatively cheap resource to identify major sources of potential contamination. More information on these sources is in paragraph 5-4 below.

5-4 Available information sources - where to look

1. EPA databases. A number of EPA and State regulations require different information to be reported. Many times, the information is stored in electronic databases which are periodically updated. Some of the databases are available and searchable on the Internet. The EPA main data page [ http://www.epa.gov/epahome/Data.html] is an excellent starting point for research. EPA's Guide for Conducting Contaminant Source Inventories for Public Drinking Water Supplies (reference 6) has more information on EPA databases and contact information.
   • NPDES Permits. The Clean Water Act established the National Pollution Discharge Elimination System (NPDES). It requires any entity desiring to discharge into waters of the United States to obtain a permit. Each permit contains information on effluent chemicals, the concentrations allowed in the discharge, and monitoring requirements.
   • EPCRA documents. The Emergency Planning and Community Right to Know Act of 1986 (EPCRA) requires facilities storing "extremely hazardous substances" over a threshold quantity to develop a list of the specific type and amount stored. Releases of these substances must also be reported.
   • SPCC plans. Spill Prevention Control and Countermeasure plans are required for facilities that store bulk petroleum products above or below ground. They will list the locations, specific types, and quantities of products stored, and may also have a great deal of information on potential sources of contamination. Installation SPCC plans can be helpful in identifying similar sources located on the installation.
   • RCRA Subtitle C. Generators of more than 100 kg per month of hazardous waste must file a notification of hazardous waste generation activities. Other requirements for "small quantity generators" also exist for those facilities not meeting the 100 kg/month threshold. Information on the treatment, storage, or disposal site and it's operation are also required, and in some cases stored in electronic databases. A manifest system for transportation and ultimate disposal is also part of the program.
   • RCRA Subtitle I. Operators of underground storage tanks for chemical or petroleum products must provide information on the location, age, size, type, and use of the underground tanks to the EPA or states.
   • Underground Injection Control. The UIC program required a permit for certain injection wells. Perhaps the most numerous and most serious are Class V wells that collect dangerous or toxic wastes and dispose of a variety of industrial wastewaters including chemical plants, laundromats, and dry cleaners. Under proposed changes to the regulations, new restrictions will be placed on the use of three categories of Class V wells:
     • Motor vehicle fluid waste disposal wells
     • Industrial waste (nonhazardous) disposal wells
     • Sanitary cesspools with capacity for 20 or more persons.
     Potential impacts on the Army of the proposed changes are discussed in an attached information paper.
2. USGS data. USGS water quality data are also available in hard copy and electronic format. The USGS maintains stream gaging and quality stations on streams and rivers throughout the U.S. Typical water quality data include nutrient levels and physical parameters, suspended solids or turbidity, and possibly inorganic chemical parameters. This information may be valuable in determining baseline water quality conditions or identifying trends in water quality for a given watershed. A variety of information is available over the Internet from the USGS web site [ http://water.usgs.gov/], including GIS data layers, water quality data, and State contacts for water resources.
3. Installation specific information. Other available information on Army Installations can be obtained from the U.S. Army Environmental Center (USAEC) or USACHPPM. USAEC maintains a Technical Information Center that archives technical reports or documents dealing with environmental issues. USACHPPM also archives technical reports which can be of assistance in determining groundwater, surface water, storm water, and drinking water source quality. In addition, the installation itself should have a number of data sources that will identify potential contamination threats. SPCC plans, lists of extremely hazardous substances, and hazardous waste management plans are developed for most installations, and should be examined.
4. Other information. Additional sources for identifying potential contaminant sources are County or local zoning and land use maps and plans and real estate records. These sources identify specific areas in the source water protection area that have the greatest potential for contamination, such as industrial or agricultural areas. Knowing where the potential exists, a geographic prioritization of effort in investigating contaminant sources can be made. Zoning and land use information can be used later in the source water protection process, because they identify how land use can or will change in coming years. They are also the vehicle through which focused source water quality protection occurs through zoning or land use restrictions.

CHAPTER 6 - ASSESSMENT OF POTENTIAL CONTAMINANT SOURCES

6-1 Introduction

Table of Contents

6-2 Source types and inventory

1. Point sources. Underground or above ground storage tanks and NPDES discharges are 2 examples of point sources. In general, much descriptive data for point sources should be available from regulatory databases. This data will be useful in identifying the risk the contaminant source poses to a drinking water source.
2. Nonpoint sources. Agricultural areas or construction areas are examples of nonpoint sources that information may or may not be available to assist in a risk determination.
3. Emergencies and catastrophic events. Accidents involving spills or other chemical releases on roadways, railways, or ports should be considered in the assessment process. Likewise, floods, storms, or other natural disasters and emergencies should also be evaluated. Information to support the risk determination may be non-specific or all-encompassing, but best professional judgement should be used where hard data are lacking,

There are many factors to consider when doing a potential contaminant source inventory and assessing susceptability of water supply to contamination:

(Source: USEPA SWAP Final Guidance, Appendix F, August 7, 1997)

• Land-use zoning
• Existing best management practices or controls
• Surface water/ground water interaction
• Has any on-site landfilling, land treating, or surface impounding of waste, other than landscape waste or construction and demolition debris taken place, and will such circumstances continue?
• Are there any sand and gravel excavations which expose the water table and are used for illicit dumping?
• Are there major transportation corridors (roads, railroads, airports) where potential spills of hazardous substances or petroleum products might contaminate the drinking water source?
• Sludge disposal areas
• Are there utilities right-of-ways using pesticides?
• Are there permitted wastewater discharges (NPDES) which are of concern?
• Are there any industrial wastewater discharges into on-site drainage systems (e.g., septic systems, dry wells, etc.)?
• Are there agricultural, landscaping, or golf course activities which might lead to releases of nutrients (fertilizers, manure) or pesticides to ground water or stormwater runoff?
• Are there concentrated releases of nitrogen to ground water from agricultural practices, landscaping practices, or dense developments relying on cesspools or septic systems?
• Are there portions of the source water protection area with high percentages of impervious sources which can themselves contribute heavy metals or organics, or which might lead to increased stormwater runoff and decreased ground water recharge?
• Location of stormwater discharges? Are there any discharges directly into a surface water supply or near a well?
• Are there road salt storage areas?
• Are there activities which involve the use, handling, or disposal of hazardous substances or petroleum products?
• Are there any on-site piles of special or hazardous waste present, will such circumstance continue, and is there piling of other wastes which could cause contamination of ground water?
• Are there any USTs present at the site, and will such circumstances continue?
• Is the use and management of above ground tanks consistent with best management practices?
• Has any on-site release of any hazardous substance or petroleum taken place which was of sufficient magnitude to contaminate ground waters (known Federal or state hazardous waste sites)?
• Has any situation(s) occurred at this site which resulted in a "release" of any hazardous substances or petroleum?
• Have any hazardous substances or petroleum, which were released, come into direct contact with the ground surface at this site? (Note--do not automatically exclude paved or otherwise covered areas that may still have allowed chemical substances to penetrate into the ground).
• Have any of the following actions/events been associated with the release(s) referred to above?
  • Hiring of a cleanup contractor to remove obviously contaminated materials including subsoils
  • Replacement or major repair of damaged facilities
  • Assignment of in-house maintenance staff to remove obviously contaminated materials including subsoils
  • Designation of the release as "significant"
  • Reordering or other replenishment of inventory due to the amount of substance lost
  • Temporary or more long-term monitoring of ground water at or neat the site
  • Stopped the use on an on-site or nearby water well because of offensive characteristics of the water
  • Coping with fumes from subsurface storm drains or inside basements, etc.
  • Signs of substances leaching out of the ground along the base of slopes at other low points on or adjacent to the site
  • On-site release(s) that may have been of sufficient magnitude to contaminate ground waters.
• Water quality monitoring and use assessments (305(b) Report)
• Depth to the water table
• Confinedness of the aquifer
• Nature and thickness of the soil sequence
• Hydrogeologic parameter values
• Physical and chemical characteristics of potential contaminants
• Other hydrogeologic/soil/chemical/ physical factors that determine the likelihood of ground-water contamination and the fate and transport of contaminants to and through the aquifer
• Probable sources and causes of use impairments (305(b) Report)
• Well integrity
• Natural sources of contamination
• Additional Factors For Surface Water Sources of Drinking Water
• Steep slopes
• Clay content of soils or soils that are highly erodible (critical areas)
• Recreational areas (campgrounds/trailer parks or greenway trails nearby a reservoir or tributaries)
• Tributaries or areas of a reservoir with high bacterial readings
• Land uses (that may not have zoning)
• Biological steam or lake assessments (305(b) Report)
• Modeling
• Upstream NPDES discharges
• Has any on-site landfilling, land treating, or surface impounding of waste, other than landscape waste or construction and demolition debris taken place, and will such circumstances continue?
• Is the use and management of containers and above ground tanks consistent with best management practices?
• Residential, commercial, or industrial construction activities.

6-3 Ranking each source

1. Ranking Strategies. Ranking each source on a prioritized basis is a simplified version of a conventional human health risk assessment which answers two basic questions: 1) what is the frequency and duration of exposure to the substance; and 2) what is the degree of toxicity of the substance. In simpler terms it is determining the likelihood that something will go wrong, and the severity of consequences if something does go wrong. Any ranking or weighting system that assigns a risk number based on the likelihood and severity will work, as long as the same system is used throughout the source water protection area. Ranking systems can be as simple or as complex as available resources permit. Specific weighting factors or the mechanics of arriving at a risk number can be chosen to make calculation as easy as possible, because the system is only meant to prioritize contaminant sources within the source water protection area. If relative risk comparisons are to be made to other contaminant sources outside the area of concern, a ranking system with standardized units and values must be used.
2. Ranking steps. An example approach to ranking risk is decsribed at http://www.epa.gov/OGWDW/Pubs/09ground.html. This online fact sheet outlines the procedure and provides a contact for obtaining the full how-to manual: "Managing Ground Water Contamination Sources in Wellhead Protection Areas: A Priority Setting Approach" (reference 9).
   1. Identify and characterize potential sources. List sources by name. In some cases, if potential contaminant sources are close together and similar, they may be able to be assessed as a single, larger source. Next, characterize each potential contaminant source. Identify the size (i.e., tank dimensions, length of pipeline, etc.), construction materials, age, type of contaminant(s) the potential source contains or transports, the distance to the drinking water source, and annual throughput of the potential contaminant source. Indicate any underground conduit systems extending between underground contaminant sources and water supply wells such as sewer lines. Also identify any means of open channel flow between surface contamination sources and surface drinking water sources. Open channels could be creeks, streams, drainage ditches, flood control channels, etc.
   2. Determine the likelihood of contamination. The likelihood of contamination has two components: the likelihood of a release occurring, and the likelihood of the contaminant reaching the water source.
   3. Determine the severity of contamination.
   4. Determine the risk of contamination by a contaminant. For a given source of potential contamination, the risk of contamination posed by a given contaminant is the combination of the likelihood of contamination and severity of contamination.
   5. Determine the risk of contamination by a source. The Overall Risk Score of contamination posed by a given source is equal to the highest of the individual risk scores posed by individual contaminants or mixtures. Grouping contaminant sources by risk level (i.e., low, medium, high) is also possible as a function of its Overall Risk Score.
   6. Develop the risk matrix. A risk matrix enables examination of risk posed by either individual contaminants or by the overall contaminant source within the watershed protection area.

6-4 Performing the assessment

1. Ground water source assessment. One very useful resource for performing the assessment process for groundwater sources is already available from the EPA. Managing Ground Water Contamination Sources in Wellhead Protection Areas (reference ) was specifically designed for this purpose in support of the Wellhead Protection Program. It describes the methodology above in greater detail, provides default values for risk and transport calculations, and has all the forms necessary to complete an assessment for a groundwater source. The method is well suited for use of a computerized spreadsheet to help compile, calculate, and manage the data generated during the assessment process.
2. Surface water source assessment. While no generalized tools are readily available for assessing the risk to surface water, much of the information in the above mentioned EPA document can be adapted for use, with the exception of portions of the contaminant transport. A possible substitution for this step would be the use of overland and stream flow models and calculations to predict time of travel, and the adoption of worst case contaminant concentrations for the fate portion of the transport.

CHAPTER 7 - DEVELOPING PROTECTION STRATEGIES

7-1 Introduction

Table of Contents

7-2 Building the Project Team

1. Identify and involve stakeholders. A broad base of people and organizations will be involved in a successful protection program. Many will likely not be associated with the installation. The diversity of the participants will create a team with the expertise, authority and interests to accomplish project program objectives. One way to identify stakeholders is to call a meeting of all involved parties living, working, or having jurisdiction within the source water protection area. Committees such as citizens advisory groups, local business groups or environmental groups can be effective in involving stakeholders and providing the team with valuable information.
2. Build and effective institutional framework. Project administration may be run at the local level with the support of State or Federal agencies, or it may be centralized at a State water quality agency. Regardless of the setup, most watershed projects necessitate a consensus to take action rather than a unilateral decision by organizational leadership. One framework that has worked successfully on many projects is a structure with an Oversight Committee, a Project Manger, a Technical Committee, a Citizens committee, and various project components. The oversight committee administers funding, approves work, contracts, and action plans. The project manager is responsible for coordinating all involved activities, and managing and reporting progress. The Technical committee identifies problems, goals, and a control strategy linking the problems with the goals. The citizens committee identifies problems and goals, educates the public, and reviews and approves action plans.
3. Educate stakeholders and the public. Source water protection projects must have explicit plans for public involving and educating the public if they are to be successful. Education increases awareness of the problems in the protection area and obtains behavior changes in particular groups, as well as allowing a better understanding of the relative contributions of different types of pollution sources. An effective education program should address each target audience in terms that are meaningful to that audience. There may be multiple audiences, to include citizen advisory council members, local elected officials, state and local agencies, corporate and land use interests, news media, and environmental groups. One way to help develop an effective education program is to develop a matrix of target audiences, behaviors to change, groups most respected by each target audience, and a strategy of how to approach each group and work cooperatively with them.

7-3 Defining the problem

1. Develop an inventory of the protection area. Developing an inventory means performing all the steps identified in Chapter 4 through 6 of this guidance document.
2. Monitor baseline water quality. Lack of baseline water quality data has been an identified problem in past watershed protection projects. If adequate data are not collected prior to the implementation of an action plan, the team may be unable to document improvements. Baseline monitoring programs are discussed in more detail in reference 8. If the Assessment of potential contaminant sources is based on past data, the baseline data should already be available. If new data need to be gathered, collection efforts should be coordinated with all State-level programs to ensure compatibility of methods and eliminate duplication of effort.
3. Decide to take action. The project team may never be able to gather enough data or convince all stakeholders that a problem exists. Yet at some point the team must proceed with the protection process based on best judgment, allowing flexibility for future changes. Some clues that the time has come to move on to set goals and continue in the process are when technical experts believe that significant problems are known; the nature of the problems is understood so that environmental indicators can be chosen to track progress; and the sources of the problems are known or can be readily determined.

7-4 Setting goals and identifying solutions

1. Identify environmental indicators and programmatic measures. Environmental indicators are measures that characterize how well a particular protection area is meeting its goals and objectives. Programmatic measures are the number of specific actions implemented to accomplish a goal. The EPA has developed 18 condition and vulnerability indicators, collectively known as the "index of Watershed Indicators". The Index is used to evaluate the "health" of aquatic resources in each of 2,111 watersheds or "Cataloguing units" in the 48 states (Alaska, Hawaii, and territories will be added in future versions of the Index). More information on the Index of Watershed Indicators, along with specific data for each of the cataloguing units is available via the Internet at the EPA's Surf Your Watershed web site [ http://www.epa.gov/surf/]. By identifying the indicators prior to goal setting, planners will ensure that every aspect of the protection area's welfare is addressed.
2. Set project goals. Before setting overall project goals, it is useful to identify potential solutions for each type of problem identified in the protection area. This identification of problems and solutions will facilitate an exchange of ideas and make sure that no options are overlooked. In developing the overall goals, the project team should develop a set of general goals reflecting a vision of the protection area in 10 to 20 years. Each goal should be backed by specific and quantifiable objectives that use environmental indicators to measure the degree of pollution prevention required. Once overall project goals are determined, setting interim goals will document progress at each step of the project. Interim goals will help measure progress toward the longer term overall goals. Interim goals can be in the form of program goals (changes in the policy of agencies and organizations), activity goals (actions taken by various participants), or Best Management Practice Goals (pollution control measures or other environmental improvement practices).
3. Agree on critical actions. Successful protection programs address all key pollution sources at the same time, rather than one at a time. This approach diffuses the "blame" for pollution problems, and avoids wasted time trying to fix blame. Also, if problems were addressed one at a time, other problems masked by the first problem become evident, and this approach rarely ends up accomplishing it's objectives. Brainstorming sessions are an effective way to identify different control measures and their associated interrelations. Although some ideas may be too complex or controversial, all political, social, and technical challenges should be identified before resources are committed to a solution that might never be acceptable. Using all available data, tools, and best judgment, decide on the critical actions that would be the most effective way to meet each of the specific goals of the project. Ensure that all involved agencies and citizens groups responsible for management actions area capable and willing to complete the actions.
4. Protect critical areas. Some resources in a protection area may be of such importance as to warrant special attention. These areas will most likely include aquifer recharge zones, areas around wellheads, and other areas directly linked to the public water supply. Critical areas of sufficient size to ensure the integrity of the resources can be delineated and managed.
5. Select point source controls and nonpoint source management practices. Selecting point source controls is rather straightforward. Point source dischargers realize that they most likely get no economic benefit from installing controls. Many protection projects rely on voluntary implementation of best management practices for nonpoint sources, and incentives must be provided to encourage installation. In choosing the appropriate management practices, give consideration to the following techniques:
   • Evaluate the land use in the protection area. Will it stay the same or change drastically because of changing social or economic conditions?
   • Realize that there are several types of management practices. The key is to use them concert with education and regulation. A single type of management practice is seldom sufficient to solve the pollution problem.
   • Consider protecting buffer zones around receiving waters as a line of defense between sources and waterbodies.
   • Prioritize the measures available for each source and pollutant and decide which should be implemented first.
   • Consider innovative approaches that link point and nonpoint source management, such as pollutant trading.
6. Target and schedule controls. This is the key activity in developing a source water protection plan. It involves reaching agreement to implement point source controls and nonpoint source management measures within a certain time frame. Management measures may also involve local ordinances or redirecting agency resources. Committing to a specific schedule is essential, and additional negotiating time should be allowed to ensure everyone involved is clear and in agreement. Agencies and local governments are the keys to this activity because they must agree to focus activities and funds on discrete areas. It is important to stress that source water protection projects do not operate in a vacuum. They should be compatible with other water quality management programs such as statewide watershed management efforts.
7. Prepare a Protection Area Action Plan. An action plan documents everything that has been learned and agreed upon prior to actually implementing management measures. The primary topics are usually the contaminant source inventory, water quality problems and their sources, indicators, goals, agreed upon actions, a funding plan, and commitments from participating agencies. A formal plan is important because it clarifies exactly what needs to be done and how it will be accomplished. It also demonstrates to the public and political interests that there is a commitment to progress.

7-5 Implementing controls

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7-6 Measuring success and making adjustments

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CHAPTER 8 - EMERGENCY CONTINGENCY PLANNING

8-1 General

Table of Contents

8-2 Essential tools

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8-3 Vulnerability assessments

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8-4 Disaster-specific Emergency Response Actions

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GLOSSARY

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REFERENCES

1. PL 99-339, Safe Drinking Water Act Amendments of 1986, 99th Congress, 19 June 1986.
2. Final Wellhead Protection Requirements and the Status of Army Facilities, Prepared for U.S. Army Environmental Center, Prepared by Horne Engineering Services, Alexandria, Virginia, Contract No. DAAA15-94-D-0013, Task 3, April 17, 1995.
3. USACHPPM Technical Guide No. 216, Meeting the Requirements of the Wellhead Protection Program, 14 February 1996
4. PL 104-182, Safe Drinking Water Act Amendments of 1996, 104th Congress, August 6, 1996.
5. State Source Water Assessment and Protection Programs Guidance, Final Guidance, USEPA Office of Water, EPA 816-R-97-009, August 7, 1997.
6. USEPA Office of Water, Guide for Conducting Contaminant Source Inventories for Public Drinking Water Suppliesi, EPA 570/9-91-014, December 1991.
7. USEPA Office of Water, Watershed Protection: A Project Focus, EPA 841-R-95-003, August 1995.
8. USACHPPM Technical Guide, Emergency Contingency Plans for potable water systems, February 1998.
9. American Water Works Association, 1994, Emergency Planning for Water Utility Management --Manual M19.
10. USEPA Office of Water, Managing Ground Water Contamination Sources in Wellhead Protection Areas: A Priority Setting Approach, EPA 570/9-91-023.
11. Wellhead Protection Program and Plan Development User Guide for Model Schedule of Services, Prepared for U.S. Army Environmental Center and U.S. Army Corps of Engineers Installtion Support Center, Prepared by RASco Inc, Woodbridge, Virginia Contract No DACA31-96-D-0053, Delivery Order 3 December 1998.

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