SOLE SOURCE AQUIFER BACKGROUND STUDY:
         CROSS-PROGRAM ANALYSIS
              Office of Ground-Water Protection
                    Office of Water
            U.S. Environmental Protection Agency
                   401 M Street, S.W.
                 Washington, D.C. 20460

                    November 1987
         U.S.  Environmental Protection Agency
         Begion 5, Library (5PL-16)
         230 S. Dearborn St-eet, Boom 1*670
         Chicago, IL  60604

-------
              TABLE   OF   CONTENTS
                                                       Page
                                                      Number
TABLE OF CONTENTS                                       i

LIST OF EXHIBITS                                      iii

FOREWORD                                                v

ACKNOWLEDGEMENT                                        vi

EXECUTIVE SUMMARY                                     vii

I.        INTRODUCTION                                   1

         1.    Information Collection Methodology        4
         2.    Report Organization                       4

II.       OVERVIEW OF REGIONAL DESIGNATION PROCESS       7

         1.    Implementation Strategies                 7
         2.    Petitions                                 7
         3.    Project Reviews                           7
         4.    The Designation Process                   7

III.      CROSS-PROGRAM ANALYSIS                        12

         1.    Institutional/Policy Review              12
              (1)  Review Of SSA Petitions             13
              (2)  Review Of Regional Response         18
              (3)  Review Of The Use Of
                   Designation Criteria                20
              (4)  Review Of Projects Receiving
                   Federal Financial Assistance        21

         2.    Review of Hydrogeologic Data             23
              (1)  Level Of Technical Information      24
              (2)  Basis Of Agiiifer Boundary
                   Delineation                         26
              (3)  Aquifer Size                        37
              (4)  Lithology                           37
              (5)  Hydrologic Complexity               37
              (6)  Vulnerability to Contamination      42

-------
Summary Of Cross Program Analysis        43
(1)  Institutional/Policy
     Characteristics                     43
(2)  Hydrogeologic Characteristics       44
               11

-------
              LIST   OF   EXHIBITS
                                                       Page
Exhibit                                               Number
  1-1    List Of Sole Source Aquifers                   2

  1-2    Location Of Designated and Pending SSAs        3

  1-3    Type Of Information Reviewed And Extracted     5
         From Regional Files For Each SSA

 II-l    Petition Content Requirements Under Old
         Designation Process                            9

 I1-2    New Sole Source Aquifer Designation
         Decision Process                              11

III-l    Year Of Petition Submittal                    14

III-2    Distribution Of Petitioner Types              16

II1-3    Concerns Of Petitioners                       17

III-4    Distribution Of Regional Review Efforts       19

II1-5    Population Served By SSA                      22

III-6    Percentage Of Population Using SSA            22

III-7    Percentage Comparison Between Petitioners
         Map Scale And Associated Land Area            25

III-8    Technical Data Presented In Petitions         25

III-9a   Principal Criteria Used By Petitioners To
         Delineate SSA Boundaries                      27

III-9b   Principal Criteria Used By EPA Regions To
         Delineate SSA Boundaries                      27

111-10   Relationship Between Petitioner's Proposed
         SSA And That Approved By EPA                  28

I11-11   Metes And Bounds For The Boundary
         Delineation Of The Spokane Valley-Rathdrum
         Prairie Aquifer                               29
                             111

-------
Exhibit                                               *T
	                                               Number

111-12   Aquifer Relationships, Seven Valleys
         Aquifer, Pennsylvania                          31

II1-13   Aquifer Relationships, New Rockford
         Aquifer, North Dakota                          32

111-14   Aquifer Relationships, Biscayne
         Aquifer, Florida                               34

II1-15   Areas Included in SSA Approved or
         Recommended for Designation                    35

111-16   Aquifer Relationships, Theoretical
         Artesian System                                36

111-17   Aquifer Size                                   38

111-18   Lithology                                      38

111-19   Aquifer Complexity                             39

II1-20   Generalized Ground-Water  Flow,  Guam            40

111-21   Location and Directions of Ground-Water
         Flow At or  Near the Top of the  Zone of
         Saturation                                      41
                            IV

-------
                          FOREWORD


    This document is one in a series of documents that
summarize the designated and pending Sole Source Aquifers
(SSAs) in eight of the ten U.S. Environmental Protection
Agency (EPA) Regions.  These documents resulted from an
EPA study that assessed the status of the Sole Source
Aquifer Program.  In addition, the information obtained
from this study was used to (1) assist in the streamlining
of the SSA designation process and (2) assist in
establishing criteria for identifying critical aquifer
protection areas in response to the 1986 amendments to the
Safe Drinking Water Act (SDWA).

    Additional information on the Sole Source Aquifer
Program can be obtained from the Office of Ground-Water
Protection in Washington,  D.C., and from the ten EPA
Regions.
                             v

-------
                       ACKNOWLEDGEMENT


    This report was prepared by the Office of Ground-Water
Protection (OGWP), U.S. Environmental Protection Agency
(EPA), Washington, D.C.  Mr. William G.  Stelz of OGWP served
as the Project Manager for EPA, assisted by Mr.  Paul
Violette.  Booz, Allen & Hamilton Inc.  and Dames & Moore
under Contract No. 68-03-3304 assisted in the preparation of
this report.   EPA Regional OGWP representatives  deserve
thanks for their cooperation in the review of this document.
                             VI

-------
                       EXECUTIVE  SUMMARY
    The Sole Source Aquifer (SSA) Program was established
under Section 1424(e) of the Safe Drinking Water Act (SDWA)
of 1974.  This section authorizes the EPA Administrator to
determine that an aquifer is the "sole or principal" source
of drinking water for an area.   The program also provides
for EPA review of Federal financially assisted projects
planned for the area to determine their potential for
contaminating the aquifer.   Based on this review, no
commitment of Federal financial assistance may be made for
projects "which the Administrator determines may contaminate
such aquifer," although Federal funds may be used to modify
projects to ensure that they will not contaminate the
aquifer.

    On September 23, 1986,  EPA's Office of Drinking Water
(ODW) officially transferred its responsibilities for
administering the Sole Source Aquifer Designation Program to
the Office of Ground-Water  Protection (OGWP).   In an effort
to smooth the transition of responsibilities and help OGWP
identify ways to administer the SSA designation program
provisions efficiently, OGWP undertook this study of the SSA
designation process.

    This report represents  an historical account of the past
SSA program.  New guidance  released by EPA in February 1987,
"Sole Source Aquifer Designation Petitioner Guidance," will
be the basis of the SSA program henceforth.  As part of this
SSA Background Study, EPA has published separate Regional
reports describing the individual SSAs within each
respective Region.

    The overall objectives  of the background study were to:

         Identify SSAs that have been designated and
         petitions that are pending

         Characterize the similarities and differences
         between SSAs

         Understand what information sources and analyses
         are needed to designate an aquifer

         Collect information on the designation process and
         procedures so that EPA may develop a more
         streamlined designation process.
                             VII

-------
     To collect information on the SSA program,  a project
 team interviewed EPA Regional staff and reviewed Regional
 files on both designated and pending SSAs.   Three-person
 teams consisting of an EPA representative,  a senior
 policy/institutional analyst, and a senior  hydroqeoloaist
 conducted the Regional visits.

     The project  team's information gathering indicates  that
 to date,  23  aquifers have received SSA designation,  19
 others have  petitions pending designation,  and  eight
 petitions are considered to  be inactive.  The following is  a
 summary of cross-program analysis of the  institutional  and
 policy characteristics of the petitions received and the
 hydrogeologic characteristics of  the petitioned aquifers as
 determined by the  team's investigation.

 (1)  Institutional/Policy Characteristics

     EPA Regions  have received petitions rather  consistently
 over the  past 11 years,  with a  peak  in submissions  in the
 early 1980s.   Environmental  groups represent  the largest
 petition  groups, although petitions  were  submitted by local
 governments,  citizens,  and local  water suppliers as  well
 About one-half of  the  petitions were submitted  in an attempt
 to stop or affect  a  specific  project.  Landfills and
 publicly  owned treatment  works  (POTWs) were the  two  types of
 facilities most  likely to  cause petitioners to  submit SSA
 applications.  The other  half of  the petitions was submitted
 to protect ground-water  resources.

     Once  the  Regions received the petitions,  they either
 collected additional data  or  contacted the USGS  and  outside
 consultants.   To provide public participation, the Regions
 held  public hearings and  accepted written public comments.
 State and local governmental  agencies often provided written
 comments  as well.

    The Regions largely used three criteria to determine
whether an aquifer should be designated.   They were:  (1) at
 least 50 percent population dependency on ground water,   (2)
the existence of alternative water supplies, and (3) the
vulnerability to ground-water contamination.  Two-thirds of
the petitions providing such information indicated over  90
percent dependency of the population on ground water.  In
fact, almost  half of the petitioned aquifers have been
characterized as providing 100 percent of  the drinking water
supply.
                             Vlll

-------
     The second criterion,  alternative water supplies,  was
 interpreted differently by various  Regions.   Some Regions
 addressed only available,  existing  sources as
 alternatives,  while other  Regions considered undeveloped,
 potential sources  as well.   The Regions  used no formal
 approach or methodology to measure  the third criterion,
 vulnerability.   Typically,  the Region reviewed real
 hydrogeologic  characteristics  and declared the aquifer to
 be vulnerable.

     For designated SSAs, most  Federal financially assisted
 projects reviewed  by the Regions were approved without
 modification.   For a few projects,  modifications  were  made
 in order to be approved for the SSA area.

 (2)  Hydrogeologic  Characteristics

     Petitions  contained up  to  nine  different types of
 hydrogeologic  information.   Ground-water use and  pollution
 source  data were most  commonly included  in the petitions.
 Lithologic  and formation nomenclature were usually
 presented as excerpts  from  geologic  reports.   Ground-water
 flow, water table  depth, and other  hydrologic  data were
 generally not  included in the  petitions.   Taken as a
 whole,  the  petitions  alone  were not  adequate for  making a
 delineation determination.

     Petitioners and  the Regions  were  approximately equally
 likely  to use hydrogeologic  criteria  as a  basis for
 delineating SSAs.  Worth noting,  however,  is that the
 Regions  frequently revised  the  petitioners'  original
 boundaries  once more comprehensive and sophisticated
 technical information  had been  reviewed.    In many cases,
 these revisions were the result  of the Region  including
 the  recharge area  and/or streamflow source zone in the
 delineated  area.   In fact,  all delineated  SSAs  included
 the  aquifer recharge area and  70  percent included the
 streamflow  source  zone.

     In terms of size,  over two-thirds of the aquifers were
 less than 1,000 square miles while several were larger
 than 12,000 square miles.  Over half of the aquifers were
 in unconsolidated deposits.  Most aquifers behaved as
 single hydrologic units (i.e.,  25 of 42 aquifers or 60
percent).  The remaining 40 percent  were multilayered,
containing several definable water-bearing zones.   The
Regions in all cases treated multiple and confined aquifer
systems as  "leaky," assuming that unconfined, overlying
units would contribute pollutants to the underlying units.
                             IX

-------
    For ground-water flow characteristics, the petitioners
generally based the analysis on surface topography and
rarely used ground-water models.   The depth to ground
water was less than 30 feet in almost two-thirds of the
cases.  Shallow depths were often considered to represent
susceptibility to contamination.   The petitions often
listed pollution sources that contributed to making the
aquifers more vulnerable to contamination.

    More detailed information on individual SSAs is
available in the individual Regional reports, which are
intended to complement this cross-program analysis.
                             x

-------
                      I.   INTRODUCTION
    The Sole Source Aquifer (SSA) Program was established
under Section 1424(e) of the Safe Drinking Water Act
(SDWA) of 1974.  This section authorized the Administrator
of the Environmental Protection Agency (EPA) to determine
that an aquifer is the "sole or principal" source of
drinking water for an area.  The program also provided for
EPA review of Federal financially assisted projects
planned for the area to determine their potential for
contaminating the aquifer.  Based on this review, no
commitment of Federal financial assistance may be made for
projects "which the Administrator determines may
contaminate such aquifer," although Federal funds may be
used to modify projects to ensure that they will not
contaminate the aquifer.  As of August 1987, there have
been 23 designated SSAs nationwide; 19 remain in some
stage of review.  These SSAs are listed in Exhibit 1-1 and
depicted on a map of the U.S.  in Exhibit 1-2.

    On September 23, 1986, the Office of Drinking Water
(ODW) officially transferred its responsibilities for
administering the SSA designation program to the Office of
Ground-Water Protection (OGWP).  As an initial step in
developing its program implementation strategy, OGWP
issued guidance (Sole Source Aquifer Designation
Petitioner Guidance, February 1987, hereafter referred to
as the SSA Designation Guidance) that has streamlined the
SSA designation process.  This guidance has been designed
to ensure that the SSA designation time frame will be
consistent with the eligibility criteria of the SSA
demonstration program authorized by 1986 amendments to
SDWA.  Also, additional information and definitions with
respect to the SSA program can be obtained from this
document.

    To develop the SSA Designation Guidance and to
effectively administer the SSA program, OGWP conducted a
review of the 12-year old SSA program.  The purpose of the
review was to collect background historical information
about the SSA designation process.   This background
information consisted of both hydrogeologic data on each
designated and pending SSA and policy/administrative
information on the designation process itself.  The study
involved three separate and distinct tasks.  Task 1
included the preparation of a directory/listing of the key
documents supporting each designated or pending SSA and
the production of a map of the designated and pending
SSAs.  Task 2 involved development of a profile of each
SSA.   In addition, information gained on the SSA
                             	-] 	

-------
                                            EXHIBIT  1-1
                                    List Of Sole Source Aquifers*
               DESIGNATED
                                                    PENDING
NJ
I
 1.  Edwards Aquifer, TX
 2.  Spokane-Rathdrum Prairie, WA-ID
 3.  Northern Guam
 4.  Long Island, NY
 5.  Fresno Co.,  CA
 6.  Biscayne Aquifer, FL
 7.  Buried Valley, NJ
 8.  Maryland Piedmont, MD
 9.  Whidbey Island, WA
10.  Camano Island, WA
11.  Cape Cod, MA
12.  Ridgewood,  NJ
13.  Upper Rockaway Basin, NJ
14.  Brooklyn-Queens, NY
15.  Nantucket Island, MA
16.  Block Island, RI
17.  Upper Santa  Cruz 8.
       Avra-Altar Basin, AZ
18.  Schenectady-Niskayuna, NY
19.  Scotts.Valley, CA
20.  Clinton Street-Ballpark, NY
21.  Seven Valleys, PA
22.  Cross Valley, WA
23.  Clarke Co.,  VA
24.  Quaboag River Valley, MA
25.  New Jersey Coastal Plain, NJ
26.  State of New Jersey
27.  Cattaraugus Creek-Sardinia, NY
28.  Mt. Olive, NJ
29.  Volusia-Floridan, FL
30.  Pleasant City, OH
31.  Catawba Island, OH
32.  Delaware Basin, TX-NM
33.  Capital Area-Baton Rouge, LA
34.  WiIcox-Shreveport,  LA
35.  Edwards Aquifer-Barton
       Springs, TX
36.  New Rockford, ND
37.  Pearl Harbor-Honolulu, HI
38.  Naco-Bisbee,  AZ
39.  Snake Plain,  ID
40.  Newberg Area, WA
41.  Seven Lakes,  WA
42.  North Florence Dunal, OR
                                           INACTIVE
                                                                              South Kingstown,  RI
                                                                              North Kingstown,  RI
                                                                              Highland (Ramapo
                                                                                Valley),  NJ
                                                                              New Castle,  DE
                                                                              Oakland Co.,  MI
                                                                              Carrizo-Wilcox,
                                                                                Bastrop Co.,  TX
                                                                              DeSoto Parish,  LA
                                                                              East Helena,  MT
   *As  of  August  1987

-------
                                        As of August 1987"
              EXHIBIT 12
LOCATION OF DESIGNATED AND PENDING SSA's
      (NUMBERS REFER TO EXHIBIT 1-1)
                                                 NOT TO SCALE

-------
 designation process  supported  ongoing development  of  the
 SSA Designation  Petition Guidance.  Task 3 encompassed
 generation of this report  including the Region-by-Region
 summaries and creation of  a dBase  III data file to  access,
 compare, and manipulate data on the characteristics of
 aquifers and petition review process.  This data file may
 be accessed by EPA Regional personnel through OGWP.

 1-  Information  Collection Methodology

    On this assignment, EPA and its consultants visited
 eight of the ten EPA Regions.  These visits entailed
 interviews with  Regional staff and a review of Regional
 files on both designated and pending SSAs.   Three-person
 teams consisting of one EPA representative, one senior
 policy/institutional analyst and one senior hydrogeologist
 conducted the visits.  The teams did not visit Regions V
 and vn because of their low level of SSA petition activity,

    The teams reviewed documents that significantly
 contributed to the designation process.   The analysts used
 data from these  notes and files for further assessment of
 the process.   Exhibit 1-3 lists the types of information
 reviewed in the  Regional files.

    Typically, the teams interviewed Regional EPA staff
 using a protocol consisting of general Questions about the
 process.   The questions primarily dealt with the
 designation process,  hydrogeologic and policy issues,  the
 draft guidance on SSA designation, petition
 characteristics, and review of projects receiving Federal
 financial assistance.

 2.  Report Organization

    This  report presents the results of  the cross-program
 analysis.   It also summarizes the key characteristics  of
 all the aquifers and analyzes similarities  and differences
 among Regional programs as well as among individual
 aquifers.   Its focus  is on both the administrative and
 technical aspects of  the historical SSA designation
process.

    Published separately are eight Regional volumes that
contain data  on SSAs  in the respective Regions.   These
documents include information about the  hydrogeologic
characteristics of the SSAs and the institutional
                             -4-

-------
                  EXHIBIT 1-3

Type Of Information Reviewed And Extracted From
          Regional Files For Each SSA
      Name  and  type of petitioner

      Reason(s)  for petition  submittal

      Contents  of the petition

      Federal Register announcements  regarding
      receipt of the petition and  request for public
      comment

      Response  to Federal Register  announcements
      (i.e., written or verbal comments)

      Public hearings records

      Hydrogeologic data and  reports

      Ground-water use information

      Pollution sources and vulnerability records

      Population data

      Alternative source studies

      Existing  contamination

      Current treatment practices

      Schedule  of designation

      Memoranda of Understanding (MOU) with other
      Federal agencies

      Role  of local/State governments  in the process

      Projects  receiving Federal financial
      assistance reviewed

      Other relevant and appropriate  information.

-------
functioning of the review and designation process.   The
information describes what was in the petition,  how it was
handled by the Agency, the supplemental studies  undertaken,
and the criteria used in the Regional decision-making
process.
                             -6-

-------
         II.   OVERVIEW  OF  REGIONAL  DESIGNATION PROCESS
l.   Implementation Strategies

    Some Regions have used different approaches in
implementing the SSA Program.  These implementation
differences resulted to some extent from differences in
Regional interpretation of the SSA program regulations
proposed in September 1977, but also from differences in
Regional and State hydrogeology and regulatory
philosophies.  For example, some Regions encouraged public
hearings and workshops to increase community awareness of
possible ground-water contamination within the SSA.  In
order to address technical concerns, many Regions responded
by contracting for a more extensive hydrogeologic assessment
of the proposed aquifer(s).  The U.S. Geological Survey
(USGS) was often used in order to obtain the necessary data.

2.   Petitions

    EPA received SSA petitions from individual citizens,
environmental groups, local governments, and public water
suppliers.  The technical detail provided in each petition
was highly variable, and the Regional staff often requested
more information.

    As a rule, the petitions were submitted either to
provide for aquifer protection or as a perceived method to
inhibit the siting of an unwelcomed project.  In many cases,
the Regions faced simultaneous support and opposition to SSA
designation from the petitioners, other interested parties,
and local and State governments affected.

3.   Project Reviews

    After an aquifer is designated as an SSA, all Federal
financially assisted projects are subject to review by EPA
before final approval is granted.  To carry out this review
function, each Region signed a Memorandum of Understanding
(MOU) with Federal agencies that provide project funds.
This process allows EPA to assess the environmental impact
of  Federal financially assisted projects and to offer
modifications where necessary.  As a result of this review,
some projects have been-modified, but the SSA program has
not resulted in cancellation of any projects.

4.   The Designation Process

    Pursuant to the draft SSA regulations,  all EPA Regions
followed the same general steps in performing the review of
                             -7-

-------
 petitions  and  designation  of  SSAs.   These  steps  are  briefly
 described  below.

     Review Petition  for Adecruacv —  When a petition  was
 submitted  to a Region, the initial step was  to review  the
 contents of the petition to ascertain  its  completeness.  A
 complete_petition was expected to contain  all the
 information and maps described in the  proposed SSA
 regulations.   The petition content requirements  from these
 regulations are contained  in  Exhibit II-l.   The  Regions
 generally  did  not request  additional data  from the
 petitioner.  The Regions formally requested  the  petitioner
 to submit  more information in only six cases.

     Acceptance of Petition — Following the  review for
 completeness and submittal of any additional requested data,
 the  Region formally accepted  the petition  and began  its
 technical  review.

     Technical  Review of Petition — The Regions  performed
 independent reviews of the petition's  data to ascertain
 whether the aquifer met the criteria for an  SSA.   These
 reviews often  involved collection of additional  data and
 review of  citations of technical documents listed in the
 petition.   In  many cases,  the Regions  contracted with the
 USGS to perform additional studies of  the  aquifer.  The
 collected  information served  as the basis  for the findings
 of the Region.

    Public Comments and Hearings — The Regions published
 Federal Register notices indicating receipt of the petition,
 specifying the time and location of any public hearings, and
 requesting public comments.

    Findings and Designation Determination — The data in
 the petition,   subsequent studies,  and  information developed
 in the comments provided the basis for the Regional
 designation decision.  The data were evaluated in terms of
 the criteria listed In the proposed regulations.

    Submittal   of Action Memorandum to EPA Headquarters —
 The Regions submitted an action memorandum to EPA
 Headquarters explaining their  findings and providing a
 recommendation on the designation decision.  The  details in
 the action memorandum varied according to the specific
 nature of each SSA.

    Designation Time Frame —  In general,  the rime frame for
 this designation process varied depending on local needs,
 hydrogeologic   factors,  and administrative constraints.   In
many cases, the designation time directly reflected the
 level of technical  detail required by the Regional staff.
                              -8-

-------
                         EXHIBIT II-l

                Petition Content Requirements
                Under Old Designation Process
    Per the Proposed Regulations (42 FR 51620,  September 29,
1977),  Section 148.10,  Petition Submission Requirements:

(a)  Name,  address,  and telephone number of the  petitioner

(b)  Statement of the requesting person's interest in the
    Administrator's determination

(c)  Statement of why contamination would result in a
    significant hazard to public health

(d)  All pertinent information regarding

    (1)  The aquifer and its location

    (2)  The location of the aquifer area the petitioner
         alleges is the sole or principal source of drinking
         water

    (3)  The population in the area described in (2)

    (4)  Alternative sources of drinking water  for the area

    (5)  The recharge and streamflow source zone(s) for the
         aquifer

    (6)  The sources of recharge to the aquifer and their
         location

    (7)  Projects which might contaminate the aquifer
         through the recharge zone

    (8)  The public water systems utilizing water from the
         aquifer, the number of people served by each
         system, and the water treatment provided by each
         system

(e)  Maps showing, to the best of the petitioner's knowledge

    (I)  The location and boundaries of the aquifer

    (2)  The location and boundaries of the recharge zone(s)

    (3)  The location of the source(s) of recharge to the
         aquifer
                             -9-

-------
The SSA Designation Guidance released by OGWP has
established a uniform time frame for designation as well as
established a new process.  (See Exhibit II-2.)
                            -10-

-------
                                                                            EXHIBIT 11-2

                                                   NEW SOLE SOURCE AQUIFER DESIGNATION DECISION PROCESS
   L PHE-SUBMBSION ACTIVITIES
                                                                                                                                    IV. DESIGNATION DETERMMATION
 PETITIONER
     H. INITIAL REVIEW/
COMPLETENESS DETERMINATION
                                                                                       ML DETAILED REVEMOTECHNICAL VERIFICATION
   EPA
TMIEFRAME
                   V
               HOBTMUWEO
                                                                   v	
                                                                 til DM1

-------
                  III.  CROSS-PROGRAM ANALYSIS


     A major objective of this report was to summarize the
 SSA designation process based upon data reviewed during
 visits to eight EPA Regions and discussions with Regional
 personnel.   This chapter presents that summary in two parts:

          Review of the institutional/policy characteristics
          of the SSA program

          Review of the hydrogeologic characteristics of the
          aguifers.

 Information collected on all  aguifers that are either
 designated  (i.e.,  23 SSAs)  or pending designation (i e   19
 petitions currently under consideration)  formed the basis
 for these analyses.

     Petitions  withdrawn from  the  process  by the petitioner
 or  not  considered  by the Region typically had  insufficient
 information for  the purposes  of this cross-program
 analysis.   Generally,  no information was  collected  from the
 States,  petitioners  or other  sources not  in the Regional
 files.

 1•   Institutional/Policy Review

     The  institutional/policy  review  addressed  four  topics:

          Petition and  petitioner  characteristics

          Regional response to petitions

         Use of designation criteria

         Review of projects receiving Federal  financial
          assistance.

     In reviewing petitions and petitioner characteristics
three areas were assessed:  the type of petitioner, the
reason for the petitioner's actions,  and the content of the
petition.  This also included looking at trends in who
submitted the petition and why.

    Review of the Regional response to receipt of a petition
consisted of an evaluation of how the Region acted on a
petition, including the reliance upon the petitioner's data
and the extent of independent Regional data collection and
analysis.  The role of the USGS in providing additional
information  was specifically noted.
                             -12-

-------
    Review of the Region's use of designation criteria was
based on the criteria contained in the regulations EPA
proposed for the SSA designation process (42 FR 51620) on
September 29, 1977.  The five criteria proposed for SSA
designation were:

         Availability of alternative sources of drinking
         water

         Size of the area and population served by the
         aquifer

         Susceptibility of the aquifer to contamination
         through the recharge zone (i.e., vulnerability)

         Location of the aquifer

         Number of public water systems utilizing water from
         the aquifer, the number of people served by such
         systems, and the treatment provided by such systems.

The review documented which criteria the Regions used in
their decision-making and how these criteria were addressed
by both the petition and each respective Region.

    Finally, a review was performed of the effectiveness of
the project reviews following designation.   Because only a
few Regions had discrete records of the results of these
reviews, the analyses are general in nature with few
specific examples of Regional activity.

(1) Review Of SSA Petitions

    Review of the petitions revealed information that may be
divided into three distinct areas:   the year of petition
submittal, the types of petitioners,  and the rationale for
petition submittal.

    Petition Submittal Date — Petitions were submitted to
the EPA Regions rather consistently over the past 12 years.
Exhibit III-l breaks out the years  of submittal of petitions
since 1975.  There was no obvious reason for the peaking of
submittals in the early 1980s.

    Several possible explanations include:

         Increased public and regional awareness of the
         process

         Belief that the resulting  designation can provide
         protection of ground-water resources

         General increasing concern for ground-water
         protection aside from the  SSA process.

                             -13-

-------
                              EXHIBIT 111-1
                      YEAR OF PETITION SUBMITTAL
16-f
      75-77
78-79
'81-'83
'84-Present
                                 Year
                                 -14-

-------
    Type of Petitioner — A total of 45 original petitioners
were identified.  The term original petitioners was used
because in many cases additional petitioners submitted
documents in support of the original submission and declared
themselves to be petitioners.  For the most part, these
additional petitioners were national environmental groups
and local officials.

    As Exhibit II1-2 indicates, environmental groups, both
local and national, comprised the largest petitioner group
(40 percent).  These petitioners often sought to protect a
local source of drinking water from a variety of general or
specific threats.  The next largest group, local
governments, represented about one-third of the
petitioners.  These local governments also demonstrated
concern about the preservation of local area ground-water
resources.  Almost 20 percent of the petitioners were
individual citizens, many of whom were concerned about a
local project or development that might affect their
drinking water.  The smallest group was the local water
suppliers (nine percent), who realized that contamination of
the ground water could represent considerable costs to them.

    Concerns of Petitioners — In about half the cases, the
petitioners identified aquifer protection as their principal
concern.  In the remainder, the petitioners were attempting
to stop or influence a specific project through the aquifer
designation process.  Exhibit III-3 shows that 20 petitions
could be identified as attempts to stop or influence a
specific project.  This was determined through the petition
information itself or petitioner correspondence with the
Region.  Such projects included landfills, publicly owned
treatment works (POTWs), pipelines, and government
installations.   In fact, the first SSA designation petition
(the Edwards Aquifer) was submitted in response to
environmental concerns about the effects of two housing
projects on recharge to the ground-water supply in the San
Antonio, Texas, area.  Landfills triggered more petitions
than any other specific project.  In Region X alone county
landfill planning was responsible for three different
petitions.

    Half the petitions identified overall improvement or
protection of ground-water resources as their principal
concern.  These petitions usually cited previous examples of
ground-water contamination that forced treatment or the
closing of wells.   The petitioner typically stated that it
would be nearly impossible to provide large populations with
alternative water supplies if the ground water were to
become contaminated; however,  socioeconomic analyses which
would asses the impact of alternative water supplies were
generally lacking in the petitions.
                             -15-

-------
           EXHIBIT 111-2
DISTRIBUTION OF PETITIONER TYPES
Environ. Groups
    40%
              -16-

-------
                                        EXHIBIT 111-3
                              CONCERNS OF PETITIONERS
                             Housing Development

                 Water Project (CoE)
Nuclear Waste Repository (DOE)
       Sewer Pipes
                                                 Landfill (Hazardous and Solid Waste)
                                  POTW (Siting and Waste Disposal)
                                            -17-

-------
(2) Review Of Regional Response

    The Regions normally accepted SSA petitions when they
were first submitted.  In fact, Regions have returned only
six petitions to the original petitioner, requesting further
information before accepting them.  In a number of cases,
the Regions requested additional data.  The petitioner
submitted the data as an addendum to the petition without
having to resubmit the entire petition.

    Petition Completeness — Many petitions were incomplete
upon submission.  In many cases, the petitions lacked basic
information on population served by the aquifer and on
alternative sources of drinking water.  The petitions often
contained inadequate technical documentation to describe the
boundaries of the aquifer, the aquifer service area, or the
recharge area and streamflow source zone.

    The type of petitioner was not indicative of the kind
and amount of data provided.  Petitions submitted by
citizens groups were as likely to be as complete as those
prepared by local governments or water suppliers.  The
Biscayne aquifer petition, which was submitted by a group of
citizens, was complete in the information provided.
Petitions submitted by local governments varied in quality.
The Guam petition, submitted by the Governor, was complete,
while a petition from four local governments in
Massachusetts lacked important information.

    The completeness of the petition seemed to be dependent
on the available resources.   Where extensive hydrogeologic
investigations already had been completed by either the USGS
or a State agency, the petitions contained substantial
technical data.  The extent of local public support also
appeared to affect the completeness of the petitions.
Petitions submitted by well-supported local groups generally
were the best petitions in terms of the depth and breadth of
information provided.

    Technical Review — Once the petition was accepted, the
Regions took a variety of steps in performing the technical
review of the documents.   These generally fell into several
identifiable categories,  as shown in Exhibit II1-4. •

    In about one-third of the cases, the Regions asked the
USGS to perform a study of the hydrogeologic conditions of
the aquifer.  In the mid-1970s, the EPA and USGS negotiated
a Memorandum of Understanding (MOU) that funded USGS
hydrogeologic studies of  12 aquifers.   Several of the
Regions used this MOU mechanism to provide supplementary
technical documentation.   Although thorough, USGS studies
typically took a year or  more to complete.  For this reason,
some Regions chose to do  their own technical documentation.
                             -18-

-------
                EXHIBIT 111-4
DISTRIBUTION OF REGIONAL REVIEW EFFORTS
                         USGS After Receipt 34%
Private Contractor 21°/c
                 Existing USGS 27%
                   -19-

-------
     In about one-quarter of the cases,  a USGS study had
 already been completed in the area and  was included in the
 petition as a reference or direct citation.   Such was the
 case with the Edwards Aquifer,  where technical studies had
 been performed for several years prior  to petition
 submission.   The petitions for  several  aquifers,  most
 notably Cape Cod,  were submitted on the basis of  the data
 and conclusions provided in an  existing USGS  study.

     In about 20 percent of the  cases, the Regions used
 outside consultants'  studies as the basis for their
 technical review.   This was often the petitioner's
 contractor and funding was provided by  the petitioner.

     For the  remaining 18 percent of the petitions,  the
 Regions performed  an  in-house review of the petitioner's
 data without outside  support.   In most  cases  this resulted
 in  the development of a technical support document.   In
 every case,  it resulted in an independent assessment  of the
 petition's data and an evaluation based on the designation
 criteria.                                          ^

     Public Comments And Hearings  — A final aspect of  the
 Regional  response  to  petitions  involved public  participation
 in  the decision-making process  through  public  comments  and
 hearings.  In  every case,  the Regions published notice  of
 the  receipt  of  a petition  and invited public  comment  on the
 proposed  designation.   Depending  on the  public  interest
 expressed  or adverse  comments received,   the Regions held  one
 or more public  hearings  in  or near  the  designated  area
 specified  in the petition.   In  this  way,  the Regions hoped
 to  achieve maximum public  involvement in  the designation
 process.

    The public  comment period is  also the point at which
 State  and  local government  agencies  often voice their
 support or opposition  to the proposed designation.  Strong
 opposition has  generally delayed the designation process.

 (3)  Review Of The Use Of Designation Criteria

    The 1977 proposed  regulations identified criteria for
making a determination with respect to SSA designation.  The
Regions, for the most part, used three of these criteria to
determine whether an aquifer should be designated:

         Percent of population dependent upon the proposed
         aquifer for drinking water

         The existence of alternative water supplies

         The vulnerability of the ground water to
         contamination.
                             -20-

-------
    Population Dependency — Exhibit II1-5 shows the large
range and distribution of populations served by the aquifer
in the designated SSA areas.  As shown, the range extends
from less than 1,000 persons to well over several million
persons.  The distribution approximates a bell-shaped curve
with the mean in the range of 10,000 to 100,000 people.

    In contrast, the distribution of the percentage of the
population dependent on the aquifers is skewed markedly.   Of
27 aquifers for which population data were available,
two-thirds were more than 90 percent dependent on the
aquifer for drinking water (see Exhibit III-6).  In fact,
most of these aquifers were characterized as providing 100
percent of the drinking water supply.  These included a
number of islands that depend entirely on ground water for
drinking water.

    Alternative Water Supplies — A second, related
criterion the Regions considered in making designation
determinations was the existence of alternative sources of
drinking water.  In some instances, Regional staff performed
capacity calculations under drought conditions to determine
the ability of the alternative to meet the demand.  These
studies were only capacity based; no Region performed formal
economic feasibility studies of potential alternative water
supplies.

    Those Regions that did not attempt a capacity study
considered only existing ground-water supply systems as
feasible alternatives.  As a rule, development of nearby
streams, lakes, or aquifers as viable alternatives to the
proposed aquifer was not considered.

    Vulnerability of Ground Water — The Regions used no
formal mechanism or approach for measuring vulnerability.  A
review of the site's hydrogeologic characteristics based on
conventional vulnerability concepts produced recommenda-
tions.  Many petitions cited well contamination as proof of
vulnerability.  The State of Louisiana  however, developed a
"Quantitative Pollution Index" under a Section 208 grant to
study the Capital Area Aquifer.  The State mapped geology,
land use, soils, and risk levels, and used these to develop
a measure of vulnerability related to recharge and
permeability.  No real use has yet been made of findings
other than to raise concern over the high levels of risk in
the study area.

(4) Review Of Projects Receiving Federal Financial
    Assistance

    Under the Safe Drinking Water Act, aquifer designation
requires the Regions to review all Federal financially
assisted projects within the designated area.  Such projects
                             -21-

-------
                                 EXHIBIT 111-5
                            Population Served by SSA
Number
of SSAs  6 -I
             <1K      1K-10K    10K-100K  100K-500K  500K-1M

                                 POPULATION
                                 EXHIBIT 111-6
                        Percentage of Population Using SSA
        20
Number
of SSAs  10
         0 -
          50%
                                                            18
60%        70%        80%        90%

     PERCENTAGE OF DEPENDENCY
100%
                                    -22-

-------
included new housing developments financed through Federal
mortgage instruments, Federal highway system modifications
and additions, funds for improvements on POTWs, airport
renovations, and economic development grants, among others.
Direct Federal actions, such as DoD activities, did not
require a review.  In order to be informed of such projects,
each Region signed an MOU with each Federal agency that
provides project funds.  Almost all Regions have MOUs with
the Farmers Home Administration (FmHA), the Federal Highway
Administration (FHA), the Veterans Administration (VA), and
the Federal Aviation Administration (FAA).   In all, there
are 11 Federal Administrations or Departments that have
signed MOUs with EPA Regions.

    The information on project reviews indicated that over
90 percent of the projects reviewed were preliminary reviews
followed by an in-depth review if necessary.  Community
Development Block Grants and Federal mortgages to housing
developers were typical of this kind of project.  For
example, on Long Island, between 1978 and 1981, 127 projects
were cited as requiring review.  Initial screening indicated
only 12 of the projects needed an analysis to determine if
they affected the SSA.  The types of projects that most
often required review were airport modifications, large
housing developments proposing to use septic systems instead
of an available sewer system, and highway construction.

    Most projects that were subjected to a review of
possible environment impact were approved without
modification.  No project was ever cancelled or stopped as a
result of an SSA impact review.  However, there were
projects that required modifications:

         Regions I and II both required several proposed
         housing developments to connect to the available
         sewer system or lose their Federal funds.

         A Region II analysis required a Federal highway
         route to be changed.  Region IV required design
         modifications for highway interchanges due to
         possible effect on the SSA.

         Region I required the removal of on-site hazardous
         wastes and old underground storage tanks at an
         airport.  FAA funds could not be used in the
         cleanup effort.

2.   Review Of Hydrogeologic Data

    Hydrogeologic information was necessary to define the
spatial limits and the vulnerability of SSAs.   The technical
                             -23-

-------
hydrogeologic information included in each accepted petition
varied with petition, but as the SSA program matured, each
Region required similar kinds of information.  This section
examines the hydrogeologic features of SSA petitions as
defined by the:

         level of technical information
         basis of aquifer boundary delineation
         aquifer size
         lithology
         hydrologic complexity
         vulnerability to contamination.

(1) Level Of Technical Information

    SSA petitions usually provided limited technical
information.  In most cases, the petitions contained
excerpts from or references to published technical reports
developed by the USGS, State agencies, water companies, or
universities.  There were, however, exceptions.  For
example, Guam provided a well-organized,  technically
complete petition that required little additional technical
support.

    In most cases, the petitioners used maps to define the
spatial limits of the proposed aquifers.   These maps
commonly consisted of topographic or geologic maps that had
been enlarged or reduced to fit on an 8-1/2 x 11-inch piece
of paper.  In general, petitioners requesting protection for
larger areas were more likely to submit small-scale maps,
while those wishing to protect smaller areas more frequently
submitted medium-scale maps.  For 15 percent of the
petitions no map was provided that depicted the designated
area.  Map scale information is summarized in Exhibit III-7.

    Nine different types of hydrogeologic information
commonly included in the petitions were identified.  Exhibit
II1-8 presents the frequency of occurrence of these data in
the petitions.  This exhibit indicates the availability of
information rather than its quality or adequacy.

    In general, the common concern among petitioners was the
degradation of ground water.  Exhibit II1-8 indicates that
ground-water use and pollution source data were most
commonly included in the petitions.  The ground-water use
information generally considered population usage estimates
and lists of public water supplies or annual yields.  In
most cases, the proposed development project was presented
as the primary source of contamination even though it may
not have been constructed yet.

    Lithologic and formation nomenclature were presented
most frequently in excerpts from geologic reports.
                             -24-

-------
                         EXHIBIT III-7

     Percentage Comparison Between Petitioners' Map Scale
                   And Associated Land Area
    Land
Area Size (mi scr. )

0-50
50-100
100-1,000
1,000-10,000
10,000+
                      Map Scale (1 inch equals)
                          Large           Medium
                        (0 - .38 mi)    ( .39 - 3.9  mi)
10%

20%
70%
                                           33%
                                           13%
                                           47%
                                            7%
                                                        Small
                                                         (4.0+)
                                                         100%*
*1 site only.
                            EXHIBIT III-8

                Technical Data Presented In Petitions
..  ,     ,
Hydrogeologic Data

Ground-Water Use
Pollution Sources
Lithology
Vulnerability
SW/GW Relationships
Ground-Water Quality
Ground-Water Flow
Water Table Depths
Hydrologic Data
                                         Occurrence  in  Petition
                                         _______  by  Percentage

                                                     90%
                                                     59%
                                                     56%

                                                     24%

                                                     15%
                            -25-

-------
Generally, no attempt was made by the petitioner to describe
or characterize the physical properties of the geological
environment.

    SSA petitions generally did not include ground-water
flow, water table, and other hydrologic data.  Most
hydrologic assessments discussed ground-water/surface-water
relationships such as whether streams were gaining or
losing.  Water quality was generally referred to as being
"good." Discussions of specific parameters were rare.

    For the most part, the extent of technical information
presented by petitioners did not provide sufficient basis
for a determination.  Many petitioners did not supply maps
or inadequately defined the boundaries of the proposed SSA.
Data that were submitted generally did not define the
specific hydrogeologic conditions that exist and the Regions
often requested the petitioners to submit more data.  In
addition, the Regions at times developed their own
supplementary data bases to define the boundaries when
necessary.

(2) Basis Of Aquifer Boundary Delineation

    Where the original petitions employed maps to delineate
the SSA boundaries, these boundaries were determined by any
of a number of hydrologic, lithologic, and political/
cultural features.  In some cases, a combination of features
was used to define the aquifers.  Exhibit III-9a displays
the principal delineation criteria used by petitioners and
the associated numbers of petitions.  Exhibit III-9b in
contrast presents the principal delineation criteria that
EPA Regions used for the same set of aquifers.

    Comparing Exhibits III-9a and III-9b indicates that both
petitioners and the Regions were most likely to use
hydrologic criteria to delineate SSA boundaries.   Although
petitioners and Regions relied on hydrologic features
approximately equally often, it is important to note that
for around 50 percent of petitions received, EPA
subsequently revised the SSA boundaries proposed by
petitioners.   The frequency of these revisions is due to EPA
often modifying or expanding the proposed boundaries based
on more extensive information collected in the review
process or through public hearings.   An example of an EPA
boundary modification is given in Exhibit .111-10.

    Though the Regions did not completely define any areas
by political  and cultural features,  they did use metes and
bounds as a legal accommodation to define SSA boundaries.
Exhibit III-ll is the first of nine pages listing turning
points that enclose the Spokane Valley-Rathdrum Prairie
                             -26-

-------
                        EXHIBIT III-9a

           Principal Criteria Used by Petitioners to
                   Delineate SSA Boundaries
                        Number of
Criteria                Petitions           % of Total

Hydrologic                     24                   60
Political/Cultural              4                   10
Lithologic                      3                    7.5
Combinations                    8                   20
Not Determined                  1                    2.5
                   Total       40           Total  100%
                        EXHIBIT III-9b

           Principal  Criteria  Used by EPA Regions  to
                   Delineate SSA Boundaries
                        Number of
Criteria                Petitions           % of Total

Hydrologic                     23                   57.5
Political/Cultural              2                    5
Lithologic                      2                    5
Combinations                   10                   25
Not Determined                  3                    7.5
                   Total       40           Total  100%
                             -27-

-------
                                                    CROSS VALLEY AQUIFER
                                               Snohomish/King Counties, Washington
  PETITIONER'S
PROPOSED AREA  •
                                                                            ii
                            EPA PROPOSED
                               AREA
                                  EXHIBIT HMO
                       RELATIONSHIP BETWEEN PETITIONER'S
                     PROPOSED SSA AND THAT APPROVED BY EPA
                                 -28-

-------
    Beginning at the mouth  of the Little  Spokane
    River in Section 32,  T.27N.,  R.42E.W.M.  and fol-
    lowing the channel  of the Little Spokane River
    upstream to the mouth of  Oeadman Creek  in Sec-
    tion 33, T.27N., R.43E.W.M.;  thence up  the chan-
    nel of Oeadman Creek  to the section line between
    Sections 2 and 3, T.26N., R.43E.W.M.; thence
    south along the section line to the northeast
    corner Section 22.  T.26N., R.43E.W.N.;  thence
    east % mile along the north line of Section  23
    to the northeast corner of the NVfc NWH Section
    23. T.26N., R.43E.W.M.; thence south  % mile  to
    the southeast corner of the NVfc NWH Section  23,
    T.26N., R.43E.H.M.; thence east about 3/4 mile
    to the section  line between Sections  23 and  24,
    T.26N., R.43E.H.M.; thence south % mile along
    the section line to the west quarter corner Sec-
    tion 24; thence east about 1% miles to the
    northeast corner NWH SW\ Section 19,  T.26N.,
    R.44E.W.M.; thence south about 3/4 mile to the
    southeast corner Mfc NVfc Section 30,  T.26N.,
    R.44E.W.H.; thence east about 1% miles to the
    southwest corner NE% NE% Section 29, T.26N.,
    R.44E.W.M.; thence south % mile to the southwest
    corner  SEH  NE%  of Section 29; thence east about
    3/4 mile to the center of Section 28, T.26N.,
    R.44E.U.M.; thence north % mile to the north
    quarter corner  Section 28; thence east about  2%
    miles  to the  northeast corner Section 26, T.26N.,
    R.44E.U.M.; thence south % mile to the east
    quarter corner  Section 26; thence east  1  mile .to
    the  east quarter comer  Section 25,  T.26N.,
    R.44E.W.M.; thence in  a  northeasterly direction
     to the north  quarter corner  Section  30,  T.26N.,
    R.45E.W.H.; thence north about  1% miles  to the
    center of  Section  18,  T.26N., R.45E.H.M.; thence
     in a north-northeasterly direction about  4 mile
     to the northwest corner  NE%  NE% Section  18;
     thence north  1  mile  to the northwest corner  N0»
     HP* Section 7,  T.26N., R.45E.W.M.; thence west h
    mile to the south quarter  corner Section  6,
     T.26N., R.45E.W.M.;  thence north  1 mile  to the
     north quarter corner Section 6; thence  east  k
    mile to the southwest  corner SPj SP» Section 31,
     T.27N., R.45E.W.M.;  thence north 2 miles  to  the
     northwest  corner, NE%  XEH  Section  30, T.27N.,
                    EXHIBIT IIM1

 METES AND BOUNDS FOR THE BOUNDARY DELINEATION
OF THE SPOKANE VALLEY - RATHDRUM PRAIRIE AQUIFER
                      -29-

-------
Aquifer.  Similar approaches were used for several other
aquifers, including the Biscayne Aquifer in Florida and the
Cross Valley Aquifer in the State of Washington.

    Topographic divides were often used to define the areas
where recharge and surface water flow were directly related
to ground water in the area of concern.  In some cases,
abrupt changes in water quality were also used for
definition purposes.

    As mentioned above, many SSA boundaries were formed by
both hydrological and political/cultural criteria.  For
example, the SSA boundaries of the New Castle, Delaware,
Aquifer were extended by the Region to the Maryland-Delaware
State line.   Conversely, many of the potential areas based
on solely political/cultural features were modified by the
Regions to conform to hydrological criteria.

    Hydrogeologic Considerations in Boundary Delineations —
Three major areas were considered in the delineation of an
SSA:   the aquifer, its recharge area, and its streamflow
source zone.  The relationships among these areas must be
understood in order to delineate an SSA properly.

    An aquifer is defined as a geologic formation, a group
of formations or a part of a formation that yields water to
wells and springs.  Examples of single formation aquifers
are the Conestoga formation of the Seven Valleys Aquifer in
Pennsylvania (Exhibit 111-12), and the glacio-fluvial valley
fill deposits in the New Rockford Aquifer in North Dakota
(Exhibit 111-13).  Examples of aquifers that include many
geologic units are the limestone formations of the Edwards
Formation in Texas or the volcanic flows of the Snake River
Aquifer in Idaho.

    An aquifer recharge area was generally interpreted as
the land surface over which water infiltrates to the aquifer
or where ground water discharges to streams that flow to the
aquifer.  In some settings, the recharge area may coincide
with the aquifer.  However, in many instances, the recharge
area extends beyond the aquifer.  For example, the Seven
Valleys SSA was expanded by the Region to include the entire
ground-water basin (see Exhibit 111-12).   Here, the
Wissahicken and Marburg Formations were included in the SSA,
since they were in the recharge area of the Conestoga
formation.  Similarly, the New Rockford Aquifer is currently
undergoing further study to determine the extent to which
the till deposits recharge the underlying valley fill
deposits, which serve as the primary aquifer material.  (See
Exhibit 111-13.)
                             -30-

-------
                                               YORK 7mi.
                                                    \
      AQUIFER
      (CONESTOGA
      LIMESTONE)
                                                    STREAM FLOW
                                                    SOURCE ZONE
                                                          1-83
PENNSLYVANIA
 MARYLAND"
                        EXHIBIT 111-12

            AQUIFER RELATIONSHIPS, SEVEN VALLEYS
                   AQUIFER, PENNSYLVANIA
                         -31-

-------
  -'    ^
 »»ROil«CMEN«Y ^V—s

   i     V
                              JAMES
                               RIVER.
HEIMDAL

 AQUIFER.
1500 -
      >• 02> ra o oo; • •£, 5 *
      ^gsfegr^?.
      L°.^s^O.?^A^^
1200
                     EXHIBIT IH-13


          AQUIFER RELATIONSHIPS, NEW ROCKFORD
                AQUIFER, NORTH DAKOTA
                        -32-

-------
 It is  likely that SSA designation ultimately would include
 some of the overlying till as  its recharge area.

    A  streamflow source zone is defined as the  land area
 from which runoff contributes  to streams and lakes that
 drain  or recharge an aquifer.  Often the recharge area and
 streamflow source area coincide, but this was not always
 the case.  The most notable examples were the Biscayne
 (Exhibit 111-14), Spokane Valley-Rathdrum Prairie, and
 Edwards Aquifers.  In each case, a we11-developed surface
 water  system existed outside the SSA and transported water
 into it.  In the case of the Biscayne Aguifer,  Lake
 Okeechobee and its drainage system are connected to a
 canal  network within the aguifer.  Water recharges the
 ground water from these canals during the drier months of
 the year.  Similarly, a small  percentage of water is
 supplied to the Spokane Valley-Rathdrum Prairie Aquifer
 from a lake which lies outside the designated area.

    Regional recommendations always included the recharge
 zone as part of the SSA delineation.  Seventy percent of
 Regional recommendations also  included the streamflow
 source zone as part of the SSA (see Exhibit II1-15).  The
 streamflow source zone was generally excluded from a
 designation if it either provided low volumes of water to
 the aquifer or would produce a significantly larger
 management area.  For example, the Snake River Plain
 Aquifer would be increased from 9,600 square miles to
 36,000 square miles if the entire streamflow source zone
 were included in the SSA.

    It should also be noted that Regional designation
 recommendations for confined aquifers have always been
 extended to include the recharge zone (Exhibit  111-16).
 In addition, all Regions that  evaluated confined aquifers
 included the recharge areas in the delineated area.

    The ability to easily define an aquifer in the field
 is important to water resource planning, facility siting,
 and protection.   Thirty-five percent of the aquifers can
be easily identified by metes  and bounds, roadways,
municipal jurisdictional lines, rivers, shorelines, and
other  rather obvious, permanent features.  Thirty-eight
percent utilize such features as topographic divides and
prominent outcroppings,  which are moderately obvious.
Twenty-seven percent have boundaries that are very
difficult to determine without extensive study.   These use
quality concentration criteria, such as the "badwater
line"  of the Edwards Aquifer,  are determined through
models or are especially obscure, as in the New Rockford
Aquifer.
                             -33-

-------
                                     DAY TON A
                                      BEACH
       ST.
PETERSBURG
                                          MELBOURNE
Recharge Area
Boundary
                                                  WEST
                                                  PALM
                                                  BEACH


                                                 FT.
                                                LAUDERDALE

                                                MIAMI

                                                 SSA Boundary
                          EXHIBIT IIH 4
             AQUIFER RELATIONSHIPS, BISCAYNE AQUIFER, FLORIDA
                         -34-

-------
                       Exhibit  Ill-is

              Areas Included In SSA Approved Or
                 Recommended For Designation
                                                 Percent
UNCONFINED AQUIFERS (39)
Aquifer And Recharge                                14
Aquifer, Recharge, And Streamflow                   64

CONFINED AQUIFERS (11)
Aquifer And Recharge                                27
Aquifer, Recharge, And Streamflow                   73
                            -35-

-------
 I
OJ
CTi
 I
                                                                                 Confined Portion of Aquifer
Potentiometric Surface
                                                                                                    " "•  r f *    T  i  •   __
                                                                                                    -  i —r '-   . . _, _ .1
                                                               EXHIBIT IIH6
                                          AQUIFER RELATIONSHIPS, THEORETICAL ARTESIAN SYSTEM

-------
 (3)  Aquifer  Size

     Over  two-thirds  of the aquifers  were less  than 1,000
 square  miles.   The smallest area was Block Island,  Rhode
 Island, which  is seven square  miles.   The largest  was  the
 Delaware  Basin in Texas,  which is 12,000 square  miles.
 Exhibit 111-17 summarizes the  size of the aquifers.

 (4)  Lithology

     Exhibit  111-18 summarizes  the major  rock types  that
 exist in  the aquifers.  Over half the aquifers were in
 unconsolidated deposits.   A small percentage was in
 crystalline  rocks.

     Lithologic complexity and  the extent of confinement
 were two  factors significant in  the  delineation  of  SSAs
 and  their water-bearing characteristics.   Sixty  percent  of
 the  aquifers essentially  behaved as  a single hydrologic
 unit, even though certain zones  may  have been  more
 productive than others.   Multilayered aquifers comprised
 the  remaining  40 percent.   These aquifers generally had
 several definable water-bearing  zones  associated with  the
 specific  lithologic  units.  Exhibit  111-19  lists aquifers
 according to their hydrologic  complexity.

     Though multiple  systems contained  isolated or
 semi-isolated  water-bearing units, they  were not
 necessarily  artesian.   Only 14 percent of the  areas
 designated or  under  consideration contained artesian
 units.  In all  cases,  however, the Regions treated
 multiple  and confined  artesian systems as "leaky,"
 assuming  that  the  overlying, unconfined  units  would
 contribute pollutants  to  the "confined"  units  beneath them.

 (5)  Hydroloqic  Complexity

     Reconstruction of  ground-water flow  in SSA studies was
 not  clearly  defined, even in USGS  reports.  Often general
 cross-sectional  flow patterns were included such as  in
 Kings and Queens Counties, New Jersey Coastal  Plain
 Aquifers,  State  of New  Jersey,  or  in Guam
 (Exhibit  111-20).  In  cases where basin morphology was
 used to delineate aquifer boundaries, flow was
 characterized by surface  topography.   The best examples  of
 relatively detailed reconstruction were the New  Rockford
 and Seven Valleys Aquifers (Exhibit 111-21) where
 illustrations depicted  local flow conditions.   In the
 former case,  these directions were critical to the
 selection of which areas were included if designation was
made.
                             -37-

-------
                       EXHIBIT 111-17

                        Aquifer Size
                                           Avq. Size  (mi sq.)
Size Range (mi sg.)   Percentage               in Range

0-50                   29                      31
50 - 100                  8                      83
100 - 1,000              31                     204
1,000 - 10,000           29                   4,424
Over 10,000               3                  12,000
                       EXHIBIT 111-18

                          Lithology


Major Rock Types                        Percentage

Unconsolidated Deposits                     53
Carbonate Sedimentary Rocks                 15
Clastic Sedimentary Rocks                   12
Igneous Rocks                                5
Metamorphic Rocks                            3
Multiple Lithologic                         12
                             -38-

-------
                       EXHIBIT  111-19

                     Aquifer Complexity
Single

Cape Cod, MA
Nantucket Island, MA
Quaboag River Valley, MA
Block Island, RI
Buried Valley, NJ
Ridgewood, NJ
Mt. Olive, NJ
Upper Rockaway Basin, NJ
Seven Valleys, PA
Maryland Piedmont, MD
New Castle, DE
Biscayne Aquifer, FL
Capital Area-Baton
  Rouge, LA
Carrizo-Wilcox-
  Bastrop County, TX
Wilcox-Shreveport, LA
New Rockford, ND
Northern Guam
Scotts Valley, CA
Pearl Harbor-Honolulu, HI
Spokane-Rathdrum
  Prairie, ID-WA
Snake Plain, ID
Camano Island, WA
Whidbey Island,  WA
Cross Valley, WA
North Florence Dunal, OR
Multiple

Long Island, NY*
Brooklyn-Queens, NY
Clinton Street-Ballpark, NY
Schenectady/Niskayuna, NY
Cattaraugus Creek-Sardinia, NY
New Jersey Coastal Plain, NJ
State of New Jersey
Volusia-Floridan, FL*
Edwards Aquifer, TX*
Edwards Aquifer-Barton
  Springs, TX*
Naco-Bisbee, AZ
Upper Santa Cruz &
  Avra-Altar Basin, AZ
Fresno Co.,  CA*
Seven Lakes, WA
Newberg Area, WA
  Contains Artesian Systems.
                             -39-

-------
               Water
                                                                                            Water
                                                                                            Table
o
I
                                                  EXHIBIT 111-20

                                     GENERALIZED GROUND WATER FLOW, GUAM

-------
77'QQ'
76*45'
                                                       7 G
     Ground-water Divide

     Direction of Shallow
     Ground-water Flow
                                   - 40*00'
                                                             7 I
                                                    SSA Boundary
    Drainage to Chesepeake Bay
    Below Mouth of Susquehanna
M D.
                                                                       39*45'
                 5 Miles
                            EXHIBIT 111-21
        LOCATION AND DIRECTIONS OF GROUND-WATER FLOW AT
            OR NEAR THE TOP OF THE ZONE OF SATURATION
                           -41-

-------
     Ground-water  models  were  rarely  used  to delineate
 boundaries  or  reconstruct  ground-water  flow.   Thus  far,
 the  Seven Lakes and  Tulalip Reservation Aquifer  in
 Region X is the only case  in  which a model was used to
 define the  extent of the aquifer.  A major USGS  study had
 been conducted in the area for purposes other  than  SSA
 designation prior to petition submission.  A
 three-dimensional, finite  difference model defined  the
 aquifer  boundary  and ground-water flow  systems.  Model
 results,  when  available, have been considered by Region X
 for  delineating the  aquifer and recharge  area boundaries.

     References in the Regional files to model use in
 designating SSA boundaries also exist for the Biscayne,
 the  Volusia-Floridan,  the  Barton Springs, and the Camano
 Island Aquifers.   For instance, in the  late 1960s,  an
 electrical  analog model  was used in  the Biscayne Aquifer
 to evaluate a hydrologic relationship between canal  and
 ground-water recharge.   Since designation in 1979,  other
 model usage has been known to have occurred for  this
 aquifer,  but this  information was not in the Regional
 files.   The other  three  aquifers contained references to
 two-  and  three-dimensional, USGS finite difference  models
 by Trescott, et al.,  which defined the  hydrologic
 properties  of various  formations.   These studies were
 conducted independently  of SSA considerations.

    For most aquifers, ground-water quality was considered
 good.  Ground-water  quality data were usually general in
 content,  and summary  data were often presented in
 association with water use and ground-water pollution
 discussions.  Most file data  presented  information  on
 total dissolved solids (TDS),  iron,  sulfates,  and
 chlorides as they  related to  salt-water intrusion.

 (6) Vulnerability to  Contamination

    In 64 percent of  the aquifers  investigated, water
 tables were within approximately 30  feet of the land
 surface.   The approximate depth to the water table was
 greater than 60 feet  in 30  percent of the aquifers.   The
 remaining 6 percent have water tables that are moderately
 deep, between 30 and  60 feet.   Water  table data were
 commonly related to vulnerability  in  unconfined aquifers.
Locations with a shallow water table  depth were considered
 especially susceptible to contamination.

    In most cases, the petitions identified potential
pollution sources that were a  cause  of concern.  These
 sources were offered as evidence of  aquifer vulnerability
 and potential impact on the quality  of drinking water.
The typical petitioner's approach  was to list  a number of
                             -42-

-------
 pollution sources,  some of which may have caused
 documented water quality problems.   Normally,  such lists
 included underground storage tanks,  sanitary landfills,
 surface-water runoff,  agricultural  practices,  on-lot
 disposal, and sewage treatment plants.   Additions were
 generally related to local concerns  associated with
 specific locations,  e.g.,  salt-water intrusion,  canals,
 underground injection wells,  and oil and gas activities.
 Rarely were actual  pollution incidents  identified by name
 and location.   Only in the Maryland  Piedmont Aquifer was a
 list of specific,  Federally-supported potential
 contamination or pollution sources  identified by the
 petitioner.

 3.   Summary Of Cross-Program Analysis

     The following is a summary of the institutional and
 policy characteristics of  the petitions  received and the
 hydrogeologic  characteristics of the petitioned  aquifers.

 (1)  Institutional/Policy Characteristics

     EPA Regions  have received petitions  rather
 consistently over the  past 11 years,  with a  peak in
 submissions  in the early 1980s.   Environmental groups
 represent the  largest  petition groups, although  petitions
 were submitted by local  governments,  citizens, and  local
 water  suppliers  as well.   About  one-half of  the  petitions
 were submitted in an attempt  to  stop or  affect a specific
 project.   Landfills  and  publicly owned treatment works
 (POTWs)  were the two types of facilities most  likely to
 cause  petitioners to submit SSA  applications.  The  other
 half of  the  petitions  was  submitted  to protect
 ground-water resources.

     Once  the Regions received the petitions, they either
 collected  additional data  or  contacted the USGS  and
 outside consultants.   To provide public  participation, the
 Regions held public  hearings  and accepted written public
 comments.  State and local governmental  agencies  often
 provided written comments  as  well.

     The Regions largely used  three criteria to determine
 whether an aquifer should  be  designated.   They were:  (1)
 at least  50 percent population dependency on ground water,
 (2)  the existence of alternative water supplies,  and (3)
 the vulnerability to ground-water contamination.
Two-thirds of the petitions providing such information
 indicated over 90 percent dependency of  the population on
ground water.  In fact, almost half  of the petitioned
aquifers have been characterized as  providing 100 percent
of the drinking water supply.  The second criterion,
                             -43-

-------
 alternative water  supplies,  was  interpreted  differently by
 various  Regions.   Some  Regions addressed  only  available,
 existing sources as  alternatives, while other  Regions
 considered undeveloped,  potential sources as well.   The
 Regions  used no formal  approach  or methodology to measure
 the  third criterion, vulnerability.  Typically, the  Region
 reviewed hydrogeologic  parameters of the  aquifer and
 declared it to be  vulnerable.

     For  designated SSAs, most Federal financially assisted
 projects reviewed  by the Regions were approved without
 modification.  For a few projects, modifications were made
 in order to be approved  for  the  SSA area.

 (2)  Hydroqeoloqic  Characteristics

     Petitions contained  up to nine different types of
 hydrogeologic information.   Ground-water  use and pollution
 source data were most commonly included in the petitions.
 Lithologic  and formation nomenclature were usually
 presented as excerpts from geologic reports.   Ground-water
 flow, water table  depth, and other hydrologic  data were
 generally not included  in the petitions.  Taken as a
 whole, the  petitions alone were not adequate for making a
 delineation determination.

     Both petitioners and the Regions most often used
 hydrologic  criteria  as a basis for delineating SSAs, and
 they were approximately  likely to rely on these
 delineation criteria.  Worth noting, however,  is that the
 Regions  frequently revised the petitioners' original
 boundaries  once more comprehensive and sophisticated
 technical information had been reviewed.  In many cases,
 these revisions were the result of the Region  including
 the  recharge area  and/or streamflow source zone in the
 delineated  area.    In fact all delineated SSAs  included  the
 aquifer  recharge area and 70 percent included the
 streamflow  source  zone.

     In terms of size, over two-thirds of the aquifers were
 less than 1,000 square miles while several were larger
 than 12,000 square miles.  Over half of the aquifers were
 in unconsolidated deposits.   Most aquifers behaved as
 single hydrologic units   (i.e.,  25 of 42 aquifers or 60
percent).  The remaining 40  percent  were multilayered,
 containing  several  definable water-bearing zones.   The
Regions  in all cases treated multiple and confined aquifer
 systems  as  "leaky," assuming that unconfined, overlying
units would contribute pollutants to the underlying units.

    For ground-water flow characteristics, the petitioners
generally based the analysis on surface topography and
                             -44-

-------
rarely used ground-water models.  The depth  to  ground
water was  less  than 30 feet in almost two-thirds  of the
cases.  Shallow depths were often considered to represent
susceptibility  to  contamination.  The petitions often
listed pollution sources that contributed to making the
aquifers more vulnerable to contamination.
                             -45-

                  S. Government Printing Office : 1988 -516-002/80527

-------