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Indiana Department of Environmental Management

IDEM > Your Environment > Source Water Protection - Drinking Water > Wellhead Protection Program > Wellhead: Phase II Implementation Wellhead: Phase II Implementation

The following has been developed to assist Indiana community water systems with fulfilling the Phase II Wellhead Protection Plan ("Phase II plan") rule requirements. The Phase II plan of a community's Wellhead Protection Plan is the implementation of the IDEM-approved Phase I Wellhead Protection Plan. The Phase II plan is due to IDEM 5, 7 or 10 years following the approval date of the Phase I plan, depending on the size of the system.

Phase II Plan Due Dates

The following schedule applies for submittal of all Phase II plans:

  • Large Systems (More than 50,000 population served) = 5 years from Phase I plan approval
  • Medium Systems (3,300 to 50,000 population served) = 7 years from Phase I plan approval
  • Small Systems (Less than 3,300 population served) = 10 years from Phase I plan approval

To determine when your Phase II plan is due:

  • refer to the Phase I plan approval letter from IDEM; or
  • contact the IDEM Ground Water Section - call toll-free at (800) 451-6027, ext. 308-3308 or direct at (317) 234-7477.

Additionally, IDEM will send out reminder letters to each system as the Phase II plan deadline approaches.

Phase II Plan Submittal Requirements (327 IAC 8-4.1-9)

By rule, the Phase II Wellhead Protection Plan submitted to IDEM must include:

  1. an updated Wellhead Protection Area Delineation (if necessary);
  2. an update to the Inventory of Potential Sources of Contamination;
  3. the results of the Implementation of the Phase I Plan; and
  4. documentation of Training of Local Responders.

Link to see the entire Wellhead Protection Rule (327 IAC 8-4.1).

When it is time to submit your Phase II plan, please fill out the Wellhead Protection Plan Phase II application (available on the IDEM Forms page) and submit the application along with the Phase II Wellhead Protection Plan.

IDEM strongly recommends that communities begin documenting their wellhead protection activities beginning as soon as the Phase I plan has been approved. This will prevent the community from having to try to recall all the activities that took place during the implementation period (assistance in documenting and tracking implementation efforts).

The following is a detailed list of items that should be included and/or updated for the Phase II plan (items for which there are no changes or updates, please indicate in the narrative of the Phase II plan that there are no changes or updates):

Wellhead Protection Area Delineation

For systems qualified to use the 3,000-foot radius delineation (pumping less than 100,000 gallons/day) that still pump less than 100,000 gallons/day at the time of the Phase II plan submittal, the 3,000-foot radius can continue to be used. The Phase II plan should include the current pumping rates in order to continue use of the 3,000-foot radius delineation. (327 IAC 8-4.1-7(b))

If at the time of the Phase I plan approval the system qualified for the 3,000-foot radius delineation, but now exceeds 100,000 gallons/day, a model-delineation should be completed and submitted to IDEM. If this applies to your system, please contact the IDEM Groundwater Section for further assistance. (327 IAC 8-4.1-10(c))

For systems that used a model delineation for the Phase I plan (pumping greater than 100,000 gallons/day), an updated model may be necessary for the Phase II plan if any of the following occurred:

  • system added new well(s);
  • system closed any wells;
  • pumping rates changed significantly (±10%) since Phase I plan;
  • the system or IDEM determines that the Phase I plan delineation was not accurate or appropriate;
  • changes in other factors deemed significant by IDEM, such as new nearby high capacity wells. (327 IAC 8-4.1-7(a))

If there is any question about whether a particular system is required to re-delineate, please contact the IDEM Ground Water Section.

Additionally, a discussion in the narrative describing how the updated wellhead protection area compares with the previously delineated wellhead protection area must be included. (327 IAC 8-4.1-9(1)(b) and 327 IAC 8-4.1-10(a)(1))

Inventory of Potential Sources of Contamination

  • The narrative must include a description of any changes in land use. (327 IAC 8-4.1-8(3)(A))
  • An updated Potential Sources of Contamination map must be included that reflects any changes. (327 IAC 8-4.1-8(3)(B))
  • The Phase II must include an updated table of Potential Sources of Contamination (PSC), including the location of any new PSC, and noting the closure or delisting of PSCs that no longer present a threat. The table must include:
    • Facility identification number;
    • Facility name and location;
    • Site description;
    • Any environmental permits issued for the site, including permit number and issuing agency;
    • Types of contamination at the site; and
    • Operating status of the site. (327 IAC 8-4.1-8(3)(C))

Implementation of the Phase I Plan

Management Plan Requirements

  • Indicate any changes in managing the sanitary setback area, including any new problems or concerns with the prohibition of storing and mixing chemicals, access to the wellhead, and best management practices for transportation routes within the sanitary setback area. (327 IAC 8-4.1-8(4)(A)(i-iv))
  • Document and discuss any changes in the management or monitoring measures for all PSCs. (327 IAC 8-4.1-8(4)(B)(i))
  • Discuss any changes in the compliance status of all production wells with state construction standards and permit requirements. (327 IAC 8-4.1-8(4)(B)(ii))
  • Discuss the system's monitoring of contaminants associated with the identified PSC's according to the departments standardized monitoring framework. (327 IAC 8-4.1-8(4)(B)(iii))
  • Discuss the system's methods or procedures for maintaining and updating records concerning changes to potential sources of contamination. (327 IAC 8-4.1-8(4)(B)(iv))
  • Document any abandoned wells found in the WHPA (list abandoned wells found and describe method of search used). Should also discuss methods and timeline for getting them sealed or secured from unauthorized access. (327 IAC 8-4.1-8(4)(B)(v))
  • Discuss how the system has addressed the use, application, storage, mixing, loading, transportation, and disposal of pesticides within the wellhead protection area. (327 IAC 8-4.1-8(4)(B)(vi))
  • Document how property owners, mineral owners and leaseholders of record were notified that they are in a WHPA. (327 IAC 8-4.1-8(4)(B)(vii))
  • Discuss how owners and operators of PSCs have been provided access to the wellhead protection plan. (327 IAC 8-4.1-8(4)(B)(viii))
  • Document public outreach activities (including copies of education materials used, description of outreach program and activities, and dates and locations of outreach activities). (327 IAC 8-4.1-8(4)(B)(ix))
  • Indicate whether Wellhead Protection signs were installed along major transportation routes. IDEM is not enforcing the installation of these signs at this time due to homeland security concerns; however a community may proceed with these signs if they feel it enhances public awareness and emergency response activities. (327 IAC 8-4.1-8(4)(B)(x))

Other Items/Activities Recommended by IDEM

The Phase II plan should include:

  • An updated list of members with their affiliations whether there were any changes in members/affiliations of the Local Planning Team. An updated list of members with affiliations should also be included. (327 IAC 8-4.1-4(b))
  • A list of meetings held since the Phase I plan approval (attach public notices, agendas, minutes) should be included.
  • Include copies of any ordinances or resolutions passed by the city, town or county that affect any aspect of the wellhead protection plan.
  • Include any other new information pertinent to the implementation of the wellhead protection plan, including new strategies for the next five years. For instance, if the plan called for sending out annual letters to Potential Sources of Contamination, indicate when that was done and include copies of the letters sent. If the Phase I indicated that public outreach would include school visits, tours of the water plant, county fair booths, etc., indicate when these activities took place and include any relevant information (narrative descriptions, photos, etc.).

Training of Local Responders

Document local responder training (type of training completed, list of people who completed training, and the date the training was completed). (327 IAC 8-4.1-8(5)(A))

Contingency Plan Requirements

  • Discuss any changes in procedures to be used in emergency response to leaks, spills, or illegal discharges. (327 IAC 8-4.1-8(5)(B))
  • Document that information was provided to local responders including (any changes in the WHPA boundary, any changes in names of CPWSS operators to contact in case of an emergency, and any changes in 24-hour telephone numbers for emergency responders, hospital and water supply owner/operator). (327 IAC 8-4.1-8(5)(C))
  • Discuss any changes in alternate sources of water. (327 IAC 8-4.1-8(5)(D))
  • Discuss any changes in procedures and methods used to notify critical water users of an emergency. (327 IAC 8-4.1-8(5)(E))
  • Update copies of procedures to follow in an emergency and indicate where they are posted. (327 IAC 8-4.1-8(5)(F))
  • Document and discuss any other changes made to the Phase I Contingency Plan.

Additional Phase II Implementation Information

Phase II plan implementation should begin as soon as the Phase I Wellhead Protection Plan has been approved by IDEM. Phase II plan implementation is simply doing the activities that the Phase I plan has indicated that the community will do during the 5-, 7-, or 10-year period prior to the Phase II plan due date. Of course, the community is not limited to doing the activities that are outlined in the Phase I plan. IDEM encourages each community to continually look for new and innovative ways to protect its groundwater resource.

IDEM also encourages each community to constantly and continually track its progress in implementing the Phase I plan. Waiting to compile all of the necessary information and updates until the Phase II plan is due to IDEM will be burdensome and may result in inaccuracies. The best method would be to start a Phase II plan file and document all activities/updates/changes as they occur. This would include, but not be limited to:

  • Agendas, minutes and public notices of all meetings where wellhead protection is discussed.
  • Copies of any informational brochures developed or distributed to water customers or potential sources of contamination.
  • An updated listing of all Potential Sources of Contamination.
  • Copies of letters sent to water customers and potential sources of contamination notifying them that they are located within a wellhead protection area.
  • Copies of any wellhead and/or drinking water ordinance or resolution adopted by the community.
  • Date that surveys of potential sources of contamination and abandoned wells took place.
  • Dates and locations of classroom presentations or classroom water facility tours.
  • Updates to the contingency plan, including new contact person and/or phone numbers.
  • Documents showing all training provided to emergency responders.
  • Any changes to the wellhead delineation including changes in population served, pumping rates, installation of nearby high-capacity wells, etc.
  • Any other changes made to the management plan and/or any additional activities or programs implemented to protect the drinking water supply.

Remember! Fill out the Phase II Wellhead Protection Plan Application form (available on the IDEM Forms page) and submit the form with the completed Phase II plan to:

Indiana Department of Environmental Management
Office of Water Quality/Groundwater Section
100 North Senate Avenue
MC 66-33-2 Shadeland Avenue
Indianapolis, IN 46204-2251