Management Options for Wellhead Protection
Barbara C. Cooper
Water Quality Education Specialist
Jane R. Frankenberger
Extension Agricultural Engineer
Fred Whitford,
Coordinator, Purdue Pesticide Programs
Wellhead protection is a way to protect a community’s drinking water supplies by managing the area around the well to prevent potential contamination. This management can be voluntary or regulatory, and depends on the desires and concerns of the community.
One of the first wellhead protection ordinances in this country was written by Governor Gage of the Jamestown Colony in 1610. It states
"There shall be no man or woman dare to wash any unclean linen, wash clothes, nor rinse or make clean any kettle, pot, or pan or any suchlike vessel within twenty feet of the old well or new pump. Nor shall anyone aforesaid, within less than a quarter of a mile of the fort, dare to do the necessities of nature, cinse by these unmanly, slothful, and loathsome immodesties, the whole fort may be choked and poisoned."
Though different rules and courtesies now define what our behaviors should be near a well, the purpose is the same - to protect the health of a community by protecting its drinking water supply. Indiana's Wellhead Protection Rule (327 IAC 8-4.1) provides guidelines that communities can use to protect the quality of their drinking water and to ensure that a safe water source is available in the future.
This publication provides an overview of wellhead protection management options. In the process of putting together a wellhead protection plan, the community’s local wellhead protection planning team will gather information about the physical characteristics, the land uses, and activities that take place in their wellhead protection area. Those steps are covered in other Purdue Extension publications. (See Sources of Information.) To protect the wellhead protection area from potential contamination, communities need to decide what management strategies will work best in their community. This publication can be used by wellhead protection planning teams, and water supply operators, along with public officials such as the Plan Commission, to develop a comprehensive framework for wellhead protection management.
What Area Requires Management?
This publication assumes that your wellhead protection planning team has already had the wellhead protection area delineated by an approved method. This delineated wellhead protection area generally overlies all the ground water that would be pumped by the well in a five-year time period, assuming no significant changes in the pumping rates.
Within the delineated wellhead protection area, the sanitary setback area is the100-200 feet nearest the well. (The specific size required for the sanitary setback is dependent on the geology of the location. It is safest to assume a 200-foot sanitary setback and to protect that area, which represents a little less than 3 acres.) Because it is the most critical zone around a water supply well, the sanitary setback area has special rules and restrictions.
The entire wellhead protection area also needs protection, but the procedures for protecting it are more flexible, and can be determined by the community.
How Do You Manage the Sanitary Setback Area?
The regulations are very specific concerning the sanitary setback area. The requirements spelled out in the wellhead protection regulations (327 IAC 8-4.1-8) include, but are not limited to, the following:
Having the wellhead protection planning team visit the wellhead is a good idea, so that the volunteers serving on the team can get a better "feel" for what the wellhead and surrounding area looks like. After the visit, reassemble the team back at your main meeting area to discuss what steps might be implemented to meet the requirements of the regulation, the needs of the community, and the need for the managers of the water system to maintain the system.
If the water utility does not own the land in the sanitary setback area, agreements with the land owner may be required to get their full cooperation in not using or storing chemicals in the designated area. The actions agreed to will form part of the written documentation of the wellhead protection management plan.
How Do You Manage the Rest of the Wellhead Protection Area?
Except for the sanitary setback area, management of the wellhead protection area is not clearly defined by the Wellhead Protection Rule. Therefore, it is the role of the wellhead protection planning team to decide how to manage this area. Since the rest of the wellhead protection area is much larger than the sanitary setback area, its management has much wider implications for the community.
Two general management strategies can be used: voluntary and regulatory. Non-regulatory strategies, such as educating the public about best management practices, will be the most widely used management tools for wellhead protection. Regulatory measures may be beneficial in some instances, but many communities may not have the political authority to use regulatory management options. The best wellhead protection may involve a combination of both management strategies.
Voluntary Management Practices
Public education and involvement are essential aspects of wellhead protection. In most areas, local land use activities can greatly influence the quality of ground water. Sometimes environmental problems are caused by normal, legal activities engaged in by enlightened citizens in the course of their everyday existence. For example, in homes using septic systems, disposing of household solvents by pouring them down the drain often transfers them directly to the ground water. Paints, oils, and unused fertilizers and pesticides that are poured onto the ground or down a drain can also end up in the ground water. Many of the people who dispose of chemicals improperly do so simply because they are unaware of the consequences of their actions. Informing and educating the public about the source of their water supply and the measures that can be taken to protect it from contamination is one important aspect of wellhead protection planning. The publication Effective Wellhead Protection Through Education, WQ-35, suggests several ways to provide community education on wellhead protection for many diverse segments of the community. (See Useful Publications)
Best Management Practices (BMP's) are measures or practices designed to prevent or reduce pollution. Most are voluntary in nature, and are enacted by responsible individuals and companies to limit liability and to increase productivity. A few examples of best management practices that are useful for ensuring good water quality and effective wellhead protection include:
Land acquisition programs or conservation easements are other non-regulatory strategies to protect ground water supplies. These might include donations or purchases of sensitive lands so that these properties can be set-aside as green space, parkland, or wildlife preserve. Such land uses will protect them from being used in a way that might harm the ground water. This process can be very expensive and is not an option for all communities, but some communities have been fortunate in receiving donations that have been used to protect the environment, while some consider such purchases a wise investment in their future drinking water.
Community waste management and minimization programs are helpful in protecting ground water by reducing the volume of wastes that go into landfills. Hazardous waste collection and residential recycling efforts are well accepted in many communities and can be included as part of your wellhead protection management plan.
Regulatory Management Practices
The most widely used regulatory management tools for wellhead protection include health and zoning ordinances. However, because all regulatory measures require a certain amount of administration, the administrative load for many of these regulations may be too great, particularly for small communities. For these communities, non-regulatory wellhead protection measures would be their best option.
Zoning techniques can be used to permit only land uses that are compatible with wellhead protection. Some of these zoning techniques and land use options will be discussed in greater detail the Purdue Extension Publication, Land Use Strategies for Wellhead Protection, WQ-37.
Subdivision regulations or controls may include provisions to require that the road drainage is directed outside the wellhead protection area, or septic systems are more tightly regulated or are prohibited.
Health ordinances can be implemented to minimize risks to ground water through requiring inspections of septic systems and training programs for workers who install septic systems. Some counties have required filters to be installed between septic tanks and leaching fields. These filters prevent costly replacement of the leaching fields due to overflows of septic tanks.
Health ordinances can also be used to require developers within the wellhead protection area to install monitoring wells down-gradient of the development. The developer is required to periodically test the ground water for likely contaminants. This procedure can possibly detect contamination early, and allow for added protection of drinking water supply wells.
Restrictions on the use of toxic and hazardous materials may be used, but such restrictions can only be implemented when the community has the legal authority to do so. Some communities have banned substances that are known ground water contaminants, like solvent septic system cleaners, in wellhead protection areas. In Indiana, communities cannot restrict the use of pesticides that are regulated by the state Pesticide Review Board.
The applicable State Codes for pesticides are IC 15-3-3.5 and IC 15-3-3.6.Wellhead protection planning teams should recognize that many regulations already exist that control the use of hazardous chemicals, and regulate activities that might damage a drinking water supply. More information on existing regulations can be found at our Web site and those for the EPA and IDEM. (See Information Contacts)
How Does Your Community Decide What Management Options Will Work?
Differences in the geology of the area allow each community some latitude in their management planning. For example, if your community’s wells are 200 feet deep and protected by a thick layer of clay-rich soil, the community can have more confidence that allowing some hazardous land activities to take place will not necessarily harm the water supply. But for a community whose well is shallow or on unprotected sand and gravel soils, the potential for contamination is high and much more restrictive management procedures should be considered.
The form that management takes in each community must be decided by the community itself. It is inevitable that there will be some differences of opinion among community members when asked to decide on a management strategy. Providing information to the public about the issues involved in wellhead protection management is the first step toward gaining a consensus from the community on management strategies. An informed public is better equipped to make the decisions that wellhead protection management will require.
Gather Information from Qualified Speakers
One effective strategy is to invite several guest speakers to make presentations. Some suggestions:
Ask for Input from the Community
Once the community is better informed about some of the issues in the wellhead protection planning process, the wellhead protection planning team will need to determine the management options that the community is willing to support. Community buy-in is essential to minimize potential conflict.
Two processes have shown their usefulness in determining group preferences:
The wellhead protection planning team could use either of the processes, or a combination of the two processes to help gain consensus about management tools in their community.
Focus Groups
In the focus group approach, several discussion groups are formed to brainstorm ideas about wellhead protection management issues. After the community has been informed of the major issues and concerns related to wellhead protection, community leaders and interested individuals can be formed into focus groups. Ten to twelve participants is an ideal number for good discussions in a focus group. Initial questions for them to tackle could be: "What ground water problems are we most likely to have?" or "What management options for protecting our ground water would work best for this community?"
The idea behind a focus group is for the members to explore a large number of options for answering the focus question, and to narrow down the all these options into a few priority responses. The responses that are determined to be priorities are further discussed at a later time, either by this group or by different groups.
Focus groups can represent different segments of the population in the wellhead area. Group members should consider what management options they can realistically and practically do to protect their ground water. Participants can offer many common sense solutions to help local wellhead protection efforts. Some participant groups to consider are listed below.
The wellhead protection planning team should come to the meetings with an open mind to listen to the many suggestions offered. From the discussion, a list of the best management tactics can be developed, and prioritized as to its effectiveness. Those considered should be written into the management plan.
Questionnaire
The other process is to survey community members using a questionnaire. An extensive listing of management options can be found in both the EPA Seminar publication, Wellhead Protection: A Guide for Small Communities and the EPA and APA publication: A Guide to Wellhead Protection (See Useful Publications.) The wellhead protection planning team can use this listing to develop a questionnaire for the public in which they ask which of these management options the community would prefer. The most commonly repeated responses could then be used to help decide on some management strategies.
Once the team receives a consensus from the public, determining a management strategy will meet with much less opposition.
What Goes into a Management Plan?
Managing Potential Contaminant Sources
Your management plan should include a section describing what was done to manage or monitor every potential source of contamination that was listed in the Contaminant Source Inventory section of your wellhead protection plan. For example, if letters were sent to residential neighborhoods within the wellhead protection area, a copy of the letter should be included. And if an agreement was reached with an industry in the wellhead protection area, whereby that industry provided information about its established management practices, or its intent to establish new management practices, this agreement should be included in the plan. If the city agreed to move its stored road salt out of the wellhead protection area, that specific agreement should be a part of the documentation in your management plan.
Well Compliance
Production wells should be in compliance with existing Indiana codes relating to construction and operation of the wells. Though this is usually already done, a statement to that effect should be included in the management plan. A statement describing the standard monitoring procedures already in effect should also be included in the management plan. While this may seem an unnecessary statement to include, it needs to be spelled out in the management plan for the sake of completeness. Hopefully the wellhead protection plan will be an often used and valuable reference to help ensure your community's drinking water will remain safe.
Abandoned Wells
Because a well can be a direct pathway for contaminants to travel to the aquifer it is important for the wellhead protection planning team to identify other wells in the wellhead protection area. Many old farmsteads have been consolidated into larger farms, but the old household or stock watering wells are still in place. The new owners usually think that they may use the old well for something in the future, so have never properly plugged it. There are also numerous old gas and oil wells around the state that have never been sealed. These wells are a hazard to ground water but might also be a safety hazard to small children. In your management plan, you should specify your plans for locating and plugging the abandoned wells within the wellhead protection area. Some guidance for plugging abandoned wells is available through other Purdue Extension publications. (See Useful Publications)
Pesticides
Each management plan is required to describe the strategy for ensuring that pesticides are properly used and stored (according to existing regulations) within the wellhead protection area. Since the regulations governing pesticides have been in place for a number of years, all that is necessary in the wellhead protection management plan is a statement about how compliance with the current regulations is monitored or encouraged.
Notification
The community must notify everyone in WHPA that they are in an environmentally sensitive area. Depending on the size of the wellhead protection area, and the size of the community, the wellhead protection planning team may need to secure help with this task. The assistance of a the county clerk, a title company, or other service to get the names and addresses of the property owners, residents, and leaseholders in the wellhead protection area may be needed. Once this list is acquired, it should be updated on a regular basis in order to provide additional information to the residents as needed.
You must notify owners/operators of potential contaminant sources of the presence of the wellhead protection area. You need to provide them with information on where the wellhead protection plan is located so that the persons responsible for contaminant source management at their facilities can read it. A cooperative dialogue between the water supply management and managers of potential contaminant sources should also be established. If any accidents were to occur at these establishments, the community water supply could potentially be at risk, and the facility would be liable. Therefore, it is in everyone's best interest to form a cooperative partnership to protect the community's water supply.
Education
Education is an essential part of Indiana's Wellhead Protection Rule. Within the management plan section of the wellhead protection plan, there should be a statement referring to the existence of the public outreach and education section of the overall wellhead protection plan. The details of the education plan should be included in a separate section, but because education is part of management, its existence should be mentioned. More information on wellhead protection education is available through other Purdue Extension publications. (See Useful Publications)
Signs
Indiana's wellhead protection rule requires that signs be posted on every major thoroughfare that passes through the wellhead protection area. You can purchase signs from Penn Industries. (See Information Contacts.) You will need to get permission from the proper authority (City Street Department, County Highway Department, or INDOT) to install the signs.
What Do You Do With Your Management Plan?
Submit It
Submit your Management Plan to IDEM as part of your Wellhead Protection Plan. IDEM personnel will ask the following questions in evaluating the management plan you submit, so it may help to keep them in mind as you prepare your plan.
Update It
According to the Rule, your wellhead protection plan must be updated regularly and the steps your team will use to complete this process should be outlined in the management plan. The management plan should state how often and by whom the plan will be updated. This update should include updates on any changes in the potential contaminant sources within the wellhead protection area. The time frame for updates should be chosen based on the complexity of the area and how fast the community is changing. Annual or biannual updates work best for most communities.
Use It
Most importantly, the plan should serve as a guide to the wellhead protection planning team, and the community as a whole. By setting time frames for public education activities and for plan updates, you insure that the plan will be used and referred to often. You should make the plan available to the public, perhaps by putting a copy in the local library.
Those team members and focus group participants assisted in determining the form and direction of the community’s wellhead protection management would probably appreciate receiving a summary of the plan.
Wellhead protection planning is not intended to burden the citizens with unnecessary rules and regulations, but is meant to provide guidelines to assist communities in protecting their own drinking water supplies from future contamination.
Useful Publications
The following Purdue Extension publications provide information about other aspects of the wellhead protection process.
You may find the following two brochures to be useful in your outreach efforts:
All the above are available through your county Purdue Extension office or by calling 1-888-EXT-INFO.
Wellhead Protection: A Guide for Small Communities, EPA/625/R-93/002. This EPA publication gives a detailed description of the entire wellhead protection process and is available free from the USEPA publication office (1-800-490-9198).
Information Contacts
References
USEPA Seminar Publication: Wellhead Protection: A Guide for Small Communities, EPA/625/R-93/002, February 1993.
USEPA, Wellhead Protection Programs: Tools For Local Governments, EPA 440/6-89-002, April 1989.
Witten, Jon and Scott Horsley, 1995, "A Guide to Wellhead Protection", Planning and Advisory Service, American Planning Association, PAS Report #457/458.
Yanggen, Douglas A. and Stephen M. Born, "Protecting groundwater quality by managing local land use", Journal of Soil and Water Conservation, vol. 45, No.2, March-April 1990.