DOCSLIB.ORG

Wellhead Protection Programs: Tools for Local Governments

Total Page：16

File Type：pdf, Size：1020Kb

Download full-text PDF Read full-text
Wellhead Protection Programs: Tools for Local Governments United States Office of Water E~A440 6-a9-002 Environmental Protection ( W H -550G) April 1989 SEPA Wellhead Protection Programs Tools For Local Governments WELLHEAD PROTECTION PROGRAMS: TOOLS FOR LOCAL GOVERNMENTS OFFICE OF WATER OFFICE OF GROUNDWATER PROTECTION U.S. E"MElyTAc PROTECTION AGENCY APRIL 1989 ? FOREWORD The 1986 Amendments to the Safe Drinking requirements of the SDWA Amendments. While Water Act (SDWA) established a new Wellhead the responsibilities of local governments depend Protection (”) Program to protect ground upon the particular requirements of their State’s waters that supply wells and weUfields that Wellhead Protection Program, localities are often contribute drinking water to public water supply in the best position to implement measures to systems. Under SDWA Section 1428 each State ensure that wellhead areas are properly protected must develop a WHP Program that consists of from contamination. several elements. Local governments typically implement zoning At a minimum, each State’s WHP Program decisions, develop land-use plans, oversee building must: and frre codes, implement health requirements, supply water and sewer services, and enforce police (1) Specify roles and duties of State agencies, local powers. Each of these local powers may be used government entities. and public water suppliers, to protect the quality of local aquifers. with-respect to WHP Programs; Local cities and counties are also often the (2) Delineate the wellhead protection area innovators in developing wellhead protection (WHPA) for each wellhead; programs by applying combinations of management techniques (e.g., zoning and source prohibitions) to (3) Identdy sources of contaminants within each meet unique locai conditions. Localities often WHPA; protect ground water as part of larger projects, such as developing growth management plans or (4) Develop management approaches to protect the economic development efforts. in close cc<opera- water supply within WHPAs from such tion with regional, State, and Federal agencies, contaminants; local governments can take positive steps to protect their wellhead areas. (5) Develop contingency plans for each public water suppiy system to respond to well or Because of the importance of local efforts to wellfieid contamination; protect ground water, EPA has prepared this Technical Assistance Document. In general, this (6) Site new wells properiy to maximize yield and document is directed at the fourth program minimize potential contamination; and element noted above, the management of contaminant sources within WHP areas. More (7) Ensure public participation. specifically, it shows how local governments, such as cities and counties, have developed innovative The Wellhead Protection Program requires the and effective wellhead protection programs, even .partiupation of all levels of government. The with limited resources and expertise. The Federal government is responsible for approving document describes wavs in which local State Wellhead Protection Programs and for governments may develop such programs, discusses providing technical support to State and local potential management tools. and provides examples governments. States must develop and implement of local programs around the country. Wellhead Protection Programs that meet the 1 ACKNOWLEDGEMENTS This document was prepared for the Environmental Protection Agency, Office of Ground-Water Protection (OGWP)by ICF Incorporated. h4.r. Stan Austin and Mr. Steven Roy of OGWP served as Task Managers for this project with assistanct from Dr. Norbert Dee. ICF Incorporated staff who were principally involved in preparing this document included Reid Harvey and Peter Linquiti, who served as Project Manager. Marian Mlay Director Office of Ground-Water Protection TABLE OF CONTENTS 1. USINGTHIS DOCUMENT .............................................. 1 Organization ofDocument ............................................... 1 .Other Technical Assistance Documents ........................................ 2 2 . IDENTIFYING LOCALNEEDS ........................................... 3 Local Objectives ...................................................... 3 Wellbead .Protection Area ................................................. 3 Wellhead Delineation ...................... : .......................... 3 Ground-Water Hydrogeology ........................................... 4 Sources of Contamination ................................................ 5 Inventory of Existing Sources ........................................... 5 Potential for New Sources ............................................. 7 Prioritizing Sources of Contamination ..................................... 7 LocalResoyces ...................................................... 8 Admini.ctrative ..................................................... 8 Resources ....................................................... 8 Economic/Political .................................................. 8 Legal ........................................................... 8 ExistingPrograms ..................................................... 9 Federal ......................................................... 9 State ........................................................... 10 RegionalandLocal .................................................. 10 3. CHOOSING APPROPRIATE TOOLS FOR WELLHEAD PROTECTION .............. 11 Overview ........................................................... 11 Zoning Ordinances .................................................. 12 Subdivision Ordinances .......................... 1. ..................... 18 Site Plan Review ................................................... 19 DesignStandads ................................................... 21 Operating Standards .................................................. 23 Source Prohibitions ................................................. 25 Purchase of Property or Development Rights ................................ 26 . PubkEducation ................................................... 29 Ground-Water Monitoring ............................................. 30 Household Hazardous Waste Collection .................................... 32 Water Conservation ................................................. 33 Other Methods ...................... ............................. 34 4. IMPLEMENTING A LOCAL PROGRAM .................................... 36 Staffing ............................................................ 36 Communication ....................................................... 37 Enforcement and Oversight ................................................ 38 I TABLE OF CONTENTS (continued) 5. "DING ADDITIONAL INFORMATION . 39 EPA Regional Ground-Water Representatives . , . , . 40 State Ground-Water Protection Contacts . , . 41 Other Sources of Information ... , . 46 ENDNOTES ........................................................... 49 8 c SECTION 1 ~~ USING THIS DOCUMENT This Technical Assistance Document (TAD) Delineating wellhead protection describes how localities can, as a part of a State areas; Wellhead Protection Program, develop and implement effective techniques for the protection Evaluating sources of contamina- of ground water. The document emphasizes tion; and innovative wellhead protection methods that have been used by local communities, discusses 0 Examining implementation issues combinations of programs that have worked well, (e.g., funding, legal authority). and presents several factors that affect the success of local wellhead protection programs, such as Section 3 (Choosing Appropriate Tools for budgetary constraints and legal issues. Examples Wellhead Protection) describes several management of the ways in which some communities are using tools, provides examples where they have been management tools to protect ground water are successfully applied, and notes how tools can be highlighted in the text in bold face print or in combined effectively. shaded boxes. Contacts for more information on these local programs are listed at the end of the The management tools described here include: document. Zoning ordinances: Direct land development and regulate land LOCAL GOVERNMENTS ARE uses; TAKING STEPS TO PROTECT GROUND WATER Subdivision ordinances: Protect land divided for development; nte town of Rib M good ewmple of a successfil local govemment Site plan review: Helps ensure ground-waterprotection progmm. Rib Moun- compliance with development tain, located in Marathon Co Plans; 0 Design standards: Prevent susceptible to contamination because of its ground-water contamination by highly permeable aquifeE In September 1985, setting design and construction after receiving assistance from the Marathon * standards; County Planning Depunment, Rib Mountain adopted zoning regtitations to protect its three 0 Operating standards: Help municipal water slipply wells. 77ie town regulate potentially hazardous prohibited iiidiistrial arid commercial develop- practices; ment in highly penneable areas overlying the town’s aquifer and, in less susceptible areas, Source prohibitions: Prohibit allowed limited industrial and commercial uses development or materials that based on special pemiits.1 threaten ground water; Purchase of property or develop- ment rights: Ensures control of 0rgan kat io n of Document land uses in wellhead areas; This TAD is organized as follows: Public education: Builds support . for ground-water protection Section 2 (Identifying Local Needs) highlights activities; several issues localities may want to
Load more

Recommended publications
  • Wellhead Protection Manual.Pmd
    Wellhead Protection Area Management Planning Manual A Community-based Approach to the Wellhead Protection Area Management Planning Process in Nebraska Wellhead Protection Area Management Planning Manual A Community-based Approach to the Wellhead Protection Area Management Planning Process in Nebraska Adapted from United States Department of Agriculture Area-wide Planning Process and Stepping Toward Better Watershed Management in Nebraska: A Community Based Approach to the Watershed Management Planning Process © 2008. All rights reserved. Printed in the United States on recycled paper with soy-based inks Contributors Deana Barger, Nebraska Department of Environmental Quality John Chess, Lincoln-Lancaster County Health Department Dave Griffith, Natural Resource Conservation Service Denis Moore, City of Edgar, NE Ralph Pulte, Nebraska Health and Human Services Scott Sobotka, Lower Big Blue Natural Resources District Chuck Wingert, Nemaha Natural Resources District Written by Rachael Herpel, The Groundwater Foundation Edited by Deana Barger, Nebraska Department of Environmental Quality Supported by a CWA Section 319 Grant from the Nebraska Department of Environmental Quality Nonpoint Source Management Program For additional copies contact the Nebraska Department of Environmental Quality’s Water Quality Planning Unit at (402) 471-2186 or visit www.ndeq.state.ne.us. Nebraska Department of Environmental Quality 1200 “N” Street, Suite 400 PO Box 98922 Lincoln, Nebraska 68509-8922 2 Table of Contents 4 z INTRODUCTION 6 z INSTRUCTIONS 7 z COVER
    [Show full text]
  • Public Water Source Protection Area
    County of Maui Department of Water Supply What do these signs mean? Question: What is a Public Water Supply Protection Area? Answer: A Public Water Supply Protection Area is the area surrounding our public drinking water supply wells—source water. The ground beneath them contains the freshwater aquifers that feed our wells. Question: How were the Public Water Supply Protection Areas determined? Answer: To protect our drinking water wells from contamination, the areas where certain activities can contaminate the water supply were mapped. The surface and subsurface areas that contribute water to a well were delineated based on their distance from a well, direction of water flow, and times of travel. These “wellhead protection areas” were scientifically determined for all public water supply throughout Hawaii using numerical models applied specifically for this purpose. Figure 1, below, shows Zone B, 2-year, and Zone C, 10-year, wellhead protection areas (WHPA). In a 2-year zone, water and any contaminants can reach a well within 2 years’ time, and in the 10-year zone within 10 years’ time. The EPA also provides an example and information about how a WHPA works here: https://www.epa.gov/water-research/wellhead-protection-area-whpa-model DWS Source Water Protection Efforts Figure 1 Maui County Wellhead Protection Areas Question: Why is source water protection important? Answer: Many public water supply wells are located in our community where intentional or unintentional human activities can cause spills, leaks, and dumping of various chemical substances on the ground which penetrates the soil to contaminate the groundwater below.
    [Show full text]
  • Wellhead Protection
    CITY OF LACEY WELLHEAD PROTECTION CHAPTER NO. 6 WELLHEAD PROTECTION 6.1 INTRODUCTION The City of Lacey relies on multiple groundwater sources to provide a safe and reliable potable water supply for its growing community (Figure 6.1). The City is committed to protecting the environment and preventing groundwater contamination through a proactive wellhead protection program. Wellhead protection programs are required by the USEPA and the Washington State Department of Health. For a groundwater-supplied water system, required plan elements include: A discussion of the hydrogeologic characteristics of the area; A susceptibility assessment of the sources; Delineation of wellhead protection areas (WHPAs); A contaminant source inventory within defined WHPAs; A contingency plan; Notification to owners/operators of potential contamination sources; Notification to regulatory agencies and local governments of WHPA boundaries and contaminant source inventory findings; Notification to local emergency responders of WHPA boundaries, results of the susceptibility assessment and contaminant source inventory, and contingency plan, and; A spill response plan. The City began implementing its Wellhead Protection Program (WPP) in 1995. In addition to the required elements listed above, over the years the WPP has also included several additional elements including land use restrictions, review of development/redevelopment proposals, site inspections of small quantity generators, groundwater monitoring, and public education. Since the last WHP update in 2003, a number of changes within the city have been considered in this update. This chapter summarizes Lacey’s updated WPP for all the required elements listed above. Most of the technical elements of Lacey’s updated WPP are described in detail in the City of Lacey Wellhead Protection Report that is included in Appendix M of this Water System Comprehensive Plan.
    [Show full text]
  • Wellhead Protection Area Delineation Guidance
    OHIO WELLHEAD PROTECTION PROGRAM’S WELLHEAD PROTECTION AREA DELINEATION GUIDANCE OHIO ENVIRONMENTAL PROTECTION AGENCY DIVISION OF DRINKING AND GROUND WATERS 122 SOUTH FRONT STREET COLUMBUS, OHIO AUGUST, 1994 FOREWORD The Safe Drinking Water Act Amendments of 1986 mandate that each state develop a wellhead protection program to protect public water supplies that use a ground water source. Guidelines were prepared by the United States Environmental Protection Agency, recognizing that each state would develop and tailor a program to suit its own needs. The Governor of Ohio designated the Ohio Environmental Protection Agency as the lead agency for carrying out the mandates outlined in the Safe Drinking Water Act. Ohio’s Wellhead Protection Program was approved by the United States Environmental Protection Agency in May, 1992. This document has been developed to assist public water supply owner/operators and/or their consultants in delineating wellhead protection areas in accordance with the requirements outlined in Ohio’s Wellhead Protection Program. Development of this guidance document has been funded, in part, with monies from the United States Environmental Protection Agency, under Section 106 of the federal Clean Water Act. TABLE OF CONTENTS Page CHAPTER 1. INTRODUCTION TO WELLHEAD PROTECTION AREA DELINEATION ............................... 1-1 INTRODUCTION .................................................. 1-1 DELINEATING A WHP AREA ....................................... 1-2 ORGANIZATION OF GUIDANCE DOCUMENT ........................
    [Show full text]
  • Wellhead Protection Program Summaries
    Source Protection Program Summaries Source Water Assessment Program Interstate Data Gathering Grant New England and New York State New England Interstate Water Pollution Control Commission February 2001 Source Protection Program Summaries In August 1998 the New England Interstate Water Pollution Control Commission (NEIWPCC) obtained EPA funding to assist the New England and New York states with their assessments of interstate source waters. The Interstate was to accomplish this by gathering data from and coordinating information exchange among the states. Initial NEIWPCC efforts included compilation of available SWAP-related GIS coverage metadata and the development of a document summarizing and outlining state Source Water Assessment Program (SWAP) contaminant inventory and susceptibility approaches into a reference document. This document, Source Protection Program Summaries provides an overview of individual state programs, with a focus on groundwater protection by summarizing New England and New York states’ wellhead protection programs. The document is organized to facilitate an easy comparison of state programs to further regional understanding of source protection efforts. States Wellhead Protection Programs are described according to the following programmatic pieces: • regulatory design and oversight • applicability • delineation • inventory • management • contingency planning • enforcement • progress Other state program policies influencing source protection are also included. Although the focus of this document is groundwater protection, state summaries include information on watershed protection programs. Questions regarding this document should be directed to Denise Springborg at (978) 323- 7929. Connecticut Wellhead Protection Connecticut’s Wellhead Protection Program, approved by EPA in March 1990, is comprised of other state programs which have been in place for several years including: Groundwater Classification and Standards System, Water Supply Plans, and Public Health Code.
    [Show full text]
  • Town of Wayland WELLHEAD PROTECTION PLAN
    Town of Wayland WELLHEAD PROTECTION PLAN Happy Hollow Wells #1, #2 Baldwin Pond Wells #1, #2, #3 Chamberlain Well #1 Campbell Well #1 Meadowview Well #1 PWS ID Number 3315000 Wayland, Massachusetts June 2011 Wellhead Protection Committee & Bruce W. Young, Source Water Protection Specialist Mass Rural Water Association 168 Main Street Northfield, MA 01360 for: Wayland Board of Public Works Revision History: draft June 2011 WPC Submitted to the BoPW V1.0 January 2012 BoPW Created MS Word from PDF, initial edits Page 2 v1.00 - 01/03/2012 TABLE OF CONTENTS ACKNOWLEDGEMENTS ....................................................................................... 5 WELLHEAD PROTECTION COMMITTEE (WPC) .............................................. 6 INTRODUCTION ..................................................................................................... 7 BACKGROUND ....................................................................................................... 7 PURPOSES – WELLHEAD PROTECTION PLANS ............................................ 10 SOURCE WATER PROTECTION IN WAYLAND .............................................. 14 TOWN OF WAYLAND WATER SYSTEM .......................................................... 17 POTENTIAL SOURCES OF CONTAMINATION (PSOCs) ................................ 23 HAPPY HOLLOW WELLS #1 AND #2 ................................................................ 26 CONTAMINATION RISK ................................................................................. 26 SYSTEM DESCRIPTION ..................................................................................
    [Show full text]
  • State of Texas Source Water Assessment and Protection Program
    February 1999 STATE OF TEXAS SOURCE WATER ASSESSMENT AND PROTECTION PROGRAM STRATEGY Water Utilities Division _________________________________________________________ _ STATE OF TEXAS SOURCE WATER ASSESSMENT AND PROTECTION PROGRAM STRATEGY Prepared by The Source Water Assessment and Protection Team Public Drinking Water Section Water Utilities Division This project was funded in part by a grant from the U.S. Environmental Protection Agency, Region VI February 1999 TNRCC Robert J. Huston, Chairman R.B. “Ralph” Marquez, Commissioner John M. Baker, Commissioner Jeffrey A. Saitas, P.E., Executive Director Authorization for use or reproduction of any original material contained in this publication, i.e., not obtained from other sources, is freely granted. The Commission would appreciate acknowledgment. Texas Natural Resource Conservation Commission Post Office Box 13087 Austin, Texas 78711-3087 TABLE OF CONTENTS Section Page 1 Overview of TNRCC’s Source Water Assessment and Protection Program ............................................... 1.1 Introduction ............................................... 1.1 Purpose of Document ......................................... 1.1 Background ................................................ 1.2 Legislative Commitments ................................ 1.2 Authority ............................................ 1.3 Funding ............................................. 1.4 Past Accomplishments .................................. 1.4 2 Program Coordination and Integration ............................... 2.1
    [Show full text]
  • State Source Water Protection Report
    State Source Water Protection Report April 2013 The information compiled in this report is the result of a collaboration among EPA’s Office of Ground Water and Drinking Water, EPA Regions, the Association of State Drinking Water Administrators, and state drinking water programs. Table of Contents: I. Introduction to 2013 State Source Water Protection Report ........................................................................ 3 II. Catalog of Case Examples .......................................................................................................................... 7 ........................................................................................................................................................................ 1. Measurement and Characterization ............................................................................................................ 8 Subcategory: Targeted Source Water Protection ................................................................................. 8 MS, TN, VT Subcategory: Additional Measurement and Characterization Examples ............................................... 9 AZ, GA, MA, MT, OR 2. State Implementation Strategies .......................................................................................................... 10 CT, KS, Navajo Nation, NM 3. Partnerships, Integration, and Leveraging............................................................................................. 12 AR, CA, CO, CN, DC, IL, MO, NE, NJ, NC, ND, OR, SC, UT, WV 4. Motivating
    [Show full text]
  • Wellhead Protection Plan, Commonwealth of Virginia
    Wellhead Protection Plan Commonwealth of Virginia Department of Environmental Quality April 15, 2005 Acronyms AST Above ground Storage Tank CDBG Community Development Block Grant CFU Carbon Filtration Unit DBA Virginia Department of Business Assistance DCLS Division of Consolidated Laboratory Services DCR Virginia Department of Conservation and Recreation DEQ Virginia Department of Environmental Quality DHCD Virginia Department of Housing and Community Development DMME Virginia Department of Mines, Minerals, and Energy DOD Department of Defense EPA United States Environmental Protection Agency EPCRA Environmental Planning and Community Right-To-Know Act FIFRA Federal Insecticide, Fungicide, and Rodenticide Act GIS Geographic Information System GSMP Generic State Management Plan LDF Land Disposal Facilities LEPC Local Emergency Planning Committees PSMP Pesticide State Management Plan RCRA Resource Conservation and Recovery Act RUCA Regulated Unit Corrective Action SARA Superfund Amendments and Reauthorization Act SDWA Safe Drinking Water Act SERC State Emergency Response Council SWAP Source Water Assessment Program SWPP Source Water Protection Plan TAC Technical and Citizens Advisory Committee, VDH UST Underground Storage Tank VDACS Virginia Department of Agriculture and Consumer Services VDEM Virginia Department of Emergency Management VDH Virginia Department of Health VERC Virginia Emergency Response Council VPI&SU Virginia Polytechnic and State University VRP Voluntary Remediation Program WAC Waterworks Advisory Committee, VDH WHPP
    [Show full text]
  • Wellhead Protection Areas: Protecting Drinking Water 331-634 • 7/31/2018
    Source Water Protection Wellhead Protection Areas: Protecting Drinking Water 331-634 • 7/31/2018 Wells in Washington State Groundwater provides drinking water for about 65 percent of Washington’s residents—in some counties it approaches 100 percent. Because groundwater can be vulnerable to contamination, public water systems must take preventative measures to minimize the possibility that land uses will contaminate the groundwater below. What are threats facing wells? There are a number of threats to wells, including: Improperly disposed of chemicals. Animal wastes. Pesticides. Human threats. Wastes injected underground. Naturally-occurring substances. (Source: Safe Drinking Water Act.) Serious health effects from drinking water contamination have been verified and documented. Cancer. Liver, kidney, and nerve problems. Birth defects and learning disabilities in children. (Source: Arizona Department of Health.) What are the costs of contamination? Put simply, contamination is very expensive. It is considerably On average, cleanup of more cost-effective to implement a proactive pollution prevention program to guard against groundwater contaminated groundwater contamination rather than clean up contamination. Costs for a supplies may be 30 to 40 times water system with a contaminated source can include purchase more costly than prevention. of water while locating an alternate supply, hydrogeologic (Source: EPA.) studies to locate alternate source water, and remediation costs. What are wellhead protection areas? A wellhead protection area (WHPA) is defined as the surface and subsurface area surrounding a well or wellfield that contaminants are likely to pass through and eventually reach the well(s). Most of the land in any WHPA is not owned or managed by the utility so emphazing good stewardship and local regulations is important to protect the souce and those who drink those who drink that well water.
    [Show full text]
  • Wellhead Protection Program Guidance Document
    June 2010 DOH 331-018 (Revised) Washington State Wellhead Protection Program Guidance Document June 2010 For more information or additional copies of this publication contact: Constituent Services Section Office of Drinking Water Department of Health PO Box 47822 Olympia, WA 98504-7822 (800) 521-0323 If you need this publication in alternate format, call (800) 525-0127. For TTY/TDD, call (800) 833-6388. Acronyms and Abbreviations BMPs Best Management Practices CARA Critical Aquifer Recharge Area CCWF Centennial Clean Water Fund CFR Calculated Fixed Radius COM Washington State Department of Commerce CWSRF Clean Water State Revolving Fund DOH Washington State Department of Health Ecology Washington State Department of Ecology EPA U.S. Environmental Protection Agency ESA Environmentally sensitive area GMA Growth Management Act GWI Groundwater under the direct influence of surface water GWMA Groundwater management area IGWC Interagency Groundwater Committee LEPC Local Emergency Planning Committee LHJ Local health jurisdiction MCL Maximum contaminant level NRCS Natural Resources Conservation Service ODW Department of Health Office of Drinking Water OTA Office of Technology Assessment PWS Public water system RCRA Resource Conservation and Recovery Act RCW Revised Code of Washington SAL State Advisory Level SARA Title III Superfund Act Reauthorization Amendments SDWA Safe Drinking Water Act SEPA State Environmental Policy Act SOC Synthetic organic compound SOP Standard operating procedures SSA Sole Source Aquifer TOT Time of travel UIC Underground
    [Show full text]
  • The Benefits of Wellhead Protection to Your Community
    The Benefits of Wellhead Protection to Your Community Minnesota Rural Water Association Conference March 4, 2014 Christopher E. Parthun MDH Principal Planner Bemidji District Office Minnesota Department of Health Acronyms • MDH – Minnesota Department of Health • MRWA – Minnesota Rural Water Association • WHPA – Wellhead Protection Area • PWS – Public Water Supply • WHPP – Wellhead Protection Plan • DWSMA – Drinking Water Supply Management Area Wellhead Protection Program • Authorized by the MN Groundwater Protection Act (M.S. 103I, Section 3, subd.5), passed in 1989. • Applies to public water supply wells. • Program is a non-voluntary requirement per MN Rules, Chapter 4720 • Program’s intent is to prevent human-caused contaminants from entering PWS wells by implementing wellhead protection. Wellhead Protection Wellhead protection is a method of preventing contamination of a public water supply well by effectively managing potential contamination sources in the area that contributes water to a public water supply well. Wellhead Protection Goals • Protect users of public water wells from short-term (acute) and long-term (chronic) health effects related to disease organisms and chemical contaminants. • Reduce the reliance of public water supplies on costly treatment facilities. • Avoid having to drill new wells as the result of contamination of the current well. • Avoid the need to remediate contaminated groundwater. 2013 MN Statutes 103I.005 Subd. 24. Wellhead protection area: "Wellhead protection area" means the surface and subsurface area surrounding a well or well field that supplies a public water system, through which contaminants are likely to move toward and reach the well or well field. Public Water Supply Well A public water system well provides drinking water for human use to: - 15 or more service connections, or to - 25 or more people for at least 60 days per year.
    [Show full text]