Wellhead Protection Plan Part 2 Amendment Process Update

Purpose:
The purpose of this case is to update the Public Works Committee on the process Staff is proposing to amend Part 2 of the Wellhead Protection Plan.

Background:
The Minnesota Department of Health (MDH) is charged with protecting drinking water sources throughout Minnesota per Minnesota Rules, Chapter 4720, Public Water Supplies, which includes administering the Wellhead Protection Program.  The purpose of the program is to prevent contamination of public drinking water supplies by identifying water supply recharge areas and implementing management practices for potential pollution sources found within those areas.  Public Water Suppliers, which includes municipalities, are required to maintain a Wellhead Protection Plan, and to amend it every 10 years.
 
City Staff has been working with MDH since March of 2017 to amend the City of Ramsey’s Wellhead Protection Plan (WHPP), which was adopted January 4, 2010, and is effective until January 4, 2020.  The City’s WHPP must be amended by October 6, 2019 to meet the required 10-year update schedule.

The WHPP consists of two parts. Part 1 delineates the City's wellhead protection zone and drinking water supply management area (DWSMA), and assesses the vulnerability of our DWSMA and municipal water supply wells. Part 2 includes a potential contaminant source inventory, a potential contaminant source management strategy, an emergency/alternative water supply contingency plan, and wellhead protection program evaluation plan.

Part 1 of the WHPP was recently amended and approved by the MDH. A copy of the MDH approval letter, received February 4, 2019, is attached.  As required, copies of the amended delineated wellhead protection areas, drinking water supply management areas, and assessments of well and aquifer vulnerabilities were issued to local units of governments wholly or partially within these areas within 30 days after receiving MDH approval of the Part 1 amendment. A copy of this letter with attachments is attached.  The City was also required to conduct a public information meeting by April 4, 2019, to present the Part 1 amendments to the public. The public information meeting was conducted on March 19, 2019, as part of the Public Works Committee meeting.

The City must now amend Part 2 of the WHPP.  To kick this process off, City and MDH Staff met on March 28, 2019, to discuss the scope of the required Part 2 amendments.  It was discussed that numerous data elements must be compiled and assessed as related to the management of potential contaminants in the drinking water supply management area that was approved with the WHPP Part 1 amendments.  Data elements are pieces of information in the form of maps, lists, records, tables and inventories. Where appropriate, the elements should be reviewed and assessed in terms of their present and/or future implications on the 1) use of the wells, 2) quality and quantity of water supplying the public water supply wells, and 3) land and groundwater uses in the DWSMA.
 
MDH prepared a Scoping 2 Decision Notice after the meeting, which was submitted to the City via email on April 4, 2019.  The Notice included a list of required data elements.  A hard copy of this Notice, including an attachment noting Potential Contaminant Source Inventory (PCSI) requirements, was received in the mail on April 8, 2019.  Copies of the Scoping 2 Decision Notice and PCSI requirements are attached.
 
Based on Engineering Staff’s current and projected workloads, the scope of work required to amend Part 2 of the WHPP, and the minimal amount of time available to complete this work, Staff recommends enlisting an engineering consultant to complete the work.
 
The cities of Andover and Anoka, who are also members of the Lower Rum River Watershed Management Organization (LRRWMO), enlisted the services of BARR Engineering to complete the Part 2 amendments for their respective WHPP’s.  It is important to note that BARR Engineering is the LRRWMO’s Engineer, and that the LRRWMO reviews and comments on all WHPP Part 2 amendments.
 
Anoka and Andover used the same project manager from BARR, Mr. John Greer, and both cities highly recommended him.  Staff met with Mr. Greer on Monday, April 8, 2019, to discuss his availability to assist the City of Ramsey with our WHPP Part 2 amendments.  Mr. Greer indicated he could assist the City with our Part 2 amendments, and noted that while the timelines are tight he felt that if data requests are addressed in a timely manner the City should be able to meet the MDH deadline of October 6, 2019.  Staff therefore requested that BARR submit a proposal for assisting the City of Ramsey with its WHPP Part 2 amendments, including a not-to-exceed fee.  Staff originally estimated costs for hiring a consultant to assist with the Part 2 amendments to be in the range of $15,000 to $30,000, depending on the scope of work identified in the MDH Scoping 2 Decision Notice.
 
On April 10, 2019, BARR submitted their proposal to amend Part 2 of the City of Ramsey’s WHPP, which includes a not-to-exceed fee of $25,100.  A copy of BARR’s proposal is attached.

Staff estimates 15 minutes will be sufficient to present this case and respond to questions.

As noted in the Scoping 2 Decision Notice, increased concentrations of tritium were recently observed in City wells indicating the wells are capturing post-1953 recharge waters. Tritium, which is a naturally occurring radioactive isotope of hydrogen and is also generated in very small amounts by nuclear power plants, is found in trace amounts in groundwater across the world.  However, tritium was generated in large concentrations in the early 1950’s during nuclear tests.  This finding will also need to be explored by BARR Engineering during the Part 2 amendments.

The current Wellhead Protection Plan is not attached to this case due to the large file size (over 50 MB).

All costs for amending Parts 1 and 2 of the City’s WHPP will be funded through the City of Ramsey’s water enterprise funds, including BARR Engineering’s work, which will be paid through the professional services budget.

Staff has reviewed BARR’s proposed not-to-exceed fee and feels it is reasonable based on the required scope of work.

No action is required at this time. Staff will provide regular updates to the Public Works Committee moving forward, and will request a Committee recommendation for the City Council to approve the amended WHPP upon completion.