LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
2­
1
2.0
Watershed
Control
Program
2.1
Introduction
A
well­
designed
watershed
control
program
can
result
in
a
reduction
of
overall
microbial
risk.
The
risk
reduction
is
associated
with
the
implementation
of
practices
that
reduce
Cryptosporidium
as
well
as
other
pathogens.
Further,
knowledge
of
the
watershed
and
factors
affecting
microbial
risk,
including
sources
of
pathogens,
fate
and
transport
of
pathogens,
and
hydrology,
can
also
help
a
system
reduce
microbial
risk.

There
are
many
potential
sources
of
Cryptosporidium
in
watersheds,
including
sewage
discharges
and
nonpoint
sources
associated
with
animal
feces.
The
feasibility,
effectiveness,
and
sustainability
of
control
measures
to
reduce
Cryptosporidium
contamination
of
water
sources
will
be
site­
specific.
Consequently,
the
watershed
control
program
credit
centers
on
systems
working
with
stakeholders
in
the
watershed
to
develop
a
site­
specific
program,
and
State
review
and
approval
are
required.
This
section
is
intended
to
assist
water
systems
in
developing
their
watershed
control
programs
and
States
in
assessing
and
approving
these
programs.

A
watershed
control
program
can
serve
an
additional
purpose
 
it
can
also
be
a
component
of
a
comprehensive
source
water
protection
program
that
addresses
chemical
and
microbial
contaminant
threats.
Much
of
the
background
information
and
preparation
needed
to
develop
a
watershed
control
program
and
comprehensive
source
water
protection
program
are
already
complete
as
a
result
of
the
source
water
assessments
required
under
the
1996
Amendments
to
the
Safe
Drinking
Water
Act.
Section
1453
of
the
Act
required
States
to
conduct
source
water
assessments
for
all
public
water
systems,
including
delineating
the
"
boundaries
of
the
areas
providing
source
waters
for
PWSs
and
identifying
the
origins
of
regulated
and
certain
unregulated
contaminants
in
the
delineated
area
to
determine
the
susceptibility
of
the
PWSs
to
such
contaminants."
Information
resulting
from
these
assessments
should
be
available
from
the
States.
Information
may
also
be
available
in
systems
that
have
had
watershed
sanitary
surveys
done.
These
surveys
are
required
as
part
of
the
Interim
Enhanced
Surface
Water
Treatment
Rule
(
IESWTR),
and
some
States
have
required
them
for
years.

2.1.1
Credits
Filtered
systems
that
develop
a
State­
approved
watershed
control
program
designed
to
reduce
the
level
of
Cryptosporidium
in
the
watershed
can
receive
a
0.5
log
credit
towards
the
Cryptosporidium
treatment
requirements
under
the
LT2ESTWR
(
40
CFR
141.722).
The
watershed
control
program
credit
can
be
added
to
the
credit
awarded
for
any
other
toolbox
component.
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
2­
2
The
list
below
provides
the
organization
for
the
rest
of
this
chapter.

2.2
What
Kinds
of
PWSs
Should
Implement
Watershed
Control
Programs
­
discusses
case
studies
of
watershed
control
programs
in
place
at
different
PWSs
around
the
Unites
States;
describes
advantages
and
disadvantages
of
implementing
a
watershed
control
program;
and
what
to
do
if
your
system
already
has
a
watershed
control
program.

2.3
How
Do
I
Apply
for
Approval
­
discusses
procedure
systems
must
follow
to
apply
for
approval
to
implement
a
watershed
control
program.
The
following
procedures
are
described:
notifying
the
State
of
intent
to
participate;
initial
approval
of
watershed
control
program;
and
maintaining
approval
of
watershed
control
program.

2.4
Developing
the
Watershed
Control
Program
Plan
­
discusses
the
factors
systems
should
consider
in
determining
the
impact
Cryptosporidium
has
on
their
water
quality,
along
with
descriptions
of
best
management
practices
systems
can
use
to
protect
their
source
water
from
Cryptosporidium.
The
following
four
areas
are
discussed:
vulnerability
analysis;
analysis
of
control
measures;
writing
the
watershed
control
plan;
and
how
States
should
assess
plans.

2.5
Maintaining
Approval
of
a
Watershed
Control
Program
­
discusses
annual
watershed
control
program
status
report,
State
approved
watershed
sanitary
survey,
request
for
re­
approval,
and
guidance
to
States
on
re­
approval.

2.2
What
Kinds
of
PWSs
Should
Implement
Watershed
Control
Programs?

Many
types
of
systems
can
benefit
from
a
watershed
control
program.
This
section
contains
case
studies
of
watershed
control
programs
in
place
at
different
PWSs
around
the
United
States.
These
studies
show
how
systems
of
different
sizes
and
source
water
types
and
with
varying
regulatory
authority
have
adopted
watershed
control
programs
to
fit
their
specific
needs.
This
section
also
describes
advantages
and
disadvantages
of
implementing
a
watershed
control
program.

2.2.1
Case
Studies
of
Existing
Watershed
Control
Programs
Watershed
control
programs
should
be
based
on
site­
specific
conditions.
A
successful
program
will
address
the
unique
combination
of
land
use,
land
ownership,
zoning,
regulatory
controls,
contaminant
sources,
and
natural
characteristics
of
the
watershed
being
considered.
The
size,
ownership,
and
jurisdictional
nature
of
the
water
utility
will
also
affect
the
role
it
plays
in
the
watershed
control
program
(
AWWARF
1991).
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
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As
shown
by
the
case
studies
below,
successful
watershed
control
programs
will
vary
significantly
in
their
approach
to
source
protection.
The
systems
in
the
case
studies
did
not
focus
specifically
on
Cryptosporidium
but
on
controlling
microbial
point
and
non­
point
sources
and
other
contaminants.
However,
many
of
the
elements
noted
in
these
case
studies
may
be
useful
in
watershed
control
programs
addressing
Cryptosporidium.
For
more
case
studies,
see
Protecting
Sources
of
Drinking
Water:
Selected
Case
Studies
in
Watershed
Management
(
U.
S.
EPA
1999a).

Burlington,
Vermont
Medium
Surface
Water
PWS,
Watershed
Located
in
Multiple
Jurisdictions
The
City
of
Burlington
has
a
population
of
40,000
and
is
located
on
the
shore
of
Lake
Champlain,
a
120­
mile
long,
12­
mile
wide
lake
that
is
the
source
of
drinking
water
for
the
city
and
other
municipalities.
In
such
a
large
watershed
with
multiple
landowners,
it
is
difficult
to
control
activities
that
affect
water
quality.
Burlington
addresses
microbial
pollution
through
a
combination
of
land
use
control,
reduction
in
combined
sewer
overflow,
watershed
restoration,
and
outreach.

Through
Act
250,
the
State
of
Vermont
regulates
land
use
near
lake
shores
and
rivers,
accounting
for
new
wastewater
treatment
plants
and
sewer
systems,
timber
management,
impervious
surface
area,
water
withdrawal
by
ski
areas
for
snowmaking,
and
other
issues.
To
address
combined
sewer
overflow
problems
that
were
affecting
Lake
Champlain
water
quality,
the
city
increased
the
capacity
of
its
main
wastewater
treatment
plant
and
extended
the
outfall
far
into
the
lake
to
dilute
the
effluent.
The
city
separated
the
sanitary
and
storm
sewers
at
its
smaller
plants.
Two
streams
feeding
into
the
lake
that
suffer
from
poor
water
quality
are
currently
undergoing
restoration,
including
retrofitting
of
existing
storm
water
detention
ponds,
channel
stabilization
to
prevent
erosion,
and
outreach
to
change
pet
waste
management,
lawn
care,
and
other
practices
(
U.
S.
EPA
2001a).

Manchester,
New
Hampshire
Large
Surface
Water
System
Where
State
Plays
an
Active
Role
The
City
of
Manchester
gets
its
water
from
Lake
Massabesic,
which
is
located
approximately
three
miles
east
of
downtown
Manchester.
Management
of
the
water
supply
is
primarily
under
the
jurisdiction
of
the
Manchester
Water
Works.
The
lake
has
a
surface
area
of
about
2,500
acres
and
a
gross
storage
capacity
of
nearly
15
billion
gallons.
For
more
than
120
years,
this
reservoir
has
served
Manchester
and
five
other
communities.
The
Lake
Massabesic
water
supply
is
supplemented
by
Tower
Hill
Pond,
which
has
a
gross
storage
capacity
of
1.3
billion
gallons.
Manchester
controls
microbial
pollution
by
restricting
land
use
in
the
portions
of
the
watershed
controlled
by
the
water
works
and
the
State.

The
watershed
area
for
the
supply
covers
42
square
miles
with
over
25
percent
owned
and
managed
by
the
New
Hampshire
Department
of
Environmental
Services
(
NHDES).
The
NHDES
monitors
these
areas
and
controls
recreational
use
through
regulations
posted
in
the
surrounding
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
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June
2003
2­
4
area,
which
are
enforced
by
a
staff
of
watershed
patrol
officers.
These
regulations
strictly
prohibit
such
activities
as
waste
disposal,
horseback
riding,
boating,
or
any
other
activity
that
would
immediately
or
indirectly
endanger
the
surface
water
quality.
Other
areas
of
the
watershed
are
primarily
monitored
by
the
Manchester
Water
Works
and
have
regulated
levels
of
outdoor
recreation.
Activities
such
as
mountain
biking
or
the
establishment
of
docks
and
moorings
are
subject
to
review
and
permitting
by
this
agency.
Parts
of
Lake
Massabesic
closest
to
the
intake
are
closed
to
all
activity.

The
NHDES
has
provided
funding
to
the
Manchester
Water
Works
for
the
protection
of
its
watershed,
specifically
funding
the
installation
of
a
storm
water
treatment
facility
and
a
project
to
address
erosion
and
sedimentation.
DES
also
provided
funding
for
emergency
planning,
wellhead
protection
management
plans,
drainage
mapping,
storm
water
best
management
practices,
and
public
outreach
and
education.
The
source
of
all
this
funding
was
the
source
water
protection­
related
set­
asides
from
the
Drinking
Water
State
Revolving
Fund
(
U.
S.
EPA
2001b).

Springfield,
Missouri
Large
GWUDI
and
Surface
Water
System
with
Rapidly
Urbanizing
Watershed
Springfield
is
a
city
of
approximately
150,000
residents
located
in
southwestern
Missouri.
Much
of
Springfield's
bedrock
is
limestone
and
dolomite,
and
karst
features
are
very
pronounced.
There
are
numerous
losing
streams,
springs,
and
large
concentrations
of
sinkholes
in
the
area.
The
city's
drinking
water
is
provided
by
City
Utilities
of
Springfield,
a
municipally­
owned
utility.
The
city
uses
a
combination
of
springs,
wells,
reservoirs,
and
the
James
River
to
supply
its
daily
demand
of
approximately
30
MGD.

The
three
primary
threats
to
Springfield's
water
quality
that
have
been
identified
by
its
watershed
committee
are:
1)
urbanization
in
the
watershed;
2)
wastewater
treatment
in
suburban
and
rural
areas,
which
consists
primarily
of
septic
systems
on
karst
terrain;
and
3)
agriculture,
especially
animal
waste
from
concentrated
beef
and
dairy
cattle
operations.
Agricultural
and
urban
BMPs
are
the
primary
methods
used
to
address
microbial
contaminants.

In
1984
a
citizen­
based
Watershed
Management
Coordinating
Committee
was
established
to
guide
and
oversee
water
protection
efforts.
The
group
later
incorporated
as
a
non­
profit
organization
and
renamed
itself
the
Watershed
Committee
of
the
Ozarks.
The
committee's
operating
budget
is
provided
by
Greene
County
(
in
which
much
of
the
watershed
lies),
the
City
of
Springfield
(
containing
the
bulk
of
the
water
users),
and
City
Utilities
(
U.
S.
EPA
2001c).

In
2001,
the
Committee
hosted
a
workshop
on
conservation
development
and
better
site
design
for
Springfield
and
Greene
County
planning
and
zoning
staff
members,
hosted
a
workshop
on
agricultural
best
management
practices
(
BMPs)
for
farmers,
helped
local
developers
incorporate
stormwater
BMPs
and
better
site
design
into
their
developments,
and
helped
local
farmers
install
alternative
watering
facilities.
The
Committee
currently
has
grants
under
Section
319
of
the
Clean
Water
Act
to
restore
several
of
the
area's
watersheds.
One
of
these
grants
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
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2­
5
involves
a
study
of
the
current
and
future
loading
rates
of
sediment
and
nutrients
and
future
construction
of
a
wetland
or
forebay
to
treat
runoff
from
the
Valley
Water
Mill
watershed
as
it
enters
the
reservoir.
Another
project
for
the
Little
Sac
River
Watershed,
which
provides
85
percent
of
Springfield's
water,
has
just
gotten
underway
(
Watershed
Committee
of
the
Ozarks
2001).

2.2.2
What
Are
The
Advantages
and
Disadvantages
of
a
Watershed
Control
Program?

2.2.2.1
Advantages
Although
the
costs
associated
with
implementing
a
particular
toolbox
option
are
systemspecific
a
watershed
control
program
can
cost
less
than
options
that
require
additional
technology
be
installed.
This
is
especially
the
case
if
other
stakeholders
contribute
time
and
resources
to
the
watershed
control
program.
Stakeholders
could
include
concerned
citizens
along
with
other
municipalities,
other
agencies
in
the
same
municipality,
and
county
or
State
employees.
Watershed
control
programs
that
involve
land
acquisition
or
purchase
of
easements,
however,
may
be
as
or
more
expensive
than
installing
treatment.

Funding
is
available
to
implement
many
aspects
of
a
watershed
control
program.
For
example,
the
Clean
Water
Act
authorizes
State
revolving
fund
loans
to
upgrade
wastewater
treatment
plants
and
provides
grants
(
under
Section
319)
for
control
of
nonpoint
source
pollution.
The
Farm
Bill
of
2002
authorizes
several
billion
dollars
for
management
of
agricultural
pollution.
Drinking
Water
State
Revolving
Funds
are
also
available
to
a
limited
extent
for
source
water
protection.
Each
State
may
set
aside
as
much
as
15
percent
of
its
grant
each
year
to
provide
loans
for
source
water
protection
activities,
including
land
or
easement
acquisition,
implementation
of
incentive­
based
voluntary
source
water
protection
programs,
and
implementation
of
wellhead
protection
programs.

In
addition,
much
of
the
information
required
to
implement
a
watershed
program,
such
as
a
contaminant
source
inventory
and
delineation
of
the
watershed,
will
already
be
available
as
a
result
of
the
source
water
assessment
conducted
under
the
1996
Safe
Drinking
Water
Act
Amendments.
Section
1453
directs
States
to
have
completed
source
water
assessments
of
PWSs
by
2003.
Although
source
water
assessment
programs
vary
from
State
to
State,
they
will
all
provide
much
of
the
information
required
to
implement
a
watershed
program,
allowing
systems
to
incorporate
existing
information
into
their
watershed
control
plans
at
minimal
cost.

Flexibility
is
another
advantage
of
a
watershed
control
program.
A
watershed
control
program
allows
a
system
to
design
a
suite
of
pollution
management
measures
tailored
to
the
physical,
political,
and
economic
characteristics
of
the
local
environment.
This
enables
systems
to
focus
resources
on,
and
restrict
costs
to,
actions
that
address
the
highest
priority
contaminants.
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
2­
6
The
reduction
and
prevention
of
source
water
contamination
by
microbial
pathogens
may
also
serve
other
public
health
and
ecological
goals,
such
as
use
of
the
water
body
for
fishing
and
swimming,
reduction
of
ground
water
contamination,
and
protection
of
aquatic
habitats
and
the
species
that
depend
on
such
habitats
for
survival.

2.2.2.2
Disadvantages
There
are
some
circumstances
where
a
watershed
control
program
may
not
be
successful.
Systems
should
consider
the
following
potential
pitfalls
in
deciding
whether
to
adopt
a
watershed
control
program.
Because
Cryptosporidium
occurs
in
low
concentrations
and
is
difficult
to
detect
using
existing
analytical
methods,
it
can
be
hard
to
determine
whether
concentrations
have
decreased
as
a
result
of
a
watershed
control
program.
In
addition,
microbiological
contaminants
are
frequently
related
to
nonpoint
sources,
and
control
of
these
sources
is
often
highly
dependent
on
changing
the
behaviors
of
large
groups
of
people.
In
a
voluntary
program
(
e.
g.,
if
the
water
system
has
no
authority
to
regulate
land
use
and
is
encouraging
landowners
to
voluntarily
take
action),
it
is
difficult
to
determine
whether
individuals
are
making
the
recommended
changes
necessary
to
control
contaminants.
Although
the
required
annual
watershed
survey
will
assist
in
evaluating
progress,
systems
that
implement
watershed
control
programs
will
need
to
be
creative
in
finding
ways
to
gauge
the
success
of
their
programs.

A
successful
watershed
control
program
requires
the
cooperation
of
a
variety
of
stakeholders;
however,
it
may
be
difficult
to
get
agreement
or
participation
from
these
stakeholders.
Alternatively,
stakeholder
groups
may
agree
to
perform
certain
activities,
such
as
outreach,
but
could
lose
funding
and
be
unable
to
follow
through
on
their
commitments.
Systems
that
have
concerns
about
the
likelihood
of
building
strong
relationships
with
their
stakeholders
may
decide
that
a
watershed
control
program
is
not
appropriate
for
them.
In
some
watersheds,
depending
on
size
of
the
watershed
control
program
and
the
ability
to
share
costs
with
others,
significant
PWS
staff
time
may
be
required
to
oversee
a
program.
These
costs
may
be
prohibitive
for
some
systems.

Urban
growth
and
land
development
can
affect
the
success
of
a
watershed
control
program.
If
growth
occurs
too
quickly
and
there
are
insufficient
controls
on
development,
the
subsequent
decline
in
water
quality
can
cancel
out
or
even
outstrip
any
improvement
resulting
from
the
watershed
program.
In
high­
growth
areas,
PWSs
should
make
sure
that
the
community
is
willing
to
support
restrictions
on
development.

2.2.3
What
If
I
Already
Have
a
Watershed
Control
Program?

Systems
that
already
have
a
watershed
control
program
in
place
are
permitted
to
choose
this
option;
however,
they
will
have
to
amend
and
strengthen
their
programs
to
get
the
log
removal
credit.
This
is
because
the
credit,
for
all
systems,
is
based
on
control
measures
that
are
in
addition
to
the
program
already
in
place.
To
get
the
additional
credit,
a
system
with
an
existing
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
2­
7
watershed
control
program
could,
for
example,
increase
public
outreach
efforts
or
toughen
land
use
ordinances
that
affect
water
quality.
Systems
with
existing
programs
must
still
go
through
the
entire
application
process.

2.3
How
Do
I
Apply
for
Approval?

After
notifying
their
States
of
their
intention
to
participate,
systems
must
include
several
items
in
their
watershed
control
program
plans.
In
addition
to
the
plan
itself,
systems
must
submit
a
vulnerability
analysis
and
an
analysis
of
the
interventions
they
considered
in
developing
the
plan.
The
procedure,
based
on
the
preamble
to
the
LT2ESWTR,
is
provided
below
(
U.
S.
EPA
2002a).

2.3.1
Notifying
the
State
of
Intention
to
Participate
Systems
must
notify
their
States
of
their
intention
to
implement
a
watershed
control
program
within
one
year
of
learning
their
initial
bin
assignment
based
on
Cryptosporidium
monitoring
(
40
CFR
141.725(
a)(
1)).
The
application
and
plan
must
be
submitted
for
approval
within
two
years
after
initial
bin
assignment
(
40
CFR
141.725(
a)(
2)).

2.3.2
Initial
Approval
of
Watershed
Control
Program
Plan
Initial
State
approval
of
a
system's
watershed
control
program
will
be
based
on
State
review
of
the
system's
proposed
watershed
control
plan
and
supporting
documentation,
including
a
vulnerability
analysis
and
analysis
of
the
proposed
control
measures
(
40
CFR
141.725(
a)(
3)).
The
initial
approval
will
be
valid
until
the
system
completes
the
second
round
of
Cryptosporidium
monitoring
(
systems
begin
a
second
round
of
monitoring
six
years
after
the
initial
bin
assignment)
(
40
CFR
141.725(
a)(
4)).
At
the
very
latest,
systems
must
begin
implementing
the
program
42
months
(
three
and
a
half
years)
after
the
end
of
the
source
water
monitoring
period
(
40
CFR
141.701).
The
program
elements
are
summarized
below
and
described
in
more
detail
in
section
2.4.

2.3.2.1
Vulnerability
Analysis,
Including
Area
of
Influence
The
application
must
include
an
analysis
of
the
system's
source
water
vulnerability
to
the
different
sources
of
Cryptosporidium
identified
in
the
watershed.
The
vulnerability
analysis
must
characterize
watershed
hydrology
and
identify
an
"
area
of
influence
on
source
water
quality"
(
the
area
to
be
considered
in
future
watershed
surveys).
The
analysis
must
also
address
sources
of
Cryptosporidium,
seasonal
variability,
and
the
relative
impact
of
the
sources
of
Cryptosporidium
on
the
system's
source
water
quality
(
40
CFR
141.725(
a)(
3)(
i)).
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
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June
2003
2­
8
2.3.2.2
Analysis
of
Control
Measures
The
application
must
present
an
analysis
of
control
measures
that
could
address
the
sources
of
Cryptosporidium
contamination
identified
in
the
vulnerability
analysis.
The
analysis
of
control
measures
must
discuss
the
effectiveness
of
each
measure
in
reducing
Cryptosporidium
in
source
water
(
40
CFR
141.725(
a)(
3)(
ii)).

2.3.2.3
Watershed
Control
Plan
The
watershed
control
plan
must
be
submitted
within
two
years
of
initial
bin
assignment.
It
must
address
goals
and
define
and
prioritize
specific
actions
to
reduce
source
water
Cryptosporidium
levels.
The
plan
must
explain
how
actions
are
expected
to
contribute
to
specified
goals;
identify
partners
and
their
roles,
resource
requirements,
and
commitments;
and
include
a
schedule
for
plan
implementation
(
40
CFR
141.725(
a)(
3)(
iii)).

2.3.2.4
Approval
and
Conditional
Approval
The
State
must
review
each
system's
proposed
watershed
control
program
plan
and
either
approve,
reject,
or
conditionally
approve
the
plan.
If
the
plan
is
approved,
or
if
the
system
agrees
to
implementing
the
State's
conditions
for
approval,
the
system
will
be
awarded
0.5
log
Cryptosporidium
removal
credit
to
apply
toward
additional
treatment
requirements.

2.3.3
Maintaining
Approval
of
Watershed
Control
Program
Systems
that
have
obtained
State
approval
of
their
watershed
control
programs
are
required
to
meet
the
following
additional
requirements
within
each
approval
period
to
maintain
compliance
with
their
programs
and
continue
their
eligibility
for
the
0.5
log
removal
credit.

°
Submit
an
annual
watershed
control
program
status
report
to
the
State
during
each
year
of
the
approval
period
(
40
CFR
141.725(
a)(
4)(
i)).

°
Conduct
an
annual
State­
approved
watershed
sanitary
survey
and
submit
the
survey
report
to
the
State
(
40
CFR
141.725(
a)(
4)(
ii)).

The
annual
status
reports,
watershed
control
plan,
and
annual
watershed
sanitary
surveys
must
be
made
available
to
the
public
upon
request.
These
documents
must
be
in
plain
language
format
and
include
criteria
by
which
to
evaluate
the
success
of
the
program
in
achieving
plan
goals.
The
State
may
withhold
portions
of
the
annual
status
report,
watershed
control
plan,
and
watershed
sanitary
survey
based
on
security
considerations
(
40
CFR
141.725(
a)(
4)(
iii)).

The
initial
State
approval
of
the
system's
watershed
control
program
is
valid
until
the
system
completes
the
required
second
round
of
Cryptosporidium
monitoring
(
40
CFR
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
2­
9
141.725(
a)(
4)).
To
be
reapproved
and
to
continue
receiving
0.5
log
treatment
credit,
the
system
must
submit
to
the
State
an
application
for
review
and
re­
approval
of
the
watershed
control
program
six
months
before
the
initial
approval
period
ends
(
40
CFR
141.725(
a)(
4)(
iii)).

2.3.3.1
Submit
Annual
Status
Report
The
annual
watershed
control
program
status
report
must
be
submitted
during
the
last
three
months
of
each
year
of
the
approval
period,
or
by
a
date
determined
by
the
State.
The
report
must
describe
the
system's
implementation
of
the
approved
plan
and
assess
the
adequacy
of
the
plan
for
meeting
the
system's
goals.
It
also
must
explain
how
the
system
is
addressing
any
shortcomings
in
plan
implementation,
including
those
previously
identified
by
the
State
or
by
the
system
during
a
watershed
survey.
If
the
system
made
any
substantial
changes
to
its
approved
program,
it
must
describe
the
changes
and
explain
the
reason
for
making
them.
If
the
change
is
likely
to
reduce
the
level
of
source
water
protection,
the
system
must
explain
what
actions
it
will
take
to
mitigate
the
effects
(
40
CFR
141.725(
a)(
4)(
i)).

2.3.3.2
Conduct
State­
Approved
Watershed
Sanitary
Survey
The
State­
approved
watershed
survey
must
be
conducted
annually
according
to
State
guidelines
and
by
persons
approved
by
the
State
to
conduct
watershed
surveys.
A
report
on
the
results
of
the
survey
must
be
submitted
to
the
State
annually.
The
survey
must
cover
the
area
of
the
watershed
that
was
identified
in
the
approved
watershed
control
program
plan
as
the
area
of
influence
and
must
focus
on
assessing
the
priority
activities
identified
in
the
plan
and
on
identifying
any
significant
new
sources
of
Cryptosporidium
(
40
CFR
141.725(
a)(
4)(
ii)).
More
information
on
watershed
surveys
is
provided
in
section
2.5.2.

2.3.3.3
Request
Review
and
Re­
Approval
The
system
must
request
a
review
of
its
watershed
control
program
by
the
State
at
least
six
months
before
the
approval
period
expires
or
by
a
date
previously
determined
by
the
State.
The
request
must
summarize
activities
and
issues
identified
during
the
approval
period
and
must
include
a
revised
plan
that
addresses
activities
for
the
next
approval
period.
The
revised
plan
must
detail
any
proposed
changes
to
the
existing
State­
approved
program.
As
with
the
initial
request
for
State
approval,
the
plan
must
address
goals,
prioritize
specific
actions
intended
to
reduce
source
water
Cryptosporidium,
explain
how
these
actions
are
expected
to
contribute
to
the
achievement
of
goals,
identify
partners
and
their
roles
and
resource
requirements,
and
provide
a
schedule
for
plan
implementation
(
40
CFR
141.725(
a)(
4)(
iii)).
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
2­
10
2.4
Developing
the
Watershed
Control
Program
Plan
The
following
subsections
discuss
the
factors
systems
should
consider
in
determining
the
impact
Cryptosporidium
has
on
their
water
quality,
along
with
descriptions
of
best
management
practices
systems
can
use
to
protect
their
source
water
from
Cryptosporidium.

2.4.1
Vulnerability
Analysis
2.4.1.1
What
Should
Be
Included
in
a
Vulnerability
Analysis?

The
vulnerability
analysis
must
address
the
vulnerability
of
each
source
to
Cryptosporidium
in
the
watershed
upstream
of
the
drinking
water
intake.
It
must
include
the
following
(
40
CFR
141.725(
a)(
3)(
i)):


A
characterization
of
the
watershed
hydrology

Identification
of
an
area
of
influence
(
the
area
to
be
considered
in
future
watershed
surveys)
outside
of
which
there
is
no
significant
probability
of
Cryptosporidium
or
fecal
contamination
affecting
the
drinking
water
intake

Identification
of
potential
and
actual
sources
of
Cryptosporidium
contamination

Determination
of
the
relative
impact
of
the
sources
of
Cryptosporidium
contamination
on
the
system's
source
water
quality

An
estimate
of
the
seasonal
variability
of
such
contamination
Systems
may
be
able
to
use
the
results
of
the
source
water
assessments
conducted
under
the
Safe
Drinking
Water
Act
Amendments
of
1996
in
your
vulnerability
analysis.
Most
States
will
have
completed
source
water
assessments
of
surface
water
systems
by
the
end
of
2003.
These
assessments
establish
a
foundation
for
the
vulnerability
analysis:
they
delineate
the
watershed,
providing
a
starting
point
for
defining
the
area
of
influence,
and
they
inventory
and
rank
the
susceptibility
of
the
water
supply
to
actual
and
potential
contamination
sources.
Some
States
involved
PWSs
in
conducting
source
inventories
and
susceptibility
analyses,
so
some
PWSs
may
already
have
this
information
on
hand.
The
assessments
covered
all
contaminants
in
a
watershed,
including
Cryptosporidium
(
U.
S.
EPA
1997).
In
some
cases,
if
sufficiently
detailed,
the
source
water
assessments
may
fully
satisfy
the
analytical
needs
of
the
watershed
control
plan's
vulnerability
analysis.

Other
source
and
watershed
information
may
be
available
from
sanitary
surveys
conducted
for
the
IESWTR
and
the
Long
Term
1
Enhanced
Surface
Water
Treatment
Rule
(
these
rules
require
sanitary
surveys
at
least
every
three
years
for
community
water
systems
and
at
least
every
five
years
for
noncommunity
water
systems).
Guidance
is
available
at
http://
www.
epa.
gov/
safewater/
mdbp/
pdf/
sansurv/
sansurv.
pdf.
The
California­
Nevada
section
of
the
American
Water
Works
Association
and
the
California
Department
of
Health
Services
Chapter
2
­
Watershed
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LT2ESWTR
Toolbox
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2003
2­
11
Division
of
Drinking
Water
and
Environmental
Management
also
have
developed
guidance
specifically
for
watershed
sanitary
surveys.

2.4.1.2
How
Should
I
Identify
the
Area
of
Influence?

The
area
of
influence
for
which
the
vulnerability
analysis
is
performed
should
be
determined
by
several
factors,
including
hydrology,
location
of
Cryptosporidium
sources,
fate
and
transport,
and
pathogen
loading
.
If
watershed
monitoring
data
are
not
available,
it
may
be
necessary
to
conduct
some
monitoring
to
determine
the
most
problematic
areas
of
the
watershed.

In
a
small
watershed,
the
geography
and
hydrology
may
not
be
important
in
determining
the
most
sensitive
areas,
since
the
distance
to
the
water
source
or
streams
feeding
into
the
source
is
small.
In
such
cases,
all
potential
sources
of
Cryptosporidium
contamination
should
be
evaluated
based
on
the
characteristics
of
the
source
and
the
likelihood
of
Cryptosporidium
release
to
a
water
body.

Delineation
As
part
of
the
source
water
assessments,
States
delineated
the
watershed
surrounding
each
PWS's
source.
These
delineations
may
be
used
as
a
starting
point
for
determining
the
area
of
influence.
To
delineate
watersheds,
some
States
started
with
watersheds
as
catalogued
by
the
U.
S.
Geological
Survey
(
USGS)
(
Horsley
and
Witten
2001).
The
USGS
has
assigned
each
watershed
and
its
subwatersheds
in
the
United
States
a
hydrologic
unit
code
(
HUC).
Because
the
HUC
subwatersheds
can
be
quite
large,
and
a
PWS's
source
may
come
from
only
a
section
of
the
watershed,
or
portion
of
a
hydrologic
unit,
sometimes
only
the
part
of
the
watershed
upstream
of
the
PWS's
intake
was
mapped.
Sometimes
watersheds
were
further
segmented
into
"
critical
areas"
within
which
more
detailed
assessments
were
performed.

Some
States
delineated
critical
areas
based
on
setbacks
from
the
edge
of
the
source
water
and
all
tributaries
feeding
into
the
source
water.
Others
defined
critical
areas
based
on
a
fixed
distance
or
time­
of­
travel
from
the
intake
(
upstream
of
the
intake
or
in
all
directions
from
the
intake)
(
Horsley
and
Witten
2001).

Systems
that
need
to
delineate
their
watersheds
or
subwatersheds
for
the
first
time
and
do
not
have
geographical
information
system
(
GIS)
available
can
do
so
easily
with
topographic
maps.
The
first
step
is
to
find
the
source
(
including
tributaries)
and
the
water
treatment
plant
intake
on
the
map.
Each
of
the
contour
lines
(
which
is
actually
not
a
line
but
a
closed
shape)
around
the
source
connects
points
of
equal
elevation.
Upstream,
the
elevation
indicated
by
each
contour
line
increases
with
distance
from
the
source.
All
precipitation
falling
within
a
zone
of
increasing
elevation
around
the
source
will
flow
towards
the
source.
Where
the
contour
elevations
stop
increasing
and
begin
decreasing
is
the
break
point.
On
the
other
side
of
the
break
point,
water
is
flowing
into
a
different
watershed.
The
area
delineated
by
connecting
the
break
points
is
the
watershed
(
AWWA
1999).
See
http://
www.
terrene.
org/
f16.
pdf
for
an
illustrated
fact
sheet
on
Chapter
2
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Control
Program
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2­
12
Delineation
Based
on
Travel
Time
In
its
watershed
control
program,
the
New
York
City
Department
of
Environmental
Protection
delineated
an
area
around
its
reservoirs
that
has
a
60­
day
residence
time
95
percent
of
the
time
(
Klett
1996).
Within
this
zone,
the
department
limits
the
operation
and
construction
of
wastewater
treatment
plants.
The
residence
time
was
calculated
using
the
formula
T=
V/
Q,
where
T=
time,
V=
volume
of
the
reservoir,
and
Q=
flow
out
of
the
reservoir.
Determining
residence
time
experimentally
would
have
been
too
timeconsuming
and
expensive.

The
department
adjusted
the
actual
reservoir
volume
in
its
calculations
to
reflect
changes
over
time.
First,
it
accounted
for
de
facto
changes
in
volume
resulting
from
stratification
(
i.
e.,
during
the
summer
there
is
little
vertical
mixing,
so
the
volume
of
the
bottom
layer
of
the
reservoir
never
enters
into
the
T=
V/
Q
equation).
Where
the
entrance
to
an
aqueduct
transporting
water
from
a
reservoir
was
significantly
upgradient
of
the
reservoir
dam,
the
volume
of
the
water
downgradient
of
the
aqueduct
also
was
subtracted,
because
water
moving
through
the
reservoir
may
enter
the
aqueduct
without
ever
reaching
the
downgradient
area.
The
department
also
adjusted
for
changing
reservoir
volumes
caused
by
rising
and
falling
water
levels.

If
the
calculated
residence
time
of
a
reservoir
close
to
New
York
City
was
less
than
60
days,
the
residence
time
of
the
next
upstream
reservoir
was
added.
Once
a
60­
day
time
was
achieved,
the
watershed
around
each
of
the
reservoirs
(
or
parts
of
the
reservoirs)
was
delineated
based
on
surrounding
topography.
delineation.
If
the
intake
is
not
at
the
downstream
end
of
the
watershed,
it
is
only
necessary
to
delineate
the
area
upstream
of
the
intake.

Systems
with
GIS
can
follow
the
same
process
using
digital
elevation
model
(
DEM)
data
rather
than
contour
lines.

Within
the
watershed,
systems
may
wish
to
delineate
the
area
of
concern
based
on
fixed
distances
from
the
shore
of
the
source
or
based
on
time
of
travel
(
see
box).

PWSs
using
ground
water
under
the
direct
influence
of
surface
water
(
GWUDI)
as
a
source
can
delineate
an
area
of
influence
by
combining
a
delineation
of
the
watershed
influencing
the
ground
water
source
with
a
delineation
of
the
wellhead
protection
area.

Watershed
Hydrology
Once
the
watershed
has
been
delineated,
PWSs
should
examine
the
hydrology
of
their
watersheds
to
help
determine
the
area
of
influence.
The
vulnerability
analysis
submitted
to
the
State
must
contain
information
on
the
watershed's
hydrology.

Stream
discharge
can
affect
the
transport
of
sediment
and
Cryptosporidium
oocysts,
especially
during
and
after
storms.

When
more
rain
falls
than
can
be
absorbed
immediately
by
the
soil,
soil
cover,
or
impervious
surface,
water
will
pond
on
the
surface.
With
increasing
rainfall,
the
water
will
flow
to
a
lower
level
on
the
surface,
to
a
river,
lake,
or
reservoir,
as
shown
in
Exhibit
2.1.
As
water
travels,
it
may
pick
up
contaminants
on
the
soil
surface
(
e.
g.,
Cryptosporidium
oocysts
from
deposited
fecal
matter).
These
particles
are
then
suspended
in
the
runoff
and
can
be
transported
to
surface
water
supplies.
The
microorganisms
(
including
parasitic
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
2­
13
Well
Septic
System
Road
with
Catch
Basin
Aquifer
Ground
Water
/
Surface
Water
Interaction
Runoff
Recharge
Precipitation
Exhibit
2­
1.
Ground
Water/
Surface
Water
Interaction
protozoa)
associated
with
the
soil
can
be
transported
as
individual
organisms,
aggregates
of
organisms,
or
within
an
aggregate
of
soil
particles
and
organisms.

Ground
water
that
is
considered
to
be
under
the
direct
influence
of
surface
water
(
GWUDI)
is
usually
immediately
adjacent
to
surface
water
or
to
the
discharge
point
of
a
spring.
These
ground
water
supplies
are
considered
especially
vulnerable
to
contamination
by
parasitic
protozoa.
GWUDI
may
be
contaminated
by
direct
infiltration
of
oocysts
from
the
surface
as
a
result
of
rain,
but,
more
commonly,
ground
water
is
contaminated
as
a
result
of
the
action
of
pumping
wells
(
see
Exhibit
2­
1).
Given
sufficiently
high
pumping
rates,
wells
can
locally
reverse
the
direction
of
ground
water
flow.
In
such
cases,
surface
water
is
induced
to
flow
from
a
river,
lake,
or
reservoir
into
the
adjacent
ground
water,
where
it
may
be
extracted
by
one
or
more
pumping
wells.
If
the
surface
water
is
contaminated
with
oocysts,
the
adjacent
ground
water
may
also
become
contaminated.

Water
quality
flow
models
analyze
specific
hydrologic,
geographic,
and
water
quality
parameters
to
estimate
the
travel
time
needed
for
contaminants
to
reach
a
drinking
water
intake
and
the
amount
of
contamination
at
that
intake.
Surface
runoff
models
may
also
be
used
to
assess
the
potential
impact
of
individual
Cryptosporidium
sources,
and
to
identify
watershed
areas
with
the
greatest
potential
impact
on
source
water
quality.
Models
should
always
be
validated
for
the
settings
in
which
they
are
used.
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
2­
14
PWSs
should
also
consider
topography
and
soil
type,
which
can
affect
hydrology.
Areas
with
steep
slopes
may
experience
a
higher
percentage
of
overland
flow
or
runoff
(
as
opposed
to
infiltration
and
subsurface
flow)
and
have
faster
overland
flow
rates
during
rainfall
than
flat
areas.
Cryptosporidium
may
be
more
likely
to
be
transported
to
water
bodies
in
such
areas,
although
if
the
topography
is
very
steep,
livestock
that
carry
Cryptosporidium
may
not
be
present.
Impermeable
or
compacted
soil,
impervious
surfaces,
unvegetated
areas,
and
a
high
water
table
can
also
affect
overland
flow.
Riparian
zones
can
be
considered
sensitive
areas
simply
due
to
their
proximity
to
streams
that
feed
into
source
waters.
They
are
also
subject
to
erosion.
PWSs
should
also
factor
soil
types
into
their
decisions;
areas
with
high
clay
content
may
be
more
impermeable
or
more
subject
to
erosion
and
can
contribute
to
high
turbidity.

2.4.1.3
What
and
Where
Are
the
Potential
or
Existing
Sources
of
Cryptosporidium?

All
Cryptosporidium
sources
must
be
reported
in
the
vulnerability
analysis
(
40
CFR
141.725(
a)(
3)(
i)).
Systems
may
be
able
to
use
source
inventory
data
collected
as
part
of
the
source
water
assessment
program.
Most
States
are
asking
systems
to
assist
with
identifying
significant
potential
contaminant
sources
(
Horsley
and
Witten
2001),
either
through
field
verification
or
through
review
of
inventory
databases
or
other
information.
Therefore,
some
PWSs
should
already
have
this
information
available.
States
will
also
be
assessing
the
risk
of
each
source
or
category
of
sources,
primarily
through
numerical
ranking
systems
and
matrices;
systems
will
have
this
information
at
their
disposal
as
well.
It
is
possible
that
the
inventory
and
ranking
of
potential
sources
may
not
be
detailed
enough
for
a
Cryptosporidium
watershed
control
program,
but
they
should
provide
a
good
starting
point.

After
noting
sensitive
areas
based
on
topography
and
geology,
systems
should
determine
whether
these
areas
coincide
with
land
use
that
could
contribute
to
microbiological
contamination.
Reviewing
land
use
and
zoning
maps
helps
target
areas
for
further
investigation
or
for
prediction
of
future
sources
and
loading.
PWSs
should
then
search
local
data
sources,
such
as
health
department
data
on
septic
systems,
and
review
recent
sanitary
survey
results.
Furthermore,
they
should
obtain
data
on
point
sources
such
as
wastewater
treatment
plants
that
require
EPA
or
State
permits,
e.
g.,
National
Pollutant
Discharge
Elimination
System
(
NPDES).
NPDES
information
(
also
called
water
discharge
permit
or
PCS
data)
is
available
on
EPA's
Envirofacts
website
at
http://
www.
epa.
gov/
enviro/
index_
java.
html.
After
identifying
potential
sources
of
contaminants,
systems
should
field
verify
the
locations
of
these
point
and
nonpoint
sources.

The
paragraphs
below
summarize
existing
research
on
Cryptosporidium
sources
and
associated
land
use
in
watersheds.
Because
most
studies
of
Cryptosporidium
occurrence
involve
sampling
at
water
system
intakes,
little
information
is
available
about
occurrence
of
Cryptosporidium
within
watersheds
and
transport
of
oocysts
to
surface
water
supplies.
The
studies
described
are
site­
specific;
it
is
important
to
investigate
these
relationships
in
one's
own
watershed
as
well.
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
2­
15
Land
Use
The
character
(
topography,
plant
cover)
and
land
uses
(
urban,
farming)
within
a
watershed
also
influence
the
occurrence
or
concentration
of
Cryptosporidium
in
surface
water
(
Hansen
and
Ongerth
1991).
Oocyst
concentrations
can
be
as
much
as
10
times
higher
in
urban
and
agricultural
watersheds
(
Hansen
and
Ongerth
1991,
Stern
1996)
than
in
undeveloped
ones.
However,
such
differences
may
be
site­
specific
 
in
streams
in
an
agricultural
watershed
in
southern
Ontario,
no
connection
was
found
between
Cryptosporidium
concentration
and
sources
or
land
use
such
as
wastewater
treatment
plants,
combined
sewer
overflows,
livestock,
crops,
houses,
wildlife,
and
campgrounds
(
Fleming
et
al.
1999).

Sources
Many
land
uses
in
a
watershed
have
the
potential
to
introduce
Cryptosporidium
into
water
supplies.
These
include
point
sources
 
combined
sewer
overflows,
wastewater
treatment
plants,
and
concentrated
animal
feeding
operations
 
and
nonpoint
sources,
including
livestock,
wildlife,
pets,
storm
water
runoff,
and
septic
systems.
Seasonal
variations
in
precipitation
may
affect
Cryptosporidium
concentrations
as
well.
Point
and
nonpoint
sources
of
Cryptosporidium
are
described
below.

Point
Sources
Point
sources
such
as
combined
sewer
overflow
(
CSO)
outfalls,
which
are
common
in
older
municipalities,
can
be
a
significant
source
of
oocysts,
depending
on
the
weather
and
the
endemic
rate
of
cryptosporidiosis.
CSOs
contain
raw
sewage
diluted
by
storm
water.
In
one
study,
Cryptosporidium
concentrations
at
CSO
outfalls
on
the
Allegheny
River
in
Pittsburgh
during
storms
ranged
from
0
to
3,000
oocysts/
100
L,
with
a
geometric
mean
of
2,013
oocysts/
100
L
(
States
et
al.
1997).

Wastewater
treatment
plants
may
also
contribute
to
oocyst
loads,
depending
on
the
amount
of
treatment
provided.
Primary
treatment
can
remove
as
little
as
27
percent
of
oocysts
from
effluent
(
Payment
et
al.
2001);
most
plants
in
the
United
States
provide
secondary
treatment,
so
removal
should
be
better.
In
the
Netherlands,
it
is
estimated
that
85
percent
of
Cryptosporidium
oocysts
occurring
in
surface
water
are
discharged
in
wastewater
treatment
plant
effluent
(
Medema
and
Schijven
2001).
In
one
study
in
Pittsburgh,
oocysts
were
detected
in
33
percent
of
samples
with
a
geometric
mean
concentration
of
924
oocysts/
100
L
over
24
months
of
sampling
(
States
et
al.
1997).
In
another
study
near
Philadelphia,
concentrations
ranged
from
33
to
2,490
oocysts
per
100
L
(
67
percent
of
samples
were
positive);
downstream
from
the
plant,
concentrations
ranged
from
325
to
825
oocysts
per
liter
(
Crockett
and
Haas
1997).

Concentrated
animal
feeding
operations
(
CAFOs)
can
be
a
significant
source
of
animal
waste,
which
can
contaminate
source
water
in
two
ways.
If
not
properly
managed,
waste
can
leak
or
overflow
from
waste
storage
lagoons,
feedlots,
or
other
facilities.
In
addition,
waste
applied
as
Chapter
2
­
Watershed
Control
Program
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Manual
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Draft
June
2003
2­
16
fertilizer
to
fields
can
run
off
into
drinking
water
sources
or
source
tributaries,
especially
if
overapplied.

Nonpoint
Sources
Agriculture
can
also
be
a
nonpoint
source
of
Cryptosporidium.
On
a
stream
running
through
a
small
dairy
farm
before
feeding
into
the
Allegheny
River,
Cryptosporidium
was
detected
in
82
percent
of
samples
(
States
et
al.
1997),
with
a
geometric
mean
concentration
of
42
oocysts/
100
L.
Twice
during
the
24­
month
study,
concentrations
of
more
than
1,000
oocysts/
100
L
were
observed.
In
an
agricultural
area
in
Canada,
drain
tiles
contained
average
concentrations
of
771
oocysts/
100
L.
Concentrations
were
high
even
in
tiles
on
farms
without
barns
(
these
farms
were
assumed
not
to
have
livestock
present).
Oocysts
were
also
present
in
some
samples
in
liquid
swine
manure
storage
lagoons
(
Fleming
et
al.
1999).

Cattle
are
thought
to
be
significant
sources
of
oocysts.
Cryptosporidium
infection
rates
in
cattle
depend
on
animal
age.
Calves,
particularly
those
less
than
one
or
two
months
old,
have
the
highest
rates
(
infection
rates
in
different
studies
range
from
2
to
39
percent
of
calves)
(
Wade
et
al.
2000,
Sischo
et
al.
2000,
Huetink
et
al.
2001).

Cryptosporidium
may
directly
enter
surface
water
via
waterfowl.
Oocysts
have
been
found
in
Canada
goose
feces
collected
in
the
environment
(
Graczyk
et
al.
1998).
Canada
geese,
some
of
which
no
longer
migrate,
could
cause
considerable
contamination
of
surface
water
sources
and
uncovered
finished
water
reservoirs.

Other
wildlife
may
also
be
a
source
of
Cryptosporidium,
though
the
impact
on
source
water
may
not
be
as
direct.
Deer,
muskrat,
and
other
small
mammals
were
shown
to
carry
Cryptosporidium
in
upstate
New
York
(
Perz
and
Le
Blancq
2001).
In
one
study
of
California
ground
squirrels,
16
percent
of
squirrels
sampled
were
found
to
shed
an
average
of
50,000
oocysts
per
gram
of
feces
(
Atwill
et
al.
2001).
The
infection
rate
in
each
species
and
the
species
present
in
each
watershed
will
vary,
so
the
contribution
from
wildlife
will
also
differ
from
watershed
to
watershed.

Although
little
research
has
been
performed
on
the
overall
prevalence
of
Cryptosporidium
in
pets,
Cryptosporidium
has
been
detected
in
dogs
and
cats,
although
pets
usually
carry
strains
that
are
rarely
detected
in
humans.
Several
studies
have
shown
dogs
to
be
significant
carriers
of
Giardia,
fecal
coliform,
and
other
bacteria
(
Schueler
1999),
and
these
microbes
have
been
found
in
storm
water,
suggesting
that
Cryptosporidium
may
also
be
present
in
urban
watersheds
and
stormwater
runoff.

Low
levels
of
Cryptosporidium
may
also
enter
surface
water
through
septic
systems
and
subsequent
subsurface
transport
(
Lipp
et
al.
2001).
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
2­
17
Cryptosporidium
sources
can
be
identified
through
polymerase
chain
reaction
(
PCR)
analysis
of
Cryptosporidium
DNA.
PCR
can
be
used
to
determine
the
species
or
genotype
of
Cryptosporidium;
many
genotypes
or
species
are
typically,
although
not
exclusively,
found
in
specific
hosts,
such
as
cattle,
dogs,
and
humans.
In
mixed­
use
watersheds,
this
information
can
help
determine
whether
Cryptosporidium
in
the
source
water
could
have
come
from
agricultural
runoff,
combined
sewer
overflows,
or
stormwater
runoff.

Influence
of
Precipitation
Systems
should
determine
the
extent
to
which
Cryptosporidium
occurrence
in
their
watershed
coincides
with
extreme
rainfall
 
68
percent
of
waterborne
disease
outbreaks
between
1948
and
1994
were
shown
to
be
associated
with
heavy
precipitation
(
Curriero
et
al.
2001).
Cryptosporidium
occurrence
may
also
be
related
to
seasonal
variations
in
infection
among
livestock,
but
any
correlation
is
site­
specific
and
depends
on
the
source.
In
a
study
in
six
watersheds,
Sobrinho
et
al.
(
2001)
found
no
substantial
difference
between
Cryptosporidium
detection
rates
during
"
event"
(
rainfall,
high
turbidity,
melting
snow
and
spring
runoff)
and
"
nonevent
sampling
when
all
data
were
taken
together.
However,
for
three
of
the
watersheds,
when
examined
individually,
detection
within
each
watershed
was
significantly
higher
during
event
sampling.

Both
Cryptosporidium
detection
and
concentrations
at
six
watersheds
were
highest
between
the
months
of
October
and
April,
with
March
experiencing
a
detection
rate
of
more
than
30
percent
and
oocyst
concentration
of
about
0.038
oocysts/
L
(
Sobrinho
et
al.
2001).

Other
studies
have
noted
a
connection
between
rainfall
and
"
extreme
runoff"
events
in
tributaries
to
drinking
water
sources
(
Kistemann
et
al.
2002).
One
study
noted
a
decrease
in
farm
stream
concentrations
of
Cryptosporidium
with
an
increase
in
5­
day
cumulative
precipitation
(
probably
because
continued
rainfall
washed
most
of
the
Cryptosporidium
downstream)
(
Sischo
et
al.
2000).

2.4.1.4
How
Do
Fate
and
Transport
Affect
the
Way
Cryptosporidium
Impacts
My
Water
Supply?

Transport
of
oocysts
in
surface
water
and
ground
water
and
survival
of
oocysts
all
affect
the
potential
impact
of
Cryptosporidium
on
water
supplies.
The
behavior
of
oocysts
in
each
medium
is
described
below.

Transport
in
Surface
Water
The
buoyancy
of
oocysts
in
water
depends
on
their
attachment
to
other
particles.
Oocysts
that
are
not
bound
to
particles
have
a
tendency
to
float,
even
after
being
centrifuged
(
Swabby­
Cahill
et
al.
1996).
Cryptosporidium
oocysts
have
a
very
low
density
(
about
1.05
g/
cm3)
and
a
very
low
settling
rate
(
2
mm
per
hour
or
less),
which
suggests
that
sedimentation
without
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
2­
18
coagulation
may
not
be
an
effective
means
of
oocyst
removal
(
Gregory
1994).
Oocysts
attached
to
wastewater
effluent
particles
may
settle
more
quickly
than
those
that
are
freely
suspended
and
sedimentation
velocity
increases
with
particle
size
(
Medema
et
al.
1998).
In
source
waters,
many
oocysts
are
likely
to
be
adsorbed
to
organic
or
other
suspended
material
and
would
probably
settle
more
quickly
than
free­
floating
oocysts
(
Medema
et
al.
1998).

Cryptosporidium
is
thought
to
be
easily
transported
over
land.
Because
oocysts
are
approximately
the
size
of
clay/
silt
particles,
the
amount
of
kinetic
energy
needed
to
entrain
and
suspend
oocysts
in
overland
flow
may
be
quite
small
(
Walker
et
al.
1998).

Transport
in
Ground
Water
Surface
water
sediments
and
the
aquifer
matrix
material
may
play
significant
roles
in
minimizing
oocyst
transport
to
water
supply
wells;
however,
it
is
difficult
to
isolate
the
effect
of
these
materials
on
transport.
For
example,
if
oocysts
are
not
detected
in
a
sample,
it
could
be
because
they
are
not
present
in
the
aquifer
or
that
they
are
present
but
were
not
recovered
in
the
laboratory.
Or
it
could
be
that
fractures
or
dissolution
conduits
in
the
aquifer
allow
ground
water
and
oocysts
to
effectively
bypass
the
protective
action
of
most
of
the
aquifer
matrix.

It
is
known
that
Cryptosporidium
can
be
transported
through
soil
and
ground
water
(
Mawdsley
et
al.
1996;
Hurst
1997).
For
instance,
in
one
study
examining
riverbank
filtration,
oocysts
were
recovered
at
a
well
200
feet
from
the
Ohio
River
(
Arora
et
al.
2000).
Movement
of
C.
parvum
through
soil
and
ground
water
is
affected
by
sedimentation
and
filtration
of
the
surrounding
soil
and
aquifer
matrix
(
Brush
et
al.
1999;
Harter
et
al.
2000).
Adsorption
of
oocysts
to
matrix
particles
also
affects
filtration.
Adsorption
depends
on
the
electrical
charge
of
the
organism
and
of
the
surrounding
matrix.
A
charge
on
the
oocyst
can
change
the
effective
diameter
of
the
oocyst;
however,
the
charge
is
difficult
to
ascertain
because
it
can
be
altered
by
the
purification
method
used
to
recover
oocysts
in
the
laboratory
(
Brush
et
al.
1998).

Factors
other
than
adsorption
and
micropore
size
may
influence
the
oocyst
movement.
C.
parvum
transport
in
one
study
was
greater
in
a
silty
loam
and
a
clay
loam
soil
than
in
a
loamy
sand
soil
(
Mawdsley
et
al.
1996);
this
contradicts
other
evidence
suggesting
that
clay
soils
exhibit
greater
adsorption
and
smaller
micropores
than
sandy
soils.
The
authors
used
intact
soil
cores
(
rather
than
columns
created
in
the
laboratory)
to
maintain
the
natural
soil
structure
and
macropores,
and
they
concluded
that
the
rapid
flow
of
water
through
macropores
largely
bypasses
the
filtering
and
adsorptive
effects
of
the
soil
and
increases
the
risk
of
Cryptosporidium
transport
to
ground
water
(
Mawdsley
et
al.
1996).

Survival
in
the
Environment
Several
factors
influence
oocyst
survival.
This
section
presents
the
findings
from
several
studies
describing
oocyst
inactivation
due
to
temperature
and
dessication.
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
2­
19
Before
oocysts
enter
a
water
source,
they
may
be
vulnerable
to
dessication.
Robertson
et
al.
(
1992)
reported
that
air
drying
an
oocyst
suspension
at
room
temperature
for
4
hours
eliminated
viability.
Oocysts
in
fecal
material,
however,
are
protected
from
desiccation,
so
their
viability
in
the
environment
is
prolonged
(
Rose
1997).
In
addition,
Cryptosporidium
in
liquid
swine
manure
has
been
shown
to
remain
viable
despite
the
high
ammonia
content
of
the
manure
(
Fleming
et
al.
1999).
However,
Olson
et
al.
(
1999)
found
that
oocyst
survival
appears
to
be
better
in
soil
than
in
feces.

Once
initial
contamination
has
occurred,
water
can
remain
a
source
of
viable
oocysts
for
days
(
Heisz
1997;
Lisle
and
Rose
1995).
Lisle
and
Rose
reported
a
duration
of
176
days
to
produce
die­
off
rates
of
96
percent
in
tap
water
and
94
percent
in
river
water
under
laboratory
conditions.
After
2
days,
only
37
percent
of
the
oocysts
in
tap
water
were
nonviable,
suggesting
that
oocysts
that
reach
the
distribution
system
might
be
viable.

Olson
et
al.
(
1999)
compared
oocyst
survival
at
temperatures
and
in
media
likely
to
occur
in
the
natural
environment.
They
examined
survival
in
­
4

,
4

,
and
25

C.
Unlike
Giardia,
which
died
off
quickly
at
low
temperatures,
Cryptosporidium
oocyst
survival
was
best
at
­
4

C,
with
close
to
50
percent
of
oocysts
remaining
viable
for
12
weeks.
Survival
was
lowest
at
25

C,
but
oocysts
were
still
viable
at
six
weeks.
Survival
rates
were
best
in
water
and
worst
in
feces.

Loading
Once
you
have
gathered
information
about
Cryptosporidium
sources
and
the
likelihood
of
the
oocysts
reaching
your
source
water
(
based
on
watershed
characteristics
and
fate
and
transport),
you
should
determine
the
amount
and
proportion
of
oocysts
that
each
source
is
expected
to
contribute
to
the
overall
Cryptosporidium
load.
Loading
can
be
calculated
fairly
easily
for
constant
point
sources
such
as
wastewater
treatment
plants
but
is
more
difficult
for
farms
and
urban
runoff;
monitoring
and
water
quality
modeling
may
be
necessary
(
see
section
below
on
monitoring).

2.4.1.5
What
Role
Should
Monitoring
Play
in
a
Vulnerability
Analysis?

The
vulnerability
analysis
is
required
to
address
sources
of
Cryptosporidium,
seasonal
variability,
and
the
relative
impact
of
the
sources
of
Cryptosporidium
on
a
system's
source
water
quality
(
40
CFR
141.725(
a)(
3)(
i)).
While
you
may
already
have
some
knowledge
of
potential
Cryptosporidium
sources
through
land
use
information
or
discharge
permit
data,
monitoring
can
help
you
determine
the
extent
to
which
these
sources
are
impacting
your
source
and
can
help
you
target
portions
of
your
watershed
for
extra
protection
or
BMP
implementation.
Although
not
required
as
part
of
the
vulnerability
analysis,
monitoring
throughout
your
watershed
for
Cryptosporidium
(
or
indicators
of
fecal
contamination)
is
the
best
way
to
measure
the
success
of
a
watershed
control
program.
Monitoring
data
collected
during
the
vulnerability
analysis
provide
a
baseline
against
which
you
can
compare
data
gathered
during
implementation
of
the
watershed
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
2­
20
Monitoring
to
Locate
Cryptosporidium
Sources
To
determine
the
source
of
Cryptosporidium
contamination
in
the
Schuylkill
River,
the
Philadelphia
Water
Department
decided
to
focus
on
a
creek
feeding
into
the
Schuylkill
just
before
the
Queen
Lane
plant
(
Crockett
and
Haas
1997).
This
creek
has
several
wastewater
treatment
plants
in
its
upper
reach
and
farms
and
parks
along
its
lower
reach.
In
the
first
phase,
the
water
department
tested
the
Queen
Lane
intake
during
dry
flow.
It
then
sampled
a
site
along
the
creek
downstream
of
the
wastewater
treatment
plants
and
one
downstream
of
the
farms
during
various
weather
conditions.
In
the
third
tier
of
sampling,
the
department
sampled
wastewater
effluent
and
additional
sites
up­
and
downstream
of
some
of
the
wastewater
treatment
plants
during
different
weather
events.
Lastly,
the
department
planned
to
focus
on
the
prevalence
of
Cryptosporidium
and
Giardia
in
livestock
and
wildlife
along
the
creek.
Results
are
discussed
in
section
2.4.1.3.
program.
Some
PWSs,
as
well
as
the
USGS
and
local
universities,
may
already
have
some
water
quality
or
streamflow
data
available.

Watershed
monitoring
can
help
narrow
down
the
locations
of
some
sources
and
determine
the
load
contributed
by
each
source.
The
Philadelphia
Water
Department,
for
example,
planned
a
four­
tier
study
to
determine
why
there
was
such
a
large
difference
in
protozoan
levels
at
two
plants
using
the
same
source
(
the
Schuylkill
River)
but
located
2.5
miles
apart
(
Crockett
and
Haas
1997)
(
see
sidebar).

Because
Cryptosporidium
occur
in
low
concentrations
and
are
difficult
to
detect,
it
may
be
helpful
to
monitor
other
parameters
in
addition
to
or
instead
of
Cryptosporidium.
While
E.
coli
concentrations
often
do
not
correlate
with
Cryptosporidium
levels,
they
are
good
indicators
of
fecal
contamination.
Fecal
coliform
bacteria
have
traditionally
used
as
water
quality
indicators,
but
E.
coli
is
thought
to
be
more
closely
linked
to
fecal
contamination.
Turbidity
does
not
always
indicate
fecal
contamination;
often,
increased
turbidity
is
simply
a
product
of
high
sediment
levels.
However,
turbidity
may
indicate
the
presence
of
a
water
quality
problem,
where
additional
research
is
necessary
to
determine
its
cause.

Monitoring
should
be
conducted
regularly.
Because
nonpoint
sources
of
microbiological
contamination
discharge
primarily
during
wet
weather
flows,
monitoring
during
or
soon
after
these
events
is
also
important.
When
combined
with
stream
discharge
data,
rates
of
storm­
related
Cryptosporidium
transport
and
loading
can
be
calculated.
The
monitoring
frequency
should
be
such
that
seasonal
variability
in
Cryptosporidium
levels
is
observable.

There
are
two
types
of
watershed
monitoring
for
stream
networks.
First,
basinwide
monitoring
involves
monitoring
just
upstream
of
the
confluence
of
two
streams
(
AWWARF
1991).
Conducted
at
stream
junctions
throughout
the
watershed,
basinwide
monitoring
helps
give
a
general
picture
of
the
water
quality
and
helps
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
2­
21
isolate
the
stream
reaches
contributing
to
contamination.
Second,
site­
specific
monitoring
involves
monitoring
just
upstream
and
downstream
of
a
suspected
or
known
point
or
nonpoint
source,
as
the
Philadelphia
Water
Department
did
(
Crockett
and
Haas
1997).
Such
monitoring
is
appropriate
where
impacted
stream
reaches
have
already
been
identified.
The
results
of
any
monitoring
should
enable
the
system
to
compare
the
relative
contribution
of
various
sources
to
the
overall
Cryptosporidium
occurrence
in
the
watershed
and
their
effect
on
water
quality.

Monitoring
in
a
reservoir
or
lake,
if
applicable,
can
help
systems
determine
the
fate
of
Cryptosporidium
once
it
flows
from
a
stream
into
the
lake,
or
once
it
enters
the
lake
directly
from
land
immediately
adjacent
to
the
lake.
Sampling
patterns
should
depend
on
the
shape
and
depth
of
the
lake.
A
round
lake
should
be
sampled
at
several
locations
and
depths
near
the
center
of
the
lake;
a
long
lake
should
be
sampled
in
a
transect
along
its
long
axis
(
AWWARF
1991).
More
specific
monitoring
may
be
needed
to
answer
more
detailed
questions
on
fate
and
transport.
For
instance,
does
Cryptosporidium
concentration
decrease
due
to
sedimentation
or
dilution?
How
long
does
it
take
for
Cryptosporidium
to
flow
from
one
end
of
the
reservoir
to
the
intake?

PWSs
may
find
it
helpful
to
use
a
geographic
information
system
(
GIS)
to
analyze
their
water
quality
and
contaminant
source
data.
For
systems
that
have
ArcView
software,
BASINS
3.0,
a
software
and
GIS
package
developed
by
EPA,
can
assist
systems
with
integrating
local
data
and
nationally
available
pre­
formatted
spatial
data
(
e.
g.,
watershed
hydrologic
unit
codes
(
HUCs),
digital
elevation
model
(
DEM)
data,
roads,
NPDES
permit
data,
and
Clean
Water
Needs
Survey
data
on
wastewater
treatment
plants).
BASINS
also
includes
a
model
for
determining
nonpoint
source
loading
and
other
models
for
loading
and
transport,
as
well
as
tools
for
assessing
contamination
from
various
sources.

2.4.2
Analysis
of
Control
Measures
The
analysis
of
control
measures
submitted
with
the
watershed
control
plan
must
address
the
relative
effectiveness
of
each
measure
at
reducing
Cryptosporidium
loading
to
the
source
water,
along
with
the
sustainability
of
each
measure
(
40
CFR
141.725(
a)(
3)(
ii)).

Control
measures
may
include
1)
the
elimination,
reduction,
or
treatment
of
wastewater
or
storm
water
discharges,
2)
treatment
of
Cryptosporidium
contamination
at
the
sites
of
the
waste
generation
or
storage,
3)
prevention
of
Cryptosporidium
migration
from
sources,
or
4)
any
other
measures
that
are
effective,
sustainable,
and
likely
to
reduce
Cryptosporidium
contamination
of
source
water.
If
you
do
not
own
or
otherwise
have
authority
over
the
Cryptosporidium
sources
in
your
watershed,
you
may
need
to
develop
and
maintain
partnerships
with
landowners
within
the
watersheds.
These
could
include
other
municipal
governments,
farmers,
wastewater
treatment
plant
operators,
regional
planning
agencies,
and
others.
Examples
of
these
partnerships
and
possible
control
measures
for
different
sources
are
described
in
the
following
sections;
further
detail
is
provided
in
Appendix
E.
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
2­
22
2.4.2.1
How
Should
I
Build
Partnerships
with
Other
Stakeholders?

Many
watershed
management
practices
cannot
be
implemented
by
water
systems
alone.
For
example,
agricultural
BMPs
must
be
implemented
by
farmers;
stormwater
BMPs
are
implemented
by
developers,
manufacturers,
and
government
agencies.
Parts
of
your
watershed
may
be
in
different
municipalities.
Therefore,
it
is
imperative
that
PWSs
work
with
these
and
other
stakeholders
to
solicit
their
input
and
earn
their
cooperation.

The
type
of
partnership
you
build
depends
on
each
type
of
stakeholder.
With
government
agencies
you
might
need
to
sign
memoranda
of
agreement
or
make
other
formalized
arrangements.
For
some
types
of
stakeholders
it
may
be
more
appropriate
or
efficient
to
reach
out
to
technical
assistance
providers
such
as
cooperative
extension
agents
or
association
representatives
and
provide
them
with
information
to
distribute.
Ultimately,
however,
you
must
reach
out
to
individual
stakeholders,
because
people
who
don't
know
about
the
watershed
control
program
will
not
be
as
likely
to
do
their
part.

Increasingly,
PWSs
are
incorporating
more
intensive
stakeholder
participation
into
their
planning
whenever
possible.
They
have
found
that
dialogue
with
stakeholders
is
more
likely
to
result
in
an
acceptable
solution
than
situations
in
which
systems
simply
inform
stakeholders
that
they
already
know
the
best
way
to
address
a
problem
(
AWWARF
2001).
The
book
Guidance
to
Utilities
on
Building
Alliances
with
Watershed
Stakeholders
(
AWWARF
2001)
explains
how
to
present
issues
to
stakeholders,
how
to
target
stakeholders,
and
how
to
structure
your
partnership
with
stakeholders.

2.4.2.2
What
Regulatory
and
Other
Management
Strategies
Are
Available
to
Me?

For
systems
in
watersheds
where
most
of
the
land
is
privately
owned,
land
use
regulations
may
be
the
best
way
to
control
pollution,
especially
in
heavily
developed
or
growing
areas.
Examples
of
possible
regulations
include
septic
system
requirements,
zoning
ordinances
specifying
minimum
lot
sizes
or
low­
impact
development,
limits
on
discharge
from
wastewater
treatment
plants
and
other
facilities,
pet
waste
cleanup
ordinances,
and
requirements
for
permits
for
certain
land
uses.
Your
ability
to
regulate
land
use
will
depend
on
the
authority
granted
to
your
municipality
by
the
State,
the
ownership
of
your
system
(
public
or
private),
and
the
support
of
your
local
government
and
the
public.
Regulatory
authority,
steps
for
designing
a
regulation
that
can
withstand
lawsuits,
and
types
of
land
use
regulations
are
described
in
the
paragraphs
below.
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
2­
23
Determining
Authority
to
Regulate
The
ability
of
a
municipality
to
pass
a
land
use
ordinance
or
other
law
to
help
reduce
contamination
may
depend
on
the
authority
the
State
grants
to
the
local
government
in
the
State
constitution
or
through
legislation,
although
States
normally
do
not
interfere
with
the
actual
land
use
and
zoning
rules
(
AWWARF
1991).
Privately
owned
water
systems
may
need
to
ask
the
cooperation
of
the
local
government
to
get
source
water
regulations
passed.
Publicly
owned
PWSs
face
less
of
a
hurdle,
although
winning
support
of
the
local
government
may
still
be
difficult.

If
the
area
of
influence
on
water
quality
extends
throughout
several
municipalities,
it
can
be
difficult
to
standardize
watershed
control
practices
throughout
the
watershed.
The
legal
framework
used
will
depend
on
who
has
jurisdiction
over
land
use
in
the
watershed
and
on
the
authority
of
the
water
system
(
AWWARF
1991).
For
example,
some
States
may
create
agencies
authorized
to
promulgate
and
enforce
watershed
protection
regulations,
or
interstate
agencies
may
be
created
to
regulate
watersheds
where
watersheds
cross
State
boundaries.
County
governments
in
some
States
may
have
some
zoning
authority
and
may
be
able
to
assist
with
enforcement
of
some
regulations
affecting
source
water
(
e.
g.,
septic
systems).

Where
PWSs
do
not
have
regulatory
or
enforcement
authority,
they
should
work
with
other
local
governments'
PWSs
and
agencies
in
their
watersheds
to
sign
memoranda
of
agreement
or
understanding,
in
which
each
entity
agrees
to
meet
certain
standards
or
implement
certain
practices.

Zoning
Early
zoning
laws
simply
prohibited
certain
land
uses
that
would
be
considered
nuisances
in
certain
areas.
Later,
zoning
ordinances
became
more
specific;
further
restrictions
were
imposed
on
the
permitted
uses,
such
as
limits
on
building
or
population
density,
percentage
of
impervious
surface
area,
building
height,
and
minimum
distance
of
buildings
from
property
boundaries.
Most
zoning
ordinances
have
grandfather
clauses
that
allow
nonconforming
uses
to
continue.
Ordinances
may
also
allow
the
zoning
authority
to
grant
variances
if
the
topography
or
size
of
a
lot
make
it
difficult
to
comply
with
a
zoning
requirement.

To
make
sure
a
zoning
law
can
withstand
a
legal
challenge,
it
is
important
to
make
sure
the
appropriate
procedures
are
followed
and
that
the
law
has
sufficient
scientific
basis
(
AWWA
1999).
First,
be
sure
you
have
the
authority
to
regulate.
Make
sure
the
rule
is
specific
enough.
Comply
with
all
administrative
procedure
requirements;
failure
to
do
so
is
the
most
common
reason
for
rules
being
revoked.
The
ordinance
should
conform
to
the
objectives
of
the
watershed
control
program
plan,
which
should
contain
enough
data
to
illustrate
how
the
ordinance
will
affect
water
quality.
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
2­
24
Ordinances
should
also
be
designed
to
withstand
a
takings
lawsuit
(
AWWA
1999).
The
fifth
amendment
to
the
U.
S.
Constitution
states
that
private
property
may
not
be
taken
for
public
use
without
just
compensation.
Any
physical
invasion
without
consent
is
always
considered
a
taking,
even
if
the
landowner
retains
ownership
of
the
land.
Installation
of
a
monitoring
well
or
stream
gauge
without
consent
is
an
example
of
a
taking.

To
prevent
takings
claims,
the
municipality
should
show
the
need
for
the
regulation
and
a
connection
between
the
ordinance
and
the
expected
result
(
AWWA
1999).
This
proof
should
be
based
on
a
scientific
analysis
beginning
with
an
accurate
delineation
of
the
watershed
or
wellhead
protection
area/
recharge
area.

Following
the
delineation,
determine
the
impact
the
regulation
will
have
by
mapping
current
and
projected
development
under
current
zoning
requirements.
Then
map
current
and
projected
development
for
the
proposed
ordinance
and
determine
the
potential
pollutant
load
under
each
scenario
(
AWWA
1999).
Local
groups
or
universities
may
be
able
to
provide
pollutant
data
and
assist
with
modeling.
This
"
buildout
analysis"
will
help
you
show
that
your
proposed
ordinance
advances
a
legitimate
government
interest
and
how
the
effect
of
the
ordinance
is
proportional
to
the
impact
of
land
use
in
your
watershed.

Types
of
Ordinances
Watershed
ordinances
usually
apply
within
an
"
overlay
district,"
which
may
be
the
area
of
influence
you
determined
for
your
watershed
control
plan.
All
existing
zoning
or
land
use
regulations
apply
within
that
area,
but
additional
requirements
apply
within
the
overlay
district.
Within
your
watershed,
particularly
within
the
area
of
influence,
there
are
many
different
kinds
of
regulatory
controls
you
may
wish
to
consider:


Large­
lot
or
low­
density
zoning.


Limits
on
certain
types
of
land
use
except
by
special
permit.


Impact
fees.


Submission
and
approval
of
a
watershed
protection
plan
or
impact
study
as
a
condition
for
development
of
a
subdivision
or
apartment
complex.


Performance
standards,
which
permit
development
but
limit
the
impact
of
the
development.

More
detail
on
each
of
these
types
of
ordinances
is
found
in
Appendix
E.
Examples
of
source
water
protection
ordinances
can
be
found
on
EPA's
website
at
http://
www.
epa.
gov/
owow/
nps/
ordinance/
osm7.
htm.

Land
Acquisition/
Conservation
Easements
Acquisition
of
watershed
land
by
the
utility
or
its
affiliated
jurisdiction
is
often
the
most
effective
approach
to
protecting
the
water
source.
EPA's
Drinking
Water
State
Revolving
Fund
Chapter
2
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Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
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June
2003
2­
25
allows
a
percentage
of
the
fund
to
be
set
aside
for
land
acquisition
associated
with
watershed
protection.

Land
trusts
and
conservancies
can
help
systems
purchase
land
to
protect
drinking
water
quality,
especially
when
government
agencies
are
unable
to
move
quickly
enough
to
buy
land
when
it
becomes
available.
Trusts
can
buy
and
hold
land
from
multiple
landowners
on
behalf
of
a
water
system
until
the
system
can
assemble
funding
to
purchase
it
from
the
trust.
The
Trust
for
Public
Land
(
http://
www.
tpl.
org)
can
provide
more
information.

Trusts
also
can
work
with
landowners
to
buy
or
have
landowners
donate
conservation
easements.
An
easement
is
a
legal
document
that
permanently
limits
the
development
of
a
piece
of
land,
even
after
the
land
is
sold
or
otherwise
changes
ownership.
See
http://
www.
landtrust.
org/
ProtectingLand/
EasementInfo.
htm
for
frequently
asked
questions
about
easements
and
for
an
example
of
a
model
easement
for
use
in
the
State
of
Michigan.
The
Land
Trust
Alliance
(
http://
www.
lta.
org),
a
trade
organization
for
land
trusts,
has
published
handbooks
on
designing
and
managing
conservation
easement
programs.

Other
government
agencies,
such
as
the
U.
S.
Forest
Service
or
State
natural
resource
departments,
may
be
able
to
buy
parcels
in
your
watershed
if
you
are
unable
to
afford
to
purchase
all
the
land
that
needs
to
be
protected.

2.4.2.3
How
Should
Point
Sources
Be
Addressed?

Changes
in
farming
practices
and
in
wastewater
treatment
technologies
in
the
past
decade
have
resulted
in
new
management
strategies
for
agricultural
and
urban
point
sources.
The
following
sections
briefly
describe
solutions
for
agricultural,
wastewater,
and
stormwater
point
sources;
detailed
descriptions
are
provided
in
Appendix
E.
As
part
of
your
application
for
watershed
control
program
approval,
you
must
submit
an
analysis
of
control
measures
that
can
mitigate
sources
of
Cryptosporidium
such
as
these
(
40
CFR
141.725(
a)(
3)(
ii)).
Loans
from
the
Clean
Water
State
Revolving
Fund
can
be
used
to
fund
projects
associated
with
wastewater
treatment
and
watershed
and
estuary
management.
See
www.
epa.
gov/
owm/
cwfinance/
cwsrf/
index.
htm
for
more
information.

°
Concentrated
Animal
Feeding
Operations
Animal
feeding
operations
(
AFOs)
are
facilities
where
animals
are
confined
for
45
days
or
more
a
year
and
where
no
vegetation
grows
in
the
area
used
for
confinement.
This
includes
farms
where
animals
graze
the
majority
of
the
year
but
are
confined
and
fed
during
the
winter
for
at
least
45
days.
Some
AFOs
are
also
considered
concentrated
animal
feeding
operations
(
CAFOs)
(
see
Appendix
E).
EPA
recently
issued
a
rule
that
changed
the
requirements
on
CAFOs
that
must
apply
for
National
(
or
State)
Pollutant
Discharge
Elimination
System
(
NPDES)
permits
(
U.
S.
EPA
2003).
The
new
CAFO
rule
requires
CAFOs
to
implement
nutrient
management
plans
that
affect
manure
handling,
storage,
and
land
application.
These
plans
will
include
best
management
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
Manual
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Draft
June
2003
2­
26
practices
(
BMPs)
primarily
designed
to
reduce
nitrate
and
phosphorus
contamination
but
which
will
at
the
same
time
reduce
pathogen
contamination.
Elements
of
this
plan
may
include
limiting
the
manure
land
application
rate,
instituting
buffer
zones
where
manure
is
applied,
ensuring
adequate
manure
and
wastewater
storage,
and
others.

°
Wastewater
Treatment
Plants
All
wastewater
treatment
plants
in
the
United
States
are
required
to
provide
secondary
treatment
(
U.
S.
EPA
2001e).
Most
plants
are
also
required
to
disinfect
their
effluent
before
discharging.
However,
conventional
chlorine
disinfection
in
wastewater
plants
is
ineffective
against
Cryptosporidium.
Some
wastewater
treatment
facilities
are
beginning
to
implement
treatment
similar
to
that
used
for
drinking
water
treatment
(
e.
g.,
advanced
treatment,
including
chlorine
disinfection,
filtration,
and
dechlorination).
PWSs
should
identify
all
wastewater
treatment
plants
in
their
watersheds
and
determine
what
their
permit
effluent
limits
are
and
whether
the
limits
are
being
met.

°
Combined
Sewer
Overflows
Combined
sewers
carry
both
sewage
and
storm
water
to
wastewater
treatment
plants.
During
storms,
the
volume
of
water
in
combined
sewers
may
become
too
great
for
wastewater
plants
to
treat.
As
a
result,
the
excess
sewage
and
storm
water
are
released
untreated
into
surface
water
through
CSOs.
CSOs
are
most
common
in
older
cities
in
the
northeastern
and
midwestern
United
States
and
can
be
a
significant
contributor
of
Cryptosporidium
to
urban
watersheds.

There
are
three
major
structural
solutions
to
the
problem
of
CSOs:


Separate
combined
sewers
into
sanitary
and
storm
sewers,
where
sanitary
sewers
flow
to
the
wastewater
treatment
plant
and
storm
sewers
release
to
surface
water.


Increase
the
capacity
of
the
wastewater
treatment
plant
so
that
it
is
able
to
treat
combined
sewage
from
most
storms.


Build
aboveground
covered
retention
basins
or
to
construct
underground
storage
facilities
for
combined
sewage
to
hold
the
sewage
until
the
storm
has
passed
and
can
be
treated
without
overloading
the
plant.

Although
CSOs
are
not
regulated
directly
under
their
own
program,
EPA
has
a
CSO
control
policy
(
U.
S.
EPA
1994)
which
encourages
minor
improvements
to
optimize
CSO
operation,
and
CSO
management
may
be
written
into
NPDES
or
State
Pollution
Discharge
Elimination
System
(
SPDES)
permits.
Minor
improvements
include
maximizing
in­
line
storage
within
the
sewer
system,
reducing
inflow,
and
treatment
of
CSO
outfalls.

°
Sanitary
Sewer
Overflows
Watersheds
with
separate
sanitary
and
storm
sewer
systems
may
still
have
water
quality
problems.
Sanitary
sewer
overflows
(
SSOs)
occur
when
untreated
and
mostly
undiluted
sewage
Chapter
2
­
Watershed
Control
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LT2ESWTR
Toolbox
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June
2003
2­
27
backs
up
into
basements,
streets,
and
surface
water.
SSOs
discharging
to
surface
water
are
prohibited
under
the
Clean
Water
Act.
Insufficient
maintenance
and
capacity
and
illegal
connections
are
some
of
the
primary
causes
of
SSOs.

SSOs
can
be
reduced
by
cleaning
and
maintaining
the
sewer
system;
reducing
inflow
and
infiltration
by
repairing
leaking
or
broken
service
lines;
increasing
sewer,
pumping,
and/
or
wastewater
treatment
plant
capacity;
and
constructing
storage
for
excess
wastewater
(
U.
S.
EPA
2001f).
EPA
is
proposing
a
rule
that
will
require
sewer
systems
to
implement
capacity
assurance,
management,
operation,
and
maintenance
programs
and
will
require
public
notification
of
overflow
events.
This
information
will
assist
PWSs
in
addressing
SSO
point
sources.

°
Municipal
Separate
Storm
Sewer
Systems
Municipal
separate
storm
sewer
systems
(
MS4s)
in
areas
with
populations
of
more
than
100,000
are
also
required
to
obtain
NPDES
permits.
Information
on
storm
sewer
outfall
locations,
volume
discharged,
conventional
pollutant
loads,
and
existence
of
illicit
discharges
is
submitted
as
part
of
the
permit
application
process
(
U.
S.
EPA
1996).
In
addition,
these
MS4s
must
develop
management
plans
addressing
items
such
as
outfall
monitoring,
structural
and
nonstructural
BMPs
to
be
implemented,
and
identification
and
elimination
of
illicit
discharges.
Illicit
discharges
to
MS4s
include
any
non­
stormwater
discharges,
such
as
discharges
that
should
be
connected
to
sanitary
sewers
(
e.
g.,
water
from
sinks,
floor
drains,
and
occasionally
toilets),
illegal
dumping
of
sewage
from
recreational
vehicles,
sanitary
sewer
overflow
backing
up
through
manhole
covers
into
storm
drains,
effluent
from
failing
septic
systems,
water
from
sump
pumps,
etc.

Small
MS4s
(
serving
areas
with
populations
of
less
than
100,000),
with
some
exceptions,
are
subject
to
NPDES
permit
requirements
if
they
are
located
in
"
urbanized
areas"
as
determined
by
the
Bureau
of
the
Census.
Those
MS4s
subject
to
NPDES
permits
must
implement
"
control
measures"
in
six
areas,
including
a
plan
for
eliminating
illicit
discharges
(
U.
S.
EPA
2000b).

PWSs
should
work
with
all
MS4
utilities
in
the
area
of
influence
to
gather
existing
information
about
storm
water
contamination.
MS4
utilities
may
need
to
install
or
retrofit
structural
BMPs,
such
as
retention
ponds,
to
reduce
contamination.

2.4.2.4
What
BMPs
Can
Help
Alleviate
Nonpoint
Sources?

The
following
sections
briefly
describe
BMPs
for
agricultural,
forestry,
and
urban
sources
of
Cryptosporidium;
detailed
descriptions
are
provided
in
Appendix
E.
Your
watershed
control
program
plan
must
discuss
how
these
or
any
other
BMPs
you
choose
will
be
implemented
in
the
area
of
influence.
EPA
Section
319
grants
and
Clean
Water
State
Revolving
Fund
loans
can
be
used
for
nonpoint
sources
and
watershed
management
purposes.

Agricultural
BMPs
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
2­
28
°
Management
Programs
The
U.
S.
Department
of
Agriculture
recommends
the
following
"
control
points"
for
controlling
pathogens
(
USDA
2000):

°
Preventing
initial
infection
by
controlling
pathogen
import
to
the
farm
°
Controlling
the
reproduction
and
spread
of
the
pathogen
throughout
the
farm
°
Managing
waste
°
Controlling
pathogen
export
from
the
farm
PWSs
should
work
with
local
soil
conservation
districts
or
cooperative
extensions
for
technical
assistance
with
BMPs.

BMPs
that
can
reduce
pathogen
loading
include
the
following:

°
Composting
°
Waste
management
(
manure
storage
and
land
application)
°
Grazing
management
°
Feedlot
runoff
diversion
°
Buffer
or
filter
strips
°
Composting
°
Can
effectively
reduce
pathogen
concentrations
°
Entire
waste
mass
should
be
uniformly
treated
and
there
should
be
no
cold
spots
°
Buffer
Strips
°
Provide
buffer
between
area
of
manure
application
or
grazing
and
adjacent
streams
or
lakes
°
USDA
(
2000)
recommends
that
buffer
and
filter
strips
be
considered
secondary
practices
for
pathogen
control
and
be
used
in
conjunction
with
control
measures
°
Grazing
Management
°
Managed
grazing
can
be
cheaper
and
less
environmentally
damaging
than
confined
feeding
and
unmanaged
grazing.
It
decreases
feed,
herbicide,
equipment,
and
fertilizer
costs,
while
reducing
erosion
and
increasing
runoff
infiltration
and
manure
decomposition
rates
(
Ohio
State
University
Extension,
undated).
°
In
managed,
or
rotational,
grazing,
a
sustainable
number
of
cattle
or
other
livestock
graze
for
a
limited
time
(
usually
2­
3
days)
on
each
pasture
before
being
rotated
to
the
next
pasture.
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
2­
29
°
Manure
Storage
°
Manure
storage
facilities
allow
farmers
to
wait
until
field
conditions
are
more
suitable
for
land
application.
°
Manure
storage
facilities
should
be
designed
to
prevent
discharge
through
leaching
or
runoff.
They
should
be
lined,
and
if
possible,
covered.
Facilities
that
are
not
covered
should
be
designed
to
contain
precipitation
and
runoff
from
a
25­
year
24­
hour
storm.

°
Land
Application
of
Manure
°
Several
precautions
taken
in
manure
application
can
prevent
runoff
from
entering
surface
water,
reducing
the
likelihood
of
Cryptosporidium
contamination.
°
Manure
should
not
be
applied
to
frozen
ground
or
before
predicted
rainfall,
or
near
tile
drains
or
dry
wells
or
to
land
subject
to
flooding.
°
For
pastures
to
be
used
for
grazing,
waste
should
be
stored
for
at
least
60
days
and
then
applied
at
least
30
days
before
the
scheduled
grazing
period,
to
avoid
infection
of
the
animals.

°
Feedlot
Runoff
Diversion
°
Diverting
clean
water
before
it
drains
into
the
feedlot
can
significantly
reduce
the
amount
of
wastewater
that
needs
to
be
managed.
°
All
roofs
that
could
contribute
to
feedlot
runoff
should
have
­
°
gutters
°
downspouts
°
outlets
that
discharge
away
from
the
feedlot
Forestry
BMPs
°
Logging
can
cause
increased
erosion,
leading
to
increased
runoff
and
making
it
more
likely
that
Cryptosporidium
present
in
wildlife
will
reach
the
source
water.
Logging
can
also
cause
elevated
sediment
levels,
resulting
in
high
turbidity,
which
affects
water
treatment
efficiency.
Examples
of
forestry
BMPs
are
listed
below
­
°
filter
strips
°
streamside
or
riparian
management
zones
°
logging
roads
should
be
constructed
to
minimize
runoff
°
road
runoff
should
be
diverted
away
from
streams
and
prevented
from
channelizing
°
loggers
should
minimize
soil
disturbance
and
compaction
on
skid
trails
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
2­
30
Urban/
Suburban
BMPs
See
http://
www.
epa.
gov/
owm/
mtb/
mtbfact.
htm
for
fact
sheets
on
technologies
and
BMPs
municipalities
can
use
to
reduce
contamination
from
wastewater
and
stormwater.

°
Buffer
Zones
°
For
watersheds
in
urban
areas,
buffer
zones
help
to
protect
development
on
the
floodplain
from
being
damaged
when
the
water
is
high,
as
well
as
protect
the
stream
from
the
effects
of
the
development.
°
The
extent
to
which
buffer
zones
reduce
Cryptosporidium
loading
is
not
well
understood;
therefore,
they
should
be
used
to
augment,
rather
than
replace,
other
watershed
management
practices.

°
Dry
Detention
Basins
°
Dry
detention
basins
temporarily
store
stormwater
runoff
and
release
the
water
slowly
to
allow
for
settling
of
particulates
and
the
reduction
of
peak
flows.

°
Infiltration
Devices
°
Infiltration
devices
remove
pathogens
and
particles
by
adsorption
onto
soil
particles
and
filtration
as
the
water
moves
through
the
soil
to
the
ground
water.
Infiltration
devices
include
(
NALMS
2000)
­
°
infiltration
basins
°
infiltration
trenches
°
dry
wells
°
Sand
Filters
°
Sand
filters
can
be
used
to
treat
storm
water
runoff
from
large
buildings
and
parking
lots.

°
Wet
Retention
Ponds
°
Ponds
can
effectively
reduce
suspended
particles
and,
presumably,
some
pathogens,
by
settling
and
biological
decomposition.
°
There
is
concern,
however,
that
ponds
attract
wildlife
that
may
contribute
additional
fecal
pollution
to
the
water,
rather
than
reducing
contamination.

°
Constructed
Wetlands
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
2­
31
°
Constructed
subsurface
flow
wetlands
(
where
wetland
plants
are
not
submerged)
can
reduce
Cryptosporidium
and
bacteria
concentrations
in
wastewater
(
Thurston
et
al.
2001).
°
Wetlands
may
also
be
useful
for
treating
storm
water
or
other
polluted
water.

°
Runoff
Diversion
°
Structures
can
be
installed
in
urban
settings
to
divert
clean
water
flow
before
it
reaches
a
contamination
source.
Structures
that
channel
runoff
away
from
contamination
sources
include
stormwater
conveyances,
such
as
­
°
swales
°
gutters
°
channels
°
drains
°
sewers
°
Pet
Waste
Management
°
Municipalities
can
implement
pet
waste
management
programs
to
encourage
pet
owners
to
properly
collect
and
dispose
of
their
animals'
waste.

°
Water
Conservation
°
Can
help
preserve
the
amount
of
water
available
for
use,
especially
during
times
of
drought.
°
Can
also
decrease
the
amount
of
wastewater
and
stormwater
generated,
thereby
protecting
the
quality
of
the
water
supply
(
U.
S.
EPA
2002d)
°
The
following
are
examples
of
water
conservation
methods
­
°
low­
flow
toilets
and
showerheads
°
reducing
lawn
watering
°
Low
Impact
Development
°
Low
impact
development
tries
to
reduce
the
amount
of
impervious
cover,
increase
natural
lands
set
aside
for
conservation,
and
use
pervious
areas
for
more
effective
stormwater
treatment
of
residential
and
commercial
developments.

°
Septic
Systems
°
Failing
septic
systems
can
result
in
clogging
and
overflow
of
waste
onto
land
or
into
surface
water.
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
2­
32
°
Water
systems
should
work
closely
with
the
local
regulatory
authority
to
ensure
that
septic
system
codes
are
being
properly
enforced
and
to
strengthen
codes
where
necessary.
°
Utilities
should
encourage
residents
with
septic
systems
in
the
watershed
to
understand
their
systems
and
the
proper
maintenance
that
their
systems
require.
Cooperative
extensions
can
work
with
residents
on
this
issue.

°
Wildlife
BMPs
°
Steps
taken
to
prevent
wildlife
from
contaminating
source
water
vary
with
the
source
and
type
of
wildlife.
The
following
are
examples
of
wildlife
BMPs
­
°
boats
with
noisemakers
to
scare
seagulls
and
geese
away
°
fences
on
the
water's
edge
to
keep
out
larger
land
animals
and
humans
2.4.3
Writing
the
Watershed
Control
Plan
Your
plan
must
establish
goals
and
define
and
prioritize
specific
actions
to
reduce
source
water
Cryptosporidium
levels.
The
plan
must
explain
how
the
actions
are
expected
to
contribute
to
the
goals,
identify
watershed
partners
and
their
roles,
identify
resource
requirements
and
commitments,
and
include
a
schedule
for
plan
implementation
(
40
CFR
141.725(
a)(
3)(
iii)).

The
Center
for
Watershed
Protection
provides
basic
templates
to
help
with
design
of
watershed
protection
programs,
including
steps
systems
can
take
in
seven
areas:
watershed
planning,
land
conservation,
buffer
zones,
stormwater
BMPs,
non­
stormwater
discharges,
watershed
stewardship
programs,
and
unique
tools
(
e.
g.,
spill
response).
Templates
are
available
at
www.
stormwatercenter.
net.

2.4.4
How
States
Should
Assess
Plans
Vulnerability
Analysis
The
vulnerability
analysis
should
evaluate
the
potential
for
the
water
supply
to
draw
water
contaminated
with
Cryptosporidium.
Cryptosporidium
prevalence
and
the
natural
sensitivity
of
the
water
source
should
be
considered
together
to
determine
the
potential
susceptibility
of
the
drinking
water
source
to
contamination.
The
utility
should
define
an
area
of
influence
for
its
water
supply
and
provide
an
explanation
of
the
assumptions
that
guided
the
delineation
of
that
area
of
influence.
The
vulnerability
analysis
should
take
into
account
hydrologic
and
hydrogeologic
factors,
intake
location,
fate
and
transport
characteristics
of
Cryptosporidium
oocysts,
and
characteristics
of
potential
sources
of
Cryptosporidium
in
the
area
of
influence.
In
addition,
the
vulnerability
analysis
should
address
the
prevalence
of
different
Cryptosporidium
sources
within
the
area
of
influence.
Some
assessment
criteria
that
States
can
use
during
their
Chapter
2
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Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
Manual
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June
2003
2­
33
review
of
vulnerability
analyses
are
provided
in
Table
2.1.
Additional
criteria
may
be
appropriate,
based
on
site­
specific
characteristics
of
the
area
of
influence
and
sources
of
Cryptosporidium
contamination.

Identification
and
Analysis
of
Control
Measures
The
water
supply
must
identify
what
measures
could
be
taken
to
reduce
or
eliminate
sources
of
Cryptosporidium
identified
in
the
vulnerability
analysis
(
40
CFR
141.725(
a)(
3)(
ii)).
These
control
measures
should
be
discussed
in
enough
detail
that
the
water
supply
has
demonstrated
it
has
a
realistic
understanding
of
what
would
be
needed
to
implement
the
measures.
The
water
supply
should
include
an
accurate
estimate
of
control
measure
costs,
as
well
as
discussion
of
the
political
feasibility
of
implementation.
Thoughtful
estimates
should
be
included
of
how
much
time
the
implementation
of
specific
control
measures
would
take,
including
any
special
considerations,
such
as
seasonal
restrictions.

In
addition,
the
system
must
address
how
implementation
of
the
control
measures
will
impact
Cryptosporidium
loading
in
the
watershed
(
40
CFR
141.725(
a)(
3)(
ii)).
The
utility
should
discuss
the
degree
to
which
control
measures
would
control
specific
sources
of
Cryptosporidium.
It
should
also
provide
context
of
the
overall
impact
of
the
implementation
of
the
control
measures,
addressing
which
control
measures
will
be
applied
to
Cryptosporidium
sources
that
are
significant
in
size
or
close
to
the
water
supply
intake,
and
how
effective
the
utility
thinks
they
will
be.
Some
assessment
criteria
that
States
can
use
during
their
review
of
the
utility's
discussion
of
control
measures
are
provided
in
Table
2.1.

The
Watershed
Protection
Plan
The
watershed
protection
plan
must
address
goals
and
define
and
prioritize
specific
actions
to
reduce
source
water
Cryptosporidium
levels.
The
plan
must
explain
how
actions
are
expected
to
contribute
to
the
specified
goals,
identify
partners
and
their
roles,
describe
resource
requirements
and
commitments,
and
include
a
schedule
for
plan
implementation
(
40
CFR
141.725(
a)(
3)(
iii)).
Some
assessment
criteria
for
States
to
use
during
the
review
of
watershed
protection
plans
are
provided
in
Table
2.1.

Cryptosporidium
control
measures
included
in
watershed
protection
plans
may
include
such
diverse
activities
as
structural
BMPs,
land
use
control
regulations,
and
public
education.
Each
of
the
activities
should
have
a
timetable
for
implementation,
a
budget,
and
details
about
how
the
activity
will
be
implemented.

Utilities
will
have
the
maximum
opportunity
to
realize
their
watershed
protection
goals
if
they
have
complete
ownership
of
the
watershed.
Utilities
should
include
in
their
watershed
protection
plan
a
description
of
efforts
that
will
be
made
to
obtain
ownership,
such
as
any
special
programs
or
budget.
When
complete
ownership
of
the
watershed
or
area
of
influence
is
not
Chapter
2
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Watershed
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LT2ESWTR
Toolbox
Guidance
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2003
2­
34
practical,
the
system
should
explain
what
efforts
will
be
made
to
gain
ownership
of
critical
elements,
such
as
reservoir
or
stream
shoreline
and
access
areas.

Where
ownership
of
land
is
not
possible,
utilities
should
describe
plans
to
obtain
written
agreements
that
recognize
the
watershed
as
part
of
a
public
water
supply.
As
much
as
possible,
maximum
flexibility
should
be
given
to
the
utility
to
control
land
uses
which
could
have
an
adverse
effect
on
the
water
quality.
Utilities
should
include
with
these
descriptions
an
explanation
of
how
they
will
ensure
that
landowners
will
comply
with
the
agreements.

Watershed
control
plans
must
identify
watershed
partners
and
their
roles
(
40
CFR
141.725(
a)(
3)(
iii)).
Plans
should
document
the
efforts
to
be
made
to
establish
voluntary
local
partnerships,
including
solicitation
of
private
individuals
living
within
the
defined
area
of
influence
who
are
likely
to
be
affected
by
decisions
made
as
part
of
the
watershed
protection
program,
whose
participation
is
important
for
the
success
of
the
program.
Plans
should
also
document
how
members
of
municipal
or
other
local
governments
or
political
subdivisions
of
the
State
that
have
jurisdiction
over
the
area
of
influence
will
participate
in
the
watershed
protection
effort.
Watershed
protection
plans
should
include
descriptions
of
how
the
proposed
local
partnership
has
or
will
identify
and
account
for
any
voluntary
or
other
activities
already
underway
in
the
area
of
influence
that
may
reduce
or
eliminate
the
likelihood
that
Cryptosporidium
will
occur
in
drinking
water.

Table
2.1
Assessment
Criteria
for
Use
By
States
When
Reviewing
Watershed
Control
Program
Plans
Assessment
Criteria
Addressed
in
Sufficient
Detail?

Vulnerability
Analysis
Has
the
area
of
influence
been
delineated
in
appropriate
detail,
taking
into
consideration
available
information
about
Cryptosporidium
fate,
transport
and
local
hydrogeological
characteristics?
Have
sensitive
areas
been
identified?

Is
the
scale
of
the
delineation
appropriate
for
the
watershed
plan?
Does
it
provide
a
level
of
detail
sufficient
for
effective
decisions
to
be
made?

Has
the
intake
location
been
identified
relative
to
the
water
body?

Is
any
information
available
about
time
of
travel
in
the
watershed?

Does
it
seem
that
all
activities
within
the
watershed
that
could
result
in
Cryptosporidium
contamination
of
the
water
supply
have
been
identified
and
located?

Have
contaminant
sources
been
located
and
described
relative
to
the
drinking
water
source
intake
location?

Have
the
likelihood
and
timing
of
releases
of
contamination
been
addressed?
Chapter
2
­
Watershed
Control
Program
Assessment
Criteria
Addressed
in
Sufficient
Detail?

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2003
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35
Are
there
permitted
wastewater
discharges
(
NPDES)
of
concern?
If
there
are
wastewater
treatment
plants
in
the
area
of
influence,
systems
should
include
information
about
their
size,
discharge
quantity,
and
whether
there
has
been
any
recent
significant
noncompliance
with
permit
conditions.

Are
sludge
disposal
areas
identified
and
characterized?
Are
there
any
locations
in
the
watershed
where
biosolids
have
been
applied?
Have
they
been
identified?
When
in
the
year
are
they
applied?

Have
stormwater
discharges
been
located?
Are
there
any
discharges
directly
into
the
surface
water
supply?

Have
septic
systems
been
identified
and
located?
What
information
is
available
about
their
age,
condition,
design,
and
siting?

Has
land
use
zoning
been
characterized?

If
land
uses
in
the
watershed
include
agriculture,
have
the
types
of
farming
been
identified?
Are
feedlots
located?
Are
fields
where
manure
is
spread
identified?

Have
Concentrated
Animal
Feeding
Operations
(
CAFOs)
been
identified
and
located?

Have
natural
sources
of
Cryptosporidium
been
identified
and
located?

Have
recreational
areas
(
e.
g.,
campgrounds,
trailer
parks)
been
identified
and
located?

Has
any
on­
site
landfilling,
land
treating,
or
surface
impounding
of
waste
other
than
landscape
waste
or
construction
and
demolition
debris
taken
place,
and
will
such
circumstances
continue?

Does
the
vulnerability
analysis
address
the
effectiveness
of
physical
barriers
(
e.
g.,
geology,
hydraulic
conditions,
intake
structure
and
location)
at
preventing
the
movement
of
contaminants
to
the
drinking
water
source?

Have
tributaries
or
areas
of
the
reservoir
with
high
bacterial
readings
been
identified?
If
so,
where
are
they
located
relative
to
the
drinking
water
intake?

If
Cryptosporidium
monitoring
data
exist
for
the
watershed,
have
results
been
addressed
and
discussed?

Have
recreational
uses
of
the
surface
water
supply
been
identified?
Has
the
effect
of
those
uses
on
Cryptosporidium
loading
been
addressed?

Are
there
portions
of
the
watershed
with
high
percentages
of
impervious
surfaces
which
might
lead
to
increased
stormwater
runoff?

Is
water
quality
monitoring
and
assessment
information
(
305(
b)
Report)
available?

Have
existing
best
management
practices
or
controls
been
identified
and
located?

Is
there
any
information
available
about
the
effectiveness
of
current
pollution
prevention
activities?
Chapter
2
­
Watershed
Control
Program
Assessment
Criteria
Addressed
in
Sufficient
Detail?

LT2ESWTR
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2003
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36
Potential
Control
Measures
to
Control
Cryptosporidium
Contamination
Do
the
control
measures
proposed
specifically
address
the
reduction
of
Cryptosporidium
contamination?

Would
the
implementation
of
the
proposed
control
measures
take
place
in
areas
where
there
would
be
an
impact
on
Cryptosporidium
loading
into
the
water
supply?

Do
the
proposed
control
measures
seem
economically
and
politically
feasible?

If
the
proposed
control
measures
are
ongoing,
has
the
utility
explained
how
they
would
be
sustained?

Is
the
water
utility
in
a
position
where
it
could
implement
the
control
measures
itself,
or
would
other
parties
be
responsible?

If
other
parties
would
be
responsible
for
implementation,
are
those
parties
motivated
and
reliable?
What
agreements
between
the
utility
and
those
parties
exist
that
document
implementation
responsibilities?

How
does
the
utility
track
control
measures
implemented
by
other
parties?

Has
the
water
system
responded
adequately
to
concerns
expressed
about
the
source
or
watershed
area
in
past
inspections
and
sanitary
surveys?

Watershed
Control
Program
Plan
Does
the
plan
specifically
address
potential
and
existing
Cryptosporidium
sources
in
the
watershed?

Have
the
proposed
actions
in
the
plan
been
clearly
defined
and
sufficiently
addressed?

Does
the
plan
explain
how
the
actions
described
are
expected
to
contribute
to
specified
goals?

Does
the
plan
prioritize
its
proposed
efforts?
Does
it
define
short­
term
and
long­
term
actions
and
prioritize
them?

Does
the
plan
include
cost
estimates
for
implementation
of
proposed
actions?

Does
the
plan
include,
in
detail,
what
other
resources
will
be
required
to
implement
the
watershed
control
measures?
Does
it
identify
the
source(
s)
of
those
resources?

Does
the
plan
include
an
implementation
schedule?

Does
the
plan
assign
responsibilities
for
implementing
short­
term
and
long­
term
actions?

How
reliable
are
the
organizations
that
will
be
carrying
out
the
source
protection
activities?

Has
an
individual
been
identified
as
the
responsible
party
for
the
plan?
Chapter
2
­
Watershed
Control
Program
Assessment
Criteria
Addressed
in
Sufficient
Detail?

LT2ESWTR
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Guidance
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Proposal
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June
2003
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37
Will
the
entire
watershed
for
the
source
be
protected?
Will
the
utility
try
to
purchase
all
land
within
the
watershed?
If
not,
will
critical
elements
of
the
watershed
be
protected
or
purchased
by
the
utility?

If
the
water
system
cannot
purchase
portions
of
the
watershed,
does
it
propose
to
have
written
agreements
with
the
landowners
concerning
land
use?

Where
access
is
limited,
will
the
watershed
be
inspected
regularly
for
new
potential
and
actual
sources
of
contamination?

Does
the
plan
address
all
existing
regulations
for
the
watershed
or
area
of
influence?

Does
or
will
the
water
system
employ
adequately
qualified
personnel
to
identify
watershed
and
water
quality
problems?
Who
is
given
responsibility
to
correct
these
problems?

Have
the
stakeholders
in
the
watershed
or
area
of
influence
been
identified?

Were
stakeholders
involved
with
the
plan's
development?

Is
it
proposed
that
the
water
system
will
actively
interact
with
other
agencies
that
have
control
or
jurisdiction
in
the
watershed?
Are
their
policies
or
activities
consistent
with
the
water
system's
goal
of
reducing
source
water
Cryptosporidium
levels?

How
does
the
watershed
protection
plan
propose
to
coordinate
protection
efforts?
Will
there
be
a
committee
of
stakeholders?

How
will
the
utility
track
progress
of
the
implementation
of
the
watershed
controls?
Does
the
plan
describe
how
the
utility
intends
to
measure
the
success
of
projects?

2.5
Maintaining
Approval
of
a
Watershed
Control
Program
2.5.1
Annual
Watershed
Control
Program
Status
Report
The
annual
watershed
control
program
status
report
must
describe
the
water
system's
implementation
of
the
approved
plan
and
assess
the
adequacy
of
the
plan
for
meeting
the
system's
stated
goals.
The
annual
report
must
explain
how
the
system
is
addressing
any
shortcomings
in
plan
implementation,
including
those
previously
identified
by
the
State
or
by
the
system
during
a
watershed
survey.
If
the
system
needs
to
make
substantial
changes
to
its
approved
program,
it
must
explain
the
nature
of
those
changes
and
why
they
are
being
made.
If
the
changes
are
likely
to
reduce
the
level
of
source
water
protection,
the
water
utility
must
explain
what
actions
it
will
take
to
mitigate
the
effects
(
40
CFR
141.725(
a)(
4)(
i)).
If
there
have
been
any
changes
to
components
of
the
program,
such
as
partnerships
or
stakeholder
groups
that
have
been
created
or
have
dissolved,
the
annual
report
should
include
this
information,
along
with
a
description
of
how
the
change
will
affect
the
watershed
control
program
plan.
Chapter
2
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Watershed
Control
Program
LT2ESWTR
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June
2003
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The
annual
status
report
must
describe
progress
being
made
implementing
individual
control
measures
(
40
CFR
141.725(
a)(
4)(
i)).
Progress
should
be
compared
with
the
original
timetable
provided
in
the
watershed
control
program
plan.
Implementation
delays
should
be
explained,
and
actions
to
prevent
further
delays
should
be
proposed.

The
original
watershed
control
program
plan
should
include
specific
measures
by
which
the
utility
can
evaluate
the
effectiveness
of
the
program.
Annual
status
reports
should
provide
updates
on
those
measures
of
program
effectiveness
as
the
watershed
practices
are
implemented.
The
report
should
address
progress
being
made
on
high
priority
activities
and,
to
the
extent
possible,
evaluate
whether
projects
are
achieving
their
objectives.
The
report
should
also
identify
emerging
issues
and
incorporate
them
into
the
watershed
protection
program.
Since
annual
status
reports
must
be
available
to
the
public
on
request,
reports
must
be
written
in
plain
language
format
(
40
CFR
141.725(
a)(
4)(
iv)).

2.5.2
State­
Approved
Watershed
Sanitary
Survey
The
annual
watershed
sanitary
survey
must
be
conducted
according
to
State
guidelines
and
by
persons
approved
by
the
State
to
conduct
watershed
surveys.
The
survey
must
encompass
the
area
of
influence.
At
a
minimum,
the
watershed
survey
must
assess
the
priority
activities
identified
in
the
plan
and
identify
any
significant
new
sources
of
Cryptosporidium
(
40
CFR
141.725(
a)(
4)(
ii)).
States
developing
a
watershed
sanitary
survey
program
may
wish
to
use
the
watershed
sanitary
survey
manual
developed
by
the
California
Department
of
Health
Services,
and
the
California/
Nevada
Section
of
AWWA
(
the
manual
is
available
from
the
California/
Nevada
Section).

The
watershed
survey
should
be
conducted
by
competent
individuals
such
as
engineers,
sanitarians,
or
technicians
with
experience
in
the
operation
of
water
systems
and
a
sound
understanding
of
public
health
principles
and
waterborne
diseases.
Other
means
of
assessing
inspector
qualifications
include
whether
the
inspector
has
attended
formal
training
sessions,
whether
he
or
she
has
documented
on­
the­
job
training,
whether
the
training
received
is
appropriate
for
the
type
and
size
of
system
being
surveyed,
and
whether
the
inspector
is
knowledgeable
about
State
and
federal
drinking
water
regulations.

The
annual
watershed
survey
should
address
the
following
areas:

°
Review
the
effectiveness
of
the
watershed
control
program
to
date
°
Identify
any
new
significant
actual
or
potential
sources
of
Cryptosporidium
°
Verify
and
re­
evaluate
the
vulnerability
analysis
°
Verify
that
the
utility
has
control
over
watershed
areas
and
activities
specified
as
its
responsibility
in
the
Watershed
Protection
Plan
°
Confirm
that
public
access
is
properly
restricted
from
areas
identified
in
the
Watershed
Protection
Plan
Chapter
2
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Control
Program
LT2ESWTR
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2003
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°
Confirm
that
fencing
and
postings
have
not
been
vandalized
or
removed
°
Identify
any
significant
hydrological
changes
in
the
watershed
that
could
affect
Cryptosporidium
loading
°
Inspect
the
intake
structure
and
identify
any
modifications
to
its
location
or
design
A
final
survey
report
must
be
submitted
to
the
State
for
approval
(
40
CFR
141.725(
a)(
4)(
ii)).
The
report
should
be
completed
as
soon
as
possible
after
the
survey
is
conducted.
The
length
of
the
report
will
depend
on
the
findings
of
the
survey
and
the
size
and
complexity
of
the
watershed.
The
survey
report
should
include:
1)
the
date
of
the
survey;
2)
who
was
present
during
the
survey;
3)
survey
findings;
4)
recommended
improvements
to
the
identified
problems;
and
5)
the
dates
for
completion
of
any
improvements.

The
annual
watershed
survey
reports
must
be
written
in
a
plain
language
format.
Survey
results
must
be
made
available
to
the
public
upon
request.
The
State
may
withhold
portions
of
the
survey
report
based
on
security
considerations
(
40
CFR
141.725(
a)(
4)(
iv)).

2.5.3
Request
for
Re­
Approval
If
the
water
system
intends
to
continue
to
receive
0.5
log
Cryptosporidium
removal
credit
beyond
the
approval
period,
it
must
submit
a
written
request
for
review
and
re­
approval
of
the
watershed
control
program.
The
request
must
be
provided
to
the
State
at
least
six
months
before
the
current
approval
period
expires
or
by
a
date
previously
determined
by
the
State.
The
request
must
include
a
summary
of
activities
and
issues
identified
during
the
previous
approval
period
and
a
revised
plan
that
addresses
activities
for
the
next
approval
period,
including
any
new
actual
or
potential
sources
of
Cryptosporidium
contamination
and
details
of
any
proposed
or
expected
changes
to
the
existing
State­
approved
program.
The
revised
plan
must
address
goals,
prioritize
specific
actions
to
reduce
source
water
Cryptosporidium,
explain
how
actions
are
expected
to
contribute
to
achieving
goals,
identify
partners
and
their
roles,
describe
resource
requirements
and
commitments,
and
include
a
schedule
for
further
plan
implementation
(
40
CFR
141.725(
a)(
4)(
iii)).

2.5.3.1
Describe
Implementation
of
Plan
The
request
for
re­
approval
should
build
upon
progress
that
has
been
made
during
the
previous
watershed
protection
period.
It
must
update
program
goals
and
priorities
for
Cryptosporidium
control
measures
and
explain
how
proposed
actions
will
contribute
to
specified
goals.
The
request
for
re­
approval
must
include
involved
parties
and
their
roles,
resource
requirements
and
commitments,
and
schedules
for
implementation.
New
actual
or
potential
sources
of
Cryptosporidium
contamination
identified
in
previous
annual
watershed
surveys
must
be
addressed,
(
40
CFR
141.725(
a)(
4)(
iii)).
Each
new
watershed
control
measure
introduced
should
have
a
timetable
for
implementation,
a
budget,
and
details
about
how
the
activity
will
be
implemented.
The
request
for
re­
approval
should
also
include
updated
measures
by
which
the
utility
can
evaluate
the
effectiveness
of
the
program.
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
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June
2003
2­
40
2.5.3.2
Describe
How
System
Is
Addressing
Any
Problems
As
part
of
the
request
for
re­
approval,
the
water
system
should
identify
any
unresolved
problems
it
encountered
during
the
previous
watershed
protection
period
that
interfered
with
achieving
the
stated
watershed
protection
goals.
The
system
should
address
how
it
intends
to
resolve
the
problems
or
change
the
watershed
protection
plan
to
work
around
the
problems.
If
the
changes
proposed
are
likely
to
reduce
the
level
of
source
water
protection,
the
utility
should
explain
what
actions
it
will
take
to
mitigate
the
effects.

2.5.3.3
Describe
Need
for
Changes
in
Plan
Many
watershed
protection
plans
will
require
periodic
revisions
to
ensure
that
their
actions
and
priorities
remain
up­
to­
date.
As
part
of
the
request
for
program
re­
approval,
the
utility
should
describe
what
changes
need
to
be
made
to
the
watershed
protection
plan
and
explain
why
those
changes
should
be
made.
Any
new
control
measure
introduced
should
be
accompanied
by
a
budget,
timetable
for
implementation,
and
details
about
how
the
measure
will
be
implemented.
The
utility
should
include
an
explanation
of
how
and
why
the
watershed
protection
plan's
priorities
may
change
for
the
next
approval
period.
The
utility
should
also
define
measures
by
which
it
will
evaluate
the
effectiveness
of
the
revised
program.

2.5.4
Guidance
to
States
on
Re­
Approval
The
State
should
consider
several
sources
of
information
when
reviewing
requests
for
reapproval
It
should
refer
to
a
system's
annual
watershed
control
program
status
reports
to
evaluate
whether
progress
made
so
far
is
acceptable
and
that
previous
timetables
have
been
accurate.
The
State
should
review
whether
the
identified
responsible
parties
are
participating
reliably
and
in
a
timely
manner.

The
State
should
review
the
annual
watershed
surveys
to
ensure
that
newly
discovered
actual
or
potential
sources
of
Cryptosporidium
contamination
have
been
addressed
in
the
request
for
re­
approval
and
feasible
control
measures
have
been
proposed.
The
State
should
also
refer
to
the
most
recent
sanitary
survey
conducted
of
the
water
system
to
see
that
source
protection
concerns
regarding
pathogen
contamination
are
being
addressed.
States
can
use
the
watershed
control
program
plan
assessment
criteria
provided
in
Table
2.1
to
guide
their
review
of
the
proposed
changes
to
the
plan.

As
part
of
the
re­
approval
process,
States
should
consider
whether
a
utility's
measures
of
program
effectiveness
for
the
previous
approval
period
were
useful
and
accurate.
If
not,
States
should
ensure
that
the
request
for
re­
approval
includes
improved
ways
to
measure
program
effectiveness.
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
2­
41
Chapter
2
­
Watershed
Control
Program
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
2­
42
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