Subsurface
      Pollution
      Problems
        in  the
United  States
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?  U.S. ENVIRONMENTAL PROTECTION AGENCY

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   I
   '    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                     WASHINGTON, D.C.  20460
                                  v Office Of Water
                                   ,Programs Operations
     "Subsurface Pollution Problems in the United States" is
a report prepared by the now Water Quality and Non-Point
Source Control Division, Office of Water Programs
Operations, Evironmental Protection Agency.  The Water
Quality and Non-Point Source Control Division 3s responsible
for developing and recommending national policy,
regulations, and guidelines for EPA and other authorities
concerned with planning, developing, coordinating, and
administering programs to protect the nations's waters.

     This publication presents a resume'' of the problems
affecting the subsurface environment- and suggests actions
designed to alleviate these problems.  Additional copies are
available upon request from the Subsurface Pollution Control
Section at the following address:
     Water Quality and Non-Point Source Control Division
     Office of Water Programs Operations
     U. S. Environmental Protection Agency
     Washington, D. C.  20^60
           Technical Studies Report:  TS-00-72-02

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                     Introduction






Historically ground water in the United States has been



a quantitatively minor water  source;  its  only  major



role  being  domestic water supply for individual homes



or small communities.  Today, ground water accounts for



nearly 20 percent  of  the  Nation1s  requirements  for



water  and has been viewed by some as the answer to the



Nation's water supply problem.  It has  been  estimated



that  the  total  useable  ground  water  in storage is



equivalent in  volume  to  the  discharge  of  all  the



Nation's  rivers  for 35 years.1  However, difficulties



in  locating,  evaluating,  developing,  and   managing



ground  water  supplies  make full use of this enormous



reserve a distant reality.








Estimates of water use in 1954 and projections for 1980



and 2000  suggest  the  increasing  importance  of  our



ground water resources.  Total water use is expected to



increase  from an extimated 300 billion gallons per day



(bgd)  in 1954, to 599 bgd in 1980 and 888 bgd in  2000;



nearly  a  3-fold  increase  in  less  than  50  years.



Municipal use is expected to increase by  250  percent,



and  manufacturing  use by 720 percent in the same time

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period.2  In many areas of the country, surface  waters



have already become so degraded that they are unfit for



many  uses  without extensive and costly treatment.  It



must be expected that our ground water reservoirs  will



be  increasingly  used  to fulfill our requirements for



high quality water.








Until recently, minimal consideration  has  been  given



to  the  effects  on  the  subsurface  environment as a



result of  waste  disposal  practices.   The  dimishing



capabilities  of  surface  waters  to receive effluents



without violation of water quality standards  has  made



the  direct  emplacement  of  wastes  in the subsurface



increasingly   more   attractive   to    waste    water



dischargers.    The   effects   of   subsurface   water



pollution, and the fate of pollutants in the subsurface



are not well understood.  Insufficient knowledge of the



hydrology  and  hydro-mechanics  of  the  ground  water



region  is  presently  available  to confidently manage



this complex system.  Other than basic facts concerning



mechanisms of flow due  to  gravity  head  differences;

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predictive  relationships  for  ground  water velocity,



mixing, dispersion, and  stratification  still  require



refinement.   It  seems  evident, however,  that ground



water pollution is essentially irreversible.   Once  an



aquifer  is  contaminated  by  percolation from surface



sources, saltwater intrusion, or from injected  wastes,



it is difficult, or in most cases unfeasible, to remove



the contaminants by flushing or pumping and restore the



aquifer to its original condition.







Sources of subsurface water contamination can generally



be  assigned  to one of three basic categories:  1) The



direct introduction of pollutants deep within the earth



by  injection  through   wells,   2)   percolation   of



pollutants  from  surface and near surface sources such



as septic tanks, leaching  ponds,  sanitary  landfills,



and  pesticides  and  fertilizers  used in agricultural



practices, and 3)  intrusion of salt  water  into  fresh



water aquifers as a result of reductions in fresh water



flow  in  coastal  areas or the breaching of impervious



strata in inland areas.

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Deep. Well Injection







Deep well injection is the emplacement of wastes within



the earth, usually below the water table and beneath  a



confining  strata  which  serves  to isolate the wastes



from  potable  water  supplies  or  other  valuable  or



potentially   valuable   resources   (figure  1).   The



feasibility of injection of liquid wastes  deep  within



the  earth  is  suggested  by  the enormous capacity of



subsurface fluid storage space.   The  earth,  however,



contains few empty spaces and waste liquids can only be



accomodated   by  compressing  or  displacing  existing



fluids or by compressing or deforming  the  surrounding



strata.   The  possible  consequences  of high pressure



waste injection  include  the  displacement  of  saline



waters  quite  distant  from  the  injection  site, the



fracturing of geologic  strata  that  could  result  in



pollution  of  high  quality aquifers,  the migration of



wastes and native  fluids  along  existing  or  created



fractures  or faults, the upward transfer of pollutants



along well casings and even the gross  readjustment  of

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                    WELLHEAD
                  CEMENT
                   WELL CASING
                          R SPACE

                  INJECTIONTUBTNG
                   CEMENT
ZONE OF
DISPOSAL
  SHALE
 ERFORATIONS
SCREEN
GRAVEL PACK
           Figure 1

   Typical Waste Injection Well System

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the  surrounding  strata.   An example of the latter is



the now infamous Denver Arsenal  injection  well  where



the injection of wastes is believed to have triggered a



series  of minor earthquakes.  The injection of fluids,



within  the  earth,  is  not   a  problem  confined  to



hydrostatics.   Included  is  the  distribution  of the



initial pressure increases and  their  effects  on  the



surrounding  rock  matrix.   Radioactive and chemically



unstable wastes may produce  heat  and  pressure  after



they  have been injected.  It is possible that injected



wastes will react with the fluids and minerals  of  the



injection horizon changing the permeability or strength



of    the    surrounding   strata.    Determining   the



compatibility of the waste solution and the fluids  and



minerals of the injection horizon on the basis of pH or



specified    salt   concentrations   is   risky.    The



identification of strata where injection is feasible is



not difficult, this however, must not be  construed  to



imply  an  adequate  understanding  of  the  effects of



injection of a given amount of fluid.

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Currently, there are two distinct types  of  deep  well



injection  practiced  in the United States.  The first,



and by far the largest in terms of number of wells  and



volume  of  fluids injected, is the return of brines or



other fluids to  the  aquifers  from  which  they  were



extracted.   This  is a very common practice in the oil



and gas industry where approximately  10,000  acre-feet



of wastes are injected yearly through many thousands of



wells in the oil producing States3.  The second type is



the  injection  of liquid industrial, municipal, or low



level radioactive wastes.  Currently a  minor  practice



compared  to  the  reinjection of brines, the number of



industrial and municipal injection wells has  increased



from  approximately 125 in 1968 to over 270 at present.



This practice can be expected to continue  to  increase



as  surface  disposal  becomes more controlled and more



costly (figure 2) .








Brine reinjection has been practiced by  the  petroleum



industry  for over 50 years, both in water flooding for



the secondary recovery  of  oil,  and  as  a  means  of

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                         Figure 2

 Increase in the Use of Waste Disposal Wells Between 1950 and 1972
 300-
  280 H
z
o
H260H
oc
Ul
0.240-
O

~220-
INDUSTRIAL WASTE DISPOSAL
WELLS IN OPERATION

INDUSTRIAL WASTE DISPOSAL
WELLS ESTIMATED TO BE IN OPERATION

NUMBER OF NEW WASTE INJECTION WELLS
PLACED IN OPERATION PER YEAR

ESTIMATED NUMBER OF NEW WASTE
INJECTION WELLS PLACED IN OPERATION
BETWEEN I968ond I972
        Adapted from American Association of
                    Petroleum Geologists Memoir 10
        "Subsurface Disposal in Geologic Basins" 1968
/
/
      1950
                                      1970

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disposal  of  the brines associated with the production



of oil.  Ideally , the brines are reinjected  into  the



strata   from   which  they  were  produced,  not  only



disposing of great volumes of liquid material but  also



preventing land subsidence and facilitating greater oil



production.   In  the  reinjection of oil field brines,



the most difficult problems of where the fluids go  are



usually  solved  or assumed to be solved.  A great deal



of exploration and documentation of  the  geologic  and



hydrologic situation has been made and is available for



areas  where  reinjection is practiced.  Unfortunately,



the wastes are  not  always  as  well  confined  or  as



accurately   emplaced   as   would   be  desired.   The



contamination of shallow ground water around oil fields



is widespread and well recognized.  The major area  for



concern  in  the  reinjection  of brines is engineering



safeguards.  Injection wells must  be  constructed  and



operated  to guarantee that the brines are entering and



being contained in the desired strata.

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Industrial  and  municipal  wastes  disposed of by deep



well  injection  are  generally  highly   noxious   and



difficult   to   treat.   There  have  been  accidents,



including the now famous earthquakes  near  the  Denver



Arsenal   injection   well,   and  the  blowup  of  the



Hammermill  Paper  company  injection  well  in   1968.



Approximately  150,000 gallons per day of wastes spewed



from the Hammermill well into Lake  Erie.   This  waste



contained spent sulfite liquor, titanium dioxide, clay,



and lignin-like compounds*.







Deep  well  injection  of  wastes  is  currently  being



practiced often without adequate controls.  Only  about



one  half  of  the  states  have regulations concerning



waste injection wells and few distinguish  between  the



reinjection  of  oil  field brines and the injection of



municipal  and  industrial  wastes.   In  general   the



information  for  proper site selection and well design



is not available to  controlling  authorities.   In  an



attempt  to avoid further degradation of the subsurface



environment  by  waste  injection  the  Federal   Water

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Quality  Administration, in October 1970, established a



policy  (Appendix A) on disposal of wastes by subsurface



injection.   This   policy   opposes   the   subsurface



injection of wastes without strict controls and a clear



demonstration  that  no  damage to present or potential



subsurfaces  resources  will  result  from  the   waste



injection.  Many of the problems of deep well injection



could  be  eliminated or avoided if it were possible to



monitor the fate of wastes  that  have  been  injected.



The  problems  associated with monitoring, however, are



legion: What is to be monitored, how, and for how long?



Certainly the pressures  and  flows  in  the  injecting



wells  must  be known, but monitoring must also be done



at some distance  from  the  injecting  well  and  must



supply  information  that  could  be  used  to halt the



contamination of  adjacent  fresh  water  supplies,  or



other environmental hazards.







The  problems  that  must  be solved to ensure adequate



control of deep well  injection  are:  Identifying  and



classifying  areas safe for injection, determining what

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volumes of waste can be safely  injected,  establishing



chemical  standards  for wastes to minimize the dangers



of incompatibility with the minerals and fluids of  the



injection  horizon,  and  development  of  methods  for



monitoring and recording deep well injections to ensure



the engineering standards of their operation.
Percolation f_rom Surface Sources







By far the major  source  of  contamination  of  ground



water  is  the  wastes which percolate down through the



soil to reach the water table.  When a  contaminant  is



introduced  at  or  just  below  the ground surface, it



begins to slowly percolate down toward the water table.



In the percolation process, the soil acts as  a  filter



and  some  of  the  contaminants are removed.  The zone



above  the  water  table  commonly  contains  air,  and



aerobic  biological  degradation  can  take  place.   A



further   process   is   chemical   adsorption.    Many



substances,  and  in  particular  phosphates,  will  be
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adsorbed by or  ionexchanged  with  the  soils.   Under



normal  conditions  all of these processes; filtration,



bi©degradation, and  adsorption  serve  to  reduce  the



waste  load  which  reaches  the  water  table.   These



processes,  however,  are  not  effective  in  removing



contaminants  such as chlorides, nitrates or pesticides



and other non-degradable organic materials.   Once  the



contaminants  reach  the water table, biodegradation of



organics changes from aerobic to anaerobic  because  of



the  lack of available oxygen.  The adsorption and ion-



exchange of minerals have not been thoroughly  studied,



but  it  seems  reasonable that the soil's capacity for



these processes can be exhausted, and  that  efficiency



will decrease with time.







Urban  and  suburban  waste disposal by septic tanks is



still very common in  the  United  States  (figure  3).



Approximately  13  million  private septic tank systems



serving an estimated 50 million people are  in  use  in



the  United  States today.s  Tremendous waste loads can



filter into the ground water from  septic  tanks  where
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 '-/-i*	f  c_, rrri-
 / [  SEPTIC   !    >
/   |   TANK

  ..JOSE SEWER
PERFORATED
PIPE
                                      ABSORPTION
                                         FIELD
                                       BLE
            Figure 3
   SEPTIC TANK SEWAGE-DISPOSAL SYSTEM

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inadequate  absorption  fields  exist  and  there  is a



growing tendency to believe  that  distance  of  travel



implies  a  delay  in the discovery of pollution rather



than the removal of wastes.  There have been  outbreaks



of hepatitis in communities which have contaminated the



ground  water with septic tank effluents.5  The problem



of detergent contamination of ground water is now  well



known  and  has  been particularly severe in California



and New York.  Even biodegradable  detergents  are  not



degraded  once they have entered the ground water where



very little oxygen is available.







Seepage or evaporation ponds as waste treatment devices



have  historically  been  used  by  municipalities  and



industries  when  surface  disposal of waste water into



natural water courses was undersirable or  unavailable.



The  use  of  such methods by industry is becoming more



common  as  disposal  to  surface  water  becomes  more



controlled.  Operation of seepage and evaporation ponds



permits  the  percolation  of dissolved wastes into the



ground water flow.
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Refuse dumps and landfills  also  frequently  introduce



contamination  to  the  ground  water.   Since sanitary



landfills   and   dumps   are    often    located    in



topographically  low areas, much of the refuse is often



situated very close to or even below the  water  table.



Subsequent decomposition of the wastes or deterioration



of  sealed containers can introduce contaminants to the



ground water supply either  by  direct  contact  or  by



percolation  through  a  short  distance in the zone of



aeration.







Agriculture  is  perhaps  the  major   contributor   of



percolating   ground   water  contaminants.   Intensive



agricultural  practices   include   the   addition   of



fertilizers,  the confined feeding of livestock and the



application of large amounts of pesticides.   In  areas



of   intensive   land  use   tremendous  quantities  of



nutrients, salts, and organic wastes enter  the  ground



water  and degrade its quality.  In an attempt to avoid



further contamination of both surface and ground waters



by agricultural practices, the Environmental Protection
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Agency, in January 1972, established a policy (Appendix



B) on the control of nutrient runoff from  agricultural



lands.
In  Illinois,  thirty percent of all wells less than 25



feet deep contain  nitrate  (NO^  )   concentrations  in



excess  of  the  45 mg/1 Public Health Service Drinking



Water Standards recommended  limit.5   The  problem  of



agricultural  contamination  of  ground  water  can  be



intensified in arid areas where ground  water  is  used



for  irrigation.   As  the  water  is  applied, some is



absorbed by the plants, but the salts are  retained  in



the  remaining  water.   The water that filters back to



the ground water has an increased  salt  concentration.



If  the  ground  water  is  recycled, the concentration



process can continue until the soil  and  ground  water



are  too  salty  to  permit  the growth of crops.  This



situation has occurred many times in the past and  once



fertile  areas  have  become useless.  The situation is



now occurring in the Southwest.

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All of the sources of surface water contamination  also



affect the ground water.  Ground and surface waters are



very  closely  connected  and  many  rivers  and  lakes



discharge to the ground water during all or part of the



year.   Such  waters  carry  any  pollutants  they  may



contain down to the water table.







The  build-up  of  contaminants  in  ground waters from



percolating pollutants is seldom dramatic, and  sources



of percolating pollutants are both diffuse and diverse,



all  of  which  compounds  the  problems of control and



abatement.  In  the  area  of  percolating  pollutants,



however, at least two needs warrant immediate research:



a) The control and prevention of increased ground water



salinity through its use for crop irrigation and return



to  the  water table; and b)  the effects of septic tank



effluents on ground water, particularly the detergents,



pesticides, herbicides, and fertilizers  they  contain.



A  better  understanding is required of the stratified,



laminar flow, and  lack  of  disperison  mechanisms  in



aquifers.    Knowledge   of  constituent  removals  and
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changes affected in the unsaturated and saturaed  zones



is needed.
Salt Water Intrusion







In  many  areas  of the United States, saline and fresh



subsurface  waters  occur  in  close  proximity.   This



condition  is  prevalent in inland areas and ubiquitous



in coastal  regions.   Proximity  implies  an  inherent



danger   of   saline   contamination   of  fresh  water



resources.  In many localities such contamination is  a



reality.







Salt water intrusion is very rarely a  mixing  process.



Ground  water  flow is laminar and salt water and fresh



water are of different densities.  Diffusion  processes



can  therefore be ignored.  Intrusion is the process of



replacing fresh water with salt water.  In theory there



is no difference between the process  whereby  the  sea



replaces   fresh   water   and   other   density-caused
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processes.   The  problems  of   coastal   and   inland



intrusion,   if   not  differing  in  kind,  differ  in



magnitude, and it is in the  coastal  areas  where  the



critical and massive intrusion problems usually occur.








If  saline  and fresh water are in contact, the frontal



surface  will  move  in  response  to  changes  in  the



pressure   head   of   either  system.   Under  natural



conditions in ground water basins there  is  a  balance



between  inflow and outflow.  In the case of an aquifer



in hydraulic continuity with the ocean or  other  large



saline  body,  there is sufficient pressure and flow to



counteract the tendency for the heavier  sea  water  to



move  inland.   When  fresh  water  is removed from the



aquifer for use, or when recharge  of  the  aquifer  is



decreased,  the  water  level  is  lowered.   The lower



pressure permits salt water  to  move  into  the  fresh



water zone (figure 4).  Intrusion caused in this way is



said  to  result  from a reversal or a reduction in the



pressure gradient.  Parts  of  Long  Island  Sound  and



mainland  New  York  provide  a typical example,.  These
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                       -PUMPING WELL
                                 AQUIFER
                                 Fresh Water
                   Figure 4
COASTAL SALTWATER INTRUSION CAUSED BY
REDUCTION IN FRESH WATER FLOW.

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areas  are  underlain  by  a  wedge  shaped   mass   of



unconsolidated sediments that extend to a depth of more



than  2,000  feet.   Major  intrusion has occurred as a



result of ground water withdrawal and the  decrease  in



aquifer  recharge caused by improved drainage and sewer



systems.  By the mid 1930's, water levels in  parts  of



Kings and Queens Counties were lowered to as much as 35



feet  below  sea  level.6 Sea water intrusion resulted.



Ground water supplies  in  the  most  highly  urbanized



areas  of  these counties have been abandoned and water



is supplied  from  the  New  York  City  water  system.



Because  of the high rates of pumping and the extension



of  sewer  systems  removing  a  recharge  source,  the



hydraulic   imbalance   persists   and  the  threat  of



intrusion increases.







Salt  water  intrusion  almost  always  has  been   the



inadvertent result of some activity of man as he alters



his  environment.  An even better demonstration of this



often results from waterway construction.  When natural



waterways  are  deepened  or  widened,  there  is   the
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possibility  that  materials  which  have  acted  as an



impermeable   blanket   between   saline   waters   and



underlying  fresh  waters  may  be  removed.   When new



waterways which connect inland areas with the  sea  are



constructed,  permeable layers may be exposed to saline



water, or sea water  may  be  conducted  past  existing



barriers.   In  either case, a channel for the movement



of salt water into fresh water aquifers is created.







On  the  highly  populated  Atlantic   coast,   between



Massachusetts and Florida, each of the states is having



problems with sea water intrusion.6  The seriousness of



the  problems  is usually dependent on the intensity of



urban and industrial development  with  its  associated



extraction and non-return of water.  On the West Coast,



California   has  had  many  problems  with  sea  water



intrusion and has spent considerable effort to  try  to



solve or ameliorate the problems.  In several places it



is  now  common  practice  to recharge the ground water



with fresh water or treated wastes so that a  mound  is



created  between  the  ground  water basin and the salt
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water (figure 5).  A series of recharge mounds then act



as a barrier and allow the ground  water  basin  to  be



pumped  down  below  sea  level.  To date, the recharge



mound  seems  to  be  the  only  effective  method   of



combating sea water intrusion.







In  inland  areas,  salinity  problems are surprisingly



widespread.  In  geologic  history,  precipitation  has



washed soluble salts from the soils.  These salts moved



with  the  fluids  until  they  arrived in large basins



where   they   were   concentrated   by    evaporation.



Approximately  two  thirds  of  the conterminous United



States is underlain by saline  waters  containing  more



than 1,000 mg/1 dissolved solids.6  The problem of salt



water  intrusion  in inland aquifers can be the same as



in coastal areas, however, in  inland  areas  there  is



more  likely  to  be a physical barrier separating salt



water and fresh water aquifers.   Care  must  be  taken



that  these  barriers are not ruptured.  A major source



of contamination is the breaching of  confining  layers



by  drilling  or  mining.   In such instances, the salt
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                          PIEZOMETRICt
                       -RECHARGE WELL
                              AQUIFER
                                Fresh Water
                   Figure 5
CONTROL OF SALT WATER INTRUSION BY USE
OF A RECHARGE MOUND

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water can move along the channels which are created and



flow into fresh water aquifers.







In  the  area  of  salt  water  intrusion,   additional



research   is   needed   to  develop  new  methods  for



prevention  and  correction  of  coastal   salt   water



intrusion.   Present  methods incorporating artifically



recharged domes of fresh water may become  increasingly



less  desirable  as  fresh  water  volume  requirements



increase causing increased ground water  extraction  to



serve the needs of increased population.



Controls







An  additional  measure  needed  for  the protection of



subsurface waters is a  waste  effluent  permit  system



similar  to  that  currently  applicable  to to surface



waters under the 1899 Refuse Act.  Deep  well  disposal



of  wastes  must  be  controlled by laws or regulations



requiring the issuance of permits based on  information



about  the disposal site and the wastes to be injected.



Surface and near surface disposal regulations,  usually
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designed   to   prohibit  surface  nuisances,  must  be



reevaluated in terms of protection of water quality  in



the subsurface.







Currently,  the  authority of the Federal Government in



the control of  subsurface  pollution  is  ill-defined.



Federal   legislation   now  being  considered  in  the



Congress,  however,  would  provide  for  an   expanded



government  role  at  both the Federal and State levels



for  the  protection  of  the  subsurface  environment.



Provisions  of  the  proposed legislation include:  The



development of state laws and regulations, pursuant  to



Federal  guidelines,  for  subsurface water protection;



development of guidelines, information and criteria for



subsurface  disposal  standards;   increased   research



activity in the scientific factors affecting subsurface



waste  disposal;  development of a subsurface pollution



surveillance and monitoring program; development  of  a



state  enforcement  system  which must include a permit



system for subsurface waste  disposal;  development  of



subsurface   disposal  site  criteria;  development  of
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injection well construction  and  operation  standards;



increased   state   program   grants  for  implementing



subsurface pollution control programs; and  development



of  a  nationwide  program  administered  by the states



pursuant to Federal guidelines  to  regulate  land  and



underground disposal of wastes toxic to human health.







A   comprehensive   approach   to   the  protection  of



subsurface waters will  require  a  concerted,  unified



effort  at  the  Federal,  State,  and  local levels of



government.  If we  are  to  consistently  produce  the



enormous  quantities  of  high  quality  water that the



future will demand and if we  are  to  avoid  the  same



degradation  of  our  ground  water  resources that our



surface water resources have undergone,  management  of



withdrawal  and  recharge must be instituted.  Research



and technology must combine efforts to fill  the  basic



knowledge   gaps  in  the  earth  sciences  that  allow



understanding of the causes and  permit  prediction  of



the effects of subsurface water pollution.
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References Cited

1. Piper, A.M., "Subsurface Facilities of Water Management
        and Patterns of Supply - Type Area Studies", The
        Physical and Economic Foundations of Natural
        Resources, Vol. 4, 1953.

2. McGuinness, C.L., "The Role of Ground Water in the
        National Water Situation", U.S.G.S. Water Supply
        Paper 1800, 1963.

3. Piper, A.M., "Disposal of Liquid Wastes by Injection
        Underground - Neither Myth nor Millennium",
        U.S.G.S. Circular 631, 1969.

4. Sheldrick, M.G., "Deep Well Disposal:  Are Safeguards
        Being Ignored?"  Chemical Engineering, PP. 74-78,
        April, 1969.

5. Patterson, J.W. et al, "Septic Tanks and the Environ-
        ment", State of Illinois Institute for Environmen-
        tal Quality, 1971.

6. "Salt Water Intrusion in the United States", Task Committee
        on Salt Water Intrusion, Journal of the Hydraulics
        Division, ASCE, Vol. 95, HY5, PP. 1651-1669,
        Sept. 1969.
                          24

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                                                        Appendix  A
            -"• —-                                    COM  5040. 10
                                                    October  15, 1970

SUBJECT:  Policy on Disposal of "Wastes by Subsurface Injection

1.    PURPOSE.   This order establishes  FWQA policy  on the dis-
posal of v/astes by subsurface injections.

Z.    BACKGROUND.

      a.    The disposal and storage of liquid v/astes by subsurface
injections are being  increasingly considered,  especially by indus-
tries facing enforcement of water quality  standards. This is
because of  the diminishing capabilities of  surface waters to receive
effluents withoiit violation of standards, and the apparent lower
costs of this method of disposal over conventional and advanced
waste treatment techniques.

      b.    The effects of underground pollution and the fate  of
injected materials are uncertain with today's knowledge.  These
wastes  could-well result in  serious pollution damage and require a
more complex and costly solution on a long-term basis.

      c.    Improper Injection of municipal or industrial wastes to
the subsurface could result in serious pollution of water supplies or
other environmental hazards.

3.    POLICY.

      a.    FWQA is opposed to the disposal or storage of wastes by
subsurface  Injection without strict controls and a clear  demonstra-
tion that such v/astes will not interfere with present or potential use
of subsurface water  supplies, contaminate interconnected surface
waters, or  otherwise daiTiage the environment.

      b.    All proposals for subsurface injection of v/astes  shall
be critically cvaluc-t e.d to 
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COM  5040. 10                                     October 15, 1970
             (Z)   Appropriate preinjection tests have been made to
 allow prediction of the fate of wastes to be injected;

             (3)   There  is adequate evidence to demonstrate that
 such injection will not interfere with present or potential use of
 wa-ter resources nor  result in other environmental hazards;

             (4)   Best practical measures for pretreatment of
 wastes have been applied;

             (5)   The subsurface injection system, has been designed
 and constructed using the best available techniques,  equipment, and
 design criteria;

             (6)   Provisions for adequate and continuous monitoring
 of the injection operation and resulting effects of the injection on
 the environment hax^e been made; and

             (7)   Appropriate provision will be made for plugging
 such wells at horizons below present or potential sources of water
 supply when their  use for disposal is discontinued.

       c.     \Yhcre  subsurface injection of wastes is practiced, it
 v/ill be: recognized  as a temporary means of ultimate  disposal to
 be discontinued when alternatives enabling greater environmental
 orotection become  available.
 j-

 4-    IMP LEMENTATIQN.   FWQA will apply this policy to the extent
 of its authorities in conducting ail program activities, including
 regulatory activities,  research and development,  control of pollution
 from Federal installations, technical assistance  to the States,  and
 tb-? admlmstralion of the cons true lion grants, Slate program grants,
                               g^YX,;:^
                               0>C,-'J" ^   -' - •"'<•>"'

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                                           Appendix B

          Policy on Control of_ :'utrient Runoff from.
          Ay ric a11ura1 La n ds  "                     '
1,  PURPOSE. To establish EPA policy on the control, of
nutrients from agricultural lands.

2.  BACKGROUND.

    a. The streams, lakes and estuaries of any area reach an
equilibrium under the natural conditions of the area.  This
applies to the nutrients reaching these waters and the
utilization of the nutrients by the aquatic biota that
inhabit the waters.  Man's activities tend to upset this
equilibrium and generally result in increased nutrients and
other pollutants reaching the waters.  The increased water
nutrient levels lead to problems that include excessive
aquatic plant growths with the attendant oxygen problems
that are associated with decomposition processes, and to an
acceleration in the aging of the water body.

    b. Along with industrial and municipal sources, man's
agricultural activities contribute nutrients to the
waterways.  If the quality of the surface and ground waters
of the nation is to be improved/ and further degradation
prevented, the nutrients resulting from agricultural
activities must be controlled along with those from
municipal and industrial sources.

    c. Nutrients from agricultural activities, either
carried by dislodged sediments or dissolved in the drainage
water include: those from native soils; decaying crop
residues; fertilizers applied to the land, both organic and
inorganic; and animal wastes.

3.  POLICY.

    a. The management of agricultural nutrients will
require: appropriate limitation of erosion and sediment
runoff; the efficient use of applied fertilizers by the
plants; tha application of fertilizers under the right
climatic and crop growth conditions; and tha retention of
animal wastes on the land.  Management programs should be
planned and implemented for complete drainage basins.
However, maximum use should be made now of existing programs
^hat are available to individual farms or groups of farms.

    b. Existing rederal, State, and local programs for
control of erosion and sedimant runoff should be implemented
on ~\n accelerated basis, and, where applicable, the upper

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roaches of watersheds should be attached first while
att-uking critical problems in other areas chat are amenable
';o oarly solutions.  Projects designed for erosion and
oodiripnt control should include nutrient runoff control
Measures»  The inclusion of such measures and acceleration
of the implementation of erosion and sediment control
projects v;ill result in reductions of the nutrients reaching
the streams while at the same time retaining the soils on
the agricultural lands.

    c. The development of fertiliser application management
plans will require full evaluation of the nutrient
availablility and retention capability of various soil types
of the appropriate agricultural area.  The capability of
existing programs/ such as those of the U.S. Department of
Agriculture and State and local Agricultural Agencies should
be brought to bear toward developing the essential
information for complete watersheds and soil structure types
at an early date.  Starting now with available information,
guidelines for fertilizer application, including maximum
recommended rates, should be developed.  The voluntary use
of the guidelines in the fertilizer program for individual
farms should be encouraged through a strong effort by the
presently available educational programs of Federal, Stata,
and local agencies and educational institutions, and through
technical assistance.  Success of the educational approach
must be adequately monitored in critical areas to determine
the needs for other approaches to achieving necessary levels
of nutrient control.  Consideration should be given to
requiring adherence to certain fertiliser application
guidelines as a condition of eligibility for selected forms
of governmental assistance.

    d. Animal wastes, principally manures, serve as both a
source of nutrients and as a soil builder when applied to
agricultural lands.  Programs to retain the manures on the
land, and incorporate them into the soil should be developed
and implemented as part of the overall nutrient management
program of a watershed while greatly increasing the use of
already proven animal waste control programs for individual
farms or animal feeding operations.

     (1) Animal v/astes should not be applied to farm lands
under adverse soil or weather conditions except when planned
methods will insure that they remain on the land.  Storage
of the v/astes in designed structures until they can be
incorporated into the soil should be used.

     (2) Watering and feeding points should be established
away from waterways along with the establishment of runoff

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a;;  vrosion co.i'r.roi  measures  to prevent the concentration of
a.j-'il wastes  in  the vici.nity of the streams,  "j"hcn a high
tl'^sity of anirials is  created through confinement/ fencing
of the streams traversing  such areas should be used as a
;. cans of preventing  water  pollution by the v/astes of the
crn.ined animals  and the physical destruction of the
streambeds and banks.

4. IMPLEMENTATION. EPA will apply this policy to the extent
of its authorities in  conducting all program activities,
including regulatory activities, research and development,
technical assistance,  control of pollution from Federal
institutions,  and the  administration of the construction
grants, State program  grants, and basin planning grants
programs.
                                  William D. Ruckelshaus
DATE:  January lU, 1972               Administrator
  L. S, GOVKHNuriW PRKVTOlfi OFHC C 1972 — 514-145 (16)

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