As on-the-ground inventories are completed, updated Source Water Assessments with Contamination Potential Rating will be sent to the PWSSs. If the second round of the Assessment has not been completed in 5 years, an update will be done on available database information. This time frame fits with the Sanitary Survey Program administered by NHHS. Ideally the PWSS will record or be able to identify any changes in their Contaminant Source Inventory over the five year period. NDEQ will check for any well changes and develop new WHPA and a new database search, as necessary. NDEQ will request that the PWSS make any additions or corrections to the existing assessment regarding issues not on record or known by NDEQ.
8.2 New Systems
It is recommended that any new PWSSs (regardless of type) will complete a Source Water Assessment before or at the time it goes on line, and provides drinking water to the public. This may be incorporated with Capacity Development which is a requirement of the Safe Drinking Water Act (SDWA) Amendments.
As other federal and state regulations change, appropriate changes and updates to Nebraska’s SWAP will be considered.
8.3 Emergency Response Plan and Other States
After SWAP submittal to EPA, development of an emergency response plan will be done in cooperation with other States, appropriate state and local agencies, and all surface water systems (or GWUDI wells). Major coordination is especially needed for Missouri and Platte River PWSSs. NDEQ recognizes how important this issue is, and with help from EPA to coordinate this effort, a notification and response system will be developed.
NDEQ has been in contact with South Dakota, Iowa, Missouri, Colorado, and Wyoming on interstate coordination issues. NDEQ will continue its cooperation with the above mentioned states, and work with all adjacent states as necessary. All information regarding contaminant source issues affecting adjacent states will be shared between Nebraska and those states.
8.4 Priority for Permits and Compliance NPDES Inspections
Discussions with NDEQ management are continuing to re-examine inspections for NPDES discharges. Discharges to rivers upstream from surface water PWSS intakes may be prioritized for more frequent inspections.
8.5 Ground Water Disinfection Rule
Information that is gained from Source Water Assessments for ground water systems could aid in determining the potential for microbial contaminants as proposed for regulation under the Ground Water Disinfection Rule now known as the Ground Water Rule. Because the Rule is not final yet, it is difficult to predict how the two programs will interact.
8.6 18 Month Extension
NDEQ is requesting an 18 month extension due to budget and time constraints. NDEQ recognizes that the lack of information and geographic locations for Transient PWSSs will make these assessments more difficult and time consuming. Additionally, the existing Sanitary Survey Program for Public Water Supply Systems has an established five year cycle in which assessments are being completed, therefore the entire time is needed to complete the Assessments.
8.7 Tribes
NDEQ sent a draft SWAP description to representatives of the Tribes in Nebraska. After SWAP approval, NDEQ will discuss the SWAP with Tribes and offer any assistance that may be needed or requested. Additionally, NDEQ will offer to perform the Source Water Assessment for each PWSS on Tribal land, if so requested and arranged by the Tribes.