EPA Review Comments & DEQ Responses

EPA's Consolidated Comments

Louisiana's Source Water Assessment Program

July 1, 1999

Note:  These Comments refer to the draft document and the appendices referred to may not be designated with the same letter in the final document.

EPA: Section 4.1 - (page 9): The State should include a paragraph concerning use of the WHPA model to determine a 2-year TOT for ground water sources. In addition, the State should clarify if the Terrace aquifer will be delineated differently based on velocity studies (For example, for Transient Non-Community sources, 1,000 ft. is not adequate to provide a 2 year TOT. It would need to be 2,324 ft.)

DEQ Reply: Louisiana does not intend to use the WHPA model for any delineations or TOT calculations. The heterogeneity and anisotropy of the unpredictable river laid deposits prevents this as discussed in Appendix I. See page 2 of Appendix I for how we determined TOT. Based on the average ground water velocity for the Terrace Aquifer, we are willing to increase the delineated area for this aquifer to 2500' when considering transient Non-Community systems.

EPA: Section 4.1 - (page 9): The second paragraph states that, "Populations served by transient non-community wells are considered less vulnerable due to limited exposure." Limited exposure to chemical and biological contaminants can cause acute health effects. Accurate tracking of adverse health effects resulting from pathogens ingested at transient non-community wells may be difficult due to the transient nature of the population drinking water from these types of water supplies. Please elaborate on the rationale for establishing the radius for transient non-community wells by indicating what specific factors were involved in the determination. Since the statewide average ground water velocity study is cited as a reference for determining the radius for transient non-community wells, please include a reference to Appendix I in the narrative.

DEQ Reply: We are going to remove the sentence (and the paragraph) that you refer to in order to avoid misunderstanding and ambiguity . We are going to substitute your wording as underlined above. The rationale for establishing the radius is discussed in the last paragraph of the first page of Appendix I. This rationale coupled with the distances in feet for a 2 year time of travel in the table on page 6 of Appendix I established the criteria of the 1000 foot radius for Transient Non-Community Systems, with the exception of the Terrace Aquifer discussed above. We will add this rationale to the discussion on radius sizes.

EPA: Section 4.1.1 - (page 9): The next to the last sentence in the section states that, "If a confined aquifer has a "remote" recharge area that is 1 mile or less from a drinking water well, then that recharge area could be considered as part of the source water protection area for that confined aquifer well." Please elaborate on what parameters will be used to determine if the remote recharge area is considered as part of the source water protection area.

DEQ Reply: The quote above defines the parameters. Attached are diagrams that may help further visualize this. These diagrams (Attachments #4 and #5) can be added to the document if you wish. For the most part, beds dip very gently in Louisiana, and as result of this we will not have many remote recharge areas. The diagram displays somewhat steeply dipping beds, and this may be found around some salt domes that have shallow expression. The maximum delineated area for ground water systems is a one-mile radius around the well. If the remote recharge area for a confined aquifer falls within this delineation, or a lesser delineation, this remote recharge area for this aquifer will be considered part of the SWPA. Also see the attached "Discussion Items for Ground Water Protection Council" (Attachment #6) whereby EPA Headquarters Protocols for Review of SWAP Submittals is outlined. Refer to Section B where Remote Recharge Areas is discussed. The Louisiana language relative to defining Remote Recharge Areas is similar to the EPA Headquarters protocol example. The remote recharge area delineation is consistent with the State's Wellhead Protection Program delineation methods.

EPA: Section 4.2 - (page 11): The first sentence of this section should read, "There are 85 intakes located within 27 water bodies in the State of Louisiana."

DEQ Reply: Correction done.

EPA: Section 4.2 - (page 11): The second paragraph under this section states that, "However, ... a flexible distance upstream from the intake will be based on individual prioritized segments for a database search. The regional DEQ surface water staff will determine the delineation based on their expert local knowledge." Please provide a rationale for segmenting, and a description of the training process the state proposes to ensure that the methods used by those with "expert local knowledge" will result in consistent conclusions statewide. The method should be sufficiently defined to ensure that another person conducting the search under similar conditions would come up with similar results.

DEQ Reply: Ultimately we decided that the database research would be throughout the contributing watershed as shown by the diagram "Surface Water Supply Protection Areas" in Appendix R. We are using segmenting to the extent that we will do ground truthing 1000 feet to either side of a stream for a segment of that stream defined by a radius of 5 miles above the intake.

The Mississippi River is an exception to this and is being handled distinctly as discussed in the program submittal and in this replies submittal. There is isolated valid TOT data available on some Louisiana streams, but after a meeting with the USGS in Baton Rouge and three ex-USGS hydrologists on contract to DEQ, it was determined that there is not reliable flow and velocity data for use in the SWAP with the exception of the Mississippi River and Bayou Lafourche where dye studies have been done. Based on the low topographic relief in Louisiana, streams are relatively slow moving and we believe that there will be sufficient time to react to a pollution event beyond 5 miles from the intake and this distance will also allow time for dilution to take place. However within the critical area, reaction must be faster, and it is important to know with accuracy what is in the critical area and where it is. Thus, we have described our methodology, however as we implement this part of the program, if we find a need of major variation we will justify it in writing.

Please refer to the EPA document STATE METHODS FOR DELINEATING SOURCE WATER PROTECTION AREAS FOR SURFACE WATER SUPPLIED SOURCES OF DRINKING WATER. On page A1-4 Salt Lake City is discussed as using the entire watershed area upstream of its surface water intakes as the basis for its management decisions. "Because of the mountainous nature of the region, drainage areas are smaller, and can thus be more easily managed than the drainage area of a river of similar size in the coastal plain of the U.S." In Louisiana, we have large watersheds and we are going to encourage water systems to manage critical areas. The key word is manage, and we believe the critical areas chosen are manageable, yet still protective of the public water supply.

The regional DEQ surface water staff came into Baton Rouge for a general training session in December, 1998. Prior to going into the field, each regional coordinator has been or will be visited by Howard Fielding and Mary Gentry whereby guidance handouts are given out. Also, a discussion takes place with regard to the specifics of their region and watershed maps and surface water intake information is given to them, and questions are answered. We believe everybody is on the same track in order to provide consistency statewide.

GPS training of the regional staff has been done by John Jennings of the Aquifer Evaluation and Protection Section which is the section handling the SWAP. Again consistency is maintained as he is an expert in this area and is their contact for questions. The regional staff is using the same equipment and are guided by the same written Standard Operating Procedure which is outlined in the program submittal in Appendix G. The method should by sufficiently defined to ensure that another person with the same expertise conducting the search under similar conditions would come up with similar results.

EPA: Section 4.2 - (page 11): For delineation of the critical zone for surface water systems, the State needs to provide some general criteria that will be used by the field personnel so that EPA can evaluate whether this zone will provide sufficient and consistent protection. The method should be sufficiently defined to ensure that another person conducting the search under similar circumstances would arrive at similar results.

DEQ Reply: Expanding upon the above comments, basin subsegment maps with surface water intakes shown are delivered to the surface water regional surveillance staff. Thus, all are working off of the statewide map, but concentrating on a large-scale version in their areas of interest. They are surveillance staff, therefore knowledgeable as to facilities and PSOCs and their effects on the waters of the State.

All of the regions are given a copy of the surface water data dictionary that is built into the Trimble Data Logger that they will be using in conjunction with the GPS unit. Thus, consistency is preserved.

The critical zone is a ground truthing zone. This is a 1000-foot buffer to either side of streams for a 5-mile radius upstream from the intake. Also, a 1000-foot buffer for ground truthing exists around lakes and reservoirs that have a surface water intake. Topography in Louisiana is very low relief for the most part, and therefore runoff tends to be slow. Also, an aerial view of the State shows significant size streams to have a meandering pattern, again indicating a low relief environment with relative slow moving streams. For many of our smaller streams, you cannot tell which direction they flow unless you are observing them during a rain event. Therefore, knowledge of facilities and PSOCs relatively close to water bodies with intakes is critical in our opinion, thus the 1000-foot critical zone.

Many surface water intakes are in the Mississippi River. A discussion of how we will handle the Mississippi River ensues relative to one of your later questions.

EPA: Chapter 5 - Assessment of Significant Potential Sources of Contamination within Delineated Source Water Protection Areas (page 13): The State needs to include a description of the approach used to derive the list of Potential Sources of Contamination (PSOCs) to be inventoried and should note that it is not all inclusive but represents the highest and most likely risks associated with the contaminants of concern. The State should address if and how sources, which are not on the list, but in the judgement of the local contact or field personnel, could represent a PSOC will be reported to the State, included in the susceptibility analysis and reported to the public. The State does not list surface impoundments as a source to be inventoried. In a study done by EPA, surface impoundments and septic systems were proven to be the two most significant sources of ground water contamination. A follow-up study on surface impoundments confirmed their threat to ground water. The State needs to include surface impoundments in the list of PSOCs.

DEQ Reply: The description of the approach used to derive the list of PSOCs to be inventoried is discussed under Vulnerability-Ground Water 6.2.1. Many sections of the submittal have related themes, and rather than be repetitious, we have discussed topics as we saw fit. The list and the ranking is based upon the causes of contaminated ground water sites under investigation and remediation by the DEQ as well as consideration of the causes of contamination of public water supplies and a literature review. We should add that our experience in the Wellhead Protection Program over the last 10 years has helped with the list derivation. Also, the Citizens and Technical Advisory Committee had input into the development of the list. "The list is not all inclusive, but does represent the highest and most likely risks". We will add this sentence to the discussion.

With reference to PSOCs that are not on the list, but in the judgement of the local contact or field personnel could represent a PSOC that should be reported to the State and included in the susceptibility analysis, we reply as follows:

Due to the limited funds and short mandated time frame of the Source Water Assessment Program, we relied on the State's experience in the Wellhead Protection Program to design an automated data collection system guided by the State's experience in the Wellhead Protection Program. We are confident that this system will cover 99% of the PSOCs found in the field. If sources not on the list are found in the field, the field personnel will call in to DEQ on a 1-800 number and will speak to a member of the State SWAP staff. The staff member will direct the field personnel to enter the unlisted PSOC as a High, Medium, or Low Generic Source. In this way, the unlisted PSOC will be reported generically to the State and will be included in the phase I and phase II susceptibility analysis.

We will add industrial surface impoundments to the list of PSOCs.

EPA: Section 5.4.2 - (page 15): Pesticide application is listed as a "higher risk" contamination source for surface water (Appendix O). However, the discussion of the Mississippi River excludes pesticide application as a source of contamination. Pesticide application should be discussed and included as a source of potential contamination for the Mississippi River or a rationale should be presented which indicates the Mississippi River is not susceptible to pesticide contamination.

DEQ Reply: We will expand the second paragraph on page 15 to mention pesticides. The United States Geological Survey (USGS) report referred to (Circular 1133), discussed pesticides. Quoting from that report, "The most notable feature of all the regional scale studies is the large increase in herbicide concentrations that occurs during spring flush. These conditions generally do not persist past mid-summer. Unfortunately, drawing conclusions from the fact that atrazine concentrations exceed the Maximum Contaminant Level (MCL) at times is complicated by the consideration that MCLs for drinking water for example, are based on average annual concentrations and not on concentrations of short duration." Testing by Jefferson Parish Waterworks in Louisiana has confirmed the short term spikes of atrazine above the MCL, however drinking water standards have not been violated.

EPA: Section 5.6 - (page 15): Consistency between the Source Water Assessment Program and the State's approved Wellhead Protection (WHP) program is essential. We suggest that the list of regulated and non-regulated Potential Sources of Contamination (Appendices E & F) for the State's WHP program be ranked for risk and incorporated as a common link between the two programs.

DEQ Reply: We will adjust Appendices E and F and add the ground water ranked PSOC list to the WHPP document. We are currently using the SWAP ground water PSOC list in the WHPP as we collect data in the field.

EPA: Section 5.6 - (page 15): The State's draft program commits to conducting a "potential susceptibility analysis" for systems that are current participants in the State's Wellhead Protection program "time and funding permitting". DEQ is reminded that SDWA Section 1453 applies to all public water supply systems, including those currently being protected by the Wellhead Protection program. As an additional consideration, the State should keep in mind that these determinations must be completed as they should be factored into the statewide rating of water systems in Phase II and will be needed by those water systems for inclusion of susceptibility information in the Consumer Confidence Report.

DEQ Reply: We can handle the DEQ Wellhead Protection Programs as we have gone back and located wells and PSOCs by GPS for all of our programs and are currently administering the WHPP to the standards of SWAP. It is the Louisiana Rural Water Association (LRWA) Programs that we are concerned about. We have located the wells and PSOCs for some of their programs by GPS as we knew they were not doing it. However, with the SWAP now in effect, we do not have the "time nor the funding" to continue this. This should be the responsibility of the LRWA, not DEQ. It is important that they abide by the State standards with regard to the requirements of the WHPP, but also that they integrate their WHPPs into the SWAP and provide GPS locations for their old programs and current programs. Furthermore, there should be quality control, just as DEQ has quality control. To be consistent with data quality, they should be using the same GPS units and laser range finders the State is using and adopt our Standard Operating Procedure. It is beyond the control of DEQ to see that this is done and there will be a void in the statewide rating of water systems in Phase II if it is not done. These systems will not have the necessary susceptibility information for inclusion in the Consumer Confidence Report. EPA and the National Rural Water Association, as partners in the WHPP with the ability to see that this is done, should take action with regard to this in our opinion. Also, we find there is an inconsistency in the EPA approach to the Wellhead Protection Program whereby step 5 protection is a goal for the National Rural Water Association programs and a requirement for the State programs.

EPA: Section 6.1.1 - (page 18): The second sentence of the last paragraph should read, "The sensitivity matrix will weight each of the sensitivity factors to determine an overall sensitivity value, ....".

DEQ Reply: Correction done.

EPA: Section 6.2.2 - (page 20): The statement, "Septic systems around the perimeter of surface water bodies that are drinking water sources have caused pathogen problems for source water, but are not a factor with regard to finished water." may be true. However, for purposes of conducting a susceptibility analysis for surface water intakes, treatment capabilities of the public water supply system can not be considered as a factor in determining susceptibility.

DEQ Reply: Septic systems are listed as a PSOC in Appendices N and O.

EPA: Section 7.1 - (page 26): The first paragraph states that, "We intend to make the assessments available to the public through announcements in the annual utility Consumer Confidence Reports and on the Internet on a quarterly basis as each system is completed." The above referenced sentence should be changed to indicate that notifying the public of the availability of a completed source water assessment through the CCR is not an option, rather, a requirement. The Consumer Confidence Report rule [See 40 CFR 141.153(b)] requires information on sources of water in the content of each annual report. The required items are as follows:

* Type, name, and location of water sources

* Availability of completed source water assessment

* Information on significant potential sources of contamination, if available

* A brief summary of system's susceptibility to contamination

DEQ Reply: We will reword thus, "We intend to make the assessments available to the water systems for inclusion in their annual utility Confidence Reports per the requirements of the Consumer Confidence Report rule (40CFR141.153(b)). Also the assessments will be available on the Internet on a quarterly basis as each system is completed.

EPA: Section 7.1 - (page 26): For surface water sources, Phase I vulnerability is expressed as the number of H, M, or L sources inside and outside the critical zone. For ground water sources, Phase I sensitivity will be expressed as H, M, or L and Phase I vulnerability will be expressed as the number of H, M, and L risk sources within and outside of 1,000 ft. assessment area. This is the information that will be released initially to the public water supply system and represents the results of the intra-system assessment. Therefore, this information should communicate as much about the relative risk of the individual sources as possible so that local protection efforts can be prioritized and implemented. EPA recommends that the source risk ranking tables or an explanation that a single source can have a relative ranking between 0.1 and 25 and the ratings assigned to individual sources can be included as part of the Phase I results. The maps should, at a minimum, display and key the source type and risk characterization (H, M, or L).

DEQ Reply: After all Phase I assessments have been completed, DEQ will also provide the water systems with the results of the Phase II Susceptibility Analysis. This is a comparative analysis that will describe the water system's potential susceptibility to contamination on a scale from 1 (low potential susceptibility) to 10 (high potential susceptibility). At this point, DEQ will target the high potential susceptibility water systems for protection activities. Therefore, DEQ will not be involved in "Protection Activities" until all assessments are done for all water systems. The nature and prioritization of "Protection Activities" will be determined from the results of the assessments. We will display and key the source type and risk characterization (H, M, or L) on the maps released as part of the Phase I assessments. See attachment # 1 for clarification.

Note that the entirety of the delineated area for ground water systems will be ground truthed. Any problems found in the field during this "Assessment Phase" will be reported to the proper agency immediately for investigation and correction if necessary. A list of state agency contacts (Attachment #3) will be provided to the water system and local officials in the event problems arise that need immediate attention. See a further discussion about this later on under comments being presented by EPA for the State to use in clarifying or enhancing its Source Water Assessment Program.

EPA: Section 7.1 - (page 26): In order to avoid confusion, examples of the standard forms and maps that will be provided to the public at the completion of Phase I need to be included in the submittal to assist EPA in evaluation of the presentation of the Phase I results. The existing map appears to show information that is only used by the State in conducting the Phase II analysis (such as final vulnerability score and the intermediate distances). The forms could be improved to make the description of the process and results more succinct, on one hand, while more completely describing the information presented graphically on the map. Louisiana may want to consider publishing at least two versions of the results, one appropriate for the general public and another containing more technical information (such as the rating for the individual sources) for use by local officials, identified PSOCs and planning organizations.

DEQ Reply: For the Phase I release of information, we will replace the points allocated to the PSOC with the risk ranking of the PSOC as (H, M, or L) on the map. We will not show the total potential vulnerability score on the map for the Phase I release, as this will not match the form we are going to release. Again, refer to Attachment # 1. We are adding additional clarification information for the Phase I release to the public in the form of fact sheets. Copies of these sheets are attached (Attachment #7). All of the susceptibility information including point assignments and total vulnerability scores for each system will be available at the time of the Phase II release as this is really when such information is pertinent. The map in our program submittal was an exhibit showing how the susceptibility analysis matrix was developed during Phase II. Phase II susceptibility information that is released to the public will be a statewide high, medium or low ranking for their water system compared to the rest of the state.

We do not want to publish two versions of the results. We believe this can lead to confusion. Also, we are trying to keep our maps and information simple, yet informative. From our experience with the WHPP, technical information is not well accepted by the general public, water system personnel, or local officials. For those interested in the derivation of the susceptibility numbers and rankings, this information will be available at the water system. The DEQ staff will also be available to answer questions as indicated in Appendix S.

EPA: Section 7.1 - (page26): The Consumer Confidence Rule requires that the results of the assessment be summarized in the CCR when an assessment is completed for a system. In Louisiana, there are two levels of assessment so "completeness" is relative. The results of the intra-system Phase I assessment, which are released quarterly as Phase I is completed are primarily for the purpose of informing and encouraging local protection efforts. EPA recommends that DEQ provide a brief summary of the results of the Phase I assessment for use in the CCR, for example, for a ground water system, a brief characterization of the sensitivity (H, M, or L) and the number of H, M, or L sources within and outside a 1,000 ft. radius. EPA also recommends that the State supply additional information to the systems at the completion of Phase II about the relative standing of the system in comparison to other systems (H, M. or L susceptibility) when Phase II is completed for use in the CCR.

DEQ Reply: We essentially agree with this; Appendix S and the discussion above relative to the two previous comments apply to this EPA comment. However, as discussed under Section 7.1 - (page 26) earlier and immediately below, protection activities will commence after the phase II assessment results are completed.

EPA: Section 7.1 - (page 26): Louisiana is to be commended for the objectivity of its approach and for making the information available to the public as field work is completed. However, since the field information, including maps and charts showing the factors which will be used to assess susceptibility will be available before the "results" of the assessment (both the intra- and the inter-) a public information and education effort will be essential. The State is encouraged to make additional efforts to inform and engage the public (such as holding statewide or local citizens meetings) as the Phase I and II results are released. The information can be disseminated through the Louisiana Rural Water Association, the State AWWA Section, and the League of Women Voters.

DEQ Reply: With regard to the encouragement to make additional efforts to inform and engage the public (such as holding statewide or local citizens meetings) as Phase I and Phase II results are released, we prefer not to do this. We want to be able to analyze the assessment information among systems as discussed above and use this information in an intelligent and organized way to establish protection activities. We believe it is a waste of time to hold statewide citizens meetings, as we have already done this as part of public involvement in explaining the SWAP to the public. We had a range of 18 to 27 people in attendance at 5 large cities in Louisiana. This was after widespread advertising and the mailing of hundreds of personal invitations. As far as local citizen meetings, we intend this as part of the "Protection Phase" of the SWAP. However, during the assessment phase, we do not have the staff or funds available to handle ongoing assessments and commence protection activities in the communities or districts of the local water systems. Once you start going into communities for local meetings and discussing results of assessments, you had better be prepared to commence protection. We see protection as necessary, but it must commence after all assessments for all water systems are completed.

EPA: Section 8.3 - (page 30): According to the information found in Appendix T, the third and fourth sentences should read, "There are 2002 public water supply systems in Louisiana, and 107 of these have approved Wellhead Protection programs. It is expected that an additional 92 water systems will be approved for the WHP program during the interval of SWAP (42 months assuming an extension)."

DEQ Reply: Correction done.

EPA: Section 8.7 - (page 32): For EPA to evaluate whether the State, to the maximum extent possible, will ensure that the assessments for persons served by interstate waters are of equal caliber to "in-state" assessments, the State should include a specific commitment to use and share appropriate assessment data with transboundary resource states.

DEQ Reply: The commitment is on page 32.

EPA: Section 8.8 - (page 32): This section states that, "the State will also encourage all public water supply systems to update their programs on a regular basis." Please be more specific by providing a recommended frequency (every three years, every five years, etc.) for systems to use as a guide for when to update their programs.

DEQ Reply: We are going to recommend that updates be done at least every three years.

EPA: Section 8.8 - (page 32): A process for "down-grading" or "up-grading" a system's susceptibility determination needs to be added to the program as a means of recognizing systems that implement effective PSOC control measures or that are successful in removing PSOCs that are a threat to its source of drinking water. Similarly, systems that fail to adequately address identified PSOCs with an effective form of protection measure may have its susceptibility determination up-graded to a higher risk.

DEQ Reply: If a system submits an update, we will rank them again based on the susceptibility analysis formula. Our experience with the WHPP is that after the problems found during the field assessment are addressed, the remaining sources are potential sources of contamination, and the highest risk ones are generally regulated. It is the unregulated ones, even though they may be of lower risk that can be troublesome due to lack of attention. These can be controlled perhaps by ordinances if a community is willing. Also, an educated community, local government, and water supply is a first line of defense. The latter is the main thrust of protection in Louisiana as result of some difficulty in getting local governments to pass ordinances under the voluntary WHPP. Once the public becomes aware of their source of water, and how and what can contaminate it, they should become "watch dogs" that protect the community. Once the assessment and protection phases are completed, and the State has disseminated information to the community, it is the community that must be vigilant in protecting its drinking water source. The State is always available to provide technical assistance and has on many occasions over the years of the WHPP.

EPA: Appendix D - In the responsiveness summary to Lake Charles, the response contains information concerning the Consumer Confidence Report, which is not accurate:

(1) The third sentence in question 1 states that, "The Source Water Assessment Program (SWAP) information is not required in these reports." This sentence is misleading. The Consumer Confidence Report Rule [40 CFR 141.153(b)] requires that the following source water items be included in the content of CCRs:

- Type, name, and location of water sources

- Availability of completed source water assessment

- Information on significant potential sources of contamination, if available

- A brief summary of system's susceptibility to contamination

(2) The final sentence in question 1 incorrectly states that EPA will post the CCRs on the Internet. The Consumer Confidence Report Rule [40 CFR 141.153(b)] does require that systems serving a population over 100,000 be required to post the CCR on the Internet. However, EPA is not required by the SDWA, the CCR final rule, or the draft CCR guidance to post CCR reports for any systems regardless of size or population served.

DEQ Reply: We have a current summary of the Consumer Confidence Report relative to Louisiana as discussed by a staff member of the Louisiana Department of Health and Hospitals. We will incorporate this information into our program and refer to it relative to your comments on the Lake Charles meeting. See Attachment # 2. We must point out that the first information we received on the CCR was the CCR Guidance from Beth Hall forwarded to us by e-mail from Ken Williams on February 19, 1999. This was 13 days after the required submittal date of the SWAP. We do not recall where we got the information that was presented at the Lake Charles meeting.

EPA: Appendix F - The list of databases used to conduct the Phase I assessments should be expanded to include: Injection wells (Class I, Class II, Class III if any, and Class V) as they become available, Solid Waste Landfills (both historical and regulated), Animal Feeding Operations (Region 6 may be able to provide a good start for this database), and all wells predating the State's Water Well Construction standards dated November 1985. The Region 6 GIS Coordinator will be able to assist DEQ in obtaining some of these databases. In addition, the State should consider maintaining a database of inventoried sources that are associated with potential release of microbial pathogens so that, if necessary, a determination of susceptibility to microbial susceptibility can be performed for each source and/or system.

DEQ Reply: Injection wells and landfills are listed under the List of Databases in Appendix F. The Department of Natural Resources (DNR), Injection and Mining Division is providing us with their current databases locating all Class I, II, III, and V injection wells. If Region 6 has a comprehensive database with locational data on Animal Feeding Operations, please let us know. We do know that the bulk of the dairy farms are located in the Florida Parishes. The current Louisiana Department of Transportation and Development database that we work with contains all registered water wells in the State including those drilled prior to 1985 and is mentioned in the database list in Appendix F. All inventoried PSOCs are going into a database that can be queried. It will be no problem to extract those PSOCs associated with the potential release of microbial pathogens.

EPA: Appendix N - See attachment #1 for suggested modifications to the relative risk ranking of these potential sources of ground water contamination. In addition, add an opening paragraph to the Appendix that provides the system with the flexibility to identify specific potential sources of contamination that may be of concern to the system.

DEQ Reply: We have made some adjustments to the PSOC lists as shown on your attachment # 1. However, we do this with some reservation since the lists were already adjusted in the Citizens and Technical Advisory Committee meetings. We will add an opening paragraph to the Appendix that provides the system with the flexibility to identify specific PSOCs that may be of concern to the system. However, this has always been the case in Louisiana, as we meet with the water system at the time of the inventory.

EPA: Appendix N - For ground water sources deeper that 1,000 ft. into confined aquifers, the State needs to look specifically for other penetrations through the confining layer(s) within the source water assessment area.

DEQ Reply: Our Oil and Gas Database and our Injection Well Databases may help with this combined with the fact that the entire SWPA for ground water systems is being ground truthed.

EPA: Appendix O - See your attachment #2 for suggested modifications to the relative risk ranking of these potential sources of surface water contamination. In addition, add an opening paragraph to the Appendix that provides the system with the flexibility to identify specific potential sources of contamination that may be of concern to the system.

DEQ Reply: See reply for Appendix N above.

EPA: Appendices N and O need to be clarified to show that Class V wells (particularly large cesspools, motor vehicle wells and industrial disposal wells) and/or the facilities commonly associated with these well types will be identified. These types of injection facilities must be characterized as "high risk" for both ground water and surface water sources.

DEQ Reply: We have now characterized these types of injection facilities as high risk in Appendices N and O. For a further discussion of Class V wells refer to the DEQ reply to the second GENERAL COMMENT below about how the LDNR, UIC Program integrates with the SWAP.

EPA: Appendix R - Page 6: The fourth sentence of the second paragraph should read, "The car wash would score from 2.5 to .5 depending on its proximity to the water body."

DEQ Reply: Correction done.

EPA: Appendix R - Page 8: The next to the last paragraph on this page should read, "Again, using the Surface Water Supply Protection Areas diagrammatic example which follows, the vulnerability number based on Anthropogenic Data from the Database Search would be calculated as follows for the Critical Area:"

DEQ Reply: Correction done.

EPA: Appendix S - Add the following information to the assessments that are to be provided to the public water supply systems that are located in EPA designated Sole Source Aquifers:

DEQ Reply: EPA should provide us with brochures if they have them as all water systems do not have access to the Internet to obtain information on the Sole Source Aquifer Program. These could be added to the assessment package that goes into the water systems.

We will add the following to the program document:

The EPA Sole Source Aquifer program has been identified as an element of protection in the Source Water Assessment Program. For areas that have been designated as sole source aquifers the local water supply system is benefited by EPA review of projects with Federal financial assistance and the modification or denial of those projects which might contaminate the aquifer. This added level of protection provides a direct benefit for water systems which rely on ground water, but can also provide additional protection for systems relying on surface water because surface water flows are sustained by base flow from ground water during much of the year. Public water supply systems located within designated sole source aquifer areas may receive priority consideration for assessment and protection activities. Local water suppliers and the public who live within designated areas will be made aware of the benefits of this program and know that they may notify EPA of projects with pending federal financial assistance

(Federal loans, loan guarantees, grants, etc) if those projects have a potential for contaminating the aquifer. This information is being made available to the public water supply systems through their completed assessments and is available to the public through the Consumer Confidence Reporting mechanism. Maps and other information on the sole source aquifer program in Region 6 are available on the Internet at http://www.epa.gov/earth1r6/6wq/swp/ssa. The EPA Region 6 contact for the Sole Source Aquifer program is:

Clay Chesney
Sole Source Aquifer Program Coordinator
Ground Water/UIC Section (6WQ-SG)
EPA Region 6
1445 Ross Avenue
Dallas, TX 75202
Tel. (214) 665-7128 FAX: (214) 665-2191
E-mail: chesney.claybourne@epamail.epa.gov

The State will obtain an electronic Geographic Information System database containing all of the designated Sole Source Aquifers within its state boundaries by contacting the EPA program contact person. If a Public Water Supply system is located within a designated Sole Source Aquifer area, that information will be reported to that system in its completed assessment.

EPA: Appendix S - Assessment forms for both ground water and surface water systems - Section A, Background: check the spelling for the word "assess" in the first sentence.

DEQ Reply: Correction done.

EPA: Appendix S - Assessment form for ground water systems - Section D, Determination of Water Well Sensitivity: Delete the word "of" from the opening sentence.

DEQ Reply: Correction done.

EPA: GENERAL COMMENT: EPA recommends that States integrate the development and implementation of Comprehensive State Ground Water Protection Programs (CSGWPP) and State Source Water Assessment Programs (SWAP) as set forth in the Agency's August 1997 State Source Water Assessment and Protection Programs Guidance. A CSGWPP can provide the means for federal and State programs that have ground water protection responsibilities (e.g. hazardous waste, pesticides, underground storage tanks, wetlands) to coordinate efforts and to focus on protection of priority ground waters, especially those used as a drinking water source. The State SWAPs do not have a legislated protection element whereas a CSGWPP could add the protection element to ground water resources that are covered by the SWAP program.

CSGWPPs are designed to: focus source control programs on preventing contamination of higher priority ground water resources; facilitate coordination among the many intrastate programs that protect ground water; and build a comprehensive approach to protection of ground water that includes all stakeholders. In addition, CSGWPPs strengthen State watershed approaches by providing an essential linkage between the State's ground water and surface water protection programs and by serving as a cross-media mechanism to ensure that public water systems dependent on ground water are targeted as a priority for federal and State prevention and remediation programs and efforts.

In the 1992 CSGWPP guidance document, States are encouraged to develop and implement programs as an integral part of watershed protection. In that guidance, EPA identified the six strategic activities that are the key elements of a CSGWPP. They are: 1.) establish a state ground water protection goal; 2.) establish priorities to direct all relevant programs and activities in the State to most efficiently and effectively achieve the ground water protection goal; 3.) define authorities and responsibilities across relevant programs state-wide for addressing established State ground water priorities; 4.) implement efforts to accomplish the State ground water protection goal consistent with the State priorities and schedules; 5.) coordinate information collection and management; and 6.) improve public education and participation in ground water protection to support the State ground water goal.

Additional information on EPA's CSGWPP is available on the Internet at:

http://www.epa.gov/OGWDW/csgwppnp.html

The EPA Region 6 contact for the Comprehensive State Ground Water Protection Program is:

Mike Bechdol, CSGWPP Coordinator
Ground Water/UIC Section (6WQ-SG)
EPA Region 6
1445 Ross Avenue
Dallas, TX 75202
Tel. (214) 665-7133, FAX (214) 665-2191
E-mail: bechdol.michael@epamail.epa.gov

DEQ Reply: The WHPP and the SWAP accomplish much of what the CSGWPP is designed to do.

EPA: GENERAL COMMENT: Non-point source of contamination from agricultural practices may represent a significant potential source of contamination to both ground water and surface water sources of drinking water. The Louisiana Department of Agriculture has developed a State Management Plan for pesticide use which addresses specific pesticides, their use, and areas of the State that are particularly vulnerable to these pesticides. Please enhance the State Source Water Assessment Program document by including a discussion of the State's Pesticide Management Plan and how the plan can be used to protect the State's sources of drinking water.

DEQ Reply: We have acquired the database of the Louisiana Department of Agriculture and Forestry (LDAF) that locates all of the Pesticide Monitoring Wells in the State. We will add this to our List of Databases in Appendix F. The State's Pesticide Management Plan has as its goal to manage the use of pesticides in order to prevent adverse effects on human health and the environment and to protect the environmental integrity of the State's water resources. The emphasis of this approach is on the prevention of contamination over remedial treatment. Priorities of the strategy focus on current or reasonably expected sources of drinking water and ground water that may be hydrologically connected to surface water. To insure the quality of the resource, the LDAF uses MCLs under the Safe Drinking Water Act (SDWA), water quality standards under the Clean Water Act (CWA), EPA Health Advisory (HA) numbers, or other approved health-based reference points as levels to activate appropriate mechanisms to protect ground water resources. Wells have been sampled on an annual basis since 1987. Originally there was a network of 50 wells. There are 2 out of service now, but replacement is intended.

For surface water, all of the pesticides used in the area of the surface water body are sampled. For ground water, all of the currently used pesticides in the state, as well as arsenic, are sampled.

Ground water problems in the State have not been from the application of pesticides, but from formulation sites, an improperly grouted domestic well, and the use of a hose in the process of sampling that was contaminated. There is a surface water atrazine problem in an area of the State that is being attended to. However, the average annual MCL for drinking water was not violated.

EPA: GENERAL COMMENT: The program document should include a discussion of how the Louisiana Department of Natural Resources' (LDNR) Underground Injection Control (UIC) program integrates with the Louisiana Source Water Assessment Program. The LDNR is listed as a member of the SWAP Committee. However, the Louisiana UIC program is not specifically mentioned in the document. This concern is addressed in comments provided by the Region 6 UIC program which were obtained through discussions with LDNR UIC staff. See Attachment 3.

DEQ Reply: As mentioned previously, the Louisiana Department if Natural Resources' (LDNR) Underground Injection Control (UIC) program has a representative on the Citizens and Technical Advisory Committee. Doyle Johnson is that representative and see his comments on injection wells as shown in the minutes of the Citizen and Technical Advisory Committee meetings of August 4, 1998 Appendix A, page 4 and September 14, 1998 on page 5.

Also, in Appendix F, injection wells are shown as a database potential source. We have obtained the DNR injection well databases for Class I, III, IV, and V injection wells.

The high risk Class V well's database for motor vehicle waste disposal wells shows none. Note from Doyle Johnson's comments of September 14 that a DNR survey of 3851 facilities with USTs identified none of these disposal wells in Louisiana. These are shallow wells, and the generally high water table in much of Louisiana may discourage the use of these wells.

Two industrial water disposal wells showed up, and they were seafood-processing companies. We have the location of these wells. There is no record of large capacity cesspools.

Since the ground water system's delineated area will be ground truthed in its entirety, and the aforementioned Class V wells will be in our data dictionary, we will record any such findings. Anything found that is not in the LDNR databases will be reported to them.

With regard to possible roles the Louisiana UIC Program might play in the implementation of SWAP in the State, we comment as follows:

1. We have been informed that the Louisiana UIC Program would like to do a detailed pilot study on injection wells in Calcasieu Parish hopefully to be supported by EPA funds. If this comes to fruition, any information obtained by the study will be helpful to the SWAP.

2. If the field assessment teams find injection wells and associated equipment in a SWPA, we would notify UIC staff of such so they may do a file review in this sensitive drinking water area and perform inspections and mechanical integrity tests if necessary.

3. We have changed the ranking of Class V injection wells to the higher risk category. By virtue of this, if they are found in a SWPA, they will be of high risk regardless of their construction elements.

4. Injection wells other than Class V are in the medium risk category. We believe this is justified based on the excellent history of injection wells relative to drinking water in Louisiana. See Doyle Johnson's comments at the August 4, 1998 meeting within the minutes, Appendix A, page 4. However, we will also report any of these injection wells found in a SWPA to the UIC staff for further study.

We have an oil and gas database for Louisiana. Likewise, we can report any oil and gas wells from that database or anything new from field investigation that falls in a SWPA to the LDNR Engineering Division for evaluation.

EPA: The following comments are being presented by EPA for the State to use in clarifying or enhancing its Source Water Assessment Program:

EPA: The program notes that Lake Charles and Calcasieu got 1997 WHPP awards. EPA recommends that these communities be used as demonstrations of how WHP programs can be incorporated into SWAP in terms of inventory update and CCR.

DEQ Reply: Our Wellhead Protection Program is continuing as always. Staff is assigned to the program, and they will be incorporating all of the approved WHPPs into the SWAP. They will work with the communities to make them aware of what we are doing, ask them to send updates, and explain the susceptibility analysis to them. The DEQ programs have been done to the standards necessary for them to meet the requirements of SWAP. SWAP and the DEQ WHPP will run concurrently, and both will get the attention they deserve.

The real problem with your recommendation has already been discussed under Section 5.6 - (page 15). If the Louisiana Rural Water Association programs are not brought up to the standards of the State program, these systems will not have the necessary susceptibility information for inclusion in the Consumer Confidence Reports. EPA and National Rural Water Association are aware of this problem as well as the Louisiana Rural Water Association. It is up to these agencies to correct this problem. It is beyond the control of the State.

EPA: The program would be strengthened if the membership of the advisory committee was broadened during implementation to include statewide representation (particularly northern LA) and representation by interests which will represent typical PSOCs. The program would also be strengthened by a brief description of the ongoing role of the advisory committee.

DEQ Reply: The League of Women Voters representative on the Citizens and Technical Advisory Committee has recommended someone in Monroe and Shreveport. We will consider these people for the committee when we need committee advice and convene another meeting. We do not want the committee much larger than it is. We want a workable committee, and we already have that. Our public meetings were conducted all over the State, and public comments were taken into consideration when formulating the program.

EPA: Quarterly release of Phase I results and completion of assessments by the year 2003 may create a bottleneck of communities seeking to establish WHP programs. The State intends to implement the WHP throughout the assessment period by request only and then prioritize systems for assistance through its Phase II analysis. The program's discussion of leveraging resources spent on assessments towards protection would be strengthened by clarifying the resources that could be devoted to this effort in the near term.

DEQ Reply: The State does not intend to implement the WHP throughout the assessment period by request only. We have chosen the water systems that DEQ will bring into the WHPP throughout the period of SWAP. We have also coordinated with the Louisiana Rural Water Association as to the water systems that they will bring into the WHPP during the period of SWAP. Again, the Louisiana WHPP will proceed concurrently with SWAP. Protection is an integral part of the WHPP and will take place as a part of it.

EPA: The State has indicated that problem PSOCs identified during the assessment will be referred to the appropriate agency for action. The program would be strengthened by a description of coordination efforts at the State level to ensure appropriate action is being taken.

DEQ Reply: Attached is the Contact List we hand out to communities in the WHPP, and that will be distributed as part of the SWAP. Several of these agencies and divisions within DEQ have already cooperated with us in getting problems corrected that were noted during WHPP field assessments. See Attachment # 3.

EPA: For the Mississippi River, please clarify proposed setback and critical area. Clarify whether the assessment will be for individual intakes or for the corridor as a whole, i.e., will there be one report or will it be PWS specific?

DEQ Reply: The west bank of the Mississippi River has a levee to the state border with Arkansas. The east bank of the Mississippi River has a levee as far north as a short distance north of Baton Rouge. Most drainage into the Mississippi River comes from the east side, and it is coming from the State of Mississippi. We have requested information on PSOCs along the river from the State of Mississippi extending from their state border with Louisiana to where the Louisiana and Arkansas borders meet. We have not received a response to this request and will have to follow up. This portion of the river will have a critical setback area of 1000 feet from the edge of the river if the State of Mississippi will cooperate to this extent. Where the river has levees, PSOCs will be assessed within the batture. We will be doing a database search only in these areas. If we find ground truthing is necessary in an area, we will do this as a last resort. Thus, for systems with intakes in the river, the delineation will be along the banks of the river from the Louisiana State line (northern boundary). The delineation for each intake will include the portion of the overall delineation that is upstream of that intake. For example, the delineation for Port Sulphur will encompass the entire delineation for the Mississippi River; the delineation for New Orleans will encompass the delineation from the intake at New Orleans to the state line, etc. As mentioned in the program submittal, the problems with regard to drinking water intakes within the river in Louisiana have stemmed from spills and accidents on the river, so it is not just the batture area that we are concerned with. All of the drinking water intakes are south of Baton Rouge, and this portion of the river will be scrutinized closely.

EPA: The State should clarify (Appendix Q, page 5, that higher risk PSOCs have a rank of 1, medium risk have a rank of 0.5 and the lower risk have a rank of 0.1 which is then adjusted by distance).

DEQ Reply: The weighting of Potential Sources of Contamination at the top of page 6 in Appendix Q explains this in our opinion.

EPA: With regard to up dating, please clarify if new systems will be assessed.

DEQ Reply: As we approach the end of the contract with the firm doing the field assessments, we will request an update of the database of public water supply systems (ground and surface water) from the Louisiana Department of Health and Hospitals (LDHH). Any new systems will be picked up. We have set up the contract to allow for more systems than we currently have in the LDHH database.

EPA: Please clarify that "non-point sources" will be more clearly identified in ground water assessments.

DEQ Reply: We have a Non-Point Source Section within DEQ. The head of this section was on the Citizens and Technical Advisory Committee. One or another staff members from this section attended the SWAP statewide public meetings. We have a statewide Land Use Map that was referred to us by the non-point staff for use in the SWAP. This map will be used for both surface water and ground water purposes and is listed in Appendix F under databases. With regard to agriculture, we will use the aforementioned map along with current information from the network of pesticide and herbicide monitoring wells around the state discussed above in reference to the first GENERAL COMMENT. We will add the pesticide monitoring database to the list in Appendix F. The Non-Point Source (NPS) Section of DEQ is compiling an assessment of the impacts of sand and gravel mining operations on the waters of the state. Since these are often large pits, there is an advanced potential for ground water pollution due to their depth. Thus, the map and coordinated effort with the NPS Section will enhance the identification of this clean ground water threat. Septic systems are considered a NPS threat also, not only to ground water, but to surface water. These are being addressed as part of the SWAP. If EPA locates a database with location information on Animal Feeding Lots/Dairies as discussed above under Appendix F; this would be helpful in addressing NPS problems relative to both surface water and ground water.

EPA: In the list of PSOCs, please explain the term "chemical".

DEQ Reply: It should have read chemical plant. Correction done.

EPA: The State should consider moving "oil/gas well and associated drilling activities, sanitary landfill, sewer treatment plant, metal plating/metal working, oxidation pond" PSOCs to the High Risk ranking for ground water sources.

DEQ Reply: See our reply relative to your first comments on Appendix N.

EPA: How will the State handle diversions in its surface water delineation and inventory?

DEQ Reply: This is being handled by the local knowledge of the DEQ regional staff. Conferences with them have already been beneficial in this respect, as the moving of water from one place to another is not always obvious.


EPA: Attachment 3

From: MIKE FRAZIER

To: BECHDOL-MICHAEL

Date: 4/8/99 8:20am

Subject: LA SWAP -Forwarded -Forwarded

I have reviewed the attached memo from Doyle Johnson (LDNR) and agree with his comments. His suggestions appear thorough and could provide important information for Louisiana's SWAP.

CC: Phil Dellinger, ALLEN-ERLECE, Ken Williams

Attachment 3 (cont.)

April 7, 1999

To: Mr. Ken Williams

SWAP Administrator - EPA Region 6

From: Doyle Johnson

Engineer Manager - Injection & Mining Division

Re: Louisiana SWAP

We have reviewed the Louisiana Source Water Assessment Program (SWAP) proposal that had been forwarded to us from EPA Region 6 Headquarters in Dallas.

With regards to the possible roles the Louisiana UIC program might play in the implementation of SWAP in the state, we would like to offer the following suggestions:

1. During the Field Data Collection phase of the program, UIC field personnel could be made available to assist identifying and categorizing any Significant Potential Sources of Contamination (SPSOC) related to injection facilities within the areas of concern. The types of SPSOC that might be encountered other than the well itself would be storage tanks, flowlines, injection pumps, etc. The field personnel could also facilitate the SWAP assessment team by notifying the operator of the time of inspection beforehand so they or their representative could be present to allow the team access to the facility and explain its layout.

2. In addition, UIC field personnel should be present to inspect any existing Class V wells discovered in the areas under review.

3. The Potential Susceptibility Ranking system mentioned in the proposal should take into consideration certain well-specific construction an operational criteria in assigning the ranking. The system might be amended to assign a vulnerability ranking to the well based on such factors as the number of casing strings set and cemented across the base of the USDW, the amount of pressure on the well, the extent of flow lines in the Source Water Protection Area (SWPA), etc. UIC personnel in the Baton Rouge office would have access to well file data in order to assess the construction of wells located the SWPA for potential hazards to the drinking water supply. All applications for injection wells permitted under the UIC program require a diagram of the facility associated with the well showing all related equipment present at time of construction; however, the current mechanical arrangement of the facility should be verified by on site inspection.

4. For injection wells located in a SWPA, a more frequent schedule of mechanical integrity testing other than the current requirement of testing once every five years might be considered.

The UIC section of the Injection and Mining Division does not regulate producing wells, which may actually turn out to be the predominant type of oil and gas industry related wells discovered in the SWPA. These wells could pose a greater hazard to drinking water sources and might require a more extensive review than injection wells for the following reasons:

1. Many of the wells were drilled and completed without any consideration given to the actual depth of the USDW in the vicinity of the well. State regulations only require that surface casing be set a cemented to a prescribed depth based on the permitted total depth of the well. In many cases this resulted in exposed USDW below the surface casing shoe. Also, state regulations do not require that these wells be tested for mechanical integrity on a regular basis. It is suggested that these wells also be assigned a vulnerability ranking based on construction and operating conditions.

2. The locations of production facilities and an inventory of the equipment found in them are generally not contained in Engineering Division files. Any assessment of these sites to identify SPSOC will require an on site inspection. These inspections could be assisted by Engineering Division field personnel in the same manner that Injection and Mining field personnel could render assistance at injection facilities.

3. The SWAP proposal discussed doing a review of Pipeline Division maps to locate pipeline crossing under surface water bodies. However, the pipelines regulated by this division are only those considered to be in the transportation mode, which is downstream to field production. It will not include field-gathering lines that run from individual wells to a central gathering facility within the field. The locations of these lines will require on site inspection.

You can contact Brent Campbell of the Engineering Division at 225-342-5524 to discuss their possible participation in the SWAP program. You can contact me at 225-342-5526 for questions concerning Injection and Mining participation.

Thank you for the opportunity to comment on this matter.

DEQ Reply: See our reply to the second GENERAL COMMENT above.


EPA: Attachment 1 and Attachment 2

DEQ Reply: See the changes below in bold or strike through.

Attachment 1

SIGNIFICANT POTENTIAL SOURCES OF CONTAMINATION AFFECTING GROUNDWATER

Higher Risk

  • Abandoned Water Wells
  • Above Ground Storage Tank
  • Agriculture Chemical- Formulation/Distribution (pesticide/insecticide)

Animal Feed Lots/Dairies

  • Battery Recyclers
  • Body Shop/Paint Shop
  • Cercla Site
  • Chemical Plant
  • Class V Injection Wells
    • Motor Vehicle Waste Disposal Wells
    • Industrial Waste Disposal Wells
    • Large Capacity Cesspools
  • Dry Cleaner/Laundromat
  • Inactive/Abandoned Site

Military Facility

  • Petroleum (includes bulk plants)
  • Septic System
  • Truck terminal
  • Underground Storage Tank
  • Wood Preserving Plant

Medium Risk

  • Airport
  • Animal Feed Lots/Dairies (1)
  • Auto/Boat/Tractor/Small Engine Shop
  • Class I Injection Wells - Disposition of Industrial and Hazardous Waste Liquids
  • Class II Injection Wells - Oil and Gas Related Liquids
  • Class III Injection Wells - Fluids to Mine Salt or Sulphur
  • Furniture Stripping
  • Inactive Water Well
  • Military Facility (1)
  • Oil/Gas Well and Associated Drilling Activities (1)
  • Oxidation Pond
  • Promiscuous Dump
  • Railroad Yard - Switching (1)
  • Railroad Yard- Loading and Offloading (1)
  • Railroad Yard- Maintenance (1)
  • Sand/Gravel Pit
  • Sanitary Landfill (active or inactive)
  • Surface Impoundments
  • Sewer Treatment Plant

Lower Risk

  • Asphalt Plant
  • Car Wash
  • Cemetery
  • Funeral Home
  • Golf Course (2) or (1)
  • Hospital
  • Injection Well (1)
  • Irrigation Well
  • Lumber Mill
  • Metal Plating/Metal Working (2)
  • Nuclear Plant
  • Oxidation Pond (1)
  • Paper Mill
  • Pipeline Compressor Stations
  • Plant Nursery
  • Port Facilities
  • Power Plant
  • Printing Shops (2) or (1)
  • Salvage Yard (2) or (1)
  • Sanitary landfill (active or inactive) (2) or (1)
  • Sewer Lift Station
  • Sewer Treatment Plant (1)

Railroads, Pipelines and Sewer Lines, Roads, and Hazardous Waste Transportation Routes are Line Potential Sources of Contamination subject to spills and leaks. They will be rated based on a pertinent number per square mile in the delineated area. (Also septic systems).

(1) - Consider moving to "Higher Risk"

(2) - Consider moving to "Medium Risk"

(3) - Consider moving to "Lower Risk"

Attachment 2

SIGNIFICANT POTENTIAL SOURCES OF CONTAMINATION AFFECTING SURFACE WATER TO BE GROUND TRUTHED

Higher Risk

  • Above Ground Storage Tank
  • Agriculture Chemical- Formulation/Distribution (pesticide/insecticide)
  • Animal Feed Lots/Dairies
  • Battery Recyclers
  • Body Shop/Paint Shop
  • Bridges and Bridge Abutments
  • Chemical Plant
  • Class V Injection Wells
    • Motor Vehicle Waste Disposal Wells
    • Industrial Waste Disposal Wells
    • Large Capacity Cesspools
  • Dry Cleaner/Laundromat
  • Military Facility
  • Petroleum (includes bulk plants)
  • Truck terminal
  • Underground Storage Tank
  • Wood Preserving Plant

Medium Risk

  • Airport
  • Animal Feed Lots/Dairies (1)
  • Auto/Boat/Tractor/Small Engine Shop
  • Furniture Stripping
  • Injection Wells Other Than Class V
  • Military Facility (1)
  • Plant Nursery
  • Promiscuous Dump
  • Railroad Yard - Switching (1)
  • Railroad Yard- Loading and Offloading (1)
  • Railroad Yard- Maintenance (1)
  • Sewer Treatment Plant

Lower Risk

  • Asphalt Plant
  • Car Wash
  • Cemetery (1)
  • Funeral Home
  • Golf Course (2) or (1)
  • Hospital
  • Injection Well (2)
  • Irrigation Well
  • Lumber Mill
  • Marina
  • Metal Plating/Metal Working
  • Nuclear Plant
  • Oxidation Pond
  • Paper Mill
  • Pipeline Compressor Stations
  • Plant Nursery (1)
  • Port Facilities
  • Power Plant
  • Printing Shops
  • Salvage Yard (1)
  • Sand and Gravel Pits
  • Sanitary landfill (active or inactive)
  • Sewer Lift Station
  • Sewer Treatment Plant (2)
  • Ship Building Operations

** Any facility type listed here that is found in a database should be checked for data accuracy but should be counted under the database inventory. It SHOULD NOT be counted under both the ground truth survey and the database search.

(1) - Consider moving to "Higher Risk"

(2) - Consider moving to "Medium Risk"

(3) - Consider moving to "Lower Risk"


DEQ Attachments Referenced in Responses

Attachment #1 - Sample Assessment Report  - See Document Appendix V

Attachment #2 - Consumer Confidence Report Rule - See Document Appendix U

Attachment #3 - Contamination Source Control Contacts - See Document Appendix V

Attachment #4 - Remote Recharge Area Diagram  - See Document Appendix J (Map View)

Attachment #5 - Remote Recharge Area Diagram - See Document Appendix J (Cross Section)

Attachment #6 - Discussion Items for Ground Water Protection Council - See Below (highlighted text) 

Attachment #7 - SWAP Fact Sheets - See Document Appendix V


ATTACHMENT #6

Discussion Items for Ground Water Protection Council

Tuesday, March 24, 1998 Ground Water Protection Division

(Taken from Regional and State comments on the February 23 Version of the Headquarters Protocols)

  1. Major Issues
  1. Overall Issues - Structure and Purpose of HQ Protocols
  • Must/Needs To Column -- "Must" requirements and the "Needs To" requirements for submittals and functional equivalents ? separate columns?
  • Supporting Information Column - Optional items helpful to Headquarters staff when reviewing ? keep it, or eliminate it, or place in another appendix, or a separate sheet just for Headquarters use?
  • Advisory Committee Purposes and Submittal Minimum ? When there is not committee consensus, how should the submittal reflect the Advisory Committee's recommendations or discussion, or majority vs. minority reports. Findings and conclusions could come in many forms and one option is for the submittal to reflect the issues on which conclusions were made or issues the state needed to address and how the state addressed them. Must the state respond on the record as opposed to just describing the advice?
  1. "Assessments for the Protection and Benefit of Public Water Systems" - Certain Cases
  • Remote Recharge Areas -- What is an acceptable approach for protection of wells in confined aquifers that receive recharge from areas not within the wellhead protection areas for those wells? Many states use different methodologies to define wellhead protection areas for confined and unconfined aquifers, as long as they are at least as protective of the wells in confined aquifers as they are of the wells in unconfined aquifers. The following example illustrates the issue:

State A's source water assessment program has stated that wells drawing from confined aquifers will have wellhead protection areas defines by an arbitrary fixed radius of 1 mile; and wells drawing from unconfined aquifers will have wellhead protection areas defined by an arbitrary fixed radius of 10 miles. If a confined aquifer has a "remote" recharge area that is 10 miles or less from a drinking water well, then that recharge area could be considered as part of the source water protection area for that confined well. If the remote recharge area for the confined aquifer is greater than 10 miles form the well, then that state might not consider the recharge area as part of the source water protection area for the well.

  

Louisiana Department of Environmental Quality 602 N. Fifth Street Baton Rouge, LA 70802
Call or e-mail a hotline · Office Address/Phone listing · Locate a DEQ employee
Call 1-866-896-LDEQ or e-mail our Customer Service Center with questions or comments