Sole Source Aquifer Petition

The Sole Source Aquifer Petition is a 57-page report submitted to the U.S. Environmental Protection Agency in 2007. The City of Bryan submitted the petition, which was prepared by Tritium, Inc., in collaboration with Bryan Municipal Utilities. (Tritium is the company owned by Todd Feenstra, AOP’s consultant on the project.)

The Introduction states the following:

“The purpose of a sole source aquifer designation is the protection and management of a vulnerable aquifer system that represents the sole source of drinking water within the designated area.”

“The goal of this petition is to present the factual, defendable information necessary to justify a sole source aquifer designation for a portion of the MICHINDOH Glacial Aquifer system.”

“The study area for this petition includes portions of nine counties which are contained within three states (Figure 1). The MICHINDOH aquifer system is comprised of variably confined, hydraulically connected, discontinuous sand and gravel intervals distributed vertically within unconsolidated glacial sediments.”

The research conducted as part of this petition includes:
1. a physical description of the aquifer and the local boundaries;
2. identification of alternative drinking water sources;
3. population, income, and water demand statistics within the designated area;
4. feasibility analyses of alternative source implementation design and costs.

The first paragraph of the Narrative gives additional description of the aquifer:

“The MICHINDOH aquifer system is an extensive sand and gravel aquifer system that covers nearly all the nine-county, three-state study area for this petition. The aquifer system is comprised of hydraulically-connected sand and gravel intervals distributed laterally and vertically through the nearly 200-foot thick Quaternary sediments that blanket the study area. The aquifer system likely extends further west and north than this study area, but the relevant groundwater basin identified within this aquifer system is contained within this nine-county area.”

The reasons given for submitting the Sole Source Aquifer Petition are:
1. Assisting the development of local initiatives for managing hazardous materials within the petitioned area.

2. Integrating surface water drainage basins and aquifer recharge areas with the existing delineated Wellhead Protection Areas (WHPA). The extent of the WHPAs is limited to the five-year time of travel for ground water particles and does not address contamination that may affect the wellfields via upgradient recharge areas and/or surface water drainage.

3. Providing local governments with the knowledge and demonstrable, defendable proof to delineate critical areas within the MICHINDOH aquifer system that are sensitive to potential contamination. The thrust of the petition is to encourage commercial, industrial, and residential growth in a responsible manner that recognizes and protects the region’s vital ground water resources.

4. Designating critical areas for protection near communities where wellhead protection delineations and programs have not been implemented.

5. Educating the urban and rural residents and business owners within the sole source aquifer area regarding the financial value of the aquifer, their dependence on this unique resource, the vulnerability of the aquifer system, the types of potential contamination, the critical portions of the aquifer, and straightforward methods of protecting this resource.

6. Enlisting federal funding assistance in encouraging growth of new industry in a responsible manner.

The Petition includes extensive information on the geology of the area (Section 2).

The Michindoh Aquifer itself is examined in detail (Section 3) including physical description, recharge areas, vulnerability assessment, streamflow source area, aquifer service area (including boundaries, both physical and economic).

The Petition (Section 4) describes the sources for drinking water for the area.

Section 5 provides “preliminary estimates of the capital costs associated with the transfer to alternative drinking water sources” if the aquifer’s water were unavailable.