spring and borehole(s), and to show chemical similarity of the water from the spring and the borehole. The similarity is necessary to show the connection, but it alone is insufficient. There must also be a demonstrated hydraulic connection between the spring and borehole.

An approach to compliance

A unified approach to FDA compliance investigations are applicable to a wide variety of spring developments and consists of documentation, continued monitoring during normal operations with associated analysis, data archiving and spring resource management.

Documentation

The purpose of documentation is to demonstrate that a spring exists and has a history of flow. Past records are often available supporting the existence of the spring. Documenting the history of a natural spring orifice is often an issue if the hole was ever destroyed or buried during development. This can also be difficult where a collection gallery or French drain was used to develop the spring. Typical sources of historic data include grant deeds (titles or ownership records of the property describing the spring), old topographic maps, geological maps, geological reports or oral histories.

In the absence of historical documentation, the spring may need to be physically inspected, which typically includes a topography survey, as well as a geological and hydrogeological surveys. The topographic relationship or geometry of a spring orifice to other springs, boreholes, surface and sub-surface geologic materials, and surface water bodies or streams can go a long way toward demonstrating the existence of a spring. Sjuch investigations can help show the hydraulic relationship of a borehole to a spring. In the worst case, the redevelopment of the spring may be needed to document the existence of the orifice.

Flow records, water quality analyses and climate information are important data needed to evaluate the source of spring water. This information is also necessary to evaluate the direct hydraulic connection between a spring

and a borehole. For purposes of FDA compliance, the quantity of flow is not as important as documenting a continuous flow for a long period. Actual historic spring flows may not be available if the spring owner did not keep flow records. Truck hauling records are helpful for a single source spring, but may be inadequate for sites with multiple producing springs.

Documentation is valuable in certifying spring facilities with local and state health agencies. As-built drawings of spring collectors, boreholes, pipelines, storage tank systems and truck loading facilities are important information to be included in a compliance report.

It's especially important to document the natural orifice of a spring during development, especially if the development will cover or obscure the orifice. Typically a collection gallery completely covers the natural orifice. Photographs and video records are important to document the existence of the natural orifice. Again, this is an issue of compliance.

Monitoring and analysis

Monitoring of springs is a key element in our compliance program. Continual monitoring of key hydraulic parameters during normal spring operations will provide information to document spring flow; and, in the case of a borehole, document a hydrolic (cont)