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4.1. ERMUSR 01-08-2013 Elk River*z,-_-_, Municipal Utilities UTILITIES COMMISSION MEETING TO: FROM: Elk River Municipal Utilities Commission David Berg—Water Superintendent John Dietz, Chair Daryl Thompson, Vice Chair Al Nadeau, Trustee MEETING DATE: AGENDA ITEM NUMBER: January 8, 2013 4.1 SUBJECT: Wellhead Protection Plan Amendment Approval for Re-Submission DISCUSSION: We have revised our Wellhead Protection Plan (WHP)to meet the Minnesota Department of Health's recent critiques of our submission. A few of our action activities were adjusted to address Well 5's moderate vulnerability, more specifically with education for potential hazard properties around Well 5's vulnerability zone. Overall, not much was changed, but a few clarifying statements were inserted to meet standards and a couple adjustments to action items were necessary to meet requirements. REQUESTED ACTION: Commission approval of the Wellhead Protection Plan ATTACHMENTS: • Wellhead Protection Plan Document PONEEI BI ® Page 1 of I NATURE Reliable Public P O W E R E D T o S a S E R V E Power Provider WELLHEAD PROTECTION PLAN FOR THE ERMU City of Elk River •// Elk River ..........:. ...„, Municipal Utilitie s This plan is in effect from: January 8, 2013 Forward - This document presents the WHP plan for the Elk River Municipal Utilities that will help provide for an adequate and safe drinking water supply for community residents. It contains the following components - • Assessment of the data elements used to prepare the plan • Delineation of the wellhead protection area, • Delineation of the drinking water supply management area, • Assessments of well and drinking water supply management area vulnerability, • Impact of changes on the public water supply well(s) used by the water supplier • Issues, Problems, and Opportunities affecting the well(s), well water, and the drinking water supply management area; • Wellhead protection goals for this plan; • Objectives and plan of action for achieving the wellhead protection goals; • Evaluation program for assessing the effectiveness of this plan;and • Contingency strategy to address an interruption of the water supply. Water Supply Wells Included in This Plan Unique Number Well Name or Number Use/Status 271176 Well#2 P 2211176 Well#3 P 481794 Well#4 P 537682 Well#5 P 580320 Well#6 P 664852 Well#7 P 694499 Well#8 P 757624 Well#9 P IP= Primary Water Supply Well E=Emergency Backup Well S=Seasonal Well WHP Plan Manager Ms.Angela Hauge, Water Operator 13069 Orono Parkway,P.O. Box 430 Elk River, Minnesota 55330-0430 Phone: 763.441.2020 Email: ahauge(a,elkriverutilities.com Dave Berg, Water Superintendent 13069 Orono Parkway, P.O. Box 430 Elk River, Minnesota 55330-0430 Phone: 763.441.2020 Email: dberg(u,elkriverutilities.com • ii WHP Team Members Angela Hauge, Water Operator, Elk River Utilities Dave Berg, Water Superintendent, Elk River Utilities Robyn Hoerr, Planner Tom Sagstetter, Co-Manager Conservation & Key Accounts Manager Bill Bronder, SWCD Manager Written By Teri Osterman, MRWA Hydrologist Gail Haglund, MDH/SWP Unit iii Table of Contents Page Executive Summary vi Chapter 1.0 Introduction 1 Chapter 2.0 Identification and Assessment of the Data Elements Used to Prepare the Plan Chapter 3.0 Delineation of the Wellhead Protection Area, Drinking Water Supply Management Area, and Vulnerability Assessments 4 Chapter 4.0 Assigning Risk to Potential Contamination Sources 5 Chapter 5.0 Impact of Land-and Water- Use Changes on the Public Water Supply Well(s) 6 Chapter 6.0 Issues, Problems, and Opportunities 7 Chapter 7.0 Existing Authority and Support Provided by Local, State,and Federal Governments 9 Chapter 8.0 Goals 12 Chapter 9.0 Objectives and Plan of Action 14 Chapter 10.0 Evaluation Program 19 Chapter 11.0 Contingency Strategy 19 Chapter 12.0 Glossary of Terms 20 Chapter 13.0 List of Acronyms 21 Chapter 14.0 References 22 Chapter 15.0 Figures 23 List of Figures Figure 1: Regional Location Map 24 Figure 2: ERMU Municipal Well Location Map 25 Figure 3: Groundwater Flow Field Map 26 Figure 4: Groundwater Flow Field Map 27 Figure 5: Wellhead Protection Areas Map 28 Figure 6: Drinking Water Supply Management Area 29 Figure 7: ERMU DWSMA Map 30 Figure 8: Surficial Geology of the DWSMA 31 Figure 9: DWSMA Vulnerability 32 Figure 10: Sherburne County Map 33 Figure 11: Anoka County Map 34 Figure 12: Wright County Map 35 Figure 13: Otsego City Map 36 Figure 14: Elk River Land Use Map 37 Figure 15: Elk River Zoning Map 38 Figure 16 Well 5 IWHPZ Map 39 Figure 17 Well 5 Sewer/Sanitary Map 40 iv List of Tables Table 1: Assessment Results for the Data Elements 2 Table 2: Potential Contamination Sources and Assigned Risk for the IWMZ 6 Table 3: Point Sources of Potential Contamination and Assigned Risk for the Remainder of 6 the DWSMA Table 4: Expected Land and Water Use Changes 7 Table 5: Issues, Problems and Opportunities 8 Table 6: Controls and Programs of the Public Water Supplier 9 Table 7: Local Agency Controls and Programs 10 Table 8: State and Federal Agency Controls and Programs 11 Table 9: WHP Plan of Action 14 Table 10: Cooperating Agencies 19 List of Appendices Appendix I: WHPA and DWSMA Delineations and Vulnerability Assessments 41 Appendix II: Inventory of Potential Contamination Sources 65 Appendix III: DNR Water Supply Approval Letter 124 Appendix IV: Ordinance Chapter 78, Connection to Water System 125 V Executive Summary The wellhead protection (WHP) plan for the ERMU of the City of Elk River presents the actions that will be taken to manage potential contamination sources that may present a risk to the quality of the community's drinking water. This plan is an amendment and was required by the Minnesota Department of Health (MDH) under authority granted by Minnesota Statutes, section 1031.101, subdivision 5 and through Minnesota Rules Chapter 4720.5100 to 4720.5590 relating to WHP planning. The ERMU is located in the City of Elk River, county of Sherburne and relies on nine primary wells that draw water from the Eau Claire- Mt. Simon- Hinckley aquifers. Water Supply Wells Included in This Plan Unique Well Name or Total Depth Aquifer Well Vulnerability Number Number (ft) Formation(s) Utilized 271176 Well#2 290 Eau Claire-Mt. Not Vulnerable Simon 2211176 Well#3 315 Mt. Simon Not Vulnerable 481794 Well#4 225 Mt. Simon Not Vulnerable 537682 Well#5 406 Mt.Simon Vulnerable 580320 Well#6 300 Mt.Simon Not Vulnerable 664852 Well#7 341 Mt.Simon Not Vulnerable 694499 Well#8 390 Mt. Simon Not Vulnerable 757624 Well#9 454 Mt.Simon- Not Vulnerable Hinckley Potential Contamination Sources and Assigned Risk Total Number within Number Within Potential Source Number Emergency Response Remainder of the Type Area and Level of DWSMA and Level Risk of Risk City Wells 8 8 H N/A N/A Non City Wells 221 12 H 209 H High Priority Non City Wells Intermediate 80 I M 79 L Priority High Capacity 1 0 N/A 1 H Wells Storage Tanks 26 1 H 7 H 18 L *H=High Risk *M=Moderate Risk *L=Low Risk vi The Drinking Water Supply Management Area (DWSMA) is shown in Figure 1 and is the focus of this plan. The vulnerability of the DWSMA to contamination is based upon an assessment of the 1) geologic protection covering the aquifer, 2) rate at which the aquifer is recharged, and 3) groundwater chemistry including the presence of contaminants of human origin. The ERMU has assigned priorities for managing potential contaminant sources that have been inventoried within its DWSMA. The inventory was based on 1) the DWSMA vulnerability, 2) the information contained in various state agency databases, and 3) information that the ERMU collected about current and historical land uses. Potential contamination sources that were assigned a high risk were given priority for inventory in the highly vulnerable portion of the DWSMA. The risk assigned to the potential source was based on 1) evidence that contaminants are present in the water supply, 2) the potential health impacts of the contaminant and (30) the quantity of potential contaminant attributed to the source contaminant's toxicity to people. Wellhead Protection Goals for the ERMU — • Maintain a safe and adequate drinking water supply for community residents that continues to meet the safe drinking water requirements for protecting the public's health, safety and general welfare of the community • Educate the general public regarding the principals and importance of water conservation and collecting additional data to support future delineation in order to promote the proper use of drinking water resources and monitor the geologic condition of Well ft 5. The following table illustrates action items that the ERMU has identified to meet the goals of its WHP plan. Further discussion of them and those of state and local government are presented in the Objectives and Plan of Action section of this plan. Summary of Wellhead Protection Actions Wellhead Protection Action Item Descriptions IN Cr e c x n r N n N C C N e n Provide ERMU residents with a pamphlet or bill stuffer that explains the importance of WHP and the need to seal priority unused wells and the Annually ERMU's willingness to support programs to find funding available. Request assistance from MRWA. Distribute materials to property owners in and outside of the ERMU limits within the DWSMA relating to the proper management of wells Continue to provide tours of the water plant to educate school children on the importance of WHP, conservation and protection Annually vii In the next two years,create and present a mobile display for agencies around the DWSMA in order to educate the public visually. Example locations: YMCA,City Library,Elk River Municipal Unities and City offices, Senior k x Activity Center. In the next year,we will take footage of a local well sealing and create a video presentation to display on ERMU website,You Tube, Face book etc... This will show the importance of well maintenance and well sealing cost- share availability Keep local city channel(Channel 12)ERTV 12 well and water footage up to date with any changes in DWSMA area. Currently demonstrate: Water system incite,water meter change outs details,wellhead protection x x importance,water conservation/SMART irrigation information,etc. Annually mail Consumer Confidence Reports so citizens are aware of the water quality Annually Contact Sherburne County annually to see what monies are available through the county for education and well sealing Annually Present Kids themed information on WHP/water conservation for Earth Day school visit and other kid activity days with schools,girl scouts, boy's scouts, home school kids. Attempt to gain additional audiences each year to reach a Annually variable age range There are known wells on the PCSI inventory without complete data fields. ERMU staff will continue to gather property owner's names,addresses, parcel identification numbers,status of wells or other applicable information k on the wells in order to complete the PCSI ERMU,City,and Sherburne SWCD will conduct MDH nitrate well water testing clinic Distribute and post educational materials related to the maintenance of above and below ground storage tanks to property owners with tanks as it relates to the protection of the ERMU drinking water supply. Place information on rA k website immediately. The ERMU,and the Sherburne SWCD will apply for grant funds to help seal unused wells located in the DWSMA. If they are successful they will use the money to seal the wells. If unsuccessful they will work cooperatively with K x k the local units of government to provide as much cost share as possible to help seal wells Provide an on-site visit to the property with the tanks identified during the inventory,that is within the I year time of travel to provide the property owner with a map of the DWSMA and information about tank maintenance se as it relates to the protection of the ERMU drinking water supply viii Notify MDH if a Class V well is identified and provide management materials to the Class V well owner As Occurs Meet with Sherburne County SWCD to discuss areas where they can work cooperatively on water and land use management issues with the DWSMA Annually and on grant funding. Work with all entities involved in the DWSMA on land use issues. As Needed Meet with Elk River Planning and Zoning to incorporate the map in the city land use and incorporate the WHP Plan into the city Comprehensive Plan Have Well#5 sampled for stable isotopes of oxygen(180)and deuterium (21-1)and several general chemistry parameters on water produced to assess the degree to which surface waters may be contributing to the well.Have MDH staff and MDH hydro geologist assist in the collection and evaluation of the sampling of surface waters up-gradient of Well#5 as needed. Apply for a SWP grant to help pay associated costs.Contact MDH as to availability of grant Programs Evaluate reasons for younger water being produced at Well#5. Evaluate the downward groundwater leakage from shallower aquifers and overlying st surface bodies into the Mount Simon-Hinckley aquifer. Implement measures that are specified in the IWMZ PCSI report Annually Monitor and maintain the 200 ft. radius around the wells to ensure that setback distances for new potential contamination sources are met. Annually Assist MDH staff in updating the IWMZ inventory for the public water supply wells. Contact your MDH Planner if changes to the locations or construction of potential contaminant sources are proposed in the IWMZ. Develop policies and procedures for an Emergency Water Plan dealing with derailment as to the proximity of the Railroad and Hwy#10 to Wells# 1 and Well#2 ix Document all wells that have been sealed by keeping track of the property owners name,address and parcel number of the well location,and share with Sherburne County. If possible, request a well sealing log from the property As Needed owner or well driller who sealed the well. Prepare an assessment of WHP plan implementation efforts every 2 '/2 years. Request assistance from MDH Planner and MRWA. k m Summarize all WHP Plan implementation efforts in a report to MDH in the 8t year. Review and update the Water Supply and Management Plan every 2 '/2 years. Make entire ERMU and City staff aware of the Contingency Plan. Where it is located and how to use it. Annually The ERMU will prepare an internal assessment of plan implementation every two and one half years and will summarize its progress with plan implementation in the eighth year when the plan amendment process begins. Emphasis in the ninth year will be to prepare an amended plan for submittal to the MDH at the beginning of the tenth year. The amended plan must be approved by the end of the tenth year to ensure that the ERMU always has an approved WHP plan in place. The MDH, MRWA, Federal and State agencies, Sherburne SWCD, and Sherburne County will provide support to the ERMU to implement various actions that are listed above. Refer to the Support provided by Local, State and Federal Governments section of this report to identify the types of outside support that will be provided to the ERMU. The ERMU will serve as the contact for enlisting support that is provided by other local governments. Generally, the MDH will serve as the contact for enlisting the support of other state agencies and from federal agencies on a case-by-case basis regarding technical or regulatory support that may be applied to the management of potential contamination sources. Also, MDH will provide technical support to the ERMU for assessing the impacts that contamination releases may present to drinking water quality and for further data collection that is summarized in the preceding table. Participation by other agencies, federal agencies, and local governments is based on legal authority granted to them and resource availability. x Chapter 1 - Introduction 1.1 Background The wellhead protection (WHP) plan for the Elk River Municipal Utilities was prepared in cooperation with the Minnesota Department of Health (MDH). It contains specific actions that the ERMU will take to fulfill WHP requirements that are specified under Minnesota Rules 4720.5510 to 4720.5590. Also, the support that Minnesota state agencies, federal agencies, and Sherburne County will provide is presented to identify their roles in protecting the ERMU's drinking water supply. The plan is effective for 10 years after the approval date specified by the MDH and the ERMU is responsible for implementing its WHP plan of action as described in Table 9 of this report. Furthermore, the ERMU will evaluate the status of plan implementation at least every two and one half years to identify whether its WHP plan is being implemented on schedule. 1.2 Plan Appendices Much of the technical information that was used to prepare this plan is contained in the appendices but is summarized in the main body of this plan. In particular— • Appendix I contains the first part of the plan, consisting of the delineation of the wellhead protection area (WHPA), the drinking water supply management area (DWSMA), and the vulnerability assessments for the public water supply wells and the DWSMA. This part of the plan is summarized in Chapter 3. • Appendix II contains the inventory of potential contamination sources that may present a risk to the ERMU's drinking water. This part of the plan is discussed in Chapter 4 in terms of assigning risk to the ERMU's water supply and is discussed as issues, problems or opportunities summarized in Chapter 6. • Appendix III contains the contingency strategy to provide for an alternate water supply if there is a disruption caused by contamination or mechanical failure. This part of the plan is discussed in Chapter 11. Chapter 2 - Identification and Assessment of the Data Elements Used to Prepare the Plan The data elements that are included in this plan document the need for the WHP measures that will be implemented to help protect the ERMU's water supply from potential sources of contamination. The ERMU met with representatives from the MDH on two occasions to discuss the data elements that are specified in MR 4720.5400 for preparing a WHP plan. The first scoping meeting that was held on November 10, 2009 addressed the data elements that were needed to support the delineation of the WHPA, the DWSMA, and the well and DWSMA vulnerability assessments. The second scoping meeting that was held on August 1, 2011 1 discussed the data elements required to 1) identify potential risks to the public water supply and 2) develop effective management strategies to protect the public water supply in relation to the well and DWSMA vulnerability. The results of each meeting were communicated to the ERMU by the MDH through a formal scoping decision notice The following table presents the data element assessment results relative to the overall impact that each data element has on the four items listed. Table 1 - Assessment of Data Elements Definitions— High (H) -the data element has a direct impact Moderate(M) -the data element has an indirect or marginal impact Low (L) -the data element has little if any impact Shaded Area—the data element was not required by MDH for preparing the WHP plan. Present and Future Implications r e ° c C W g 3 It it .E Data Source Data Element e 3 .c it 3 0 g 4 MC. 0 = 4) a ` ° a ' I, Precipitation Geology Maps and geologic H H H H MGS,DNR,USGS,Consultant descriptions Reports Subsurface data H H H H MGS,MDH,MPCA,DNR,MDA Borehole geophysics H H H H MGS,Consultant Reports Surface geophysics H H H H DNR, MPCA,Consultant Reports Maps and soil descriptions Eroding lands Water Resources Watershed units List of public waters Shoreland classifications Wetlands map Floodplain map Land Use ERMU,County,Met Council(Metro Parcel boundaries map L H L L area only) L L MGIO,ERMU,watershed unit(need Political boundaries map L H to define) PLS map L H L L MGIO M H Sanborn Fire Maps,Historical Society, Land use map and inventory M H ERMU Records,County Comprehensive land use L L M H ERMU,County map 2 Present and Future Implications a t 1/4o i Data Element y ° W m w ; e Data Source et `o — 9y • 3 .flt "um � 3 Qu 3 � dae ° q aa3 t, Zoning map L L L H ERMU,County Public Utility Services Transportation routes and L L M M MGIO corridors Storm sanitary sewers and None None None None MGIO PWS system map Oil and gas pipelines map None None None None MGIO Public drainage systems None None None None MGIO,County ditches map or list Records of well construction, maintenance, H H H H ELK River Municipal Utilities,CWI, and use _ MDH files Surface Water Quantity Stream flow data Ordinary high water mark data Permitted withdrawals Protected levels/flows Water use conflicts Groundwater Quantity Permitted withdrawals H H H H DNR Groundwater use conflicts H H H H DNR Water levels H H H H DNR,MPCA,MDA,MDH,ERMU Surface Water Quality Stream and lake water quality management classification Monitoring data summary Groundwater Quality Monitoring data H H H H MPCA,MDH.MDA,USGS Isotopic data H H H H MPCA,MDH.MDA, USGS,County, UMN Tracer studies H H H H DNR,MPCA Contamination site data M M M M MPCA,MDA Property audit data from L H H L MPCA,MDA,property owner contamination sites MPCA and MDA L H H L MPCA,MDA spills/release reports The availability of the information relating to each data element that is used in this plan was evaluated by the Minnesota Department and the Elk River Municipal Utilities. Actions that are 3 needed to address deficiencies in either the quality or the amount of data are included in the plan of action (Chapter 9). Chapter 3 - Delineation of the Wellhead Protection Area, Drinking Water Supply Management Area and Vulnerability Assessments A detailed description of the process used for 1) delineating the WHPA and the DWSMA, and 2) preparing the vulnerability assessments of the ERMU water supply well(s) and DWSMA is presented in Part 1 ERMU WHP Plan, Appendix 1. The Public work was performed by a geoscientist licensed by the State of Minnesota and employed by Bolton & Menk Engineering. 3.1 WHPA and DWSMA Delineation — Figure 1 shows the boundaries of the WHPA and the DWSMA. The WHPA was delineated by using computer simulations of groundwater movement to generate the underground capture zones for ERMU eight wells. The DWSMA boundaries were designated using the following criteria — • Center-lines of highways, streets, roads, or railroad rights-of-ways; • Public Land Survey coordinates; • Property or fence lines; 3.2 Well Vulnerability Assessment - The construction and water quality obtained from the wells that are used by the Public Water Supplier is included in the assessment of well vulnerability. All ERMU public water supplies are completed in the Mt. Simon-Hinckley formation and seems to exhibit confined aquifer conditions in most of the Elk River area. Tritium tests were performed on all ERMU wells, and only samples from Well 5 showed an indication of younger (post-1953) groundwater and is classified as vulnerable. It is hypothesized that either the Eau Claire Formation is thinner at the Well 5 location and potentially absent east of the well where buried bedrock valley is present. Or, it is possible that the integrity of the well casing itself has been compromised to allow infiltration of water from the upper aquifers into the water from the well. 3.3 DWSMA Vulnerability Assessment- The vulnerability of the DWSMA (Figure 1) was determined using geologic, soils, and groundwater chemistry information. Vulnerability is variable (moderate and low) in the area. While there is good protection provided over the Mt. Simon aquifer in the area of the ERMU DWSMA by the shale-rich, low-permeability Eau Claire formation, there is speculation that in the vicinity of Well 5 the protective shale Eau Claire layer may thin out and allow the infiltration of water from more shallow aquifers. Therefore, the recharge area around Well 5 is vulnerable (moderate), while the remaining portion of the DWSMA for all other wells is not vulnerable. 4 Chapter 4 - Assigning Risk to Potential Contamination Sources The types of potential contamination sources that may exist within the DWSMA were derived from the information collected to satisfy the data element requirements (Chapter 2). The impact assigned to each data element as part of the assessment process (Table 1) was used to assess the types of potential contamination sources that may present a risk to the ERMU's drinking water supply. Generally, the ERMU considers all types of land- and water-uses as presenting a possible risk to groundwater quality where the source water aquifer exhibits a high or very high vulnerability. Where the source water aquifer exhibits a moderate vulnerability, certain types of potential contamination sources that may release contaminants to the subsurface must be included in addition to wells, excavations that may reach the source water aquifer and certain types of Environmental Protection Agency Class V wells. These additional types include above ground and buried chemical and fuel storage tanks, underground waste disposal practices, pipelines and fuel/chemical spills. Where the source water aquifer exhibits a low or very low vulnerability, certain types of potential contamination sources that may release contaminants to the subsurface must be included in addition to wells, excavations that may reach the source water aquifer and certain types of Environmental Protection Agency Class V wells. 4.1 Contaminants of Concern None of the contaminants that are regulated under the federal Safe Drinking Water Act have been detected in the ERMU water supply wells. However, the vulnerable nature of the aquifer requires that potential contamination sources that may release them be inventoried. These potential sources likely reflect those that could present a threat to drinking water if a contaminant release were to occur because the contaminants have a known impact on public health. 4.2 Inventory Results and Risk Assessment The ERMU Wellhead Protection Team conducted the inventory of potential contaminant sources. The MDH provided the team with a listing of potential contamination sources from state agency databases and team members provided knowledge about other potential sources that are not addressed under state regulatory programs. Most of the work was accomplished at meetings of team members although this was supplemented with driving throughout the DWSMA to confirm some of the information. The inventory began with updating the locations of potential contamination sources in the area that is located within 200 feet of each city well and is referred to as the IMWZ. A description of the locations of potential contamination sources is presented in Appendix II. A summary of the results for the IWMZ is listed in Table 2 and complete IWMZ PCSI reports are presented in Figure 6, and for the remainder of the DWSMA in Table 3. The priority assigned to each type of potential contamination source addresses 1)the number inventoried, 2) its proximity to an ERMU well, 3) the capability of local geologic conditions to absorb a contaminant, 4) the effectiveness of existing regulatory controls, and 5) the time required for the ERMU to obtain cooperation from governmental agencies that regulate it. A high (H) risk potential implies that the potential source type has the greatest likelihood to negatively impact the ERMU's water 5 supply and should receive highest priority for management. A low (L) risk potential implies that a lower priority for implementing management measures is assigned. Table 2 Potential Contamination Sources and Assigned Risk for the IWMZ Total Source Type Level of Risk Wells(Non-City) 2 H Above Ground Storage Tanks 1 H Sewer Lines 1 H Table 3—Point Sources of Potential Contamination and Assigned Risk for the Remainder of the DWSMA Total Number within Number Within Potential Source Number Emergency Response Remainder of the Type Area and Level of DWSMA and Level Risk of Risk City Wells 8 8 H N/A N/A Non City Wells 221 12 H 209 H High Priority Non City Wells Intermediate 80 1 M 79 L Priority High Capacity 1 0 N/A 1 H Wells Storage Tanks 7 H 26 1 H 18 L *H=High Risk *M=Moderate Risk *L=Low Risk Chapter 5 - Impact of Land- and Water- Use Changes on the Public Water Supply WeII(s) The ERMU estimates that the following changes to the physical environment, land use, surface water, and groundwater-may occur over the ten-year period that the WHP plan is in effect. This is needed to determine whether new potential sources of contamination may be introduced in the future and to identify future actions for addressing these anticipated sources. Land- and water- use changes may introduce new contamination sources or result in changes to groundwater use and quality. The anticipated changes may occur within the jurisdictional authority of the ERMU although some may not. The following table describes the anticipated changes to the physical environment, land use, and surface water or groundwater in relationship to their 1) the influence that existing governmental land and water programs and regulations may have on the anticipated change, and 2) the administrative, technical, and financial considerations of the public water supplier and property owners within the DWSMA. 6 Table 4- Expected Land and Water Use Changes Expected Change Impact of the Influence of Existing Administrative, (Physical Environment Land Expected Change Government Programs Technical,and Financial, Use,Surface Water,Ground On the Source and Regulations on the Considerations due to the Water) Water Aquifer Expected Change Expected Change Physical Environment : No change is anticipated. Does not apply Does not apply Does not apply Land Use: ERMU The ERMU expects expects light commercial moderate growth over the The Mount Simon-Hinckley growth. The ERMU next 10 years,although aquifer is highly regulated expects light residential doesn't foresee any large and currently is capable of Do not see any changes due to growth in established water users which would sustaining several high this expected change subdivisions cause significant changes in the amount of water capacity ERMU wells in the pumped. No changes in Elk River area. DWSMA Surface Water: Evaluate downward ground Well#5 Well# 5 is producing Does not apply water leakage from shallower younger water aquifers Ground Water: ERMU Changes in the Does not apply Does not apply wells have historically groundwater supply are provided groundwater of unlikely to occur excellent quality and quantity Chapter 6 - Issues, Problems, and Opportunities 6.1 Identification of Issues, Problems and Opportunities - The ERMU has identified water- and land-use issues, problems and opportunities related to I) the aquifer used by the ERMU water supply wells, 2) the quality of the well water, or 3) land-or water-use within the DWSMA. The ERMU assessed 1) input from public meetings and written comments that it received, 2)the data elements identified by the MDH during the scoping meetings, and 3) and the status and adequacy of the ERMU's official controls and plans on land use and water uses as well as those of local, state, and federal government programs. The results of this effort are presented in the following table which defines the nature and magnitude of contaminant source management issues in the ERMU's DWSMA. Identifying the issues, problems and opportunities as well as resource needs enables the ERMU to: 1) take advantage of opportunities that may be available to make effective use of existing resources, 2) set meaningful priorities for source management and 3) solicit support for implementing specific source management strategies. 6.2 Comments Received — There have been several occasions for local governments, state agencies and the general public to identify issues and comment on the ERMU's WHP plan. At the beginning of the planning process, local units of government were notified that the ERMU was going to develop its WHP plan and were given the opportunity to identify issues as well as to comment. A public information meeting was held to review the results of the delineation of 7 the WHP area, DWSMA, and the vulnerability assessments and the meetings of the WHP protection team were open to the public. Also, a public hearing was held before the completed WHP plan was sent to MDH for state agency review and approval. The following issues were identified during comment periods— Table 5—Issues,Problems and Opportunities Problem Associated Adequacy of Impacted with the Identified Opportunity Associated Existing Controls to Issue Identified Feature with the Identified Issue Issue Address the Issue The ERMU can partner with The ERMU does not There are likely Aquifer The ERMU needs to Sherburne County&SWCD to have authority to require numerous unused Well Water assess which wells help property owners pay for that unused wells be and unsealed wells Quality present a threat to the the costs of properly sealing properly sealed. on residential DWSMA aquifer based upon their unused wells. &commercial (Select all depth,construction,and The MDH has grant programs The MDH has authority properties that apply.) state of repair available to assist with the to require well sealing sealing of wells No jurisdiction for a ERMU will work closely with County presently has Aquifer small number of the numerous jurisdictions on zoning and building DWSMA DWSMA boundaries extend properties located within land use decisions outside permit jurisdiction over Well Water and outside the ERMU's jurisdiction. the DWSMA located past ERMU limits Quality DWSMA. outside ERMU limits. At the present time the ERMU,local and state governments have existing controls in place The ERMU to address most issues as recognizes this is a they occur. Some issues 10 year plan and The ERMU has the are uncontrollable and that issues, Aquifer The ERMU needs to opportunity to work with other unforeseen and problems,and DWSMA have the flexibility to local units of government to additional controls might opportunities can Well Water address changing address those issues, problems need to be considered to change from today Quality situations and opportunities that may address new issues. The which can impact change over the next 10 years. ERMU local and state the implementation governments are strategies continually updating land use controls as new issues,new problems and new opportunities occur. The ERMU has With limited resources ERMU will form working ERMU has limited time limited resources to the implementation of partnerships with local units of and resources for implement all of the the WHP Plan will be a government and state agencies implementation. management DWSMA challenge to the ERMU. that have regulatory authority strategies contained and/or programs to help with within this WHP implementation. plan New high capacity Aquifer The ERMU has no The ERMU will keep updating The ERMU will need to wells drilled within DWSMA authority over the land use controls to allow the work closely with MDH the DWSMA or one Well Water construction and ERMU the authority over the and the MN Dept of mile of the Quality pumping rates for newly construction of high capacity Natural Resources of 8 DWSMA might constructed high ERMU wells within the Water in the alter the WHPA capacity wells located corporate boundaries and work identification of high boundary and outside of the with the appropriate agencies capacity wells which provide a pathway jurisdiction on those outside oftheir might be drilled within for pollutants to jurisdiction. the DWSMA or one mile enter into the of the DWSMA aquifer boundaries and their potential impact on the WHPA boundaries. The ERMU has authority The ERMU is Aquifer ERMU regulates domestic and Local citizens have over the construction of continually updating land DWMA irrigation wells through the opportunity to domestic use private use controls as new Well Water Ordinance Chapter 78,Article drill irrigation wells Quality µ'ells. The ERMU II,Division 2. issues,new problems and allows irrigation wells new opportunities occur Continue to evaluate Well#5 Work with MDH to Aquifer Well#5 is producing for downward groundwater develop a process for Well#5 DWSMA younger water and could leakage from shallower evaluating Well#5 for Well Water have some leakage from aquifers and overlying surface groundwater leakage and Quality shallower aquifers. bodies. surface water. Aquifer If the tank is not Tank was discovered during ERMU will provide tank Above ground the PCSI and the owner is p storage tank located DWSMA maintained and properly cooperative with the city in information and Well Water sealed some leakage educational materials to in the I WMZ. Quality could occur. making sure the tank does not the owner of the tank cause contamination issues. Chapter 7 - Existing Authority and Support Provided by Local, State, and Federal Governments In addition to its own controls, the ERMU will have to rely upon partnerships formed with local units of government, state agencies, and federal agencies with regulatory controls or resource management programs in place to help implement its WHP plan. The level of support that a local, state, and federal agency can provide to help offset the risk that is presented by a potential contamination source will depend up on its legal authority as well as the resources that are available to local governments. 7.1 Existing Controls and Programs of the Public Water Supplier - The ERMU has identified the following legal controls and/or programs that it has in place that can be used to support the management of potential contamination sources within the DWSMA. Table 6—Controls and Programs of the Public Water Supplier Type of Control Program Description Building Permits Provides an opportunity to require performance standards to offset potential risks posed by a land use. Ordinance Requiring Hookup Requires private land owners to connect to ERMU to ERMU Services services when available. Zoning Ordinance and Provides oversight and control to make sure orderly Conditional Use Permits(CUP) growth occurs with the ERMU. Specifies performance standards needed to offset potential risks 9 posed by land use. Comprehensive Plan Establishes ERMU wide goals and priorities towards orderly growth and protecting water resources. Domestic Well Ordinance Controls the drilling of wells in the water supply area. 7.2 Local Government Controls and Programs - The following departments or programs within Sherburne County may be able to assist the ERMU with issues relating to potential contamination sources that 1) have been inventoried or 2) may result from changes in land and water use within the DWSMA: Table 7 - Local Agency Controls and Programs Government Name of Program Description Unit Control/Program Sherburne Land Use Permits Regulates land-uses to comply with zoning County Planning ordinances. and Zoning CUP/IUP Permits Specifies performance standards needed to offset Department environmental risk presented by a proposed land use. Sherburne Water Planning Establishes county wide goals and priorities towards County Soil and protecting water resources. Water Administration for grant The Sherburne County SWCD promotes the Conservation programs for local protection of water and soil resources in the County District(SWCD) governments. through educational programs, collaboration with other local, state and federal agencies. Administers local comprehensive water plans for the county. Elk River Joint Powers Works to improve the quality of Elk River Watershed Watershed District through education,conservation and district. responsible use of resources. City of Elk River Ordinance Regulates connections to water system with ERMU ordinances. 7.3 State Agency and Federal Agency Support - The MDH will serve as the contact for enlisting the support of other state agencies on a case-by-case basis regarding technical or regulatory support that may be applied to the management of potential contamination sources. Participation by other state agencies and the federal government is based on legal authority granted to them and resource availability. Furthermore, the MDH 1) administers state regulations that affect specific potential sources of contamination and 2) can provide technical assistance for property owners to comply with these regulations. The following table identifies specific regulatory programs or technical assistance that state and federal agencies may provide to the ERMU to support implementation of its WHP plan. It is likely that other opportunities for assistance may be available over the ten-year period that the plan is in effect due to changes in legal authority or increases in funding granted to state and 10 federal agencies. Therefore, the table references opportunities available when the ERMU's WHP plan was first approved by MDH. Table 8 - State and Federal Agency Controls and Programs Government Type of Program Program Description Unit MN Dept.of State Well Code MDH has authority over the construction of new Health (MR Chapter 4725) wells and sealing of wells. MDH staff in the Well Management Program offers technical assistance for enforcing well construction, maintaining setback distances for certain contamination sources, and well sealing. MN. Dept. of WHP MDH has staff that will assist the ERMU with Health identifying technical or financial support that other governmental agencies can provide to assist with managing potential contamination sources. MDH administers SWP grant program. MN Dept. of Water Appropriation Permitting DNR can require that anyone requesting an increase Natural (MR Chapter 6115) in existing permitted appropriations or to pump Resources groundwater must address concerns of the impacts to drinking water if these concerns are include in a WHP plan. EPA Class V Wells Automatic closure of Class V automotive waste disposal wells within the WHP Area. Inventory of all Class V Wells. MPCA Hazardous waste generators and MPCA identifies,regulates clean up spills, leaks and storage tanks other hazardous material that can affect health and environment 7.4 Support Provided by Non-profit Organizations The Minnesota Rural Water Association (MRWA) has provided technical assistance to the ERMU of Elk River throughout the development of this WHP Plan and will assist the ERMU with implementing its WHP Plan by providing: I) referenced educational and outreach materials for land owners, 2) technical assistance for implementing individual WHP action items listed in the Plan, and 3) support to the ERMU for assessing the results of Plan implementation. 11 Chapter 8 — Goals Goals define the overall purpose for the WHP plan as well as the end points for implementing objectives and their corresponding actions. The WHP team identified the following goals after considering the impacts that 1) changing land- and water-use changes over time have presented to drinking water quality and 2) future changes that need to be addressed to protect the community's drinking water: • Maintain a safe and adequate drinking water supply for community residents that continues to meet the safe drinking water requirements for protecting the public's health, safety and general welfare of the community • Educate the general public regarding the principals and importance of water conservation and collecting additional data to support future delineation in order to promote the proper use of drinking water resources and monitor the geologic condition of Well # 5. Chapter 9 - Objectives and Plan of Action Objectives provide the focus for ensuring that the goals of the WHP plan are met and that priority is given to specific actions that support multiple outcomes of plan implementation. Both the objectives and the wellhead protection measures (actions) that support them are based on assessing 1) the data elements (Chapter 3), 2) the potential contaminant source inventory (Chapter 5), 3)the impacts that changes in land- and water-use present (Chapter 6)and 4) issues, problems, and opportunities referenced to administrative, financial, and technical considerations (Chapter 7). 9.1 Objectives - The following objectives have been identified to support the goals of the WHP plan for the ERMU— 1. Create awareness and general knowledge about the importance of WHP in the Elk River Community and the ERMU DWSMA. 2. Properly inventory and manage potential contaminant sources to protect the drinking water supply for the ERMU. 3. Gather additional information within the DWSMA in order to better understand the size and vulnerability of the DWSMA 4. Effectively track and report the implementation efforts and wellhead protection plan progress to all governing authorities. 5. Manage the Inner Wellhead Management Zone to prevent contamination of the aquifer near the public supply wells. 6. Effectively prepare the ERMU for disruptions to the water distribution system. 9.2 WHP Measures and Action Plan - Based upon the factors, the WHP team has identified WHP measures that will be implemented by the ERMU over the 10-year period that its WHP plan is in effect. The objective that each measure supports is noted as well as 1) the lead party and any cooperators, 2) the anticipated cost for implementing the measure and 3) the year or years in which it will be implemented. 12 The following categories are used to further clarify the focus that each WHP measure provides as well as help to organize the measures listed in the action plan: • Data Collection • IWMZ Management • Land Use Management • Potential Contamination Source Management • Public Education and Outreach • Reporting and Evaluation • Water Use and Contingency Strategy 9.3 Establishing Priorities— WHP measures reflect the administrative, financial, and technical requirements needed to address the risk to water quality or quantity presented by each type of potential contamination source. Not all of these measures can be implemented at the same time, so the WHP team assigned priority to each. A number of factors must be considered when WHP action items are selected and prioritized (part 4720.5250, subpart 3): I. Contamination of the public water supply wells by substances that exceed federal drinking water standards 2. Quantifiable levels of contamination resulting from human activity 3. The location of potential contaminant sources relative to the wells. 4. The number of each potential contaminant source identified and the nature of the potential contaminant associated with each source 5. The capability of the geologic material to absorb a contaminant 6. The effectiveness of existing controls 7. The time required to get cooperation from other agencies and cooperators 8. The resources needed: staff, money,time, legal, and technical The ERMU defines priority for implementing a WHP measure as an action that directly addresses a Potential Contaminant Source (PCS) which protects their drinking water supply from contamination from the potential contaminant source. The following table lists each measure that it will implement over the ten year period that the ERMU's WHP plan is in effect as well as the priority that it has assigned to each measure. 13 Table 9 -WHP Plan of Action Public Education and Outreach ERMU Action Alone Implementation time frame o Unless P. .- Cooperator is o g Description N , Noted u '4:- O M V V1 •O l� M P N N N FFFiii ' 0 N 0 0 0 0 0 0 0 0 Provide ERMU residents with a pamphlet or bill stuffer that 2 explains the importance of WI-IP and the need to seal priority ERMU, v, v X unused wells and the ERMU's willingness to support programs to 1 SWCD, c Annually .e_ find funding available.Request assistance from MRWA. 9 N Distribute materials to property owners in and outside of the 2 ERMU limits within the DWSMA relating to the proper ERMU, oo k k 5 management of wells I MRWA tern , Continue to provide tours of the water plant to educate school children on the importance of WHP,conservation and protection. ° k k k Educate the Energy City tour groups on WHP and water topics to 1 ERMU globalize water protection information. -0- In the next two years,create and present a mobile display for agencies around the DWSMA in order to educate the public ERMU o k k X visually. Example locations: YMCA,City Library,Elk River 1 us ;) Municipal Unities and City offices,Senior Activity Center. In the next year,we will take footage of a local well sealing and • create a video presentation to display on ERMU website,You oo k 9 2 Tube,Face book etc...This will show the importance of well 1 ERMU osen maintenance and well sealing cost-share availability Keep local city channel(Channel 12)ERTV 12 well and water o u footage up to date with any changes in DWSMA area. Currently S k k IS a demonstrate: Water system incite,water meter change outs I ERMU 2 t details,wellhead protection importance,water conservation/SMART irrigation information,etc. Annually mail Consumer Confidence Reports so citizens are P. aware of the water quality o Annually o o 2 Contact Sherburne County annually to see what monies are E v available through the county for education and well sealing Annually = x 1 ERMU cn 2 14 I Public Education and Outreach —Continued dv ERMU Implementation time frame r;• ? Provide an on-site visit to the property with the tanks identified ' during the inventory,that is within the 1 year time of travel to °o 3 z provide the property owner with a map of the DW SMA and 4 ERMU ° k gil information about tank maintenance as it relates to the protection VI of the ERMU drinking water supply Notify MDH if a Class V well is identified and provide 2 management materials to the Class V well owner E it IE 0 2 ERMU , As Occurs A v 2 ex Land Use Management ERMU dAction Alone Implementation time frame v Unless -g" Cooperator is - o • 4 Noted o in g Description W Li U - m V V1 b r CO Q 0 N N GGGG U 0 0 0 0 0 0 0 0 0 0 N N N N N N N N N N N O Meet with Sherburne County SWCD to discuss areas where they ii, can work cooperatively on water and land use management issues ding. 2 Annually 'FE'. , with the DWSMA and on grant funll Y SWCD tig N tIJ 2 Work with all entities involved in the DWSMA on land use issues. ERMU, v ✓ SWCD, E 2 Sherbnme co. As Needed It. ( Planning vi /Zoning Meet with Elk River Planning and Zoning to incorporate the map `-° in the city land use and incorporate the WHP Plan into the city E 5 z Comprehensive Plan 2 ERMU P k A O in 2 16 Data Collection ERMU Implementation time frame „ -el Action Alone . ? H Unless y 2 .` o_ Description Cooperator is a `" ° r °° N a p ° Noted N N N N N N N N N N Q Have Well#5 sampled for stable isotopes of oxygen(180)and deuterium(2H)and several general chemistry parameters on water a produced to assess the degree to which surface waters may be E contributing to the well. Have MDH staff and MDH hydro 3 ERMU, F k 2 geologist assist in the collection and evaluation of the sampling of MDH oa ± surface waters up-gradient of Well#5 as needed. Apply for a N SWP grant to help pay associated costs. Contact MDH as to availability of grant Programs Evaluate reasons for younger water being produced at Well#5. N Evaluate the downward groundwater leakage from shallower tl 6 aquifers and overlying surface bodies into the Mount Simon- 3 ERMU , k E Hinckley aquifer. MDH IWMZ Management ERMU Implementation time frame > o Action Alone ,4: U d Unless a Description M y ,n e n m ON o — N O b Cooperator is U x 0 0 0 0 0 0 N N N CL N N N N N N N N N N Q Noted Implement measures that are specified in the IWMZ PCSI report Gd 1 5 ERMU Annually N N Monitor and maintain the 200 ft. radius around the wells to ensure N that setback distances for new potential contamination sources are E 6 met. 5 ERMU Annually rn 17 Assist MDH staff in updating the IWMZ inventory for the public water supply wells. Contact your MDH Planner if changes to the E tia locations or construction of potential contaminant sources are 5 ERMU,MDH k d proposed in the IWMZ. Ye Develop policies and procedures for an Emergency Water Plan v N dealing with derailment as to the proximity of the Railroad and E E Hwy#l0 to Wells#2 and Well#3 5 ERMU F k x Ce N p u Reporting and Evaluation ERMU Im,lementation time frame u v Action Alone :? r, •.1 N Unless :n .> V N Q Nt V in b N P O N N 2 0 Description 9 .D Noted is v o 0 0 0 0 0 0 0 0 0 L < l Voted N N N N N N N N N N 0. .0 Q Document all wells that have been sealed by keeping track of the v N property owners name,address and parcel number of the well E 3 location,and share with Sherburne County. If possible,request a 4 ERMU As Needed ✓ well sealing log from the property owner or well driller who V, ± sealed the well. Prepare an assessment of WHP plan implementation efforts every 2 '/:years. Request assistance from MDH Planner and MRWA. ERMU , E 4 MDH, k k k B , MRWA Summarize all WHP Plan implementation efforts in a report to v N MDH in the g's year. ERMU, 4 MDH, k d MRWA a 18 Water Use and Contingency Strategy ERMU Implementation time frame w Action Alone •�r •- y Unless r. o Description °x o M < a : : a o - Cooperator is U r r r " O Q Noted N N ry o ry ry o o ry o - 00 Review and update the Water Supply and Management Plan every c4 2 '/x years. 6 ERMU k k k Make entire ERMU and City staff aware of the Contingency Plan. N Where it is located and how to use it. E 6 ERMU Annually m g 9.4 Commitments from cooperators — The following agencies that are listed in Table 10 have indicated that they will support the Public Water Supplier with the implementing the WHP measure(s) in which they are identified. Table 10 - Cooperating Agencies List Agency Name— Measure Number Actions Agency Will Take Measure Number Minnesota Department of 10,13,18,19,20,23,26,27 Technical Assistance and WHP Rule Health(MDH) Sherbume County 17 Technical Assistance and Land Use and Zoning Planning and Zoning Oversight. Sherburne County SWCD 1,10,13,16,17 Technical Assistance with well sealing,grant administration and Water Plan Coordination. Minnesota Rural Water 1,2,26,27 Technical Assistance with WHP plan writing and Association(MRWA) implementation. ERMU 1,2,3,4,5,6,7,8,9,10,11,12,13,14,15,16, City of Elk River-Elk River Municipal Utilities 17,18,19,20,21,22,23,24,25,26,2728,29 Staff Chapter 10 - Evaluation Program Plan evaluation is specified under objective 4 and provides the mechanism for determining whether WHP action items are achieving the intended result or whether they need to be modified to address changing administrative,technical, or financial resource conditions within the DWSMA. Evaluation is used to support plan implementation and is required under MR 4720.5270 prior to amending the ERMU's WHP plan. The ERMU has identified the following procedures that it will use to evaluate the success with implementing its WHP plan. 19 1. A annual briefing to the ERMU council will provide the basis for documenting whether each action step for that year was implemented; 2. The WHP team will meet at a minimum every two and one half years to assess the status of plan implementation and to identify issues that impact implementation of action steps throughout the DWSMA; 3. The ERMU will assess the results of each action item that has been taken annually to determine whether the action item has accomplished its purpose or whether modification is needed. Assessment results will be presented in the annual report to the ERMU council. 4. The ERMU will prepare a written report that documents how it has assessed plan implementation and the action items that were carried out. The report will be presented to MDH at the first scoping meeting that it will hold with the ERMU to begin amending the WHP plan. Chapter 11 - Contingency Strategy The WHP plan must include a contingency strategy that addresses disruption of the water supply that is caused either by contamination or mechanical failure. The ERMU has a water supply plan in effect that was approved by the Minnesota Department of Natural Resources and it fulfills the contingency planning requirements for wellhead protection. A copy of this plan is available for public review during regular business hours at the ERMU offices and is referenced in this section. Chapter 12 - Glossary of Terms Conjunctive Delineation means a WHP area that is defined by two components consisting of I) the capture zone for a well that is based on generating flow path lines within the subsurface area(s) of contribution and 2) a surface area that may contribute recharge to the capture zone. Data Element means a specific type of information that is required by the Minnesota Department of Health to prepare a wellhead protection plan. Drinking Water Supply Management Area (DWSMA) means the surface and subsurface areas surrounding a public water supply well, including the WHP area, that must be managed by the entity identified in the WHP plan. (MR4720.5100, subpart 13). This area is delineated using identifiable landmarks that reflect the scientifically calculated WHPA boundaries as closely as possible. Emergency Response Area (ERA) means the part of the WHP area that is defined by a one- year time of travel within the aquifer that is used by the public water supply well (MR4720.5250, Subpart 3). It is used to set priorities for managing potential contamination sources within the DWSMA. 20 Emergency Standby Well means a well that is pumped by a public water supply system only during emergencies such as when an adequate water supply cannot be achieved because one or more primary or seasonal water supply well cannot be used. Inner Wellhead Management Zone (IWMZ) means the land that is within 200 feet of a public water supply well (MR4720.5100, subpart 19). The public water supplier must manage the IWMZ to help protect it from sources of pathogen or chemical contamination that may cause an acute health effect. Non-point Source Contamination refers to contamination of the drinking water aquifer that is caused by polluted runoff or pollution sources that cannot be attributed to a well-defined origin, e.g., runoff from agricultural fields, feedlots or urban areas. Point Source Contamination refers to contamination of the drinking water aquifer that is attributed to pollution arising from a well-defined origin, such as discharge from a leaking fuel tank, a solid waste disposal site, or an improperly constructed or sealed well. Primary Water Supply Well means a well that is regularly pumped by a public water supply system to provide drinking water. Seasonal Water Supply Well means a well that is only used to provide drinking water during certain times of the year either when pumping demand cannot be met by the primary water supply well(s) or for a facility, such as a resort, that is closed to the public on a seasonal basis. Vulnerability refers to the likelihood that one or more contaminants of human origin may enter either I)a water supply well that is used by the public water supplier or 2)an aquifer that is a source of public drinking water. WHP Area (WHPA) is the surface and subsurface area surrounding a well or well field that supplies a public water system,through which contaminants are likely to move toward and reach the well or well field (Minnesota Statutes, Part 1031.005, subdivision 24). WHP Plan Goal means an overall outcome of implementing the WHP plan, e.g., Providing for a safe and adequate drinking water supply. WHP Measure means a method adopted and implemented by a public water supplier to prevent contamination of a public water supply, and approved by the Minnesota Department of Health under Minnesota Rules parts 4720.5110 to 4720.5590. WHP Plan Objective means a capability that is needed to achieve one or more WHP goals, e.g., implementing WHP measures to address high priority potential contamination sources within 5 years. 21 Chapter 13 - List of Acronyms List of Acronyms DWSMA - Drinking Water Supply Management Area ERA - Emergency Response Area ERMU - Elk River Municipal Utilities IWMZ - Inner Wellhead Management Zone LUG - Local Unit of Government MDH - Minnesota Department of Health MRWA - Minnesota Rural Water Association SWCD - Soil and Water Conservation District SWPA - Source Water Protection Area WHP - Wellhead Protection WHPA - Wellhead Protection Area Chapter 14—References 22