When your drinking water source comes from underground, wellhead protection is critical to keep the water supply clean. A wellhead protection area is the surface and subsurface surrounding a water well or wellfield, where contaminants could move toward them.
An US Congressional amendment to the Safe Drinking Water Act in 1986 now requires states to develop and obtain Environmental Protection Agency (EPA) approval for wellhead protection programs. Spills or leaks in the Wellhead Protection Area could contaminate the public water supply and subject the owner/operator of the facility to heavy fines, the cost of groundwater cleanup, additional treatment, and monitoring for the water system.
After the passage of the federal law, the Tennessee Department of Environment and Conservation (TDEC) created Tenn. Division of Water Resources Rule 0400-45-01-.34 (on page 212) that require public water systems to delineate the wellhead capture zone, catalog any potential contaminant source in that zone, and ensure there is a spill response notification and contingency planning. TDEC has a webpage explaining WHPP's and Table 1 outlines the potential sources of groundwater pollution.
An US Congressional amendment to the Safe Drinking Water Act in 1986 now requires states to develop and obtain Environmental Protection Agency (EPA) approval for wellhead protection programs. Spills or leaks in the Wellhead Protection Area could contaminate the public water supply and subject the owner/operator of the facility to heavy fines, the cost of groundwater cleanup, additional treatment, and monitoring for the water system.
After the passage of the federal law, the Tennessee Department of Environment and Conservation (TDEC) created Tenn. Division of Water Resources Rule 0400-45-01-.34 (on page 212) that require public water systems to delineate the wellhead capture zone, catalog any potential contaminant source in that zone, and ensure there is a spill response notification and contingency planning. TDEC has a webpage explaining WHPP's and Table 1 outlines the potential sources of groundwater pollution.
A Wellhead Protection Plan (WHPP) is a plan to protect the area – both above ground (the surface) and below ground (the subsurface) – around a well that supplies drinking water. It is a plan, for the community and local government, to help keep groundwater clean and safe by managing what we do on the surface. It is both preventative, limiting what types of activities can happen around wellheads, and mitigating, with plans for what to do in the event of a spill near a wellhead.
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A Wellhead – or the top of a well that draws water from underground – creates a suction effect in the groundwater surrounding that well (that's the Cone of Depression). The more it pumps, the more it pulls groundwater down toward the well screen, where it is pulling water up to the surface from below.
When harmful substances – like chemicals, bacteria, or pollutants – are spilled on the surface, they gradually seep into the ground. Think gas stations, leaking storage tanks, accidents at industries, dry cleaning chemical spills, oil dumped at auto shops – spills happen often. If spilled near a well, they can be pulled down toward that well screen underground, much faster than they do when spilled in an area where groundwater isn’t being pumped.
This means that the areas around wellheads are particularly vulnerable – if we don’t protect them, we can quickly contaminate our drinking water source.
It is also a cost effective approach to reduce the likelihood that an owner/operator of the facility could be subject to heavy fines and the cost of groundwater cleanup, OR that the publicly-owned water system has to pay the cost of remediation and well replacement.
Really, this affects everybody who uses water supplied by that well! But in practice, Wellhead Protection Plans directly impact landowners in the area that's designated as a Wellhead Protection Area (WHPA - more on those later). If a Wellhead Protection Overlay District is in place, anyone who wants to pull a permit in the WHPA must comply with extra zoning regulations & land use restrictions than if they weren’t in a WHPA. So, if you want to build a new factory and you’re in a WHPA, you must build with extra protections in the case of spills, and you are limited in what types of materials you can use onsite.
If your business cannot comply, you must request an exception – often a Special Use Permit or a Variance – that requires an appeal to the local zoning board with a public hearing. This impacts all future permits – existing businesses are often “grandfathered in,” given time to get into compliance, or forced to comply when they pull a future permit.
The Wellhead Protection Plan (WHPP) is required by all public water suppliers through State regulations and allows local governments to establish Overlay Districts via an ordinance. Once the ordinance is adopted, the real enforcement of the WHPP happens through land use & zoning. An accompanying zoning amendment is often passed – this outlines all of the extra precautions & use restrictions (along with some exemptions) that must be followed in that area. An overlay is also added to the land use map designating the Wellhead Protection Area (WHPA). So, when future development applicants within the WHPA apply for permits, if they are within that overlay, they must show that their project complies with the WHPP before they can move forward and/or get their Certificate of Occupancy to start operating their business.
A Wellhead Protection Plan (WHPP) includes the following:
There are 4 categories of wellheads, determined based on how much water the well is producing. Regulations are tiered for each category – for example, the protection area around a Category 1 Well (producing less than 20,000 gallons of water per day) is much smaller than around a Category 4 Well (producing 1 million+ gallons of water per day). The bigger the well’s capacity, the bigger the restrictions.
There are two zones defined in the Wellhead Protection Plan as concentric circles at a set radius around the wellhead. These zones together define the Wellhead Protection Area (WHPA):
Zones 1 and 2 are defined by the time of travel, or how long it takes a contaminant at the surface to reach the well. Scientists determine this through computer modeling at various points in a radius around the well. Zone 1 is often delineated based on a 1 year time of travel (i.e. it takes contaminants 1 year to seep through the ground and reach the well), and Zone 2 is often a 25-30 year time of travel, but depends on the specific geology of the area.
Ideal use of land in the Wellhead Protection Area is to maintain the natural landscape, designating the land as a conservation easement. Low-impact parks can also be a great way to protect the land – as long as passive recreation (hiking trails, picnic areas, etc.) and native plantings without a need for fertilizers are used.
Realistically, though, land within a Wellhead Protection Area may not be zoned Conservation, and may already have a variety of uses onsite. That’s why, within a Wellhead Protection Area, we recommend the following best management practices:
Our goal? For every area that depends on groundwater to have a Wellhead Protection Overlay District in place! So far, here's who has a Overlay District in West TN:
