SOURCE WATER PROTECTION PROGRAM

FIGURE 2 Alluvial and Other Sand and Gravel Aquifers in Montana

FIGURE 3 Source Water Protection Demonstration Project

FIGURE 4 Montana Source Water Protection Projects as of January 1999

FIGURE 5 Map of the Inventory Region for Havre's #3 Well

FIGURE 6 Map of the Spill Response Region for Billings, Montana

FIGURE 7 Watershed Regions Delineated for Public Water Systems

Using Surface Water 3-6

FIGURE 8 Distribution of Cropped Agriculture Across Montana

FIGURE 9 Population Density in Montana

LIST OF APPENDICES

APPENDIX A PUBLIC PARTICIPATION

APPENDIX B ADVISORY COUNCIL

APPENDIX C GROUND WATER PROGRAMS

APPENDIX D WHP SUPPORTING AGENCIES

APPENDIX E PUBLIC AWARENESS AND EDUCATION

APPENDIX F SWP INVENTORY FORM

APPENDIX G GLOSSARY

APPENDIX H UNIFORM FLOW EQUATION (AFTER TODD)

APPENDIX I EPA REVIEW PROTOCOL CHECKLIST

APPENDIX J SWP REPORT GUIDANCE

APPENDIX K POTENTIAL CONTAMINANT SOURCE INDICES

APPENDIX L .. DELEGATED ENTITY CONTRACT TEMPLATE

APPENDIX M RANKING CRITERIA AND PROCEDURE

SECTION 1

1.0 Introduction

The Montana Source Water Protection Program is intended to be a practical and cost-effective approach to protecting public drinking water supplies from contamination. A major component of the Montana Source Water Protection Program is termed delineation and assessment. The emphasis of delineation and assessment is identifying significant threats to drinking water supplies and providing public water systems with the information they need to protect their sources of water. Delineation is a process whereby areas that contribute water to aquifers or surface waters used for drinking water, called source water protection areas, are identified on a map. Geologic and hydrologic conditions are evaluated in order to delineate source water protection areas.

Assessment involves identifying businesses, activities, or land uses in source water protection areas where certain contaminants are generated, used, or transported and then determining the potential for contamination from these sources. Developing a program that completes delineation and assessment is mandatory for states under the federal 1996 Safe Drinking Water Act (see also section 10 for discussion about how Montana will meet this mandate). Delineation and assessment is the foundation of source water protection plans, the mechanism public water systems use to protect their drinking water sources. Although voluntary, source water protection plans are the ultimate focus of source water delineation and assessment. The program described in this document is designed to encourage public water supplies and communities to complete source water protection plans that meet their specific needs.

ELEMENTS OF THE MONTANA SOURCE WATER PROTECTION PROGRAM

# Roles and Duties of State and Local Entities

# Source Water Protection Area Delineation Methods and Criteria

# The Scope of contaminant Source Inventories

# Procedures for Assessing Susceptibility

# Descriptions of Assistance and Education Programs

# Requirements for Emergency Plans

# Requirements for New Public Water Supplies

# Public Participation

Montana uses the existing voluntary Montana Wellhead Protection Program (WHPP) developed under section 1428 of the 1986 Safe Drinking Water Act (SDWA) as a framework for developing and implementing the new requirements mandated by the 1996 SDWA. WHPP was developed to encourage public water systems (PWS) to develop written plans to protect drinking water sources through community planning. The seven elements of WHP; roles and duties, delineation, source identification, managing the protection area, contingency planning, new wells, and public participation, are retained in the Source Water Protection Program (SWPP). The core provisions added are mandatory delineation of source water protection areas, assessment of susceptibility of public water systems to contamination, making the assessments available to the public, and timetables for completion of these elements.

The name of the program has been changed to SWPP to reflect the newer more comprehensive approach. Montana developed SWPP by reviewing available sources of existing data at the federal, state, and local levels. Methods and criteria for completing assessments of all community and non-community PWS were developed pursuant to this review and are described in this document.

Also, methods that will be used to assess the susceptibility of PWS to potential contaminant sources are described. Through the new mandates, the program focuses funding available from set-asides out of the State Drinking Water Revolving Fund on identifying the most effective approach to protecting Montana's drinking water supplies.

Public participation and public right-to-know are central philosophies of SWPP. The program presented in this document was developed through an open process involving comments from a cross-section of interested parties. An advisory council with an associated technical working group provided formal review and comment during development of this document. Public meetings and an enhanced public participation campaign provided opportunity for less formal public participation. Another component of public participation incorporated into Montana's SWPP is public notification of source water assessments. Source water assessments will be made public through consumer confidence reports whenever possible and other media in an effort to notify citizens of potential threats to their drinking water sources. Knowledge of potential threats should provide motivation for voluntary management by local governing bodies. Assistance in developing source water protection plans also can provide motivation for voluntary management. Education of the general public and training for professionals working with PWS also is emphasized to support voluntary management efforts.

Montana's source water protection approach emphasizes a general goal of drinking water protection and benefit to public water supplies. Benefits to PWS will occur in several ways. Benefits will occur directly when the program provides maps and supporting data that identify the source water and potential contaminant sources within the source water protection area for each PWS. Benefits will also occur indirectly to PWS because the passthrough grant option encourages joint delineation and assessments for systems located close to one another or within watershed subareas. Protection of drinking water will occur as state and federal environmental regulatory agencies base decisions regarding state waters used for drinking on delineations and assessments. Protection will also occur as PWS utilize delineation and assessments as the foundation for completing local source water protection plans. Management strategies will be recommended in source water protection plans when PWS source waters are identified as susceptible to contamination. Also, source water assessments are intended to facilitate monitoring flexibility.

Criteria for delineating source water protection areas and the detail required in subsequent contaminant inventories depend on the sensitivity of the source water and the type of PWS. For example, surface water and unconfined groundwater sources are given special attention because they are sensitive to microbial and nitrate contamination, both acute health hazards. Less rigorous criteria are prescribed for transient noncommunity PWS because people are exposed for a limited time. A differential susceptibility assessment approach is outlined that targets immediate health hazards for all systems but targets long-term chronic health hazards only at community and non-transient PWS.

Implementation of SWPP will be coordinated among several programs at the Montana Department of Environmental Quality (DEQ). The Source Water Protection Section of the Pollution Prevention Bureau will have responsibility for meeting the source water assessment mandates of the 1996 SDWA but will work closely with the Public Water Supply Program of the Community Assistance Bureau to ensure the maximum benefit to PWS. The Resource Protection Planning, Water Protection and Monitoring, and Data Management bureaus also will have roles in helping local governing bodies implement SWPP. The goal of interbureau coordination is to ensure that SWPP is integrated in an overall watershed protection approach.

The Montana Source Water Protection Technical Guidance Manual (MBMG 1998) is a reference manual intended to more fully describe the six step process of developing a source water protection plan. Readers are encouraged to review the manual for details on how the program described by this document can be implemented. Copies can be obtained by contacting the Source Water Protection Section at DEQ (406 444-4806) or by visiting the training section on the Source Water Protection homepage at http://water.montana.edu/training/default.htm.

1.1 Source Water Protection Goals and Objectives

The Montana Source Water Protection Program adopts the goals stated in the Montana Constitution and the Montana Water Quality Act. The following is quoted from the constitution: "The state and each person shall maintain and improve a clean and healthful environment in Montana for present and future generations...[including] the protection of the environmental life support system from degradation..." (Article IX, Section 1). Further, from the Montana Water Quality Act: "It is the policy of this state to conserve water by protecting, maintaining, and improving the quality and potability of water for public water supplies..." (Montana Code Annotated (MCA) 75-5-101). The objective of SWPP is to protect and benefit PWS by delineating source water protection areas, by identifying potential contaminant sources and by assessing the susceptibility of water supplies to identified contaminant sources.

1.2 Montana Resources

Montana, the fourth largest state (147,046 square miles) in the United States, has approximately 879,000 residents and a population density of approximately six people per square mile. Montana is a rural state with seven major urban areas, the largest of which is Billings in Yellowstone County with 126,000 people. Fifty nine percent of Montanans live in these seven metropolitan areas. The majority of the remaining population lives in small communities located along alluvial valleys throughout the state. Approximately 618,800 residents or about 69 percent of the total population of Montana rely on a PWS for domestic use (community PWS). An even larger percentage of the population uses water from a PWS when considering the use of restaurants, businesses, schools, and campgrounds. Only approximately 15 percent of the 645 community PWS are associated with incorporated towns or cities and almost half of the community PWS serve fewer than 100 inhabitants.

Major industries in Montana are agriculture, timber, mining, tourism, and oil and gas production and processing. Manufacturers produce goods ranging from food to wood products, primary metals, petroleum, and coal. Major agricultural crops are wheat, barley, sugar beets, and hay. Livestock produced include cattle, hogs, sheep and poultry. Figure 1 shows how groundwater is used in Montana.

About one third of Montana's land is managed by the federal government. The largest single federal land manager is the U.S. Forest Service, which manages more than 26,000 square miles; primarily timbered land at higher elevations in the western third of the state. The Bureau of Land Management manages 12,600 square miles, primarily in the eastern half of the state. The Bureau of Indian Affairs and tribes manage more than 8,300 square miles on seven Indian reservations.

The Continental Divide bisects the state. The Missouri and Yellowstone rivers drain the eastern 80 percent of the state; the Kootenai and Clark Fork of the Columbia drain most of the remainder. Perennial tributaries of the major rivers acquire water from surface runoff and groundwater seepage.

Montana contains three major groundwater regions based on landform and geology. These are known as the Western Mountain Region, Glaciated Central Region, and Non-glaciated Central Region. Generally, aquifers within these regions are further characterized as shallow surficial aquifers or bedrock aquifers. In all three regions the most important aquifers are found in the alluvial valleys of the major rivers (see Figure 2).

Alluvial valley aquifers consist of saturated sand and gravel deposits that commonly are hydraulically connected to perennial streams. These aquifers occur in clearly defined channels that normally do not extend beyond the floodplain and adjacent terrace. Well depths typically are less than 150 feet and the capacities of alluvial valley aquifers to transmit water are at least 10 times greater than adjacent formations. Total dissolved solids are usually less than 300 milligrams per liter owing to the relatively short residence time of water in these aquifers. In western Montana, very thick fine-grained glacial or basin fill deposits typically underlie alluvial valley aquifers. In eastern Montana, the alluvial valley aquifers are underlain by bedrock.

Older bedrock aquifers of Paleozoic and Mesozoic age supply water to PWS in much of central Montana. These water-bearing formations consist of limestone, fine-grained sandstone or siltstone, and are confined by overlying shales. Wells penetrating bedrock aquifers in eastern Montana are usually deeper than 150 feet and yield less water than alluvial aquifer wells. However, fractures and solution openings may occur in bedrock aquifers and increase groundwater yield. Water in bedrock aquifers is usually poorer quality than that found in alluvial aquifers with total dissolved solids ranging from 500 to 300,000 milligrams per liter.

1.3 Montana's Experience with Source Water Protection

1.3.1 Source Water Protection Demonstration Projects

Montana undertook six projects between 1989 and 1998 to demonstrate source water delineation and protection approaches (see Figure 3). 1) The first project, in Missoula, was funded by EPA in 1989 after the Missoula Valley Aquifer was designated a Sole Source Aquifer. 2) A project in East Helena coordinated by the Helena Valley Water Quality Protection District was undertaken to delineate source water protection areas for wells and an infiltration gallery near a stream. 3) The Park County planning department and the City of Livingston PWS undertook a cooperative effort to develop an ordinance appropriate for a small community. 4) A project in Choteau focused on delineating a source