Where is the Water Well? The Competing Interests of Homeland Security and Environmental Health

Can you find the location of a water well in on a governmental mapping system? The answer is maybe – and it varies nationwide. A strong tension between the environmental health protection and safeguards for homeland security controls whether you will find that water well. Environmental health protection invites for more transparency in water well locations to aid vulnerability assessments from spill sites, while homeland security management invites hiding the well locations for fear that terrorist would know their locations to affect an assault. How can we balance the environmental health and security threat, and determine if we have the proper policy course? Why is there so much variance nationally?

The North Carolina mapping system as an example of where the tensions have competed, and have limited the potential of a promising public mapping service. The Public Water Supply Section of the North Carolina Department of Natural Resources maintains an interactive web map that shows water wells juxtaposed with contaminated sites.

Terradex’s stake in this discussion is toward maintaing the effectiveness of our duties of helping assure long term safety around contaminated sites. Greater transparency, or at least permission to view, would facilitate Terradex’s environmental health stewardship functions by permitting a routine view of whether water wells have been installed, or shifted from dormant to active. At Terradex, we believe the benefit to public health protection warrants reconsidering the current paradigm that favors masking well locations, and establishing a mechanism to increase transparency to those serving to protect environmental health.

Since the terrorist attacks of September 11, 2001, the well mapping pendulum quickly shifted to favor the concern posed by terrorist threats to drinking water supply. This led to the shutting off of convenient web-based access to water well information. Given Terradex’s California origins, we experienced first hand the disappearance of water well locations from state mapping systems. California’s GeoTracker displayed water wells, then in response to homeland security concerns the California Department of Public Health quickly locked down the data pertaining to occurrence and location of private and public water wells.

Terradex nationally scours state and county systems to be alert to installation of new water wells to a site with residual contamination. Many institutional controls place a limit on development of new water wells. Terradex periodically reviews our monitored sites for new water wells, and issues an alert when recently installed wells are discovered. Therefore we noticed the North Carolina well mapping system as a model as we fulfilled our institutional control monitoring duties, but also saw that its potential hampered by the unresolved tension between two important concerns.

Water Wells Will Always Be Vulnerable to Spill Sites

There are typically two classes of water supply wells: 1) community wells which have a relatively large service area and are typically regulated by a state agency, and 2) private water wells which are typically permitted by a county health agency. State agencies often catalog private water wells even though the permitting duty for private wells ordinarily rests with the county agency (e.g., county health departments).

Contamination of water supply wells is a proven risk. The seminal research of the late 1990s by Lawrence Livermore National Laboratory (LLNL) analytically reached the conclusion that an actual threat occurs anywhere land is developed near soil and groundwater contamination and when nearby groundwater is used as a source of drinking water.

Figure 8-35 from the LLNL study models the absolute threat probability over a 100-year time span for the 30% of Leaking Underground Fuel Tanks (LUFT) sites in California where benzene may threaten to impact a well. Potential impacts for benzene with and without ethanol are shown. The threat increases over time, and stands as a reminder for the importance of tracking water well usage.

Additionally, Figure 8-47 from the LLNL article shows, the threat is prevalent where where population occurs and increases where reliance on private water wells persists.Private wells typically have shallower well seals, and are more vulnerable to groundwater contamination in shallow aquifers. In metropolitan areas, the reliance shifts to community wells which typically have deeper seals and are less likely at risk. Still, when an impact to a public well occurs, the consequences can be enormous as occurred in Santa Monica, California in the 1990s.

The lesson from this research is that any spill site should assess vulnerability to nearby water supply wells – both community/public and private. The threat is ongoing, especially as plumes could be destabilized by groundwater pumping and migrate toward a water well. This concern is typically embodied into institutional controls, and Terradex carries the duty for its clients to validate that wells are not developed.

Homeland security concerns, in some states, purposely limit the ability to know the location and status of water wells, both private and public. The interest served by being cautious for homeland security could make assessing the health threats posed to water wells near spill sites difficult to do and, in turn, may increase the likelihood that contamination of these wells will occur into the future. As such, we welcomed seeing North Carolina’s approach whereby spill sites and water wells are displayed on a common mapping platform.

North Carolina’s Water Well Mapping System Is A Model for Showing Water Well Vulnerability

The mapping system by North Carolina is representative of the potential for environmental professionals when they need to evaluate the proximity of water wells to contaminated sites. The screenshot of the system below shows water wells mapped, as well as contaminated sites. The mapping system allows zooming to an area of interest, and selecting well types or potential contaminated sources to aid a vulnerability evaluation.

A screenshot of the North Carolina Public Water Supply Mapping system.

The North Carolina Mapping systems strength is the catalog of water wells the map maintains and the ability to juxtapose numerous categories of spill sites relative to a well locations. This map view highlights how water wells and contaminated sites are close to each other, and therefore drinking water derived from water wells is vulnerable to contamination.

While the North Carolina mapping system offers a glimpse to the future, the well location mapping could be even better:

  • Stale Water Well Data is Dated. The water well data has not been updated for approximately two years. While water well information changes slowly, this limits the tools utility when one is looking for the occurrence of new water wells that may be unknowingly vulnerable.
  • Usability Shortcomings. According to an interview with North Carolina Public Water Supply Section, poor usability issues were designed into the mapping system. For example, there is no capability to search by address. Additionally, the street level coverage is limited. Ultimately, this prevents most users from finding helpful information and makes use of the tool tedious.
  • Well Detail Information. When requesting information on a well through web data systems, the North Carolina data systems do not identify the well’s location.

According to North Carolina, the apparent shortcomings are intentional to satisfy homeland security concerns. While the mapping system shows great potential, the usability concerns still hinder the site’s practical use to assess vulnerability. If you can’t find a site or consider nearby roads, how can you practically assess vulnerability? You can’t. With a change of priorities, the mapping system for North Carolina is well poised to become a national model of disclosure of water well information for interested parties to judge the threat of contamination to nearby wells.

Screenshot of Mecklenburg County Water Well Information System

At the County level we have discovered additional examples of transparency of water well location information. North Carolina at Mecklenburg County shows a mapping system with water wells juxtaposed to contaminated sites. Dennis Tyndall with the County described how the water well information is updated each night, so the public can discover new water wells in close to real time. The system periodically succeeds in preventing new water wells in areas of contamination. The implementation of this mapping system began with the County passing a groundwater ordinance that demanded that the County staff evaluate all new water well permits against the presence of spill sites. The mapping tool they generated for their internal use, was displayed in a simpler form for public use. While at the County level, this again represents a fresh model for disclosure of water well locations.

A Challenging Tension Exists Between Environmental Health Protection and the Perceived Need to Protect Against Homeland Security Risk

So far we have established the vulnerability of the drinking water supply through spills of chemicals to land. What do we know about the threats to the drinking water supply by terrorism? In an article “Water and Terrorism” by Dr. Peter Gleick of the Pacific Institute, Dr. Gleick consider the broad security risks to the water supply, and also delved into threats to water supplied through wells. The article is summarized below:

“The importance of freshwater and water infrastructure to human and ecosystem health and to the smooth functioning of a commercial and industrial economy makes water and water systems targets for terrorism. The chance that terrorists will strike at water systems is real; indeed, there is a long history of such attacks. Water infrastructure can be targeted directly or water can be contaminated through the introduction of poison or disease causing agents. The damage is done by hurting people, rendering water unusable, or destroying purification and supply infrastructure. More uncertain, however, is how significant such threats are today, compared with other targets that may be subject to terrorist attack, or how effective such attacks would actually be. Analysis and historical evidence suggest that massive casualties from attacking water systems are difficult to produce, although there may be some significant exceptions. At the same time, the risk of societal disruptions, disarray, and even overreaction on the part of governments and the public from any attack, may be high.”

Within Glieck’s research, there are only a few identified events of terrorist impact on water wells, and these terrorist events were primitive — for example, the dumping of dead bodies into wells in Kosovo or Angola. No threats to water wells were catalogued typical of scenarios whereby a well system’s integrity is violated by a chemical reagent. The article identifies more likely terrorist scenario such as attacking larger reservoirs or water works.

Apparently, in 2001 there was a threat to the US water supply. Gay Porter DeNileon reports in an article titled Critical Infrastructure Protection: The Who, What, Why, and How of Counterterrorism Issues that a threat to the US water supply was received by the FBI. The threat proved to be a hoax, but became a basis for water agencies to observe water system vulnerability. Mr. DeNieleon reporting seems to have highlighted an origin of the hiding of locational information regarding water wells. He reports:

“One of the biggest issues that many water utility executives raise is the confidentiality of information, e.g., concerns that the public may have easy access to details of a vulnerability assessment under local and state Freedom of Information Act (FOIA) laws. The federal FOIA allows agencies to withhold information that “could reasonably be expected to endanger the life or physical safety of any individual,” and “geological and geophysical information and data, including maps, concerning wells” (FOIA). Also at the federal level, most sensitive data would not be available, because utilities are not required to provides such information to USEPA or any other agency at this time. A water industry ISAC and the FBI and the National Infrastructure Protection Center (NIPC – now assimilated into the US Department of Homeland Security) identified that the Infraguard program may be the answer to some of these concerns. By limiting access to, and possibly encrypting information, only those with the proper access codes or passwords will be allowed read or browse specific data. The USEPA and Association of Metropolitan Water Agencies (AWMA) are also working with the CIAO to assist municipal utilities in dealing with local and state FOIA laws. Utilities are advised, nevertheless, to have their attorneys review any plans to collect sensitive information, such as the results of vulnerability assessments, to ensure that the utility has a basis for withholding information under state and local laws.”

Though we have found possible origins of confidentiality on water wells, this policy is not uniformly implemented nationwide. Many states like Illinois or Texas, disclose water well information, while other large states like California do not. In a FOIA response to Terradex, California Department of Public Health identifies a rationale, but provides no direct substantiation.

Concluding Thoughts

This policy arena demands a fresh looks, and a method should be designed by which environmental professionals may find locational information with which to accomplish their mission: the protection of the drinking water supply from threats posed by nearby sources of environmental contamination. Terradex cannot evaluate the current nature of terrorist threats, nor would that be appropriate. However, the literature reports no incidents that substantiate postures held by some agencies. We recommend that states develop limited-access procedures to permit environmental professionals to obtain copies of water well maps to conduct analysis. We know that the threats posed by contamination are credible, and there are ample tools to permit environmental professionals find the locational information to complete their health and safety duties. While some states already do not find hiding water wells necessary, those states, like California, could use credentials to be responsive to homeland security concerns while also serving environmental health objectives.

We know this post is not exhaustive, and therefore not complete in its perspective. The inspiration for this post was the difficulty to achieve Terradex’s duty of protectiveness against barriers set by homeland security concerns. If you have experience with mapping systems that display water wells, or with states that have made policy changes to sway the pendulum toward further disclosure of water wells, then please share this knowledge. We will evolve this post to share the state of water well information disclosure.

Updates

Where does the authority for masking water wells lie? The USEPA is guided by Legislation and Directives, but these directives do not stipulate that the locations of water supply wells should be hidden. The USEPA’s programs are informed by the Bioterrorism Act that includes protection of community drinking water systems. Again, the Act does not direct hiding water well locations. According to USEPA, these determinations to hide water wells are a state or possibly utility determination.

We also enjoyed a well developed conversation on LinkedIn’s Environmental Issues in Business Transactions group. We can watch this develop.

One Comment

  1. Tina Berry
    Posted August 24, 2011 at 3:48 pm | Permalink

    Your point is well taken, Bob. Having formerly worked as an environmental professional, I can appreciate the challenges behind national security protection and the need for environmental risk evaluation and analysis. I would add to your argument that the “public right-to-know” is equally important. As a concerned citizen, homeowner and parent, one should have access to water well information to determine potential threats to one’s self, one’s family and/or one’s property. Mapping systems made available to the public by regulatory agencies would be helpful in this.

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