Source Water Assessments in Oregon - Implementation Plan

• Sheree Stewart, Oregon Department of Environmental Quality
• Dennis Nelson, Oregon Department of Human Services (currently the Oregon Health Authority (OHA) Drinking Water Program)

Note: Oregon’s Implementation Plan was completed and accepted by EPA in 1999 and governed the completion of Source Water Assessments between 2000 and 2005. The Oregon Health Division referred to in this document has had several name changes: it was the Department of Human Services until 2011 and is currently the Oregon Health Authority. 

The federal Safe Drinking Water Act (SDWA) Amendments of 1996 provided staff for the Department of Environmental Quality (DEQ) and the Oregon Health Division (OHD) to address new requirements. The Amendments mandated that states agencies conduct "source water assessments" for every public water system. This means that DEQ and OHD must delineate the groundwater and surface water source areas which supply public water systems, inventory each of those areas to determine potential sources of contamination, and determine the most susceptible areas at risk for contamination. With the help of a citizen's advisory committee, a "Source Water Assessment Plan" was developed to describe the approach Oregon will take to meet the requirements over the next four years. The plan was approved by the U.S. Environmental Protection Agency in July 1999.

This Implementation Plan summarizes the DEQ and OHD staffing for the Source Water Assessments, describes the time constraints for the assessment tasks, and provides a list and prioritization of public water systems receiving Source Water Assessment Reports.

Source Water Assessments Who gets them?

Approximately 75% of Oregons citizens get their drinking water from public water systems. Public water systems in Oregon are regulated by the Oregon Health Division (OHD). In Oregon, public water systems with greater than 3 hookups, or serving more than 10 people, year-round are regulated. There were approximately 3550 listed total public water systems in Oregon as of mid-1999. Of the total, 3175 of these are groundwater wells or springs, and 375 of these are surface water intakes on rivers and reservoirs. The 50 largest public water systems, serving >10,000 each, supply drinking water for 60% of the population of the state. In terms of sources of drinking water by population, 50% of Oregons citizens rely solely on groundwater (mostly small systems). Approximately 30% rely solely on surface water. These are mostly large systems. Another 20% rely on surface water and groundwater, as an emergency backup supply or combination system.

Federal funding for the Source Water Assessments will be used to address those public water systems regulated by the Safe Drinking Water Act. These are the systems that have at least 15 hookups, or serve more than 25 people year-round. There will be 2656 public water systems addressed by this new program over the next three years. Of those, 1156 will receive full assessments and 1500 will receive limited assessments---assistance through focused outreach from OHD. In addition to the 1452 transient noncommunity water systems receiving limited assessments, we have added 48 schools and day cares to the list that serve less than 25 people, but are regulated by the state here in Oregon. The 48 schools and day care facilities will get limited assessments.

Attached to this plan is a list of Oregon public water systems which will receive full source water assessments (see List of Public Water Systems to Receive Source Water Assessments). This list was generated from the June 1999 OHD public water system database. It represents the list of systems that were active at the time of Oregon's Source Water Assessment Plan approval by EPA. Present resources for implementing the program will likely prohibit us from adding to this list as new public water systems are established in Oregon over the next 3 years. A list of the transient public water systems receiving limited assessments can be obtained from OHD.

The numbers of public water systems by system type are as follows:  

• 2656 public water systems receiving Source Water Assessments
  • 1156 full assessments
    • 816 Community systems (>15 hookups, or >25 people, year-round)
      • 671 groundwater systems
      • 110 surface water systems
      • 35 both groundwater and surface water
    • 340 Nontransient Noncommunity systems (<15 hookups, >25 people at least 6 months/year)
      • 327 groundwater systems
      • 10 surface water systems
      • 3 both groundwater and surface water
  • 1500 limited assessments (OHD provides technical assistance)
    • 1452 Transient Noncommunity systems (campgrounds, parks, restaurants, rest areas, etc.)
      • 1394 groundwater systems
      • 55 surface water systems
      • 3 combined systems
    • 48 Schools and Day Care Facilities (small public water systems <25 people, but regulated by OHD)
      • 327 groundwater systems
      • 10 surface water systems
      • 3 both groundwater and surface water

Staff Time Estimates How many hours?

DEQ and OHD have 11 federally-funded staff positions to implement the requirements, including program coordination, computer database development, GIS development, technical assistance, contamination source inventories, surface water delineations, groundwater delineations, and susceptibility analyses. OHD will conduct the groundwater delineations and aquifer sensitivity analyses. DEQ will be responsible for the surface water delineations and inventories for all 1140 systems. Both agencies have responsibilities for developing databases, geographic information systems, and Web sites to provide technical assistance and access to the results.

The time to accomplish each task was originally estimated in early 1998 in order to develop the agencies FTE/budget request packages. Lacking specific procedures, the estimates were very rough. To develop the estimates, we relied on the staff time estimates of the previously approved procedures for delineation and inventory in the wellhead protection approach. Those estimates demonstrated that the OHD and DEQ Source Water Assessment work would require the maximum available set-aside money from the FY97 Safe Drinking Water Act funds. The 11 new positions for OHD and DEQ are budgeted to make maximum use of the funds over the next 3 years. The Source Water Assessments must be completed by January 2003.

The limitations of positions and staff time for each agency now serves as a limitation of the average time we will be able to spend on each public water system. Table 1 lists these time constraints or budgets for each public water system receiving a source water assessment.

Table 1. State agency time constraints for each public water system

Source Water Assessment Task	Hours/ Public Water System
Obtain surface water intake GPS location (includes travel time*)	4 hours
Initial public water system contact/field visit*	2 hours
Obtain/prepare GIS or topo base map	1-2 hours
Delineate the groundwater source area/sensitivity analysis for systems < 500	2-5 hours
Delineate the groundwater source area/sensitivity analysis for systems > 500	25-65 hours
Delineate the surface water watershed/sensitive areas	20 hours
Query 7 databases for sensitive areas	2 hours
Potential contamination source inventory (includes field work*, meetings and creating ArcView map)	15 hours
Generate final map product (ArcView/GIS)	4 hours
Report writing/preparation of SWA Report for each system (includes setup for public access)	5-15 hours

*Trips to public water systems are consolidated to minimize travel time to each geographic area.

The initial development of procedures and set-up has taken approximately six months after the new positions were hired. For example, the development and coordination of the Source Water Assessment procedures at DEQ have taken approximately 6200 hours of staff time. Designing and setting up the Access database to track progress and results will involve some 1600 hours of staff time.

Once the procedures are in place, DEQ and OHD will be able to spend an average of 40 staff hours on each of the 1156 public water systems in the state to conduct the full assessments. It is essential that we look for ways to streamline the tasks. Our goal will be to find a way to complete a consistent, useful "Source Water Assessment Report" for each system within the task timeframe that allows us to get them all done by January 2003.

Implementation Priorities and Schedule

There is a significant amount of interest in drinking water protection (and all water quality) issues in Oregon. When the DEQ citizen's advisory committee helped determine the approach for how the Source Water Assessments would be done in Oregon, the committee suggested ways to prioritize the work. One consistent recommendation in prioritizing was to promote citizen involvement. The public water systems that have significant community interest in developing a Drinking Water Protection Plan are our highest priorities. For example, this would include the communities that have established water quality advisory committees, watershed council involvement, or demonstrate a commitment to use the Source Water Assessment results to move forward with protection of their public water system. Agencies have solicited names of the top priority communities through a variety of ways as we developed the program. Another high priority grouping will be those systems that have had significant detections of contaminants in their public water system monitoring results or have known high risk contamination threats near their intake or wells. Systems that are performing their own assessments form the next grouping and technical assistance to these systems will continue concurrently with our other priorities. TMDL and Groundwater Management Areas will dictate the geographic areas for determining the priorities for the other 1100 public water systems not in Tier 1 and 2.

TIER 1 Public water systems with significant community interest or contamination threats

These communities (approximately 85) have requested high priority status based on significant community involvement or interest.   The following Source Water Assessments are scheduled to be done by mid 2000:

• Surface water systems include:
  • Astoria
  • Canby
  • Clackamas River Water
  • Estacada
  • Lebanon (intake)
  • Molalla
  • Oakland
  • Reedsport
  • Scappoose
  • Seaside
  • South Fork Water Board
  • Sutherlin
  • SW Lincoln Co (Waldport)
  • The Dalles (intake)
• Groundwater systems include:
  • Avion Water Company Deschutes Valley WD
  • Banks
  • Bend Water Department
  • Bonneville Power (Celilo)
  • Brookings
  • City of Redmond
  • City of Rogue River
  • City of Wood Village
  • Cove
  • Deer Park Water Assoc
  • Dufur
  • Falcon Cove Beach WD
  • Grass Valley
  • Halfway
  • Independence
  • Keizer
  • Knappa Water Association
  • Lafayette
  • Lebanon (wells)
  • Malin
  • Maupin (springs)
  • McNulty Water Assoc
  • Merrill
  • Monmouth
  • Monroe
  • Mt. Angel Abbey
  • Newberg WD
  • North Plains
  • Oak Grove Water Co.
  • Ogden-Martin
  • Pendleton
  • Pine Grove WD
  • Prineville
  • Rivergrove Water District
  • Riviera Mobile Park
  • Roats Water System
  • Rufus
  • St. Helens
  • Suburban East Salem
  • The Dalles (wells)
  • Valley Vista WD
  • Warren Water Assoc
  • Wilsonville (wells)
  • Woodburn
  • Josephine County Schools (includes 15 schools)
  • Lane Co. Systems (McKenzie and Mohawk Basins)
    • Rainbow Park
    • Lazy Days MHP
    • McKenzie Palisades
    • Vida-Lea Mobile
    • Deerhorn Comm
    • Camp Creek Elem.
    • Mohawk Elem.Blue River WD
    • Shangri-La WD
    • Shenandoah
    • Walterville Elem

This is a partial list of public water systems with significant contamination detects or threats. These 10 communities will also be high priority Tier 1 systems:

• Albany (nitrates)
• Bandon (bacteria and sediments)
• Burns (VOCs)
• Coastal St Helens Chemical (nitrates)
• Damascus (VOCs)
• Lakewood Estates (VOCs)
• Lebanon (toxics)
• Milwaukie (VOCs)
• Port Orford (nutrients and sediments)
• Spray (MTBE/petroleum)

TIER 2 Public water systems conducting their own assessments

Many public water systems want to conduct their own source water assessments. With dedicated resources and extensive local knowledge, in most cases, their work is equivalent or may be better than DEQ and OHD will accomplish in doing the assessment for them. It is important to enable those communities that want to be proactive in implementing the source water assessment tasks with local resources be given an opportunity to do so. DEQ and OHD can delegate the assessment tasks to any public water system that demonstrates the ability to do them. For the communities that have fulfilled filtration exemption requirements, the information for the source water assessment has already been gathered and will simply need to be compiled and made available to the public (if it is not already).

While public water systems are working on their own assessments, DEQ and OHD staff will provide technical assistance as requested. The time limits for agency staff must be consistent with what is presented in this Implementation Plan. For example, neither agency can commit resources to conduct complex or extensive modeling for delineations beyond the proposed assessment methodologies.

Concurrent with our Tier 1 priorities, we will begin providing limited assistance to the following Tier 2 communities that have initiated their own source water assessments, performed filtration exemption reports, or are preparing their own Drinking Water Protection Plans:

• Baker City (filtration exemption)
• Beaverton (ASR wells)
• Bend (filtration exemption)
• Boardman
• Clackamas (ASR wells)
• Eugene (McKenzie watershed)
• Hubbard
• Medford
• Portland (Bull Run; filtration exemption)
• Portland (Columbia wellfield)
• Salem (ASR wells)
• Salem (Santiam watershed)
• Tualatin Valley (ASR wells)
• Veneta

TIER 3 TMDL and Groundwater Management Area program priorities

For the approximately 1100 remaining source water assessments to be done in Oregon, we will prioritize the work in basins where DEQ is conducting "Water Quality Management Plans" to address Total Maximum Daily Load (TMDL) requirements for 303(d) listed streams, and within the designated Groundwater Management Areas. The systems not in the priority basins will be done last.

The data from the source water assessments will feed directly into future TMDL efforts in the municipal watersheds. The results of the inventory and susceptibility analysis will be very useful for the TMDL data collection and scoping phases. The drinking water intake locations will be used to identify beneficial uses in developing the TMDLs.

The anticipated start date for the Tier 3 systems is mid 2000. Source water assessments will be prioritized within the sub-basins scheduled for initial TMDL work over the next three years (prior to January 2003). The assessments will be prioritized in the following order within each of the DEQ Regions:

• Eastern Region
  Upper Grande Ronde, Upper Klamath Lake, Williamson, Sprague, Umatilla, Wallowa, Mid-Columbia-Hood, Willow, Mid-Columbia-Lake Wallula, Walla Walla, Imnaha, Lower Snake-Asotin, Lower Grande Ronde, Hells Canyon, Upper Deschutes, Upper Quinn, Little Deschutes, Upper Deschutes, Lost River, Alvord Lake
• Northwest Region
  Tualatin, Wilson-Trask-Nestucca, Nehalem, Necanicum, Lower Columbia-Youngs, Lower Columbia-Clatskanie
• Western Region
  Applegate, Umpqua, North Umpqua, South Umpqua

Source water assessments for groundwater systems will be prioritized within the following Groundwater Management Areas:

• Lower Umatilla Basin
• Northern Malheur County

TIER 4 Technical Assistance

Many public water systems and communities in Oregon have initiated drinking water protection efforts. Six public water systems have already received DEQ certifications for their completed Drinking Water Protection Plans. For these systems, there is no need to do a source water assessment since the assessment results are part of the final plan. The delineation, inventory, and the (equivalent of a) susceptibility analysis will need to be made accessible to the public. DEQ and OHD will assist these communities in preparing the information for public access to ensure the data is available by January 2003. For the following systems with certified plans, DEQ will continue providing technical assistance to them as they implement their protection plans.

• Coburg (certified 1998)
• Junction City (certified 1998)
• Powell Valley Road Water District (certified 1999)
• Rogue Lea Estates (certified 1999)
• Springfield Utility Board (certified 1999)
• Rainbow Water District (certified 1999)

Assistance from large public water systems

Due to the serious time constraints for state agencies to complete the assessments, DEQ and OHD will be asking the larger public water systems to assist in conducting their assessment. For those serving over 20,000 customers, we will ask the public water system to perform the majority of their own source water assessment. For those serving over 10,000, we will ask for a minimum of some local assistance to perform the inventory. DEQ and OHD will provide more detailed guidance to these systems by mid 2000, including the options for how to accomplish the assessments and the minimum requirements for public accessibility to the results.

All Source Water Assessments must be completed by January 2003 in Oregon.

Need More information?

This Implementation Plan has been prepared to summarize how state agencies in Oregon will prioritize the public water systems in conducting the source water assessments . For additional information, to obtain a copy of Oregon's "Source Water Assessment Plan", or to arrange a presentation on drinking water protection, contact Sheree Stewart, Drinking Water Protection Program Coordinator, Oregon DEQ, 503-229-5413.

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