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  GUIDELINES  FOR GROUND-WATER  CLASSIFICATION
UNDER THE EPA GROUND-WATER PROTECTION  STRATEGY
                   FINAL  DRAFT
                  NOVEMBER 1986
       A final of this  document was never approved.
       The EPA does not approve of the  contents of
       this document [Per Jerri-Anne Garl, Chief,
       Safe Drinking Water Branch, April 11, 1993]
      OFFICE OF  GROUND-WATER PROTECTION
                OFFICE OF  WATER

     U.S.  Environmental Protection  Agency
               401  M Street,  S.W.
             Washington, D.C. 20460
         U.S. Environmental Protection
         Region 5, Library (PL-12J)
         77 West Jackson Boulevard, 12th Ptaar
         Chicago.  II  60604-3590

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0,3, Environmental Proteclk

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                       ACKNOWLEDGEMENTS

     The guidelines  were prepared by  the Office  of  Ground-
Water Protection under the  overall guidance  of the Director,
Marian  Mlay.    The  project  manager  was Ron Hoffer,  with
additional  technical   support  provided  by   Jose  Valdes.
Assistance  in developing  the  socioeconomic  and  ecological
aspects  of the  system  was provided  by  Brendan   Doyle  and
Arthur  Koines  of  the Office  of Policy Planning and  Evalua-
tion.  Much of their  effort  led  to  a   set  of  supporting
analyses which, while  unpublished,  were  valuable  in  framing
options.  Joyce Edwards of OGWP helped in the secretarial and
logistical aspects of this document from the inception of the
proj ect.

     Technical consultants  played  a significant role  in the
preparation  of these  guidelines.    The primary  technical
consultant  was Geraghty &  Miller,   Inc.   (G&M), Dr.  William
Doucette, project manager.  Other members of the G&M  support
team included  Michael  Gaudette, Bonnie Halberstam, Caroline
Hoover,    Don Lundy,  Paula  Magnuson,   Jeffrey  Mahan,  and
Jeffrey Sgambat.   Gloria Hall at G&M performed the majority
of word processing.   Subcontract assistance was provided by
ICF, Inc.,  Paul Bailey,  project manager.   Other ICF  support
team  members   were  Craig   Dean,  Janis   Edwards,  and  Liane
Heatherington.

     The efforts of  the  Classification  Guidelines  Work Group
are especially appreciated.   Serving with representatives of
the EPA program offices  and EPA Regions were Robert Moore of
the Connecticut Department of Environmental Protection, Edith
Tanenbaum of the Long Island  Regional  Planning Board,  Rodney
DeHan of the Florida Department of  Environmental Regulation,
Maxine Goad of the New Mexico  Department  of  Health, and John
Moore  of the  U.S.  Geological  Survey.    The technical  and
policy insight of all the work group members helped immeasur-
ably to carry through  the spirit  of the EPA Ground Water
Protection  Strategy.   Any  shortcomings   in  this  document,
should not, however, be  attributed to  the work group  members
as individuals.

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                      EXECUTIVE SUMMARY

                            PART I
Introduction

     The  Environmental Protection  Agency  (EPA)  issued  its
Ground-Water  Protection  Strategy  in August,  1984.    This
guidance  document   for   ground-water  classification  is  a
follow-up  to the  Strategy,  and  is  a major  step   in  EPA's
efforts  to provide  policy direction  for  EPA programs  with
ground water responsibility.   The purpose of this document is
two-fold:  (1)  to further  define  the classes, concepts,  and
key terms  related to  the classification system  outlined in
the Ground-Water Protection Strategy, and (2) to describe the
procedures  and  information  needs  for  classifying  ground
water.   Through  the release of the  Draft  Guidelines, public
comment  is  being solicited  on  the appropriate direction to
meeting these purposes.

     Through  the  process  of  classification,  ground-water
resources are  separated  into hierarchical categories on  the
basis of their value  to  society,  use, and  vulnerability to
contamination.   Ground-water  classes will  be a factor in
deciding the level  of  protection  or remediation  the resource
will be provided.

Background

     The core  of the  Ground-Water  Protection Strategy is  a
differential protection policy that recognizes that different
ground  waters require different levels  of  protection.    A
three-tiered  classification  system  was established as  the
vehicle  for implementing this policy.

     The  classification  system  will,  as  appropriate,   be
implemented  by  EPA  program   offices  and  state   agencies
responsible for EPA delegated programs as  changes in program
guidance and  regulation  are  made.   The  differential protec-
tion policy, as  expressed through the classification system,
will assist the programs in tailoring protection policies for
ground  water.    In permit-based actions  concerning  point
sources  of pollution,  classification will  most likely become
an additional step in  site-specific analysis.  Similarly,  EPA
is  considering  various   approaches  for  using  differential
protection and  other  strategy-related policies  for broader-
based, nonpoint sources.   Two recent EPA rule-making actions-
                            11

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- one for Superfund and one  for  radioactive  waste disposal—
incorporated aspects of the classification system.  Other EPA
program  offices  are  in  different   stages  of  developing
approaches to  implementing the system.   It is  important to
note that  the Guidelines  are  not enforceable in particular
EPA programs  until  legally incorporated by  program guidance
regulations, or other appropriate means.

     State  agencies responsible  for  managing ground  water
will  not be  required by  EPA  to  adopt  the  classification
system for  general  program use.   In fact,  many  states have
already developed ground-water protection approaches tailored
to their particular land  use  and  hydrogeologic  conditions.
However,  state agencies carrying  out  delegated or authorized
EPA programs  may need to  use these  guidelines  as  they are
implemented by those programs.

     It  should be noted  that a site  located in  a designated
Safe  Drinking Water Act  Sole  Source Aquifer  (SSA) is not
automatically placed in Class  I.   The criteria  for SSAs are
less rigorous than those of Class I.  Greater rigor is needed
for classification  since,  unlike SSAs,  Class I  will   be  a
decision-making factor in program regulations.   SSAs are only
considered at  the Federal level  under financially assisted
projects such as farm loans and rural water districts.

     At least half of the  states  are  using,  or are seriously
considering using,  some  form of a  site-by-site  or anticipa-
tory classification system.  Under its existing programs, EPA
will perform  site-by-site  rather than aquifer or well  field
classification.  However,  the classification system presented
in this  guidelines document  attempts to  be  generally con-
sistent with broader classification systems  that  may be used
by the states.  EPA is considering the substitution of  state
ground-water  classification  systems   for   the   EPA  system
wherever possible.  In the implementation of its ground-water
protection programs,  EPA will  consider and incorporate,  to
the extent possible, State Wellhead Protection Areas approved
under the Safe Drinking Water Act Amendments of 1986.

The EPA Ground-Water Classification System

     The EPA  Ground-Water  Classification System  consists of
three  general  classes of  ground  water representing a  hier-
archy  of ground-water  resource  values  to  society.   These
classes  are:

         Class I - Special ground water
                             iii

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        Class II  -  Ground water currently and  potentially a
        source for drinking water
        Class III - Ground  water not  a source  of  drinking
        water.

     The  classification  system  is,  in general,  based  on
drinking water as the highest beneficial use of the resource.
The  system  is designed  to be  used  in   conjunction with the
site-by-site  assessments  typically  conducted  by  the  EPA
program  offices   in  issuing  permits  and deciding on  appro-
priate remedial action.

Classification Review Area:

     A  site-by-site  approach  to  classifying  ground  water
necessitates delineating  a segment of ground water  to which
the  classification  criteria  apply.   Since  EPA is not clas-
sifying ground water on a regional or aquifer-specific basis,
a Classification  Review Area concept is  incorporated as a key
element  in  the  classification  decision.  This  is,  however,
strictly an  area  for review  of ground-water characteristics
and not an area where  regulation will be imposed beyond that
of the specific activity under consideration.

     The  Classification  Review  Area   is  delineated  based
initially on a  two-mile  radius from the boundaries  of the
"facility"  or the  "activity."    An  expanded  Classification
Review  Area  is  allowed under  certain   hydrogeolgoic  condi-
tions.  Within the  Classification  Review Area,  a preliminary
inventory of public water-supply wells,  populated areas not
served  by  public supply,  wetlands,   and surface waters,  is
performed.    The  classification  criteria  are then applied to
the  Classification  Review Area  and  a  classification  deter-
mination made.

Subdivision of Classification Review Area and Interconnection
Concepts:

     Where  hydrogeologic  data   are   available,  the  Classi-
fication  Review  Area  can  be  subdivided  to  reflect  the
presence of  naturally  occuring ground-water bodies that may
have  significantly  different use  and value.   These  ground-
water bodies, referred to as "ground-water units", must be
characterized  by  a  degree   of   interconnection  (between
adjacent ground-water  units)  such that  an adverse change in
water  quality to  one  ground-water  unit will have  little
likelihood of causing  an adverse change in  water quality in
the adjacent ground-water unit.  Each  ground-water  unit can
                            IV

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be treated  as a separate  subdivision of the  Classification
Review Area.  A classification decision  is made  only for the
ground-water  unit  or  units  potentially  impacted  by  the
activity.

     The identification of ground-water  units  and assessment
of  interconnection   between  ground-water  units   may,   in
critical cases,  require a  rigorous hydrogeologic  analysis.
The acceptance  of  subdivisions  will  be  on  a  case-by-case
basis after review of the supporting analysis.

     The recognition of ground-water unit subdivisions to the
Classification Review Area establishes  a spatial  limit  for
classification and  the application of protective management
practices.   The degree of interconnection to adjacent ground-
water  units  and  surface  waters  is  also a  criterion  for
differentiating  between  subclasses   of  Class   III  ground
waters.

     Ground-water   units   are  mappable,   three-dimensional
ground-water  bodies  delineated  on the  basis of  the  three
types boundaries described below:

     Type 1:  Permanent ground-water flow divides

     Type 2:  Extensive,   low-permeability   (non-aquifer)
              geologic units  (e.g.,  thick, laterally exten-
              sive  confining  beds)  especially where charac-
              terized  by  favorable hydraulic  head  relation-
              ships  across  them   (i.e.,  the  direction  and
              magnitude of flow through  the low-permeability
              unit)

     Type 3:  Permanent  fresh-water/saline-water  contacts.
              (Saline  waters being defined  as  those waters
              with  greater than  10,000  mg/1  of Total  Dis-
              solved  Solids).

     The  type  of  boundary  separating  ground-water  units
reflects the  degree of interconnection  between  those units.
Type 2 boundaries constitute a low degree of interconnection.
A  low degree is expected  to be  permanent unless improper
management  causes  the low-permeability  flow boundary  to be
breached.  Type 1 and Type 3 boundaries  imply an intermediate
degree  of  interconnection.   They  are prone  to alteration/
modification  due  to  changes in ground-water  withdrawals and
recharge.
                              v

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     A high  degree of  interconnection is inferred  when the
conditions  for a  lower  degree  of  interconnection are not
demonstrated.   High interconnection of waters  is  assumed to
occur within a given ground-water unit and where ground water
discharges into adjacent surface waters.   A high  degree of
interconnection  implies a  significant potential  for  cross-
contamination of waters if a component part of these settings
becomes polluted.

Class I - Special Ground Waters:

       Class I  ground waters  are resources of unusually high
value.  They are highly vulnerable to contamination and are
(1)  irreplaceable  sources  of  drinking  water  and/or  (2)
ecologically vital.  Ground water, which is highly vulnerable
to  contamination,   is  characterized   by   a  relatively  high
potential for contaminants  to  enter and/or to be transported
within the ground-water flow system.

     In these Draft Guidelines, the Agency is seeking comment
on the appropriate  approach to defining "highly vulnerable."
Public  comment  will  influence  the  Agency's  choice  of  an
approach  for the Guidelines  when they  are issued  in  final
form.   To  assist  in  framing the discussion, these  Draft
Guidelines  focus  on two  options  for  determining  vulner-
ability.  Both  of these  require consideration of a number of
hydrogeologic parameters.   Option A would require  use of the
DRASTIC  system  (Aller  et  al,  1985),  a numerical  ranking
system developed by the National Water Well Association under
contract  to  EPA.   The  DRASTIC  system provides a  method of
scoring an area's "vulnerability" based upon consideration of
various parameters  such as  depth to water, recharge, aquifer
media, etc.  Using this approach, an area would be considered
"highly  vulnerable"  if  its  DRASTIC  score  exceeds  levels
specified in these  Guidelines.  Option B  does  not rely on a
set  methodology with numerical  criteria.   Instead, vulner-
ability  would  be   assessed in  a  more  qualitative manner,
relying  on  best professional judgement.    The user  might
consider  specific  technical   parameters  within the DRASTIC
system  (i.e.,  depth to water, net recharge,  aquifer media,
etc.), but would not  attribute scores to these parameters or
provide  numerical  cutoffs  for defining  "highly vulnerable"
areas.  Other techniques would also be allowable under Option
B.    Thus,   this alternative  is  considered qualitative  in
nature  since specifics as to methods  or criteria  are not
provided  in  these  Classification  Guidelines.   Instead, the
overall  advantages and disadvantages  of the  general  cate-
gories  of techniques  is provided.    Comments  on  these two
                               VI

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options,  as well  as  other  options  for  assessing  vulner-
ability, will be considered by the Agency  in determining how
best to incorporate this factor in classification decisions.

     Ground water  nay  be considered  "irreplaceable" if  it
serves a substantial population and if delivery of comparable
quality and quantity of water from alternative sources in the
area  would  be  economically infeasible   or  precluded  by
institutional constraints.

     In these Draft Guidelines,  the Agency is also soliciting
comment on  approaches to judging two aspects of  the "irre-
placeable" criterion.   Option A incorporates  a quantitative
determination of the population served by  the source and the
economic  feasibility  of  replacing  the source.    Under  this
approach,   a  drinking  water source would  be  considered
"irreplaceable" if  it  serves at  least 2500 people  and the
annual cost to a typical user of replacing the source exceeds
0.7 to 1.0 percent of the mean household  income in the area.
Option B focuses on a qualitative assessment of the replace-
ability of the  ground water.    Under  this  approach,  the
relative size of the population served by  the source and the
cost of replacing the source  would be factors to consider in
assessing  the  source's  "replaceability."    The  Guidelines
would not, under Option B, provide a set methodology, nor one
or more numerical  cutoffs.    Again,  the determination would
focus  on  best  professional  judgement.    A user  following
Option  B   may  choose,  however,  to  consider  some  of  the
quantitative methods  or  approaches  in Option  A,  if deemed
relevant in a  particular classification decision.   Comments
on these two options, as  well as  other  options for assessing
"substantial  population"   and   "irreplaceable"   (from  an
economic  standpoint),  will be  considered by the  Agency  in
determining how best to incorporate these  factors in classi-
fication decisions.

     Ground water may be  considered ecologically vital if it
supplies a  sensitive  ecological  system located  in a ground-
water  discharge area  that  supports  a  unique  habitat.   A
unique habitat is  defined to  include  habitats for endangered
or threatened species listed  or proposed for listing pursuant
to the  Endangered  Species Act (as amended  in 1982),  as well
as certain types of Federally managed and protected lands.
                            VI1

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Class II  - Current and  Potential Sources of  Drinking Water
and Water Having Other Beneficial Uses:

     All non-Class  I  ground water currently used,  or poten-
tially available, for drinking water and other beneficial use
is  included in  this category,  whether  or  not  it  is  par-
ticularly vulnerable to contamination.  This class is divided
into  two  subclasses;  current  sources  of  drinking  water
(Subclass  IIA),   and potential   sources  of  drinking  water
(Subclass IIB).

     Ground water is  considered  a current source of drinking
water under two  conditions.    The  first condition  is  the
presence of  one  or more operating drinking-water  wells  (or
springs) within  the Classification Review Area.   The second
condition  requires  the  presence  within  the  Classification
Review Area of a water-supply reservoir watershed (or portion
of a water-supply reservoir watershed)  designated for water-
quality protection,  by either state or local government.

     The concept  of  a  current  source  of drinking  water  is
rather broad by  intent.   Only a portion  of the ground water
in the Classification Review Area needs to be supplying water
to drinking-water wells.

     A  potential  source of drinking water is one  which  is
capable of yielding a quantity of drinking water to a well or
spring  sufficient  for   the needs  of  an average   family.
Drinking water is taken specifically as water  with a total-
dissolved-solids  (TDS)   concentration  of less  than  10,000
mg/1, which  can  be used without treatment,  or which can  be
treated using methods reasonably employed in  a public water-
supply  system.    The  sufficient  yield criterion  has   been
established at 150 gallons/day.

Class III  -  Ground  Water Not a  Potential  Source of Drinking
Water and of Limited Beneficial Use:

     Ground waters that are saline, or otherwise contaminated
beyond  levels which  would  allow use  for drinking  or other
beneficial purposes,  are in this class.   They include ground
waters  (1) with a total-dissolved-solids  (TDS)  concentration
over 10,000  mg/1, or  (2) that are  so  contaminated by natur-
ally occurring conditions,  or by the  effects  of broad-scale
human activity (i.e., unrelated to a specific activity),  that
they cannot be cleaned  up using  treatment methods reasonably
employed  in public  water-supply systems.   Two  alternative
tests are  proposed  for  making this determination.   A refer-
                            viii

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ence-technology test is proposed in the draft and an optional
economically-based test is included in Appendix G.

     Class III  is subcategorized primarily  on the basis  of
the degree of interconnection with surface waters or adjacent
ground-water units containing ground water of a higher class.
Subclass  IIIA  ground  waters  have  a  high-to-intermediate
degree of interconnection to adjacent ground-water units of a
higher class or surface waters.   In  addition,  Subclass IIIA
encompasses ground waters in  those  settings  where  yields are
insufficient from any depth within  the Classification Review
Area  to  meet  the needs  of  an  average size  family.   Such
ground  waters,  therefore,   are  not  potential  sources  of
drinking water.

     Subclass  IIIB  is  restricted to  ground waters  charac-
terized  by  a   low  degree  of  interconnection  to  adjacent
surface waters  or ground waters of  a  higher  class  within the
Classification Review Area.   These ground waters are natural-
ly isolated from sources ojf drinking water in such a way that
there  is  little potential  for  producing  additional  adverse
effects on human  health and the environment.   They have low
resource values outside of  mining,  oil and  gas recovery,  or
waste disposal.

                           PART II

Classification Procedures

     These Guidelines provide a more  in-depth  discussion  of
the  actual  process  of site-by-site classification.    The
process  is  facilitated through  a  classification  decision
chart  and associated  worksheet.    These  were developed  to
provide  a systematic  approach  to  classifying ground  water
based on certain criteria, e.g.,  presence of wells, ecologic-
ally vital areas, water quality,  irreplaceability,  etc.   They
are  provided as  suggested approaches only,  since  a  given
setting  may be  more  effectively  handled  through  another
sequence of steps.

     Classification  requires  certain  information  on  the
character of the Classification Review Area.   The emphasis of
data  collection is  on  readily  available sources.    More in-
depth  analyses  are  not  expected  routinely,  but,  may become
necessary for Class I or, especially, Class III areas and for
subdivision of the Classification Review Area.
                              IX

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     Preliminary data needs include:
        Base map of the Classification Review Area,
        Inventory  of  public  water-supply  systems  in  the
        review area,
        Delineation of areas served by private wells,
        Demographic  information  for the public  water-supply
        systems and areas of private wells,
        Survey of ecologically vital areas, and
     .   Hydrogeologic data  sufficient  to judge vulnerability
        of or support interconnection analysis.
     The remaining sections of this chapter contain technical
guidance for the following:
        Expansion of the Classification Review Area,
        Subdivision  of the  Classification  Review  Area  and
        Determination of Interconnection,
        Determining Irreplaceability,
        Determining Ground-Water Vulnerability,
        Determination of Reasonable Treatment, and
        Ground-Water and Surface-Water Interactions.
                              PART III
     The final chapters of this document are appendices which
contain the following information:
     Appendix A - Glossary
     Appendix B - Alternative Options Considered
     Appendix C - Sample Applications of  Ground-Water Class-
                  ification
     Appendix D - DRASTIC Factors and Ratings
     Appendix E - Background Data Regarding Class I and III
     Appendix F - Census Bureau Information
     Appendix G - Economic  Tests  for  Determining  Class  I
                  Irreplaceable   Waters   and   Class   Ill-
                  Untreated Ground Waters
                              x

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            GUIDELINES FOR GROUND-WATER CLASSIFICATION
          UNDER THE EPA GROUND-WATER PROTECTION STRATEGY
                              CONTENTS

ACKNOWLEDGEMENTS	    i
EXECUTIVE SUMMARY	   ii
TABLE OF CONTENTS	   xi

                               PART  I
                     BACKGROUND AND DEFINITION
                      OF GROUND WATER CLASSES

1. 0  INTRODUCTION	    1
     1.1  EPA1s Ground-Water Responsibilities 	    1
     1.2  The Purpose of this Document	    1
     1.3  Organization of this Document	    2
2 . 0  BACKGROUND.	    3
     2.1  Need for Ground-Water Classification	    3
     2.2  Guidelines Development 	    4
     2.3  Implementation in EPA Programs	    6
     2.4  Interaction with State Ground-Water
          Protection Efforts	   10
3 .0  THE EPA GROUND-WATER CLASSIFICATION SYSTEM	   15
     3.1  An Overview of the Ground-Water Classes
          and Subclasses	   16
          3.1.1  Class I - Special Ground Waters	   16
          3.1.2  Class II - Current and Potential
                 Sources of Drinking Water and Water
                 Having Other Beneficial Uses	   20
          3.1.3  Class III - Ground Water Not a
                 Potential Source of Drinking Water
                 and of Limited Beneficial Use	   21
     3.2  Classification Review Area	   22
          3.2.1  Technical Basis for Two-Mile Radius	   23
     3.3  Subdivision of the Classification Review
          and Interconnection Concepts	   25
          3.3.1  Ground-Water Units	   26
          3.3.2  Interconnection	   27
          3.3.3  Illustration of a Subdivision	   27
     3.4  Key Terms and Concepts for Defining Class I	   30
          3.4.1  Highly-Vulnerable Ground Water	   30
          3.4.2  Irreplaceable Source of Drinking Water	   32
                 3.4.2.1  Substantial Population	   33
                 3.4.2.2  Uncommon Pipeline Distance	   34
                 3.4.2.3  Comparable Quality	   34
                                 xi

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                     TABLE OF CONTENTS (Cont.)
                 3.4.2.4  Comparable Quantity	    35
                 3.4.2.5  Institutional Constraints	    35
                 3.4.2.6  Economic Infeasibility	    36
          3.4.3  Ecologically Vital Ground Water	    37
     3.5  Key Terms and Concepts for Defining Class II	    37
          3.5.1  Current Source of Drinking Water	    39
          3.5.2  Potential Source of Drinking Water	    39
                 3.5.2.1  Water Quality/Yield Data Needs	    41
          3.5.3  Sufficient Yield	    41
     3.6  Key Terms and Concepts for Defining Class III	    43
          3.6.1  Methods Reasonably Employed in Public
                 Water Treatment Systems	    43
          3.6.2  Insufficient Yield at Any Depth	    44
          3.6.3  Interconnection as a Class III Criterion...    45
                              PART II
                DETAILED CLASSIFICATION PROCEDURES

4 . 0  CLASSIFICATION PROCEDURES	   46
     4.1  Preliminary Information 	   52
          4.1.1  Base Map of Classification
                 Review Area	   52
          4.1.2  Well Survey	   52
          4.1.3  Demography	   53
          4.1.4  Ecologically Vital Areas	   53
          4.1.5  Hydrogeologic Data	   54
     4.2  Conditions and Procedures for Expanding the
          Classification Review Area	   55
          4.2.1  Hydrogeologic Settings	   55
          4.2.2  Expanded Classification Review Area
                 Dimensions	   56
     4.3  Subdivision of the Classification Review Area
          and Interconnection Concepts	   59
          4.3.1  General Hydrogeologic Information
                 Needed for Identifying Ground Water
                 Units and Analyzing Interconnection	   61
          4.3.2  Type 1 Boundaries: Ground-Water
                 Flow Divides	   62
          4.3.3  Type 2 Boundaries: Low-Permeability
                 Geologic Units	   67
          4.3.4  Type 3 Boundaries: Fresh/Saline
                 Water Contacts	   73
          4.3.5  High Interconnection Scenarios	   80
          4.3.6  Example of Subdividing a Classification
                 Review Area	   80
                                 xn

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                     TABLE OF CONTENTS  (Cont.)

     4.4   Determination of Irreplaceability	    88
          4.4.1  Substantial Population (Option A)	    91
          4.4.2  Substantial Population (Option B)	    91
          4.4.3  Uncommon Pipeline Distance	    93
          4.4.4  Comparable Quality Analysis	    95
                 4.4.4.1  Water Quality Parameters	    95
                 4.4.4.2  Sources of Information	    95
          4.4.5  Comparable Quantity Analysis	    96
          4.4.6  Institutional Constraints	    98
                 4.4.6.1  Example of Considerations for
                          a More Detailed Assessment	    98
          4.4.7  Economic Infeasibility (Option A)	   101
                 4.4.7.1  Annualizing Capital Costs	   103
                 4.4.7.2  Using Water Supply Utility
                          Rates and Fees to Estimate
                          Costs of Alternative Water
                          Supply	   103
                 4.4.7.3  Household Income of Substantial
                          Population	   103
          4.4.8  Economic Infeasibility (Option B)	   104
          4.4.9  Summary	   104
     4.5   Determining Ground-Water Vulnerability	   107
          4.5.1  Option A: DRASTIC	   107
                 4.5.1.1  DRASTIC Methodology	   109
                 4.5.1.2  Application of DRASTIC to the
                          Classification Review Area	   109
                 4.5.1.3  Limitations to the Application of
                          DRASTIC	   112
          4.5.2  Option B: Qualitative  Assessment	   112
     4. 6   Determination of Reasonable Treatment	   115
          4.6.1  Standards and Criteria for Treatment	   115
          4.6.2  Treatment Technologies	   117
                 4.6.2.1  Regional Availability of
                          Reference Technologies	   117
                 4.6.2.2  Treatment Efficiencies	   120
          4.6.3  Methodology for Determining Treat-
                 ability	   121
          4.6.4  Sample Problem	   127
     4.7   Ground-Water and Surface-Water Interaction	   130
          4.7.1  Ground-Water Discharge to Surface
                 Water	   130
          4.7.2  Surface Water Discharge to Ground
                 Water	   130
5 . 0  REFERENCES	   135
                                Xlll

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                     TABLE OF CONTENTS (Cont.)


APPENDIX A:  GLOSSARY	   A-l

APPENDIX B:  ALTERNATIVE OPTIONS CONSIDERED FOR
             DEFINING CLASSIFICATION KEY TERMS
             AND CONCEPTS	   B-l

APPENDIX C:  SAMPLE APPLICATION OF THE CLASSIFICATION
             PROCEDURES	   C-l

APPENDIX D:  TABLES OF DRASTIC FACTOR VALUE RANGES
             AND CORRESPONDING RATINGS	   D-l

APPENDIX E:  BACKGROUND DATA:  CLASS I AND CLASS III
             ISSUES	   E-l

APPENDIX F:  GENERAL CENSUS BUREAU INFORMATION;
             NATIONAL CLEARINGHOUSES FOR CENSUS DATA
             SERVICES; AND BUREAU OF THE CENSUS STATE
             COORDINATING ORGANIZATIONS	   F-l

APPENDIX G:  ECONOMIC TESTS FOR DETERMINING CLASS I -
             IRREPLACEABLE AND CLASS III -
             UNTREATABLE GROUND WATERS	   G-l
                                 xiv

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                        LIST OF FIGURES
                                                          Page


2-1  Conceptual Framework Between Ground-Water
     Classification Program Policies for Facility
     Siting, Engineering, and Operation	   5

2-2  Example of State Protection Systems	  9

2-3  Idealized Well Field Protection Zones in West
     Germany	  11

3-1  Summary of Ground-Water Classes	  17

3-2  Relationship of Classes, Key Terms, and Concepts	  18

3-3  Conceptual Classification Flow Chart	  19

3-4  Hypothetical Classification Review Area Showing
     Potential Class Determining Factors	  25

3-5  Illustration of a Hypothetical Classification
     Review Area	  28

3-6  Illustration of a Subdivided Classification
     Review Area	  29

3-7  Example Class I - Ecologically Vital Ground Water....  38

3-8  Example Class II - Current Source of Drinking Water..  40

3-9  Example Class II - Potential Source of Drinking
     Water	  42

4-1  Procedural Classification Chart	  47

4-2  Example of Geometry and Dimensions of the Proposed
     Expanded Review Area and For Karst Settings	  58

4-3  Hydrogeologic Sections Showing Flow Systems of
     Increasing Complexity with Type I Boundaries	  64

4-4  Example of Type 1 Flow Divide Boundary	  66

4-5  Example of Type 2 Boundary	  69

4-6  Example of Type 2 Boundaries Between Aquifers
     in a Sedimentary Basin	  71

4-7  Example of Type 3 Boundary Through an Unconfined
     Aquifer in a Coastal Setting	  76
                               xv

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                   LIST OF FIGURES (Cont.)

                                                          Page

4-8  Example of Type 3 Boundary in an Evaporite/Saline
     Water Setting	  77

4-9  Example of Type 3 Boundary Through Basin Fill in
     a Closed Basin/Arid Climatic Setting	  79

4-10 Examples of High Interconnection Between
     Ground-Water Unit and Surface Water	  81

4-11 Hypothetical Setting for Demonstrating the
     Subdivision of a Classification Review Area	  84

4-12 Hypothetical Classification Review Area	  85

4-13 Subdivision of a Hypothetical Classification
     Review Area into the Ground-Water Units	  86

4-14 Criteria for Class I - Irreplaceable	  89

4-15 Example Class I - Substantial Population	  92

4-16 Outline of Procedure for Analyzing Potential
     Institional Constraints to the Use of an
     Alternative Source of Water	 100

4-17 Test for Class I - Irreplaceable Ground Water	 105

4-18 Potential Evaporation Versus Mean Annual
     Precipitation in Inches	 108

4-19 Illustration of Drastic Mapping	 112

4-20 Illustration of Surface Water Recharge to Ground
     Water for the Edwards Aquifer, Texas	 132

4-21 Cross-Section of an Alluvial Aquifer Showing
     Surface Water Recharge from the Mohawk River	 133

4-22 Ground-Water Isotherms of Mohawk River Basin	 134
                             xvi

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                        LIST OF TABLES

                                                          Page

4-1  Classification Worksheet	   48

4-2  Range of Values of Hydraulic Conductivity and
     Permeability	   74

4-3  Uncommon Pipeline Distance for Different
     Populations	   94

4-4  Population Institional Constraints	   99

4-5  Drastic Range Rating for Depth to Water	  110

4-6  Summary of Operational Methods for Defining
     the Key Term "Highly Vulnerable" Ground Water	  114

4-7  RMCL & MCL Values for Selected Contaminants	  116

4-8  Health Advisories for Selected Contaminants in
     Water	  118

4-9  Application of Treatment Technologies in
     Public Water Supply Systems,  by EPA Region	  119

4-10 Description of Treatment Process	  122

4-11 Effluent Quality Working Table From Sample Problem..  128
                            xv 11

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          PARTI

BACKGROUND AND DEFINITION
 OF GROUND WATER CLASSES

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                            PART  I

                       1.0  INTRODUCTION

1.1  EPA's Ground-Water Responsibilities

     EPA currently administers more than eight statutes which
direct the Agency toward reducing or eliminating  threats to
ground water from  a  large  number and  variety of  sources.
This is  a  far from  simple  task  and is one which  commands a
major part  of the  Agency's budget and  personnel  resources.
Changes  in statutes and resulting regulations  have  occurred
in the past/ and will continue to occur  in the  future,  to
further manage these pollution sources.  Through EPA's long-
range planning  efforts  and,  more  recently,  an  agency-wide
direction  toward  overall  risk  management,   ground-water
protection on  a cross-media basis,  the second  "problem"  is
receiving increased attention.

     An  important tool in  this cross-program phase  was made
available in August  1984,  when EPA released its Ground-Water
Protection Strategy.   This Strategy represents  the  official
policy of  EPA in this field,  and followed  extensive debate
and  analysis within  EPA,  among  other  Federal  and  State
agencies, and with  the public.   The goal of  the  Strategy is
to maximize  and coordinate protection  functions,  both within
Headquarters and  the Regions.    It was not meant  to resolve
all of today's ground-water protection  issues,  but rather to
set up a framework for better overall protection.

     Ground-water   classification   was  introduced   in  the
Strategy as  a key element  in setting priorities  for regula-
tory action  prioritizing attention and  resource management.
As will  be discussed more  fully in Chapter 2.0,  classifica-
tion was deemed  essential, given  the potentially  enormous
numbers of pollution sources matched by the expense of clean-
up programs,  should contamination occur.

1.2  The Purpose of this Document

     This  document  provides  the  technical  guidelines  for
implementing  the  classification  system,  originally  estab-
lished in the Ground-Water Protection Strategy.   By following
the procedures and  methods outlined, ground water, which may
be affected  by  a  facility  or activity under  EPA review,  can
be placed within a relevant class or classes, representing an
implied hierarchy of protection.  While the use of the system
by EPA  programs  is  discussed  briefly  in  Section 2.3,  this
document should be  viewed  essentially as a  set of technical
guidelines for  ground-water  evaluation via  classification.

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Specific  management   strategies,   "standards",   and  other
program  related policies,  are  outside the  subject  of  this
document.

     It  is  also critical  to note  that EPA  will not,  as  a
result  of these  guidelines, the  Strategy,  or  its  current
statutory authorities, be classifying large segments of land,
aquifers, etc.,  in-advance  of  any specific  decision.   The
Agency, or the delegated/authorized States, will only classi-
fy the  ground water around  specific  sites or  areas  where  a
decision  related to  a permit, degree of  clean-up or regula-
tion, etc.,  is to be made.  These differences are highlighted
further  in Chapter 2.0.

1.3  Organization of this Document

     Chapter  2.0  provides additional background information
on  the   Ground-Water   Protection   Strategy,   including  the
rationale and  use  of  classification.    EPA's  site-by-site
approach  is also contrasted with broader areawide mapping and
classification  efforts.   The  remainder  of  the  guidelines
document  is  organized into  three  major parts.   Chapter 3.0
contains  an  overview  of  the  classification  system,  and
definitions and explanations  of Hey terms and concepts.   The
procedures  for classification  are  documented  in Part II,
Chapter  4.0.  This chapter is designed for potential users of
the  system;  whereas,   the  previous  chapters  provide  less
detailed  information  suited  for  general  interest.   Chapter
4.0  provides  a  step-by-step user's  manual,  covering the
recommended sequence of decisions,  corresponding data needs,
and  technical  methods  for  each.    A  series  of  Appendices
follows  in Part III and includes  a glossary (Appendix A) and
a  discussion  of  the  alternative  options  considered  for
defining  classification  key  terms  and  concepts (Appendix B) .
Appendix  C is  particularly relevant since it illustrates the
classification  procedures through  a series  of  sample  case
studies.   The  remaining  appendices  provide background in-
formation and important references for performing the classi-
fication procedures.

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                       2.0  BACKGROUND

2.1  Need for Ground-Water Classification

     The EPA Ground-Water  Protection  Strategy (August,  1984)
consists of four major elements:

     . Strengthen  State  Institutions —  through  technical
       assistance and State grants

     . Cope  with  Unaddressed  Sources  —  through  source-
       specific protection programs in cooperation with other
       EPA programs

     . Establish  EPA  Policy  for  Ground-Water  Protection—
       through  the   establishment  and   implementation   of
       protection policies

     . Strengthen EPA  Institutions — through the establish-
       ment of  Offices of  Ground-Water  Protection  at  Head-
       quarters and in the Regions.

     These guidelines  stem from the  third element,  and  the
need to  achieve greater consistency  in  the  various programs
at  EPA with ground-water  protection  responsibilities.   The
Agency  was concerned  that  the focus solely on  individual
polluting activities, rather than on the resource which might
be  affected, was  leading  to problems  with consistency.   Some
EPA programs tended  to factor-in ground-water considerations
to  a  greater  extent  than other programs.  Some  EPA programs
implemented specific statutes  which  themselves  held  a bias
toward  one medium,  such  as  surface  water,  in  a  way that
impacts on ground water were not fully assessed.  Complicating
the situation was the fact  that many of  these  programs  had
become well established in their methods of operation.

     In light of  these factors,  EPA adopted  a policy for the
Ground-Water  Protection  Strategy  that  "protection  should
consider  the  highest  beneficial use  to which  ground  water
having  significant water  resources  value  can  presently  or
potentially be  put."  This  "differential  protection" policy
acknowledges that some ground water  deserves unusually high
protection  due  to  their  current use,  relative  value  to
society,  and vulnerability  to contamination.    For  these
ground  waters  (Class  I),  management will  include  extra-
ordinary protective measures.   For most  ground waters  (Class
II), the very high "baseline" of protection inherent in EPA's
programs  will  be  applied.   Ground waters which  have  lower
value to society  for water supply  or  other disposal purposes
(Class  III),  would logically,  under  this policy,  require a

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different  management  approach.    Furthermore,  the  policy
asserts that  the extremes of the  system (i.e., Class  I  and
III)  should  be  restricted  to rather  infrequent  situations,
reflecting  the  importance  of  effectively  managing  ground
water for its best use.

     The Agency  recognized  that in-advance  aquifer classifi-
cation offers a community or State certain advantages from an
overall management perspective.  EPA  believes,  however, that
such decisions should be made at the state or local levels of
government.    The major purpose  of  these  guidelines  is,
however,  to  support  the site-by-site assessments typically
employed  in  EPA  permits,  impact  statements,  and  other  de-
cisions.   Differences  among such systems  are reviewed  in
Chapter 2.3.

     The Ground-Water  Protection Strategy established a more
protective  category   (Class  I)  than  had been in existence
prior to 1984.   This  more protective  category will be recog-
nized in a consistent way from program to program.  Class III
provides  for the formalization of  where  EPA programs  can
recognize  lower  resource values  —  i.e.,   not   sources  of
drinking water — either now or in the foreseeable future.

2.2  Guidelines Development

     The  development  of  these  guidelines  began  in  August,
1984, and  consisted  of three phases  —  definition, testing,
and  review.   Throughout  the  process,  the Office  of Ground-
Water Protection  (OGWP) worked closely with a guidelines work
group, consisting of representatives from several  states, EPA
regions, other EPA programs,  and the  U.S. Geological Survey.

     In the definition  phase, key  terms  and concepts related
to  the  classification scheme described  in  the Strategy were
analyzed  in  detail.    These included  key terms and concepts
such  as  "irreplaceable  source of  drinking water,"  "eco-
logically vital," "highly vulnerable," and "current source of
drinking  water."  Several  alternative  options  for defining
each  term were  drawn up,  along with data  requirements and
methodologies  for employing  each.   Many, of  the  alternative
options  were  derived  from approaches  used  by  other EPA,
state,  and  local programs to  address  similar  or  related
concepts.  Each  approach was examined with respect to its:

      . Consistency with  statutes,  other programs,  and with
       the overall intent of the Strategy;

      . Flexibility  for  accommodating  State  and  region-spe-
       cific  characteristics  or concerns;

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                           FIGURE 2-1
  CONCEPTUAL FRAMEWORK BETWEEN GROUND-WATER CLASSIFICATION AND
PROGRAM POLICIES FOR FACILITY SITING, ENGINEERING, AND OPERATION
 DIFFERENTIAL
  PROTECTION
    POLICY
GROUND-WATER
CLASSIFICATION
    SYSTEM
                          FACILITY SITING
                         AND ENGINEERING
                             FACILITY
                           OPERATION
                         OTHER PLANNING
                         AND EVALUATION
                                                      TAILORED
                                                    GROUND-WATER
                                                     PROTECTION

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     .  Arbitrariness;  and

     .  Potential difficulties or complexities  in implementa-
       tion.
     The next phase involved the preparation of detailed case
studies with which to test  the  initial  classification frame-
work.   Candidate  case  studies were canvassed  from  a variety
of sources and  a  small  workshop held to determine  the work-
ability of the  classification definitions and to  select the
most  relevant  and  representative samples  for the  guidance
document.  The  feedback from this phase led to  a  refinement
of the classification system and procedures.

     Finally, the project  focused on review and revision of
several drafts.   The public will review and comment on this
draft in late 1986.  Comments from the  public  review will be
factored into the development of  final  guidelines  in 1987.

2.3  Implementation in EPA Programs

     The Ground-Water  Protection  Strategy  provides  two key
insights on  implementation.   First,  the Strategy establishes
the  differential  protection  approach as an official Agency
policy.    Classification is  set  as the  primary  means  to
implement that policy.   Next, the Strategy  provides examples
of how classification may be used by specific EPA programs to
assist  in  framing  various  program  policies.   A  conceptual
schematic of this approach is shown in Figure 2-1.

     In  order  to  implement these  classification  guidelines
(which  are  not  themselves  enforceable  requirements),  EPA
programs will  need to  modify their specific  guidance docu-
ments and  regulations.   Decisions  as to how they  are to be
implemented  can  only  be  made  through  EPA  program office
actions, taking  into consideration  each  program's statutory
requirements.   Actual  implementation may be  different than
the  examples portrayed  in the  Ground-Water Protection Stra-
tegy due to changes in statutes and the need to be consistent
with  more  recent program policies.   The approach  cited for
the Resource Conservation and Recovery  Act  (RCRA)  program in
the  Strategy,  for  example,  was  presented  in the  framework
that  existed before the sweeping Hazardous and Solid Waste
Act Amendments  of 1984  (HSWA).   As  it  responds  to HSWA, EPA
will  develop  a coherent approach  to ground-water  protection
that  incorporates  such  Congressionally-mandated requirements
under  HSWA  as  the waste-specific "waste bans,"  location
guidance/standards,  liner/technology   standards,   and  cor-
rective  action requirements.    Differential   protection and

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classification will  also be  incorporated into  this broader
context.

     Two specific  rule-making actions have  been completed—
one for  Superfund,  and one under  the  Comprehensive Environ-
mental Response, Compensation and Liability Act (CERCLA,  or
"Superfund"),  and  one  for  radioactive wastes.   The  CERCLA
National Contingency Plan (NCP)  revised on November 20,  1985
(50 FR  47974)  establishes  the  process  for removal  and/or
remedial  actions  at  Superfund  sites (40  CFR Part  300).
Revised  Section  300.68(e)(2)  addressing  scoping of response
actions during remedial investigations includes an assessment
of  "(v)  Current and  potential  ground-water use  (e.g.,  the
appropriate ground-water classes under the system established
in the EPA Ground-Water Protection Strategy" to assist in the
determination of what type of action should be taken.

     EPA also cites the Strategy in its list of other Federal
criteria,  advisories,  guidance,  and  State  standards to  be
considered.  The list is found in the October 2, 1985, policy
on  CERCLA   compliance   with   other  Environmental  Statutes
(published as  an appendix to the preamble of the  NCP) .   The
policy provides  that  (among  other  things) the classification
factors  must  be  considered  in  remedial  action  if  it  is
pertinent.   If the Agency  finds that they  are pertinent in
response actions,  but  does  not use them,  or uses and alters
them,   the  decision  documents  must  state  the  rationale.
Guidance  manuals  for   implementing  the  new NCP are  under
development by the Agency.

     The  second  completed   implementation  action  is  the
release of the "Environmental Standards for the Management of
Disposal of  Spent Nuclear  Fuel, High-Level  and Transuranic
Radioactive Wastes."   EPA's  role under the overriding Atomic
Energy Act is very limited and is primarily standard-setting.
The final  rule  (40  CFR  Part 191;  released in  the Federal
Register  on  September  19,  1985)  includes  two  standards
relative to differential protection:

     . A drinking-water-related  standard  is  to  be applied to
       all locations if a "special source" of ground-water is
       present.  "Special  sources" are further defined  as a
       major subset within the Class I definition included in
       these guidelines.

     . A "total  dose"-related standard is to  be  applied at
       the boundary  of a "controlled  area"  for "significant
       sources of  ground water."   "Significant" sources are
       essentially  a  major  subset   within   the  Class  II
       definition included in these guidelines.

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     At this  time, conceptual  approaches to  implementation
are in  different  stages of development and  consideration by
programs  administering  all major  ground-water related  sta-
tutes in  EPA.   In permit-based,  "point-source"-type actions,
it  is  expected that  classification will  be essentially an
additional  step in site-specific  analysis.    Broader-based,
non permit/non-point sources are more problematic.   In farm-
by-farm application of  pesticides,  for example, there  is no
regulatory  mechanism  to  evaluate  each site-by-site  action.
EPA is  beginning  to consider the approaches  to implementing
differential protection and other  Strategy-related policies
for these broader  sources.  Again,  the  classification guide-
lines will  be  implemented as appropriate, given the overall
authorities of the Agency under specific statutes.

     Since neither the guidelines definitions nor the program
implementation  options  have been finalized,  it is  impossible
to predict  the  numbers  of EPA  classification decisions which
will result or be included in  each particular class.   Some
initial  analyses   have  been performed  utilizing  aggregated
(i.e.,   not  site specific) data on  gross  hydrogeological and
socioeconomic  characteristics  around a  subset of  over 1400
RCRA, CERCLA, and UIC facilities.  Assuming that the "quanti-
tative" options (all  denoted  as Option A  in  Section 3.0 and
4.0)  are  selected,   the  range  in classification  outcomes
covers:

     Class  I        5 to  11 percent
     Class  II       83 to 94 percent
     Class  III      1 to  6 percent

     Given  the different interpretation of  the "qualitative
options"  for Class I  terms (each  denoted as Option  B) , no
such analyses  could be performed.    It  is  important to note,
however,  that  these  estimates reflect   the  percentage of
classification  decisions  and  not   percentage  of  all  United
States  ground  water or aquifers.   Additionally,  these  esti-
mates were  made on the  basis of several assumptions regarding
individual  site  characteristics.  Sensitivity  analyses  show
that the  above ranges  in  percentage values  account for most
of the  uncertainties associated with these assumptions.

     It is  appropriate  to  note,   however,   that  well-field
protection  is  typically the "high  end"  of any classification
system  as  it  is  most  often  oriented to  current, important
public  water  supplies.    Potential drinking  water sources,
ecologically   vital  ground  waters,  and  low-quality,   non-
drinking  water sources  are not identified or managed in  such
systems.

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                                    FIGURE 2-2
                       EXAMPLE OF STATE PROTECTION SYSTEMS
                                     CRITICAL RECHARGE AREA
ZONING/LAND USE
 RESTRICTIONS
   CLASSIFIED
   GROUND WATER,
   SURFACE WATER
   WATERSHED
GROUND-WATER
DISCHARGE LIMIT
 WELL FIELD
 PROTECTION ZONE
                                                  PERMIT WAIVERS TO
                                                  ALLOW DEGRADED GROUND-WATER
                                                  (OLD INDUSTRIAL AREA)
            EXPLANATION

            	  ADMINISTRATIVE BOUNDARY

                •     WELL

            *m«li!'i'wml MOUNTAIN RIDGE

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     A final  note:   these  guidelines may not  be used  as  a
defense or guide to future settlements of Federal enforcement
or other  administrative  or  judicial cases unless,  or until,
specific programs issue implementing directives, regulations,
or  policies  on  how  these  concepts  are  to be applied  to
specific programs in a consistent manner with their statutory
authorities and mandates.

     2.4  Interaction  with  State   Ground-Water  Protection
          Efforts

     The EPA  Ground-Water Classification  system will  be used
as  an important tool  for  decision-making in  EPA  programs,
including  those  programs  delegated  to  the  states.    State
agencies responsible for ground-water management will not be
required  to adopt  the EPA  classification system or  another
system for  general state program  use.   State agencies imple-
menting delegated  or authorized EPA  programs will,  however,
need to use these classification guidelines as appropriate to
those programs.  Many states have, however, developed ground-
water  protection  approaches  that  are  tailored  to  their
particular  land  use  and  hydrogeologic  conditions   (e.g.
generic examples in Figure 2-2).  At this time,  at least hall
of the States have in  operation,  or under serious considera-
tion, some  form  of site-by-site or in-advance classification
system.

     It is  important to distinguish between these two generic
types of  classification  systems.   An in-advance or anticipa-
tory  approach to hydrogeologic mapping  or   aquifer  classi-
fication  is believed by many  to be  essential  for  effective
local ground-water management  (e.g.,  Conservation Foundation
1985).   Through  this process, geologic  and  hydrologic char-
acteristics  of  currently  used  or  potentially  available
ground-water  sources are assessed  through mapping,  computer
simulation, etc.  Plans for water use are drawn-up,  and land-
use controls  either  suggested and/or actually put into place.
These  controls may  be fairly  sweeping  in nature  and cover
industrial  siting,   housing development,  road   construction,
etc.

      Several  Western European countries implement the concept
of well-field protection zones  (Figure 2-3), often thought of
as the most pragmatic  approach to anticipatory  classification
of  public water-supply settings  (e.g., Milde,  et al, 1983).
In West Germany, for example, nearly  80 percent of the 14,000
well  fields in that  country have protection areas in-place or
in the process of being  established.  The  key protection area
is  located within  2 kilometers  (about  1.2 miles)  from the
well.  As in  most  such systems, only a portion  of the entire
                             10

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                       FIGURE 2-3
IDEALIZED WELL FIELD  PROTECTION  ZONES IN WEST  GERMANY
              (AFTER MILDE ET. AL.,  1983)
                                 -PHYSICAL LIMITS OF AQUIFER

                           •—WELL

                          1—WELL ZONE (10 METERS)

                    1—BOUNDING FLOW LINE

                   -FIRST PROTECTION ZONE BOUNDARY (50 DAYS TIME OF TRAVEL)

          !— BOUNDARY OF MOST DISTANT "iMPLEMENTABLE* PROTECTION ZONE (2 KILOMETERS)

    BOUNDARY OF OUTERMOST PROTECTION ZONE
                         11

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aquifer is given  the  "special" designation.   In Switzerland
the distances are shorter (minimum of 200 meters or about 650
feet);  those  in  the  Netherlands are  time-of-travel  based
(typically 10 and 25 years travel  time).   Well-field protec-
tion zones are  incorporated  in some state and  local protec-
tion systems;  most  notably,  in Florida  and the  New England
states.

     There has been  considerable  activity at  the  Federal
level in the area of enhancing State protection efforts.  On
June 19, 1986, the President signed  into law the Safe Drink-
ing Water Act Amendments of 1986.  This  law includes two new
ground-water provisions, the first of which,  (Section 1427),
is  a  demonstration  program   establishing  critical  aquifer
protection areas (CAPA) within Sole Source Aquifers.  This is
considered a program which  is limited in  extent,  and geared
to demonstrating techniques for protection of  certain impor-
tant ground waters.

     The second element of the Amendments requires the States
to  develop  programs to protect  the wellhead  areas of all
public water systems within their jurisdiction "from contam-
inants  that  may have  any  adverse effects  on  the  health of
persons."   These wellhead  protection areas  are  defined as
"any  surface  or  subsurface  areas  surrounding  wellfields
through which contaminants are reasonably  likely to move and
reach a well or wellfield."   EPA is required to issue techni-
cal guidance within  a  year  after enactment which the States
may  use (i.e., may  not choose to  use)  for determining the
extent of the wellhead protection areas.

     The Act specifies  that the following  elements be incor-
porated into State programs:

        Duties of State and  local agencies and  public  water
        supply systems in implementing the program

        Determination  of wellhead protection areas  for each
        public well

        Inventory  of  all  potential  anthropogenic  sources
        within the protection area

        A  program that contains  as appropriate,  technical
        assistance,  financial  assistance,  implementation of
        control measures,  education training  and demonstra-
        tion  projects   to  protect  the  wellhead  areas  from
        contaminants
                             12

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        Contingency plans  for alternative water  supplies  in
        case of contamination

        Siting considerations for all new wells

        Procedures for public participation.


     This program  must  be submitted to the Administrator  of
EPA within the three years after enactment and the States are
expected to implement this program  within two years after  it
has been approved by the Administrator.  The only effect on a
State  of  failing  to  submit  a  Wellhead  Protection Program,
however, is the loss of related funds.

     The provision  is  structured to give  all States maximum
flexibility in formulating their programs and the Administra-
tor will disapprove a  program only if it  is not adequate  to
protect public water  wells  from contamination.   Any  dis-
approval must  be  made  within nine months  of submittal;  and,
should  a  program  be  disapproved,  a  State must modify  the
program and resubmit their plans within six months.

     Once a program is approved, the Administrator shall make
50 to  90 percent match  grants to the State for costs for the
development and  implementation  of  the State program.   The
Congress has authorized $20  million for each  of  FY 1987  and
1988 and $35  million  for each  FY 1989 through 1991.  As  of
this date,  however,  no  funds for  FY  1987  have  been appro-
priated.

     It  is  appropriate  to   note,  however,  that  wellfield
protection is  typically the  "high end" of any classification
system, as  it is most  often oriented to  current,  important
public  water   supplies.   Potential  drinking  water sources,
ecologically  vital  ground  waters,  and  low-quality,  non-
drinking water sources  are not  identified or managed in such
systems.

     The important point  is  that anticipatory classification
is best performed and implemented by State and local govern-
ments  that hold  land-use  authority.    Under its  program,
existing statutes and budget  resources, EPA can only perform
site-by-site classification  as  part of its routine program-
by-program  effort.   The classification  system  outlined  in
this guidelines document  attempts to be generally consistent
with broader   anticipatory  classification  systems.   Unlike
anticipatory  classification, which  takes  many  years  (and
considerable technical and financial resources) to implement,
site-by-site classification can  be  rapidly factored into  EPA
                             13

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procedures in  a way that  is  legally consistent with Agency
authorities.   By taking this  approach, however,  EPA does not
wish to discourage anticipatory classification — an approach
which the Agency feels is a very useful one for effective re-
source management at the State and local levels.

     Since  a  cornerstone  of  the  Ground-Water  Protection
Strategy is fostering State-specific efforts,  EPA  is consid-
ering the  substitution  of State  ground-water classification
systems  for  the EPA  system wherever  possible.    Given past
program precedents, the State system will most likely need to
be  "equivalent to"  or  "at  least  as  stringent"   as  EPA's.
Since the  implementation of the EPA ground-water classifica-
tion system is still  in the  early  stages,  specific criteria
or  factors for such  evaluations have not  been determined.
Options  for Agency consideration, even though preliminary in
nature,  will  be examined over  the  course of  the  next year.
Institutional  mechanisms at  the Headquarters  and Regional
levels for reviewing such systems will also be considered.

     In  addition,  EPA will  be evaluating the legal basis for
incorporating State Wellhead Protection areas approved by the
Agency under the SDWA Amendments into its operating programs,
as well  as into this ground-water classification framework.
                             14

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     3.0  THE EPA GROUND-WATER CLASSIFICATION SYSTEM

     The  EPA  Ground-Water  Protection  Strategy  established
three general  classes of  ground water representing  a hier-
archy of ground-water  resource  values  to  society.    These
classes are:

        Class I - Special ground water
        Class II  -  Ground water  currently  and  potentially a
        source for drinking water
        Class  III  -  Ground  water not a  source  of  drinking
        water.

     The  classification  system  is,  in  general,  based  on
drinking water as the highest beneficial use of the resource.
Ground  water  does   serve other beneficial  uses,  such  as
manufacturing, electric  power generation,  livestock  produc-
tion, irrigation, and ecosystem support.   Most such  uses of
ground water will be encompassed in Class I or Class II, in
that water of a quality suitable for drinking will also be of
a  quality to  serve  as  a raw  water source  for  most other
beneficial uses.  Class  I does  include a  special non-drink-
ing-water component for "ecologically vital" ground water.  A
more  complete discussion  of the other  beneficial  uses  of
ground water is found in Appendix B.

     The  classification  system  is designed  to  be  used  in
conjunction  with   the   site-by-site   assessments  typically
conducted by the  EPA program  offices  in issuing  permits,
deciding  on  appropriate  corrective action, etc.   The Agency
does not have authority within its statutes to require states
to do broad-scale,  in-advance (anticipatory)  aquifer  mapping
or classification.    Those  states which  do choose to adopt
such tools will, of  course,  have a  key component  for  compre-
hensive resource management.  Anticipatory classification of
aquifers  is  one  nf  the ten  components of  a state comprehen-
sive  ground-water  protection  program  recommended  by  the
National  Ground-Water Policy Form  (Conservation  Foundation,
1985).

     The EPA Ground-Water Classification system allows EPA to
incorporate many of  the  same concepts  found in state  systems
into the  Agency's  routine case-by-case decision  making.   An
important surrogate for  in-advance  mapping employed  in  the
EPA  system  is the  Classification Review  Area.    This  is  the
area or,  in actual terms, the volume to which the classifica-
tion  criteria primarily  apply  and  is  explained more thor-
oughly in Section 3.2.
                          15

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     The  remaining discussion  in  this section  focuses  on
defining the  classes  and key terms  and concepts of  the EPA
Ground-Water Classification System.   Many technical terms are
used in  the descriptions,  a number  of which are  defined in
the Glossary (Appendix A).

     The class  definitions presented  in this document  have
evolved  from  those presented in the Ground-Water  Protection
Strategy.   While  there are no substantive  changes in the
class concepts,  the descriptions  are revised to reflect the
results  of the  guidelines development process.   For  this
reason,  the  reader  should  reference  those  parts  of  the
Strategy document  defining the  classification system primar-
ily for background purposes.

     Finally, it should  be noted that  the  Agency is request-
ing  public  comment  on all  these  terms  and  definitions.
Particular  attention  should  be placed on  the  approach to
defining three Class  I  terms:  "highly  vulnerable," "substan-
tial  population,"   and   "economically  infeasible."   Whereas
only one option  is presented for the bulk of the classifica-
tion terms, two options  are presented for each of these three
Class I defining terms.

3.1  An Overview of the  Ground-Water Classes and Subclasses

     The  EPA Ground-Water Classification  System  consists of
three  major classes.    Two  classes  are  subdivided into  sub-
classes,  allowing  for  the  refinement in  the hierarchy of
recognized  resource values  (Figure 3-1).   The classes and
subclasses  of ground water are differentiated using key  terms
and concepts.  The relationship between classes and key  terms
is illustrated in  Figure 3-2 and flow-charted conceptually in
Figure 3-3.

3.1.1  Class I - Special Ground Waters

       Class  I ground waters  are  resources of unusually  high
value.   They are  highly vulnerable  to contamination and are
 (1)  irreplaceable sources  of  drinking  water  and/or  (2)
ecologically  vital.  Ground water  may  be considered "irre-
placeable"  if it  serves a  substantial population,  and, if
delivery of comparable  quality and quantity of  water  from
alternative sources in the area would be economically infeas-
ible  or  precluded by institutional  constraints.   (It should
be  noted that  the Agency is  providing several  options for
determining these  factors,  so as to focus public  comment on
the best way of incorporating  these concerns in  classifica-
tion  decisions.)   Ground water may be considered "ecologic-
                              16

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ally vital" if it supplies a sensitive ecological system that
supports a unique habitat.

     It should be  noted  that a site located  in  a designated
Safe  Drinking Water  Act Sole  Source Aquifer  (SSA)  is  not
automatically placed  in  Class  I.   The criteria  for  SSAs  are
less rigorous than those of Class I.   Greater rigor is needed
for  classification since,  unlike  SSAs,  Class  I  will  be  a
decision-making factor in program regulations.  SSAs are only
considered at the Federal  level  under  financially  assisted
projects such as farm loans, rural water districts, etc.

     It is expected  that Class I decisions will  be  small in
number.   Such ground waters will  generally receive  extra-
ordinary  protection  due  to the  potential  risk  to  large
numbers of citizens dependent upon a source of drinking water
or the risk of further endangerment  to endangered or threat-
ened species dependent upon unique habitats.

     The key  terms and  concepts used to  distinguish  Class I
include:

         . highly vulnerable to contamination
         . ecologically vital ground water
         . irreplaceable source of drinking water
           - substantial population
           - comparable quality
           - comparable quantity
           - institutional constraints
           - economic infeasibility.

     3.1.2  Class II - Current and Potential Sources of
            Drinking Water and Water Having Other Bene-
            ficial Uses

     All non-Class I ground water currently  used,  or poten-
tially available,  for drinking water and other beneficial use
is  included  in Class II,  whether  or not  it  is particularly
vulnerable to contamination.   This class is divided into two
subclasses; current sources of drinking water (Subclass IIA),
and potential sources of drinking water  (Subclass IIB).

     Class  II ground waters  comprise the  majority of  the
nation's ground-water resources that may be affected by human
activity.  Class  II  ground waters  will generally receive the
very high level of protection which represents the "baseline"
of  EPA  programs.   It is assumed that  any ground water which
is  currently  used for drinking water will fall  in Subclass
IIA, unless Class  I  criteria apply.   Other ground waters are
considered potentially usable  as  a  source of drinking water,
                            20

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both from quality and yield standpoints (Subclass IIB), until
demonstrated otherwise.

     3.1.3  Class III - Ground Water Not a Potential
            Source of Drinking Water and of Limited
            Beneficial Use

     Ground waters that are saline, or otherwise contaminated
beyond  levels  which would  allow use  for drinking  or other
beneficial purposes, are  in this  class.   They include ground
waters  (1) with a total  dissolved solids  (TDS)  concentration
over 10,000 mg/1, or (2) that are so  contaminated by natur-
ally occurring conditions,  or by the  effects of broad-scale
human activity (i.e., unrelated to a specific activity), that
they cannot be cleaned up using  treatment methods reasonably
employed in public water-supply systems.

     Class  III  ground-water  units*  are  subcategorized pri-
marily  on  the  basis of their degree of interconnection with
surface  waters  or  adjacent  ground-water  units of  a higher
class.   In addition, Class III encompasses  ground waters in
those very rare  settings where yields  are insufficient from
any depth  within  the Classification Review  Area to meet the
needs  of  an  average size   family.    Such ground  waters,
therefore, are not potential sources of drinking water.

     The key terms  and concepts used to evaluate a Class III
decision include:

     .  interconnection  to  adjacent  ground-water units  (as
       defined in Section 3.3) and surface waters
     . treatment methods  reasonably employed in public water
       supply systems
     . insufficient yield.

     Subclass  IIIA  includes  ground-water  units which  are
highly  to  intermediately interconnected  to  adjacent ground-
water units of a  higher class and/or  surface waters.  These
may, as a result, be contributing to the degradation of the
adjacent waters.  They may be managed  at a  similar level as
Class  II  ground  waters  depending upon  the  potential  for
producing  adverse effects on  the  quality  of adjacent waters.

     The subdivision of  Class III represents a refinement in
the  classification   system  as  originally presented  in  the
Ground-Water Protection  Strategy.   Placing  shallower,  more
interconnected, ground waters in Class II, for example, would

*The concept of ground-water units is discussed in Section
 3.3.
                            21

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imply a  quality and  resource  value that  may not be  appro-
priate.   The Class IIIA designation in these cases provides a
clear  indication  that these  highly  interconnected  ground
waters are not in themselves sources of drinking water.

     Class IIIB  is restricted to  ground-units  characterized
by a low degree of interconnection to adjacent surface-waters
or  other ground-water  units of  a higher  class within  the
Classification Review Area.  These ground waters are natural-
ly isolated from sources of drinking water in such a way that
there is little potential  for  producing adverse  effects  on
quality.  They have low resource  values  outside of mining or
waste disposal.

3.2  Classification Review Area

     Classifying  ground  water  necessitates  delineating  a
segment  of ground  water to which  the classification criteria
apply.    Since  EPA  is not classifying  ground  water on  a
regional or aquifer-specific basis, an alternative to defined
aquifer  segments  is  needed.   This  is  the  Classification
Review Area.

     It  is  important to  understand that  the Classification
Review Area is delineated  as part of the site-by-site review
process.  It  is  a  review  area  and not a  regulatory area.   To
put it another way, EPA believes  it appropriate to look at a
broad area  for characterizing the  types of  ground  water  of
concern.  Regulatory  or permit controls will not be imposed
in  that  entire  area;  only  that  particular portion  or site
which is subject to the  EPA program which  is  utilizing the
classification for decision making.

     The  Classification  Review  Area  is  delineated  based
initially on  a  two-mile  radius  from  the boundaries  of  the
"facility" or the  "activity."   The  facility or activity may
be  physical   in  nature (e.g.,  the  edge  of  proposed surface
impoundment)  or  hydrogeologic  (e.g., the  edge  of contamina-
tion area).   The dimensions  of the Classification Review Area
can be expanded  in hydrogeologic  settings of intermediate to
very high ground-water  flow  velocities where these velocities
occur  over distances  greater than two  miles.    A detailed
discussion  of these  settings  and  procedures to  expand  the
review are provided in  Part  II, Section 4.2.

     Within  the  Classification  Review  Area,  a preliminary
inventory of  public supply wells, populated areas not  served
by  public supply,  wetlands,  and surface waters, is performed
as  described in  Part  II,  Section 4.1.    The classification
                            22

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criteria are  then applied to the  Classification  Review Area
and a classification determination made.

     Initially,  all  ground water  within the  Classification
Review  Area  is   assumed  to  be highly connected  hydr©geo-
logically to the activity (both vertically and horizontally).
This approach will always lead  to the highest class deter-
mination.   Where more hydrogeologic data are  available,  the
Classification Review Area can  be  subdivided to  reflect  a
more accurate appraisal of the interconnection  between  the
ground waters  associated  with the activity and other ground
waters  of  the Classification Review  Area.    This topic  is
presented in the  following section (3.3).  Where  the Classi-
fication Review  Area  is subdivided, a  decision resulting  in
several  ground-water  classes  could  result.    For  example,  a
disposal  well could   potentially   affect  all ground  water
through which the well  is constructed.   If the disposal well
penetrates  a  fresh water zone  in  order  to  inject into  a
deeper,  salt  water zone,  a classification decision for both
zones would be needed.

     Figure  3-4   illustrates  a  Classification  Review  Area
around  a proposed facility.   The site of  the  facility  is
approximately  500  feet in diameter.   Water supplies  in  the
Classification Review  Area  include  a  public water  supply
system well and  a densely settled area of private  wells.   A
river with  a  wetland  runs through the  review  area.   Each  of
these facts may  bear  on the decision of the class of ground
water.

     3.2.1  Technical Basis for Two-Mile Radius

     EPA examined three sources of data in  establishing  the
radius of the  Classification  Review Area.  The data provided
insight  into  the  length of  flow path over  which high degrees
of  interconnection occur.   In  addition, they indicate dis-
tances  contaminants   could  be  expected to  move   in  problem
concentrations should they be  accidentally introduced into
the ground-water system.  The data sources were:

        A survey of contaminant plumes  from investigations of
        existing spills, leaks,  and discharges

        A  survey of  the distances  to  downgradient  surface
        waters from hazardous-waste facilities

        Calculations  of  the  distances from  which  pumping
        wells draw ground water under different hydrogeologic
        settings.
                             23

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H
                                24

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     A  discussion of  this  data  and  its interpretation  is
provided in Appendix E.

3.3  Subdivision of the  Classification Review Area;  Concepts
     of Ground-Water Units and Interconnection

     Subdivision of the Classification Review Area is allowed
in order to recognize naturally occurring ground-water bodies
that may  have  significantly different use  and value.   For
purposes of  subdividing  the review area,  these ground-water
bodies, referred to as "ground-water  units",  must be charac-
terized  by  a  degree  of  interconnection (between  adjacent
ground-water  units)  such  that an  adverse  change  in  water
quality to one  ground-water  unit  will have little likelihood
of causing an adverse change in water quality in the adjacent
ground-water unit.  Each ground-water unit can be treated as
a separate subdivision of  the  Classification Review  Area.   A
classification  decision  is  made  only  for  the  ground-water
unit or units potentially impacted by the activity.

     The concepts of ground-water units and  the interconnec-
tion between adjacent  ground-water  units  are  particularly
important  to the application  of  the  classification system.
First,  the degree of interconnection to adjacent ground-water
units and  surface waters is a criterion  for differentiating
between subclasses of  Class  III ground waters.   Second,  the
delineation of ground-water units establishes a spatial limit
for classification and the application of protective manage-
ment practices.   Hydrogeologists  routinely assess the inter-
connection between bodies  of ground water for such  purposes
as designing water-supply systems,  monitoring  systems,  and
corrective actions of contaminated water.  Where ground-water
bodies are shown  to be poorly  interconnected, it is possible
to spatially distinguish between their use and value.  Waters
within a ground-water  unit are inferred  to  be highly inter-
connected  and,  therefore,  a  common   use and  value can  be
determined.  As a consequence,  it is  possible to selectively
assign levels of protection to specific ground-water units to
reflect differences in use and value.   Protection applied to
adjacent  ground-water  units  will  have  little  beneficial
effects.

     The identification  of ground-water units and the evalu-
ation of  interconnection between ground-water  units may,  in
critical  cases, require a rigorous  hydrogeologic analysis.
The analysis may be dependent upon data  collected  off site
that is  not part  of  the readily available  information nor-
mally used in a classification decision.   For these reasons,
the  acceptance  of  subdivisions  will be  on  a  case-by-case
                            25

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basis after review of the supporting analysis.   A discussion
of appropriate analyses is presented in Part II,  Chapter 4.0.

     3.3.1  Ground-Water Units

     Ground-water units  are  components  of the  ground-water
regime, which is defined as the sum total of all  ground water
and  surrounding  geologic media  (e.g.,  sediment  and  rocks).
The top of the ground-water regime would be the  water table;
while, the  bottom would be the  base of  significant  ground-
water circulation.   Temporarily  perched water tables within
the vadose zone (see Glossary) would generally not qualify as
the upper boundary of the regime.  The Agency recognizes that
upper and lower boundaries are sometimes difficult to define
and  must  be  based  on  the  best  available information  and
professional judgment.

     The ground-water regime can be subdivided into mappable,
three-dimensional, ground-water units.   These  are defined as
bodies of ground  water that  are  delineated on the basis of
three types of boundaries as described below:

     Type 1:  Permanent  ground-water  flow divides.    These
              flow divides should be stable under all  reason-
              ably foreseeable conditions,  including  planned
              manipulation of the ground-water regime.

     Type 2:  Extensive,   low-permeability   (non-aquifer)
              geologic units  (e.g.,  thick,  laterally exten-
              sive confining beds), especially where charact-
              erized  by  favorable  hydraulic head relation-
              ships  across them  (i.e.,   the  direction  and
              magnitude of flow  through  the low-permeability
              unit).    The  most  favorable  hydraulic  head
              relationship  is  where  flow  is   toward  the
              ground-water  unit  to be   classified  and  the
              magnitude  of the   head  difference  (hydraulic
              gradient)   is   sufficient   to   maintain  this
              direction  of  flow  under all  foreseeable con-
              ditions.  The integrity of the low-permeability
              unit  should not be interrupted by improperly
              constructed  or abandoned  wells,   extensive,
              interconnected  fractures,   mine  tunnels,   or
              other apertures.

     Type 3:  Permanent  fresh  water-saline  water  contacts
              (saline  waters  being  defined as  those waters
              with  greater than  10,000   mg/1  of  Total Dis-
              solved  Solids).    These  contacts  should  be
              stable  under all  reasonably  foreseeable con-
                            26

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              ditions, including planned  manipulation  of the
              ground-water system.

     3.3.2  Interconnection

     The  type  of  boundary  separating  ground-water  units
reflects the  degree of interconnection between  those  units.
Adjacent  ground-water  units  demarcated  on  the  basis  of
boundary  Type  2  are  considered to  have  a  low degree  of
interconnection.  A low degree of  interconnection  implies a
low potential  for adverse changes  in water  quality  within a
ground-water  unit due  to migration  of  contaminated  waters
from an  adjacent  ground-water unit.  A low  degree  of  inter-
connection  is  expected  to   be  permanent,  unless  improper
management causes the low-permeability  flow boundary  to  be
breached.  The  lowest degree of  interconnection occurs where
a  Type  2  boundary  separates naturally  saline  waters  from
overlying fresh waters (less than 10,000 mg/1 TDS),  and the
hydraulic gradient  (flow direction)  across the  boundary  is
toward the saline waters.

     Adjacent ground-water units demarcated on  the  basis  of
boundary Type 1 and 3 are considered  to have an  intermediate
degree of interconnection.   An intermediate degree  of inter-
connection  also  implies  a  relatively  low  potential  for
adverse  changes in water quality within  a  ground-water unit
due  to  migration of  contaminated  waters  from  an  adjacent
ground-water unit.   Type 3  boundaries, however,  are charac-
terized  by  a  diffusion  zone  of   fresh  water-saline  water
mixing that will  be affected by changes  in  water quality in
either  of the  adjacent ground-water units.   Type  2  and 3
boundaries are  also prone to alteration/modification  due  to
changes  in ground-water withdrawals and recharge.

     A high  degree of  interconnection  is inferred  when the
conditions  for a lower  degree  of  interconnection are not
demonstrated.   High interconnection of waters  is assumed to
occur within a  given ground-water unit and where  ground water
discharges into adjacent surface waters.   A high  degree  of
interconnection implies a significant  potential for  cross-
contamination of waters if a  component part of these settings
becomes polluted.

     3.3.3  Illustration of a Subdivision

     The  Classification Review  Area  depicted previously  in
Figure 3-4 may be subdivided based on  hydrogeologic consid-
erations to  narrow the focus of the  classification decision
to the ground-water unit  most relevant  to the facility.  For
example,  the  hydrogeology may consist  of two  aquifers sep-
                            27

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                       FIGURE 3-5
ILLUSTRATION OF A HYPOTHETICAL CLASSIFICATION REVIEW AREA
                       28

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                             FIGURE 3-6
    ILLUSTRATION OF A SUBDIVIDED CLASSIFICATION REVIEW AREA
                                                                    Public Water
                                                                      Supply
                                                                       W«H
   Wet I acids with
   Endangere
...'•"'•""Specie
                                                                    Ground-Water Unit
                                                                          /Boundary
                                                                            Lower
                                                                            Ground-Water
                                                                            Unit
                                 29

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arated by a thick, laterally extensive  aguitard,  as shown in
the cross-section in Figure 3-5.  If the aguitard is shown to
satisfy  all  the  criteria  for  a  Type  2  boundary,  then  the
Classification Review Area can be subdivided into two ground-
water units as  depicted in Figure  3-6.   For an  activity at
the surface,  the upper ground-water  unit would be  the most
relevant to the classification decision.  The  lower ground-
water unit  would  not be  considered relevant  and  could be
excluded from subsequent consideration  in the classification
process.

3.4  Key Terms and Concepts for Defining Class I

     As  mentioned  previously,  Class  I  encompasses  those
ground waters found to  be  hiahlv  vulnerable  to contamination
and defined  as  either  an  irreplaceable source  of drinking
water or as  ecologically vital around  water.   This section
presents an expanded  discussion  for  these,  as well as sup-
porting key terms and concepts.

     3.4.1  Highly-Vulnerable Ground Water

     Ground water which is highly vulnerable to contamination
is characterized  by  a relatively high  potential  for contam-
inants  to  enter  and/or to  be transported  within  the flow
system.   This concept for classification purposes, focuses on
the inherent hydrogeological characteristics of the Classifi-
cation  Review  Area.    Thus,   vulnerability  encompasses  the
leaching potential  of  the  soil  and/or  vadose  zone  and  the
ability  of  the  saturated  flow system  to move contaminants
over  a   large  geographic area  (not  just beneath  any  given
site).

     It  should be  noted that  the Agency  is  providing  two
options  for  operationally defining vulnerability.   Comments
on these, as  well as other approaches  for assessing vulner-
ability, will be  considered by the Agency in determining how
best to  incorporate this factor in classification decisions.
Both  approaches  recognize that  ground-water  vulnerability
occurs  in a  continuum  from very low  to very  high vulner-
ability, just as  soil leaching potential varies and  saturated
flow velocities vary  from  very low to very high.  Advantages
and disadvantages inherent in each option are provided.

     Option A focuses on the use  of the DRASTIC system  (Aller
et  al,   1985),  a numerical ranking  system developed  by the
National Water  Well Association,  under  contract to EPA.  The
DRASTIC  method examines seven  hydrogeologic characteristics
of an area:
                             30

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     D - p_epth to water table
     R - net Recharge
     A - Aquifer media
     S - Soil media
     T - topography
     I - Impact of the vadose zone
     C - hydraulic Conductivity of the subject ground-
         water flow system

     The  DRASTIC  method  can  be  performed  using  readily
available  information on  each of  the above-listed  charac-
teristics.   In most  cases,  for the purposes  of classifica-
tion,  no  new field  work,  drilling,  or  extensive  mapping
procedures  should  be required.   The method yields  a single
numerical value, referred to as the DRASTIC  index.

     A two-tier DRASTIC criteria is proposed within option A.
The tiers  are distinguished  according  to  hydrologic regions.
In  regions  where  estimated  annual  potential  evapotrans-
piration exceeds mean annual precipitation,  the DRASTIC cri-
terion for highly vulnerable is 120.   This is done to incor-
porate  some  regional specificity  based  on this  important
parameter.    In  regions  where  estimated  annual  potential
evapotranspiration does not exceed mean annual precipitation,
the  DRASTIC criterion for highly vulnerable  is 150.   Pro-
cedures for using DRASTIC  in the  context  of a classification
exercise are provided in Part II Section 4.5.

     The  use  of DRASTIC,  furthermore, is  commensurate with
the idea  that ground-water vulnerability  (for classification
purposes)  should not  vary according to the  type of activity
which  is being  evaluated.   Vulnerability  to  contamination
must,  for  the purposes  of  a  universal  classification,  be
independent of activity type.  Otherwise,  the class of ground
waters may change with  each activity; an approach  which is
inconsistent  with  state  efforts,  for  example.   Finally,  the
determination  of  vulnerability should not  be inferred as  a
prediction  of  contaminant  concentrations   due  to  facility
failure, or other contaminant release from the activity under
consideration.

       Among  the  various methods   considered,  DRASTIC  has
several advantages.   It  was  prepared using a Delphi approach
(a  consensus  building approach)  on a panel of practicing,
professional  hydrogeologists  familiar  with  the potential  for
ground-water  contamination across  the  nation.   It builds on
earlier  systems,  such as  those of  the Le Grand System (Le-
Grand,  1980)  and the Surface Impoundment  Assessment System
(Silka and  Sweringer,  1978).   It  is applicable on a regional
level  (i.e.,  several  square  miles), on par  with the size of
                            31

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the  Classification  Review Area.  Furthermore,  DRASTIC  was
designed to be  used with readily available,  regional  hydro-
geologic information.  And it was also designed  to overcome
the problems of more simplistic  methods  (e.g.,  single-crite-
rion  or  multiple-independent-criterion  system)   that  may
ignore  relevant  factors  or  the relative  importance  of  a
factor compared to other factors  (see Appendix B for discus-
sion of other approaches considered).  Yet,  it is relatively
simple to  use  and  includes the  primary factors  inherent to
the area-wide vulnerability concept implied in classification
decisions.

     A distinct disadvantage of requiring the use of Option A
is that it denies the user of the Guidelines the opportunity
to  consider  other  methods or  to exercise  full  freedom of
professional judgment where appropriate.   In addition, some
believe that the  DRASTIC method  may  oversimplify the charac-
terization of an area where the hydrogeology is very complex.

     Under Option B, users of the Guidelines could,  if they
wish, consider  the same parameters that  are  considered under
the DRASTIC approach, but  would not be compelled to use the
DRASTIC system  or the numerical cutoffs  set  forth in these
Guidelines  for determining what ground  waters  are "highly
vulnerable."    Rather,  those  classifying the ground  water
would take the various parameters into account in arriving at
a  professional  judgment  of   whether the  ground  water  is
"highly vulnerable."   The  advantage  of this  approach is that
it  provides  the  person classifying the  ground  water with
complete  flexibility  in  considering the  complexity  of  the
particular site being evaluated.   The disadvantage  of this
approach  is  that,   since  different  though  well-qualified
professionals may reach different  judgments under the same
set  of circumstances,  some  certainty,  predictability,  and
reproducibility is  sacrificed.

     3.4.2  Irreplaceable Source of Drinking Water

     A ground-water  source may be classified  as irreplaceable
if  it  serves  a substantial population, and,  if reliable de-
livery  of comparable quality  and  quantity  of water from
alternative  sources  in the   region would   be  economically
infeasible or precluded by institutional  constraints.   It is
important to emphasize that the  irreplaceability criterion is
a relative test in that  its goal is  to identify those  ground
waters of  relatively high  value  (compared to others).   As a
result, these  may deserve  to  be treated as  unique or "spe-
cial."  In order to  consider a  source of  ground water to be
irreplaceable,  several  factors  must  be  addressed in more
detail.   "Substantial population" must be considered for all
                            32

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assessments.  Where a substantial population is determined to
be present, other factors must be assessed including:
       .  uncommon pipeline distance
       .  comparable quality
       .  comparable quantity
       .  institutional constraints,
       .  economic infeasibility

     In  these  draft  Guidelines,  the Agency  is  soliciting
comment  on  approaches  to  judging  the  "replaceability"  of
current drinking water sources.  Two options are presented to
help  frame the discussion.   Option  A would  require,  among
other factors, a quantitative or semi-quantitative assessment
of  the population  served  by the  source  and the  economic
feasibility of replacing the source.  Option B incorporates a
qualitative  assessment  of the substantial  population/econo-
mically irreplaceable factors.  Under this approach, the size
of  the population served and  the cost of  using  alternative
sources would be evaluated,  but not with the use of preferred
methodologies accompanied by numerical cutoffs or  other set
criteria.

     This  section describes  the factors that must be  con-
sidered under either of the above alernatives and  how  they
would be used in making a determination of "irreplaceability"
under each alternative.   Since  Option A relies  on specific
techniques/cut-offs,  it  is  discussed  at  greater  length.
Section 4.3  in  Part II presents  a  more  detailed  description
of methodologies, in particular for Option A, with additional
background material being provided in the Appendices.

          3.4.2.1  Substantial Population

          Under   Option   A,  the   "substantial   population"
criterion can be met if at least 2500 people are served by:

           . well(s) on a public system (where the people live
            either  inside   or   outside   the  Classification
            Review Area), and/or

           . private wells  in a  densely  settled  area  (>1000
            persons/sq mi).

     Characteristics of U.S. public water-supply systems pre-
dominantly  using  ground water are described  in  the Federal
Reporting  Data  System (FRDS).   The system  was developed by
the U.S. EPA  Office of  Drinking  Water to provide  data on the
size,  characteristics,  and  compliance  of public water  sys-
tems.    FRDS data  shows  that  10  percent of  water-supply
systems  serve more  than 2500  people.   Thus, it  generally
                            33

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defines  areas  of potentially  high communal  risk.   That  10
percent, however, accounts for about 80 percent  of the total
U.S.  population served  by ground  water.    A more  detailed
discussion of the  size of water-supply systems  can  be found
in Appendix E.

     Under  Option  B  the  relative  size  of  the  population
served by  the  drinking water  source would  be one  factor  to
consider in  determining whether  a source  is "replaceable."
The size of the population served,  for example,  will have  to
be taken into account in determining the economic feasibility
of using alternative sources in the area.   Thus, rather than
using a  formula and specific cutoff as would be required  if
the first  approach were chosen,  the user  of the Guidelines
would  have the flexibility to  balance  various factors  in
determining whether a drinking water  source is "irreplace-
able."

          3.4.2.2  Uncommon Pipeline Distance

          Uncommon  pipeline   distance  means  a  reasonable
maximum  distance over  which  water is piped in the region  by
populations of  approximately the same size as the substantial
population  under  consideration  in the  classification  de-
cision.    The   concept  of uncommon pipeline  distance  was
included  in  the   irreplaceability  criterion  to  make  the
classification  process easier  to  implement.  This criterion,
although  fairly  general  in  nature,  provides   a means  for
estimating  the  limits  of the area within  which  potential
alternative water sources may be  located.   Without  such a
boundary, any water source in the country might be considered
a  replacement  for  any other  water source,  making  the irre-
placeability concept  unworkable.    This criterion  is appli-
cable  under  both Options  A  and  B.  A table presenting "un-
common  pipeline  distances"   based  on  analyses of  several
water-supply  systems  is  presented  in Table 4-3.    In  all
cases, this table merely provides general guidance and should
be taken qualitatively.

          3.4.2.3   Comparable Quality

          The  Agency  has defined  "comparable   quality"  in
terms of the quality of raw sources of drinking water used in
the area,  considering, in a  general way,  both  the types  of
contaminants that are present and their  relative concentra-
tions.    The  intent  is  to   make rough   order-of-magnitude
comparisons to  determine whether the potential alternative is
of the same general quality as the  source,  and as other water
used  for drinking  in  the EPA Region,  without  conducting a
                             34

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specific, parameter-by-parameter comparison.   This criterion
is considered in the same manner in both Options A and B.

          3.4.2.4  Comparable Quantity

          The Agency intends  "comparable  quantity"  to  mean
that the  alternative source  or  sources,  whether  surface  or
ground water, is/are capable of reliably supplying water  in
quantities  sufficient to meet the year-round needs  of the
population  served  by the  ground  water.    This  definition
considers only the needs of the population at the time of the
classification decision.  In developing their own classifica-
tion systems, states  may  choose, however, to consider modest
population  growth  and  increasing water  needs  over  time.
Again, this criterion would be considered in a similar manner
under both Options A and B.

          3.4.2.5  Institutional Constraints

          For  purposes  of   the  classification  system,  the
Agency defines institutional constraints as legal or adminis-
trative restrictions that preclude replacement water delivery
and may  not be alleviated  through administrative procedures
or market  transactions.  Institutional constraints  can elim-
inate  one  or  more  possible  alternative  sources  from  con-
sideration  (and,  likewise,  indicate which alternate supplies
are more viable than others)  and,  therefore, can necessitate
a Class I  irreplaceable  designation.   Such constraints limit
access to  alternative water  sources  and may  involve legal,
administrative, or other controls over water use.

     EPA has placed potential institutional constraints into
three categories:

      (1)  Probably   Binding  constraints   —  which  include
          treaties, agreements among states, and decisions by
          the  U.S.   Supreme Court  that  are  not  capable  of
          being revised through market transactions or simple
          administrative processes

      (2)  Constraints which may  possibly be binding — such
          as, when market transactions, or simple administra-
          tive  processes may not be able  to  provide  an
          alternative  source of water (e.g.,  limits  on the
          source or amount of water that are created by state
          law)

      (3)  Constraints unlikely to  be  binding  —  when market
          transactions,  or  simple  administrative processes,
          usually can ensure an alternative source of water.
                            35

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     These  factors  would be  evaluated in  a  similar way  in
both Options A and B.

          3.4.2.6  Economic Infeasibility

          To  frame  the  Agency's  consideration of  "replace-
ability"  for  classification purposes,  two options  are  spe-
cifically  presented for  public comment.   In  Option A,  an
alternative source  of  replacement water is economically in-
feasible  if the annual  cost  to a typical user would exceed
0.7 to 1.0  percent  of  the mean  household income in the area.
EPA  is  proposing a  threshold in this  range  and  is seeking
comment  on the  applicability of this  economic test and/or
other thresholds.   Appendix 6 provides  a detailed discussion
of these tests.

     Although  the  economic infeasibility  criterion suggests
an "ability to pay" measure, this does not mean that users of
the water  would be  expected to pay  for a  replacement source
in the highly  unlikely event  of contamination.   Rather,  this
approach  is intended solely  as a relative test  to identify
those waters deserving of special protection.

     This criterion does not require a rigorous analysis, but
rather a  general understanding of the  alternative source(s)
and  rough estimates of  replacement  costs.  To perform  this
analysis, data in the following areas are needed:

     . Physical  characteristics  of  the  alternative  water
       sources

     . Estimates of capital and operating costs for using the
       alternative source

     . Household incomes of the ground-water users.

In most  instances,  generally available data  will  be suffi-
cient  to apply  this test.   Simple,  inexpensive  estimation
techniques will be adequate.

     In  Option B,  the  cost  of  replacing a  drinking  water
source would  be one factor in  judging its "replaceability."
This  cost could be taken into  account along with  the  com-
munity's  ability and/or  willingness  to pay  for  alternative
water  sources in judging whether it is  truly economically
infeasible  to  replace  the  water.     Recommended  methods,
approaches, or criteria  would  not  be  incorporated  by guid-
ance.  Best  professional  judgement   in specific  situations
would be the basis  for decisions.  To cite one example, water
suppliers  in  some cases may  be "financially  constrained" in
                              36

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their ability  to provide  alternative  water.   These  limita-
tions could be addressed in a qualitative manner.

     3.4.3  Ecologically Vital Ground Water

     As  a  result  of the guidelines  development  process,
ecologically vital  ground water  (Figure  3-7)  is  defined as
supplying a sensitive ecological  system supporting a   unique
habitat.

     Underlined  in the  above  statement  are  the two  terms
which require  further  definition.    A sensitive  ecological
system  is  interpreted in  these guidelines as an  aquatic or
terrestrial  ecosystem located  in  a ground-water discharge
area.   A unique habitat  is   primarily defined  as a  habitat
for a listed or proposed endangered or threatened species, as
designated pursuant to the Endangered Species Act  (as amended
in  1982).   In some cases,  certain Federal land management
areas, congressionally designated and managed for the purpose
of  ecological  protection,  may  also  be  considered  unique
habitats  for  ground-water  protection,   regardless  of  the
presence of endangered  or threatened species per  se.   Among
those most likely to be included are:

     . Portions of National Parks
     . National Wilderness Areas
     . National Wildlife Refuges
     . National Research Natural Areas.

     A discharge area is  an  area  of land  beneath which there
is a net annual  transfer  of  water from the saturated  zone to
a  surface  water body,  the land  surface,  or the  root  zone.
The net discharge  is  physically manifested by  an increase of
hydraulic heads with depth  (i.e., upward ground-water flow).
These zones may  be associated with natural  areas of  dis-
charge,   such   as  seeps,   springs,  caves,   wetlands,  streams,
bays, or playas.

3.5  Key Terms and Concepts for Defining Class II

     Class  II  encompasses all non-Class I  ground water cur-
rently used, or potentially available,  for drinking and other
beneficial uses, whether or not it is particularly vulnerable
to  contamination.    Class II  has been  subdivided into  two
subclasses which comprise the major key terms:  current source
of drinking water and  potential source of drinking water.
                             37

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                        FIGURE 3-7
   EXAMPLE CLASS I  -  ECOLOGICALLY VITAL GROUND WATER
                    WHERE DISCHARGE AREAS'
^X                       ^&>C~ ••*-*'-~^-+.*.-;V*       OR PROPOSED ENDANGERED
                                                             ARE HABITATS FOR LISTED
                                                             OR PROPOSED ENDANGERE
                                                             OR THREATENED SPECIES
I
I
                                    V

            FACILITY

    \                            i            . '          \     ARE CONTAINED IN A
     \                          !          /  PFHFRAI  I     NATIONAL PARK, WILDERNESS
      \                         I ______    /     lAKinc   i     AREA, ETC. THAT IS MANAGED
        \                           I   ./
                                                   FQR |TS ECOLOGICAL VALUES
                           !       i
                           r       i
                           l	i
                           38

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     3.5.1  Current Source of Drinking Water

     Ground water is considered  a  current source of drinking
water under two conditions  (Figure 3-8).   The first and most
common  condition  is the  presence  of  one or more  operating
drinking-water wells (or  springs)   within the Classification
Review Area.   The second condition occurs in the absence of
wells or  springs, and  includes  ground-water discharge  to a
surface water reservoir used  as  a  drinking-water supply.  It
requires the  presence  within the  Classification Review Area
of a water-supply watershed reservoir  (or portion of a water-
supply  reservoir  watershed)  designated  for water-  quality
protection, by either State or local government.

     The concept  of a  current  source  of drinking water is
rather broad  by intent.   Only a portion  of  the ground water
in the Classification Review Area needs to be supplying water
to  drinking-water wells.   It should  also  be  noted  that a
current source of drinking  water,  which meets the irreplace-
able/ highly vulnerable  criteria,  is Class I.

     3.5.2  Potential Source of Drinking Water

     A potential  source of  drinking water in the Classifica-
tion  Review  Area is  one  which  is  capable of yielding a
quantity of drinking water to a well or spring sufficient for
the needs  of an  average  family.    Drinking water  is taken
specifically  as  water  with  a  total-dissolved-solids  (TDS)
concentration  of  less than 10,000 mg/1,  which can  be used
without treatment,  or   which can  be  treated  using  methods
reasonably  employed  in  a public  water-supply  system.   The
sufficient  yield  criterion  has  been  established  at  150
gallons/day  (see  Section 3.6.2  for the  rationale).   Ground
water not currently used  for  a source  of drinking water will
be classified as a potential source of drinking water, unless
demonstrated otherwise.

     An uppermost limit  of 10,000 mg/1  TDS was chosen for
several reasons.   Many State and  Federal programs  currently
use 10,000  mg/1 TDS  to distinguish  potable  from non-potable
water.   Some states  set lower  limits   because the  TDS of
drinking water is usually well below  10,000  mg/1.   A survey
of rural water  supplies (EPA, 1984),  for which ground water
was the principal source,  found  a maximum TDS  level  of 5949
mg/1.   Eighty-five percent of rural water-supply systems were
less  than  500 mg/1  TDS.   Given  the  range  of  TDS  values,
10,000 mg/1 provides the flexibility needed  in a nationwide
program.    It  also ensures that  other  beneficial  uses  of
ground water will receive substantial protection.
                             39

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                   FIGURE 3-8
EXAMPLE CLASS  II  - CURRENT SOURCE OF DRINKING WATER
    f
      / DRINKING WATER
    /        WELL
                                      >,
          x
 I
I
UNPROTECTED
WATERSHED
                   FACILITY
 \
  \
                    PROTECTED
                    WATERSHED
   \
      x
               DRINKING WATER
               SUPPLY RESERVOIR
                      40

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     Establishing  a minimal  yield  (i.e., to  wells  and
springs) in the definition  of potential  source is consistent
with  the  hierarchy  of  resource  values  reflected  in  the
classification scheme.   Areas where all  water-bearing mate-
rials fail the "sufficient-yield" criterion will have little,
if  any,  resource  value for  drinking  water and,  therefore,
fall into Subclass IIIA.

     By a de facto assumption, any ground water not a current
source of  drinking water will  be  classified as  a potential
source of  drinking water,  unless a  lower resource  value is
demonstrated.   This approach  was  chosen because  it enables
EPA  to  set a  minimum  Federal  "floor"  which provides  broad
protection while placing the burden of proof on the person(s)
interested  in  demonstrating  that  the  subject ground  water
meets the criteria for a lower class of ground water.  Figure
3-9  indicates  the  concept of a potential  source  of drinking
water.

               3.5.2.1  Water Quality/Yield Data Needs

               Specific data  needs for  water-quality testing
and water-yield testing were not established as  part of  the
Class II criteria.   The  general rule  is to presume,  in  the
absence of data, that the quality and yield of a ground-water
resource is sufficient  to meet the criteria for  a potential
source of  drinking water.    Where  the ground  water can be
demonstrated to fail   the  quality  or  yield  criteria,  the
result could be a Class III designation.

     3.5.3  Sufficient Yield

     The definition of  a potential source of  drinking water
implies a yield sufficient  to meet the  long-term basic needs
of  an  average  family by a well or  spring.    The sufficient
yield criterion was established at  150  gallons-per-day  (see
Section 3.6.2 for rationale).  In cases where the Classifica-
tion  Review Area   or  the   appropriate  subdivision  of  the
Classification Review Area  does not  contain  a  well or spring
routinely used  for drinking water,  and can be  shown to have
insufficient yield, then  a  designation  of Subclass IIIA,  for
the  ground  waters  in the Classification Review  Area or  its
subdivisions  (as  described  in  Section  3.6.2),  is possible.
As mentioned previously, unless it is demonstrated otherwise,
the  Classification  Review  Area  is presumed  to  meet  the
sufficient yield criterion.
                             41

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                               FIGURE 3-9
         EXAMPLE CLASS II - POTENTIAL SOURCE OF DRINKING WATER
                                                 xx
                                                       \
                                                          \
           I                     FACILITY                     j
           V           '          J
NO DRINKING WATER WELLS IN
CLASSIFICATION REVIEW ARE A, BUT'                    o            i            2 MILES
•  < 10,000 MG/L  TDS
•  TREATABLE IF CONTAMINATED
•  CAPABLE OF YIELDING WATER
   TO WELL OR SPRING
                                   42

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3.6  Key Terms and Concepts for Defining Class III

     The third class of ground water encompasses those waters
which are not potential sources of drinking water due to:

     1) salinity   (i.e.,  greater   than  10,000  mg/1  total
        dissolved solids),

     2) contamination,  either  by   natural  processes  or  by
        human  activity  (unrelated  to a  specific  polution
        incident), that cannot  be  cleaned  up using treatment
        methods  reasonably  employed  in public water-supply
        systems  (or economically treated).  or

     3) insufficient yield  at anv  depth  to provide  for the
        needs of any average-size household.

     Subclasses  are differentiated based  primarily on  the
degree of  interconnection to adjacent  waters  (i.e.,  surface
waters and/or ground water of a higher class).

     The key terms  and  concepts underlined  above are defined
in this section.

     3.6.1  Methods  Reasonably  Employed   in  Public  Water
            Treatment Systems

     Ground  water  may  be  considered  "untreatable"  if,  in
order  to meet  primary  drinking water  standards and  other
relevant Federal criteria or guidelines, treatment techniques
not  included  on a  reference  list  of  commonly  applied  tech-
nologies must  be  used.   The  focus  on public-water  system
techniques  (rather  than all  technologies)  was established in
the Ground Water Protection Strategy.  The reference list has
been designed  to account for  variations  in the  use,  avail-
ability, and  applicability of  treatment  technologies  in an
EPA  Region.   This  approach  is a  relatively  simple  decision
framework that does  not involve detailed  engineering or cost
analyses.  An optional  approach which focuses  on treatment
costs  compared  with total  system  costs   is  presented  for
review and comment in Appendix G.

     For application to the  classification system,  EPA has
made an  inventory  of all  known or  potential water- treatment
technologies and classified each as belonging to one of three
categories:

     . Methods  in  common  use  that  should  be  considered
       treatment methods reasonably employed in public water-
       treatment systems,
                             43

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     . Methods known  to be  in use  in a  limited number  of
       cases  that  may,  in  some regions  because of  special
       circumstances,   be considered  reasonably employed  in
       public water-treatment systems, and

     . Methods not in  use by public  water-treatment  systems.

     Methods  in  common use  include  aeration,  air  stripping,
carbon  adsorption,  chemical   precipitation,   chlorination,
flotation, fluoridation, and granular media filtration.

     Methods  known to  be  used  under special  circumstances
include:    desalination  (e.g.,  reverse  osmosis,  ultrafil-
tration,  and  electrodialysis),  ion  exchange,  and  ozonation.
In most  EPA Regions,   these  treatment methods should  not  be
considered  methods  reasonably  employed   by  public  water
systems.  In  certain EPA Regions,  because  of special ground-
water  quality or water  scarcity  circumstances,  they  may  be
considered reasonably employed.

     Treatment methods  not  in use by public water  treatment
systems include:   distillation and wet air oxidation.   These
methods are considered new  to water  treatment  although they
have been applied for industrial purposes in the past.  Since
their application  to water treatment is  experimental at this
time, they should not be considered treatment methods reason-
ably employed in public water systems.

     It  should  be stressed  that  some  techniques  such  as
granular media filtration are used by public water- treatment
plants  for  polishing   (e.g.,  final treatment).   These tech-
niques may  be insufficient  to adequately treat  for heavily
contaminated ground water.   In such cases,  where unrelated to
a  given  source  of pollution,  a  Class  III designation  is
likely.  In other cases where the listed treatment techniques
are in use and would be equally effective and insignificantly
more costly to apply to the  contaminant  under consideration,
the water would  be considered "reasonably  treatable" and not
Class III.

     Treatment capacity to  handle certain concentrations  or
combinations  of contaminants may not be employed in a region,
although  the basic  technologies  are available.    In these
cases, the optional economics-based tests may be preferential
to the reference technology approach.

     3.6.2  Insufficient Yield at Anv Depth

     In  order to  establish  Subclass  IIIA  on  the  basis  of
insufficient  yield,  two  conditions  must  be met within the
                              44

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Classification Review Area or  appropriate  subdivision of the
Classification Review Area.   These conditions are:

     (1) There are  no wells or  springs  used as  a  source of
         drinking water regardless of well yield.

     (2) All water-bearing units  meet  the  insufficient yield
         criterion.

     Given  variability in  regional aquifer  characteristics
and climate, a value of 150 gallons-per-day  was selected as
the cutoff  for sufficiency.  This level  of production should
be possible throughout the  year, in  order  to  qualify  as  a
potential source of drinking water.  The yield can be obtain-
able  from  drilled  wells,  dug  wells,  or  any other  method.
Agricultural, industrial, or municipal uses of these marginal
water-bearing areas would require significantly higher yields
than a  domestic  well and would,  therefore, be unable to use
this low-yield ground water as a water source.  The figure is
based on  a conservatively* low  yield below which it  is con-
sidered unlikely or  impractical  to support  basic  household
needs.

     In setting the sufficient yield criterion, EPA consulted
its own guidelines concerning water needs and  related waste
flows   for  single  family  dwellings.    EPA's  water-supply
guidelines  indicate  that per capita residential water needs
range from  50 to 75  gallons-per-day (EPA,  1975)  for a single
family  residence.   Waste flows from single  family  dwellings
using septic  systems average  45 gallons-per-day per capita
(EPA, 1980, page 51).  Using an average family size and a per
capita  water  need of approximately 50  gallons-per-day,  the
well-supply  criterion was established at approximately 150
gallons-per-day.    (Note that, to be on the conservative side,
this assumption  of household usage  is  the  lowest figure used
in these guidelines.)

     3.6.3  Interconnection as a Class III Criterion

     The  subclasses  of  Class  III  ground  water  are  differ-
entiated  in part by  the relative degree  of  interconnection
between these waters and those in adjacent ground-water units
and/or  surface waters.   A  discussion of  ground-water units
and the concept  of degrees of  interconnection is provided in
Section 3.3.  Subclass IIIA ground-water units are defined to
have  a  high-to-  intermediate degree  of  interconnection to
adjacent ground-water units or surface waters.  Subclass IIIB
ground-water  units  are defined  to  have  a  low degree  of
interconnection  to ground-water  units of  a  higher  class or
surface waters within the Classification Review Area.
                             45

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              PART II




DETAILED CLASSIFICATION PROCEDURES

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                           PART II

              4.0  CLASSIFICATION PROCEDURES

     The  previous  sections  provide   both  background  and
overview of the EPA ground-water  classification  system.   The
system  is  based on an analysis  of  data which  is  generally
available  from  published  sources,  telephone  or  in-person
contacts,  or  other program-related  sources,  such  as  permit
packages and  environmental  impact statements.   The need for
detailed information  on  the  hydrogeologic or  socioeconomic
properties  of an area will increase,  for example, where  a
Class  I or  Class III designation  is  possible,  or a  sub-
division of ground waters in the Classification Review Area
is  being considered.   In  the majority  of  decisions,  data
gathering and  interpretation will be simple and inexpensive.

     This chapter provides  a more in-depth discussion of the
actual  process of site-by-site classification.   The process
is  facilitated  through  a  classification procedural  chart
shown  in Figure 4-1.   A  corresponding  classification "work-
sheet"  (Table 4-1)  follows the sequence  of procedural  chart
steps.  Classification will typically begin with step one and
continue until a final class determination is made.  Both the
procedural  chart  and worksheet were developed  to  provide  a
systematic  approach   to   classifying  ground  water based  on
certain criteria, e.g., presence  of wells, ecologically vital
areas,  water  quality,   irreplaceability,  etc.    They  are
provided as suggested approaches  only, since a  given setting
may be more effectively handled  through  another sequence of
steps.

     It  is important  to  realize  that,  as  a result of the
classification  procedure, the  Agency  is  not classifying  a
specific ground-water region,  per  se.    The classification
process will  assist  the  EPA  programs in  such  activities as
permitting and corrective-action  assessments.  No mapped unit
will be generated, although a Classification Review Area will
be employed as an aid in the decision process.

     Lastly,  the  system  assumes  a  broad  definition  for
current  use as a source of  drinking water  (IIA).  In the
absence  of current use,  the  system will  lead  to  a  deter-
mination of potential  source  of drinking water  (IIB), unless
a  lower resource value   is demonstrated.   Other beneficial
uses of ground water will  be  considered  in  making Class II
determinations.
                             46

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47

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                         TABLE 4-1
                  CLASSIFICATION WORKSHEET
Step  Question/Direction           Response/Comment*
      Establish  Classification
      Review  Area   (CRA)  and
      collect   preliminary
      information.     Optional-
      Demonstrate   subdi-
      vision (s)  of the CRA

      Locate  any  ecologically
      vital areas in the  CRA.*
      Does the CRA or appropri-
      ate  subdivision overlap
      an   ecologically  vital
      area?

      .  Yes, go to next step
      .  No, go to Step 4

      Perform   vulnerability
      analysis.   Is the  CRA or
      appropriate subdivision a
      highly   vulnerable
      hydrogeologic setting?

      .  Yes,  then  the  ground
        water   is   CLASS   I-
        ECOLOGICALLY VITAL
      .  No. go to next step

      Determine   location   of
      well(s)  within the  CRA or
      appropriate subdivision.
      Does  the   CRA  or  appro-
      priate   subdivision
      contain well(s) used for
      drinking water?

      .  Yes, to to next Step
      .  No, go to Step 8
 *To be completed when performing classification.
**Steps 2 and 3  may be performed in reverse order.
                            48

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Step  Question/Direction           Response/Comment11


  5*  Inventory   population
      served by well(s).
      Does the well(s) serve a
      substantial population?

      .  Yes, go to next step
      .  No,   then  the   ground
        water  is  CLASS   IIA-
        CURRENT   SOURCE   OF
        DRINKING WATER

  6*  Unless proven  otherwise,
      the drinking water  source
      is  assumed to  be   irre-
      placeable.      Optional-
      perform  irreplaceability
      analysis.  Is the  source
      of    drinking    water
      irreplaceable?

      .  Yes, go to next step
      .  No,   then  the   ground
        water  is  CLASS   IIA-
        CURRENT   SOURCE   OF
        DRINKING WATER

  7   Perform    vulnerability
      analysis.  Is the  CRA or
      appropriate subdivision a
      highly   vulnerable
      hydrogeologic setting?

      .  Yes,  then  the   ground
        water   is   CLASS  I-
        IRREPLACEABLE SOURCE OF
        DRINKING WATER
      .  No,   then  the   ground
        water   is  CLASS  IIA-
        CURRENT   SOURCE  OF
        DRINKING WATER
*Under irreplaceability analysis Option B, Steps 5 and 6 are
considered qualitatively.
                            49

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Step  Question/Direction           Response/Comment*
  8A  Determine   location   of
      reservoirs within the CRA
      or   appropriate   sub-
      division.
      Does the  CRA or appropri-
      ate  subdivision  contain
      reservoirs    used   for
      drinking  water?

      .  Yes,  go to next step
      .  No,  go  to  Step 9

  SB  Determine   status   of
      watershed(s)   containing
      reservoir(s)   present  in
      the  CRA  or  appropriate
      subdivision.
      Does that portion of the
      water-shed designated for
      water-quality  protection
      overlap   the   CRA   or
      appropriate  subdivision.

      .  Yes,  then  the  ground
        water  is   CLASS  IIA-
        CURRENT   SOURCE   OF
        DRINKING WATER
      .  No,  go  to  next step

  9   Determine   yield   from
      ground-water   medium
      (total   depth    across
      CRA or appropriate
      subdivision).   Can   it
      yield 150 gallons-per-
      day to a  well?

      .  Yes,  go to next step
      .  No,   then   the  ground
        water  is  CLASS  IIIA-
        NOT   A   SOURCE   OF
        DRINKING WATER  (INSUF-
        FICIENT YIELD)
                            50

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Step  Question/Direction           Response/Comment11
  10  Determine   water-quality
      characteristics   within
      the  CRA  or  appropriate
      subdivision.
      Is   the  water   quality
      greater than  10,000  mg/1
      total   dissolved   solids
      (TDS)?
      (Note:  If  water  quality
      is  unknown,  then   this
      question must be  answered
      no.)

      .  Yes, go to Step 12
      .  No, go to next  step

  11  Are the ground waters  so
      contaminated  as  to  be
      untreatable?
      (Note:  If  water  quality
      is  unknown,  then   this
      question must be  answered
      no.)

      .  Yes, go to next step
      .  No,   then   the  ground
        water  is   CLASS   IIB-
        POTENTIAL   SOURCE   OF
        DRINKING WATER

  12  Perform   interconnected-
      ness  analysis.   Is  there
      a  low  degree of  inter-
      connection   between   the
      ground   water   being
      classified  and  adjacent
      ground  units or  surface
      waters within the initial
      CRA?

      .  Yes,  then  the  ground
        water  is  CLASS  IIIB-
        NOT   A    SOURCE    OF
        DRINKING   WATER   (LOW
        INTERCONNECTION)
      .  No,   then  the  ground
        water  is  CLASS  IIIA-
        NOT   A    SOURCE    OF
        DRINKING  WATER (INTER-
        MEDIATE-TO-HIGH
        INTERCONNECTION)
                             51

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4.1  Preliminary Information

     An overview  of basic information needs  for classifica-
tion is presented in this section.  More detailed discussions
are provided in the balance of this chapter as well as in the
Appendices.   The  collection of  preliminary  information  is
meant to  reflect  an approach to  classification  which begins
simply and  directly.   The data should be  collected from the
most current and best available sources.   It should include a
well/reservoir  survey,  demographic information,  and identi-
fication of ecologically vital areas.   Regional hydrogeologic
data will be required if an interconnection analysis needs to
be made.   Otherwise, a  general description of  the regional
geology,  geomorphology,  and  hydrogeology  would be  useful.
Again, the  emphasis is on available  information rather than
on detailed in-field analyses.

     4.1.1  Base Map of Classification Review Area

     The Classification  Review  Area is defined  by  drawing a
two-mile  radius  from  the boundaries  of  the  facility  or
activity  area.    An expanded  review  area  is allowed  under
certain  hydrogeologic   conditions of   intermediate-to-high
ground-water velocities.  These conditions and the procedures
to expand the  Classification Review Area  are  presented  in
Section 4.2.    This Classification Review  Area  may  be sub-
divided based on  a   hydrogeological analysis of interconnec-
tion between  adjacent  surface  waters and ground-water units
as   described  in Section  4.3.   A base map illustrating the
facility location,  and  the Classification  Review Area bound-
ary is, of course, a vital piece of basic data.

       4.1.2  Well Survey

       A well  survey should  include  the location,  use,  and
pumpage capacity  of  existing public water-supply wells  or
well  fields within the  Classification  Review Area.   Public
vater-supply  systems are  defined under  the  Safe  Drinking
Water Act as those  serving more than  25  persons  or with more
than  15 service connections.   Information  on  the well depth
and screened interval depth may be needed if a subdivision of
the  Classification Review Area is to be made.

     A detailed inventory of private residential wells is not
necessary.  As pointed out in Section 4.4, census data  (e.g.,
densly settled  areas) can  be  a  good estimation approach.  As
a preliminary  step, the delineation  of  areas not  served by
public water supplies,  and the  approximate number or density
                              52

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of homes in  the  area should be obtained.  The  simplest well
data to be  included are the estimated number of  wells pres-
ent, and  other general  characteristics  of private wells  in
the Classification Review Area.

     Well information may be obtained from water authorities,
public health  agencies,  regulatory agencies permitting well
drilling, well drillers,  or other  state  or local  entities.
Sources  of   the  data  should be  documented and,  where  the
information is not available, it should be so stated.

     Water-supply  reservoirs  designated  for  water-quality
protection  in  the  Classification Review  Area    need  to  be
identified and  described.   Again,  state and local  agencies
may be  utilized in  this  capacity.     Water-supply  reservoir
watersheds   designated  for  water-quality  protection  are
specifically recognized  in  the  ground-water  classification
system.

     4.1.3  Demography

     Information on  populations served by public  and private
wells  will   be  needed  if  it  is  apparent that  substantial
populations  may  be involved, which  could lead to a  Class I
decision.  A first-cut approximation for public supply wells
in the  area  can be made  by  dividing  the total  pumpage capa-
city  by the  typical  per capita consumption  rates  for the
region.  Estimates  of  the number  of private wells in densely
settled areas within the  Classification Review Area will also
be necessary.   Densely settled areas  can be  located on U.S.
Census Bureau maps.  Procedures for determination of substan-
tial population are provided in Section 4.4.

     4.1.4   Ecologically  Vital Areas

     Identification  of areas which may be candidate discharge
points  for ground  water is a first step in locating ecologi-
cally vital  areas.   Such areas may include springs, streams,
caves,  lakes,  wetlands,  estuaries,  coastlines,  embayments,
and playas.   Once these  candidate  discharge  areas  have been
identified  (since proving  discharge may  require  field stu-
dies) ,  the  presence of a habitat  for a  listed  or proposed
endangered or  threatened species  (pursuant to the Endangered
Species  Act  as amended  in 1982)  needs to be  examined.  The
location of  any  such areas,  or any Federal lands managed for
ecological values  within the Classification Review Area must
be  identified.   The  Regional  Office of  the  U.S.  Fish and
Wildlife Service and the  State Endangered Species coordinator
                              53

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or Heritage Program administrator  are  two sources for infor-
mation regarding unique habitats and/or endangered or threat-
ened species.   Information about  Federal lands may  also be
obtained  from  Federal land management agencies such  as the
National  Park  Service, U.S.  Forest Service,  and Bureau of
Land Management.  The presence  of  Federal lands is indicated
on most state and county road maps and U.S. Geological Survey
quadrangle sheets.

     4.1.5  Hydrogeoloaic Data

     Regional  hydrogeologic  information  will  be  needed,  to
some extent, in  order to perform a DRASTIC  analysis  for the
vulnerability criterion; estimates are needed on:

       depth to water
       net recharge
       uppermost aquifer media
       soil media
       topography (slope)
       vadose zone media
       hydraulic conductivity-of the uppermost aquifer.

     This  information is  typically reconnaissance in nature
and may  likely be obtained from county/regional reports and
also State geologic  surveys.    Pertinent  information  will be
obtained  from  U.S.   Geologic  Survey  cross-sections,  topo-
graphic maps,  stratigraphic  sections,  county  geologic maps,
and U.S. Department of Agriculture soil maps.

     If  interconnectedness  of  ground water  with  adjacent
ground units and surface waters is to be analyzed, additional
detailed hydrogeologic  information  is  necessary.  This might
include  descriptive   hydrogeologic  data,   aquifer test  data
from previous  studies,  semi-quantitative  flow nets,  computer
simulations, or other relevant  information.  This information
is  critical  for all Class  III   demonstrations.    Specific
considerations  for   interconnection  to  adjacent  water  is
described  in Section  4.3.

     The  best available  sources  of  published  hydrologic/-
geologic  information  are  the  U.S.  Geological Survey publica-
tions, State  geological surveys,  scientific books and jour-
nals, and U.S. Department of Agriculture county  soil surveys.
Data supporting facility permit applications, Clear Water Act
Section 208  studies,  as well as Environmental Impact State-
ments, may also be useful.
                             54

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     4.2  Conditions and Procedures for Expanding the Classi-
          fication Review Area

     Expansion of  the  Classification Review Area  is allowed
under certain hydrogeologic conditions.   The two-mile radius
may  be  insufficient for determining  the use  and  value  of
ground water  and  identifying  potentially affected  users  in
hydrogeologic conditions of intermediate to very high ground-
water  flow velocities  where  these  velocities  occur  over
distances much  greater  than  two miles.   In such  settings,
there is  a potential  for  activity-related contaminants  to
move beyond  a  two-mile  radius  in a  relatively short  time
frame,  especially  under  the influence  of large-scale ground-
water  withdrawals.    This  section  represents  qualitative
descriptions  of   those   hydrogeologic   settings   where  an
expanded review  area is appropriate,  and the  procedures  to
quantitatively  establish  the  dimensions  of  the  expanded
review area based on hydrogeologic characteristics.

     An expansion  of the Classification Review Area will  be
triggered  upon the  determination  that  the activity  under
review  occurs  within  two  hydrogeologic  settings.    Because
these settings  are  described qualitatively,  some  level  of
hydrogeologic information  will be  needed to match  the  real
settings to qualitative description.

     4.2.1  Hydrogeologic Settings

     Two hydrogeologic settings  have  been  identified  where
expansion of  the Classification Review  Area is appropriate.
They are:

     A.   Settings  (referred to as Karst  settings)  where the
         principle aquifer is  relatively shallow (<100m) and
         composed  of carbonate rocks,  with  a  well developed
         system  of  solution-enlarged  openings   (secondary
         porosity).  The solution-enlarged openings serve as
         the  main conduits  for  ground-water  flow  and are
         interconnected  into  distinct  but dynamic ground-
         water  basins  feeding a  complex  of  cave streams.
         These settings  are often referred to as karst  areas
         or karst  aquifers.   Flow through the conduit system
         is  extremely rapid,  as  much  as  1800  ft-per-hour
         (Quilan  and  Ewers,  1985) over long  distances,  in
         some cases  up to 15 miles.  Settings may be found in
         the  following  ground-water  regions   (after Heath,
         1984):
                            55

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          6.  Non-Glaciated Central Region
          7.  Glaciated Central Region
         10.  Atlantic and Gulf Coastal Plain Region
         11.  Southeast Coastal Plain Region, and
         15.  Puerto Rico and the Virgin Islands.

     B.  Certain settings (referred to as alluvial basin set-
         tings) where the general length of ground-water flow
         paths  are  significantly  greater  than  the  two-mile
         Classification Review  Area radius  (i.e., where the
         distance between  perennial streams is  greater than
         four  miles).    These  settings  are  predominantly
         alluvial basins and other basins  filled with uncon-
         solidated to semi-consolidated materials and are, in
         addition, characterized by:

            An unconfined aquifer as the dominant aquifer

            Losing streams  as  the predominant source  of re-
            charge

            Transmissivities  and  flow velocities  that  are
            moderate to high (>250 m2/d and >60 m/yr, respec-
            tively)

            Relatively  low annual  rain fall  (less  than  20
            inches)

         The ground-water  regions (after Heath,  1984)  where
         these settings can be found include:

         2.  Alluvial Basin Region
         3.  Columbia Lava Plateau Region
         4.  Colorado Plateau and Wyoming Basin Region
         5.  High Plains Regions, and
         6.  Non-Glaciated Central Region.


     4.2.2  Expanded Classification Review Area Dimensions

     The dimensions  of  the  expanded review area are governed
by the hydrogeologic characteristics  of  the region.   Flow-
system  boundaries,  flow direction,  and flow velocities are
the key characteristics.

     For Setting  A,  karst  areas,  the  expansion area dimen-
sions  will  be  based  on  boundaries  of  the  ground-water
basin(s) encompassing the  activity.    A  basin  includes all
                              56

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recharge  areas  supplying the  cave stream  extending to  the
perennial  stream where  the cave-stream  discharges.    These
basins can be mapped using dye-tracing studies and  a water-
level map.  However, due to the  expense of  such studies,  few
basins have been mapped.  As a  surrogate,  it  is recommended
that the distance to the nearest spring-fed, perennial stream
be employed to  establish the expanded review-area dimensions
as shown  in Figure 4-2.   The reviewer  is cautioned  that, in
some  cases,  the nearest  perennial  stream may  not be  the
discharge for the  subject ground-water  basin.   Such  an error
can be minimized by locating the topographic high (the water-
shed  divide)   between the  nearest  perennial  stream    and
adjacent streams.  If the activity is on the same side of the
topographic high as  the  nearest  perennial stream, then it is
reasonable to assume that the nearest perennial stream is the
discharge.  If  not, then the  discharge is likely to be the
perennial steam on the same side of  the  topographic high as
the  activity/facility.    In  rare  cases,  the  activity  or
facility is located on the topographic high.  In such a case,
the  expanded   review  area  should  extend  to  the  nearest
perennial stream on all  sides of the topographic high.

     For  Setting B, alluvial  basins, the  dimensions  of the
expanded  review area are  based  on the  average ground-water
flow velocity within the basin.  The radius is to be extended
to a  distance that ground water will flow  in  a period of 50
years.   For example,  if flow velocities averaged  400 feet-
per-year,  then  the  expanded  radius  would be  20,000  feet,
approximately  four miles.   In  the event  that ground-water
flow velocities are unknown, an expanded radius of five miles
is recommended.

     Ground-water  flow velocities  range over several orders-
of-magnitude.   The highest  velocities are those of the karst
cave  streams.   In alluvial basins, it  will be unlikely that
flow velocities as high  as  one mile a year will occur except
over very short distances not representative of flow through-
out the basin.

     The  dimensions  of  the  expanded  review area  can  be
modified  to  account for the direction of  flow.   Where flow
direction  can  be  reliably  determined,  only the  downgradient
portion  of the expanded review  area  need  be  examined.   The
expanded  review  area  can  also  be subdivided  according to
rules  outlined  in Section  4.3.   Examples of expanded Classi-
fication Review Area for both a  Karst setting and an  alluvial
basin  setting are provided in Appendix C case studies 10 and
11, respectively.
                              57

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                    FIGURE  4-2
EXAMPLE OF GEOMETRY AND DIMENSIONS OF THE PROPOSED
      EXPANDED REVIEW AREA  FOR  KARST SETTINGS
 EXPLANATION

 PROPOSED FACILITY
                           58

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4.3  Subdivision of the Classification Review Area;  Identifi-
     cation  of Ground-Water  Units  and Analysis  of  Inter-
     connection Between Ground-Water Units
     The ground-water  regime defined in  Chapter 3.0 can  be
subdivided  into  three-dimensional,  mappable  ground-water
units.   The  Classification Review Area,  regardless  of  size,
may be  subdivided to  allow more  precise definition of  the
specific ground-water  units where classification should  be
focused.  This  chapter presents the methods and examples  by
which  subdivisions   are identified  and  how  the  degree  of
interconnection between the subdivisions is analyzed.

     Subdivision  of  a  Classification  Review Area  may  be
carried  out  to  separate ground-water units  having different
use  and  value   and,  therefore,   are  subject  to  different
degrees  of protection.   For example, the subdivision  of the
Classification Review  Area will be necessary  to justify the
following types of conclusions:

         Deep  ground-water  units  with Class  IIIB water  are
         overlain at  shallow  depth by ground-water units with
         Class I or II water,

         The  ground-water  unit associated  with an  activity
         does  not discharge  to  an  ecologically vital  area
         present in the Classification Review Area,

         A  shallow,   ground-water   unit  that  is a  potential
         source of drinking water  (Class  IIB)  is underlain by
         a deeper ground-water  unit that  is currently used as
         a source of  drinking water  (Class IIA)


     Having  identified  the ground-water units  within  the
Classification  Review  Area,  the  user  of  this document  is
ready to classify  the waters within the  units in accordance
with  the methods  set  forth in  other  sections  and schema-
tically  summarized  in  Figure  4-1.   The  interrelationship
between  ground-water unit  subdivisions and the classification
of ground water are  as  follows:

      .   All  ground   water  within   a  ground-water unit  has a
         single class designation.

         Boundaries   separating  waters  of different  classes
         must coincide with boundaries of  ground-water units,
                              59

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        One or more adjacent ground-water units  may have the
        same class designation.

     Ground-water units are delineated on the  basis of three
types of boundaries described below:

     Type 1:  Permanent  ground-water flow  divides.    These
              flow  divides   should  be  stable   under  all
              reasonably  foreseeable  conditions,   including
              planned   manipulation  of   the   ground-water
              regime.

     Type 2:  Extensive,   low — permeability   (non-aquifer)
              geologic units  (e.g., thick,  laterally  exten-
              sive confining beds),  especially where charac-
              terized by  favorable hydraulic  head relation-
              ships across  them  (i.e.,  direction and  mag-
              nitude  of  flow  across  the   low-permeability
              geologic unit).   The most favorable hydraulic
              head relationship  is  where flow is  toward the
              ground-water  unit  being  classified  and  the
              magnitude  of  the  head  difference  (hydraulic
              gradient)    is   sufficient   to   maintain  this
              direction   of   flow   under   all   foreseeable
              conditions.   The integrity of  the  low  perme-
              ability  unit  should  not  be  interrupted  by
              improperly  constructed  or   abandoned  wells,
              extensive,   interconnected   fractures,    mine
              tunnels or other apertures.


     Type 3:  Permanent  fresh  water-saline  water  contacts
              (saline  water  defined as  those  waters  with
              greater  than  10,000  mg/1 of Total  Dissolved
              Solids).  These contacts should be stable under
              all reasonably  foreseeable conditions,  includ-
              ing  planned manipulation  of  the  ground-water
              regime.

     The degree of interconnection between ground-water units
is  related to  the  type of  boundary.   A high  degree  of
interconnection  is  assumed for  all waters within  a  single
ground-water unit.   Adjacent units that are  separated  by a
Type  1  (ground-water flow  divide)  or Type 3  (fresh  water-
saline water contact)  boundary have an intermediate degree of
interconnection.  Adjacent units separated  by  a  Type 2  (low-
permeability geologic unit)  boundary  have a  low  degree  of
interconnection.
                           60

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     The degree of interconnection across  the  three boundary
types  defined here  depends  on  selected  key  physical  and
chemical processes governing movement of water and dissolved
solute  in  the subsurface.   Under steady/state  ground-water
flow conditions the principal  mechanisms effecting potential
contaminant movement across Type 1 (ground-water flow divide)
or Type 3  (salinity difference) boundaries would be mechani-
cal dispersion and chemical diffusion.  These  conditions are
considered  by EPA  to represent  an  intermediate degree  of
interconnection.   Under  transient flow conditions  caused  by
pumpage or  accelerated recharge of fluids within the Class-
ification Review  Area,  there  exists  the  potential  to  spat-
ially  displace  a ground-water flow  divide  or  saline/fresh
water interface boundary.  For this reason EPA believes that
foreseeable changes in aquifer stresses and increased ground-
water use  in the Classification  Review Area should  be con-
sidered in  determining the permanence  (i.e.,  location over
time) of such boundaries.

     The primary mechanism for contaminant  transport across a
Type 2 boundary is the physical movement of ground water into
or  from the low-permeability geologic unit.    The  Agency
recognizes  that   the  physical and chemical processes that
control fluid and solute  transport through  low-permeability
non-aquifers  is not as well understood as it is for aquifers.
However, for the  purposes of  assessing the  degree of  inter-
connection,  one must  be  able  to infer that  the  flow rate of
water through the non-aquifer is very  small relative to the
flow rates through adjacent aquifers.

     The following  subsections present further  guidance and
examples  on  how  boundaries between  ground-water  units are
identified.

     4.3.1   General   Hydroaeoloqic  Information  Needed  for
             Identifying  Ground  Water  Units  and  Analyzing
             Interconnection

     The  information  required to  subdivide  the  ground-water
regime  into  ground-water  units  generally  includes   topics
within  the fields of geology, hydrology,  and  management of
ground-water resources   (controls  on  withdrawals/recharge,
properly  abandoning  deep  wells,  etc.).    The  description of
the  ground-water  regime  and any  potential subdivisions must
be  as  quantitative  as possible.   The Agency recognizes that
the  degree  of precision  with  which the Classification  Review
Area  can  be  subdivided  is   limited  by  the  abundance and
quality of readily available  data.   Supplementation of the
existing data base with  field and laboratory investigations
both on-site and  off-site  may  be needed to accurately confirm
                             61

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the existence of subdivisions.  The following discussion will
serve to guide the types of data collection efforts needed to
justify the subdivision of the Classification Review Area.

     Background   information   on  geologic   formations   and
occurrence/movement  of ground  water can  be  obtained at  a
regional scale  of accuracy from State and  Federal agencies.
Topographic  maps  published  by  the U.S.  Geological  Survey
(USGS)  are  now available  at  useful scales  for most  of  the
nation.  These can help identify ground-water flow directions
and  flow divides  for the uppermost aquifer.   Data  on  the
distribution and  characteristics of  soils  are available from
the USDA Soil  Conservation Service.  General information on
precipitation,   run-off and  recharge rates  can be  obtained
from the USGS  and can be  supplemented by  climatic data from
weather  stations  around the  country.    Ground-water pumpage
and locations/depths  of wells can  generally be obtained from
State agencies  that  issue  well  permits,  or from local Public
Health Agencies and water districts.

     The first step  is  to  identify all  aquifers occurring
within  the  ground-water  regime of  the  Classification Review
Area.   In  areas  that have been well  studied these  will be
recognized and documented in government agency  reports.   In
poorly  studied areas, proper recognition of  aquifers can be
inferred from  lithologic descriptions of geologic formations,
structural  features  of the area  (if flow  is mainly through
fractured  rock),   and the depth and design  of wells.   The
areal and  vertical extent of hydrogeologic  units  within the
ground-water regime  can be shown  in a  series of  cross-sec-
tions and  maps.  For most hydrogeologic settings  it will be
most useful to  interpolate between locations where conditions
are  known   (i.e., wells,  outcrops, excavations,  etc.)  and
present  variations in thickness and elevations of important
units with contour maps prepared at  a common  scale.

     After the  identification and graphical representation of
the  geologic  framework  it is  possible  to  identify ground-
water units within the ground-water  regime using the guidance
provided in subsequent sections.

     4.3.2  Type  1 Boundaries;  Ground-Water  Flow Divides

     The concepts of  ground-water  flow systems may  not be
familiar to some  readers and needs to be reviewed in order to
understand flow divide boundaries between ground-water units.
Figure  4-3(a)   shows  in  vertical  cross-section a  series of
adjacent  shallow  ground-water flow systems  for  a  single-
layer,  water-table aquifer.   The systems are bounded at the
base by a  physical  impermeable  boundary.   As  is  typical in
                               62

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humid  regions,  the  water-table  profile  conforms  to  the
topographic profile.

     The flow net in Figure 4-3(a)  clearly shows that ground-
water flow occurs from the recharge area  in the highlands to
the discharge areas in the lowlands  (i.e.,  valleys).   Verti-
cal line  segments  AB and CD  beneath  the valleys  and ridges
constitute  ground-water  flow  divides,   i.e.,   imaginary  im-
permeable boundaries  across which  there is no  flow.   In the
figure,  these ground-water  flow  divides  separate  adjacent
flow systems  ABCD  and ABEF which,  for purposes  of subdivi-
sion,  correspond to ground-water units  separated by  Type 1
boundaries.

     In  simplified,  symmetrical  systems such  as  those  il-
lustrated  in  Figure 4-3(a),  ground-water flow  divides coin-
cide exactly with surface water divides and extend vertically
to the base of the  aquifer.   In more  complex topographic and
hydrogeologic settings these  properties  may diverge substan-
tially from the situation, illustrated.

     A comparison of Figures 4-3(a) and 3(b) reveals how flow
patterns and divides  are altered when the undulations in the
water  table  are  superimposed  on  the  regional  hydraulic
gradient towards a  more  regional stream  and discharge area.
Ground-water flow divides in Figure 4-3(b) extend through the
full  thickness of  the aquifer only  at either  end  of  the
entire flow regime.   The  full dimension of  the  flow regime
may or may not be  encompassed by the two-mile radius.   The
total  length,  S  in the figures, can range  from  hundreds to
thousands of feet.

     Figure 4-3(c)  is an  example of  more complex conditions
in which  the  flow  patterns and  flow  systems are effected by
both topography and  regional  variations in hydraulic conduc-
tivity of layered earth materials.  Given adequate data, com-
puterized models of  real sites can provide approximations of
ground-water flow patterns.  In  general, the level-of-sophis-
tication  employed  to demonstrate  the presence of a  Type 1
boundary  should  be  comensurate with the complexity  of the
hydrogeologic setting.

     The spatial location of the water-table and ground-water
flow divides may be stable under natural flow conditions but
can  be  modified by  man-made  hydraulic  stresses,  such  as
large-scale  ground-water  withdrawals or  recharge.   In some
cases  it will  be necessary to estimate the permanence  (i.e.,
location with time) and position of ground-water flow divides
under    stressed conditions  from  available hydrologic  and
geologic data and foreseeable changes in water  use.
                            63

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                                     FIGURE A-3
                  HYDROGEOLOGIC SECTIONS SHOWING FLOW  SYSTEMS OF
                   INCREASING COMPLEXITY WITH TYPE  1 BOUNDARIES
                               - RID6E TOP FLOW DIVIDE
                                                           LAND SOUf ACE
                                                            WATER TABLE
                           TYPE I  BOUNDARIES
      a)   Simple flow  systems associated with a water-table aquifer
          (after Hubbert,  1940).
     0.2S
 TYPE
BOUNDARY
       0
           DISCHARGE TO
           REGIONAL STREAM
           AND WETLANDS
                                  DISCHARGE TO
                                  GAINING STREAMS
        0
01S    0.2 S  03S   04 S    055   06S   07S   0.8 S   09S
                                                                I—TYPE I
                                                                 BOUNDARY
     b)  Ground-water flow pattern  in a water-table  aquifer with local  and
         regional discharge areas  (after Freeze and  Whitherspoon, 1967).
    0.2 S
     0.1 S -
 TYPE 1
BOUNDARY
                                                                —TYPE  I
                                                                 BOUNDARY
        0     0.1 S   0.2S   03S   0.4S   0.5S   0.6S   0.7S   0.8S   0.9S
     c)   Ground-water flow  pattern in dipping  sedimentary rocks with local
          and regional discharge areas (after Freeze and Whitherspoon,  1967).
                                         64

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     A good example of ground-water units separated by a Type
1 flow divide boundary  is shown in Figure 4-4,   The  setting
illustrated consists of two alluvial valleys  with high-yield
wells completed  in sand  and gravel  deposits,  separated  by
sandstone bedrock  that  can only provide limited  supplies  to
domestic wells.   Ground water in the alluvium is derived from
precipitation and  from the  bedrock,  and  discharges  to  the
river under  natural conditions.   Under pumping  conditions,
the water pumped by the high-yield wells  is  derived  largely
from  the  river,   from  local  precipitation,  and  from  the
bedrock.   Near the wells  in the eastern valley,  flow system
boundaries are affected by ground-water withdrawals  and  are
stable as long  as  the  well  discharges  are  steady.    The
ground-water flow  divide  separating the two  valley aquifers
is  not  effected  by  pumpage,  and  provides  the  essential
characteristic that allows the  delineation  of  ground-water
units A and B.

     In order to provide  EPA with  a defensible ground-water
flow-divide delineation,  a limited  flow analysis  will  gen-
erally be required as  a minimum.   An acceptable  approach  is
to prepare a water budget for the  ground-water  unit in order
to show a reasonable order-of-magnitude  balance on flow into
and out of the system.   This could involve the preparation of
a ground-water flow net (see Glossary for definition)  for the
uppermost aquifer  with  accompanying estimates  of volumetric
flow  into  and out of  the unit.   The flow  net can  be  gen-
eralized and need  not be rigorously correct in a quantitative
sense.  The  analysis  should be carried  out  even  though part
of  the ground-water  system  continues   outside the  Classi-
fication Review  Area,  that is,  if part or  all of the  dis-
charge  or  recharge area of  the  unit  extends  beyond  the
Classification Review Area.

     The semi-quantitative flow net of the uppermost aquifer
should be supplemented by a  vertical   hydrogeologic cross-
section  and  supporting  data  showing  that  the  uppermost
aquifer is,  in fact, underlain  by an extensive  aquitard  or
crystalline rock non-aquifer within the Classification Review
Area.   The flow net can  be  based on available  water-table
elevation data as  interpreted from water levels in  relatively
shallow wells; locations/elevations of springs,  wetlands, and
perennial  streams; and supplemented with  topographic eleva-
tions.  The rates  and directions  of flow can be estimated in
plan  view given a water-table  contour  map and estimates  of
aquifer thickness  and  hydraulic  conductivity.    The  conduc-
tivity can be obtained  from  the area-specific reports, field
or  laboratory  tests,   or by  estimating  a  range from  the
scientific  literature  based  on earth material type.   Flow
patterns inferred  from these data must also consider  signifi-
                          65

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                                       FIGURE 4-4
                         EXAMPLE OF TYPE 1 FLOW DIVIDE BOUNDARY
                                  GEOLOGIC MAP
                                    ELEVATED BEDROCK
                                         AREA
                                                                               2 MILES
                                 HYDROGEOLOGIC CROSS SECTION
                                       GROUND-WATER FLOW DIVIDE
       A (West)
4OOFT
200 FT
                                   A1 (East)
                 ALLUVIAL  AQUIFER

                 SANDSTONE AQUIFER

                 GENERAL FLOW DIRECTION

          '/'/'   BASE OF CIRCULATION
   ACTIVE
 MUNICIPAL
SUPPLY WELL
                                                        CLASSIFICATION REVIEW
                                                        AREA BOUNDARY
                                     66

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cant spatial  and directional  variations  in conductivity  in
areas  having a  more  complex  stratigraphic  and  structural
geologic conditions.

     At the beginning  of the flow analysis, it  is important
to determine  whether the  ground-water flow system is  in  a
state  of  steady  or transient  flow.   Areas that  are charac-
terized by a  lack of ground-water development and usage can
generally  be assumed  to  be  in  steady  state.    This  will
simplify  the  analysis because the estimate  of  system  dis-
charge can be equated  to recharge.  If the  natural recharge
rate compares favorably with  a reasonable  percentage of mean
annual precipitation,  the ground-water flow divides  can  be
considered reliable.   The  applicant  can  go to  the ground-
water literature to obtain "reasonable" estimates to recharge
in any geographic/ground-water region  of  the United  States
(e.g.,  see US6S Water-supply Paper 2242 by R.C.  Heath,  1984).

     In  areas characterized  by  large-scale withdrawals  of
ground water  from shallow or deep aquifers, the  flow regime
is more   prone  to  be  in  a  transient  state.     Evidence  of
transient conditions includes:

        Declining ground-water levels
        Depletion of ground-water storage
        Movement of flow divides

When such evidence of movement exists, it may be necessary to
estimate  the  ultimate  steady-state  position  of the  flow
divides  assuming conservatively  large withdrawal  rates and
small water flow and storage properties.

     4.3.3  Type  2  Boundaries;   Low-Permeability  Geologic
            Units

     The  Agency would  assign a low degree of interconnection
across the low-permeability geologic unit  (Type  2 boundary)
if the following conditions can be shown:

        The   low-permeability  geologic  unit   is  laterally
        continuous  beneath  the entire area and/or limits the
        lateral  continuity  of the  more   permeable geologic
        unit

        There are  no known wells,  mine shafts,  etc. that are
        improperly  abandoned  or unsealed through  the geologic
        unit
                              67

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        The geologic  unit has a  small  permeability relative
        to both adjacent geologic units and to geologic media
        in general

     .   The flow of water through the  geologic unit per unit
        area is  insignificant relative to the  flow of water
        per unit area through adjacent strata

     Low-permeability  geologic  units  include  fine-grained
sediments and sedimentary rocks, such as clays and shales, as
well as  crystalline  igneous and metamorphic  rocks  that have
few interconnecting fractures.   Because these materials have
small  permeabilities,  small  quantities of  water  will  be
transmitted through them  in response to hydraulic gradients.
In  areas where  hydraulic  heads  beneath  or  within  a  low-
permeability unit are greater than heads in an aquifer above
the unit,  the  hydraulic  gradient has  an upward  component
across the Type 2 boundary.   The Agency considers this to be
the  most  favorable   head  relationship because  it  further
ensures  that  the direction  of ground-water movement  at the
boundary serves to inhibit the migration of contaminants into
and across this type of boundary.

     In selected environments,  such  as deep geologic basins,
the applicant  is  free  to  make arguments  that the  flow of
fluids is negligibly small through the low-permeability unit.
The actual  cut-off values of key variables such  as perme-
ability, thickness and  hydraulic  gradient  are not specified
in these guidelines and are left to professional judgments.

     Figure 4-5 illustrates a setting where the presence of a
thick,  regionally extensive aquitard establishes a low degree
of interconnection between a shallow ground-water unit and a
deeper underlying ground-water unit  (aquifer).   This config-
uration  is  common  in the Atlantic  and Gulf  coastal plain
settings where  the lower aquifer is the  principal regional
aquifer and is  a  source of water  supply.   It is overlain by
an extensive confining  clay that may be tens  of feet thick.
The shallow ground-water  aquifer system supplies only limited
amounts of water to wells.  The reasons for the low intercon-
nection between aquifers  in this setting are as follows:

        the flow of water through the aquitard is exceedingly
        small,

        the time of  travel of water through  the aquitard is
        very large

     Sedimentary basins commonly exhibit multiple freshwater
aquifers each separated by a regionally extensive low-perme-
                             68

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                                       FIGURE 4-5
                               EXAMPLE OF TYPE 2 BOUNDARY
                                              CRA
                             2-MILES
  MSL
   10
                   ALLUVIAL AQUIFER
                   (UPPER GROUND-WATER
                    UNIT)
                                                      2-MILES
                                            FACILITY
   20
ff  30
                                          AQUITARD
X
a.
Hi
a
40
   50
   60
                                        AQUIFER
                                (LOWER GROUND-WATER UNIT)
   70
                                              69

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ability confining unit.   Figure 4-6 is an example  of such a
basin  where  ultimate  discharge  of  the  deep  fresh  water
through  overlyirg  low-permeability  confining  units  (flow
barriers)   is  to the  ocean.   Deeper  ground  waters  in these
basins  will be  characterized  by  a  Total  Dissolved Solids
(TDS) concentrations that may be much greater than the 10,000
mg/1 limit  for  Class III ground waters,  and  interconnection
is considered to be  low,  even though  hydraulic gradients are
in the direction of less saline water.

     The reasons for the low degree of interconnection are as
follows:

     . salts are retained in  deep  aquifers confined by late-
       rally extensive aquitards,

     . the  flow of  water  through the confining  units  is
       exceedingly small,

     . the time of travel through  the confining unit is very
       large

     . the  depth to these  waters  is generally  below  the
       bottom of any major water-supply wells in the area.

     Deep,  confined,  saline  ground-water units  with  a  low
degree  of  interconnection  to  overlying  fresh  ground-water
units  are currently the  primary hydrogeologic  setting into
which wells can be permitted to inject hazardous wastes under
present EPA and  state Underground  Injection  Control (UIC)
regulations.  These  waters  are herein  defined  as  Class III,
Subclass  B  ground water.   EPA's position is  that  the inter-
connection  test for  such candidate  Class  IIIB waters will
follow those tests for the UIC program, Class I wells.

     In general, the demonstration of the existence of a Type
2  boundary requires that one identify and characterize the
laterally   continuous   low-permeability   non-aquifer  that
constitutes the boundary.  The following is a list of  factors
to be considered in making this demonstration:

     . Stratigraphic setting and lithologic characteristics

     . Structural  setting  and   joint/fracture/fault   charac-
       teristics

     . Hydrogeologic  setting and  hydraulic  head/fluid flow
       characteristics
                            70

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[__
rf
                     Nl /Hld30
                     71

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     The first distinction should be between whether the non-
aquifer is of sedimentary or  igneous/metamorphic  origin.   If
it is sedimentary in origin,  an  identification of the envir-
onment  of  deposition will  permit  inferences  about  the  ex-
pected  geometry,  thickness,   and   continuity  of  individual
strata.   These  inferences  should  be defended  with geologic
sections  including  data  from  well  logs  and/or  measured
sections.   The  age of  the  unit, the degree  of cementation,
and  degree  of  compaction  are all  qualitatively  related  to
water-bearing  characteristics   (hydraulic  conductivity  and
porosity).

     If  the unit  is  an igneous  or metamorphic  rock,  the
continuity  and  thickness can  usually be inferred  from geo-
logic maps and  reports  for  the region in which the Classifi-
cation  Review Area  exists.    Identification of igneous rocks
that have tabular geometries such as volcanic flows, ash-fall
deposits, or intrusive  sills  and dikes  will allow inferences
about thickness and continuity.  These  may  serve  as aquifers
or   aquitards   within   a  sequence  of   sedimentary  rocks.
Crystalline  "basement"  rocks  of  igneous  and  metamorphic
origin  underlie the  entire  North  American  continent.   In
areas where these rocks are fractured and exposed at or near
the  land  surface,  they generally serve  as  poor-yielding
aquifers.  However,  significant circulation can be assumed to
be  restricted   to  the  upper   few  hundred  feet because  the
fractures tend  to  close with  depth.   In other areas,  where
these rocks are buried by younger  rocks, they can generally
be assumed to represent the base of active circulation unless
there is evidence to  the contrary.  In  these situations the
Type 2  boundary is equivalent to  the  bottom  of  the ground-
water regime (see Glossary).

     A  general  knowledge of the tectonic setting and struc-
tural  geologic  history  of  the  region  will  provide insight
into the types and  frequency of  geologic  structures  to  be
found  in the  Classification  Review Area.    Numerous  field
studies  have  shown  that  significant   ground-water  flow  in
consolidated sedimentary and  crystalline rocks is controlled
by geologic structures.  These features include folds, faults
and  associated joints and fractures in the rock.

     Major  structures  such  as  fault   zones   that  intersect
consolidated  rock   formations  may  hydraulically  connect
multiple aquifers into  a system  of  aquifers.   Fault zones in
consolidated rocks  are known to   collect  water  from  large
areas and control the  locations  of ground-water discharge at
                             72

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major springs.   In softer  sediments  and in  some  structural
settings,  fault  zones  can  have  the  opposite  effect  by
producing  barriers  to  flow.    Individual  joints  and  small
fractures  in  consolidated rocks and  sediment can be  mapped
systematically with  field studies, however,  proof of  their
absence  is the more  important  element in  demonstrating the
presence of a Type 2 boundary.

     The   best  evidence  of   low-permeability   non-aquifer
conditions constituting  a Type  2 boundary  are those  related
to  the  hydrogeologic  setting and  measured hydraulic  para-
meters.   Table 4-2  shows that the  hydraulic  conductivity of
both sedimentary  deposits and igneous/metamorphic rocks can
be estimated within several orders-of-magnitude  on the basis
of lithology alone.   In parts of the United States associated
with  large ground-water usage, there has  been  a  need  to
understand the ground-water regime and these areas will often
have  been  studied  by  various  government agencies.    Con-
sequently, the hydraulic properties of aquifers and aquitards
will be known  in quantitative  terms.    In these areas the
thickness, lateral extent, and hydraulic conductivity will be
documented.   A favorable condition would  then be associated
with a  recognized aquitard or aquiclude that is  known to be
relatively thick, homogeneous,  widespread,  and poorly perme-
able.  The optimum head condition would be such that vertical
hydraulic  gradients are  directed  upward  through the  unit,
i.e., across the Type 2 boundary.

     4.3.4  Type 3 Boundaries;  Fresh/Saline Water Contacts

     Type  3  boundaries  between  bodies of  ground  water with
contrasting  concentrations of  Total  Dissolved  Solids  (TDS)
most  commonly occur  within  the following  types of  hydro-
geologic settings:

     . Sea-water  intrusion   into   fresh-water   aquifers  in
       coastal regions,

     . Saline  waters  associated with ancient evaporite de-
       posits  in sedimentary basins,

     . Saline  waters   associated   with  closed  topographic
       basins  in arid regions.

     . Saline  brines in  deep geologic basins,

     . Geothermal fluids  in tectonically active regions,
                            73

-------
                                  TABLE 4-2

         RANGE OF VALUES OF HYDRAULIC CONDUCTIVITY AND  PERMEABILITY

                       (AFTER FREEZE AND CHERRY,  1979)
             Rocks
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                                       74

-------
     In the  above settings, the  TDS of naturally  occurring
saline water  may be 3  to 10 times  greater than the  10,000
mg/1 criterion.   Owing  to natural  concentration gradients,  a
zone of diffusion is normally observable between the  saline
and  fresh ground waters.   The  10,000 mg/1  TDS  isometric
surface will generally  be situated within the  diffusion zone
separating the waters of contrasting salinities.

     Figure 4-7  illustrates how a wedge  of sea water which
has  intruded  into an unconfined  aquifer  is identified  as  a
separate  ground-water  unit  of  higher  salinity and  density
relative  to  an  adjacent  ground-water  unit,  in  the  same
aquifer,  containing fresh  water.    In this setting,  there
exists  a  zone  of diffusion  between two  flow systems  that
contain fresh water and  sea water.   The  salinity boundary
would occur along the 10,000 mg/1 TDS isometric surface.

     Figure  4-8   illustrates a  second hydrogeologic  setting
characterized  by  the  presence  of  near-surface  evaporite
deposits overlying deeper-bedrock units.  Salts are dissolved
from the evaporite units by the circulating ground waters and
a  shallow zone of  saline waters  coexists with  fresh  ground
waters within  the same flow system.   However, based  on the
delineation of  a Type  3  boundary, two  distinct ground-water
units can be identified.

     Although the saline  water  is primarily confined  to the
low-permeability  evaporite  formation,  this water leaks into
the  underlying  aquifer creating  a zone of  diffusion  within
the  underlying  aquifer.   The boundary between the two ad-
jacent  ground-water units  would  be drawn  along the  10,000
mg/1 TDS  isometric surface within the  diffusion zone.   The
diffusion zone  would be  a  stable feature assuming the flow
system  is in both hydraulic and  geochemical  steady  state.
The degree of  interconnection between these adjacent ground-
water  units  is  defined  to be  intermediate.    The type  of
setting illustrated in Figure  4-8 is not  as  common  as the
coastal intrusion setting illustrated  in Figure 4-7,  but it
is known to exist in selected parts of the United States.

     In the  above two  settings,  the intermediate  degree of
interconnection  between  ground-water  units  is due   to the
limited potential  for the exchange of waters across a  Type 3
boundary within  a diffusion zone.   In the first setting, the
salt water and fresh water are in separate,  but adjacent flow
systems.   In  the second  case,  the diffusion  zone is more
extensive and may or may  not be within  a  single flow system.
A  third case  involves  a single  regional flow system with the
diffusion zone in the deeper and more downgradient  end of the
system.
                              75

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                                        FIGURE  4-7

                           EXAMPLE OF TYPE 3  BOUNDARY THROUGH AN

                          UNCONFINED AQUIFER  IN A COASTAL SETTING
                                                                   FACILITY

                                                                           OCEAN
                    FRESH   WATER
                     (GROUND-WATER UNIT)
                                        ZONE

                                    DIFFUSION
BASE OF AQUIFER   —.
             EXPLANATION


             {gg:gy;;|   > 30.00O mg/l TDS WATER


             [    |   DIFFUSION ZONE


             	—   GROUND-WATER FLOW DIRECTION


             _.£._   WATER TABLE


             Hc«wL»-   CLASSIFICATION REVIEW AREA


             •'      lO/XO mq/JL TDS ISOCONCENTRATION LINE
                                            76

-------
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     The third setting includes naturally saline ground water
contained  within  topographically-closed  structural  basins
within  arid  parts of  the western  United States  (e.g.,  the
Great Salt Lake Desert).  Figure 4-9 shows an example of such
a  setting where  the  water is  recharged  from runoff  from
mountain ranges adjoining the basin, circulates to the center
of the  basin,  moves vertically  through confining  beds,  and
discharges to playa lakes and the atmosphere.  These settings
are  known to  have brine waters  greatly in  excess of  the
10,000 mg/1  Class  III  criteria within the  discharge area to
depths as great as 2000 feet below land surface.

     Distinct ground-water  units can be  delineated based on
the  identification  of  Type  3  boundaries as shown  in Figure
4-9.   Under natural  conditions  the diffusion  zones encom-
passing these boundaries  are stable and ground-water units A
and  B  can be identified  as shown.   Large-scale withdrawals
from upgradient  fresh  (Class  II)  ground water  or injection
into  the  saline  (Class  III)  ground-water  can  laterally
displace the diffusion zone.  The pumped wells may eventually
yield saline water  and will cease  to be sources of drinking
water.   Thus,  the  potential to  cause  adverse water-quality
effects may result from improper resource management.

     Type  3  boundaries  are the least  interpretive of  the
boundary  types  because  they  are  simply  equivalent to  the
10,000  mg/1  TDS isometric  surface  through  the ground-water
regime.   These  boundaries  are  then  easily  recognized  and
mapped  when  TDS data  are  available for ground  waters from
various  depths  and  locations  in the  Classification Review
Area.   The  elevations  at which  ground-water TDS is equal to
or greater than 10,000 mg/1 has been mapped  and published for
selected basins and regions.   The principal sources for such
data are the USGS and state geological surveys, especially in
states  having  abundant oil  and  gas resources.   In areas of
known sea-water  intrusion,  or  upconing  of  salt water due to
pumpage, published data are occasionally available which will
show in vertical section  or plan view the extent of the salt-
water wedge.  This may be conservatively taken as the 10,000
mg/1  TDS boundary where more  specific  TDS   data  are  not
available.   In  areas  of  known  high temperature geothermal
resources, published data are  available to estimate the Type
3 boundary location.   Because  these areas,  are few in number
and are limited in  areal  extent, few will be co-located with
potential Classification  Review  Areas.    Equally limited are
data bases for saline  water settings associated with soluble
evaporite deposits.   At  specific sites in  these  areas,  the
relationship  between  water  quality,  soluble  strata,  and
ground-water flow directions can be established and the Type
3  boundary  mapped.    This  relationship can  be assumed  in
                            78

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adjacent areas, where the  stratigraphy  and flow patterns are
known, in  order  to extrapolate the Type 3  boundary  to other
parts of the Classification Review Area.

     4.3.5  High Interconnection Scenarios

     High  interconnection  of  waters   is   assumed  to  occur
within  a  given  ground-water  unit  and where  ground  water
discharges  into  adjacent  surface-water  bodies.   The  latter
situation  is specially  relevant in identifying  Subclass IIIA
ground waters,  for occasions  where  these  are  not  potential
sources of drinking water.

     Subclass  IIIA can  be associated  with shallow,  uncon-
fined, aquifers  that underlie broad,   urbanized,  industrial
areas where numerous diffuse  sources  of  contamination have
degraded water quality.   Figure 4-10 shows hydrogeologic set-
tings that may qualify  for class  IIIA  (Untreatable).    The
two  examples  shown  include  urban/industrial  areas  located
near  major surface waters and overlying  alluvial  sediments
that  are  saturated at relatively shallow  depths.   As shown,
the degraded water must be contained within a shallow ground-
water unit that discharges to the local surface-water body.

     4.3.6  Example  of   Subdividing  a   Classification  Review
            Area

     Figures 4-11  through  4-13 illustrate  how  a hypothetical
Classification Review Area is subdivided  into ground-water
units  and  the potential  classification  decision   for  each
unit.  It  should be emphasized that for purposes of an actual
classification decision, not all the subdivisions illustrated
here  would  be  necessary, as  only  the   ground-water  unit
relevant to the facility would be classified.

     The  facility  for  which  a classification decision  is
needed  is located  on the  floodplain  of a perennial  stream
that  flows in  a  direction  towards  the  viewer in Figure 4-11.
The water  table  is relatively shallow  beneath  the floodplain
and  is  essentially  at  the  land  surface  in  wetland  areas
adjoining  the  stream.   The habitat for an endangered species
is located in  a wetland on the opposite  side  of the stream
from the facility.

     The  geology  of the Classification  Review  Area consists
of essentially flatlying  sedimentary formations  overlying a
crystalline  basement composed of undifferentiated  granitic
and metamorphic  rocks.   Three local aquifers and  two aqui-
tards are  recognized in the area.  The uppermost aquifer is a
water-table aquifer  defined as the saturated part  of  a sand
                              80

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and gravel deposit overlying  a  low-permeability  shale forma-
tion.   This  aquifer  is  recharged  by the  infiltration  of
precipitation  and discharges  primarily  to  the  stream  and
wetland  areas.    It  is locally  used  for water  supply  by
domestic wells in a nearby residential development.

     Figure  4-11  shows a  deeper  middle  aquifer  that  is
sandwiched between two regionally extensive shales that serve
as aquitard confining beds.   Ground water is pumped from the
middle aquifer at a municipal well which  supplies water to a
nearby city.  The city also receives water pumped from deeper
wells in the  lower aquifer, however,  these wells are located
on the other  side of the city off the left edge  of  Figure 4-
11.  Pumpage from these wells has caused sea  water to intrude
the lowest aquifer from the ocean located off  the right edge
of Figure  4-11.   The lower aquifer is  underlain by crystal-
line rocks which have  low permeabilities  and are not used as
an aquifer in the area.

     Figure  4-12  illustrates the  cylinder-shaped volume  of
earth material that underlies the Classification Review Area.
The  ground-water regime  is  defined  to  include all  ground
water  and  earth  materials  between  the  water  table  in  the
uppermost  aquifer  and  the  contact between the  lower aquifer
and the basement rocks.  Figure 4-13 shows how the regime can
be subdivided into five ground-water  units.  For purposes of
an actual classification decision,  only the ground-water unit
that could potentially be  affected by  the facility  would be
pertinent.

     Ground-water units 1 and 2 are subdivided along a Type 1
ground-water  flow divide boundary beneath the  sinuous peren-
nial river.   This boundary  is inferred from  a  mapping of the
flow  pattern within  the uppermost  aquifer.   The  aquitard
beneath the  aquifer  exhibits no evidence of discontinuities
within the Classification Review Area.  It is  present in all
deep wells in the  area and  consistently shows  large vertical
gradients  across  it.   Even so,  the  estimate of the rate of
ground-water  flow  per unit area through  the unit  (based on
these gradients  and  hydraulic conductivities)  is no greater
than  10~6  cm/sec which  is  negligibly  small  relative  to
ground-water  flow rates in adjacent aquifers.  Based on these
characteristics,  the  aquitard  constitutes  a  Type  2  low
hydraulic  conductivity,  non-aquifer boundary.    The vertical
extent of  ground-water units 1 and 2  is  thus,  delineated by
the existence of this physical boundary.

     Ground water within the  middle  aquifer  is identified as
a  third  ground-water unit with the  overlying  and underlying
aquitards  constituting Type 2 boundaries.  In addition to the
                              83

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84

-------
                                        FIGURE 4-12
                        HYPOTHETICAL  CLASSIFICATION REVIEW AREA
Ground -
 Water
 Regime
                                               AauJtard  -inr^m:
                                                                                         Jppwmost
                                                                                          Aquifer
                                                                                          Middle
                                                                                          Aquifer
                                                                                          Lower
                                                                                          Aquifer
                                          85

-------
o,

                                                               Typ« 2
                                                               Boundary

-------
characteristics described  above  for the uppermost  aguitard,
long-term aquifer tests have been performed  on  the  municipal
wells completed in the middle and lower aquifer.  These tests
indicate that less than ten percent of water pumped from the
aquifers is  derived from  the  leaking aquitards, thus  their
designation as Type 2 boundaries is justified.

     Ground  water  within the lower  aquifer  is  generally
moving towards a major pumping center located outside of the
Classification Review Area.  A significant part of  the water
in  this  aquifer has  been replaced by  sea  water having TDS
concentrations in  excess  of  30,000  mg/1.    The problem has
been  studied by the  U.S. Geological  Survey in  cooperation
with the city.   The movement  of the  interface  between fresh
and saline water is being monitored  with  a  few  deep wells.
The approximate  location  of   the  interface   at  the  time  of
subdivision was approximately known and,  lacking specific TDS
data,  is taken  as the 10,000  mg/1  TDS Type  3  boundary sep-
arating ground-water  units 4  and 5 on Figure 4-13.   Because
the  actual  10,000  mg/1  TDS  boundary  is  probably  several
hundred  feet further towards the  well  field,  use of the
interface as  this  boundary makes ground-water  unit  4 larger
and unit 5 smaller than it actually may be.   These errors are
conservative  in  the sense of  providing levels  of protection
to these waters as determined by class designation.

     Based on the above  general  discussion  of classification
related criteria the ground-water units may be classified, as
shown on Figure 4-13, as follows:

        Unit 1 may be Class I Ecologically Vital Ground Water
        due  to  the  endangered  species habitat  within the
        discharge area,  wetland environment  and  potentially
        vulnerable condition,

        Unit  2 may  be Class IIA, current source  of drinking
        water due  to the  residential wells  screened in this
        unit,

        Unit  3  may be Class  IIA current source  of drinking
        water owing to its use for water supply but is poorly
        interconnected to the Class IIA water  in the upper-
        most aquifer,

      .  Unit  4 may  be Class  IIB  potential  source of drinking
        water  even though it maybe  used  for water supply
        outside the Classification Review Area

        Unit  5 may be Class IIIA, not a potential  source of
        drinking water because it has a TDS above 10,000 mg/1
        and has a intermediate degree of interconnection with
        adjacent  Unit  4,  a  potential  source of   drinking
        water.
                                87

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4.4  Determining Irreplaceability

     Figure 4-14  displays  the general concept  of irreplace-
ability for Class I ground water.   The goal is  to identify
those waters  of  such  relatively high  value that  unusually
high protection is warranted.  For  the  purposes of  classifi-
cation,  this is not meant to be an extremely rigorous, costly
exercise.    In many instances, estimates will  suffice.   For
example,  a  census of  residents  should  not be performed  to
determine whether a substantial  population  is affected — if
available  information  suggests  that  current  water  users
approximate the required thresholds,  the criterion  should be
considered  satisfied.   Similarly,  irreplaceability  will  be
assumed unless  an analysis  is deemed  desireable;  typically
when a  permit applicant feels that a Class  II situation is
truly the case.   If an analysis is performed,  it should not
be necessary  to evaluate every  possible replacement source;
rather,  rough  estimates developed  for  no more than  a small
number of representative replacement  water  sources  should be
adequate to indicate the presence or  absence of a irreplace-
able source.  These "shortcuts"  are necessary since detailed
water-supply alternative  studies are inordinately  expensive
and are reserved  for  such major projects as large  multiple-
purpose dams and reservoirs.

     A  ground  water   serving a substantial  population  is
considered  irreplaceable,  if  alternatives  are not suitable
due to any one or more of the following five criteria:

        Use of  the alternative  source  would require piping
        water over an unreasonable or uncommon distance

        The  alternative  source  is  incapable  of  providing
        water  of  quality  that  is  comparable  to  typical
        quality of  ground  water used   for  drinking  in  the
        Region

        The alternative source is incapable of yielding water
        in  sufficient  quantity  to  serve  the  substantial
        population

        Access to the  alternative source is precluded due to
        institutional constraints

        Use of  the alternative source is economically infea-
        sible.

     Again, the general procedure  is to first determine  if
the ground water within the Classification Review Area or the
appropriate subdivision serves a substantial population.   If
                              88

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                                            FIGURE 4-14
                              CRITERIA FOR CLASS I - IRREPLACEABLE
                                   ANY ONE OF SEVERAL FACTORS:
• POLLUTED GROUND-
 WATER I SNOT OF
 COMPARABLE QUALITY
            /
   • GROUND-WATER IS
    ECONOMICALLY
    INFEASIBLE
                                     CLASSIFICATION
                                     REVIEW  AREA
                                                                            .   • RIVER IS
                                                                                INSTITUTIONALLY
                                                                                PRECLUDED
                                                                          • GROUND-WATER IS
                                                                            ECONOMICALLY INFEASIBLE
                                                                            TO DEVELOP AND PIPE TO
                                                                            CLASSIFICATION REVIEW
                                                                            AREA
            	AREA OF INVESTIGATION CONSIDERED
                        TYPICAL FOR THE REGION
                                                 89

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so,  then  the  source   is   considered  irreplaceable  until
demonstrated otherwise using the above five criteria.

     The following sections  discuss definitions  for the more
specific procedures,  and key  factors related to  irreplace-
ability:

        . Substantial population
        . Uncommon pipeline distance
        . Comparable quality
        . Comparable quantity
        . Institutional constraints
        . Economic infeasibility.

Each of  the  following sections  describes  particular  methods
based on data  available  from Federal and  State  agencies and
other easily accessible sources.  Each section identifies and
characterizes  relevant  data  sources.    Where  appropriate,
example calculations are used  to illustrate data application
and  appropriate  quantitative  methods for  determining  irre-
placeability.

     In these Draft Guidelines, the Agency is also soliciting
comment  on  approaches to judging  two aspects of  the "irre-
placeable" criterion.   Option A  incorporates  a  quantitative
determination of the population  served by  the  source  and the
economic  feasibility of replacing the  source.    Under this
approach,  a  drinking   water   source  would  be  considered
"irreplaceable" if  it serves  at  least  2500 people  and the
annual cost  of  typical user of  replacing  the  source  exceeds
0.7 to 1.0 percent of  the mean household income  in the area.
Option B focuses on  a  qualitative assessment of  the replace-
ability  of  the  ground  water.    Under this  approach,  the
relative size of the population  served by  the  source  and the
cost of  replacing the  source would be factors  to consider in
assessing  the  source's  "replaceability."   The  Guidelines
would not under Option B, provide a set methodology,  nor one
or more  numerical  cut-offs.   Again,  the determination would
focus on best professional judgment.  A user following Option
B may choose,  however,  to consider some of the  quantitative
methods  or  approaches in Option  A,  if deemed relevant in a
particular classification  decision.   Comments on  these two
options, as well as  other options for assessing  "substantial
population" and "irreplaceable"  (from an economic standpoint)
will be  considered by the Agency  in  determining how  best to
incorporate these factors in classification decisions.
                              90

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4.4.1  Substantial Population (Option A)

     Under  Optional  A,  ground  water  is deemed  to serve  a
substantial  population  if  at   least  twenty-five  hundred
persons are served by (Figure 4-15):

     . centralized public  water  supply well(s)  within  the
       Classification Review Area or appropriate subdivision
       whether the population lies inside or outside Classi-
       fication Review Area or

     . private wells within the Classification Review Area or
       appropriate  subdivision  for   persons   living   in  a
       densely settled area (i.e., census definition based on
       1,000 persons-per-square mile) or

     . a combination of the above.

     This  definition  of substantial  population is  based on
numerical thresholds and concepts already used by the Census
Bureau.  The  population data necessary  to make these  deter-
minations is widely accessible and sufficiently up-to-date.

     In most  instances,  making these  determinations will be
straightforward.  If the well(s)  in the Classification Review
Area  or  appropriate  subdivision  service  a  public  water
system, an  estimate of  the number of user households multip-
lied by the average number of persons-per-household  (2.7 on a
national  basis,  each  state or  locality  may be  somewhat
different) should approximate the total population served; if
the population is served by other water sources, these should
be  accounted  for  proportionately.      (Water  supplied  for
industrial and agricultural purposes should not be included.)
For private well users, it will be necessary both to estimate
the population  in the Classification  Review  Area not served
by  public water  systems  and,  also,  to calculate  the pop-
ulation density.  The EPA maintains a data system called GEMS
(for Graphical Exposure Modeling System) which  can be used to
estimate  both  population  and  population  densities   for  a
variety of areas around a point (see Appendix E for details).

     4.4.2  Substantial Population (Option Bl

     Option  B  differs  from  Option   A  in  that  no specific
numerical  cut-offs are  dictated  for  determining "substantial
population"  or  the  "economic  feasibility"  of replacement.
Rather,  the relative  size of the population  served  by the
source would  simply  be factors to consider  in assessing the
source's "replaceability."   A determination that a source is
"irreplaceable" would require a qualitative assessment of the
                             91

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                                 FIGURE A-15
                EXAMPLE CLASS I -  SUBSTANTIAL POPULATION
   r
     *

 I

                                   >
                                     ^
     \
                                           (A)  WELL(S) ON PUBLIC SYSTEM SERVES
                                               22500 PERSONS; EITHER INSIDE OR
                                               OUTSIDE CLASSIFICATION REVIEWAREA
                 FACILITY
 %
   \

      •\

           (B) PRIVATE WELLS IN
              DENSELY SETTLED AREA
              SERVE >2500 PERSONS
                                                     FACILITY
  r
    f

         s
                                       \

                FACILITY
 o   o  \0
     °\
 o      I
    0   I
O o   0|

                                       \
                                                                           \
                                                                            \
                                                                        o o  o/
                                                                           o

                                                                          /

%
 o o  o
o    / o
 \
   \


                                     /
                                           (C)  PRIVATE WELLS AND
                                               PUBLIC SUPPY WELL(S)
                                               SERVE >2500 PERSONS
                                      92

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technical  and economic  feasibility of  replacing it  taking
into account  all  of  the factors that may be  relevant  in any
specific case.  Some of  the  same  steps  in data gathering and
analysis included in Option A might be  utilized,  or alterna-
tively, other procedures could  be  substituted.   The overall
approach  to  determining replaceability  would,  however,  be
more  qualitative in character,  and be more dependant  on
professional judgment.

     4.4.3  Uncommon Pipeline Distance

     Designating an uncommon pipeline distance for the Region
is an  important early step  in  determining irreplaceability.
This  uncommon  distance will  set  a   hypothetical  radial
boundary around  the  site within which  an alternative source
of water can be located.  It, therefore, restricts the number
of  alternative  sources that  should be  considered in  the
classification decision.   If no  alternative  institutionally
available water source of comparable quantity and quality can
be located within a  reasonable  distance,  the  ground water in
the  Classification  Review Area should  be  considered to  be
Class  I  irreplaceable.    In  theory,  this  is  the  maximum
distance water  is currently  piped  from  the raw  water source
to the distribution system for each population category.

     The determination  of uncommon pipeline distance depends
on many factors,  including  topography,  geology,  hydrology,
availability  of  developed  water  resources  (e.g.,  lakes,
reservoirs,   etc.),   institutional   constraints  on   water
development,  water  demand,  and  economic resources.   As  a
result, distances can vary  significantly.  In the semi-arid
regions of  the  West, water may be  conveyed 50 miles or more
from  the  source  to  the  distribution system.   In  the  more
humid East, however,  water is typically  piped five  miles or
less.   Piping  distances can  also  range  considerably  even
among neighboring states.

     Although it is reasonable to define an uncommon pipeline
distance  for  different  population  categories,  it  is  in
practice, extremely  difficult to  set rigid criteria.  In the
absence of  an exhaustive survey,  guidance on  these distances
is available  in Table 4-3,  based  on information provided by
EPA's  research  laboratories and  the Federal  Reporting  Data
System  (FRDS) maintained by EPA's  Office of  Drinking Water.
The distances proposed in Table 4-3 are based on the applica-
tion of a  one percent  income threshold  that is applied as an
economic criterion for  other Class I tests.  These distances
can be  calculated for other threshold  levels.   Working from
data provided by EPA's Cincinnati water-quality laboratories,
which  estimate  the  costs  of piping various quantities  of
                             93

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                            TABLE 4-3
      UNCOMMON PIPELINE DISTANCES FOR DIFFERENT POPULATIONS
               (Based on an 1% Economic Threshold)
     Population Size
Uncommon Pipeline Distance
        <5,000
     5,000-10,000
    10,000-25,000
    25,000-100,000
       >100,000
        25 miles
        35 miles
        70 miles
       100 miles
       150 miles or more
These distances could be computed for different levels of income
thresholds (e.g., 0.2%, 0.5%).
                               94

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water  (the  size of  pipes varied  with the  amount of  water
being  delivered  to  a  certain  size  of  population),  EPA
proposes  indexing  these  costs  to  the  amount  of  dollars
expressed by the  income  threshold  for  a  certain size  of
population.   For example,  a population  of 2500  persons  would
exceed  their 1% income  threshold  when the  costs  of  piping
water  exceed  $2.4  million.    This  dollar  amount  roughly
translates into an average piping  distance of  13  miles when
estimating the  costs  of  installing  and  pumping  along  the
pipes of  the diameter needed to deliver  a sufficient amount
of water  to  2500  persons.  The result of  this  approximation
should  be used as  general guidance for  the lower bound  of
uncommon pipeline distance.

     4.4.4  Comparable Quality Analysis

     Once  a   potential  alternative  water source  has  been
located,  it  is  important  to determine whether the quality is
comparable to that of other drinking water in the EPA Region.
The term  "comparable quality"  is defined  as  a level of water
quality  that is   not  substantially  poorer  than  other  raw
drinking water resources in the EPA Region.

          4.4.4.1  Water Quality Parameters

       To be considered of comparable quality, the quality of
the alternative water  resource should be  —  within an order-
of-magnitude — as good  as or  better  than, existing drinking
water  resources,  taking  into  account  the precision of  the
measurement  of  each  parameter.    For  example,  an existing
water source may have an average of 93 mg/1 TDS, with a range
of 75 mg/1 to 100 mg/1.   An alternative  water  source may be
considered not  of comparable  quality,  if it has  an  average
TDS of  1,300 mg/1  with a range of 1,000  mg/1 to 1,600 mg/1.
For some  parameters  of interest (e.g., taste,  color,  odor),
the evaluation  may be highly subjective.   It is again meant
to be  a  relative  test which  considers  a few  general  cate-
gories  of parameters  (e.g.,   TDS,  organic  compounds,  heavy
metals,  radionuclides  and other secondary physical/chemical
properties).

     Existing information on  water quality   should be used,
given  the very high  cost  of new  series  of   sampling  and
analysis.    The comparison is  intended  to  be  relative  and
subject to professional judgment.

          4.4.4.2   Sources  of Information

          At  the Federal  level,  three  important sources for
water  quality information may be  consulted:   EPA, the Army
                             95

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Corps of  Engineers,  and the United  States  Geological Survey
(USGS).    Each  of these agencies has  conducted,  or continues
to  conduct,   comprehensive  surveys  that   describe  water
resources in the U.S.   Although not  always  designed specif-
ically to provide detailed  water quality data,  these studies
provide information  sufficient to facilitate the comparable
quality  considerations  of  the  ground-water  classification
system.

     EPA has  funded  comprehensive studies of Regional water
quality  to  determine  the  principal  point  and  non-point
sources of pollution.  These studies, conducted under section
208  of  the Clean  Water  Act,  for  example,  give  a  broad
overview  of water  quality  (U.S.  EPA,  1980b).*   They  are
generally obtainable through  the  State  and local  agencies
which received the  funding.    The Army  Corps   of  Engineers
conducts similar regional water-resource  studies in  order to
examine water  supply and demand  within specified river  and
lake basins in the  United States.   The  most useful  resource
of  data  from  USGS  will .often be  the published basin-wide
investigations of ground- and  surface-water  resources.   USGS
also maintains the National Water Data Exchange  (NAWDEX)
which is  designed to  assist  users in  identification,  loca-
tion, and acquisition of information on water resources.  The
National  Water Well Association  (NWWA), Worthington,  Ohio,
maintains a library  of all USGS and  State  Geological Survey
information on water  supply  and  quality.    Using  automated
searching capabilities,  the NWWA  can identify   and  list  all
publications concerning a specific geographic area.

     On  a more  local  level,  regional  planning boards  and
councils  of government,  may also have  information  on poten-
tial  drinking  water  supplies  and  river,  lake,  and stream,
quality  in  their regions.   State agencies  that administer
environmental  protection,   land  use  planning,  agricultural,
geological  survey,  public  health, and  water programs,  are
excellent information  sources.   State universities  (particu-
larly  land-grant   universities)   may   sometimes  serve   as
repositories of  information concerning  ground-  and surface-
water supplies.

     4.4.5  Comparable Quantity Analysis

     Within a  reasonable distance range, as determined by the
"uncommon pipeline"  distance  analysis, a number of alterna-
tive  sources of water may be  identified.   These sources  may
include both   surface  or ground water.   Common  examples of
surface water  that can be  considered as a replacement source
re   rivers,    streams,   natural   lakes,  and  impoundments.
Alternative ground-water sources  may be located in  the same
                             96

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aquifer,  or  in  another  nearby  aquifer,   horizontally  or
vertically separated from the source aquifer.

     Determining whether the alternative  source,  or sources,
can yield adequate quantity requires three analytical steps:

        determine current users' present water-supply needs

        characterize  potential  sustainable  water  yield  of
        alternative source

        compare potential supply and current demand.

Each of these steps is discussed briefly below.

Step 1;  Determine current supply needs of water users

     If the ground  water to be classified supplies a public
water system,  current supply needs will be known by the water
utility.   If  the  ground  water  to be  classified serves  a
substantial population using  private  wells,  current  water
needs must be estimated using  population  figures  and assump-
tions concerning typical water use.

Step 2;   Characterize potential  sustainable water yield  of
alternative water supply

     This  information  is best  obtained from the previously
mentioned,  published studies.    In  addition,  routine  water
shortages  in  communities  currently served by an  alternative
source,  for  example,  would  indicate  that  the  alternative
source may not  (conceptually) be able to provide water for an
additional  population increment.    Rapidly falling  ground-
water  levels  over  time  also  indicate  that an  alternative
source may not  be capable of  consistently  providing suffic-
ient yield year-round.  However, levels which are not falling
may  also  indicate  a  source  which is  unavailable  for  ad-
ditional usage, but one which  is being properly managed.   In
cases where the ability  of  an  alternative source  to meet the
needs  of  the  substantial   population is   unclear,  a  more
quantitative analysis may be necessary*

Step 3;   Compare  alternative water supply and existing water
demand

     In  cases where the  alternative  source is located  in a
water-rich  area,  the  comparison  of user  needs  and source
yield may  be  done on an  annual basis.   The comparison should
be conducted  on a monthly basis where the alternative source
is ground  water under existing or  potential stress or where
                           97

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the alternative  source  is a surface water  with considerable
month-to-month variability  in flow.   Important  sources  for
water-quantity  information  include local  water  utilities,
State water agencies, and the U.S. Geological Survey.

     4.4.6  Institutional Constraints

     Institutional constraints involve legal, administrative,
and other similar forms of control over access to water.  For
purposes  of  this  Guidance,  the  Agency  has  adopted  the
following definition of institutional constraint:

          An  institutional  constraint  is  a  situation  in
          which,  as  a  result  of a legal  or  administrative
          restriction, delivery of  replacement  water may not
          be assured through simple administrative procedures
          or market transactions.

     While a detailed examination of  legal  and institutional
issues  is rarely  called for,  a preliminary   review  should
indicate whether an institutional constraint is present.  The
following  discussion  presents   a  breakdown   of  potential
institutional  constraints   and   a  general   procedure  for
determining  whether  a  binding institutional   constraint  is
present  in  a particular  situation.   Appendix E provides  a
more detailed description of constraints  as well as informa-
tion sources.

     The  Agency  has  analyzed  the potential constraints  and
determined which  are probably binding, which may be binding
in some  cases or  possibly binding,  and which are unlikely to
be binding.   For a straight-forward assessment, comparison of
the constraints  affecting  a particular source  of water,  the
list of  constraints  presented in Table 4-4,  should suffice.
In those  cases where a  detailed assessment  is  warranted,  the
procedure outlined in Figure 4-16 is suggested.

               4.4.6.1  Example of  Considerations for a More
                        Detailed Assessment

               A potential source of replacement water  (e.g.,
the Rio  Grande  River)  may  be subject  to  an  international
treaty  (e.g., the 1944  Treaty between the  United States and
Mexico  on Utilization  of  the Waters  of  the  Colorado  and
Tijuana Rivers and of the Rio  Grande)  limiting the  amount of
water that  may  be withdrawn by  users in the  United States,
and to  an Interstate  Compact limiting the amount  of water
that may be used  within a  particular state.    In  addition,
that portion of the river flow assigned to a particular state
may already  be  fully taken up by other users.   Finally,  the
                             98

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                          TABLE 4-4

             POTENTIAL INSTITUTIONAL CONSTRAINTS
Probably Binding Constraints

   Water is subject to international treaty
   Water is subject to interstate water apportionment compact
   Water is allocated by the U.S. Supreme Court as  a result
   of litigation among states
   Water is subject to Federal or Indian reserved right
Possibly Binding Constraints

   Water is allocated by litigation among persons
   Water is allocated by permit
   Water  is allocated  by  local  water  district or  another
   local authority

   Amount of water that may be used is limited:
   -  by public trust doctrine
   -  by instream flow protection requirements
      by state law
   -  by permit
      by local management authority
   -  by  prior  appropriation(s)  that  are  all  for  highest
      beneficial use
   -  by Federal navigational servitude
   Place of use of water is limited:
      by state law
   -  by permit
      by local authority


Constraints Unlikely to be Binding*

   Water  is  subject  to  prior  appropriation  (unless  for
   highest beneficial use)
   Water is subject to riparian right
   Physical access to property is restricted:
   -  by property rights of other persons limiting rights-of-
      way for pipes, ditches, conduits, etc.
      by  Federal or  State  statutes  requiring environmental
      impact  assessment  or  establishing  other  procedural
      requirements.


*Upon application of simple administrative procedures or
 market transactions.
                            99

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                                                FIGURE 4-16
                  OUTLINE  OF  PROCEDURE  FOR  ANALYZING POTENTIAL INSTITUTIONAL
                   CONSTRAINTS TO THE USE OF AN ALTERNATIVE  SOURCE OF WATER
                                   Identify Potential
                                Institutional Constraints
                                  Related to Source
                                  Determine Type of
                                     Constraints
                    NO
                                                        YES
                                                        YES
                                                        YES
                                       Physical
                                        Access
                                      . Restricted
           YES
                       Identify Potential
                      Market  Mechanism
YES
Alternative Source
   Available
 Procedure
Available to
  Alleviate
 Constraint
                                                                   YES
                                                                                 Alternative is Subject to
                                                                                   a Binding Constraint
             Identify Potential
              Administrative
                Procedure
                                                      100

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            Capital costs:
                Well field development
                Raw water intake structure (wells)
                Water treatment facility
                Pumping stations
                Storage
                Transmission system
                Rights-of-way
                Land
                Relocation of utilities

            O&M costs:
                Labor, equipment
                Utilities
                Parts/inventory
                Administration

            Other costs:
                Architectural and engineering fees
                Legal and administrative fees

    There are  ample sources of information that may be used
for  estimating  costs.     These  include  Federal  and  State
agencies, architectural and engineering consulting firms (A/E
firms),  trade  associations, and  local water  utilities (ACT
Systems, Inc.,  1977,  1979; Temple, Barker  and Sloane,  Inc.,
1982; AWWA,  1981).   Costs can vary somewhat  from  one region
of the  country to another.  For  purposes of classification,
only a general estimate is needed and, initially, there is no
need to undertake a detailed cost estimation study.

     Various  EPA  reports  on  water  supply and  waste-water
treatment  are  also  a good  source of  information  on  costs
(e.g., Culp, et  al,  1978).  The  results  of such studies are
presented in the form of tables  and  cost curves,  subdivided
into  construction costs and O&M  costs.    This data can  be
updated  simply  to  allow  for  inflation  and  geographical
variations by energy and labor costs.

     Another useful data source is the MWWA Nationwide Water
Well Drilling Cost  Survey  (NWWA,  1979).   The results of this
survey are summarized in the form of  tables giving drilling,
as well  as casing  costs, as a  function of the well diameter,
hydrogeologic conditions,  and  other  factors.   Although this
survey dates back to 1979,  it is the most recent available
from NWWA.   The  data in the  survey  should be  escalated  to
account  for  inflation.   Cost  indices published quarterly  by
Engineering  News Record  give  a  very  recent  indication  of
construction, operation, labor, and other costs.
                            102

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     The  remaining portion  of Section  4.4 provides  useful
supplementary information for  most  classification decisions.
More  advanced  procedures  for use  in  special  cases,  are
provided in Appendices E and 6.

        4.4.7.1  Annualizing Capital Costs

        Capital costs  are the  initial  costs of  investments
needed  to develop  a  new drinking  water source.   They  may
include architectural and engineering fees,  as well as legal,
real  estate or  other  fees incurred  as part  of  planning,
constructing, and  implementating a new water system for this
analysis.

    For purposes of determining economic feasibility,  capital
costs  must be  annualized before they  can  be  added  to  O&M
costs  to  obtain the total  annual  costs of  the alternative.
Capital costs are  annualized by multiplying by an annualiza-
tion factor:

    Capital Costs x Annualization Factor (AF) =
    Annualized Capital Costs

The annualization  factor divides the total capital costs into
equal  annual payments  that  would be required  if  the capital
expenditures  were financed  using   a   standard  fixed-rate
mortgage.   As  a first cut,  a  factor of 0.1 can  be used.   A
more  refined  factor   should not  be necessary  but   can  be
computed according to Appendix E.

               4.4.7.2  Using Water  Supply  Utility Rates and
                        Fees to Estimate Costs of Alternative
                        Water Supply

               In  some circumstances,  the  cheapest alterna-
tive water supply available to a community  will  be a nearby
water-supply  utility.    The alternative  water-supply system
may  be  modeled  after  an   existing system that  serves  a
community  in the  same  region that  is similar in both popula-
tion  size and characteristics.  In such cases,  the  cost of
the alternative  supply may be  estimated  using  the rates and
fees charged  by the existing utility to  its service popula-
tion.

               4.4.7.3  Household   Income   of   Substantial
                        Population

               The   final   step   in  determining  economic
infeasibility  involves  comparing  the  annual  costs   of  the
alternative water  system to average household incomes in the
                             103

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community.  Income data is generally  available  in two forms:
per household  income  and per capita  income.  The two  may be
used interchangeably, by  factoring in the average  number of
persons  per household.   In  addition,  income  is  sometimes
reported as "personal  income"  or  "money  income."   Household
money  income   should  be  the  income  figure  used  for  this
exercise and is available from a number of sources.

     4.4.8  Economic Infeasibility (Option Bl

     Option B differs  from Option  A  in that no  specific
numerical cut-offs are dictated for  determining "substantial
population" or the  "economic  feasibility"  of  replacement.
Rather,  the relative size  of  the population  served  by the
source would  simply  be factors to consider in  assessing the
source's "replaceability."  A determination that  a source is
"irreplaceable" would require a qualitative assessment of the
technical  and economic  feasibility  of  replacing  it  talcing
into account  all  of  the  factors that may be relevant in any
specific case.  Some of the same steps in data  gathering and
analysis included in Option A might  be utilized,  or alterna-
tively,  other  procedures  could be substituted.   The overall
approach  to  determining  replaceability  would,  however,  be
more  qualitative in  character,  and  be more  dependant  on
professional judgment.

     4.4.9  Summary

     The  criteria  for Class I  irreplaceability may  be best
summarized through a hypothetical example.  Consider the city
of Waterfed, an urban area with a population  of 25,000, that
receives  its  water  from  a public well  system.    The water
meets  primary  drinking  water  standards  and  is  of  good
chemical  quality.    The  average  daily  usage  is  7  million
gallons-per-day.

     There  is  an alternative   to Waterfed's  central  well
field.   For the sake of simplicity,  assume that  this source
is either representative of other sources, or is  the only
alternative   drinking  water   source  within   a   reasonable
distance of the  city.   If the  alternative is to  serve as a
replacement,  it  must satisfy  the set  of criteria  which is
depicted  in Figure 4-17.   The first criteria is  that the
alternative water source must  be of comparable  quality to
water  in the  surrounding  area.   If the alternative source
were substantially inferior  to Waterfed's water  and conven-
tional treatment  could not improve the  quality to a compar-
able level, the city's ground water would be considered Class
I irreplaceable.   In this case,  the  alternative  is inferior
in terms of organic  materials, but  is substantially equiva-
                             104

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                               FIGURE 4-17
                TEST FOR CLASS I - IRREPLACEABLE GROUND WATER
                               SUBSTANTIAL POPULATION
                                           YES
                      IS THE PIPELINE DISTANCE TO REPLACEMENT
                             WATER SOURCE UNCOMMON?
       YES
                                           NO
           NO
               IS ALTERNATIVE WATER
               SOURCE OF COMPARABLE
                      QUALITY?
                                                                    NO
   WATER IS
   CLASS I
IRREPLACEABLE
   NO
                NO
                                            YES
                       WILL THE ALTERNATIVE SOURCE PROVIDE
                         COMPARABLE QUANTITY OF WATER?
YES
                          1
YES
                      DO INSTITUTIONAL CONSTRAINTS PRECLUDE
                         ACCESS TO REPLACEMENT SOURCE?
                                            NO
                                  IS REPLACEMENT
                              ECONOMICALLY FEASIBLE?
                                           YES
                                  WATER IS NOT
                                      CLASS I
                                  IRREPLACEABLE
  UNDER OPTION B, THESE STEPS
  ARE CONSIDERED QUALITATIVELY
                               105

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lent in  terms of heavy  metals and other  inorganics,  radio-
nuclides, and other physical  and  chemical properties.   The
level of organic contamination is  not  unusual  in the Region.
Conventional  water  treatment can remove the organic contam-
inants;  and,  Waterfed's  water, therefore,  is  not Class  I
Irreplaceable by this criterion.

     The next criteria  area  to  address  is  the  comparable
quantity  of  water.    If  the  alternative  cannot  provide
Waterfed with the  7  million gallons of water  it needs every
day, the ground water would be classified as Class I.

    The  next criteria   area   addresses   established  laws,
administrative systems, or other forms of social control over
access to water  which may preclude the use of  the potential
replacement water  source.   If there  are any  institutional
restrictions  that  do not allow the replacement water  to be
obtained through administrative procedures or  market  trans-
actions, Waterfed's  well water would be considered Class I.
No  such barriers  exist, and  Water fed's  well  water  is  not
Class I irreplaceable by this criterion.

    If  Waterfed's  water is  not  to  be  considered Class  I
irreplaceable, replacing the  city's  well water must  be an
economically  viable  option.   Under Option A,  the annualized
replacement cost to  a  typical  user must be within or greater
than 0.7 to  1.0  percent of the mean household  income  in the
community to  be Class I.  Waterfed's mean household income is
$20,000  per   year  and there  are  9,100 households.    If  the
annualized  cost of replacing the  city's ground water is
within  or  greater than  the range  of  $1.27 -  $1.82 million
($20,000 times 9,000 times  0.7 -  1.0  percent),  the water may
be designated Class I irreplaceable under this option.   Based
on  rough estimates,  the capital  cost for constructing  the
pipeline  to  pump  water  from  the  alternative  source  is
approximately $2 million. Using the simplified annualization
factor of 0.1 yields an annualized capital cost of $200,000.
The annual operating and maintenance costs are  likely to be
between  $150,000  and  $200,000,  yielding  a total annualized
replacement cost of  between  $350,000  and $400,000.   Since
this is  at most,  0.31 percent  of  the  mean household income,
Waterfed's current  water source  is replaceable  and,  there-
fore,  is, in  the final  analysis,  not  Class  I  irreplaceable.
There  is no  need to perform a more detailed  economic analy-
sis.

     Under  Option  B,  these  or  other  cost/ability-to-pay
factors  would be  addressed in a  more qualitative fashion.
Such analyses may indicate,  for example, that the area is not
"water-short" and that  the  community generally  seems able to
afford such services as  water  supply  improvement.   Thus,  the
supply is considered "replaceable" under Option B as well.


                               106

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          4.5.1.1  DRASTIC Methodology

          DRASTIC  is  an   acronym  representing  seven  key
hydrogeologic factors correlated to the potential for ground-
water contamination listed below:

     D - p_epth to the water table
     R - Net Recharge to ground water
     A - Aquifer media
     S - Soil media
     T - Jopography (slope of the land)
     I - Impact of the vadose zone
     C - Hydraulic Conductivity of the subject
         ground-water flow system

     The  DRASTIC  methodology   consists   of  several  steps
leading toward a  single  DRASTIC index number.   In the first
step, each factor is given  a  rating  between 1 and 10 (except
for net recharge, which  is rated between  1 and 9) depending
upon the  range of  parameter values within  a  hydrogeologic
setting.   Consider  the range of values for  depth to water,
and  corresponding  ratings,  shown  in Table  4-5.    A setting
with a  depth to  water of  28 feet  would be rated as  a  7.
(Tables listing the range of values and corresponding ratings
for each factor are provided in Appendix D.)

     In the second step, each factor rating is  multiplied by
a factor weight  to give a  factor index.    For  instance, the
weight for depth to water is 5 and, thus,  if the rating is 7,
the factor index is 35 (7 times  5).   For  the final step, the
individual factor indices are added together to arrive at the
DRASTIC index.

     The degree of confidence in a DRASTIC index number is a
function of the reliability of  the hydrogeologic information
used to  rate  each factor.   In settings where  the hydrogeo-
logic  information  is well  established,   due  to  localized
ground  water  and geologic  studies,   for  example,  the  index
will have  a  narrow  confidence  band.   As in  any procedure
involving professional judgment, a more experienced or better
trained evaluator will provide a more  accurate portrayal of
ground-water vulnerability to contamination.

     4.5.1.2  Application  of  DRASTIC  to  the Classification
              Review Area

     DRASTIC can be applied to the Classification Review Area
using one  of  two approaches.   In  the  most general approach,
the  ranges of  each  DRASTIC  factor can  be estimated  from
available  information  and  a  single  DRASTIC  index generated
                           109

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               TABLE 4-5
DRASTIC RANGE RATING FOR DEPTH TO WATER
       (FROM ALLER ET AL, 1985)
           Depth to Water
              (Feet)
Range
0-5
5-15
15-30
30-50
50-75
75-100
100+
Rating
10
9
7
5
3
2
1
             Weight:  5
             110

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for  the  entire  Classification  Review  Area.    The  average
rating for each factor would be chosen where the range in the
values of actual factor parameters spans two or more ratings.
For example, if the depth  to  water across the Classification
Review Area ranged from 5  to  30  feet,  then two ratings would
be bracketed  (see Table 4-5),  ratings of  9  through 7.   An
average rating of 8 would  be  chosen.   This approach does not
allow for the differentiation between hydrogeologic settings
within  the  Classification  Review  Area  where  the range  in
values of factor parameters may not be so variable.

     The  second  approach  is  to  map  out  the  major   hydro-
geologic  settings  that have  significantly different  DRASTIC
indices within the Classification Review  Area.   Differences
in DRASTIC  indices in the  range of 10  to 20 or  more index
points are  considered significant.  Where  DRASTIC units are
mapped out, an area weighted,  average  index can be computed.
However,  if the  activity occupies  any portion of a  DRASTIC
map unit  with  an  index greater  than the "highly vulnerable"
criterion, or, if more than 50 percent of the Classification
Review Area exceeds  the  criterion, the  setting   should  be
designated as highly vulnerable.

     As an illustration of the mapping approach, consider the
proposed activity shown in Figure 4-19.  Within the Classifi-
cation Review  Area,   three  hydrogeologic settings  have been
mapped and labeled:  A, B,  and C.  The DRASTIC index for each
hydrogeologic setting is    180,  140,  and  100,  respectively;
while, the  area for  each  setting is 20  percent,  45 percent,
and 35 percent, respectively.   The weighted  average  DRASTIC
index is calculated as follows:

                                          Area
          Map    DRASTIC   Proportion   Weighted
          Unit    Index      of Area     Index

           A       180         .20          36
           B       140         .45          63
           C       100         .35          35

                         Weighted Index   134

     For  this  illustration,   the  map-unit,   area-weighted
DRASTIC  index of  134  is   less  than  the  highly  vulnerable
criterion of  150.    If map-unit A  had been greater  than  50
percent of  the Classification Review Area,  or,  if the activ-
ity had  occurred in  map  unit A,  the designation of highly
vulnerable would have been automatic.
                            Ill

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                               FIGURE 4-19
                     ILLUSTRATION  OF DRASTIC MAPPING
                     MAP UNIT B
                     DRASTIC = I4O
                                 MAP UNIT A
                                 DRASTIC = 180
                                              MAP UNIT B
                                              DRASTIC =I4O
                                  MAP UNIT C
                                  DRASTIC = 100
EXPLANATION
	CLASSIFICATION REVIEW AREA BOUNDARY
                                                                         2 MILES
                                   Ilia

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          4.5.1.3  Limitations to the  Application of DRASTIC

          DRASTIC has been  designed to account for  a number
of different  conditions,  among  which  are multiple  aquifers
and  confined  aquifers.    There  is also  a  separate  index
designed strictly for agricultural analyses.

     The  DRASTIC methodology allows  for the  depth-to-water
rating to be adjusted for confined aquifers.   With this tech-
nique,  different aquifers  within  the Classification Review
Area could receive a different DRASTIC index.   Generally, the
deeper  aquifers  will be  less  vulnerable.   However,  contam-
inants entering  in a vulnerable  recharge area  may reach even
the deepest aquifer given sufficient time.   The system typic-
ally   favors  the uppermost aquifer  in determining vulner-
ability  and  a  single  DRASTIC  index attributable  to  the
Classification Review Area,  or subdivision of  the Classifi-
cation  Review  Area.   This  is  generally  consistent  with
Agency's  philosophy  that  the primary  aquifers  threatened by
the  bulk of  EPA regulated  programs  are  those  under  table
conditions.    Where  the  uppermost  aquifer  is  found to  be
vulnerable,  all  ground water  with  a  high  degree of inter-
connection  to  the   uppermost  aquifer  is  to  be  considered
highly  vulnerable.   Confined  aquifers with a  low-to-inter-
mediate  interconnection to  the  uppermost  aquifer  are  con-
sidered less vulnerable.

     The  DRASTIC method  also   establishes  a  separate  and
different set  of factor weights  for agricultural activities.
Because the  Agency  has  decided to  consider vulnerability as
independent of activity, only the regular factor weights will
be applied.

     4.5.2  Option B;  Qualitative Assessment

     In this option, the  user of Guidelines would select the
most  appropriate operational  tools   for  assessing  vulner-
ability. The selection might be based on factors such as site
setting,  professional   experience  of  the  user,  the  avail-
ability of  data, or previous  program experience.    In  some
cases,  general comparisons  of the  hydrogeologic  setting to
others where vulnerability  is  a  concern might  suffice.   The
analysis  might end  at  that point,  or  a detailed mapping or
flow net analyses might commence.  Option B is called "quali-
tative,"  since these Guidelines would not include  referred
tests  of  methods to follow,  or other  numerical  criteria/
decision steps.

     There  are  five  general  categories   of  vulnerability
methods which  have  been  analyzed  in  the  context  of  these
                            112

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Guidelines.  Within  each of the  five broad categories  is a
series  of  sub-approaches that  could  be  used.    Although
discussed in Appendix B,  the five are summarized in Table 4-
6. As  one moves from the  "qualitative  description" approach
through   to  the  "integrative  criterion",   sophistication
generally  increases  along with  cost and  complexity.    The
qualitative  approach  could  include  some  of  the  DRASTIC
factors as well.  Rather  than utilize the ranking and weigh-
ing scheme discussed  in the  previous section, or  all of the
seven DRASTIC factors could be reviewed for a given area, and
professional judgment used accordingly.
                              113

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     4.6  Determination of Reasonable Treatment

     The  ground-water classification  system  indicates  that
Class III ground  waters  are those which  (1)  contain greater
than  10,000  mg/1  total  dissolved  solids   (TDS);  (2)  are
yielded in insufficient quantities to satisfy the needs of an
average  household;   or  (3)  are  so  contaminated that  they
cannot  be  cleaned   up  using  treatment  methods  reasonably
employed in public water systems.  An  approach to define the
latter based  on a comparison to  "reference  technologies" is
provided  in  this  section.    An alternative approach,  new to
this  draft,  is  available  for  consideration  and  review.
Although  the  test  is somewhat more  complete  and,  perhaps,
expensive to perform,  it is  believed to be more rigorous and
definitive  in its  application.   The  alternative which can
eventually replace,  or be used in conjunction with "reference
technologies" is fully discussed in Appendix G.

     4.6.1  Standards and Criteria for Treatment

     The  above  definition  implies   that  an  analysis  of
treatment methods  should  consider relevant  "standards  and
criteria" for  long-term  drinking water use.   No one  set of
such  "numbers" are available  and thus,  some  professional
judgment may be required.

     Under the Safe  Drinking Water Act, for  example,  EPA has
issued  National Interim Primary  Drinking Water Regulations
(NIPDWR).   These  regulations set maximum  contaminant levels
(MCLs) for a  number of inorganic,  organic, and microbiologi-
cal contaminants  in drinking water.    These  values  are based
on both health factors and technical/economical feasibility.
MCLs for selected parameters can be found in Table 4-7.

     In  addition  to  MCLs  which  are  enforceable standards,
RMCLs  or  recommended maximum contaminant   levels  are  set
reflecting  EPA's  goal  of no  known  or  anticipated  adverse
health  effects.    Both  RMCL  and  MCL  values  are  updated
periodically.   For  example, proposed  RMCL values  for eight
volatile  organic chemicals  are  published   in the  Federal
Register  (1985).   It is the objective of the agency  to set
MCLs as close to RMCLs as possible.

     EPA  provides drinking  water suppliers  with additional
guidance under the  authority of the  Safe  Drinking Water Act.
EPA is  now  in the process,  for example,  of  developing RMCLs
for additional  contaminants  to serve  as  guidance for estab-
lishing new drinking  water MCLs.   The  Agency is accelerating
the pace of  both RMCL  and  MCL  issuance.    Other  chemicals
addressed under the Clean  Water Act (CWA)  may be  inter-
                           115

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                          TABLE 4-7
        RMCL  & MCL VALUES FOR SELECTED CONTAMINANTS1
 Contaminants                     RMCL               MCL
                                 (mg/1)              (mg/1)

Inorganic Species:
  Arsenic                         0.05               0.05
  Barium                           1.5                  1
  Cadmium                         .005              0.010
  Chromium                         .12               0.05
  Fluoride                          -              1.4-2.4
  Lead                           0.020               0.05
  Mercury                         .003              0.002
  Nitrate (as N)                    10                 10
  Selenium                        .045               0.01
  Silver                            -                0.05

Organic Species:
  Benzene                            0
  Vinyl Chloride                     0
  1,1-Dichloroethylene           0.007
  1,1,1-Trichloroethane           0.20
  p-Dichlorobenzene              0.750
  Trihalomethane                    -                 .1
  Lindane                           -              0.004
Sources:  Federal Register, Vol. 50, No. 219, Nov. 13, 1985.
           p 46889, p 46958, p 46957.
           Guidance on Feasibility Studies Under CERCLA, June
           1985, U.S. EPA, Cincinnati, Ohio
                              116

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mittently encountered in a water  system,  and are believed to
pose a risk for the near term,  yet are currently unregulated
in drinking water.  The guidelines for these are developed by
the  Office of  Drinking Water in the  form  of Health  Ad-
visories.  The health advisories are not mandatory for public
water systems,  but provide  information for  emergency situ-
ations.  (Health Advisories are available on some contaminants
where no MCLs or  RMCLs are published, Table  4-8.)   They are
calculated at three exposure levels:   one day,  seven  or ten
days, and longer term  (1 to  2  years).   A margin of safety is
factored in  to protect the  most sensitive  members  of  the
general population (U.S. EPA, 1985; Federal Register, 1985).

     Finally,  the  RCRA program in developing  its  Alternate
Concentration Limits  (ACLs), and  in  responding to  the  land
disposal bans portion of the RCRA amendments of 1984, will be
examining  the  applicability  of  other  sets  of  criteria  and
standards for both carcinogenic and non-carcinogenic contam-
inants.   These will likely be useful for addressing the large
number of contaminants without current MCLs,  RMCLs, or health
advisories.

     4.6.2  Treatment Technologies

     Many different treatment technologies are currently used
for treating surface and ground waters which serve as public
drinking water  supplies.   These technologies  can be classed
into  five  general categories:  volatile  organic  chemicals
removal;  non-volatile  organic   chemicals  removal;  metals
removal;   non-metallic  inorganic  chemicals   removal;   and
disinfection.    Some technologies  are effective  in reducing
only  a  few types of  contaminants, while others  may effi-
ciently  treat  several contaminant classes  simultaneously.
Although  most  processes  are  designed to   treat  a  single
"class" of  contaminants,  many will provide  some beneficial,
non-design removal of other contaminant classes.  (Appendix E
briefly  describes each  of  several  generic  treatment tech-
nologies  with  reference  to  their  appropriate  usage  and
limitations.)

          4.6.2.1  Regional    Availability    of   Reference
                   Technologies

          Table 4-9  presents  the use  of various  treatment
technologies by EPA  Region.   Most of  the  reference tech-
nologies are currently  in  use at  public water supply systems
in  all  regions  of the  country,  however,  not necessarily in
hazardous-waste  applications  (e.g.,  carbon  adsorption  is
sometimes  used  in taste  and odor applications and not for
removal of  volatile  organics).   The exceptions  to this are
                              117

-------
                         TABLE  4-8
    HEALTH ADVISORIES FOR SELECTED CONTAMINANTS IN WATER
CHEMICAL
Benzene
Carbon Tetrachloride
Chlordane
1, 1-Dichloroethylene
1, 2-Dichloroethylene
1, 2-t-Dichloroethylene
Dichloromethane
Ethylene glycol
Formaldehyde
n-Hexane
p-Diozane
Methyl Ethyl Ketone
Polychlorinated
biphenyls (PCB)
Tetrachloroethylene
Toluene
1,1, 1-Trichloroethane
Tr i chl or oe thy 1 ene
Xylenes
Health
1-day

0.2
0.0625
1.0
4.0
2.7
13
19.0
0.030
13
5.68
7.5
0.125 0
2.3
21.5

2.0
12
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0.23
0.02
0.0625

0.4
0.27
1.3

0.030
4.0
0.598
0.75
.0125
0.175
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0.2
1.2

Longer
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0.07

0.0075
0.07


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0.02
0.34
1.0
0.075
0.62
aTotal trihalomethanes refers to the sum concentration of
 chloroform, bromodichloromethane,  dibromochloromethane,
 and bromoform.
                             118

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                                      TABLE  4-9
                APPLICATION OF TREATMENT TECHNOLOGIES  IN  PUBLIC WATER
                           SUPPLY SYSTEMS, BY EPA REGION3
Technologies Applied
in All Regions

  Aeration"
  Carbon Adsorption
  Chemical Precipitation
  Chlorination
  Flotation6
  Fluoridation
  Granular Media Filtration

Technologies Applied
in Some Regions

  Air Stripping0
  Desalination
  Ion Exchange
  Ozonation

Technologies Generally
Not Applied3

  Distillation
  Wet Air Oxidation
  Biological Treatment
 6
 7
28
A3
30
30
20
 3
 0
 0
 0
 0
 0
 0
                                   II   III
28
12
55
99
64
38
48
 3
 0
 5
 0
 0
 0
 0
                  Number of Systems Identified

                 IV    V   VI   VII   VIII    IX
21
 8
67
96
94
42
61
 4
 0
 3
 1
 0
 0
 0
 58   96   9
  4   13   3
109  227  25
161  292  70
186  217  58
 97  211  15
107  185  32
  2
  5
  2
  2
  0
  0
  0
 0
 0
28
 0
 0
 0
 0
0
6
1
0
0
0
0
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          86
          90
          57
          65
0
0
2
0
0
0
0
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0
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0
0
0
0
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           119
            80
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 0
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 0
 0
 0
 0
a This table  is based  primarily on  data available in the 1981 AWWA Survey of Public
  Water Supply Systems, and supplemented with  case studies  drawn from  the available
  literature.   The data  reflect only the use of the technologies in water utilities,
  and to not represent usage patterns of those  technologies for  wastewater or indus-
  trial process  water treatment.  Data describing 1500-1600 public water systems were
  consulted.

b The AWWA Survey includes air stripping in this category.

c Plants were identified independent of the AWWA survey.

" No evidence of application of these technologies was found in  the set  of 1500-1600
  public water systems examined.

e Includes technologies using skimming, diffused air, diffused oxygen, and pressurized
  gases.                                 119

-------
desalination,  ion  exchange, and  ozonation; these  treatment
technologies nay be considered reasonably employed in certain
Regions.  Air stripping, which is most often used for removal
of volatile  organic solvents  from  ground waters,  should  be
considered "available"  for Class III analyses,  despite  its
limited use in public water supply systems.

     Other treatment  technologies may be applicable  in  the
future,  but   are  not  now  considered readily  available  or
reasonably employable.    Distillation techniques have  long
been  employed  for  treating  industrial   process  water,  for
example,  but  is  generally reserved for  such  water,  for
example, but  is generally reserved  for such areas  as water-
short  islands.    Biological treatment techniques have  been
used  for in  situ  clean  up of  ground  waters  and  although
efforts  to  develop  biological treatment technology  is  not
applicable  or  reasonably  employable.    Wet  air  oxidation
techniques are  used in  industry  for  removal of  organics from
process wastewater.   Efforts to develop  this technology  for
application  in water treatment  are  also underway,  but  the
techniques should not be considered reasonably employable.

     The  reference  list  of these technologies are  used  to
define the set  of available water treatment technologies.   A
partial bibliography of resources and references  is given in
Appendix E.

          4.6.2.2  Treatment Efficiencies

          Evaluation of  treatment efficiencies for  a single
contaminant or  group of contaminants requires the evaluation
of  interferences  and interaction  of contaminants.   General
background data on  treatment  performance indicate  ranges  of
values  for  efficiency.    For  example,  EPA's  Treatability
Manual  for Priority  Pollutants  (U.S.  EPA,  1980),  presents
examples  of  typically  achievable   contaminant  removal  ef-
ficiencies for  a range of contaminants and technologies.

     More  precise  determination requires  pilot testing  or
comparison  by  experts  with  other   similar  waste  streams.
Appendix E indicates the general level-of-success the various
treatment technologies have with frequently encountered waste
streams.    Removal  efficiencies are not  reported   in  the
literature for  all  contaminants,  as  experience  using certain
technologies  is not available.

     Contaminant  concentration,   physical  conditions  (e.g.,
pH,  temperature),   solution chemistry,  and the  presence  of
competing or  interfering contaminants can  all  contribute  to
the  large   variations   in  removal   efficiencies  that  are
                            120

-------
reflected in the literature.   For  situations  in which a more
accurate assessment of treatment efficiencies is desired, the
user  of these  guidelines may wish  to refer  to a  partial
bibliography of sources listed at the end of Appendix E.

     Table  4-10 lists  some  of  the  major advantages,  dis-
advantages,  and limitations  associated with each  treatment
process.    For  developing  process  configurations,   it  is
usually desirable to remove the  contaminants  first  that they
may interfere with  subsequent processes.  For  example,  if a
system uses both granular media filtration for solids removal
and ion  exchange  for softening,  the  filtration stage should
precede  the  ion  exchange  stage  in  order  to assure  that
potential  resin-fouling  solids  are  eliminated  from  suspen-
sion.   As  another example,  plants  with solvent contamination
will  air  strip  or carbon  adsorb  the organics  prior  to
chlorination,   to   prevent  the   formation   of  halogenated
organics which are less efficiently removed.

     4.6.3  Methodology for Determining Treatability

     To determine if a ground water can be cleaned up using
treatment  methods   reasonably  employed  by   public  water
systems, the permit reviewer may  wish  to follow the steps
described below.

     1. Describe the contamination problem.

     The  description  of  the contamination  problem  should
include  information  on  the  natural   or  background  water
quality,  the  extent  of  contamination,  and  the  physical
factors  influencing both  ground water  and  treatment.   The
natural  quality  of a ground water  may be   inferred  from
historical data or  by  comparison to  background ground waters
in the site vicinity.

     Contaminants in  the ground water of concern  should be
specified and the range in concentrations noted.  In particu-
lar,  if  the  type   and   concentration  of  contaminant  vary
spatially, this should be indicated as it has design implica-
tions  for  treatment configurations.   The analyses used and
the range  of sampling and measurement  error should  also be
provided to  assist  the reviewer in  understanding the degree
of  certainty of contamination.   It  is  important to  address
the areal  extent of  contamination to  be  sure  it meets the
basic  notion that  contamination  is  not  related to  an in-
dividual facility or activity.

     The  physical parameters  of  concern  include flow pat-
terns, climatology, and  other site-specific  issues.   Many of
                              121

-------





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the treatment  processes  are highly sensitive  to temperature
fluctuations;  therefore,  ambient  temperature  ranges  become
important  in selecting  appropriate  technologies or  housing
requirements.  The climate  in the  area  of concern,  including
data on the  freeze/thaw  cycles, and any storm  or wind events
that may  affect the  treatment  processes  must also be  con-
sidered,   other   site-specific   considerations   may   become
important on a case-by-case basis.

     2.  Determine the desired effluent quality

     To determine  the desired quality  of the treated water
following  completion  of  all treatment  processes,  acceptable
concentrations  for   each   contaminant   must  be  addressed.
Relevant Federal Criteria include  the MCL, the RMCL,  and the
longest-term Health  Advisory for  each  contaminant.    These
values are sometimes unavailable for certain contaminants due
to insufficient data.

     3.  Define the applicable treatment technologies

     For each  contaminant  present,  certain treatment tech-
nologies may be particularly applicable.   Refer  to  Table 4-8
and Table  4-9  and  supplementary information  in Appendix E to
identify regionally available  removal technologies  for each
contaminant.  This list  of  technologies should be considered
the universe of  available processes for  treating the ground
water.

     4. Compile regionally available process configurations

     Before  assessing ground water treatability, the permit
reviewer must  define  a  set of treatment  process configura-
tions that may be used to remove contaminants from the ground
water.   These process  configurations  should be  developed
considering  efficient  contaminant removal  to  the  minimum
level  required.   Any  combination  of  the treatment  processes
should be  considered readily available nationwide.

     5.  Evaluate treated water quality

     To evaluate  typically achieved water quality  using any
given  treatment  process configuration,  the  concentration of
specific contaminants in the ground water/influent,  levels of
background water  quality parameters  (pH, TDS, etc.)  and the
removal efficiencies  of each contaminant using each treatment
process ideally should be known.

     Background data/manuals on treatability developed by EPA
can be consulted for initial guidance  on treatment perform-
                             126

-------
ance. For example, typical removal efficiencies are indicated
in EPA's  Treatability Manual  for Priority  Pollutants  (U.S.
EPA,  1980).  A qualified  water treatment engineer could also
determine the relative effectiveness and a probably range of
effluent  quality  levels   achievable   for  many  frequently
encountered  contaminant  mixes.    Interference effects  pos-
sibly,  from  adverse levels  of various  contaminant combina-
tions,  background  water-quality  parameters  (e.g.,  pH,  or
heavy   metals,   varying   concentrations),   can   affect  the
efficiency  of treatment  processes.    Because of  this,  in
complex mixtures or where little experience exists, the lack
of bench  or the pilot scale treatability  studies  may  limit
the ability of the engineer in developing an estimate.

     6.  Determine if desired water quality is met.

     Once  the approximate   effluent  concentration of  each
contaminant has been evaluated for a given treatment process,
these  can  be compared   to the  appropriate  water  quality
standard.   If  all effluent concentrations  are less than the
desired water  quality,  the  ground water  can be  cleaned up
using treatment  methods  reasonably employed  in  public  water
supply  systems.   If  some  effluent contaminant concentrations
exceed  desired water quality,  the treatment process config-
uration does  not adequately clean the  ground water, and an
alternative configuration should be evaluated for contaminant
treatability.  If all available treatment process configura-
tions do  not remove  contaminants to the levels which meet
desired water quality, the  ground water cannot be cleaned up
using treatment  methods  reasonably employed  in  public  water
supply systems.  These will then be candidates for Class III.

     4.6.4  Sample Problem

     The following  example  is  illustrative  in nature and is
not meant to represent conditions at any specific facility.

     A  permit applicant  has  asked  to  site  a   facility  in
Region IV, and has made the claim that the site location will
only  affect  Class  III  ground  water.     The  chemical  con-
taminants  in the ground  water,  listed in  Table  4-11,  are
apparently  from  multiple sources and  occur  throughout  the
Classification Review Area.

     The desired water quality levels are listed in Tables 4-
7 and  4-8.   For  cadmium  and selenium the applicant defines
the desired maximum effluent contaminant concentrations  to be
equal to  the MCLs  as presented  in  Table  4-7.   For  carbon
tetrachloride, desired effluent quality is  derived from the
ten-day  Health  Advisory   (the  only  available),  while  for
                               127

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toluene, trichloroethylene,  and tetrachloroethylene  a long-
term Health Advisory was used.

     The treatment  processes that most readily  removes such
volatile organics such as carbon tetrachloride, tetrachloroe-
thylene,  and  toluene  include  carbon  adsorption  and  air
stripping.    Metals,  such as  cadmium and  selenium,   can  be
removed using  chemical precipitation, desalination,  and ion
exchange.    Granular  media  filtration  would  probably  be
considered  for  removal   of  residual   particulate  matter,
following  a  chemical precipitation  step,  particularly  if
desalination,   carbon adsorption,  or  ion exchange  processes
followed.   All of  these  processes are  currently in  use  in
public water supply systems in Region IV.

     Achievable effluent  quality must be evaluated  for each
treatment process  configuration to determine if the ground
water can be  treated to meet desirable levels.   Process and
contaminant specific removal  efficiencies  are  provided for
all six contaminants.   (Please note:   these values  are  to
illustrate  the process and  are  not  intended  to be actual
efficiencies.)   As  indicated by  calculated  WQO values and
comparing  them  with  WQd  values  (Table  4-10),  treatment
process configuration A can  result in removal of trichloroe-
thylene,  tetrachloroethylene,  and carbon  tetrachloride  to
acceptable levels.   However,  levels of cadmium, selenium, and
toluene following treatment using process configuration A can
not meet the desired water quality.  Therefore, the applicant
must consider an additional treatment process configuration.

     Removal  efficiencies for  the process  configuration  B
including air  stripping,  chemical precipitation, filtration,
and desalination can achieve acceptable water quality levels
for all  contaminants.   Thus, according to  this methodology,
this ground water is not  Class  III because  it can be cleaned
up  using treatment methods  reasonably  employed in public
water supply systems.

     An alternate economically-based test for determining the
treatability of potential Class II ground  water is proposed
in Appendix G.
                             129

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4.7  Ground-Water and Surface-Water Interaction

     Interconnected  ground  water  and surface  water nay  be
managed or  regulated for different,  and  sometimes  conflict-
ing, uses.   The Agency  recognizes that  the  interconnection
and  interaction  between  ground  water  and  surface  water
necessitates  coordination between  efforts to classify  and
manage both kinds of water resources.

     Two conditions  involving the  interaction between ground
water and surface water deserve consideration in ground-water
classification.   One  condition is  the  recharge of  ground
water from a surface-water body.   The other is the  discharge
of ground water to surface water.

     4.7.1  Ground-Water Discharge to Surface Water

     Ground-water discharge to surface-water bodies  occurs in
many hydrogeologic settings and  is the dominant condition in
high  rainfall  areas.    Where  poor  quality  ground-water
discharges  to  surface  watert   a  potential  to  impact  the
quality of  those  surface waters exists.   The classification
system accounts  for three conditions where ground  water  is
interconnected  to  surface  waters  and  where  surface-water
quality may be degraded:

        Class  I Ecologically  Vital  Ground  Water   -  Ground
        waters providing base flow to,  or supporting  water
        levels  for,  unique terrestrial  or aquatic  habitats
        associated with water bodies;

        Class  II  Current Source of  Drinking Water  - Ground
        waters currently used as a source of  drinking water,
        including those  ground waters  which  discharge to a
        drinking  water  supply  reservoir with a  protected
        watershed

        Class  III  Ground Waters Not  a  Potential Source  of
        Drinking Water - Saline or  regionally contaminated
        ground  waters that  are  interconnected  to  adjacent
        ground waters or surface waters.

     4.7.2  surface Water Recharge to Ground Water

     The recharge  of ground water from a surface-water body
is  the  natural and prevalent means of ground-water recharge
in  the drier  western states,  but can  also  occur  in high
rainfall-rich  areas due  to  the pumping  or ground  water  in
                              130

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close proximity  to the water body.   An example  of  surface-
water recharge  to ground  water concerns the  use of  stream
impoundments to accelerate recharge.  Figure 4-20 shows such
an impoundment,  referred to  as a recharge basin  on  a  stream
crossing the recharge  zone of the Edwards Aquifer in  Texas.
Another example is the recharge of Mohawk River waters into a
sand and  gravel aquifer which  supplies well  fields serving
the  cities  of  Rotterdam  and  Schenectady,   New  York,  as
demonstrated  in  Figure  4-21.    The following  Figure  4-22
indicates  that  the warmer river water enters the  aquifer,
mixes  with  the cooler  ground  water,  and  is  subsequently
withdrawn by the wells.

     The potential for poor  quality  surface water to degrade
ground-water quality  is  implied in these examples.    They
further demonstrate  the need  to consider surface-water use
and quality  in  managing ground-water quality  where  surface-
water bodies provide  significant recharge.  The  classifica-
tion system  by  itself, however,  is not  intended to  be the
focus for managing such settings.
                             131

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                          FIGURE 4-20
              ILLUSTRATION OF SURFACE WATER RECHARGE TO
              GROUND WATER FOR THE EDWARDS AQUIFER, TEXAS
                       RECHARGE
                         ZONE
     UNCONFINED
     EDWARDS FORMATION
A-
        RECHARGE POND-/
          CONFINED
          EDWARDS FORMATION
                             RECHARGE DAM
                                -A1
                                             o WATER SUPPLY
                                              WELL
                       PLAN
EDWARDS
FORMATION" II
RECHARGE
  ZONE
         GLEN ROSE
         LIMESTONE
                                    GLEN ROSE
                                     LIMESTONE
                     ^ WATER SUPPLY
                     (WELL
                           *£ SOIL COVER
                                                 CONFINING
                                                 CLAY UNIT
                                                  EDWARDS
                                                  FORMATION
              CROSS-SECTION
                             132

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                                    FIGURE  4-21
                  CROSS-SECTION OF AN ALLUVIAL AQUIFER SHOWING
                  SURFACE WATER RECHARGE FROM THE MOHAWK RIVER
                                       WELL FIELD A
WELL FIELD B
                      MOHAWK
                       RIVER
 .; •- SAND AND GRAVEL .;.. • '.?.: .• •>.••«.•.-•«.• •„*.• ••:.:• «...
?##>^^
•• •. •-.,••'.".'.».-• »•..•:-*•.;-'•.• V'- •;.• .'•:«•.:• fv:•;:.-MIJ.V'--
                                      133

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                                       134

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                       5.0  REFERENCES

American Water Works  Association,  1981.   1981  Water Utility
     Operating Data.

Act, Systems,  Inc., 1979.   Volumes  I  & II, Managing Small
     Water Systems: A Cost Study Prepared for U.S. EPA, Water
     Supply  Research  Division.     Municipal  Environmental
     Research Labs, MERL.

Act, Systems,  Inc.,  1977.   Volumes  I  and  II,  The  Cost of
     Water Supply  & Water Utility Management,"  Prepared for
     U.S. EPA Water Supply Research Division, MERL.

Aller,   Linda,  Truman Bennett,  Jay H.  Lehr, and  Rebecca J.
     Petty,    1985.    DRASTIC  A  Standardized  System  for
     Evaluating  Ground   Water  Pollution   Potential  Using
     Hydrogeologic  Settings.   R.S.  Kerr,  Envir.  Res. Lab.,
     EPA/600/2-85/018; Ada? Oklahoma.

American Public  Health Association,  et al,  1976.   Standard
     Methods  for the  Examination of Water  and Wastewater,
     14th  edition.    American  Public  Health  Association;
     Washington, D.C., 1193 pp.

DiNova  F.  and M. Jaffe,  1984.   Local Regulations for  Ground-
     Water Protection Part  I:  Sensitive Area Controls.  Land
     Use Law and Zoning Digest.  Vol. 30, No. 5, P.6 to 11.

Flach,   Y.W., 1973.   Land Resources.   In: Recycling Municipal
     Sludges and Effluents  on  Land.   University of Illinois;
     Champaign, Illinois.

Freeze, R.A. and J.A.  Cherry,  1979.   Groundwater.  Prentice-
     Hall, Inc.  Englewood Cliffs, N.J.

Freeze,  R.A.  and  P. A.   Witherspoon,   1967.    Theoretical
     Analysis of Regional Ground-Water Flow:  3.  Quantitative
     interpretations.   Water  Resources  Research  4,  pp 581-
     590.

Geraghty & Miller,  Inc., 1984.  Stochastic Model of  Correc-
     tive  Action Costs  at Hazardous Waste Management  Facili-
     ties.   Final  Report prepared  for  U.S. EPA,  Office of
     Solid Waste; Annapolis, Maryland.

Heath,   R.C.,  1984.    Ground-Water  Regions of the  United
     States.  U.S. Geological Survey Water Supply Paper 2242,
     U.S. Government Printing Office, Washington, D.C.
                            135

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Heath, R.C., and F.W. Trainer,  1981.   Introduction to Ground
     Water Hydrology.  Water Well Journal Pub. Co.; Worthing-
     ton, Ohio.

Hubbert, M.K., 1940.  The Theory of  Ground-Water Motion.   J.
     Geo., 48, pp 785-944.

LeGrand, Harry E.,  1980.   A Standardized System for Evalua-
     ting Waste-Disposal Sites.   National Water Well Associ-
     ation;  Worthington,  Ohio.

Milde, G.,  K.  Milde, P. Friesel;  M.  Kiper, 1983.   Basis in
     New  Development   of   Ground-Water  Quality  Protection
     Concepts in Central Europe.  Papers in the International
     Conference  Ground-Water and  Man,  Vol.  II, p  287-295.
     Austrialian Government Printing Service, Canbarra.

National Water Well Association, 1979.  Water Well Drilling
     Cost Survey.  NWWA, Worthington, Ohio.

Office of Solid  Waste,  U.S.  Environmental  Protection Agency,
     1984.  Permit  Writer's  Guidance Manual for the Location
     of Hazardous Waste Land Storage and Disposal Facilities
     - Phase  1;  Criteria  for  Location  Acceptability  and
     Existing  Regulations   for Evaluating  Locations.    U.S.
     Environmental Protection Agency;  Washington, D.C.

Office  of Research  and Development, Municipal  and Environ-
     mental Research Laboratory/ U.S.  Environmental Protec-
     tion  Agency,   1980.    Design Manual:   Onsite Wastewater
     Treatment  and  Disposal  Systems.    Technology Transfer;
     Cincinnati, Ohio.

Office  of  Water  Programs,  U.S.  Environmental  Protection
     Agency,   1975.     Manual  of  Individual  Water  Supply
     Systems.  U.S.  EPA; Washington, D.C.

Qui.lan,  J.E.   and  R.O.  Evans,  1985.   Ground-Water  Flow in
     Limestone  Terranes:  Stragety,  Rationale  and Procedure
     for  Reliable,   Efficient  Monitoring  of  Ground-Water
     Quality  in  Karst Areas.   From Proceedings 5th, National
     Symposium and  Exposition  on  Aquifer  Restoration  and
     Ground-Water  Monitoring,  National Water  Well Associa-
     tion, Worthington, Ohio.

Silka,  Lyle R.  and Ted L.  Sweringer,  1978.    A  manual for
     evaluating  contamination potential of surface impound-
     ments.   U.S.  Environmental Protection Agency, Office of
     Drinking  Water,  EPA 570/9-78-003;  Washington, D.C.
                              136

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Temple, Barker & Sloane, Inc., 1982.  Survey of Operating and
     Financial  Characteristics  of  Community Water  Systems.
     Prepared for U.S. EPA, Office of Drinking Water.

U.S. Environmental  Protection Agency,  1980a.   Treatability
     Manual for Priority Pollutants.  U.S. EPA, EPA 600/8-80-
     042, a-e; Washington, D.C.

U.S. Environmental  Protection Agency, 1980b.   Water Quality
     Management Directory, Agencies and Funding Under Section
     208, 4th Edition.  U.S. EPA; Washington, D.C.

U.S. Environmental  Protection Agency,  1980c.   Design Manual:
     Onsite   Wastewater  Treatment  and   Disposal  Systems.
     Office  of Research  and Development  Municipal  Environ-
     mental Research Laboratory.  Cincinnati, Ohio.

U.S. Environmental Protection Agency, 1984.  National Statis-
     tical Assessment  of  Rural  Water Conditions.   Office of
     Drinking  Water  (WH-550)  Publication  EPA 570/9-84-OC4;
     Washington, D.C.

U.S. Environmental  Protection Agency,  1984b.   Ground-Water
     Protection Strategy.   Office of Ground-Water Protection,
     Washington, D.C.

U.S. Environmental  Protection  Agency,  1985b.    Guidance on
     Feasibility Studies Under CERCLA, EPA/540/6-85/ 003.

U.S. Environmental  Protection Agency,  1985.   Draft Report-
     Liner Location Risk and Cost Analysis Model, Appendix C.
     Office   of  Solid  Waste,    Economic  Analysis  Branch;
     Washington, D.C.

U.S. Geological  Survey, 1984.  National  Water Summary 1984.
     Water  Supply  Paper   2275.     United States  Government
     Printing Office, Washington, D.C.
                             137

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  PART III




APPENDICES

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APPENDIX A




  GLOSSARY
    A-l

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                         APPENDIX A
                          GLOSSARY*
AQUIFER - A geologic formation, group of geologic formations,
     or part of a geologic  formation that yields significant
     quantities of water to wells and springs.

AQUIFER SYSTEM - A  heterogeneous  body of intercalated perme-
     able and  less  permeable material that acts  as  a water-
     yielding hydraulic unit of regional extent.

AQUITARD - A confining bed that retards, but does not prevent
     the  flow  of water  to  or  from  an adjacent  aquifer;  it
     does not readily yield water to wells or springs.

CONE  OF  DEPRESSION -  A depression  in the  POTENTIOMETRIC
     SURFACE of a body of ground  water that has the shape of
     an inverted cone and develops around a pumped well.

CONFINED  CONDITIONS -  Exists  when  an  aquifer  is  confined
     between two layers  of  much less pervious material.  The
     pressure  condition  of  such  a  system  is such  that  the
     water level  in a well penetrating  the confined aquifer
     usually rises above the top of the aquifer.

CONTAMINANT PLUME  - Irregular  volume  occupied by a body of
     dissolved or suspended pollutants in ground water.

CRA - Abbreviation of Classification Review Area.

DISCHARGE AREA - A  discharge  area is an area of land beneath
     which there  is a net annual transfer  of  water from the
     saturated zone to a surface-water body, the land surface
     or  the  root  zone.     The  net  discharge  is  physically
     manifested by  an increase  of hydraulic heads with depth
     (i.e., upward  ground-water  flow to  the  water table).
     These zones  may  be associated with  natural  areas  of
     discharge  such  as  seeps,  springs,  caves,  wetlands,
     streams,  bays,  or playas.

ECOLOGICAL  SYSTEM  (ECOSYSTEM)  -  An  ecological  community
     together with its physical environment.

ECOLOGY - The  science of the relationships between organisms
     and their environment.


*For  general  information only — not to  be viewed  as  sug
gested or mandatory language for regulatory purposes.
                            A-2

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ECOSYSTEM - See ECOLOGICAL SYSTEM.

FLOW  NET -  A graphical  presentation  of  ground-water  flow
     lines and lines of equal pressure head.

GEOLOGIC FORMATION - A body of rock that can be distinguished
     on the basis of  characteristic  lithologic features such
     as chemical composition, structures, textures,  or fossil
     content.

GROUND-WATER  -  Subsurface water within the zone of  satura-
     tion.

GROUND-WATER  BASIN  - (a) A subsurface structure having the
     character of  a  basin  with respect to the  collection,
     retention,  and  outflow  of water,  (b) An aquifer,  or
     system  of  aquifers, whether  or not basin-shaped,  that
     has  reasonably well defined hydrologic boundaries and,
     more or  less,  definite areas  of recharge  and discharge.

GROUND-WATER  FLOW   DIVIDE  -  An imaginary  plane  (or  curved
     surface)  distinguished by  the limiting  flow lines  of
     adjacent  flow  systems.   Conceptually  there  is  no flow
     across this plane between the flow systems.

GROUND-WATER  FLOW REGIME  -  The sum total of all ground water
      (water   within  the  saturated  zone)   and  surrounding
     geologic media (e.g.,  sediment and rocks).  The top of
     the  ground-water regime  is the  water table  while the
     bottom  would   be the  base  of  significant ground-water
     circulation.    Temporarily perched waters  within the
     vadose  zone would  generally not qualify  as  part of the
     ground-water regime.

GROUND-WATER  FLOW  SYSTEM  (GROUND-WATER  SYSTEM)  -  A  body of
     circulating  ground  water  having  a  water-table  upper
     boundary and  ground-water flow divide  boundaries along
     all  other sides.   These boundaries encompass distinct
     recharge and discharge areas unique to the flow system.

GROUND-WATER  SYSTEM - See GROUND-WATER FLOW SYSTEM.

HYDRAULIC CONDUCTIVITY  - The capacity  of earth materials to
     transmit water.

HYDRAULIC GRADIENT  - The change in  STATIC  HEAD per-unit-of-
     distance in a  given direction.

HYDRAULIC HEAD GRADIENT - See HYDRAULIC GRADIENT.
                            A-3

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PIEZOMETRIC SURFACE - See POTENTIOMETRIC SURFACE.

POTABLE WATER  -  Water that is  safe and palatable  for  human
     use;  concentrations of  pathogenic organisms  and  dis-
     solved  toxic constituents  have  been reduced to  safe
     levels, and  it  has been treated  so as to be  tolerably
     low in objectionable taste, odor,  color,  or turbidity.

POTENTIOMETRIC SURFACE  (PIEZOMETRIC SURFACE)  - An  imaginary
     surface representing the STATIC HEAD of ground water and
     defined by the level to which water will rise in a well.
     The WATER TABLE  is  a particular potentiometric surface.

RECHARGE AREA  -  A recharge area  is an area of  land beneath
     which  there  is  a net  annual transfer of water through
     the vadose  zone  into the ground-water regime.   The net
     recharge is manifested by an decrease in hydraulic heads
     with  depth  (i.e.,   downward  ground-water  flow  from the
     water table).

SATURATED ZONE - A subsurface zone in which all the voids are
     filled  with  water under pressure greater than  that of
     the atmosphere.   This zone  is  separated  from  the over-
     lying  zone  of aeration (unsaturated  zone) by  the WATER
     TABLE.

STATIC HEAD  (HYDRAULIC HEAD) - The height above a datum plane
     of the surface of a column of water (or liquid) that can
     be supported by the static pressure at a given point.

STRESS  (PUMPING STRESS)  - Drawdown of  water level and change
     in HYDRAULIC GRADIENT induced by pumping ground water.

SURFACE-WATER  DIVIDE -  The  line of  separation,  or ridge,
     summit,  or  narrow  tract  of high  ground,   marking the
     boundary  between   two   adjacent   drainage   basins,  or
     dividing the  surface waters that flow naturally in one
     direction from  those that  flow in the opposite direc-
     tion.

TOTAL  DISSOLVED  SOLIDS   (TDS)  -  The  quantity of  dissolved
     material in a sample of water determined either from the
     residue  on   evaporation  by  drying  at 180°C,   or,  for
     waters  containing  more  than  1,000  parts per million,
     from the sum of determined constituents.

UNCONFINED  CONDITIONS  - Exists when the upper limit of the
     aquifer is  defined by the water  table itself.   At the
     water  table,  water in the  aquifer pores is at atomos-
     pheric pressure.
                            A-4

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UNSATURATED ZONE - See VADOSE ZONE.

VADOSE ZONE (ZONE OF AERATION)  - A subsurface zone containing
     water under pressure  less than that of  the  atmosphere,
     including water held by capillarity, and containing air
     or gases generally under atmospheric pressure.

WATER  TABLE  - The  surface of a body  of unconfined  ground
     water at  which the  pressure  is  equal  to  that of  the
     atmosphere.

WATER-TABLE GRADIENT -  The change in elevation of the  water
     table per unit of horizontal distance.
                             A-5

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               APPENDIX B


ALTERNATIVE OPTIONS CONSIDERED FOR DEFINING
   CLASSIFICATION KEY-TERMS AND CONCEPTS
                   B-l

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                      TABLE OF CONTENTS
                                                        Page

1.0  INTRODUCTION	  B-3
2 . 0  CLASSIFICATION REVIEW AREA	  B-4
3.0  CLASS I KEY TERMS AND CONCEPTS	  B-5
     3.1  Irreplaceable Source of Drinking Water	  B-5
          3.1.1  Substantial Population	  B-5
          3.1.2  Comparable Quality	  B-5
          3.1.3  Economic Infeasibility	  B-6
     3.2  Ecologically Vital Ground Water	  B-7
     3.3  Highly Vulnerable Ground Water	  B-8
          3.3.1  Alternative Approaches to
                 Utilize Ground-Water
                 Vulnerability Concept	  B-8
          3.3.2  Selection of a Methodology to
                 Operationally Define Ground-
                 Water Vulnerability	  B-9
4 . 0  CLASS II KEY TERMS AND CONCEPTS	  B-14
     4.1  Current Source of Drinking Water	  B-14
     4.2  Potential Source of Drinking Water	  B-15
     4.3  Ground Water with Beneficial Uses
          Other Than Drinking	  B-17
5. 0  CLASS III KEY TERMS	  B-18
     5.1  Methods Reasonably Employed in Public
          Water Treatment Systems	  B-18
                             B-2

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                      1.0  INTRODUCTION

     One phase  of the process  for preparing  the Guidelines
for Ground-Water  Classification involved defining  key terms
and  concepts related to  the  classification  scheme.    The
Office of  Ground-Water Protection and guidelines work group
developed these definitions through  an  intensive analysis of
alternative options.   As described previously, each approach
was examined with respect to its:

        stringency

        consistency  with  other  programs,  and  the  overall
        intent of the strategy

        flexibility   for   accommodating   state  and  region-
        specific characteristics or concerns

        arbitrariness

        potential implementational difficulties or  complexi-
        ties
     This  Appendix   documents  those  options   which  were
considered during  the development process, but  not specifi-
cally  highlighted  for  public consideration  in  these Draft
Guidelines.   The alternatives discussed are  not necessarily
poor approaches  to the  key issues and  concepts.   In fact,
many are  currently used very effectively by  other Federal,
State,   and local  programs.   These  options,  however,  were
deemed  less  suitable   for  a  classification  system  with
nationwide, broad-spectrum application.    Comments  on these
alternatives,  especially in the  case  of  the "vulnerability,"
"substantial  population,"   and  "economically  irreplaceable"
terms  will,   of course,   be   considered  by  the  Agency  in
preparing the Final Classification Guidelines.
                            B-3

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               2.0  CLASSIFICATION REVIEW AREA

     Prior to  the development  of the Classification  Review
Area concept, the Agency reviewed the methods used by states
in designating classified segments for ground-water systems.
These include the classification  of aquifers,  or portions of
aquifers as  defined  by geology, water quality,  and surface-
water  relationships.    In addition,  cones  of  influence  of
individual wells are mapped and classified by some states.

     It was decided that these techniques are not appropriate
for  the  EPA process,  as  they  would   involve    in-advance
classification of large areas,  in  some cases,   hundreds  of
square  miles in  extent.   The  Strategy  clearly establishes
that classification  at this  scale is within  the role  of the
states.  A more  limited scope of  review  which centers on the
proposed activity or facility was found to be most consistent
with EPA policy.

     One option which was also considered included a range in
variable  radii  for  the  Classification   Review  Area,  using
combinations of hydrogeologic characteristics such as ground-
water velocity,  or  types  of geology  (e.g.,  karst or glacial
till)  specific to  different regions  of the country.   The
disadvantage of using  a geology-based variable radius is the
inconsistency of  its use.   Given  that  this  is  a method of
approximation only,  designation of too small a Classification
Review Area  could provide  inadequate protection  to intercon-
nected ground-water resources.

     Also considered was the use of activity-specific radii—
for  example,  a   different   radius  for   landfills  than  for
pesticide application or underground tank installation.  This
alternative  was  critiqued  for several reasons.   Most impor-
tantly,  the  Agency   believed  that use  of activity-related
criteria  to  define  the  Classification Review Area  could
result  in a  different classification being applied  to the
same ground  water for different  types  of activities.   The
classification process  is designed to avoid such variability
whenever possible.
                             B-4

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             3.0  CLASS I KEY TERMS AND CONCEPTS

3.1  Irreplaceable Source of Drinking Water

     3.1.1  Substantial Population (Option A)

     Option A for "substantial population" takes into account
a quantitative or semi-quantitative assessment of both public
water  systems  and  concentrations of  private  wells.    This
approach  also  takes  into  account the  added burden of  pro-
viding alternative  drinking water to  users not served  by a
centralized water supply.

     This definition  for substantial population provides two
important advantages:
        It considers  both  central city and  suburban/  rural
        settings  (public  water  systems as  well as  private
        well users)  and,  therefore,  makes  ground water  in
        both settings potential Class I waters.

        It is  based on terms, and thresholds defined by the
        Census Bureau, is  compatible with  publicly available
        census data,  and  incorporates  terms that have  been
        used to describe population settings by other Federal
        programs.

     Another  option  for  a   "quantifiable"  Option  A  which
involved defining "substantial population" in relative terms,
considering all populations  served  by public  water  systems
within a state.    This  option  would  define  a  substantial
population as  one that  is served by  a public water  system
that is larger than,  for example,  at least 95 percent  of the
systems that are served by ground water in the state.   Such a
definition would  ensure   that,  at  a   minimum,  the  largest
system or systems in each state would qualify as serving a
substantial population.    One concern was  that this  might
produce   inconsistencies   between  states.     Some  possible
conflict  with  the policy  of  giving  "special"  protection  to
areas with greatest communal  risk (inherent in the Strategy)
was also  noted.   It  should be remembered that Option  B for
defining  "substantial population"  is more  qualitative  in
nature.

     3.1.2  Comparable Quality

     The  Agency  considered   a   definition  of  "comparable
quality"  consistent with the  Class III definition  of "treat-
able," or having Total Dissolved Solids equal to or less than
10,000 mg/1,  but  was concerned over  the possibility  that
alternatives  might  be  considered  acceptable  replacements
                             B-5

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although they  deviate considerably from  the quality of  the
current source  or from the  quality  of water typically  used
for drinking in this Region.

     3.1.3  Economic Infeasibility

     Several  alternative  options  considered  for  defining
economic  infeasibility  under  the  "quantitative  test"  of
Option  A  were  assessed.   One involved  using  the  criteria
developed by  EPA'S Office of  Drinking Water for  evaluating
excessive economic burden.    This  set of  approaches  would
designate an  alternative  source  as economically  infeasible
if:
        water bills  to a typical user (a user who  consumes
        about 100,000 gallons-per-year) will increase by more
        than $100 per year

        water bills  to a typical  user will  increase  to  more
        than $300 per year

        the  system  investment  (measured  as  undepreciated
        replacement  costs)  will  increase by more than  100
        percent.

Such options  do not  account  for  the  community's  ability to
pay, a  consideration  of  significant  importance.    Moreover,
the dollar values  set  by  the  criteria  are dated and have not
been adjusted to account for inflation.

     Another option  considered for defining  economic infea-
sibility would  designate  a source as  infeasible if  the  cost
to a typical  user exceeds the amount paid by the  upper  five
percent of all public  water-system users  in  the state.   This
option  accounts  for ability and  willingness to pay  to  some
extent.   Judgments  are based, however,  on data  describing
water costs  (rather than  household  income)  statewide.   The
measure  of  ability  or  willingness  to  pay is,   therefore,
indirect.   This  measure is  also  less  accurate than  the
selected approach because statewide water rates do not always
reflect the true  cost  of  the water.   Subsidies  from state or
local governments and economies of scale may cause rates paid
by users to be lower than actual costs.

     A  third   approach  considered   was  an  evaluation  of
economic feasibility on the basis of a comprehensive cost and
benefit  analysis.   This  option  would require  a much  more
data-intensive  and complex  analysis  than  any  of  the  other
options considered.   More important,  the  Agency noted that a
cost/   benefit   analysis   would  necessarily  give  explicit
consideration to  the type of activity motivating  the classi-
                              B-6

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fication decision, contrary to the intent of the Ground-Water
Protection Strategy.   It should be remembered  that  Option B
for determining "economic  irreplaceability"  is  more qualita-
tive  in nature,  but could  utilize some  of these  specific
measures as appropriate.

3.2  Ecologically Vital Ground Water
     Several  alternative  options  were  considered,  but  not
highlighted for public comment,  within the  definition  of an
ecologically vital area.  These included:
        Designating all discharge areas as ecologically vital
        ("all discharge areas" option)

        Designating  ground-water  discharge  areas  as  eco-
        logically  vital  if  they  contain  an  endangered  or
        threatened  species,  or a management area designated
        for  ecological  protection  by  a  Federal,  State  or
        local agency ("any protected ecosystem in a discharge
        area" option)

        Using critical  habitats instead  of all  habitats of
        endangered species ("critical habitats" option).


     The "all discharge areas" option was attractive, in that
it would  be  relatively uncomplicated to  implement  and  would
serve to define both key terms,  sensitive ecological system,
and unique habitat.   The Agency, however,  perceived that it
would result in a very  large number of Class I designations,
which is  not  in keeping with the intent  of the Ground-Water
Protection Strategy.  More important, not all discharge areas
are associated with truly unique habitats.

     The "any protected ecosystem in a discharge area" option
was  judged  to  be   an  exceedingly  comprehensive  approach,
accommodating   currently  existing  ecological   protection
programs  at  all  levels of  government.    However,  extensive
research would  be required to identify the  universe of such
protected areas,  and many inconsistencies exist from program
to program and from state to state.

     To clarify the "Critical  Habitats" option, the  reader
should  be  aware that  Critical  Habitat areas  are designated
for  some  endangered or threatened  species, and range  from
less  than one  square  mile  to  thousands  of  square  miles.
Specific locational  information is available  in  the Federal
Register and  Code of  Federal  Regulations for  each  of  these
areas.    Use  of  Critical  Habitats  alone  was  considered
unworkable for  several  reasons.   Pursuant  to the Endangered
Species Act  of  1973, equivalent protection  must  be afforded
                            B-7

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to  all  habitats,  not just  Critical  Habitats.   Many  truly
endangered  species   lack  Critical  Habitat   designations.
Although, at the present tine, Critical  Habitats are assigned
on a  routine  basis when species become endangered,  this was
not the case at  the  inception of the  program.   Under extreme
circumstances,   Critical   Habitats  are   intentionally  not
delineated  to  avoid  publicizing  an  especially  sensitive
species.   Limiting  unique habitats  to  only the  designated
Critical Habitats would leave the habitats of many endangered
and threatened species without Class I protection.

3.3  Highly Vulnerable Ground Water

     With  respect  to  ground-water  vulnerability  to  con-
tamination, options  for  both basic  utilization and  opera-
tional  standpoints were  examined.   The Agency  is  requesting
comment most specifically  on  the latter,  although  the choice
of operational definition  will have an  impact  on the overall
concept use.

     3.3.1  Alternative Approaches to   Utilize the Ground-
            Water Vulnerability Concept

     Two alternative approaches were considered for utilizing
the ground-water vulnerability concept.   Both  were  based on
the concept that vulnerability is dependent upon  the nature
of the  activity.   This concept has validity in two respects.
First,  different kinds  of activities will  involve  wastes of
contrasting hazard.   For  example, hazardous wastes disposed
of  within  a  RCRA  landfill present  a significantly greater
health  risk upon  direct  contact  than  some mining wastes.
Second, different kinds of activities have contrasting design
and  operating features.    Consider  the  comparison of land
treatment versus underground  injection  (via a  deep  well)  of
secondarily treated  municipal waste waters.   Some activities
take  place within the  ground water  medium and others take
place well  above the ground-water table.   Thus,  an approach
employing  this  concept  would  provide  a greater  activity-
specific picture of  the potential  for contamination to occur.

     The first alternative considered would have incorporated
an  activity-dependent vulnerability  concept,   requiring the
development  of  specialized  operational  methodologies  for
defining vulnerability  for different activities.  The Agency
found  two  major disadvantages  for this  approach.    First,
under  an activity-dependent  vulnerability  concept,  the same
ground  water  would  likely be placed into  different classes
where different  activities take  place or are proposed in the
same  vicinity.    Ground  water  could be  vulnerable  to one
activity  and  not the other.   It  might lead  to confusion in
                           B-8

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the regulated  community, and  the public  at large,  to  find
that the  class of ground water changes with  each activity.
Secondly, the  effort and time to  develop  specialized opera-
tional methodologies  for each  activity  would be substantial.

     The  second  alternative  considered  involved  removing
vulnerability  as  a  class-determining  factor.    Each  EPA
program  would, at  its  option,  establish  activity-specific
operational definitions  for vulnerability  as might be needed
for  implementing  management   strategies.     The  principal
advantage  is  that the  class of  ground water  would consis-
tently reflect the current and potential use of the resource.
Specific  operational  definitions would  then not need to be
developed  and  tested as  part  of  the 06WP  classification
program.   One  major disadvantage was  raised,  in addition.
Ground-water vulnerability  to contamination  was established
in  the  Ground-Water Protection  Strategy   as  an  essential
component  to  the Class  I concept.   If EPA had  decided to
consider   removing   vulnerability  as   a   class-determining
factor, then this very important concept would be lost.

     3.3.2  Selection  of  a   Methodology   to  Operationally
            Define Ground-Water Vulnerability

     Five  operational   methodologies  were   considered  to
determine ground-water vulnerability (see Table B-l).

            3.3.2.1  Qualitative Methodology

            A  descriptive/qualitative method establishes the
vulnerability of hydrogeologic settings, based on concepts of
terrain lithology or hydrogeologic functions, as expressed in
a  few well  chosen,   technical words.   Examples  of  highly
vulnerable settings  might  include areas of  karst terrain or
ground-water recharge areas.   Examples  of  low vulnerability
may be discharge areas  or confined  aquifers.    The general
procedures to  implement  such a  method would  be  to either
match  a  candidate, real  setting to a "standard setting," or
to provide a map  showing their location.   While no quantita-
tive criteria  would  necessarily  be set,  this type of method,
when   implemented,  will result  in the   establishment  of
"precedent criteria" whenever  a  specific site is accepted or
rej ected.

            3.3.2.2  Single Factor Methodology

            The single  factor method would employ a single
quantitative criterion  to all  hydrogeologic settings.   For
example,  areas with  a depth to  water of less  than 150  feet
could  be  considered  highly vulnerable to contamination.   The
                             B-9

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B-10

-------
fatal  flaw to  this  method  is  the  selection  of a  single
quantitative factor to represent highly vulnerable conditions
that  can  be  applied  across  the  country and  its  various
hydrogeologic settings.

            3.3.2.3  Multiple Factor Metholocrv

            The  method   of   listing  multiple  independent-
criteria  is  commonly  applied  in  state  programs  for  the
location of hazardous-waste facilities and  other facilities
used  for the disposal  of  noxious wastes.    The principal
drawback is the  lack of  consistency  in these criteria among
states.  This method also has the  disadvantage  of not being
able  to  weigh  each  factor  according  to  their  relative
importance for contaminating ground-water.   In  addition,  it
sets  a criterion  that must  be met  for  each  factor.   The
approach is inflexible, in that  a  poor rating for one factor
cannot  be balanced against  a  superior   rating  of  another
factor to achieve an average acceptable rating.  This balanc-
ing is  important because  ground-water transport  and leaching
potential are not additive processes, but are multiplicative.

            3.3.2.4  Numerical Rating Methodology

            The numerical rating methodology  is  an extension
of the  multiple  independent factor  criteria  listing method.
In addition to  establishing multiple  factors, the range for
each  factor  is  subdivided  and  assigned   relative numerical
ratings.   An  example concerns the depth-to-water factor  in
DRASTIC  (Aller,  et al,  1985)  shown  in Table  B-2.    The
numerical factor ratings can be multiplied by weight in order
to reflect the relative importance of factors.   Finally, the
factor ratings,  or weighted factor ratings, are added to give
a  final  score.   The selection  of factors follows  the  same
reasoning as discussed for the multiple factor method.  Under
this type of method, only a  criterion for the final score is
established.   As  long as the  final score criterion  is  met,
there are no limits assigned to any factors.

     Hybrids of a numerical rating method and multiple factor
method, or more  sophisticated types of standards,  are  also
possible.  For example, minimum  criterion can be established
for critical  factors.    In  addition,  factor ratings  may  be
multiplied  or divided  by  other  factor   ratings  to  better
approximate interrelationships between those factors.

     The principal  advantages of  a numerical rating method
include those presented for  the  multiple  factor  method,  plus
factor  weighting.    These  systems  are  relatively easy  to
implement, depending upon  the  difficulty of measuring the
                            B-ll

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                   TABLE  B-2
    RANGES  AND RATINGS FOR DEPTH TO WATER
AS USED IN THE NUMERICAL RATING SYSTEM DRASTIC
             (ALLER, ET AL, 1985)
                Depth to Water
                    (feet)
Range
0
5
15
30
50
75

- 5
- 15
- 30
- 50
- 75
- 100
100+
Rating
10
9
7
5
3
2
1
Weight: 5

                     B-12

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factors  selected.    Factor  weighting  allows for  the  more
important  factors  to  be distinguished.    This  method  also
allows for compensation  between factors,  a low  score  in one
factor may be offset by a high score in another factor.

     The disadvantages are essentially the same as those of a
multiple factor method.  The  factor weights,  when used,  will
be somewhat  subjective.   The typical approach  to  assigning
weights  is to poll the  "experts"  and establish  a  consensus
value.  Weights assigned in one region may not work very well
in other regions.   The selection  of a  cut-off value  for
highly vulnerable will also have a limited technical basis.

            3.3.2.5  Integrative Methodology

            Integrative  methodologies  are often  considered
the most sophisticated, since they can represent the interac-
tion  and relative  importance  of  the various  hydrogeologic
factors.  The Office of  Solid Waste is investigating a time-
of-travel criterion as part  of hazardous-waste land disposal
siting requirements.   The high-level radioactive waste (HLW)
program  within  the Department of  Energy has established a
time-to-exposure criterion.   The disadvantage of the integra-
tive methods  (for localized vulnerability assessments)  is the
need  for accurate, site-specific  data, usually  requiring a
detailed   hydrogeological   investigation.     This   presents
conflicts with lower-risk activities where high cost investi-
gations  are  typically  not   performed.     In addition,  the
integrative  methods  are less  suited to mapping  purposes
should states be interested in building upon EPA's system.

     As  a  final  note,  Option B for determining vulnerability
opens up the use of any or all of these approaches, depending
on  site  and  decision  specificity.   It is  considered  a
"qualitative"  option  since   the  Agency   would  not  provide
specific recommendations on preferred methods, cutoffs, etc.
                           B-13

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             4.0   CLASS II KEY TERMS AND CONCEPTS

4.1  Current Source of Drinking Water

     Several alternative options  were considered within the
definition of current  source  of drinking water.  These were
based upon:

     . Occurrence  of multiple  wells  in  the  Classification
       Review Area ("multiple well" option)

     . Exceedance  of  a  specified  ground-water  production
       level in the  Classification Review Area ("exceeding a
       production level" option)

     . Application  of  intensive  management  practices,  or
       evidence  of  regional  stress   in  the  Classification
       Review Area ("intensive management or stress" option).

     The multiple well option  is  an expansion of  the "one-
well"  option that is  highlighted for public  comment.   The
determination of  a current source  of  drinking  water would be
based upon the presence of two or more wells and would result
in  a more restrictive  current-source subclass  and increase
the size of the potential-source subclass.   This option would
have created a bias against the more sparsely populated rural
areas.  The philosophy of the Agency  is  that,  if a source is
being used as drinking water by even one family, it should be
classified  and protected  as a current  source of drinking
water.

     The  "exceeding-a-production  level"  option  looks  at the
volume  of drinking water being pumped,  rather than   a set
number of wells.   The  intent  of the  option  was to screen out
little-used  aquifers from  the current  source  of  drinking-
water  designation.   This  option  was  not highlighted  for
public  comment for  the same  reasons  as   the multiple-well
option.

     The "intensive management  or stress" option would  focus
on areas which are controlled through ground-water management
agencies,  or are exhibiting pumping  stress  (e.g.,  persis-
tently falling water levels).   This  approach by itself could
overlook  a large number of  other sources  of  drinking water
that are  not managed for ground-water withdrawal,  or are not
under stress.
                           B-14

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4.2  Potential Source of Drinking Water

     Several other options were considered for the definition
of "potential source of drinking water."  These included:

        Stricter water-quality criteria
        Non-quantitative yield criterion
        Specific water-quality data needs
        Socioeconomic considerations.

     The "Stricter Water-Quality  Criteria1*  option would have
adopted the Federal primary drinking-water-quality standards,
in addition to  the  selected TDS cutoff.  This  was viewed as
an  attractive  approach  because  it   addresses   levels  of
specific toxic  contaminants.   However,  it  was deemed  to be
overly restrictive since many ground waters that  do not meet
primary drinking water standards  are treatable.   Also,  it is
hard to "prove" they meet the MCLs.

     The "Non-Quantitative  Yield Requirements" option  would
have set no minimum yield to qualify as  a  potential source.
The Agency decided,  however, that areas do exist where yields
are  insignificant,  however rare,  and,  therefore,  must  be
considered  in  order  that the   classification   system  be
complete.

     Since ground-water  quality  data  are  not  consistently
available for all areas  or regions, the  issue  of data  needs
for  classification  was  carefully  examined.    One  option
studied  was   to require  a ground-water quality  test  for
classification.   This  approach  would  result in the  most
accurate quality assessment of  the potential  for the ground
water to serve as drinking water,  but was considered  to be
unnecessarily burdensome for most activities.

     The "Socioeconomic Considerations" option would base the
determination  of  potential drinking water  on  Socioeconomic
criteria.  Some water is potentially drinkable, but may never
be used because it  is too  costly  to retrieve,  not available
because of  institutional constraints,  or  is  in  an  area in
which development  is unlikely.    This  approach was rejected
because it was  judged difficult to  implement  and not highly
workable, since economic  and institutional trends are  often
difficult to predict.  Also, the test is too  complex for the
baseline of protection in Class II.
                            B-15

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                          TABLE B-3
               BENEFICIAL USES OF GROUND WATER
                OTHER THAN FOR DRINKING WATER
A. MUNICIPAL
B. AGRICULTURE
C. INDUSTRY
D. MINING AND ENERGY
   DEVELOPMENT
E. ENERGY PRODUCTION
F. ECOLOGICAL  (NON-CLASS I)
G. STORAGE/WASTE DISPOSAL
H. RECREATION
I. PASSIVE USES
fire protection
district heating
landscaping
blending

irrigation
livestock
frost protection
blending

heating/cooling
process water
blending

mineral
geothermal
hydrocarbon

power plants
heat pumps

baseflow
heat pumps

disposal of waste
and treated waste
water effluent
surplus fresh water
management

swimming pools  (indirect)
golf courses
ice skating (indirect)

physical support for
earth structures
impedance of subsidence
and salt-water  intrusion
                       B-16

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     4.3  Ground  Water  with  Beneficial  Uses   Other  Than
          Drinking

     Within  the context  of  "other beneficial  use"  (OBU),
several  options were  considered  but  not adopted.    These
included:

     . Providing a separate subclass within Class II for OBU

     . Consideration of specific OBUs v. all OBUs as a group

     . Giving more protection to ground water with  dual
       uses.

     The idea of creating a third subclass under Class II for
ground waters with other beneficial  uses  (Table  B-3)  was not
adopted for several reasons.  First, the existing current and
potential  source  of  drinking-water subclasses  appears  to
provide  sufficient  protection  for the  majority  of  OBUs.
Second, most  OBU ground waters would have a dual  role  as a
current or  potential  source of drinking water,  and would be
afforded  the  protection  given  to  drinking  water  as  the
highest and best use.  Third, it would be difficult to assess
the protection that should  be  afforded  for OBU ground waters
as  a general  subclass,  because  quality,  yield,   and  other
requirements are so varied  among the many different uses and
between regions.

     Because EPA does  not  intend to use different management
practices according to the various  other  beneficial  uses of
ground water, the Agency judged the consideration of specific
OBUs to be  unnecessary.  In addition, the selection,  defini-
tion, and  determination of  resource value of OBUs would be
difficult on a national scale,  since resource values and uses
vary considerably within a region.   Some states are reviewing
specific OBU  subclasses  for agricultural  or  other purposes.
This is an  ideal approach  for  tailoring ground-water protec-
tion at the state  level, though  it was  deemed impractical to
adopt  some number  of subclasses  for OBUs  on  a  nationwide
basis.

     The  Agency  considered  providing  a  higher  level  of
protection  to drinking water,  which is also being used for
selected  OBUs.    This  approach  was considered  to be  less
feasible on a national scale since  resource  values and uses
vary widely.
                            B-17

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      APPENDIX C

SAMPLE APPLICATIONS OF THE
 CLASSIFICATION PROCEDURES
          C-1

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                 SAMPLE APPLICATIONS OF THE
                  CLASSIFICATION PROCEDURES
     The following  case studies are presented  to illustrate
the central  classification concepts and  use of  the  various
classification  procedures.    Individual  case  studies  are
presented  in a  systematic fashion  in  accordance with  the
Classification Procedural  Chart (Figure 4-1)  and associated
worksheet  (Table  4-1)  - instructions or questions are posed
followed by  the  corresponding  information with  subsequent
directives,  or  a  final class  determination.   The  general
format for the case studies begins with a presentation of the
preliminary information and concludes with  the completion of
the Classification Worksheet.

     Each case study  has  been modeled  after real activities
and physical settings.  Data sources have been generalized to
avoid identification of the specific site  under examination.
The particular  activity under  consideration  has  also  been
omitted  since  classification is  essentially  independent of
the activity type.   Place names and  localities  have  been
disguised,  but  my  be  recognizable to a   familiar  reader.
Costs  and  other  figures  used  in these   case studies  are
hypothetical.    It  should also  be  noted that  the  final
classification decision presented in each case study does not
represent the Agency's determination  for  the  real activity
from  which  the  case  study has  been  developed  since  some
factors  were changed  for  the  purposes of  this  review.   A
summary of case studies and related  issues  addressed  in each
case is presented in Table C-l.
                            C-2

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                         CASE  STUDY  1

                         Introduction

     The following  case  study is an example of  a Class IIA-
Current Source  of Drinking Water.  The  standard Classifica-
tion  Review Area,  defined by  a  two-mile  radius from  the
proposed  facility,   is  used  in this  example.   Although  a
substantial population is involved,  the Classification Review
Area is not highly  vulnerable to ground-water contamination.

        Preliminary Information with Respect to  the
                  Classification Review Area

General

     A  permit  application is  being  submitted  for  a  site
located in the Eastern  United States,  east of the  City of
Hilton  Heights.    Land  use in the area is primarily  rural
farmland interspersed with- chemical industries.   The Classi-
fication Review Area is shown in Figure Cl-1.

     Maps  provided in this case study  were  developed from
U.S. Geological  Survey  quadrangle  sheets.   Text information
was  collected  from ground-water availability  studies  con-
ducted  by  the  county,  U.S.  Geological  Survey  reports,  and
from U.S.  Census Bureau statistics.

Geo1ogy/Hydrogeo1oqy

     The stratigraphic sequence of  geologic  units regionally
present is, in descending order  (Figure Cl-2):
     . Umber Formation - silty sand
     . Hunter Formation - clay
     . Toth Formation - sandstone
     . Crystalline  igneous and metamorphic bedrock.

The  major  aquifers  in  the  area  are  the  Umber  and  Toth
Formations.  The  Hunter  Formation is known  to be an unfrac-
tured, laterally continuous aquitard.

Well/Reservoir Survey

     Two large  capacity  water-supply wells, screened in the
Umber aquifer and registered  with the state,  are located in
the Classification  Review  Area.  These  wells  provide public
water  supplies  for  the  City  of  Hilton  Heights,   which,
according to U.S. Census Bureau statistics,  had a population
of 3,700 persons in 1980.
                             C-4

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                                   FIGURE Cl-1
            BASE MAP ENCOMPASSING THE CLASSIFICATION REVIEW AREA

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 EXPLANATION
  •      PROPOSED FACILITY
	CLASSIFICATION REVIEW AREA BOUNDARY
         INDUSTRIAL SUPPLY WELL
         MUNICIPAL SUPPLY WELL
         CITY LIMITS
         ROADWAY
         RIDGE
                                                                          2 MILES
©
•
                                      C-5

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     Additionally, if the  proposed activity is  permitted,  a
new well will be  constructed at the site.   This  well will be
screened in the deeper Toth aquifer.

     No water-supply  reservoirs  are present  in the Classi-
fication Review Area.

Demography

     The  City  of Hilton  Heights  is   located  west of  the
proposed  facility and  has  a  population  of  3,700.     All
residents are served by ground-water supplies, therefore the
well field  is considered  to  serve a  substantial  population
under Option  A.   As  no irreplaceability  analysis  was  per-
formed,  the  ground waters  are  assumed to  be  irreplaceable.
Under Option  B,  the  population is considered  substantial by
recognized experts given the demographics of the region.

Ecologically Vital Areas

     U.S.  Fish  and  Wildlife  Service   records  indicate  the
Classification  Review  Area  does  not  encompass  any Federal
lands designated for ecological  protection or  ecologically
vital areas.

Vulnerability

     Given that the irreplaceability of the ground waters is
assumed, it is  necessary to perform  a  vulnerability analysis
for the area.   Under Option A for determining vulnerability,
DRASTIC is utilized with the following results averaged over
the review area:

UMBER FORMATION                Rating   Weight   Number

. Depth to water  - 15-30 ft       7       5        35
. Net recharge -  approximately
  20 in/yr                        9       4        36
. Aquifer media - silty sand      63        18
. Soil media - loam               52        10
. Topography -2-6%               9       1          9
. Impact of vadose zone media -
  sand with silt  and clay         5       5        25
. Hydraulic conductivity -
  100-300 gpd/ft2                 2       3       	6

                           DRASTIC Index (TOTAL)   139

     This area is not considered highly vulnerable to ground-
water contamination under Option A since the DRASTIC Index is
less than 150.
                           C-7

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     Under Option B for determining vulnerability, two expert
hydrogeologists  in the  area  were  consulted.    The  hydro-
geologic setting of loamy soils overlying silty sand aquifers
are considered  "vulnerable" but  not "highly vulnerable"  by
these experts.
                            C-8

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     Referring to  the Procedural Chart  shown in Figure  4-1
and associated worksheet  in Table  4-1,  the ground water is
classified using the following steps:
Step  Question/Direction
Response/Comment
      Establish Classification
      Review Area (CRA)  and
      collect preliminary
      information.  Optional -
      Demonstrate subdivi-
      sion (s) of the CRA.

      Locate any ecologically
      vital areas in the CRA.
      Does the CRA or appro-
      priate subdivision
      overlap an ecologically
      vital area?

      . Yes, go to next step
      . No, go to Step 4

      Determine location of
      well(s) within the CRA
      or appropriate sub-
      division.  Does the CRA
      or appropriate sub-
      division contain well(s)
      used for drinking water?

      . Yes, go to next Step
      . Mo, go to Step 8

      Inventory population
      served by well(s).
      Does the well(s) serve a
      substantial population?

      . Yes, go to next step
      . No, then the ground
        water is CLASS IIA-
        CURRENT SOURCE OF
        DRINKING WATER
The CRA is defined by a
two-mile radius from the
proposed facility.  No
CRA subdivision has been
performed.
No ecologically vital
areas are present in the
CRA.
Yes, two large-capacity
water-supply wells are
located within the CRA.
Yes, under Option A, the
population served exceeds
the 2500-person threshold.
Under Option B, the popu-
lation is considered
substantial by recognized
experts given the demo-
graphics of the region.
                            C-9

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Step  Question/Direction
       Response/Comment
      Unless proven otherwise,
      the drinking water source
      is assumed to be irre-
      placeable.  Optional -
      perform irreplaceability
      analysis.  Is the source
      of drinking water
      irreplaceable?

      . Yes, go to next step
      . No, then the ground
        water is CLASS IIA-
        CURRENT SOURCE OF
        DRINKING WATER
       Yes, irreplaceability is
       assumed.
      Perform vulnerability
      analysis.  Is the CRA or
      appropriate subdivision a
      highly vulnerable hydro-
      geologic setting?

      . Yes, then the ground
        water is CLASS I-
        IRREPLACEABLE SOURCE
        OF DRINKING WATER
      . No, then the ground
        water is CLASS IIA-
        CURRENT SOURCE OF
        DRINKING WATER
       No, under Option A, a
       DRASTIC index of less than
       150 does not constitute a
       highly vulnerable hydro-
       geologic setting.
       Under Option B, the area
       is not deemed highly vul-
       nerable by hydrogeologic
       experts.
FINAL CLASS DETERMINATION:
CLASS IIA - CURRENT SOURCE OF
DRINKING WATER
                          C-1o

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                         CASE  STUDY  2

                         Introduction

     This case study is a permutation of Case Study 1 leading
to a Class IIB - Potential Source of Drinking Water classifi-
cation.   Although  the preliminary  information remains  the
same, the  Classification Review Area has been  subdivided to
identify those  ground-water units not  highly Interconnected
with the ground-water unit directly beneath the facility.   In
this manner, we have  attempted  to illustrate how subdividing
the  Classification  Review Area  can alter the  final  ground-
water  classification.    Subdivision  of  the  Classification
Review  Area  into  ground-water  units  results  in  a  class
determination of  potential source  of drinking  water  rather
than a current source.

         Preliminary Information with Respect to the
                  Classification Review  Area
General

     Material  presented in  Case Study  1  is not  repeated.
Figure C2-1  is a  map of  the water-table  surface  developed
from U.S. Geological  Survey  and  State Geological Survey well
data and water-level  measurements made specifically for this
study.

Classification Review Area Subdivision (Interconnection)

     Three ground-water  units can  be identified within the
Classification  Review Area  (Figures  C2-2  and  C2-3).    The
topographic  divide  serves  as   a  ground-water  flow  divide
creating ground-water units 1 and 2 (Figure C2-2).  Two large
capacity water-supply wells,  located  in  ground-water unit 1,
provide public water supplies for the City of Hilton Heights.
Under pumping  conditions,  the water pumped  by the high-yield
wells  is derived  from  ground-water  unit   1,   resulting  in
displacement of the  ground-water flow divide (Figure C2-2).
The river, recharged  by ground-water unit  2,  does  not serve
as  a  ground-water  flow  divide.    Regional  investigations
conducted by  county  hydrogeologists have shown  that ground-
water  flow beneath the  river  occurs  in the  lowermost Umber
Formation.   The Hunter Formation,  an unfractured,  laterally
continuous  aquitard,   restricts  vertical   flow  between  the
Umber and Toth aquifers.  Thus, a third ground-water unit can
be identified and is confined to ground-water movement in the
Toth aquifer.
                          C-11

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                                  FIGURE C2-1
                            MAP OF  THE WATER TABLE
 EXPLANATION
  •      PROPOSED FACILITY
	CLASSIFICATION REVIEW AREA BOUNDARY
         INDUSTRIAL SUPPLY WELL
         MUNICIPAL SUPPLY WELL
         CITY LIMITS
         ROADWAY
         RIDGE
©
•
•63.
                                                                            Z MILES
GROUND-WATER UNIT NUMBER
WATER TABLE CONTOUR,
IN FEET
GROUND-WATER FLOW DIRECTION
                                   C-12

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                                          C-14

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     An  intermediate  degree  of  interconnection  is  demon-
strated where  a Type  1  boundary separates  adjacent  ground-
water  units and  a  Type 2  boundary with  a  low degree  of
interconnection is  demonstrated due  to the presence of  an
aquitard.  Thus, it  is possible  to  subdivide the Classifica-
tion Review Area in  order to restrict ground-water classifi-
cation    to  the  ground-water  unit  which  is  potentially
affected by the presence of the proposed facility.

     Potential  contaminants  entering the  ground water  from
the facility would be  transported in  ground-water unit No.  2
and, ultimately, discharge  to the  river.    The  ground water
classification  decision  is  thus  restricted to  ground-water
unit No. 2.

     The following classification demonstration is limited to
ground-water unit No.  2  located beneath the proposed facil-
ity.  Classification  of  other  ground-water  units  is  not
necessary*
                           C-15

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     Referring to  the Procedural Chart  shown in Figure  4-1
and associated worksheet  in Table  4-1,  the  ground-water  is
classified using the following steps:
Step  Question/Direction
Response/Comment
      Establish Classification
      Review Area (CRA) and
      collect preliminary
      information.  Optional -
      Demonstrate subdivi-
      sion^) of the CRA.
      Locate any ecologically
      vital areas in the CRA.
      Does the CRA or appro-
      priate subdivision
      overlap an ecologically
      vital area?

      . Yes, go to next step
      . No, go to Step 4

      Determine location of
      well(s) within the CRA
      or appropriate sub-
      division.  Does the CRA
      or appropriate sub-
      division contain well(s)
      used for drinking water?

      . Yes, go to next Step
      . No, go to Step 8
The CRA is defined by a
two-mile radius from the
proposed facility.  The
CRA has been subdivided
into three ground-water
units.  The ground-water
classification decision
is restricted to ground-
water unit No. 2 located
beneath the proposed
facility.

No ecologically vital
areas are present in the
CRA.
No drinking-water wells
are within ground-water
unit No. 2.
                            C-16

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Step  Question/Direction
Response/Comment
  8A  Determine location of
      reservoirs within the
      CRA or appropriate sub-
      division.
      Does the CRA or appro-
      priate subdivision
      contain reservoirs
      used for drinking water?

      . Yes, go to next step
      . No, go to Step 9

  9   Determine yield from
      ground-water medium
      (total depth across
      CRA or appropriate
      subdivision).  Can it
      yield 150 gallons-per-
      day to a well?

      . Yes, go to next step
      . No, then the ground
        water is CLASS IIIA-
        NOT A SOURCE OF
        DRINKING WATER
        (INSUFFICIENT YIELD)

 10   Determine water-quality
      characteristics within
      the CRA or appropriate
      subdivision.
      Is the water quality
      greater than 10,000 mg/1
      total dissolved solids
      (TDS)?
      (Note: If water quality
      is unknown then this
      question must be answered
      no.)

      . Yes, go to Step 12
      . No, go to next step
No reservoirs are present
within the subdivided CRA.
Yes, the ground-water
medium is presumed to meet
the sufficient yield
criterion.
No, the water-quality is
unknown.
                           C-17

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Step  Question/Direction           Response/Comment
 11   Are the ground waters so     No,  the water-quality is
      contaminated as to be        unknown.
      untreatable?
      (Note: If water quality
      is unknown then this
      question must be answered
      no.)

      .  Yes, go to next step
      .  No, then the ground
        water is CLASS IIB-
        POTENTIAL SOURCE OF
        DRINKING WATER
FINAL CLASS DETERMINATION:  CLASS IIB - POTENTIAL SOURCE OF
                            DRINKING WATER
                           C-18

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                         CASE  STUDY  3

                         Introduction

     This case  study  is an example of a  Class  IIB Potential
Source of Drinking Water.  The standard Classification Review
Area, defined by  a two-mile radius from  the  proposed facil-
ity, is  used in this example.   No drinking  water wells are
present within  the Classification Review Area.   Also absent
are any ecologically vital areas.

             Preliminary Information with  Respect
              to the Classification Review Area

General

     A permit  application is being submitted for  a  site in
the  Armadillo  Desert in the Basin and  Range  physiographic
province.  The  standard Classification Review Area is shown
in Figure C3-1.  The U.S."Geological Survey characterizes the
regional  landscape as  broad,  open,  relatively  flat-floored
valleys,  separated by  rugged mountain ranges.   Valley-fill
deposits  are sands,  gavels,  and cobbles  of local  origin,
transported to the site by alluvial and  colluvial processes.
Figure  C3-2  is  a generalized  cross-section  of   the  hydro-
geology in the  Classification Review Area  determined  from a
limited number of borings.

     The climate of the Armadillo Desert  is characterized as
arid.   Average  annual  evapotranspiration  exceeds  average-
annual precipitation  by  an order  of magnitude;   hence,  the
area is normally water deficient.

Well/Reservoir Survey

     No ground  water  wells or drinking water reservoirs are
present in the  Classification Review  Area (Figure C3-1).  If
the permit is  approved  for the  facility  to begin operation,
bottled  drinking  water  will  be  delivered  to  the site for
employee use.

Demography

     The nearest town is ten miles north of the proposed site
and  has  an  approximate population  of 5,000.   There  are no
known  rural  dwellings  within  a  two-mile  radius  of  the
proposed site.

Ecologically Vital Areas

     No  ground-water   discharge  areas,  or  Federal  lands
designated for ecological protection, are present in the two-
mile Classification Review Area.
                              C-19

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                                FIGURE C3-1
         BASE MAP ENCOMPASSING THE CLASSIFICATION REVIEW AREA
 EXPLANATION

   •    PROPOSED FACILITY

	CLASSIFICATION REVIEW
        AREA BOUNDARY

	INTERMITTENT STREAM

  ——   GROUND-WATER FLOW DIRECTION

	 ROADWAY
2 MILES
                                  C-20

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    C-21

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     Referring to  the procedural chart  shown in Figure  4-1
and the associated  worksheet  in Table 4-1, the  ground water
is classified using the following steps:
Step  Question/Direction
                             Response/Comment
  8A
Establish Classification
Review Area (CRA) and
collect preliminary
information.  Optional -
Demonstrate subdivi-
sion (s) of the CRA.

Locate any ecologically
vital areas in the CRA.
Does the CRA or appro-
priate subdivision
overlap an ecologically
vital area?

. Yes, go to next step
. No, go to Step 4

Determine location of
well(s) within the CRA
or appropriate sub-
division.  Does the CRA
or appropriate sub-
division contain well(s)
used for drinking water?

. Yes, go to next Step
. No, go to Step 8

Determine location of
reservoirs within the
CRA or appropriate sub-
division.
Does the CRA or appro-
priate subdivision
contain reservoirs
used for drinking water?

. Yes, go to next step
. No, go to Step 9
                                   The CRA is defined by a
                                   two-mile radius from the
                                   proposed facility.  No
                                   CRA subdivision has been
                                   performed.
                                   No ecologically vital
                                   areas are present in the
                                   CRA.
                                   No drinking water wells
                                   are present in the CRA.
No, there are no reser-
voirs present within the
CRA.
                          C-22

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Step  Question/Direction
       Response/Comment
  9   Determine yield from
      ground water medium
      (total depth across
      CRA or appropriate sub-
      division) . Can it
      yield 150 gallons-per-
      day to a well?

      .  Yes, go to next step
      .  No, then the ground
        water is CLASS IIIA-
        NOT A SOURCE OF
        DRINKING WATER
        (INSUFFICIENT YIELD)

 10   Determine water-quality
      characteristics within
      the CRA or appropriate
      subdivision.
      Is the water quality
      greater than 10,000 mg/1
      total dissolved solids
      (TDS)?
      (Note: If water quality
      is unknown then this
      question must be answered
      no.)

      .  Yes, go to Step 12
      .  No, go to next step

 11   Are the ground waters so
      contaminated as to be
      untreatable?
      (Note: If water quality
      is unknown then this
      question must be answered
      no.)

      .  Yes, go to next step
      .  No, then the ground
        water is CLASS IIB-
        POTENTIAL SOURCE OF
        DRINKING WATER
       Yes, in the absence of
       data, sufficient yield
       is assumed.
       No, water-quality char-
       acteristics within the
       CRA are unknown.
       No, water-quality char-
       acteristics within the
       CRA are unknown.
FINAL CLASS DETERMINATION:
CLASS IIB - POTENTIAL SOURCE OF
DRINKING WATER
                           C-23

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                         CASE  STUDY  4

                         Introduction

     This case study was developed from Case Study 3 in order
to demonstrate an expanded  Classification  Review Area for an
alluvial setting.   The  classification  decision with  a two-
mile  Classification  Review  Area  was  Class  JIB  Potential
Source of Drinking Water.   No sources of  drinking water were
found in the two-mile Classification Review Area (Figure C4-
1).   An expanded review area as demonstrated in  this case
study may lead to a different classification decision.

            Preliminary  Information with Respect
              to the Classification Review Area

Expanded Classification Review Area

     This setting is found in the alluvial basin ground-water
region (after Heath, 1984) and based on the above information
matches the conditions for  an expanded  Classification Review
Area.  These conditions are:

        An unconfined aquifer as the dominant aquifer

        Losing streams as the predominant  source  of ground-
        water discharge

        Transmissivities  and  flow  velocities   that  are
        moderate to high  (>250  m2/d and  >60 m/yr,  respec-
        tively)

        Relatively low annual  rainfall  (less than 20 inches-
        per-year)

     The expanded review  area  is  based  on a five-mile radius
from the activity boundary.   A five-mile  radius was selected
because  calculation  of  ground-water  velocities  near  the
proposed facility was not possible  due  to a lack of informa-
tion on ground-water gradients.  Where velocity is known, the
expanded review  area  radius is the distance water will flow
in 50 years.  Figure C4-2 shows the expanded review area.

General

     A permit  application is  being submitted for  a  site in
the  Armadillo  Desert  in the  Basin and Range physiographic
province.    The U.S. Geological  Survey  characterizes  the
regional landscape  as broad,  open, relatively  flat-floored
valleys, separated  by rugged  mountain  ranges.   Valley-fill
                          C-24

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                               FIGURE C4-1
     BASE MAP  ENCOMPASSING THE  TWO-MILE CLASSIFICATION REVIEW AREA
 EXPLANATION

   •    PROPOSED FACILITY

	CLASSIFICATION REVIEW
        AREA BOUNDARY

	INTERMITTENT STREAM

  —•-   GROUND-WATER FLOW DIRECTION

	 ROADWAY
2 MILES
                                  C-25

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                                   FIGURE C4-2
        BASE MAP  ENCOMPASSING THE EXPANDED CLASSIFICATION REVIEW AREA
                                                                        4 MILES
    •   PROPOSED FACILITY
	CLASSIFICATION REVIEW
        AREA BOUNDARY
	INTERMITTENT STREAM
	•- GROUND-WATER FLOW DIRECTION
	 ROADWAY
    •   RESIDENTIAL WELL
    O   IRRIGATION WELL
                                   C-26

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deposits  are  sands, gravels,  and cobbles  of local  origin,
transported to the  site by  alluvial  and  colluvial processes.
A generalized  cross-section of  the  hydrogeology within  the
five-mile Classsification Review Area was assembled  based on
a review of literature and well logs  available for the region
(see Figure C4-3).   The uppermost aquifer  is  unconfined  and
has a transmissivity greater than 300 m2/d.

     The climate of the Armadillo Desert is characterized as
arid.    Average  annual  evapotranspiration  exceeds  average
annual  precipitation  by an order of  magnitude; hence,  the
area  is  normally  water  deficient.    Ground-water  recharge
occurs  primarily  at  the   higher  elevations  as  snow  melt
charged streams lose water into the ground.

Well/Reservoir Survey

     No ground-water wells  or drinking  water  reservoirs  are
present   in  the  two-mile  Classification  Review   Area.
However,  within  the  expanded Classification  Review  Area,
there are  two  wells used  for  irrigration and one well used
for water  supply to a residence.  If the permit is  approved
for the  facility to begin  operation, bottled  drinking water
will be delivered to the site for employee use.

Demography

     The nearest town is ten miles north of the proposed site
and has an approximate population  of 5,000.   There  are no
known  rural  dwellings  within  a  two-mile  radius  of  the
proposed  site.   There  is  one  dwelling  within  the  expanded
review area.

Ecologically Vital Areas

     No  ground-water  discharge  areas,  or  Federal  lands
designated for  ecological  protection,  are  present  in either
the two-mile or expanded Classification Review Area.
                           C-27

-------
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                                          C-28

-------
Expanded Classification Review Area Decision

     Referring to  the Procedural Chart  shown in Figure  4-1
and associated worksheet  in Table  4-1,  the ground water  is
classified using the following steps:
Step  Question/Direction
       Response/Comment
      Establish Classification
      Review Area (CRA)  and
      collect preliminary
      information.  Optional -
      Demonstrate subdivi-
      sion (s) of the CRA.
      Locate any ecologically
      vital areas in the CRA.
      Does the CRA or appro-
      priate subdivision
      overlap an ecologically
      vital area?

      . Yes, go to next step
      . No, go to Step 4

      Determine location of
      well(s) within the CRA
      or appropriate sub-
      division.  Does the CRA
      or appropriate sub-
      division contain well(s)
      used for drinking water?

      . Yes, go to next Step
      . No, go to Step 8

      Inventory population
      served by well(s).
      Does the well(s) serve a
      substantial population?

      . Yes, go to next step
      . No, then the ground
        water is CLASS IIA-
        CURRENT SOURCE OF
        DRINKING WATER
       The CRA has  been expanded
       to a five-mile radius
       from the activity boundary
       because of an alluvial
       hydrogeological setting
       and a lack of information
       on ground-water velo-
       cities.  No  CRA sub-
       division has been
       performed.

       No ecologically vital
       areas are present in the
       CRA.
       Yes, one drinking-water
       well is present in the
       expanded CRA.
       No,  the well does not
       serve a substantial
       population as determined
       by Option A.
FINAL CLASS DETERMINATION:
CLASS IIA-CURRENT SOURCE OF
DRINKING WATER
                            C-29

-------
                         CASE  STUDY  5

                         Introduction

     Case Study 5 is an  example  of  a  Class IIIB - Low Inter-
connection  ground  water.   This  case is  based on  a  permit
application for underground injection of  liquid wastes.   The
standard  Classification  Review Area,  defined by  a  two-mile
radius from the  proposed facility,  is used  in  this  example.
Subdivision of the  Classification Review  Area is exemplified
below.

         Preliminary Information with Respect to the
                 Classification  Review Area

General

     A permit application  is  being  submitted for underground
injection  of  liquid   wastes  into   the   Emery  Formation.
Planning, zoning, and tax-maps indicate land use in  the area
is primarily for farming and  cattle production.   The Classi-
fication Review Area is  shown in Figure C5-1.

Geologv/Hydrogeologv
     U.S.  Geological  Survey  reports  indicate  the  target
formation for subsurface disposal  is  the  lower ground-water
unit  (Emery  sandstone)   located  at  a  depth  of  approximately
4,000 feet  (Figure  C5-2).  Below this formation are  basement
rocks of  quartzite,  schist,  and granite.   The  upper ground-
water units are composed of flat-lying, alternating layers of
dolomite, limestone, and sandstone.

     The  stratigraphic  sequence shown  in  Figure  C5-2  was
developed from previous well logs  taken  during  oil and gas
exploration.   The  stratigraphy  encountered  correlates  with
the stratigraphy in other parts of the basin and reflects the
regional geology.

     Water-quality  samples were  also  taken  during drilling.
It was  determined that  ground water  in the Emery Sandstone
has  a total  dissolved  solids content ranging  from 12,000-
15,000 mg/1.

     Potable  water  for area  residents,  as  well  as  for
livestock, is produced  from  the  uppermost sandstone aquifer,
the Wagner Formation.
                          C-30

-------
                              FIGURE C5-1
        BASE MAP ENCOMPASSING THE  CLASSIFICATION REVIEW AREA
             \
             \
               \
                \

                            PROPOSED
                            INJECTtON
                              WELL
 EXPLANATION



	CLASSIFICATION REVIEW AREA BOUNDARY


   •    RESIDENTIAL WELL


        ROADWAY
2 MILES
                                  C-31

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Classification Review Area Subdivision (Interconnection)

     Three ground-water  units can  be identified within  the
Classification  Review Area  and  are  numbered as  shown  in
Figure  C5-3.   Ground  waters in  each ground-water unit  are
separated from each other by unfractured, laterally extensive
shale units.   A low degree of interconnection is demonstrated
due to  the  presence of these  Type  2 boundaries.   The inte-
grity  of  these  boundaries  has  not  been  compromised  by
improperly  constructed   or   abanondoned  wells,   or  other
apertures.  Injection and pressure  tests  performed indicate
that pressures  required to  meet the  design flow  rate fall
well below the Emery  Formation's pressure-induced fracturing
limits.

     Normally ground-water classification would be restricted
to the ground-water unit which is potentially affected by the
presence of the proposed facility.  The proposed facility, in
this case, is a liquid waste injection well.   Under a worst-
case  scenario,  potential  contaminants  entering  the  ground
water  from the  facility would be tranported in  all  ground-
water  units  underlying  the  facility rather  than  just  the
Emery  Formation.   Therefore, classification of  each  ground-
water unit is necessary.

Well/Reservoir Survey

     Figure C5-1  shows the  location of four  domestic wells
identified in  the Classification Review Area.   These wells
are screened  within 200  feet of the ground surface  in  the
uppermost sandstone aquifer.

     No water-supply  reservoirs   are present in  the  Classi-
fication Review Area.

Ecologically Vital Areas

     The  only  discharge point  in the  Classification Review
Area is from  the  upper sandstone aquifer  to a local stream.
However,  the  U.S. Fish  and  Wildlife  Service  confirmed that
this  stream  does  not  provide   habitat  for  an  endangered
species.  Additionally, no Federally-protected lands exist in
the area.   Thus,  the ground water  is not  considered  to be
ecologically vital.
                          C-33

-------
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          C-34

-------
     Referring to  the Procedural Guide  shown in Figure  4-1
and assoicated worksheet in Table 4-1, ground-water Unit  No.
3 is classified using the following steps:
Step  Question/Direction
                             Response/Comment
  8A
      Establish Classification
      Review Area (CRA)  and
      collect preliminary
      information.  Optional -
      Demonstrate subdivi-
      sion (s) of the CRA.
Locate any ecologically
vital areas in the CRA.
Does the CRA or appro-
priate subdivision
overlap an ecologically
vital area?

. Yes, go to next step
. No, go to Step 4

Determine location of
well(s) within the CRA
or appropriate sub-
division.  Does the CRA
or appropriate sub-
division contain well(s)
used for drinking water?

. Yes, go to next Step
. No, go to Step 8

Determine location of
reservoirs within the
CRA or appropriate sub-
division.
Does the CRA or appro-
priate subdivision
contain reservoirs
used for drinking water?

. Yes, go to next step
. No, go to Step 9
The CRA is defined by a
two-mile radius from the
proposed facility and has
been subdivided because
of the presence of low
permeability flow barriers
beneath the ground-water
units.

No ecologically vital
areas are present in the
CRA.
                                   No drinking water wells
                                   are within ground-water
                                   unit No. 3.
No reservoirs are present
within the CRA.
                            C-35

-------
Step  Question/Direction
Response/Comment
  9   Determine yield from
      ground water medium
      (total depth across
      CRA or appropriate
      subdivision).   Can it
      yield 150 gallons-per-
      day to a well?

      .  Yes, go to next step
      .  No, then the ground
        water is CLASS IIIA-
        NOT A SOURCE OF
        DRINKING WATER
        (INSUFFICIENT YIELD)

 10   Determine water-quality
      characteristics within
      the CRA or appropriate
      subdivision.

      Is the water quality
      greater than 10,000 mg/1
      total dissolved solids
      (TDS)?
      (Note: If water quality
      is unknown then this
      question must be answered
      no.)

      .  Yes, go to Step 12
      .  No, go to next step

 12   Perform interconnected-
      ness analysis.  Is there
      a low degree of inter-
      connection between the
      ground water being
      classified and adjacent
      ground units or surface
      waters within the initial
      CRA?

      .  Yes, then the ground
        water is CLASS IIIB-
        NOT A SOURCE OF
        DRINKING WATER (LOW
        INTERCONNECTION)
Yes, the uppermost
sandstone aquifer exceeds
the sufficient yield
criteria.
Yes, ground-water unit
No. 3 contains water with
TDS averaging 12,000 to
15,000  mg/1  and  exceeds
the Class III TDS
threshold.
Yes, verticle movement to
adjacent upper or lower
units is restricted by
geologic units of low
permeability.
                           C-36

-------
Step  Question/Direction           Response/Comment
        No, then the ground
        water is CLASS IIIA-
        NOT A SOURCE OF
        DRINKING WATER (INTER-
        MEDIATE-TO-HIGH
        INTERCONNECTION)
FINAL CLASS DETERMINATION:  CLASS IIIB - NOT A SOURCE OF
                            DRINKING WATER
                            (LOW INTERCONNECTION)
                          C-37

-------
  Classification of  Ground-Water  Unit No. 2  is  accomplished
using the Procedural Guide shown in Figure 4-1 and associated
worksheet in Table 4-1.
Step  Question/Direction
                             Response/Comment
  8A
      Establish Classification
      Review Area (CRA) and
      collect preliminary
      information.  Optional -
      Demonstrate subdivi-
      sion^) of the CRA.
Locate any ecologically
vital areas in the CRA.
Does the CRA or appro-
priate subdivision
overlap an ecologically
vital area?

. Yes, go to next step
. No, go to Step 4

Determine location of
well(s) within the CRA
or appropriate sub-
division.  Does the CRA
or appropriate sub-
division contain well(s)
used for drinking water?

. Yes, go to next Step
. No, go to Step 8

Determine location of
reservoirs within the
CRA or appropriate sub-
division.
Does the CRA or appro-
priate subdivision
contain reservoirs
used for drinking water?

. Yes, go to next step
. No, go to Step 9
The CRA is defined by a
two-mile radius from the
proposed facility and has
been subdivided because of
the presence of low perme-
ability flow barriers
between the ground-water
units.

No ecologically vital
areas are present in the
CRA.
                                   No drinking water wells
                                   are wihtin ground-water
                                   Unit No. 2.
No water-supply reser-
voirs are within the
CRA.
                           C-38

-------
Step  Question/Direction
      Response/Comment
  9   Determine yield from
      ground water medium
      (total depth across
      CRA or appropriate
      subdivision).  Can it
      yield 150 gallons-per-
      day to a well?

      . Yes, go to next step
      . No, then the ground
        water is CLASS IIIA-
        NOT A SOURCE OF
        DRINKING WATER
        (INSUFFICIENT YIELD)

 10   Determine water-quality
      characteristics within
      the CRA or appropriate
      subdivision.
      Is the water quality
      greater than 10,000 mg/1
      total dissolved solids
      (TDS)?
      (Note: If water quality
      is unknown then this
      question must be answered
      no.)

      . Yes, go to Step 12
      . No, go to next step

 11   Are the ground waters so
      contaminated as to be
      untreatable?
      (Note: If water quality
      is unknown then this
      question must be answered
      no.)
       . Yes, go to next step
       . No, then the ground
        water is CLASS IIB-
        POTENTIAL SOURCE OF
        DRINKING WATER

FINAL  CLASS DETERMINATION:
       The uppermost sandstone
       aquifer exceeds  the
       sufficient yield criteria,
       Water quality is unknown
       for ground-water unit
       No.  2.
       Water quality is unknown
       for ground-water unit
       No. 2.
CLASS IIB - POTENTIAL SOURCE OF
DRINKING WATER
                            C-39

-------
      Finally, classification  of  Ground-Water Unit No.  1 is
accomplished  using  the following  steps from  the  Procedural
Guide shown  in  Figure 4-1 and associated worksheet  in Table
4-1:
Step  Question/Direction
       Response/Comment
      Establish Classification
      Review Area (CRA) and
      collect preliminary
      information.  Optional -
      Demonstrate subdivi-
      sion (s) of the CRA.
      Locate any ecologically
      vital areas in the CRA.
      Does the CRA or appro-
      priate subdivision
      overlap an ecologically
      vital area?

      . Yes, go to next step
      . No, go to Step 4

      Determine location of
      well(s) within the CRA
      or appropriate sub-
      division.  Does the CRA
      or appropriate sub-
      division contain well(s)
      used for drinking water?

      . Yes, go to next Step
      . No, go to Step 8

      Inventory population
      served by well(s).
      Does the well(s) serve a
      substantial population?

      . Yes, go to next step
      . No, then the ground
        water is CLASS IIA-
        CURRENT SOURCE OF
        DRINKING WATER
       The CRA is defined by a
       two-mile radius from the
       proposed facility and has
       been subdivided because
       of low permeability flow
       barriers between the
       ground-water units.

       No ecologically vital
       areas are present in the
       CRA.
       Four domestic wells are
       present within ground-
       water unit No. 1.
       The wells do not serve a
       substantial population as
       determined under Option A.
FINAL CLASS DETERMINATION:
CLASS IIA - CURRENT SOURCE OF
DRINKING WATER
                           C-40

-------
                         CASE  STUDY  6

                         Introduction

     The  following  case  study  deals  with  the  issues  of
treatability  and interconnection.   It  is an  example of  a
Class IIIA -  High  Interconnection between surface and ground
waters.   In  addition,  based  on  the ground-water  discharge
scheme of  this flow  system,  and  the intermediate  degree of
connection  between  ground waters  on  opposite  sides of  a
river, the Classification Review Area has been subdivided.

         Preliminary Information with Respect to the
                 Classification Review Area

General

     A  permit  application is  being  submitted  for   a  site
approximately  1000  feet  west  of the Pearl River  (Figure  C6-
1).  This site is located.within city limits.

Geology/Hydroqeology

     Based  on  U.S.  Geological  Survey  reports,  the  site
geology consists of 15 to 30  feet  of flood plain  silts  and
very  fine  sands  immediately  beneath  the proposed  facility
(Figure C6-2).  The water table is located  in this unit.
Underlying the silty unit  are  4 to  11  feet of more permeable
fluvial  sand.   Thick  lacustrine  clays  below the   fluvial
sediments form the  lower flow boundary of the  site.   Ground
water discharges to the Pearl River.

Classification Review Area Subdivision (Interconnection)

     It is  known that the Pearl River  serves as  a  ground-
water flow divide,  therefore,  division  of the Classification
Review Area  into  two separate ground-water  units  (each of
which discharges to the river)  is possible (Figure C6-3).   An
intermediate degree  of interconnection  is demonstrated where
the adjacent ground waters are  in separate ground-water units
due to the presence  of a flow boundary.   The  position of the
river  as  a flow boundary  is not expected to  change  to  any
significant  degree  from  current  or  planned  ground-water
withdrawals.

Well/Reservoir Survey

     No water-supply reservoirs or drinking-water  wells  are
present in the Classification  Review Area.   Local residents'
drinking-water  supply  is piped-in from a source  outside  the
Classification Review Area.

     The above  information was  verified  by the County Public
Health Agency.


                           C-41

-------
                                 FIGURE C6-1
           BASE MAP ENCOMPASSING THE CLASSIFICATION REVIEW  AREA
 EXPLANATION

  •     PROPOSED FACILITY

	CLASSIFICATION REVIEW
        AREA BOUNDARY
        WETLANDS


        CITY LIMITS


        DIRECTION OF GROUND-WATER FLOW

        ROADWAY
2 MILES
                                 C-42

-------
C-43

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Demography

     The population is centered on the west side of the Pearl
River.  Based on U.S. Census Bureau statistics, approximately
100,000 persons reside there.  The remainder of the Classifi-
cation Review Area is sparsely populated.

Ecologically Vital Areas

     The  Classification  Review Area  does not  encompass  any
Federal   lands   designated  for  ecological   protection   or
ecologically vital areas.   Ground-water  discharge areas have
been  identified as  the  Pearl  River  and associated  tribu-
taries.   The U.S. Fish  and Wildlife  Service  confirmed that
these areas do not provide unique habitats for any endangered
species.

Treatabilitv

     Over  the  years,   the  city  has  maintained  numerous
industrial  activities which  have resulted  in gross,  wide-
spread  contamination  of  the  ground  water.    Based  on  an
extensive network of monitoring wells, it has been determined
that the  ground water has been polluted by various organic
and inorganic constituents.   Table  C-3 lists various contam-
inants present in the ground water and treatment efficiencies
typically reported in EPA treatability and effluent guideline
manuals.    The  amount  of  contaminant  cited  represents  an
average  of water-quality samples  obtained  from  monitoring
wells located on  the west  side  of  the Pearl  River.   Should
these waters be used as a source of drinking water they would
require treatment using  technologies  such as  air stripping,
lime  precipitation,   sand filtration,  and  reverse  osmosis.
Table  C-3  also presents  contaminant concentrations  after
application of these  technologies.   Drinking water standards
for some  constituents were not  met,  therefore,   the  ground
water is  deemed untreatable,  by reasonably available tech-
nologies.

     The following classification demonstration is applicable
only to the ground-water  unit  located beneath the  proposed
facility  -  the  western portion of  the Classification  Review
Area  relative  to the Pearl  River.   Classification  of  the
ground-water unit east of the river is not necessary.
                          C-45

-------
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C-46

-------
     Referring to  the Procedural Chart  shown in  Figure  4-1
and associated worksheet in Table  4-1,  the ground  water is
classified using the following steps:
Step  Question/Direction
                             Response/Comment
  8A
      Establish Classification
      Review Area (CRA) and
      collect preliminary
      information.  Optional -
      Demonstrate subdivi-
      sion (s) of the CRA.
Locate any ecologically
vital areas in the CRA.
Does the CRA or appro-
priate subdivision
overlap an ecologically
vital area?

. Yes, go to next step
. No, go to Step 4

Determine location of
well(s) within the CRA
or appropriate sub-
division.  Does the CRA
or appropriate sub-
division contain well(s)
used for drinking water?

. Yes, go to next Step
. No, go to Step 8

Determine location of
reservoirs within the
CRA or appropriate sub-
division.
Does the CRA or appro-
priate subdivision
contain reservoirs
used for drinking water?

. Yes, go to next step
. No, go to Step 9
The CRA is defined by a
two-mile radius from the
proposed facility and has
been subdivided into two
ground-water units.  The
ground-water   classifica-
tion decision is restrict-
ed to the western ground-
water unit.

No ecologically vital
areas are present in the
CRA.
                                   No, the ground-water
                                   unit being classified
                                   does not contain any
                                   drinking-water wells.
No water-supply reser-
voirs are present in the
CRA.
                           C-47

-------
Step  Question/Direction
Response/Comment
  9   Determine yield from
      ground-water medium
      (total depth across
      CRA or appropriate
      subdivision).  Can it
      yield 150 gallons-per-
      day to a well?

      .  Yes, go to next step
      .  No, then the ground
        water is CLASS IIIA-
        NOT A SOURCE OF
        DRINKING WATER
        (INSUFFICIENT YIELD)

 10   Determine water-quality
      characteristics within
      the CRA or appropriate
      subdivision.
      Is the water quality
      greater than 10,000 mg/1
      total dissolved solids
      (TDS)?
      (Note: If water quality
      is unknown then this
      question must be answered
      no.)

      .  Yes, go to Step 12
      .  No, go to next step

 11   Are the ground waters so
      contaminated as to be
      untreatable?
      (Note: If water quality
      is unknown then this
      question must be answered
      no.)

      . Yes, go to next step
      . No, then the ground
        water is CLASS IIB-
        POTENTIAL SOURCE OF
        DRINKING WATER
Yes, the ground-water
medium is presumed to meet
the sufficient yield
criterion.
No, the ground-water unit
being classified has less
than 10,000 mg/1 TDS.
Yes, the ground-water unit
being classified is deemed
untreatable by reasonably
available technologies.
                           C-48

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Step  Question/Direction
       Response/Comment
  12  Perform interconnected-
      ness analysis.  Is there
      a low degree of inter-
      connection between the
      ground water being
      classified and adjacent
      ground units or surface
      waters within the initial
      CRA?

      . Yes, then the ground
        water is CLASS IIIB-
        NOT A SOURCE OF
        DRINKING WATER (LOW
        INTERCONNECTION)
      . No, then the ground
        water is CLASS IIIA-
        NOT A SOURCE OF
        DRINKING WATER
        (INTERMEDIATE-TO-HIGH
        INTERCONNECTION)
       No, a high degree of
       interconnection exists
       between the ground water
       and surface waters.  An
       intermediate degree of
       interconnection exists
       between ground waters on
       opposite sides of the
       river.
FINAL CLASS DETERMINATION:
CLASS IIIA - NOT A SOURCE OF
DRINKING WATER (INTERMEDIATE
TO HIGH INTERCONNECTION)
                           C-49

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                         CASE STUDY  7

                         Introduct ion

     A Class I  irreplaceable drinking-water source is repre-
sented  in  this Case  Study.    The standard  Classification
Review Area, defined  by a two-mile radius  from  the proposed
facility, is used in this example.   Relevant issues for irre-
placeability  include   substantial  population  and  vulner-
ability.

         Preliminary Information with Respect to the
                 Classification Review Area

General

     A permit application is being submitted for a site along
the White River in the  midwest  (Figure  C7-1).  Land  use in
the vicinity is light to heavy  industrial  with a residential
area to the north.

Geology/Hydrogeology

     The U.S.  Geological Survey  and county hydrogeologists
characterize the principal aquifer  of the  well field (Figure
C7-2)  as a fractured sandstone formation which is overlain by
a  sandy glacial till  and alluvium.   Ground-water movement
through  the water-table aquifer   occurs  primarily  through
fractures and  is  toward the White River  where  the  ground
water discharges (Figure C7-3).

Well/Reservoir Survey

     A  municipal  well  field exists  north  of  the proposed
facility.   It  contains  19  large-capacity  wells   pumping  a
total of  8  million gallons-per-day (mgd).   These wells are
screened in the fractured sandstone formation  to an approxi-
mate depth of 300 feet.

     Residential wells are also present in the Classification
Review  Area although  their exact  locations  have not  been
determined.     It  is   known,  however,  that they are  also
screened in the sandstone, as well as the alluvium.

     No water-supply reservoirs are present in the Classifi-
cation Review Area.

Demography

     The population within the  Classification  Review Area is
estimated  at  125,000,   60  percent of  which  are  provided
drinking water  from the well  field.   This site  population
constitutes a  substantial population under irreplaceability
Option A.
                           C-50

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                                 FIGURE C7-1
           BASE 'MAP ENCOMPASSING THE CLASSIFICATION REVIEW AREA
EXPLANATION
   •   PROPOSED FACILITY
       CLASSIFICATION REVIEW
       AREA BOUNDARY
   •   MUNICIPAL WELL
— x	 CITY LIMITS
       ROADWAY
                                                                           2 MILES
                                   C-51

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                                                                                                                                                 UJ



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-------
                                 FIGURE  C7-3
                     MAP OF THE WATER  TABLE SURFACE
                                                                              2 MILES
 •    PROPOSED FACILITY

	CLASSIFICATION REVIEW
       AREA BOUNDARY

 •     MUNICIPAL WELL

-70	 PIEZOMETRIC HEAD

	 DIRECTION OF GROUNDWATER FLOW
                                    C-53

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Ecologically Vital Areas

     Ground water discharges to the White River.  It has been
confirmed  by  the U.S.  Fish and  Wildlife Service  that this
area  does  not  provide  habitat  for any  endangered species.
Thus, the  ground water  is not considered to be ecologically
vital.

Vulnerability

     Under  Option  A  for  determining  vulnerability,  one
approach,  presented  here, is  to map out each hydrogeologic
setting  in the  Classification  Review  Area  that  may have
differing  DRASTIC indices.  An  area weighted average index
can then be computed.  Figure C7-4  shows the mapped DRASTIC
map units.
                                   Rating  Weight   Number
Map Unit A - Glacial Till

. Depth to water - 5-10 feet
. Net recharge - 6-9 inches/year
. Aquifer media - fractured
  sandstone
. Soil media - clay loam
. Topography - 6-12 percent
. Impact of vadose zone media -
  sand and gravel with significant
  silt and clay
. Hydraulic conductivity -
  estimated 500 gpd/ft2
9
8

8
3
5
5
4

3
2
1
45
32

24
 6
 5
                20
                              DRASTIC Index (TOTAL) 144
                                   Rating   Weight   Number
Map Unit B - Alluvium
  Depth to water - 5-10 feet         9
  Net recharge - 6-9 inches/year     8
  Aquifer media - fractured
  sandstone                          8
  Soil media - sandy loam            6
  Topography - 2-6 percent           9
  Impact of vadose zone media -
  sand and gravel with significant
  silt and clay                      7
  Hydraulic conductivity -
  estimated 500 gpd/ft2              4
        5
        4

        3
        2
        1
        45
        32

        24
        12
         9
                35
                             DRASTIC Index (TOTAL)  169
                            C-54

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                    Area Weighted DRASTIC

Hap      DRASTIC        Proportion of          Area Weighted
Unit      Index   Classification Review Area      Index	

 A         144              40%                     57.6
 B         169              60%                    101.4

     Classification Review Area Weighted Index       159


The facility is sited over Hap Unit  B  and is designated as a
highly vulnerable hydrogeologic setting.  If the facility had
overlain Hap  Unit A then the  decision  would  still be  for
highly  vulnerable because the area weighted DRASTIC  index
exceeds the criterion and more than  50 percent  of the CRA is
highly  vulnerable.   Thus, the entire  Classification Review
Area  is  designated  as highly  vulnerable  to  ground-water
contamination under Option A for assessing vulnerability.

     Under Option B  for determining  vulnerability,  an expert
hydrogeologist in the area was consulted.   The hydrogeologic
setting of fractured sandstone overlain by sandy glacial till
and alluvium is considered highly vulnerable by this expert.

Irreplaceability

     An analysis  of available alternative sources  of  water
was  not conducted.   Thus,  by  default,  the  drinking-water
supply is assumed irreplaceable under both Options A and B.
                           C-55

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                                              07-4
                                            CUSSlpICAriON
TJ ALLUVIUM
 1 TILL
                          C-56

-------
Review       minary
collect prei-3- otional
information-
  vital
per
                              HO
                              areas
   formed.
                next step
                    -
               to next Step
                                   persons
                s
                                                 *-»
                                                 in
                              C-57

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Step  Question/Direction
       Response/Comment
      Unless proven otherwise,
      the drinking water source
      is assumed to be irre-
      placeable.  Optional -
      perform irreplaceability
      analysis.  Is the source
      of drinking water
      irreplaceable?

      .  Yes, go to next step
      .  No,  then the ground
        water is CLASS IIA-
        CURRENT SOURCE OF
        DRINKING WATER

      Perform vulnerability
      analysis.  Is the CRA or
      appropriate subdivision
      a highly vulnerable
      hydrogeologic setting?

      .  Yes, then the ground
        water is CLASS I -
        IRREPLACEABLE SOURCE
        OF DRINKING WATER
      .  No,  then the ground
        water is CLASS IIA-
        CURRENT SOURCE OF
        DRINKING WATER
       Yes,  the drinking water
       is assumed irreplaceable
       under Options A and B.
       (Irreplaceability analysis
       not performed).
       Yes,  the CRA is a highly
       vulnerable hydrogeologic
       setting under both
       Options A and B.
FINAL CLASS DETERMINATION:
CLASS I - IRREPLACEABLE SOURCE OF
          DRINKING WATER
                           C-58

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                        CASE STUDY  8

                        Introduction

     Case Study  8  relates to an  ecologically  vital habitat.
However, the  Classification Review Area is subdivided such
that the  ultimate  ground-water  class determination  beneath
the  facility  is  Class IIB  -  Potential  Source of Drinking
Water.

         Preliminary Information with Respect to the
                  Classification Review Area

General

     A  permit application is  being  submitted for  a  site
located along the  Logan  River  (Figure  C8-1).   The  area is
generally undeveloped, with the exception of the city located
in  the northwestern portion  of the Classification  Review
Area.

Geo 1 ocry/Hydr ogeol ocry

     U.S. Geological  Survey reports indicate the Valley Sand
aquifer is protected  by the  Green Formation, a predominantly
clayey  sediment  unit which  is  known  to be an unfractured,
laterally continuous aguitard.    The upper  Caldor Formation
aquifer {Figure C8-2) discharges to rivers in the region, and
leaks downward into the aguitard.  Beneath the proposed site,
ground water  from the Caldor aquifer moves away from the site
and discharges into the Logan River.

Classification Review Area Subdivision (Interconnection)

     It is known from existing studies that the river and its
tributaries serve as  ground-water divides in the area,  thus,
creating  three  ground-water  units  which  discharge  to  the
river  bodies.   Each system has  been numbered as shown in
Figure C8-3.  That  portion of the Classification Review Area
containing the  proposed  facility (ground-water unit No.  1)
does not discharge  to the segment of  the river designated as
an endangered species critical habitat.  As such, this ground
water unit is not highly  interconnected  to the waters of the
critical habitat.

Well/Reservoir Survey

     Based on state  and  local  planning  board records,  no
municipal/residential  wells  or  water-supply  reservoirs  are
present in the Classification Review Area.
                           C-59

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                               FIGURE C8-1
        BASE MAP ENCOMPASSING THE CLASSIFICATION REVIEW AREA
EXPLANATION
        PROPOSED FACILITY
        CLASSIFICATION REVIEW AREA BOUNDARY
        WETLANDS
        ECOLOGICALLY VITAL AREA
        CITY LIMITS
        ROADWAY
2 MILES
                                 C-60

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                                                                               I
                                        C-61

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Demography

     Based on  U.S.  Census Bureau  information,  approximately
20,000  persons  live  in  the  northwestern  section  of  the
Classification Review  Area.   The remaining area  is  undevel-
oped to date.

Ecologically Vital Area

     National  Fish  and Wildlife Federation records  indicate
that the southernmost  portion of the  Logan River,  within the
Classification  Review  Area,  is  designated  as  a  critical
habitat for an endangered fish species.  The location of this
habitat  also  serves  as  a  ground-water  discharge area  for
ground-water  units  2  and 3  (Figure  C8-3).    It should  be
noted, however,  that the proposed  facility is located such
that any potential  pollutants leaching into the ground water
would enter ground-water  unit No.  1  and eventually discharge
to the Logan River.
                           C-62

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                          FIGURE C8-3
       MAP OF THE  WATER TABLE AND GROUND-WATER UNITS
            WITHIN  THE CLASSIFICATION REVIEW AREA
PROPOSED FACILITY

CLASSIFICATION REVIEW AREA BOUNDARY

WETLANDS


ECOLOGICALLY VITAL AREA

CITY LIMITS
65.
                                                                    2 MILES
GROUND-WATER UNIT NUMBER

WATER TABLE CONTOUR,
IN FEET

GROUND-WATER FLOW DIRECTION
                            C-63

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     Referring to  the J»rocedural Chart  shown in  Figure 4-1
and associated worksheet in Table  4-1,  the ground  water is
classified using the following steps:
Step  Question/Direction
                             Response/Comment
  8A
      Establish Classification
      Review Area (CRA) and
      collect preliminary
      information.  Optional —
      Demonstrate subdivi-
      sion (s) of the CRA.
Locate any ecologically
vital areas in the CRA.
Does the CRA or appro-
priate subdivision
overlap an ecologically
vital area?

. Yes, go to next step
. No, go to Step 4

Determine location of
well(s) within the CRA
or appropriate sub-
division.  Does -the CRA
or appropriate sub-
division contain well(s)
used for drinking water?

. Yes, go to next Step
. No, go to Step 8

Determine location of
reservoirs within the
CRA or appropriate ssaj»-
division.
Does the CRA or appro-
priate subdivision
contain reservoirs
used for drinking water?

. Yes, go to next step
. No, go to Step 9
The CRA is defined by a
two-mile radius from the
proposed facility and has
been subdivided into
three ground-water units
due to  the presence  of a
ground-water divide.

While there is an eco-
vital habitat within the
CRA, the ground-water unit
being classified does not
discharge into it.
                                   No water-supply wells are
                                   present within the CRA.
No water-supply reser-
voirs present in the
CRA.
                           C-64

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Step  Question/Direction
       Response/Comment
  9   Determine yield from
      ground water medium
      (total depth across
      CRA or appropriate
      subdivision).  Can it
      yield 150 gallons-per-
      day to a well?

      .  Yes, go to next step
      .  No, then the ground
        water is CLASS IIIA-
        NOT A SOURCE OF
        DRINKING WATER
        (INSUFFICIENT YIELD)

 10   Determine water-quality
      characteristics within
      the CRA or appropriate
      subdivision.
      Is the water quality
      greater than 10,000 mg/1
      total dissolved solids
      (TDS)?
      (Note: If water quality
      is unknown then this
      question must be answered
      no.)

      .  Yes, go to Step 12
      .  No, go to next step

 11   Are the ground waters so
      contaminated as to be
      untreatable?
      (Note: If water quality
      is unknown then this
      question must be answered
      no.)

      .  Yes, go to next step
      .  No, then the ground
        water is CLASS IIB-
        POTENTIAL SOURCE OF
        DRINKING WATER
       Yes, the ground water
       medium is presumed to
       meet the sufficient yield
       criterion.
       No, water quality is
       unknown.
       No, water quality is
       unknown.
FINAL CLASS DETERMINATION:
CLASS IIB - POTENTIAL SOURCE OF
DRINKING WATER
                           C-65

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                         CASE  STUDY  9

                         Introduction

     The following case  study is  a  permutation of Case Study
8 leading to  a Class I  -  Ecologically Vital Classification.
Although the  preliminary  information  remains the  same,  the
location of the endangered species habitat  has  changed (see
Figure C9-1).   Relevant issues addressed in this case include
ecologically vital areas and vulnerability.

Ecologically Vital Areas

     The State Endangered  Species  Coordinator  reports that
the banks of  the Logan River provide  wetland habitat for an
endangered  species.    This  area  serves  as a  ground-water
discharge area for the Caldor Formation.   (Figure C9-2).

Vulnerability

     A vulnerability analysis is the next step in the ground-
water  classification   process  upon  determining   that   an
endangered species habitat is present  within the Classifica-
tion  Review  Area  and  the habitat can be  shown  to be  a
discharge area  for the proposed activity.   This is necessary
in order to establish  whether the  area  is highly vulnerable
to ground-water contamination.  (See Section 4.4 and Appendix
D for procedural information.)

Under Option A for determining vulnerability, DRASTIC is
utilized with the following results:

CALDOR FORMATION                   Rating  Weight  Number

. Depth to water - 5 to 10 feet      9       5       45
. Net recharge - approximately
  10-15 in/year                      9       4       36
. Aquifer media - sand with
  silt, clay,  and lignite            7       3       21
. Soil media - sandy loam            6       2       12
. Topography - less than 2%         10       1       10
. Impact of vadose zone media -
  interbedded sand with silt,
  clay and lignite                   6       5       30
. Hydraulic conductivity -
  highly permeable (approximately
  .16 ft/sec)                        10       3       30

                              DRASTIC Index  (TOTAL) 164

A DRASTIC score of 150 or more constitutes  a highly vulner-
able hydrogeologic setting under Option A.
                          C-66

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                                  FIGURE C9-1
           BASE MAP ENCOMPASSING THE CLASSIFICATION REVIEW  AREA
 EXPLANATION
  •      PROPOSED FACILITY
	CLASSIFICATION REVIEWAREA BOUNDARY
         WETLANDS
         ECOLOGICALLY VITAL AREA
         CITY LIMITS
         ROADWAY
2 MILES
                                   C-67

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                                   O
                                   O
                                   U)
                                   I
C-68

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     Under Option B for determining vulnerability,  two expert
hydrogeologists were  consulted.    These  experts disagree  on
whether  the hydrogeologic  conditions present  constitute  a
"highly  vulnerable"  setting as  they  have  differing  pro-
fessional opions  regarding  the  hydrologic properties  of the
aquifer media.   This situation under Option B was resolved by
making the conservative assumption that the setting is highly
vulnerable.
                           C-69

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     Referring to  the Procedural Chart  shown in  Figure  4-1
and associated worksheet in Table  4-1,  the ground  water is
classified using the following steps:
Step  Question/Direction
Response/Comment
      Establish Classification
      Review Area (CRA) and
      collect preliminary
      information.  Optional -
      Demonstrate subdivi-
      sion (s) of the CRA.
      Locate any ecologically
      vital areas in the CRA.
      Does the CRA or appro-
      priate subdivision
      overlap an ecologically
      vital area?

      . Yes, go to next step
      . No, go to Step 4

      Perform vulnerability
      analysis.  Is the CRA or
      appropriate subdivision a
      highly vulnerable hydro-
      geologic setting?

      . Yes, then the ground
        water is CLASS I -
        ECOLOGICALLY VITAL
      . No, go to next step
The CRA is defined by a
two-mile radius from the
proposed facility and has
been subdivided into
various shallow flow
systems due to the
presence of a ground-water
divide.

Yes, an ecologically vital
area is present in the
CRA.
Yes, under Option A,
a DRASTIC score of 150 or
more constitutes a
highly vulnerable setting.
Under Option B,
differing expert pro-
fessional opinions
exist, therefore, it is
conservatively assumed
that the hydrogeologic
setting is highly
vulnerable.
FINAL CLASS DETERMINATION:  CLASS I - ECOLOGICALLY VITAL
                          C-70

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                        CASE STUDY 10

                         Introduction

     Case Study 10 is another example of a CLASS IIA replace-
able drinking-water source.  An analysis determined that the
ground-water supply was replaceable.

         Preliminary  Information with Respect to the
                  Classification Review Area

General

     A permit application is being submitted for a site which
would overlie  a  highly transmissive  aquifer,  serving  as the
major water-supply aquifer  for  the  area.   A two-mile Classi-
fication Review Area (shown in Figure 10-1) was employed.

Geology/Hydrogeology

     Based on U.S. Geological Survey field work, the aquifer
is  divided  into  two,  approximately 50-foot  thick,  highly
interconnected zones (Figure C10-2).  The upper zone consists
of  dense,  sandy  limestones and soft,   fine-grained,  quartz
sandstones.  The  lower  zone is  made of  hard, medium-grained,
quartz sandstones and  sandy limestones  which exhibit  exten-
sive  dissolution  features.    Underlying  the  aquifer  is  a
limestone formation of low permeability.

Well/Reservoir Survey

     The  Classification Review  Area contains  a well  field
comprised  of  large-capacity wells  that  produce  8  million
gallons-per-day  for  75,000 area  residents  (Figure  C10-1).
The wells are screened in the lower sandy limestone formation
where  dissolution  features have  greatly  enhanced  aquifer
permeability.

     No water-supply reservoirs  are present.

     The above information  was  verified by the county public
health agency.

Demography

     The Classification Review Area is well  populated.   Based
on  U.S.  Census  Bureau  information,  an   estimated  75,000
persons  live within  the two-mile-wide radius.   All persons,
as  well as  industries, utilize ground-water  resources for
their  drinking  water   supply.    This  site  population  con-
stitutes  a  substantial  population  under   irreplaceability
Option A.

                           C-71

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                                FIGURE C10-1
     BASE MAP ENCOMPASSING THE CLASSIFICATION REVIEW AREA
                  \



 EXPLANATION
   •    PROPOSED FACILITY
	CLASSIFICATION REVIEW
        AREA BOUNDARY
   •    MUNICIPAL WELL
 	'  STREAM
	,...—  INTERMITTENT CREEK
        ROADWAY
2 MILES
                                 C-72

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                        C-73
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Ecologically Vital Areas

     No  ecologically  vital  areas  are  present  within  the
Classification  Review Area.    The  State Endangered  Species
Coordinator  confirmed that  the  Classification  Review  Area
does not  contain any  ecologically  vital areas or provide  a
habitat to any endangered species.

Irreplaceabilitv Analysis

     The well/reservoir  survey  in the Classification  Review
Area indicates a municipal well  field producing 8 mgd and
serving 75,000  area  residents and it is determined  that the
substantial population criterion  is met  under  both Options  A
and B.   Subsequently, a Class I, irreplaceability analysis is
performed.   In  determining  irreplaceability,  the  following
factors are addressed:

     .  Uncommon pipeline distance
     .  Comparable quality
     .  Comparable quantity
     .  Institutional constraints
     .  Economic infeasibility

     The  notion  of  uncommon   pipeline  distance  creates  a
manageable boundary  within which alternative  water  supplies
can be identified.  According to Table 4-3,  a distance of 100
miles would  be appropriate  in  this case.   Use  of  surface-
water  resources  in  the  area   is  precluded  due  to  tidal
influences  requiring  desalination.    However,  a review  of
local geological  reports,  indicates the continuity  of lower
sandy limestones tapped by the existing municipal well field.
To the  south,  urbanization and agriculture  is limited indi-
cating that production of the required volume of water may be
possible.   An alternative well  field could be  located four
miles south of  the  facility  and five  miles  from the  existing
water plant.

     Local  geological  reports  include  extensive  data  on
ground-water  quality,   particularly   for   the  lower  sandy
limestone unit.   Throughout  the region,  this unit is used as
a  water-supply  aquifer, and background  water quality para-
meters  have  limited  variation.    Elevated total  dissolved
solids levels have  been observed 15 miles  to  the southeast.
However, as  far as  five miles south, the TDS  levels average
less than 100 mg/1,  only 25 mg/1  higher than  the  existing
municipal wells to the north.   As a result, water quality is
anticipated  to  be   of comparable  quality   to the  existing
source,  and  treatment  in  addition to that received  by the
existing source will not be required.
                          C-74

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     Although water-quality  data is well  characterized,  the
quantity  of water  that  can be  produced  or the  aquifer's
sustainable  yield  is  not specically known in the  proposed
area.   However,  data  from  a  local US6S observation  well
indicates fairly constant water  levels  in  the proposed area.
The data  also  indicates the sandy limestone  formation to be
slightly  thicker near  the USGS observation well  than  in the
vicinity  of the  municipal  well  field.    Additionally,  the
composition of the sandy  limestone formation  in  each area is
similar.  In this region,  aquifer transmissivities correlate
closely   with   thickness,   indicating   fairly   homogeneous
permeability of  materials.   Although  a  pump  test was  not
conducted, productivity would  appear to be between  7  and 12
mgd, and should be adequate to replace the existing source.

     Planning  and  zoning  maps  and  tax maps indicate  that
lands in  the proposed  area are privately owned and are zoned
for agriculture.   Also,  no  other supply  wells  are  recorded
within  a  3-mile  radius of  the proposed alternative supply.
As a result, it is likely that an adequate property could be
acquired  to establish the  new  well  field.    The  easement
required  for the 5-mile pipeline  should also  not represent a
constraint as a power utility easement already exists between
the two points.

     The  final step  in evaluating the  alternative supply is
to determine if the  additional cost  of  water-supply develop-
ment  and  delivery would  be economically   infeasible  to  the
community.  The additional cost to be borne would include:

     . Land aquisition
     . Well-field development
     . Pipeline construction

     According to the  local  economic development agency, the
average cost of agricultural land in the area is $2500/acre,
resulting  in  a  cost  of $50,000   for a 20-acre  property
suitable  for a well  field.   In order to develop  8 mgd, four
100-foot  deep,  16-inch  wells  are  required,   including high
capacity  pumps  and  testing.   This  system would  cost about
$500,000  according  to  cost  information  provided  by  the
municipality from construction of the  existing  system.   The
10-year   old  cost   data   was   escalated  using  appropriate
construction cost indices.   Operation  and maintenance costs
for the well field  were  also provided  and average $200, OOO/
year, mainly for power  and  well maintenance.   Construction
costs for a five-mile,  30-inch  diameter  pipeline  was esti-
mated from  previous  sewerage transmission lines constructed
in the  area.   A local engineering firm constructed the line
and  indicated  the cost at  approximately   $30/foot  or about
$750,000.  As the power utility is providing the easement for
no  charge,  this is  the total capital  cost.    Operation and
                           C-75

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maintenance of  the line  is  estimated at  an annual  cost  of
$100,000.   Other cost  components such  as the water plant,
distribution  lines  and treatment  facility will  not  require
replacement.

     In  order to compute  the  total annual  cost  of  the  new
water-supply  components,   capital costs  are  annualized  as
indicated in Section 4.3 or in Appendix E.
     Total Capital Cost ($1,300,000)  x
     Annualization Factor (.1)  -
     Annualized Capital Cost ($130,000)

     The annualized capital cost  of  $130,000  is added to the
$300,000 in operation  and maintenance costs  resulting in  an
average  annual  cost  of $430,000 as  the  incremental increase
in  water-supply  cost.     This  figure expressed on  a  per
household basis results in $15  per household  (e.g.,  75,000
people/2.7 people/household «  28,000).  Using Option  A  for
assessing irreplaceability, the figure of  $15 is  compared to
the average annual  household  income for the  state.   Average
household income  for the  state  is $20,000 according  to  the
1980 census figures.   As  $15  is  less  than  1  percent  of that
figure  ($200), the ground water is considered replaceable and
not Class I under Option A.

     Under Option B, expert socioeconomists in the area were
consulted.  These experts agree  that the  cost of replacing
the ground  water does  not exceed  the  community's ability to
pay.   Thus,  under  Option B,  as  under Option  A,  the ground
water would be considered replaceable  and not Class I.
                           C-76

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     Referring to  the Procedural Guide  shown in Figure  4-1
and associated worksheet in Table  4-1,  the ground water is
classified using the following steps:
Step  Question/Direction
Response/Comment
      Establish Classification
      Review Area (CRA) and
      collect preliminary
      information.  Optional -
      Demonstrate subdivi-
      sion (s) of the CRA.

      Locate any ecologically
      vital areas in the CRA.
      Does the CRA or appro-
      priate subdivision
      overlap an ecologically
      vital area?

      .  Yes, go to next step
      .  No, go to Step 4

      Determine location of
      well(s) within the CRA
      or appropriate sub-
      division.  Does the CRA
      or appropriate sub-
      division contain well(s)
      used for drinking water?

      .  Yes, go to next Step
      .  No, go to Step 8

      Inventory population
      served by well(s).
      Does the well(s) serve a
      substantial population?

      .  Yes, go to next step
      .  No, then the ground
        water is CLASS IIA-
        CURRENT SOURCE OF
        DRINKING WATER
The CRA is defined by a
two-mile radius from the
proposed facility.  No
CRA subdivision has been
performed.
No ecologically vital
areas are present in the
CRA.
Yes, a well field com-
prised of large-capacity
wells that provide 8 mgd
for 75,000 area residents
is Dresent in the CRA.
Yes, drinking-water wells
within the CRA serve a
population of 75,000.
Under Option A, the
population served exceeds
the 2500-person threshold.

Under Option B, the
population served is
considered substantial
given the demographics of
the region.
                          C-77

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Step  Question/Direction           Response/Comment
      Unless proven otherwise,     No,  under Option A, the
      the drinking water source    ground water is con-
      is assumed to be irre-       sidered replaceable.
      placeable.  Optional -       Under Option B, the
      perform irreplaceability     ground water is con-
      analysis.  Is the source     sidered replaceable.
      of drinking water
      irreplaceable?

      .  Yes, go to next step
      .  No, then the ground
        water is CLASS IIA-
        CURRENT SOURCE OF
        DRINKING WATER
FINAL CLASS DETERMINATION:  CLASS IIA-CURRENT SOURCE OF
                            DRINKING WATER
                           C-78

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                        CASE STUDY 11

                         Introduction

     This  case study  details the  problems associated  with
karst hydrogeology  and the need for  an  expanded Classifica-
tion Review Area.  The hypothetical facility setting is first
examined  using the  standard  two-mile Classification  Review
Area and  second using  an expanded  review area to demonstrate
the disparity of results and limitations of a two-mile radius
to this particular setting.

            Preliminary Information with Respect
              to the Classification Review Area

General

     A  permit application is  being  submitted  for  a  site
located  in  Central  Kentucky  near  the   Little Blue  River.
Planning  and zoning maps  indicate land  use  in the area  is
primarily  rural  farmland.   Several population  centers exist
at distances  greater than two miles which  are  served  solely
by ground water.

Regional Physiography/Geology

     The  area under  consideration  is  within the  Central
Kentucky  Karst terrain which is characterized  by sinkholes,
infrequent  streams  and  an integrated  system  of  subsurface
drainage   conduits   within  a  carbonate   bedrock  complex.
Directly west of the facility, streams drain  an upland area,
flowing eastward to the sinkhole  plain.   At the  plain,  the
streams intersect sinkholes and surface  water  is diverted to
the underground network of solution conduits within the karst
bedrock.   This zone where surface water  is re-routed  to the
subsurface  represents  the  termination  of  the  eastwardly
extent  of the more  resistant sandstone  formation overlying
limestone  and dolomites.   Without the  resistant  sandstone,
surface  water has  reworked  the  carbonate bedrock  into  a
network  of  vertical  and  horizontal solution  cavities  and
conduits that drain the sinkhole plain eastward to the Little
Blue River (Figure Cll-1).

Hydrogeology

     The hydraulic characteristics of a karst aquifer are far
different  from the  Darcian  principles  of flow  through  a
granular  media.    Instead, ground-water circulation  occurs
through a  system of conduits  having a variety  of  shapes and
capacities.   The  spatial position and relationship  of these
                           C-79

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conduits and  the temporal hydraulic  heads within the  voids
determine the geometry of ground-water flow paths.   Regional
investigations  including  dye  tracer tests,  field  mapping,
exploratory  drilling,  spelunking,   and  geochemical  recon-
naissance  sampling  have  been  performed  by  county  hydro-
geologists.  The flow system is characterized  as  dynamic and
undergoes  major changes depending  upon the  magnitude  of  a
precipitation recharge  event.   Extending  our view  eastward
past the  two-mile  Classification Review  Area radius to the
Little Blue River  during two distinct precipitation/recharge
events will  help in  understanding  the intricacies  of  karst
groundwater circulation (Figure Cll-1).

     During periods of low flow (little or no precipitation),
surface-water recharges the carbonate aquifer at the sinkhole
plain and  travels  through a series of solution  cavities to
the  ground-water Basin  B trunk  conduit  (Figure C11-2  and
Figure  Cll-3).   Under these  conditions,  each  ground-water
basin  hydraulically  operates  as  a  separate entity.    The
general direction  of flow in Basin B (although  tortuous) is
directly toward the Little Blue River.

     During peak rainfall events,  recharge to the aquifer via
sinkholes  and swallets  causes  ground-water levels within the
Basin B  trunk conduit to  increase  to the point  where upper
cavity transverse  conduits are intersected  and  ground-water
migrates  into the  trunk conduits  of Basins  A and  C.   This
process is termed  "ground-water piracy".   The consequence of
this  process can  be severe.    In  the  example  setting,  a
substantial  population within Basin  C  is served by  ground
water from the trunk  conduit.  During high intensity recharge
events,  ground  water from Basin B which  could  potentially
contain contaminants from the proposed  facility  will  travel
to  all  three  ground-water  basins.    In effect,  disposal
activities  in  one  distinct  basin  could  potentially  affect
both the  substantial population  and the  ecologically vital
area.

Well Survey

     Within  the two-mile  Classification Review Area radius,
several domestic wells exist on the sinkhole plain as well as
domestic spring houses  along the sandstone upland region.
Within the expanded  review area there  is a  small  city that
relies on  ground water taken from a cave stream.
                           C-80

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                                         FIGURE Cll-1
                            FEATURES OF THE EXAMPLE KARST SETTING
  EXPLANATION
   •    PROPOSED FACILITY
 	CLASSIFICATION REVIEW AREA BOUNDARY
   ®    3000 POPULATION WELL CENTER
 t%8^<|  ECOLOGICALLY VITAL AREA
   o~   SPRING/SEEP
 -^	FLOW  ROUTE
-«•	HIGH-LEVEL OUTFLOW ROUTE
	  GROUND-WATER BASIN  BOUNDARY
 •^--•  SWALLET OF SINKING STREAM
4 MILES
                                           C-81

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  o
  z
  W
  c/5
  8
cs
 i
u

  E3
  en
  en

  §
  u
   Csl
                                             C-82

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                         FIGURE Cll-3

        EXAMPLE OF OVERFLOW ACROSS  GROUND-WATER BASINS
ou-
60-
40-
on

BASIN C


BASIN B


BASIN A

 UJ
 u.
    0-




  -20-




  -40-
                        BASE FLOW CONDITIONS

                                  (A)
  80-
ui
UJ
a.
 60-





 40-




 20-




  0-





-20-
 -40-
         BASIN C
       SUBSTANTIAL
       POPULATION
       SERVED
BASIN B
                          FLOW DIRECTIONS
BASIN  A
                         ECOLOGICALLY
                         VITAL AREA
                 HIGH INTENSITY FLOW CONDITION


                          C-83(B)

-------
Demography

     Several small cities exist nearby but do not fall within
the  two-mile  Classification  Review  Area.    Two  population
centers each having populations  around  3500  to 4000 individ-
uals  are  found within  the  expanded  review area.    Rural
residents  in  the two-mile Classification Review  Area number
approximately 100.  The  population  is small  enough, however,
not to involve the issue of substantial population.

Ecologically Vital Areas

     The   two-mile   Classification   Review  Area   does  not
encompass  any   Federal   lands  designated   for   ecological
protection or  ecologically vital areas.   To  the northeast,
within the expanded review  area and  along  the  Little Blue
River, several cave streams have been designated  as critical
habitats for  a rare and endangered aquatic species.   Given
that the cave stream is  a discharge area for ground water,
this habitat qualifies as an ecologically vital area.

Vulnerability to Contamination

     Under Option A for assessing vulnerability,  the DRASTIC
methodology yields the following results (averaged over the
review area):

                          Range    Rating   Weight  Number

Depth to Water            30-50       5        5      25
Net Recharge                10+       9        4      36
Aquifer Media             Karst      10        3      30
                        limestone
Soil Media           Thin to absent  10        2      20
Topography                 6-12       5        1       5
Vadose Zone Media         Karst      10        5      50
                        limestone
Hydraulic
  Conductivity             2000+     10        3      30

                              DRASTIC Index (TOTAL)  196

     A DRASTIC Index of 196, exceeds the 150 criterion and,
therefore,  the area is determined to be highly vulnerable to
contamination under Option A.

     Under Option B for assessing vulnerability, expert
hydrogeologists in the area were consulted.   Given the
substantial lack of soil media and the high permeability of
the aquifer, these experts agree that the area is "highly
vulnerable."
                           C-84

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              Classification Based on Two-Mile
                 Classification Review Area

     Referring to the procedural chart shown in Figure 4-1
and the associated worksheet in Table 4-1, the following
classification was performed using a two-mile Classification
Review Area as shown in Figure Cll-4.
Step  Question/Direction
       Response/Comment
      Establish Classification
      Review Area (CRA) and
      collect preliminary
      information.  Optional -
      Demonstrate subdivi-
      sion(s) of the CRA.

      Locate any ecologically
      vital areas in the CRA.
      Does the CRA or appro-
      priate subdivision
      overlap an ecologically
      vital area?

      . Yes, go to next step
      . No, go to Step 4

      Determine location of
      well(s) within the CRA
      or appropriate sub-
      division.  Does the CRA
      or appropriate sub-
      division contain well(s)
      used for drinking water?

      . Yes, go to next Step
      . No, go to Step 8

      Inventory population
      served by well(s).
      Does the well(s) serve a
      substantial population?

      . Yes, go to next step
      . No. then the ground
        water is CLASS IIA-
        CURRENT SOURCE OF
        DRINKING WATER
       The CRA is defined by a
       two-mile radius from the
       proposed facility.  No
       CRA subdivision has been
       performed.
       No ecologically vital
       areas are present in the
       two-mile CRA.
       Yes, several domestic
       wells exist on the sink-
       hole plain as well as
       domestic spring houses
       along the sandstone
       upland region.
       No substantial populations
       are present in the CRA as
       determined by Option A.
FINAL CLASS DETERMINATION:
CLASS IIA-CURRENT SOURCE OF
DRINKING WATER
                           C-85

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                                     FIGURE Cll-4
            BASE MAP ENCOMPASSING THE TWO-MILE CLASSIFICATION REVIEW AREA
                                     x

                                                      \
                                    \
                                     \

                                                      X
                                                                                      I
 EXPLANATION

  •    PROPOSED FACILITY
	CLASSIFICATION REVIEW AREA BOUNDARY

  ®    SPRING HOUSE FOR DOMESTIC USE
——  ROADWAY
4 MILES
                                        C-86

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               Classification  Based  on Expanded
                  Classification Review Area
        The expanded  Classification Review Area is  shown in
Figure Cll-5.  The  following work  sheet explains the classi-
fication decisions.  Note that Figure Cll-5 does not show the
location  of the  cave  stream  network  nor  the location  of
ground-water basin divides as shown in  Figure  Cll-1.   In the
majority of Karst areas, this information will not be known.

        Because this  karst  setting is  composed of carbonate
rocks  having  a well  developed  system  of enlarged  solution
openings an expanded  Classification Review Area  is  allowed.
It will  be assumed that the true location of ground-water
basins and karst streams is not known.  The dimensions of the
expanded review area  are then determined by the  distance to
the  nearest  spring-fed  perennial  stream; in  this  case  the
Little Blue River.   The topographic high between  the Little
Blue River and the next stream to the east is further east of
the  facility.   Therefore,  it can be  assumed under the rules
of Classification Review Area   expansion  that ground  water
beneath the facility  will move toward the Little Blue River.
The expanded review area is shown in Figure Cll-5.
                           C-87

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                                     FIGURE Cll-5
           BASE MAP ENCOMPASSING THE EXPANDED  CLASSIFICATION REVIEW  AREA















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                                                                                       4 MILES
CN'
PROPOSED FACILITY
CLASSIFICATION REVIEW AREA BOUNDARY
EXPANDED CLASSIFICATION REVIEW AREA
SPRING HOUSE FOR DOMESTIC USE
30OO POPULATION WELL CENTER
ECOLOGICALLY VITAL AREA
SPRING/SEEP
ROADWAY
                                      C-88

-------
Step  Question/Direction
Response/Comment
      Establish Classification
      Review Area (CRA) and
      collect preliminary
      information.  Optional -
      Demonstrate subdivi-
      sion (s) of the CRA.

      Locate any ecologically
      vital areas in the CRA.
      Does the CRA or appro-
      priate subdivision
      overlap an ecologically
      vital area?

      . Yes, go to next step
      . No, go to Step 4

      Perform vulnerability
      analysis.  Is the CRA or
      appropriate subdivision
      a highly vulnerable
      hydrogeologic setting?

      . Yes, then the ground
        water is CLASS I-
        ECOLOGICALLY VITAL
      . No, go to next step
The CRA has been expanded
because of the karst
setting.  No CRA sub-
division has been
performed.
Yes, ecologically vital
areas are present in the
CRA.
Yes, under Options A and
B, the expanded CRA is a
vulnerable hydrogeologic
setting.
FINAL CLASS DETERMINATION:  CLASS I-ECOLOGICALLY VITAL

Note: It  is possible that  the ground water  may also  be an
irreplaceable source of drinking water, however, there was no
need  to perform  an  irreplaceability analysis because  the
ground water qualified as Class  I  under  the ecological vital
criteria.
                          C-89

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         APPENDIX D


 TABLES OF DRASTIC FACTOR VALUE
RANGES AND CORRESPONDING RATINGS
             D-l

-------
RANGES AND RATINGS FOR DEPTH TO WATER
           Depth to Water
               (Feet)
Range
0-5
5-15
15-30
30-50
50-75
75-100
100+
Rating
10
9
7
5
3
2
1
Weight: 5

 RANGES AND RATINGS FOR NET RECHARGE

Net Recharge
(Inches)
Range
0-2
2-4
4-7
7-10
10+
Rating
1
3
6
8
9
             Weight:   4
                  D-2

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              RANGES AND RATINGS FOR AQUIFER MEDIA

Aquifer Media
Range
Massive Shale
Metamorphic/Igneous
Weathered Metamorphic/Igneous
Thin Bedded Sandstone,
Limestone, Shale Sequences
Massive Sandstone
Massive Limestone
Sand and Gravel
Basalt
Karst Limestone
Rating
1-3
2-5
3-5
5-9
4-9
4-9
6-9
2-10
9-10
Typical Rating
2
3
4
6
6
6
8
9
10
Weight: 3

                RANGES AND RATINGS FOR SOIL MEDIA
                           Soil Media
      Range
Rating
Thin or Absent
Gravel
Sand
Shrinking and/or Aggregated Clay
Sandy Loam
Loam
Silty Loam
Clay Loam
Nonshrinking and Nonaggregated Clay

                           Weight:  2
  10
  10
   9
   7
   6
   5
   4
   3
   1
                               D-3

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          RANGES  AND RATINGS FOR TOPOGRAPHY
                     Topography
                   (Percent Slope)
Range
0-2
2-6
6-12
12-18
18 +
Rating
10
9
5
3
1
Weight: 1

RANGES AND RATINGS FOR IMPACT OF VADOSE ZONE MEDIA

Impact of Vadose Zone Media
Range
Silt Clay
Shale
Limestone
Sandstone
Bedded Limestone, Sandstone, Shale
Sand and Gravel with
significant Silt and Clay
Metamorphic / Igneous
Sand and Gravel
Basalt
Karst Limestone
Rating
1-2
2-5
2-7
4-8
4-8
4-8
2-8
6-9
2-10
8-10
Typical Rating
1
3
6
6
6
6
4
8
9
10
                    Weight:  5
                      D-4

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RANGES AND RATINGS FOR HYDRAULIC CONDUCTIVITY

Hydraulic Conductivity
(GPD FT2)
Range
1-100
100-300
300-700
700-1000
1000-2000
2000 +
Rating
1
2
4
6
8
10
                 Weight:  3
                D-5

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      APPENDIX  E

    BACKGROUND DATA:
CLASS I AND CLASS III ISSUES
        E-l

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                       TABLE OF CONTENTS

                                                           Page

E.I  REQUIREMENTS AND SOURCE OF WATER-USE DATA	    E-3

E.2  USE OF GEMS SYSTEM FOR ESTIMATING WELL DENSITY....    E-4

E. 3  DENSELY SETTLED CRITERION	    E-5

E. 4  STATE LAW	    E-6

     E.4.1  General Background Information on
            Institutional Constraints	    E-6
     E.4.2  Federal Law	    E-8
     E. 4.3  Interstate Compacts	    E-9
     E. 4.4  Local Regulations	    E-10
     E. 4.5  Treaties and International Laws	    E-ll
     E. 4.6  Property Law	    E-ll

E.5  IRREPLACEABILITY: THE ANNUALIZATION FACTOR	    E-ll

E. 6  WATER COSTS VS. WATER RATES	    E-13

E. 7  SOURCES OF INCOME DATA INFORMATION	    E-15

E. 8  OVERVIEW OF TREATMENT TECHNOLOGIES	    E-18

     E. 8.1  Air Stripping/Aeration	    E-18
     E. 8.2  Carbon Adsorption	    E-19
     E. 8.3  Chemical Precipitation	    E-20
     E.8.4  Desalination	    E-21
     E.8.5  Flotation	\	    E-22
     E.8.6  Granular Media Filtration	    E-23
     E.8.7  Ion Exchange	    E-23
     E.8.8  Ozonation	    E-24
     E.8.9  Disinfection and Fluoridation	    E-24

E.9  SOURCE OF INFORMATION ON ECOLOGICALLY VITAL
     GROUND WATERS	    E-25

E. 10 RADIUS OF CLASSIFICATION REVIEW AREA	    E-25

REFERENCES	    E-43
                            E-2

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E.I  Requirements and Sources of Water-Use Data

     The  first  step  in  determining whether  a  substantial
population is  affected  is to  identify  ground waters  in the
Classification Review Area  (CRA)  serving as  drinking water
sources.  It will be necessary to determine whether these are
the  sources  of  local  town  or city drinking  water,  and  to
distinguish  between centralized  public  water  systems  and
decentralized private wells.

     If the ground water feeds public supplies, the following
determinations should be made:

        Locations of wells for public water supply;

        Well depths and pumping rates,  if available;

        Areas serviced by public water mains  from the source
        being classified;

        Whether the ground water is the only  source for the
        population it supplies;

        Percentage of water originating in the Classification
        Review Area  used  for household purposes  (factoring
        out industrial and irrigation uses);

        Number of households  supplied by  public system  (data
        are likely to be reported in this form); and

        Number of persons  per  household  for  the  area,  as
        reported  by the  Census  Bureau,  to  determine  the
        population supplied by the public system.

     The  first  step  in  obtaining  this   information is  to
contact local and state organizations with responsibility for
maintaining records of drinking  water supplies and usage for
the area.  These agencies include:

        Federal/state/local geological surveys;
        State/local health departments;
        State/local water departments;
        Local water treatment facility;
        Local water utility;
        State department of natural resources; and
        State department of energy.

     One  or  more  of  these  organizations  should  maintain
accurate records of public water usage, most  likely in terms
of the number of households or hookups supplied by the public
                           E-3

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system.   This  number may be  translated into an estimate  of
the  population served  by  using  the  number  of persons  per
household  reported  by  county  in 1980  Census  of  Population
state  summaries  (see detailed references) .   Water used  for
industry or irrigation  need to be disaggregated so that only
drinking water usage is included.

     Where public water sources  do not supply  the residents
within  the affected  area,  detailed  information  on  private
wells will be  needed.   The  same  agencies  mentioned above may
also  have  information  on  private wells.    Private  sector
organizations  that may  have useful  information  include water
companies and well-drilling firms.

E.2  Use of GEMS System for Estimating Well Density

     One  means of  estimating private  well  usage in  areas
where no  local information  on private wells is  available,  is
to  use population data for the  area  of  interest available
through   the   Graphical  Exposure  Modeling  System    (GEMS)
maintained by  EPA's  Office  of Toxic Substances, or a  private
census  data service  (see  list  of organizations  registered
with the  National  Clearinghouse  for Census Data Services in
Appendix E).

     Information on  the GEMS  system is available  from EPA's
OTS  modeling   team.   Using the  GEMS Census  Data  (CD)  pro-
cedure,  it is possible to retrieve  population and  housing
count  data  from  the  1980 Census for circular areas around a
point, which  can be  designated using latitude  and longitude
coordinates or the  ZIP code of the location.   The  system
provides  information  within defined concentric  rings  ranging
from 0.1 to 10,000km in radii.  It is necessary to supply the
number  of  sectors  into which   the  rings  are   divided;  the
procedure  allows from 1 to 16.    Sectors  are  numbered clock-
wise  with the first sector  centered  at  zero   degrees (the
north  compass  point  direction).   The  program tabulates total
population and housing  counts by ring distance  and sector.  A
simple  mathematic  conversion can be used to  transform  the
population counts into  density.

     The manner  in which population data  are recorded by the
Bureau  of  the Census  and  reported by GEMS  can  result  in
reports  of no population  for  some areas  where  people  are
living.   This information  can  be  verified or corrected  by
consulting  local officials.   It is unlikely  that  such areas
would  satisfy  the densely settled test,  however.
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E.3  Densely Settled Criterion

     If private wells in the CRA  are  found to serve at least
2,500 people,  the densely settled  criterion will be  met if
the CRA is part of  a  census-designated densely settled area.
If it is contained  in an  Urbanized Area  as described by the
Census  Bureau,  the  population  is  by  definition  densely
settled unless it can be shown  to meet any of the exceptions
described under  the  definition of a densely  settled area.
Census  Designated  Places   (CDP's)  also  by  definition  are
densely  settled.    These are  unincorporated  places  with  a
population density of at least 1,000 persons per square mile.
They  are outlined  on  Census  tract   maps  for  metropolitan
areas, on block numbering area  maps in nonmetropolitan areas
of less than 10,000 people (see Appendix F).

     Key terms used by the Census Bureau as follows:

        Metropolitan statistical  area (MSA):    (a)  a city of
        at least  50,000  population, or (b)  a Census Bureau-
        defined urbanized  area  of at least  50,000  with  a
        total  metropolitan  population of  at  least 100,000
        (75,000 in  New England).   There are  277  MSAs (as of
        June 30,  1984).   Every state has at least one MSA.

        Urbanized area  (UA):  a population  concentration of
        50,000 or more,  generally  consisting  of  a central
        city together with its surrounding  densely settled
        contiguous territory or "suburbs"  (the urban fringe).
        There are about 420 UA's.

        Urban place;  any population  living  within urbanized
        areas; or places  of  2,500 or more people outside
        urbanized areas.

        Densely settled  area;  not an official  statistical
        division,  but used by the  Census  Bureau  to indicate
        an area with  a population density of at  least 1,000
        persons per square mile within an urbanized area or
        Census Designated Place (CDP).

     Urbanized Areas  may  include  areas which do  not qualify
as densely settled,  (e.g.,  less than 1,000 persons per square
mile)  but are  included  within  such geographic  boundaries
because they either:

        Eliminate enclaves  of  less  than  five square miles
        which are surrounded by built-up areas.
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        Close  indentations  in  the  boundaries  of  densely
        settled areas that are no more than one  mile across
        the open end and encompasses no more than five square
        miles.

        Link  outlying areas  of qualifying  density,  provided
        that the outlying areas are:

        (a) Connected by road to,  and are not more than 1-1/2
            miles from,  the main body  of  the urbanized area.

        (b) Separated from  the main body  of the  urbanized
            area by  water or  other undevelopable  area,  are
            connected  by  road  to  the  main  body  of  the
            urbanized area, and are  not more than five miles
            from the main body of the urbanized area.

        Are  nonresidential  urban  areas  (e.g.,   industrial
        parks, office areas,  or major airports), which have
        at least one-quarter of their boundaries contiguous
        to an urbanized area.

     MSA's and their components are listed in the 1980 Census
of Population -  Supplementary Report;  Metropolitan Statis-
tical  Areas  and  are mapped   on  State  MSA  outline  maps.
Urbanized  area  (UA)  outline  maps  are  generally  contained
within MSA publications.

E.4  General  Background  Information  on  Institutional  Con-
     straints

     Institutional constraints on the availability of water
can arise  from at  least six general sources.   Each of these
is discussed below.

          E.4.1  State Law

          State  law  creates basic  rights to  the withdrawal
and use of surface and ground  water.  For example,  state law
may  regulate  the  rights to   or  ownership of  water,  the
withdrawal, uses and allocation of water,  conjunctive use of
surface and  ground water, protection  of  instream users, and
measures required  to protect ground water.   The  law in most
states, however, does not create a right to unlimited amounts
of water,  and may  restrict where  the water may be used  (U.S.
EPA, 1985;  Council of State Governments,  1983).   The states
have  created  different  methods  for establishing  rights to
water and resolving  conflicts  over rights to withdraw and use
water.  There are  three  major  systems of regulation of water
withdrawal and use:
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        The Eastern  (common  law)  doctrine,  used in  about  37
        states,  provides that ownership of  land  carries with
        it a right to water in adjacent lakes or watercourses
        (a  riparian  right)  and  to water  beneath the  land.
        The use  of  the  water,  however,  may be  restricted.
        Under the absolute use doctrine it  is possible  for a
        landowner  to withdraw  unlimited amounts  of  water,
        without liability for damage to other landowners, and
        to  transport the  water  off  the  land.    Under  the
        reasonable use doctrine it is possible to withdraw an
        amount of water necessary for the use or enjoyment of
        the overlying  land,  but the  water  may not  be  tran-
        sported away from  that  land.   Under the correlative
        rights doctrine, the right to withdraw  ground  water
        is based on the relationship  between the size of the
        aquifer and the area of the overlying land.

        The Western  (appropriation)  doctrine,  used  in  about
        13 states, provides  that water is a public  resource,
        and rights to  water may  be acquired by  actual use.
        Conflicts in priority  of use are ordinarily settled
        by the principle of  "first  in time,  first in right."
        Hierarchies of use, however, may also be established.

        Permit systems, used in about 31  states, may be used
        in conjunction with  the common law  or  appropriation
        doctrines, and may be applied  to surface and/or  to
        ground water.  Rights to water under a  permit system
        are acquired by  application to a regulatory author-
        ity.   If the authority  determines  that no  superior
        claim exists to  the Water,  it  records the  claim,
        issues a permit for  use,  and  polices the actual use.
        Permit systems may co-exist with other forms of water
        regulation,  such  as  designated ground-water protec-
        tion zones or management  areas.   Many  permit systems
        specify  priorities  for  different types  of uses  of
        water  (beneficial  uses),  generally making  domestic
        use, such  as drinking water, the highest beneficial
        use and  making  other uses,  such  as  commercial  or
        industrial use and irrigation, lower beneficial uses.


     Conflicts among users,  or  prospective users,   of  water
are resolved by most states  in three  ways:   the conflict may
be  decided  by  the  administrative  organization  that  ad-
ministers the water  rights system in  the state,  particularly
if water use permits are  required;  special  organizations may
be created to resolve water  disputes; and the  state or local
courts may  resolve disputes.   State  law in certain circum-
stances may allow the  use of eminent domain powers  to shift
                            E-7

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water from one use to another,  or to allow physical access to
water, and state  law may grant the use of eminent domain to
the  Federal  government  for certain  purposes.    Frequently,
when  insufficient water exists  for  all claimed  uses,  lower
beneficial uses may give way to higher beneficial uses.

     Some  states  have  attempted  by  law  to  restrict  or
preclude the export of water to users in other states, either
by  requiring  legislative  approval  of  water  exports,  by
requiring  reciprocity agreements with  the  states receiving
the water, or  by absolute prohibitions.  All  of these  forms
of restriction have recently been subject to legal challenge.

     A number  of  states,  particularly in  the West, designate
ground-water protection  zones  or management areas,  and seek
to  coordinate  surface  and  ground-water  use   (conjunctive
management).    Measures  of conjunctive management may include
restrictions   on   pumping  ground water,   requirements  for
aquifer recharge, and well spacing requirements.  Some states
(e.g., Texas, Nebraska) delegate aquifer protection authority
to local administrative bodies.

     E.4.2  Federal Law

     As  a user  of water,  the Federal government generally
defers  to state  regulation of  water.    Federal  laws  often
pertain  to Federal and  Indian reserved rights  to water and
Federal  activities affecting water.   In common  law States,
Federal rights to water are linked to ownership or control of
land.    In prior  appropriation and  permit States,  Federal
agencies  (e.g., the Bureau of Reclamation) register claims to
water.   The  Federal government  may,  however,  have special
access  to water  in  certain circumstances.   Statutes  (e.g.,
the  Oil and  Gas  Well  Conversion Act)  or  executive orders
(e.g.,  the Executive Order of April  17,  1926)  may reserve
water rights on Federal public lands for particular purposes.

     For  certain categories of Federal lands  withdrawn from
the  public domain and  reserved  for such  uses  as national
forests, wildlife  refuges, and parks, Federal reserved rights
doctrine  can provide access to water  irrespective of  State
law.    The courts have  created  this doctrine,  which  holds
generally  that  reservation of public  domain  lands  for   a
particular purpose carries with it  an implied reservation of
sufficient water to  satisfy the purposes  for  which the land
was  reserved.   The  right  is not  created by  use  or lost
through  non-use.   Therefore,  in  certain  circumstances, even
if  the water  is being  used by another person,  the Federal
government can obtain water for its  own use.  The purpose of
the  water is determined as of the time the land  reservation
                             E-8

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was  created,   and the  reserved  right  is limited  to  that
purpose.   (For example,  if the  reservation  was  created  to
provide  agricultural  land,  reserved  rights  to  irrigation
water may  exist,  but there  are  no reserved rights  to water
for industrial purposes.)

     An  Indian   reserved   right,   similar to  the  Federal
reserved right, has  also been created by the courts.   This
doctrine  is  apparently based  on  the  presumption  that  in
creating an Indian reservation the President  and/or Congress
intended to reserve sufficient water for the use of the land.
Indians  may hold superior  rights to  water   connected  with
reservation  lands.    Apparently,  such rights  may  be  sold,
although  it  is  unclear  whether  only the amount  of  water
actually being used  or the entire potential right may  be
transferred.    In addition  to  reserved  rights,   in  a  few
instances  Indians also  hold special  water rights  based  on
treaties (e.g., Treaty of Guadalupe Hidalgo).

     Federal  water  resource agencies,  such as the  Corps  of
Engineers,   the Bureau of  Reclamation, and the  Soil Conser-
vation  Service, as well as such  Federally-chartered agencies
as  the  Tennessee  Valley  Authority and  the Bonneville Power
Authority,  can affect  water availability,  either through the
water  rights  that  they  hold   or through  their  decisions
concerning  water  management  (Congressional   Budget  Office,
1983).   Numerous  other Federal agencies and  laws  can affect
water  resource  decisions   indirectly.    Examples  of  such
agencies or laws include  the Forest  Service and  Bureau  of
Land  Management   (right-of-way   decisions),   the   Fish  and
Wildlife Service  (requirements under  the Fish  and Wildlife
Coordination  Act),   the  National  Environmental  Policy  Act
(Environmental  Impact  Assessment  requirements), Clean Water
Act  (dredge  and  fill  permit requirements) and the  Wild and
Scenic  Rivers Act   and  National  Wilderness  Preservation
requirements.

     E.4.3  Interstate Compacts

     Conflicts  among  two  or  more states  or  the  Federal
government  concerning  rights to  water  in streams generally
are  resolved  either through interstate compacts  or through
litigation  (Clyde,  1982,  1984;  Schwartz,  1985;  Sporhase vs.
Nebraska,  1984).   The result in either  case is usually  a
decision  allocating  the  in-stream flow  among  the  states
claiming the  water.   In  a few cases,  ground  water  has also
been allocated among states by  interstate compact  or court
decision.
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     Interstate  compacts  are  agreements among  states  that
have been  ratified  by the legislatures of the  participating
states and the U.S. Congress.  The  compact creates  a binding
law within the participating states  and a binding  contract
among the  states.   In certain cases, the Federal  government
also joins the compact, and the compact  is then  binding also
on the  Federal government.   The members and powers of  the
compacts currently  in existence  vary widely, from  bilateral
agreements  (e.g.,   Snake  River  Compact  between  Idaho  and
Wyoming)  to agreements  affecting  large numbers  of  states
(e.g., Colorado River Compact),  and from compacts exclusively
devoted  to  allocating river  water  (e.g.,   Arkansas  River
Compact  of 1949)  to  compacts establishing   regional  multi-
purpose  water  resources  management  (e.g.,   Delaware  River
Basin   Compact).     Approximately  25   interstate   compacts
currently are in operation.

     In  the absence  of  a resolution of conflicting  claims
through an interstate compact,  litigation among states before
the U.S. Supreme Court may be the only means to resolve the
conflict.    In deciding  such cases, the  Court  ordinarily
attempts  to  carry out  an  equitable apportionment of  the
interstate  stream.   Because the  Court  has been called upon
less frequently to  resolve disputes  among  states over ground
water, the standard used in such cases is less clear.

     E.4.4  Local Regulations

     Local  administrative  bodies   with  jurisdiction  over
sources of water in particular areas may exercise powers such
as well spacing  and  pumping  rates  that  affect the  avail-
ability  of water.   As previously noted,  state  legislatures
may delegate  power to local bodies  to  administer particular
aspects of the water allocation or water protection system in
the state.   Examples  of  such local  agencies include under-
ground  water   conservation  districts   (Texas),  which  are
empowered  to provide  for  spacing of wells   and  to regulate
well pumping  in order to minimize the drawdown  of  the water
table;  ground-water management districts (California),  which
are authorized  to  manage  ground-water withdrawals;  and water
conservation  districts (Nebraska),  which  are authorized to
regulate ground-water use.   Other  special purpose districts
may  also  affect  water   availability.    The Texas  Harris-
Galveston   coastal  subsidence  district,  for   example,  is
authorized to regulate withdrawal of ground water in order to
limit land subsidence.
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     E.4.5  Treaties and International Laws

     Treaties between  the United  States and  its  neighbors,
Mexico  and Canada,  allocate the  waters  of  rivers  flowing
between the countries.   The 1944 Treaty of Utilization of the
Waters  of the  Colorado  and Tijuana    Rivers  and  the  Rio
Grande, for  example,  apportions the  waters of  those  rivers
between  the  two  countries  and  creates  an  International
Boundary and Water Commission (IBWC) to  apply  the  treaty and
settle  disputes.   Although ground water use is  not  fully
covered by the treaty, the  IBWC has attempted  to address the
management of international ground-water resources.

     In addition  to treaties  signed by the  United  States,
certain international  law proposals  being developed by the
United  Nations  and  the  International  Law Association  may
sometime  in  the  future establish general  principles  for the
allocation of  ground  and surface waters  between two  coun-
tries.

     E.4.6  Property Law

     State law  governs the  ownership and use of  land.   In
particular,  "property  law"  affects physical access  to  water
supplies through restrictions on rights of way and easements,
or defining  powers of eminent  domain.   State  and Icoal law
generally  regulates  land use and  access to land  by persons
who  are  not landowners.    Access  to  water,   including the
location  of  pipes,  storage, pumping,  treatment,  and  other
facilities  can be delayed  or  restricted  by  the  property
rights of persons whose land must be crossed or used for such
facilities.   Special  procedures, such  as  easements,  eminent
domain, and  condemnation  may be required to obtain necessary
rights-of-way.  Special procedures vary from state to state.

E.5  Irreplaceabilitv;  The Annualization Factor

     An   annualization  factor   may   be  used  in  comparing
economic  feasibility  in  the   irreplaceability test.    The
annualization  factor  (AF),  also  known  as a  real  capital
carrying charge, is given by:

                   AF =      r
     where r = real interest rate
           n - life expectancy of capital equipment

The  annualization factor is  derived to obtain  equal annual
payments of capital costs in constant dollars (i.e., adjusted
                           E-1 1

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for inflation) .   This annual izat ion factor is  equivalent to
the formula used to obtain a total  of  n equal annual payment
for a  fixed mortgage  in  real  dollars, where r is  the  real
interest rate for the mortgage.

     The choice of  real  interest rates depends on  the costs
of available  financing for water  supply alternatives.   The
U.S.  Office of Management and  Budget  (OMB)  recommends that a
ten percent  (10%)  real  interest  rate be  used to  discount
capital  costs  in   the  analysis  of   regulatory   options.
Therefore,   an interest rate of  ten percent  can  be  used to
derive annualization  factors.   Alternatively,  real  interest
rates on tax  exempt bonds used to  fund water  projects can be
used in the analysis.

     Municipalities and  local  governments  can rely  on  tax-
exempt  bonds  to  finance  their  water   supply   projects.
According to  Standard  & Poor's,  the average nominal interest
rate on tax exempt bonds was 9.0%  in May 1985.  The yield on
individual  bonds  would  depend  on the  bond   rating.    Real
interest  rates on tax-exempt  bonds  can  be  derived  from
nominal rates  (i)  by the following formula:
                  1 -
                      1 + e
where:  r = real interest rate
        i = nominal interest rate
        e = expected rate of inflation

Assuming an expected rate of inflation of 4 percent

              r . 1+.0908   - 1
                  1+.04
                = 1.049 - 1
                = .049 " .05 or 5 percent

Annualization  factors  are  calculated here for  both  5 and 10
percent real interest rates.

     Dereivation of the annualization factor  (AF) is affected
by  the expected  life  of  the  capital equipment  (n) .    The
appropriate  life-expectancy value  to be  used  depends upon
many factors,  including  the type and complexity of equipment
and annual operating and maintenance schedules.  Typically, a
value of 30 years is a reasonable life expectancy for a water
treatment  plant  involving  conventional  techniques  such  as
sand  filtration,  flocculation and  precipitation,  and chlor-
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ination. Other,  simpler systems  may remain  operational  for
longer  periods  and  certain  components  (such  as  valves,
montioring  equipment,   or  motors)  may  not   last  30  years.
Capital costs can be annualized by three single steps:

     (1)  Estimte capital costs
     (2)  Estimate annualization factor
     (3)  Multiply capital costs time annualization factor to
          obtain annualized costs.

     Table  E-l  provides  three  annualization  factors  that
incorporate  alternative assumptions  for life  expectancy  of
the capital equipment,  assuming a  real  interest rate of five
and ten percent, respectively.   The values  from the  table
above can be used directly to annualize capital costs.  After
capital costs are annualized, they  should  be  added to annual
O&M costs to obtain the total annual costs.

     The procedure for  annualizing  capital costs  can best be
illustrated by a numerical example:

     Assume Capital Costs                = $1,200,000
            Real interest rate           = 10% or .10
            Life expectancy of
              capital equipment          =30 years

    Then
           AF = -
              =     .10       =      .10
                1-1/(1+.1)J0      1-1/17.449

              = .10  = .106
                .943

   Annaulized Capital Costs = Capital Costs x AF
                            = $1,200,000 x .106
                            = $127,200

E.6  Water Costs vs. Water Rates

     Ground-water classification  for  Class  I - Irreplaceable
would normally require an assessment of the economic costs of
an  alternative  water supply  under  both the  qualitative and
quantitative  approaches  for  judging  irreplaceability.   The
discussion in this  section  indicates  that  rates changed by a
water  supply utility may  not  reflect economic  costs  for
various  reasons.    This  implies  that  when  the  feasibility
determination is not clear-cut and when sufficiently detailed
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      TABLE E-l
ANNUALIZATION FACTORS
n
(Life Expectancy of
Capital Equipment)
15
30
40
AF
(Annualization Factor)
r = .10
.131
.106
.102

r = .05
.096
.065
.058
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cost accounts are available from the utility, these should be
used in preference to the rate schedules to estimate costs.

     The economic  cost of the  water supply may  differ from
the charges made to the community by the utility for a number
of reasons.   The utility may not  set rates on the  basis of
economic costs  of supply, or the utility  may not  face  the
true economic costs.   Rates  and fees may be set  with refer-
ence  to  the  average  costs  of  the  utility,  whereas  the
economic costs  of additional water  supply  capacity  are  the
marginal (or incremental) costs of this  capacity.  Secondly,
the utility may  charge different rates  to different types of
users in such  a  way that one type of user   (e.g., industrial
users)  implicitly  subsides  other  types  of  users   (e.g.,
households).  The concepts are illustrated in examples below.

     Consider  a  hypothetical  system   that  serves  10,000
households.  It  has annual O&M  costs of $500,000  and annual-
ized capital expenses of $500,000 (including an allowance for
an acceptable return on capital).   Therefore the total annyal
expenses of the  system are $1,000,000.    The utility charges
all households  served by the system the  same flat  rate of
$100  per  annum  to  recover  costs  and  capital  charges  of
$1,000,000.  Suppose that the system is  expanded to serve 100
additional  users;  O&M costs  increase   to   $60,000,  capital
charges increase to $600,000.   The one time costs of connect-
ing the  new users of  $100,000  are  recovered  immediately by
charging each additional user a connection  fee of $100.  The
utility  re-computes  rates  of  11,000  users  based on  total
costs and capital charges of $1,2000,000, and so charges each
user $109.09 ($1,200,000 divided by  11,000).  The charges to
the new users  are  the total connection  fee  of $100,000 plus
$109,000 annually  (1,000  multiplied  by  $109.09)  for  a  total
of $119,090.   However  the  true costs to the system of  the
additional users  is  $109,000  connection  costs plus $200,000
annually   ($1,309,000  minus  $1,000,000)   for a  total   of
$309,000.   Therefore the rates and fee charged  tot he  new
users understate the true economic  costs.   The  converse is
also possible; marginal costs may be lower than average costs
so the  charges  to  new users may exceed the  true  economic
costs.

     Consider a  system serving  10 industrial  users  and 1000
households.   Total  system  costs are  $1,000,000  per annum.
The system supplies  supplies 200,000,000  gallons annually.
Each household uses  an average of 100,000  gallons per annum
and each  industrial  user takes 1,000,000 gallons per annum.
The  utility  charges  industrial  users   of  0.75  cents  per
gallon,  raising  annual  revenue  of  $75,000,  and  charges
households  a  flat rateof  $25 per  annum,  raising  a further
                           E-15

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$25,000.  Total  revenues  are $100,000 which covers the  cost
of the  system.   Household  users are  charged  an average  of
0.25  cents  per  gallon,  and  so  are  implicitly  subsized  by
industrial users.   Economic costs of the  system  are  0.50
cents  per gallon,  which  exceeds  the  implicit per-gallon
charge to household,  and  is less than the per-gallon  charge
to industrial users.

     A  further  general  reason that  utility  rates  may  not
reflect economic costs is that the utility does  not  face the
full  economic costs of the  system.    This  can arise if  the
utility's capital  expenditure is  subsidized  by grants  and
loans from State or Federal  agencies,  or  by  preferential tax
treatment.   This introduces a further  potential source  of
difference between rates and economic costs.

     In  cases  where  cost  accounts  are  not available,  the
financial  accounts   of  the  utility  should  provide   some
information that may be used to adjust rate schedules to more
closely reflect economic oosts.  For  example,  capital  grants
for  construction received  by  the utility  from  state  and
Federal funds will  be shown on the balance  sheet.   This can
be compared with total plant costs (the book  value  of  these
fixed assets) to  find the proportion  of  capital  costs  borne
by the utility.  Suppose 50  percent of the capital  costs are
paid for by grants and 50 percent by the utility.  Annualized
capital expenses are  60 percent  of  total  operating  expenses.
In this  case,  the utility  is effectively subsidized for 30
percent  of  total  operating  expenses.   In this  case,  the
utility  is   effectively  subsized  for  30 percent  of  total
operating  expenses   (50  percent  of  60  percent  of  total
expenses).  As the  utility  faces only 70  percent of economic
costs,  rates  should  be  increased  by  a  factor of  1.43  (100
percent  divided  by  70  percent)  to crudely  reflect  this
difference between rates and economic costs,   other potential
distortions may  be  more difficult to  correct  (even crudely)
without  access  to  costs  accounts.     For  example,   while
different types  of  users  may be charged  different  rates,  it
may  be impossible  to determine whether  this reflects  dif-
ferent  costs  of providing  a service  to  different types  of
users or cross-subsidization between user types.

E.7  Sources of Income Data Information

     Income data is available from various sources;  depending
on the  specificity,  and the population density  of  the area.
Data  sources include  the following:

      1) County  or  City  Level  - The County  and City  Data
        Books, U.S. Bureau of the Census, 1983.
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     2)  Census Tract  Reports  for each  Standard  Metropolitan
        Statistical Area.

     3)  Block Reports  (Maps  in print)  and Block Group  data
        for areas  of the  county which were  blocked by  the
        1980 Census, but are not within tracts.

     4)  Enumeration District Reports for areas of the country
        (rural)  which were not blocked by the 1980 Census.

     5)  Regional Office of the Census.

     6)  State  Coordinating  Organizations  which  may   have
        compiled income data for a specific area.

     7)  Companies  within  the   National   Clearinghouse   for
        Census   Data  Services   that  provide   demographic
        studies.

     County and city  income figures  are listed  in The County
and Citv  Data Book.  U.S.  Bureau of  the  Census, 1983.   The
County  and City Data Book shows for  each county  and  city
(defined  by more  than  25,000  people)  the median  household
income for 1979.

     Each  standard metropolitan  statistical  area  is broken
down  progressively into  tracts,  block groups,   and blocks.
The smallest unit for which income data is available from any
depository  library or  from  GPO.   The reports  contain  both
means and medians of household income from 1979.

     Certain  areas  of the county were not tracted  but  were
blocked.   These  areas may be found  in unincorporated places
of more than 10,000 people and in states (Georgia, Mississip-
pi, New York,  Rhode Island, and  Virginia),  which contracted
with the Census Bureau.  The unit in which income information
may be found for these areas is the block group.   Two sets of
material should be obtained from the Census Bureau:  (1)  block
maps, available  in print  and  categorized by state,  and (2)
block group  reports  available  as  STE-1A  microfiche or on
computer tape.   Areas not blocked in  the  1980  census (i.e.,
rural areas)  are broken down  into enumeration districts  that
average approximately  550  people and  are  listed by counties
within states.

     Regional and  state offices may also provide specialized
income  information.    A  list   of  the information  service
specialists in  the Census Bureau Regional  Offices  and  State
Coordinating Organizations may be found in Appendix F.
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     Private demographic  companies,  which the  Census  Bureau
refers  to  as   "National  Clearinghouses   for   Census  Data
Services"  may  also  be  helpful.    For  example,  if  median
household  income inside a 3  mile radius  around a CRA  were
desired, a  national  clearinghouse would  be able to  provide
appropriate information.   A  list  of these organizations  is
available in Appendix F.

E.8  Overview of Treatment Technologies

     The  following  discussions  of  treatment  technologies
indicate the typical  area of application  and  limitations  of
particular  significance  and  the potential problems  encoun-
tered  when treating  water with multiple  contaminants.    A
series of references is included that can be used for general
background  data.   Many  treatment  processes,  particularly
those used  in  water  polishing,  develop reductions  in  treat-
ment  efficiencies in  the  presence  of  interfering  contam-
inants,  so that "pretreatment" is  required.    In  existing
water treatment  facilities, the pretreatment requirements are
met  using  the  processes  in an  order  which  progressively
removes various  interferences.  For example, a  facility which
receives a water with high levels  of adsorbable organics and
high suspended solids may use granular media filtration prior
to carbon  adsorption  in an effort to minimize  the  levels  of
solids  in the  influent to  the carbon adsorption; the load of
solids to the adsorption column will disrupt this process.

     If  several  processes in a  treatment  configuration have
disruptive  interference problems,  the particular combination
of  processes  cannot  be  reasonably  employed   to  treat  the
water.   This  situation might occur  if an influent contained
high levels  of dissolved organics and of  inorganic chemical
oxidants, and the treatment configuration under consideration
was  a  combination  of desalination  and  ion  exchange.   The
dissolved  organics, which would be  removed by desalination,
could  severely disrupt the ion  exchange  efficiencies, while
the  chemical  oxidants  (removable  by  ion exchange)  could
disrupt  the desalination  process.   This  particular treatment
configuration  would,  in  this  instance,  be eliminated  from
further  consideration because additional  pre-treatment would
be required to manage the chemical interences.

     E.8.1  Air  Stripping/Aeration

     Air  stripping  and aeration can be  used for  removal  of
volatile  contaminants  from   ground  water,  as  well   as  for
introduction of  oxygen  to the water.  Air is  passed through
the  water  or the  water  is  finely sprayed  into the  air,
enhancing  transfer of dissolved gases from the water  to the
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air,  which may be  treated  further  or discharged.    Cost
effective  and  efficient treatment  requires  continuous  or
semi-continuous flow.  The process has been used for ammonia
removal,  hydrogen  sulfide  removal,  and  volatile  organic
carbon  removal  in  both  water   and   wastewater  treatment
operations.    The  treatment  efficiences  and design  are  a
function of the contaminant loading  to the  air;  water ratio,
the  length  of contact  time,  contaminant  volatility,  and
temperature.    Removal  efficiencies  of  volatile  organics
ranging  from  10  to  greater  than  99.0 percent  have  been
reported in the literature.

     Although  air  stripping  is  a  relatively  inexpensive
technology  for  removal  of  volatile contaminants,  its  use in
public  water  supply  systems  to  date  has  been  somewhat
limited.  This is primarily due to an absence of need for the
technology, which is in wide-spread use in Superfund remedial
action  and wastewater   treatment  operations.    Traditional
aeration, which is  in common  use  among public  water  utili-
ties, has typically been installed to  provide oxygenation of
waters, and the removal  of volatile  contaminants is merely a
beneficial side-effect.

     Temperature limitations  in regions  experiencing  severe
winters may be such that air stripping and aeration processes
must be housed  indoors or in  thermally protected facilities.
If the treated water contains high levels of suspended solids
(unlikely to  occur  with ground waters),  some pre-treatment,
such as filtration or pH adjustment,  may be required prior to
air stripping.

     Aeration and air stripping pose potential air pollution
problems  if large  amounts  of volatile contaminants  in the
treated  waters are transferred  to the  air.   If this  is a
problem, emission control devices  are  required.   Most ground
waters, however, are not likely to contain concentrations of
volatile contaminants sufficiently large to warrant such con-
trols.

     E.8.2  Carbon Adsorption

     Carbon  adsorption   treatment  of  ground  waters  entails
contacting  the water with  activated  carbon, which  adsorbs
contaminants  and  removes  them  from  solution.    Granular
activated  carbon,   used  in  beds  or  columns,  is the  most
commonly  used form, although  powdered activated  carbon has
been   used  in  some   wastewater   treatment  applications.
Treatment processes  can use  both  batch and continuous feed
operations.   Activated carbon adsorption effectively removes
many  organic   and   inorganic  contaminants  from  solution.
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Treatment efficiencies are  a  function of the type  of carbon
used, the concentration and type of contaminants present, the
length  of contact  time  for  each  unit  of water,  and  the
interval between carbon regneration or  replacement.   Removal
efficiencies ranging from 0 to greater than 99.9 percent have
been reported in the literature.

     Although activated  carbon adsorption  theoretically can
provide limitless removal  of  contaminants, in  reality there
are  economic  limitations to  the applicability  of  activated
carbon treatment.  Removal  of high  concentrations  of contam-
inants may require overly  frequent  carbon replacement, while
hard to  remove contaminants  may require  enormous  treatment
facilities  with  several   carbon   contact systems:     both
situations may incur  excessive  expense,  and  though  tech-
nically feasible would be effectively unavailable.

     Influent  to  the  carbon  adsorption  process  must  be
relatively free of suspended solids and oil/grease to prevent
clogging  of  the adsorption beds.   Suspended solids  of less
than 50 mg/1 and oil/grease of less than
10 mg/1 are recommeded concentrations to avoid interferences.
Biological activity in the carbon beds may become  a problem
in  some  instances,   causing  clogging  and  taste  or  odor
generation.

     Removal  efficiencies  in carbon  adsorption systems are
affected  by  changes  in  influent flow and  influent chemical
composition.    The presence of  multiple  contaminants  in the
influent  may reduce adsorption efficiency for some  of the
constituents,  although  in  some instances  increased  removal
efficiencies have been noted with multiple contaminants.  For
any  given water to be treated,  the selection  of  the appro-
priate carbon and system design requires laboratory testing
to   determine  the   specific   adsorption  efficiencies  and
interferences for that influent.

     E.8.3  Chemical Precipitation

     Chemical  precipitation,  coagulation,  flocculation,  and
sedimentation are all  interrelated processes which are most
often  used  to  remove  metals  and  certain  organics  from
solution.   For  waters  containing  dissolved  solids,  a pre-
cipitant  is added which reacts with the contaminant to form a
solid, or to  shift solution chemistry in such a way that the
contaminant  solubility is  reduced.   The  precipitated con-
taminant  can then  be removed by  gravity sedimentation  or
mechanical  solids removal processes.    Commonly  used pre-
cipitants  include lime,  caustic,  soda ash, iron  salts, and
phosphate  salts.    Some waters contain  colloidal  suspended
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solids which cannot  be readily  removed using  conventional
sedimentation.   Treatment of  these contaminants, which are
usually organic  in nature,  entails addition of  a  coagulant
(usually  alum,   cuprous sulfate,  or  ferrous  sulfate)  that
forces  the  suspended  solids  to  agglomerate  into  larger
particles,  which can  then  be removed  using  gravity  sedi-
mentation.    Some  facilities  add  polymeric  coagulant  or
precipitation aids, which  have been shown to enhance removal
efficiencies in some cases.  Chemical precipitation processes
can be run as batch or continuous flow operations.  Treatment
efficiencies  depend upon  the  contaminant  type  and  concen-
tration  present,   the   solution   pH  and  temperature,  the
precipitants added, time and degree of mixing,  and  the time
allowed for sedimentation.

     Precipitation  of metals from  solution  can  be  inhibited
by the presence of chelating  agents in the waters,  such as
humic materials  (naturally occuring organic acids)  or other
organic compounds.   This problem can 'be  eliminated  by using
precipitants with stronger affinities  for the  metal  than the
complexion  agent or by using  pH  adjustment to  disrupt the
metal complex.

     Use  of  chemical  precipitation  processes  generates  a
sludge which must  be  disposed of appropriately.    Sludges
containing heavy metals or certain  organics may be considered
to be hazardous wastes and  as such  should be  disposed in
RCRA-regulated facilities.

     E.8.4  Desalination

     Desalination  processes  remove  contaminants  from  the
influent using membranes to separate an enriched stream  (high
contaminant  concentration)  from a  depleted  stream.   Reverse
osmosis and ultrafiltration use  a pressure differential to
drive  the  separation,  while  electrodialysis  depends  on an
electric  field.    The concentrated or enriched  stream fre-
quently requires further treatment, while the depleted stream
is usually potable.  Desalination processes have been used to
purify waters to drinking water quality in certain regions of
the  country  where  fresh  water  is in  short  supply.    The
processes  are  in  more  widespread  use  for  treatment  of
industrial  process waters which  must  be of  extremely high
quality.    Treatment  efficiencies  are  a   function  of  the
molecular size and  concentration of contaminants, strength of
the  separation  driving  force,  membrane type,  and  system
configuration.    Removal  efficiencies  of  greater  than  90
percent have been reported in the literature.
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     Desalination  processes  are  highly sensitive  to  vari-
ability in the influent, and drastic changes  in  pH,  tempera-
ture, or suspended solids.   Any of these factors can effec-
tively reduce  treatment efficiencies  and the membrane life.
The  suspended  solids  in  a desalination  influent should  be
minimized to particle  sizes 10 microns  or  less in  order  to
prevent membrane  fouling.   Biological activity  can  severely
impair  the  process  efficiency,   and  disinfection  may  be
required prior to desalination.  The presence of chlorine may
also disrupt efficient desalination,  dechlorination  or non-
chlorine disinfection processes may be desired.

     Desalination  processes  are  very  expensive and  energy-
intensive.   Because of this, desalination is not  frequently
used for  removal  of contaminants which are  readily removed
via other treatment processes.  However, for  high TDS waters
and  waters  with  large  dissolved  molecules,   these  processes
may provide cost effective contaminant removal.

     E.8.5  Flotation

     Flotation is  used  to  remove  oil  and grease or  suspended
particles  from  the agueous  phase.   The  process  involves
introduction  of  a  gas  (usually  air)  into  solution,  and
subsequent  attachment  of  the gas. bubbles  to  particulate
matter  which  then  floats to  the  surface.    The  floating
particulates  can  be  skimmed  and  removed  for  disposal  or
farther  treatment.    Surfactants  and  pH-modifications  are
often used to improve process performance.   Flotation is used
in many public water utilities across  the nation for removal
of organic  matter from surface waters,  but the most common
use of the process is  removal  of  oils  and grease from indus-
trial  petroleum  wastewaters.    Removal efficiencies are  a
function of concentration,  size,  mass  of contaminant partic-
les,  air loading rate,  types of  chemical  additives used,
hydraulic loading  rate, and  skimmer design.   Removal effici-
encies over 95 percent have  been  reported in the literature.

     Flotation is effective for  contaminants with  densities
less  than  or  near to that  of  water,  but  is  relatively
ineffective for contaminants which are denser than water.  It
is not  particularly effective at  removing dissolved contam-
inants, although chemical additives can be used to decrease
contaminant solubility.  If volatile contaminants are present
in the  influent,  flotation may result in simultaneous strip-
ping of these contaminants from solution.
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     E.8.6  Granular Media Filtration

     Granular  media filtration  is widely  used to  separate
solids from  aqueous streams.  Water  is fed  (via  gravity or
applied pressure) through a  bed  of granular media, which may
consist of sand, gravel, coke, or  combinations of  the three.
Periodically the filter is  "backwashed,"  which removes the
filtered particles  into a relatively small  volume of waste-
water which  must be disposed  or treated further.   Granular
media filtration is commonly used  in  water  utilities follow-
ing chemical precipitation to  ensure  turbidity standards are
met.  Filtration performance depends upon  the solubility of
the  contaminants,  the  strength  and  size  of  contaminant
particles, the type of granular  media used,  the hydraulic
loading rate, and the interval between backwashings.  Removal
to suspended solid  levels less than 10  mg/1 has been report-
ed.

     E.8.7  Ion Exchange

     Ion exchange processes, like  carbon adsorption, operate
by removing contaminants  from  solution  onto a receptor.  The
ion exchange process  uses a chemically reactive resin which
exchanges  innocuous ions for  the  contaminant  ions  in solu-
tion.  The reaction is reversible,  which allows a  facility to
regenerate  the  ion    exchange  resin  and  reuse   it.    Ion
exchange processes  are most commonly used  to generate high
quality industrial  processes waters,  but recent applications
have  also included wastewater  treatment  and  ion  exchange
water softening to remove  hardness  in drinking  water sup-
plies.   Ion  exchange can be used  for  removal of  almost any
ion  from solution,  but is  not  very effective  for removing
uncharged  contaminant  species.  Removal  efficiencies, which
have been  reported  in excess  of 99.9 percent, are dependent
upon  the  ionic  charge  of  the  contaminants,   contaminant
concentration,  type of  resin  used,  hydraulic  loading,  and
interval between resin regeneration.

     Although  almost  any  ionic contaminant can  be removed
using  ion  exchange processes,  the  specific  ion  exchange
resins used are  usually specific to certain types  of contam-
inants.   Resin selectivity is based on the type  (positive, or
negative)  and  degree  of charge on the  contaminant ions.  If
several  types   of  contaminants  with   varying  charge  are
present,  efficient  ion  exchange   treatment  may  require  a
series of diffrent resins.

     Changes in  pH  or the presence of  organic and inorganic
complexing agents  may  cause certain ionic species  to form
uncharged or differently charged chemical complexes, which in
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turn  can  reduce the  efficiency of  ion exchange  treatment.
These problems are often overcome by adjusting pH so that the
desired ionic species  are present,  or by  pretreating  the
influent to remove complexing agents.   Pretreatment may also
be  required  if  the  influent  to  the  ion  exchange  process
contains excessive suspended solids  which will clog  the bed
or foul the resin.

     E.8.8  Ozonation

     Ozonation is  a  chemical  oxidation process in  which the
influent stream is contacted with  ozone which breaks refrac-
tory  (non-biodegradable)  organic  compounds  into  smaller,
treatable  or  non-toxic  compounds.    Used  alone  or  in con-
junction with ultraviolet radiation,  it is a highly effective
means of treating dilute concentrations of organics.  Because
it  is  an  expensive    process  to  construct  and  operate,
ozonation  is  not  in common use  in  public  water  utilities
across  the   nation.     However,   several   individual  water
treatment systems use ozone rather than chlorine to disinfect
their water supply.   The process  can  achieve both effective
disinfection  and up to  99  percent  removal  of certain organic
compounds.     Ozonation   effectively  removes   pesticides,
chlorinated  hydrocarbons,   alcohols,  chlorinated  aromatics,
and cyanides.

     The efficiency of contaminant removal using ozonation is
dependent upon the retention time of the process reactor, the
ozone dose rate,  the ultraviolet light  dose rate,  and the
contaminant  type  and  loading.    Treatability  studies  are
required  prior  to installation  of  ozonation processes  to
treat specific influent streams.

     Ozonation is  currently used by only a  few public water
supply  systems,  primarily  as a disinfection  process.   It is
an  expensive process  which  is  readily  replaceable  with
chlorination  for  disinfection,  but which  has been gaining
acceptance  for use in public water supply systems because it
does not cause any by-product trihalomethane formation.  Lack
of use  of  ozonation  in  public  water supply treatment systems
may be  due to economic constraints and limited need for the
technology.

     E.8.9  Disinfection and Fluoridation

     Two  water  treatment  processes which   are  universally
available   are  chlorine   disinfection  and  fluoridation.
Chlorine  disinfection  is  the  most commonly  used  means  of
destroying  bacteria  in public water  supplies.   Fluoridation
of water  supplies  is  used  to prevent dental health problems.
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The processes  do  not remove chemical  contamination  from the
wastestream;  they serve  instead as  preventive measures  in
control of disease and maintenance of public health.

E.9  Source  of  Information  on  Ecologically  Vital  Ground
     Waters

     Tables E-2, E-3, and E-4 provide a list of U.S.  Fish and
Wildlife and  State Heritage Program representatives  who may
be  contacted  to  obtain  information  on  the  location  of
potential unique habitats when classifying ecologically-vital
ground waters.

E.10 Radius of Classification Review Area

     The EPA classification  system  utilizes a Classification
Review Area with  a radius of two miles  from  the boundary of
the facility or activity.  The radius is intended to be large
enough to  identify wells and  surface waters which  are high
interconnected  with ground  water under  the  facility.   The
following  sources  of  information  were  examinaed  in  the
selection of this radius:

        A  survey  of  existing  contaminant  plumes  documented
        through  investigations  of   spills,   leaks  and  dis-
        charges

        A  survey  of  the distances  to  downgradient  surface
        waters from hazardous-waste facilities; and

        Calculations  of  the  distances   from which  pumping
        wells draw ground water under different hydrogeologic
        settings.

These sources are described below.

Plume Survey

     A survey of contaminant plume geometries, (i.e., length,
width and depth) was prepared in connection with the develop-
ment  of  a  stochastic model  of  corrective  action  costs  at
hazardous-waste management  facilities  (Geraghty  &  Miller,
Inc., 1984).   The plume  survey provides generalized informa-
tion on the distances contaminants have been known to migrate
regardless  of time,  source type or  hydrogeologic  setting.
This was  viewed as  an  indication of  the area which  may be
affected if contaminants  were  accidentally released from the
site.
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                                TABLE  E-2
             LIST OF OFFICES OF ENDANGERED SPECIES
                U.S.  FISH AND WILDLIFE SERVICES
The  Fish  and Wildlife  Service,  a unit  of the  U.S.  Department  of  Che
Interior,  has been delegated  the  main  responsibility  for coordinating
national and international efforts on behalf of  Endangered Species.

In  the  ease of  marine  species,  however, actions are taken in cooperation
with  the  Secretary of  Commerce,  through  the  Director  of  the National
Marine  Fisheries  Service                               Similarly,  in  the
area  of import/export  enforcement for  Endangered  plants,  Interior coop-
erates  with and  is  assisted  by  the Department' of Agriculture through  the
Animal  and Plant  Health Inspection  Service (Liaison listed on page  7).

PROGRAM MANAGER—ENDANGERED SPECIES—Mr.  Ronald  E.  Lambertson
Associate Director-Federal Assistance
U.S. Pish and Wildlife Service
U.S. Department of the Interior
Washington, D.C.   20240
  Telephone:  202/343-4646

CATEGORY COORDINATOR—ENDANGERED  SPECIES—Mr. Roman Koenings
Deputy Associate  Director—Federal Assistance
U.S. Fish and Wildlife Service
U.S. Department of the Interior
Washington, D.C.   20240
  Telephone:  202/343-4646
Mr. John M. Murphy, Chief
Office of Program Development
  and Administration
U.S. Plan and Wildlife Service
1000 North Glebe Road, Room 629
Arlington, Virginia
  Telephone:  703/235-1726, 7, 8

Mr. John L. Spinlcs, Jr. Chief
Office of Endangered Species
U.S. Fish and Wildlife Service
1000 North Glebe Road, Suite 500
Arlington, Virginia
  Telephone:  703/235-2771, 2
Mailing Address for Office of_ Progr.-
  Development and Administration

U.S. Pish and Wildlife Service
Washington, D.C.  20240
Mailing Address for Offlee .of
  Endangered Species

U.S. Pish and Wildlife Service
Washington, D.C.  20240
     Dr. Kenneth R. Russell, Chief, Branch of Biological  Support
       Telephone:  703/235-1975, 6, 7

     Mr. Brian Cole, Chief, Branch of Management  Operations
       Telephone:  703/235-2760, 1, 2
                                  E-26

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Chief
Federal Wildlife Permit Office
U.S. Fish and Wildlife Service
1000 North Glebe Road, Suite 600
Arlington, Virginia
  Telephone:  703/235-1937, 8, 9

Mr. Clark Bavin, Chief
Division of Lav Enforcement
U.S. Fish and Wildlife Service
1735 K Street, NW., 3rd Floor
Washington, D.C.
  Telephone:  202/343-9242
Mailing Address for Federal
  Wildlife Permit Office

U.S. Fish and Wildlife Service
Washington,  O.C.  20240
Mailing Address for Division
  of Lav Enforcement
P.O. Box 28006
Washington, D.C.
20005
     Mr. Thomas Striegler, Special-Agent-in-Charge, Branch of Investigations
       Telephone:  202/343-9242
Dr. Richard L. Jachowski, Chief
Office of the Scientific Authority
U.S. Fish and Wildlife Service
1717 H Street, NW., Room 536
Washington, D.C.
  Telephone:  202/653-5948, 49. 50
Mailing Address for Office of
  the Scientific Authority

U.S. Fish and Wildlife Service
Washington, D.C.  20240
Regional Endangered Species Coordinators:

The U.S. Fish  and Wildlife Service is comprised of seven Regional Offices.
(See map on  inside  back cover for geographic boundaries.)  Each office has
a senior official who has been designated as a Regional Endangered Species
Coordinator.   Additionally, each  of  the regions has several Field Offices.
Problems of a local nature should be referred to these offices.
Region 1  Regional Director  (Attention:  Mr. Sanford R. Wilbur
          Endangered Species Specialist)
          U.S. Fish and Wildlife Service
          Suite 1692, Lloyd 500 Building
          500 NE. Multnomah Street
          Portland, Oregon  97232
            Telephone:  503/231-6131   (FTS:  8/429-6131)

Field Offices

          California
          1230 "N" Street, 14th Floor
          Sacramento, California  95814
            Telephone:  916/440-2791   (FTS:  8/448-2791)

          Idaho
          4696 Overland Road, Room 566
          Boise,  Idaho  83705
            Telephone:  208/334-1806   (FTS:  8/554-1806)
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          Nevada
          Great Basin Complex
          4600 Kletzke Lane, Building C
          Reno, Nevada  89502
            Telephone:  702/784-5227   (FTS:   8/470-5227 or 5228)

          Washington/Oregon
          Buildtng-3, 2625 Parkmont Lane
          Olympia, Washington  98502
            Telephone:  206/753-9444   (FTS:   8/434-9444)

          Pacific Islands Administrator
          300 Ala Moana Boulevard, Room 5302
          P.O. Box 50167
          Honolulu, Hawaii  96850
            Telephone:  808/546-5608   (FTS:   8/546-5608)
Region 2  Regional Director  (Attention:   Mr.  James Johnson
          Endangered Species Specialist)
          U.S. Fish and Wildlife Service
          500 Gold Avenue, SW.
          P.O. Box 1306
          Albuquerque, New Mexico  67103
            Telephone:  505/766-3972   (FTS:   8/474-3972)

Field Offices

          Arizona
          2934 West Fairaont Avenue
          Phoenix, Arizona  85017
            Telephone:  602/241-2493   (FTS:   8/261-2493)

          New Mexico
          P.O. Box 4487
          Albuquerque, New Mexico  87196
            Telephone:  505/766-3966   (FTS:   8/474-3966)

          Oklahoma/Texas
          222 South Houston, Suite A
          Tulsa, Oklahoma  74127
            Telephone:  918/581-7458   (FTS:   8/736-7458)

          Texas
          c/o CCSU, Box 338
          6300 Ocean Drive
          Corpus Christi, Texas  78411
            Telephone:  512/838-3346   (FTS:   8/734-3346)
          Fritz Lanham Building, Room 9A33
          819 Taylor Street
          Fort Worth, Texas  76102
            Telephone:  817/334-2961   (FTS:  8/334-2961)
                                 E-28

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Region 3  Regional Director  (Attention:  Mr. Janet M. Engcl
          Eadaogered Species Specialist)
          U.S. Pish and Wildlife Service
          Federal Building, Fort Snelling
          Twin Cities, Minnesota  55111
            Telephone:  612/725-327.6   (FTS:   8/725-3276)
Region 4  Regional Director  (Attention:  Mr. Alex B. Montgomery
          Endangered Species Specialist)
          U.S. Fish and Wildlife Service
          The Richard B. Russell Federal Building
          75 Spring Street, SW.
          Atlanta, Georgia  30303
            Telephone:  404/221-3583   (FTS:  8/242-3583)

Field Offices

          Alabama/Arkansas/Louisiana/Mississippi
          Jackson Mall Office Center
          300 Woodrow Wilson Avenue, Suite 3185
          Jackson, Mississippi  39213
            Telephone:  601/960-4900   (FTS:  8/490-4900)

          Florida/Georgia
          2747 Art Museua Drive
          Jacksonville, Florida  32207
            Telephone:  904/791-2580
(FTS:   8/946-2580)
          Kentucky/North Carolina/South Carolina/Tennessee
          Plateau Building, Room A-5
          50 South French Broad Avenue
          Asheville, North Carolina  28801
            Telephone:  704/258-2850 ext. 382   (FTS:   8/672-0321)

          Puerto Rico/Virgin Islands
          P.O. Box 3005
          Marina Station
          Mayaguez, Puerto Rico  00709
            Telephone:  809/833-5760   (FTS:  8/967-1221)
Region 5  Regional Director  (Attention:  Mr.  Paul Nickersoa
         ' Endangered Species Specialist)
          U.S. Fish and Wildlife Service
          Suite 700, One Gateway Center
          Newton Corner, Massachusetts  02158
            Telephone:  617/965-5100 ext. 316   (FTS:   8/829-9316,  7,  8)
                                   E-29

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Field Offices
          Coanecticut/Maine/Vermont/Massachusetts
            New Haapshire/Rhode Island
          P.O. Box 1518
          Concord, New Hampshire  03301
            Telephone:  603/224-9558, 9   (FTS:  8/834-4726)

          District of Columbta/Delavare/Maryland
            Virginia/West Virginia
          1825 Virginia Street
          Annapolis, Maryland  21401
            Telephone:  301/269-6324   (PTS:  8/922-4197)
          Neu Jersey/Pennsylvania
          112 West Foster Avenue
          State College, Pennsylvania
            Telephone:  814/234-4090

          Nev York
          100 Grange Place
          Cortland, New York.-  13045
            Telephone:  607/753-9334
16801
(FTS:
8/727-4621)
(FTS:   8/882-4246)
Region 6  Regional Director  (Attention:  Mr.  Don Rodgers
          Endangered Species Specialist)
          U.S. Fish and Wildlife Service
          P.O. Box 25486, Denver Federal Center
          Denver, Colorado  80225
            Telephone:  303/234-2496   (FTS:  8/234-2496)

Field Offices

          Colorado/Utah
          Room 1406, Federal Building
          125 S.  State Street
          Salt Lake City, Utah  84138
            Telephone:  801/524-4430   (FTS:  8/588-4430)

          Kansas/Nebraaka/North Dakota/South Dakota
          223 Federal Building
          P.O. Box 250
          Pierre, South Dakota  57501
            Telephone:  605/224-8692   (FTS:  8/782-5226)
          Montana/Wyoming
          Federal Building, Rooa 3035
          316 North 26th Street
          Billings, Montana  59101
            Telephone:  406/657-6059 or 6062
        (FTS:   8/657-6059)
                                  E-30

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Regional Director  (Attention:  Mr. Dennis Money
Endangered Species Specialist)
1011 E. Tudor Road
Anchorage, Alaska  99503
  Telephone:  907/786-3*35   (FTS:  8/907/786-3435)
                          E-31

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                                                       TABLE  E-3
               LIST OF STATE  NATURAL  HERITAGE  PROGRAM  OFFICES
                                                October 1985
Nongama Branch
ARIZONA HERITAGE PROGRAM
Arizona Game t Fun Department
2222 W. Groen.ay Rd.
Phoeni.. AZ 85023
602/943-3000 .245
  •ranch Supervieori Terry  Johnaon
  ZoologUti Dick Todfl
  Zootogiets Cecil Schmlbo
  Zoologiat: JIB Brooks
  0*» Manager i Rich Si I nek I
  Habitat Spec. i truce Palmer
  Wildlife RetiM: Cindy Oorathy

ARKANSAS NATURAL HERITAGE INVENTORY
225 E. Merkhem. Suit* 200
Licctt Rack. AR 72201
501/371-1706
  Coordinator/Zoologist:  Ken  Smitn
  Ecalogist: To* Fott
  Botanist: Sttvt Orzetl
  Out Manager: Cindy Osbcrne

CALIFORNIA NATURAL DIVERSITY  DATABASE
e/o CA Oept. of Fish 1 Geme
1416 9th Strict
Sacramento, CA 35814
916/322-24S3
  Section Leader: Steve Nicola
  Prog. Menager/Ecol: Debcran Jensen
  Zoologist: Larry Eng
  Res.Asst/Zooi : Carrie Shaw
  Aouatic EcoL: John Ellison
  EcoLogist: Bob Holland
  Botanut: Jin Shevock
  Ait:. Botanist: Cindy Roy
  Data Handler: Sylvia Gude
  Element Prea.Plen: Roianne  Btttxen
  End. Plants Coord: Susan Cocnrane
  SNAP Coordinator: Chris Unkei

CCL3RADO NATUBAL HERITAGE INVENTORY
Cape, of Natural Resources
1313 Sharpen St.. An. 718
Cenver, CO  80203
303/865-3311
  Botanist: Steve O'Kane
  Ecoi: Susan Gelstc»itsc-
        203/660-3142

CONNECTICUT NATURAL OIVE'SIT" 3ATA64SE
Natural Resources  Center
Oept.  of Environmental P'ctaction
Staca  Or.rice  Building, An. 553
165 Capital Avenue
Hartford,  CT  06106
203/566-3540
  Biologiat/Oata  Man:  Nancy Hurray
  Ecologist:  Kan  Hatzlar
  Date  Handler:  Megan  Rollins
 FLORICA  NAFja^L AflWS INVENTCRY
 2£A E. 6tn  Avenue
 TaUanassee,  '. :'3C3
 904/224-e207
   Coordinator: Stave Gate»ood
   Zoologist:  Oala Jackson
   Botanist: Dennis Hirdin
   Ras.Scac/Oata Manager: Jt« Huller
   Secretary:  Judith Lyons
•HAHAII HERITAGE
 111S SatUH St.. HOI
 Honolulu, HI B6B17
 BOB/S37-4S08
   Director: Audrey Na»nan

 IDAHO NATURAL HERITAGE PROGRAM
 4696 Ovaritnd Rd., Suite 518
 Bofaa, 10  83705
 201/334-3402 or 3648
   Coord1nator/Zool: Craig Orovea
   totanlst/Ecologist: Steve Caicco
   Data handlar/Bloli Pa> Peterson

 INDIANA HERITAGE PROGRAM
 Oiv. of Nature Presarvaa, IN ONR
 612 Stata Offtea lldg.
 Indianapolis, IN 46204
 317/232-4078
   Coordmator/Bot: Jia Aldricn
   Ecologist: Nika Honoya
   Plant Ecologist: To» Post
   Zoolo'gist: Brian Abrall

 IOWA NATURAL AREAS INVENTORY
 Stata Conservetion Coamission
 Wallace State Office Bldg.
 Oes Homes,- IA 50319
 515/2B1-35J4
   Ecologist: John Pearson
   Data Handler; John Fieckenstein
   Zoologtat: Oaryl Howe11
   Botanut: Mark Laoacnke

 KENTUCKY HERITAGE PROGRAM
 ICY Neture Preserves Commission
 407 Broedney
 Frankfort, KY 40601
 5C2/;oi-ZS66
   Director: Richard Hannan
   Botanist: Marc Evans
   Zcoiogist: Ranald Cicarello
   Ornithol: Brainard Paimei—3eil
   Aquetic BIOL: Bill Fisher
   Secretary: Julie Smitner

 LOUISIANA NATURAL HERITAGE PROGRAM
 Oeoartment of Neturai Resources
 Coestal Management Division
 P.O. Boi 44124
 Batcn Pouge, LA 708C4-4124
 50V342-460S
   Coordinator/Ecol: Nancy Jo Craig
   Zoologist: uary Laster
   Botanist: Annette Perner
   Data Manager: Alenea Williams

• MAINE NATURAL HERITAGE PROGRAN
 Maine Chapter
 •22 Main Street
 Toosram, ME  04C86
 207/729-51S1
   Coorctnator: Jonn Albright
   Data Menager/Sct: ^i Oste'DrccK

 MARYLAND NATURAL HERITAGE &
    ENVIRONMENTAL REVIEW
 Ceot. of Natural Resources
 C-3, Taves Stata Office Bldg.
 Annapolis, MD 21401
 js^-ucj .:s;= D.C.DIRECT DIAL
 ;C1/265-3655
   Coor3'natcr/Bot: Dan Boone
   Envi ronmentsv-|So%5 : Arrc^C ^crsan
   Man. Area Soft: Sist* Ricneri;^
' MODEL NATURAL HERITAGE PROGRAM
 The Nature Conservancy
 1800 N. Kant St.,  Suite BOO
 Arunaton, VA  22209
 703/841-5307
   Zoologist: David WHcove
   Botanist: Mary Paimr
   Ecologist: being hired

 MASSACHUSETTS HERITAGE PROGRAM
 Oiv. of Fiahenea  t Wildlife
 100 Cartridge St.
 Boeton, KA 02202
 617/727-9194
   Coordineur/Ecolt Henry Woo I say
   Botanfati (nice  Some
   Zooiogieti Scott Kelvin
   Data Manegar: Joanna Tribbla
   Heb.Prat.Spec: Annie Marlowe

 MICHIGAN NATURAL FEATURES  INVENTORY
 Mason Building. 5th  floor
 Boi 30028
 Laneing, MI 48909
 517/373-1552
   Coordmator/Bot: Sue Crispin
   Ecologtst: KIB Chapman
   Zoologist: Lam  Wilsmern
   Data Manager: S:u Ouxinga

 MINNESOTA NATURAL  HERITAGE  PROGRAM
 Department of Natural Resources
 Bo 6
 St. Paul, MN  55155
 612/296-4284
   Coordinator: Baroara Coffin
   Botanist: Welby  Smith
   Ecologist: Kattn wendt
   Zoologist: Lee Pfannmuller
   Data Manager: Carman Converse

 MISSISSIPPI NATURAL  HERITAGE PROGRAM
 111 H. Jefferson St.
 Jecpison, J« 39202
 601/354-7226
   Coord/Bot/Wild.Bio:  Kan  Goreon
   Zoologist: Boo Jones
   E:oiogist: Jim Wiseman

 MISSOURI  NATURAL HERITAGE  INVEWTCRY
 Missouri  Deot. Of  Conservation
 P.O. 3oi  180
 Jefferson City. MO 65102
 314/751-4115
   Coordinator: Mike  S«eet
   Biologist: Dennis  Fi^y-XSIO
   Secretary: Diana Munstarman

 MONTANA NATURAL HERITAGE  PROGRAM
 State  Library Building
 1515 E. 6tn Ave.
 Helena, MT 59620
 406/444-3C09
   Coordinator/?ool:  David  Center
   Botanist: Steve  Sneuy
   Ecologiat: Nancy Grulke
   Data Teen/Sec: Lisa Shepperd

 NAVAJO NATURAL HERITAGE  PROGRAM
 Bo< 2429
 »mec« =sc«. AZ S6S15-!i2S
 oC2^-a;i-S^3  jr 9-U9
   Acting  Coord/Botanist:  Oonne  House
   Data Maneger: Virju  Link
   Zoologist:  vacant
(*  = Proto-Heritage  Programs)
                                                        E-32

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NEVADA NATURAL HERITAGE PROGRAM
Dept. of Coneervetlon I Neturel
  Resources
e/o Oiy. of State Perfce
Capital Complej, Nye Bldg,
201 S. Fell Sc.
Careon City, NV 89710
702/885-1360
  Coordinator/tel.i be me. hired
  Research tel.: being hired

NEW HAMPSHIRE NATURAL HERITAGE PROGRAM
e/o Society for the Protection of N.H.
  Forests
54 Portsmouth Street
Concord, KM  03301
603/224-9945
  Coordinator/Bat: Frances Breckley
  Oeta Manager: Edit Hentcy

NEW JERSEY NATURAL HERITAGE PROGRAM
Offica of Natural Lands Nanaganant
109 w. Stece St.
Trenton, HJ 08625
609/984-1339 or 1170
  Coordinator/Ecol: Thomas Bradan
  Botanist: David Snydar
  Zoologist: Jin Scaiscie
  Data Hanagar: Jane Sans
  Oats Handler: Elena Williams

NEK MEXICO NATURAL RESOURCES
  SURVEY SECTION
ViUagra Bldg.
Santa ft, MH 87503
505/B27-7862
  Coordinator: Cathy Carrutners
  Botanist: Paul Kmgnt-7850
  Botanist: Anna Cully
  Data Handler: Leslie Price
  Hgmt. Analyst:. Denise Gross

NEW YCRK NATURAL HEFITAGE PHCGRAH
Wildlife Raaourccs Canter
Oeimer. NY  120S4-S767
£18/439-8014 ,203
  Coordinetor/Zool: Pat Hehlhoo
  Ecologist: Carol Rescnke
  Botanist: Stava Clements
  Data Henejer: flacnal Pleujr.ner
  L.I. Botanist: Bob Zare^ca
                 367-3225

NORTH C1SOLINA NATURAL ME9ITAGE
Dipt, cf Natural & cccnor-c PCS.
Oiw. of Stata Parks
Bo> 276B7
Ralaign, NC 27611
919/733-7795
  Coordinator: Charlas E. Boa
  Botanist: Laura Hanabarg
  Ecologiatt Alan Haamay
  Procaction Spac: Julia H. Moora
  Wttlancs  Inv.Pas.Soac:  Stevtn Lacnar^
  Zoologist: Harry Laurand, Jr.
  Inv.  Info. Spac: Miki Scnafaia

NORTH DAKOTA NATURAL HERITAGE  INVENTORY
N.O. Gana & Fish Dapartnant
100 N. Bisaiarck Eiprassusy
Bismarck, NO SBS01
701/221-S310
  tjcrc Tracer/2cci:  3ar£, ser
  Zoologist: Cnns Reitnei

SOUTV CAROLINA HEPITAGE TRUST
S.C. KUdl.l Marine Ratourcel Oept.
P.O. Bo> 167
Coluaeia. SC 29202
803/756-0014
  Coord/Zeol: Stave Bennett
  Fi*n t wual.Bio: Jono Caly
  Envir.Planner: S:u Gree:er
  Botanist: Doug Reynar
  Ecolojisti John Nelson
  Ft* Bie/Preserva Mc,r: Jtm Sorro.
  Secretary! Keye DieL Oenieia

SOUTH DAKOTA NATURAL MEPITAGE
S.O. Oaot.  cf Same* F>sn i Psrks
3iv. af =sr,rs i 'ec.-eation
Sigurs Arcerscn dLC£.,  3-114
Pierre,  SO  S7£01
605/773-4226
  Botanist: David Or
  Data Soec: Ge£jT._^aei
 (TBeNEBSEE HERITAGE PROGDAM)
 ECOLOGICAL SERVICES DIVISION
 TN Oepertaiefit of Coneervetton
 701 Broadcay
 NeahvUle, TN 37203
 BlS/74a-6545
   01 rector i Oen Eager
   Zaolagiet: Pent Meawl
   Plent Ecol/Prot.Plani Larry Seilth
   Belenlati Pwi (eejere
   •Ue-llfe te*U Oeryl  Durhw
   Beta Beee Menegeri Dave Snupe
   Aq.Bio/Pro.Rev.Coon  Rooerte Hylton

 TEXAS NATURAL HERITAGE  PROGRAM
 General Lend Offica
 Stephen F. Austin Bldg.
 Austin, TX  78701
 512/475-0660, 0661, 0621, OBOp
   Aast.Deputy Commissioner/
     Lend Hgmt.Oivi Ben  Brown
              512/475-1539
   Coordinator: Tine Bondy
   Zoologist! Rei Mahl
   Ecologist: David Diamond
   Botanist: Jackie Poole
   Data Manager; Robert  Murpny
   Secretary! Jackie Solit

 TVA REGIONAL HERITAGE
 Office of Natural Resources
 Norns. TN 3782B
 615/494-9600
   Coord inetor: Dull am H. Redennd-X2613
   Project Meneger: J. Ralpn Jordan
   6otaniat: Josspn L. Collins
   Net.Araea Coord: Judith 6.  Po«ars
   Zoologist: Cheries P. Mivho^sor.

*VEFHCNT NATURAL HERITAGE PROGRAM
 Vemont Field Office
 138 Main Street
 Hontoolier. VT 05602
 B02/229-4425
   Coordinator: Marc OesHeu.les
   Ecologist/Oata Man:  Lu Thompson

 WASHINGTON NATURAL HERITAGE PRCGRAM
 Department cf Natural  Resources
 Hail Stop EX-13
 Olympia, WA 36504
 2C6/753-244B
   Coordinator/Bot: Merit Shaeran
   Ecologist: Ltnea Kunze
   Plant Ecoicgist: Reid ScnuUer
   Secretary: Charlotte Neison
   Habitat Preserv.Soec: Batty  Rodeneit

 VEST VIRGINIA WILDLIFE/HERITAGE
   DATABASE
 Wildlife Resources Division
 ONR Cperations Center
 P.O. Box 67
 Elkins, WV 2E2>1
 304/636-1767
   Aest. Director! Pete Zurcuc.i
   Coordinator/Ecol: Brian McDonald
   Data Handler: Sandra Hahringar
   Botanist: Garria Rouse
                                                       E-33

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 WISCONSIN NATURAL HERITAGE PROGRAM
 Endangered Beeourcea/4
 Oapt. of Natural Reaourcoa
 101 S. Woeetor St.. Bo* 7311
 Nodi eon, *1 53707
 SO8/266-0924
   Zoolognci IUI Seittn
   Ecologiet: Erie Epstain
   Botanleti Juno DoMorpuni
   Doto Nonogori Kothy Sleeer

 •VONIN8 NATURAL HERITAGE PROGRAM
 1603 Cap Ho I Avenue.  Rei.323
 Cheyenne, Iff 82001
 303/860-8142
   CooroVBotanfeti voeont
 too Jonkino.  Vieo President, Sennet    (41-5320
 Mjrfly  Wtoting.  Oireetsr,  Horitogo        (41-1339
 Sh»U«y  Rodoion, AttitttnC Oiroctor, HFA  841-S3S7
 tat Oifploy.  Director.  PStO              1X1-5322
 Jung jo  An, Budgit Spoeiolut            M1-53S8
 Jack Whitt, Notionol  Eealogitt       217/3(7-8770
 Ooretny  AUord. Claisificocion  Ecol. 217/3(7-8770
 Larry  Morta,  Oirictor,  Mac'I Oataboat    (41-53(1
 Mary Broanon, Nat'I OataOaaaa Aatociata  (41-53(0
 Hargarat Oraoa. National  Info.Man.       (41-53(0
 Oavi Honiman, Mierocomoutar Analyt:      (41-53S5
 Btrnadatta Scn.ot.fio,  Mieroeaniaucar
                        Spaciauat        841-5355
 Kan  Mrignt, Sanior Programar/Anai.      i<1-53Si
 Carol  Hodga. Admmiatrativa Actc.. HFA   (41-<3
-------
                                   TABLE E-4
                   LIST OF ADDITIONAL REFERENCES
50 CFR 17.11 and 17.12,  Endangered and Threatened Wildlife and Plants, January
    1, 1986.

U.S. Fish, and Wildlife Service,  Contaminant  Issues of Concern - National
    Wildlife Refuges.  January 1986.

Guidance on Ground Water Classification:  Approach to Completing Follow-up
    Research, January  1985,  prepared  by GCA  Corporation for the U.S.
    Environmental Protection Agency - Land Disposal Branch, Washington, B.C.,
    Contract No. 68-01-6871.

40 CFR 270.3(c), EPA Administered Permit  Programs:  The Hazardous Waste Permit
    Program.

Guidance on Remedial Investigations Under CERCLA, Chapter 9, EPA/540/G-85/002,
    June 1985.

Guidance on Feasibility Studies  Under CERCLA.  Chapter 6, EPA/540/G-85/003,
    June 1985.
                                 E-35

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     The  data  base  for  the  survey  included  ground-water
quality   investigations,   consultant   reports,   and   other
publically-available literature  (e.g.,  scientific journals).
The  availability of  data was  limited  by the  confidential
nature of many  privately-funded  contamination investigations
and  the  relatively small number of off-site investigations
conducted by  the government prior  to  the  implementation of
the Superfund program.

     The  survey  found   50  contaminant  plumes  containing
inorganic  and  organic  contaminants.     Hydrocarbon  plumes
consisted  of   dissolved   and  liquid   phase  (undissolved)
materials.  The  sources of the plumes were spills,  leaks and
discharges  from  diverse  sources  including  municipal  and
industrial  sites,   transportation   accidents   and  unknown
sources.   Plume boundaries  were  defined as  a  detectable
increase above background quality.

     The survey  showed that the median  plume  length was 1600
feet.  Ninety-five per cent of the  plumes were less than two
miles in length.  A histogram of plume lengths is provided in
Figure E-l.

     The  data  were too  limited to determine  whether  the
plumes  in this  survey had  reached their maximum lengths.
Theoretically,  if  a contamination  source is  continuous and
the  contaminant  is  not degraded,  transformed, or immobilized
in route,  the plume length will  eventually be  equal  to the
distance  to  a downgradient discharge  point.    Other factors
which  could  prevent  plumes   from  reaching  their  naural
discharge points include  insufficient time since the contam-
inant release and the implementation of an effective remedial
program.   In some  cases a  steady-state  condition may be
reached between  contaminant input by the source and dilution
due  to recharge.  While it is now known whether the plumes in
this survey had  reached equilibrium, it is not likely due to
their random  selection that any  one of  the above factors had
any  unusual degree of influence on the results.

Distance to Downgradient Surface Waters

     ICF,  Inc., conducted  a survey of  117  hazardous-waste
management  facilities  for  development  of  the EPA  Liner/
Location  Model   (U.S. EPA, 1985).   For  each  site,  the down-
gradient  distance  to surface  waters (e.g.,  lakes, streams,
ocean, bay or marsh).  This information provides  insight  into
the  distance at  which a flow boundary for the shallow ground-
water system  is  likely to be  encountered.  Thus, limited the
area potentially impacted by a facility.
                           E-36

-------
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-------
     Some of  the facilities int he  survey were  included  in
EPA's  "site  visit"  facility  survey.     Other  sites  were
selected  from among available  Part  B Permits.   A  site  was
included  in  the  survey only  if  it  provided  information
sufficient  to   operate  the   liner/location   model  (e.g.,
comprehensive  facility  design  parameters and  hydrogeologic
information).     Facility  sites  were  located  on  U.S.G.S.
topographic maps using  latitude and  longitude  data.    G&M
assisted ICF by  identifying the general  direction of ground-
water flow  from  the site on the topo map.  Figure E-2 shows
the  frequency distribution histogram for distance  to  down-
gradient  surface  waters.    Ninety-five  percent  of  these
distances are less than two miles.

Pumping Well Capture Zones

     One of the  criteria for establishing the  radius  of the
Classification  Review  Area  was  to   identify  highly  inter-
connected  ground-water   resources.    One  test  of  intercon-
nection is the capture of ground water by a pumping well.  It
is presumed that all of the area supplying water to a pumping
well should be placed in one classification.

     All ground water within a flow system between a well and
the  upgradient  ground-water  divide  may  be  assumed  to  be
potentially  flowing  into  the  well.    In  addition,  wells
reverse  ground-water  flow and capture   ground  water  from
downgradient   locations  as  well  as   "lateral"  locations
(perpendicular to the regional  flow direction,  see Figure E-
3) .   Thus,  the  well  capture  zone extends in  all directions
from  the  well.     To  determine  whether  a  facility  to  be
classified  may  fall within  a well  capture  zone  it  is,
therefore, necessary to perform an inventory of wells in all
directions  from  the site, not  just in a downgradient direc-
tion.

     Site-specific  data would be required to  establish with
confidence  whether a well is  drawing ground  water  from  a
site.   Optimally,  pumping test results  and  accurate water
table data should  be obtained.   In many cases calculations
would need to be  supplemented  by modelling to estimate the
area with accuracy.  Such data might be used in subdividing a
classification review area; however,  the initial area must be
large enough  to  identify all wells to be evaluated.

     To  determine whether  the  two-mile  radius  would satis-
factorily  identify water-supply wells  capturing  water from
under a  site  (a  formula developed  by Todd, 1976)  was used to
determine  the generalized  dimensions  of  well  capture zones
under  different hydrogeologic conditions.    The  formula,
                           E-38

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-------
illustrated  in  Exhibit E-5,  provides  a  calculation of  the
maximum  downgradient extent  of well  capture  (XL)  and  the
lateral  distance  (YL)  (perpendicular to  non-pumping ground-
water  flow  gradients).    Lateral  and  downgradient  capture
distances were calculated for a range of transmissivities and
water-table  gradients  under pumping conditions of  .5 to 3.0
mgd.  Incompatable well yields  and transmissivities were not
used.  Table E-5 shows the results of the calculations.

     The well  yields were  selected to represent  the  common
range  of pumping  rates  for  water  supply  wells  (U.S.  Geo-
logical  Survey,  1984).   With  the  exceptions noted  below,
water-supply wells  are generally  smaller than  2  mgd.    The
largest  lateral  capture  distance  for  a 2.0 mgd  supply well
for the transmissivities and gradients examined is two miles.
Thus,  the  two-mile  radius  would  identify  the majority  of
individual water-supply  wells which could be  drawing  water
from under  a proposed facility  or site  in  directions  other
than the downgradient direction.

     NOTE:    Exceptions  include  the basalt  aquifers of  the
     Columbia Plateau and Hawaii, where common well sizes are
     up  to  4 mgd  and  some may  exceed  18 mgd;  the Floridan
     Aquifer in  Florida  and Georgia where common  yields are
     up  to  7  mgd  and may  exceep  28  mgd;  and  the  Chicot
     aquifer of the Lake Charles formation in Louisiana where
     common yields up to 3.5 mgd are found.  Other regionally
     extensive high-yielding  aquifers where  wells  may exceed
     2 mgd  include the Texas Edwards aquifer,  thick members
     of  the  Atlantic and Gulf  Coastal Plains,  alluvium and
     older sedimentary basins in  California and  the  Sparta
     Sands in Arkansas.

     In  summary, the plume  survey  and  survey of distances to
discharge  boundaries  support  the  two-mile  radius  in  the
downgradient  direction.     The  plume  data  indicates  that
distance that  contaminants  are  known  to migrate  in problem
concentrations  and  the  distance  to discharge points  data
indicate the likelihood  that a flow boundary will be inder-
cepted.  Pumping well capture distances provide the basis for
including  lateral  and upgradient  areas in the  review  area.
Thus, the two-mile  radius provides an initial identification
of potentially highly  interconnected ground  water related to
a site under classification.
                           E-41

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                            TABLE E-5
    LATERAL AND DOWNGRADIENT WELL CAPTURE DISTANCE  (in feet)
                        (after Todd,  1976)
Transmissivity/Gradient (ft/mi)
10,000/30-50 50,000/10-30 100,000/5-10
.5 MGD
1.0 MGD
2.0 MGD
3.0 MGD
Lateral
Downgradient
Lateral
Downgradient
Lateral
Downgr ad i ent
Lateral
Downgradient
4400-2640
1400-840
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
2640-880
840-280
5280-1760
1680-560
10,560-3520
3360-1120
15,840-5280
5040-1680
2640-1320
840-420
5280-2640
1680-840
10,560-5280
3360-1680
15,840-7920
5040-2520
Governing Equations

Lateral Distance
Downgradient Distance
= ft
= ft
= gpd
- gpd/ft
Q
T
                      YL - Q/2Ti
                      XL = Q/2 Ti
N.A. = Not applicable
                            E-42

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      REFERENCES EVALUATING INSTITUTIONAL CONSTRAINTS OR
                 WATER TREATMENT TECHNOLOGIES

 American Water  Works Association.   Research Foundation  and
      Keuringsinstituut voor Waterleidingartikelen  (Coopera-
      tive  Report).    "Occurrence  and  Removal  of  Volatile
      Organic Chemicals  from  Drinking  Water."   Denver,  CO.
      1983.

 American Water Works Association.   Water  Quality  Treatment.
      Denver, CO.   1971.

 Argo,  D.G.,  "Control  of  Organic Chemical  Contaminants  in
      Drinking Water."   U.S. Environmental Protection  Agency
      Seminar, 1978.

 Argo, D.R., "Use of Lime Clarification and Reverse  Osmosis in
      Water  Reclamation."    Journal Water  Pollution  Control
      Federation 56:1238-1246.   December,  1984.

 Clyde, S.E., "Legal  and Institutional Barriers  to  Transfers
      and Reallocation of Water Resources,"  29   S. Dak.  L.
      Rev. 232 (Spring 1984).

 Clyde, S.E., "State  Prohibitions  on the  Interstate Exporta-
      tion of Scarce Water Resources,"  53 U. Colo. L. Rev.  529
      (1982) .

 Congressional Budget Office, Current Cost-Sharing and Financ-
      ing  Policiesfor   Federal  and  State  Water  Resources
      Development.  Special Study-,  July 1983.

Council of  State Governments,  Interstate Compacts  and Agen-
      cies ,   1983, provides  annual  listing of names  and phone
      numbers  of  commissioners of interstate  compacts  and
      compact  administrators,   and  citations  to  state  and
      Federal legislative enactments of compacts.

 Gulp, R.L., G.M. Wesner, and G.L.  Gulp.  Handbook of Advanced
      Wastewater  Treatment.    2nd  Edition.     Van  Nostrand
      Reinhold,  New York, New York.  1978.

 Environmental Science and  Engineering,  Inc.,  Malcolm Pirnie,
      Inc.   "Fort  Lauderdale   Water   Quality  and   Treatment
      Study."   Prepared  for  the  City  of Fort  Lauderdale,
      Florida.  1981.
                            E-43

-------
Ferguson,  T.L.  "Pollution Control  Technology  for  Pesticide
     Formulators and Packagers."  Prepared  for U.S.  Environ-
     mental Protection Agency, Office  of  Water and Hazardous
     Materials Programs.  January, 1975.  EPA-660/2-74-094.

Glaze, W.H.,  et al.   "Oxidation of Water  Supply Refractory
     Species  by Ozone With  Ultraviolet  Radiation."     U.S.
     Environmental  Protection   Agency.     EPA-570/9-74-020.
     1974.

Gummerman,  R.C.,  R.L.  Culp,  and S.P.  Hansen.   "Estimating
     Water  Treatment Costs.   Volume 1.   Summary."   Prepared
     for  U.S.  Environmental  Protection  Agency  Office  of
     Research  and  Development.    Cincinnati,  OH.    August,
     1972.  EOA-600/2-79-162a.

Hoigne, J., and H.  Bader.   "Ozone Requirements and Oxidation
     Competition  Values  of  Various   Types   of   Water  for
     Oxidation  of  Trace  Impurities."   U.S.  Environmental
     Protection Agency.  EPA-570/9-74-020.   Washington, D.C.
     1979.

Joyce,  M.    "Smyrna,  Delaware  Solves a Water  Problem."
     Journal of Environmental Health 42(2):72-74.   September/
     October 1979.

Kim, N.K.,  and  D.W. Stone.   "Organic  Chemicals and Drinking
     Water."  NYS Department of Health, Albany, N.Y.  1981.

Larson,   C.D.     "Tetrachloroethylene  Leached  from  Lined
     Asbestos Cement Pipe  into Drinking Water."   Journal of
     the  American Water Works  Association.   75(4):184-188.
     April  1983.

Mackison,  F.W., R.S. Stricoff, and  L.J.  Partridge,  Jr., eds.
     "Occupational  Health  Guidelines  for Chemical  Hazards."
     U.S.  Department  of Health  and Human Services  and U.S.
     Department  of Labor.   NIOSH/  OSHA.  Washington, D.C.
     January, 1981.  DHHS  (NIOSH) 81-123.

Malarkey,  A.T.,  W.P.  Lambert, J.W.  Hammond,  and  P.J. Marks.
     "Installation  Restoration  General  Environmental  Tech-
     nology Department.  Final Report.  Task 1.  Solvent and
     Heavy Metals  Removal  from Groundwater."   Roy F. Weston,
     Inc.,  West Chester, PA.   Prepared  for  U.S.  Army Toxic
     and  Hazardous Materials Agency.   January,  1983.
                            E-44

-------
McBride, K.K.   "Decontamination  of  Ground  Water for Volatile
     Organic  Chemicals:    Select Studies  in  New Jersey"  in
     Aquifer Restoration and Ground Water Rehabilitation — A
     Light  at the  End  of  the  Tunnel.   Proceedings  of  2nd
     National  Symposium on Aquifer  Restoration and  Ground
     Water  Monitoring.   David  Nielsen, ed.    Columbus,  OH.
     pp. 105-113.  May 26-28, 1982.

Mccarty,  "Volatile  Organic  Contaminants Removal  by  Air
     Stripping."    Proceedings,  AWWA  Seminar,  99th  Annual
     National  AWWA  Conference,  San  Francisco, CA.    June,
     1979.

Metcalf  and  Eddy,  Inc.    "Volatile  Organic  Removal:   Two
     Ground Water  Supply  Case Histories."  Presented  at  the
     New York Section AWWA.  1980.

Nabolsine,  Kohlman, Ruggiero Engineers,  P.C.    "Technical
     Memorandum:   Well  Water Supply Testing  for the Removal
     of  Organic Contaminants."   Office of  the Mayor,  Glen
     Cover,  New York.  1978.

O'Brien, R.P.,  et  al.   "Trace Organics Removal from Contam-
     inated  Ground Waters  with  Granular  Activated Carbon."
     Presented   at  the  National  ACS meeting,   Atlantic,
     Georgia.  1981.

Plimmes, J.R., ed.   Pesticide Chemistry in the 20th Century.
     ACS  Symposium,  Division  of Pesticide  Chemistry.   New
     York, N.Y.  April,  1976.

Schwartz, E.B.,  "Water as an Article  of Commerce:   State
     Embargoes Spring a Leak Under Sporhase  v.  Nebraska.  12
     ENV. Affairs 103 (1985).

Schwinn,  D.E.,  D.F. Storrier,  R.J.  Moore and  W.S.  Carter.
     "PCB Removal  by Carbon Adsorption."   Pollution Enain-
     eering 16(1):20-21.  1984.

Shukle, R.J.   "Rocky Mountain Arsenal  Ground-Water Reclama-
     tion Program" in  Aquifer Restoration and  Ground Water
     Rehabilitation—A  Light  at the  End of  the  Tunnerl.
     Proceedings   of 2nd  National  Symposium on  Aquifer
     Restoration and Ground Water Monitoring.   David Nielsen,
     ed.  Columbus, OH.   May 26-28,  1982.  pp. 367-374.

Singley, J.E.,  et  al.   "Use of  Powered Activated  Carbon  for
     Removal  of Specific  Organic  Compounds."   Proceedings,
     AWWA Seminar,  99th Annual  AWWA  Conference.   San Fran-
     sico, California.   June 1979.
                           E-45

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                    APPENDIX F

         GENERAL CENSUS BUREAU INFORMATION;
  NATIONAL CLEARINGHOUSES FOR CENSUS DATA SERVICES;
                        AND
BUREAU OF THE CENSUS STATE COORDINATING ORGANIZATIONS
                         F-1

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         GENERAL CENSUS BUREAU INFORMATION

   Regional Census Bureau contracts :

   .  Atlanta, Georgia  30309:   1365 Peachtree Street,
     N.E.,  Room 625
             Telephone: (404)  881-2274

   .  Boston, Massachusetts 02116;  441 Stuart Street,
     10th Floor
             Telephone: (617)  233-0226

   .  Charlotte. North  Carolina  28202;  Suite 800, 230
     South Tryon Street
             Telephone: (704)  371-6144

   .  Chicago. Illinois  60604;  55 East Jackson Boule-
     vard,  Suite 1304
             Telephone: (312)  353-0631

   .  Dallas. Texas75242;  1100  Commerce Street, Room
     3C54
             Telephone: (214)  767-0625

   .  Denver,  Colorado  80225;   575  Union  Boulevard,
     P.O. Box 25207
             Telephone: (303)  234-5825

   .  Detroit.  Michigan 48226;  Federal Building and
     U.S.  Courthouse,  Room 565,  231  West  Lafayette
     Street
             Telephone: (313)  226-4675

   .  Kansas  City,  Kansas  66101; One  Gateway Center,
     4th and State Streets
             Telephone: (816)  374-4601
Information in each of the 12 regional offices of the
Census Bureau answer  questions  about census publica-
tions  and products  and  help users  locate  and  use
census data.   They also  conduct workshops  and  make
presentations on census programs and services.
                      F-2

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   .  Los  Angelas.  California  90040;  11777  San  Vin-
     cente Boulevard, 8th Floor
          Telephone: (213) 209-6612

   .  New   York.   New   York   10007;   Federal   Office
     Building, Room 37-130, 26 Federal Plaza
          Telephone: (212) 264-4730

   .  Philadelphia.  Pennsylvania   19106;    William  J.
     Green,  Jr.,  Federal  Building,  600  Arch  Street,
     Room 9244
          Telephone: (215) 597-8313

   .  Seattle. Washington  98174; New  Federal  Building,
     Room 312, 915 North Second Avenue
          Telephone: (206) 442-7080

Libraries with government depositories

   .  1980   Census   of    Population  -   Supplementary
     Report,  Metropolitan  Statistical   Areas,   Order
     No. PC 80-SI-18)

   .  Urbanized Areas; 1980

   .  1980 Census reports for each state
                      2
   .  Census tract maps  for local area
                      2
   .  Income statistics

   .  Enumeration Districts
2
 Customer Service Bureau, Data User Service Division,
 Bureau of the Census, Washington, D.C. 20233
 (202) 763-4100

 Geography Division, Bureau of the Census,
 Jeffersonville, Indiana (812) 288-3213
                        P-3

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National Clearinghouse  for
Census  Data  Services
Address List
                                                  January 1983
U.S. Department of Commerce
      Bureau of the Census
  Washington, D.C. 20233
The National Clearinghouse for Census Data Services
is  a referral service for users needing  specialized
assistance  in obtaining  and utilizing statistical data
and related products prepared by the Census Bureau.
This assistance ranges  from  informational services
such as seminars or workshops to technical services
such as providing tape  copies or performing geocod-
ing. The organizations  listed  in this  brochure have
notified the Census Bureau that they can supply users
with the services noted below.

Organizations registered with  the National Clearing-
house for Census Data  Services complete a checklist
describing services they provide. These may include
one or all of the following:

  •  Preparation  of  computer tape  copies, printouts,  or
     special files and extracts.
  •  Preparation of microfiche copies, printouts from micro-
     fiche, or other micrographic services.

  •  Preparation  of analytic reports, area comparisons, or
     area profiles.

  •  Online access to data.

  •  Training programs or other informational services in
     accessing and/or using census data.

  •  Special services such as geocoding, site selection, market
     area analysis, redistricting, or other activities using census
     products.
                 Organizations registered  with  the Clearinghouse are
                 not  franchised,  established, or  supported  by  the
                 Bureau of the Census. Each organization establishes
                 its own methods of operation, cost structure, and the
                 clientele eligible for services. The Census Bureau does
                 not monitor or control the prices or the quality of
                 services offered by those organizations.

                 This brochure provides a listing of  organizations by
                 State. The letters A through M are used to indicate
                 the services provided  by  the individual organizations.
                 More detailed information can "be obtained directly
                 from  the  individual  organization or .from the State
                 and  Regional Programs  Staff,  Data User  Services
                 Division, Bureau  of  the Census, Washington, D.C.
                 20233. telephone (301) 763-1580.

                 Related data services are provided  directly  to users
                 through  the  Census  Bureau's  Data User  Services
                 Division and  the Bureau's regional offices (listed on
                 the  last  page of  this brochure).  In many States,
                 services similar  to those offered by. Clearinghouse
                 registrants may also  be  provided to State and local
                 governments  and others  through State data centers
                 (consortiums  of State  agencies,  universities,  and
                 libraries).  For information on the State Data Center
                 Program, contact a Census Bureau  regional office or
                 the State and Regional Programs  Staff, Data User
                 Services Division, Bureau of the Census, Washington,
                 D.C. 20233, telephone (301) 763-1580.
  California
  Allstate Research and Planning
   Center. Ann: Nicholas Gannam.
   Allstate insurance Company, 321
   Middlefield Road, Menlo Park.
   94025.415/324-2721 (A.8.C.H.M)
  Biddle and Associates, inc., Ann:
   Cheryl Morgan/Barbara Ounlap, 903
   Enterprise Dnve. Suite 1.
   Sacramento. 95625. 916/929-7670
   (B.C.H.LM)
  California Survey Research. Ann: Ken
   Gross. 152 Ventura Blvd.. Suite
   1101. Sherman Oaks, 91403. 213/
   986-9444 (B.C.H.M)
  Criterion Incorporated, Ann: Bill
   Bamberger, 11100 Roselle Street.
   San Diego, 92121. 714/455-0162
   (A.B.C.E.HJ.K.UM)
David Bradwell and Associates. Inc.,
  Ann: David Bradwvil. 860 Las
  Gallmas Avenue. San Raphel,
  94903. 415/479-4960 (B.O.H)
Demographic Research Company.
  Ann: Joseph J. Wetssmann. 233
  Wilshire Blvd.. Santa Monica,
  90401. 213/451-8583
  (A.B.C,D.H,I,J.K,LM)
General Research Corporation. Ann:
  Lynn Heidlar/ Michael Sharp, 5383
  Hollister Avenue, P.O. Box 6770.
  Santa Barbara. 93111. 805/964-
  7724 (A.B.C.E.H.M)
National Decision Systems, Ann:
  Came Goodman. 9968 Hibert
  Street, Suite 100. San Diego, 92131.
  714/695-0060 (B.C.E.H.M)
Nobi Takahashi and Associates. Ann:
  Nobi Takanashi. PO Box 1319,
  Oakland. 94604 415/465-0293
  (A.B.D.E.H.l.K.LM)
Rose Institute of State and Local
  Governments, Ann- Robert S
  Walters. Pitzer Hall. Claremont
  McKenna College, Claremont.
  91711. 714/621-8159 (A.B.C.H.M)
Urban Decision Systems, inc.. Ann-
  James A Pans. 2032 Armacost
  Avenue, P O Box 25953. Los
  Angeles. 90025. 213/320-8931
  (A.B.C.E.H.K.L.M) (Organization also
  located m other states, please
  contact individual listed above for
  further information.)

-------
 Donnelley Marketing Information
   Sen/***. Ann- Bnan Becker, 1515
   Summer Street. Stamford. 06905.
   203/357-8735 (A.3.C E.H J.L.M)
 National CSS. Ann Jeffrey M. Lee,
   Business Research Products. '87
   Danoury Road. Wilton. 06897 203/
   762-2511 (A3C.E.H.K.L.M)
   (Organization also located m other
   state's, ciease contact individual
   listed aoove  for furrer information )
 Reebie Associates. Attn  David A
   isacowitz. Principal. 200 Railroad
   Avenue. Greenwich. 06830 203/
   561-8661 (A.B.C.H.M)
 Research  for Policy Decisions.  Attn:
   Norman Spector. One Financial
   P'aza. Hartford. 06103 203/247-
   3411 (A.B.C.E.H.I.J.K.L.M)
 District of Columbia
 Occuoations. Inc . Ann- Lloyd V
   Tornme. 1260 21st Street. N W..
   Suite 801, Washington. D C , 20036.
   202/659-3876 (A.B.C.E.E.H.L.M)
 Florida
 Behavioral Science Research. Attn:
   Robert A Ladner, 1000 Ponce  de
   Leon Blvd.. Coral Gables. 33134.
   305/448-7622 or 800/327-6207,
  outside Florida (A.B.C.D.F.H.I.L.M)
 Census Group Computing Center.
  Attn- Paul Manna, Flonda State
  University. Tallahassee. 32306.
  904/644-4836 (A.B.C.O.E.K.M)
 info Tech. Inc . Ann- Marlin Eby. P 0
  Sox 14545. Gainesville. 32605  904/
  375-7624 (A.B.CD.G.H.I.K.L.M)
St °etersburg Times and E/emng
  mcecendent. Ann Jack Vernon /
  Susan McKeivey. Research
  Department. P 0 Box 1121. St.
  Petersburg. 33731 813-393-8451
  (A 9CO E.H.I J.KL.M)
Census Access Program. Ann-  flay
  Jones, University of Florida
  L tranes. Department of Reference
  3rd 3:bi.ography, university of
  r'craa, Gainesville. 32611 904/
  392-0363 (A3CDEGHJX-M)
Management institute. Ann G  Hartley
  Meihsh/Michael J  White/ Pamela S
  Tucker. College of Business
  Administration. University of South
  Flonda, Tampa 33620. 813/974-
  4264 (A.B.C.D.E.I.L.M)
Hawaii
Department of Budget and Finance.
  Attn  Tad Nakano, Electronic Data
  Processing Division. P O Box 150.
  Honolulu. 96810 808/548-3117
  (A.3.C.H.L)
Illinois
Concordia College, Attn: William
  Kammrath, 7400 Augusta Street.
  River Forest. 60305 312/771-8300
  (A.B.C.DE.H.L.M)
Indiana
 Research Associates. Inc . Attn John
  J Carter. P O Box 44640.
   Indianapolis.  46244  317/266-6925
   (A.B.C.H.J.K.L.M)
Louisiana
Tn-S Associates. Incorporated, Ann:
  Kenneth Selle/Wayne Hatcher, P O.
  Box 130. Puston. 71270. 318/255-
  6710 (A.B.C.D.E.H.I.L.M)
Main*
Creative Computing Services. Ann:
  Celeste Carey. RFD #1. Box 5590,
  Dryden. 04225. 207/645-3321
  (A.B.C.O.H.J.K.M)
Social Science Research Institute.
  Ann- Garrett Bozytmsky, 164
  College Avenue. Orono. 04473.
  207/581-2555 (A.B.C.O.H.L.M)
Maryland
Systems Sciences, inc.. Attn- Chns
  Gordon. 4340 East-West Highway.
  * 1122. Bethesda.  20814  301/654-
  0300 (A.3.C.H.J.K.M)
Massachusetts
Geographic Systems, inc., Ann:
  Spencer Joyner, 100 Main Street,
  Reading. 01867 617/942-0051
  (A.B.C.H.J.K.M)
Modeling Systems. Incorporated. Ann:
  Geoffrey N. Berlin. Ten Emerson
  Place. Suite 3-E. Boston. 02114.
  617/277-6778 (HJ.K.L.M)
NERCOMP, Ann: Robert Gibbs,
  President, 439 Washington Street
  Braintree. 02184. 617/848-6494
  (A.8,C,D.E.H."L,M)
United Community Planning
  Corporation. Ann: Donald D. Dobbin,
  87 Kilby Street. Boston,  02109.
  617/482-9090 (B,C,H,U,K.L.M)
Urban Data Processing, Inc.. Ann: Bill
  Max field. 209 Middlesex Turnpike.
  Burlington. 01803.  617/273-0900
  (A,3,C.O,H.J,K.M)
Michigan
COMSHARE. Attn: Ted Jastrzembski.
  3001 South State Street. Ann Arbor,
  48106.313/994-4800
  (A.8.C.E.H.LM) (Organization also
  located >n other states, please
  contact individual listed above  for
  further information)
Data Research Center. Ann: Scott D.
  Phillips, 715 East F-ont Street,
  Traverse City. 49684  616/947-2501
  (C.H.L.M)
Data Coordination Division. Ann:
  Patricia C. Becker. Planning
  Department. City of Detroit. 3400
  Cadillac Tower. Detroit. 48226. 313/
  224-6389 (B.D.H.I J.M)
inter-University Consortium for Political
  and Social Research. Attn: Erik W.
  Austin. P O Box 1248. Ann Arbor.
  48106. 313/763-5010 (A.B.C.D.L.M)
LAM Consulting. Incorporated. Ann:
  Jacquard W  Guenon. 220 Albert
  Street.  Suite 211. East Lansing,
  48823  517/337-7750
  (A.B.C.E.F.H.I.LM)
Michigan State University. Ann-
  Anders C. Johanson. Computer
  Laboratory. East Lansing. 48824
  517/355-4684 (A.B.C.D.E.H.J.K.L.M)
Oakland County Planning Division,
  Attn- David R. Hay. 1200 North
  Telegraph Road, Pontiac. 43053.
  313/858-0720 (A.B.C.D.F.G.H.I)
Southeast Michigan COG. Ann: Jim
  Thomas, 1248 Washington Blvd..
  Book Building. Detroit 48226. 313/
  961-4266 (A.B.G.H.I.J.K.M)
Total Environmental Systems. Inc..
  Attn  Robert E Seaman. 414  North
  Larch Street. Lansing.-J8912  5i7/
  482-2500 (A.B.C.H.I J < L Vt)
Tn-Coonty Regional Planning
  Commission. Attn- Jason E Wnitler.
  913 W Holmes Road. Suite 201.
  Lan»ng, 48910  517/393-0342
  (A.B.C.D.E.H.U.K.L.M)
Minnesota
OATAMAP, Inc., Ann: Grant I
  WarfieW. 9749 Hamilton Road. Eden
  Praine. 55344 612/941-0900
  (A,3.C.H,I.J.K,L.M)
Mississippi
Mississippi State University. Ann E'len
  S. Bryant, Department of Sociology,
  P 0  Drawer C, Mississippi State.
  39762.601/325-2495
  (A.B.C.D.G.H.L.M)
Missouri
MARC Research Data Center. Ann:
  Jon A. Nelson, 20 West 9th Street.
  2nd Floor, Kansas City. 64105. 816/
  474-4240 (A.B.G.H.I.J.K.M)
University of Missoun-St.Louis. Ann:
  John G. Blodgen. Computer Center.
  8001 Natural Bndge  Road. SL
  Louts, 63121  314/553-5131
  (A,B.C,H.J,K.LM)
Nebraska
Metromail Corporation. Ann: William
  Dougherty,  901 West Bond Street,
  Lincoln, 68501. 402/475-4591
  (A.C.H.J.M)
New Hampshire
Geographic Data Technology, me .
  Ann: Donald F Cooke. 13
  Dartmouth College Highway,  Lyme,
  03768. 603/795-2183 (J.K.M)
New Jersey
Association of Public Data Users, Attn-
  Richard D  Bender, Princeton
  University Computer Center, 87
  Prospect Avenue. Princeton, 08540.
  609/452-6023 (A.B.C.D.F.H.L.M)
Pnnceton-Rutgers Census Data
  Prciect. Ann Judith S Rowe.
  Princeton University Computer
  Center. 87  Prospect Avenue.
  Princeton, 08540. 609/452-6052
  (A.B.C.D.E.F.G.H.l.L.M)
New York
American Demographics Magazine,
  Ann: Peter K Francese, 127  West
  State Street. P 0. Box 68, Ithaca,
  14850 607/273-6343 (L.M)
CUNY Data Service. CASE.. Ann:
  Robert Foss. Director. Graduate
  School and University Center. City
  University of New York. 33 West
  42nd Street, New York, 10036. 212/
  354-0640 or 790-4459
  (A.S.C.O.E.H.J.K.L.M)
Demographic Systems, incorporated,
  Attn Marvin Finkelstem, Census
  Service Center Director, 325
  Hudson Street.  New York. 10013.
  212/255-8707 (A.C.H.M)
                                                         F-5

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         Marketing Group, Inc.. Attn:
  Henry Lee. 1290 Avenue of the
  Amencas, New York. 10104. 212/
  581-8725 (A B.C.D.H.I.J.K.LM)
Market Statistics. Attn: Edward J.
  Spar. 633 Third Avenue, New York.
  10017  212/986-4800 (A.B.C.D.H.M)
National planning Data Corporation.
  Attn  Patsy Bailey Aiiard, P O Box
  610.  'thaca. U850. 607/273-8208
  (A.3 C  D E H.K.L) (Organization also
  located m other states, pleas*
  contact individual listed above for
  further  information.)
User Services. University Computing
  Center. Ann: Frank Pens. SUNY at
  Sutfaio. 4250 Ridge Lea Road.
  Amherst.  M226. 716/831-1761 or
  1771 (A.B.C.E.F.G.J.K.M)
Tn-State  Regional Planning
  Commission. Attn- Juliette EMis. 1
  World Trade Center, 82nd P!oor,
  New  York. 10048. 212/938-3*02
  (A.8.C.D.H.I.J,K.L..M)
Ohio
Public Demographics. Inc.. Ann:
  Michael Starke. P O Box 19005.
  Cincinnati. 45219.  513/681-3735
  (A.3.C.D.E.H.J.M)
Oklahoma
Oklahoma State University. Attn:
  Eldean Bahm. university Computer
  Center. Mathematical Sciences
  Building 113. Stillwater. 74078. 405/
  624-6301 (A.B.C.I.L.M)
Oregon
Profiles Northwest. Attn- H W
  Cummins. 66 W 24th Avenue.
  Eugene, 97405 503/484-1318
  (C.HIJ.K.L.M)
Pennsylvania
Delaware Valley Regional Planning
  Commission. Attn  Ronald
  Fiialkowski. 1819 John F  Kennedy
  Blvd.. Philadelphia. 19103  215/567-
  3000 (A.B.C.E.H.U.K.L.M)
Planning  Data Systems, Ann- Barry H
  Cohen. 1601 Walnut Street. Suite
  1524. Philadelphia. 19102  215/665-
  1551 (A.8.C.D.H J.K.M)
Pcbinson Associates, me . Ann Morns
  Olitsky. Bryn Mawr Mall. 15 Morns
  Avenue, 3ryn Mawr. 19010 215/
  527-3100 (D.H.I.M)
Southwestern Pennsylvania Regional
  Planning Commission, Attn: Wade
  G. Fox, Mann Building. 8th Floor.
  Pittsburgh. 15219. 412/391-5590/
  5599 (I)
The UNI-COLL Corporation. Attn:
  Alanna J. Keiton, 3401  Market
  Street. Philadelphia.  19104  215/
  387-3890 (A.B.C.D.E.H.J.K.M)
Tennessee
Econographics of Knoxville, inc.. Arn-
  Robert J  McCulloch. P 0 Box
  9638. Knoxville.  37920-0638. 615/
  982-1225 (H.I.J.M)
Mempms State University. Ann: Lew
  Alvarado. Bureau of  Business and
  Economic Research. Memphis.
  38152. 901/454-2281 (A.B.C.F.H.L)
Regional and Urban Studies
  Information Center. Ann Andrew S.
  Loebi. Oak Ridge National
  Laboratory, P O  Sox X. Oak Ridge.
  37830.615/574-5966
  (A.B.C.D.G.H.L.M)
Texaa
Houiton-Galveston Area Council. Ann:
  Dons Davis. 3701  West Alabama.
  Suite 200. P O. Box  22777,
  Houston. 77227 713/627-3200
  •
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                      NATICNU. CLEARINGBGOS&,BQfc.CEM>US-CKI& SERVICES

                                   ADDRESS LIST — Addendum
Delaware

Census and Data System
Attn:  Edward Ratleoge
University of Delaware
Willard Hall, Roan 312
Main Street
Newark, Delaware 19711
302/738-8405
(A,B,C,D,E,J)

Florida

Paul E. Gagnon
Economic Research Consultant
1021 N.E. 8th Avenue
Fort Lauderdale, Florida  33304
305/463-9732
(D,H,M)

Illinois

Northeastern Illinois Planning Connission
Attn:  Chuck Metalitz
Research Services Depar&nent
4uO West Madison Street-2nd Floor
Chicago, Illinois  60606
312/454-0400

Maryland

Congressional Information Service
Attn:  Laima Rivers
4520 East-West Highway, Suite 800
Bethesda, Maryland  20814
301/654-1550 or 800/638-8380
(F)

Ed Nichols Associates
Attn:  Ed Nichols
P.O. Box 158
176 Laytonsville Road
Washington Grove, Maryland 20880
301/258-5003
(A,B,C,H,J,M)
Regional Planning Council
Attn:  Josef Natnanson
2225 No. Charles Street
Baltimore, Maryland  21218
30 V38 3-5855
(A,B,C,D,H,J,K)

New Jersey

Princeton-Rutgers Census Data ?roje<
Attn:  Gertrude Lewis
Center for Computer and Information
   Servics
Rutgers University-Hill Center,
Busch Campus
P.O. Box 879  „
Piscataway, New Jersey  08854
201/932-2483
(A,B,C,D,E,F,G,H,L)

New York

Columbia University Center for the
  Social Sciences
Attn:  Lauretta O'Dell
814 International Affairs Building
420 Nest 118th Street
New York City, New York 10027
212/280-3038
(B,C,D,E,F,G,H,L)

(Address Change)
Financial Marketing Group, Inc.
377 Park Avenue South
8th Floor
New York, New York  10010
212/685-5930

North Carolina

Personnel Research, Incorporated
Attn:  Chris Northup
1901 Chapel Hill Road
Durham, North Carolina  27707
919/493-7534
(A,B,C,H,H)
                                       (more)

                                     F-7

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 Pennsylvania

 K. H. Thomas Associates
 Attn:   Kenneth  H.  Thomas
 University Cizy Science Center,
   Suite 200
 3508 Market Street
 Philadelphia, Pennsylvania  19104
 215/332-2^00
 (A,B,C,F,G,H,I,L,M)

 Rhode Island

 Social  Science  Data Center
 Attn:   James M.  Sakoda
 Brown University
 Box 1916
 providence, Phode  Island   02912
 401/863-2550
 (A,B,C,D,E,)

 Texas

 William G. Barker  and Associates
 Attn:   Bradley M.  Feinberg
 1009 w. Randol  Mill Road
 Suite 212
 Arlington, Texas  76012
 817/255-0794
 (B,C,E,H,J,K,M)

 (Name and Services Change)
 DUAL-Catm. inc.  and DUALabs
 (A,B,C,DrH,M)

 Virginia

 Orringtor. Econonics, Inc.
 Attn:  Jack Goodman
 P.O. Box 3756
 Arlington, Virginia  22203
 703/527-5990
 (M)

Washington

 Samraamish Data Systems
 Attn:   Richard Schweitzer
 1413 177th Avenue, N.E.
 Bellevue, Washington  98808
 206/644-2442
 (B,C,H,L)
                                                        May 1983
                                   F-8

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State Data Center Program
State
Coordinating Organizations
AddreSS List	January 1984
US Department of Commerce • Bureau of the Census • Washington, D.C 20233
ALABAMA

   Alabama State Data Center
   Center for Business and
     Economic Research
   University of Alabama
   P.O. Box AS
   University, AL  35486
   Dr. Carl Ferguson, Director
  •Mr. Sdward Rutledga
   (205) 348-^5191

   Office of State Planning
     and Federal Prograos
   State Data Center
   P.O. Box 2939
   3465 Norman Bridge 3d.
   Montgomery, AL  36105-0939
   .vtr. Gilford Gilder
   (205) 284-8775

   Alabama. Public Library Service
   6030 Monticello Drive
   Montgomery, AL  36130
   Mr. Anthony Miele
   (205) 277-7330

 ALASKA

   Alaska Department of Labor
   P.O. Box 1149
   Juneau. AS  99802
   David Swanson
  •Ms. Barbara Baker
   (907) 465-^513

   Office of the Governor
   Office of Budget and
     Management
   Division of Strategic Planning
   Pouch AD
   Juneau, AS  99811
   Mr. Thomas Chester
   (907) 465-2203
  Department of Education
  Division of Libraries and
    Museums
  Alaska State Library
  Pouch G
  Juneau, AS  99811
  Mr. Lou Coatney
  (907) 465-2942

  Department of Community and
    Regional Affairs
  Division of Local Government
    Assistance
  Pouch BH
  Juneau; AS  99811
  Mr. Doug Griffla
  (907) 465-4734

  Institute for Social, Economic,
    and Government Research
  University of Alaska
  707 "A" Street, Suite 206
  Anchorage, AK 99501
  Mr. Jack Xr'jse
  (907) 273-4621

ARIZONA

  The Arizona Department of
    Economic Security
  1300 Test Washington, 1st  Floor
  P.O. Box 6123-045Z
  Phoenix, AZ  35005
  *Ms. Linda Strode
  (602) 255-5984

   Research Specialist
   College of Business Admin.
   Arizona State University
   Temp*, AZ  85287
   Mr. Too Rex
   (602) 965-3961
 'Denotes key contact person
                             E>_O

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   College of Business Admin.
   Northern  Arizona  University
   Box  15066
   Flagstaff, A2   86011
   Or.  Ron Gunderson
   (602)  523-2358

   Federal Documents Section
   Department of  Library,  Archives,
      and  Public Records
   Capitol,  Third Floor
   1700 West Washington
   Phoenix,  AZ  85007
   Atif a  Rawan
   (602)  255-4121

   Dean of the Graduate  College
   Administration Building,  Sm. 501
   University of  Arizona
   Tucson, AZ  85721
   Dr.  Lee B. Jones
    (602)  626-4031

 ARKANSAS

    IREC-Cbllege of Business Admin.
   University of  Arkansas
   33rd and  University Avenue
   Little Rock, AR  72204
   Dr.  Barton Westerlund, Director
   Sarah  Breshears
   *Dr.  Forrest Pollard
    (501)  371-1971

    Arkansas  State Library
    1 Capitol Mall
   Little Rock, AR  72201
   Ms.  Frances Nix
    (501)  371-2159

 CALIFORNIA

    State  Census Data Canter
    Department of  Finance
    1029 P Street
    Sacramento, CA  95814
    Ms.  Unda Gage
   *Mr.  Bill  Schooling, Director
    (916)  322-4651
  Sacramento  Area CCG
  800  H Street
  Suite 300
  Sacramento, CA  95314
  Mr.  Bob Faseler
  (916) 441-5930

  Assn.  of Bay  Area Governments
  Hotel Claremont
  Berkeley, CA   94705
  Ms.  Patricia  Perry
  (415)  841-9730

  Regional Research Institute
    of Southern California
  600  S. Ccnmonwealth St.
  Los  Angeles,  CA  90005
  Mr.  Tim Douglas
  (213) 385-1000

  Source Point
  Security Plaza Pacific
   1200 3rd Avenue
  San  Diego,  CA  92101
  Ms.  Karen  Lamphere
   (714) 236-5353

   State Data Center Program
  University of Calif.-Berkeley
   2538 d**.rminy Way
   Berkeley,  CA   94720
   Ilona Eixiowski
   (415) 642-6571

COLORADO

   Division of Local Government
   Colorado Dept. of Local Affaii
   1313 Sherman Street, Rm. 520
   Denver,  CO  30203
  "Mr.  Reid Reynolds
   Ms.  Rebecca Picaso
   (303) 866-2351
•Denotes key contact person
                                      F-10

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   Business Research Division
   Graduate School of Bus. Admin.
   University of Colorado-Boulder
   Boulder, CO  80309
   Mr. Gerald Allen
   (303) 492-8229

   County Information Service
   Department of Economics
   Colorado State University
   Fort Collins, CO  80523
   Ms. Sue Anderson
   (303) 491-5706

   Documents Department
   The Libraries
   Colorado State University
   Port Collins, CO  80523
   Us. Karen Fachan
   (303) 491-5911

CONNECTICUT

   Comprehensive Planning Division
   Office of Policy and Management
   State of Connecticut
   30 Washington Street
   Hartford, CT  06106
  *Mr. Theron A. Schnure
   (203) 563-3905

DELAWARE

   Delaware Development Office
   99 Kings Highway
   P.O. Box 1401
   Dover. DE  13903
   Mr. Nathan Hayward, Acting Dtr.
  •Mr. Doug Clendaniel
   (302) 736-4271
   Computing Center
   University of Delai
   192 S Chapel Street
   Smith Hall
   Newark, DE  197U
   Mr. Bob Shaffer
   (302) 738-8441
DISTRICT OP COLOMBIA

    Data Services Division
    Mayor's Office of Planning
      and Development
    Room 458, Lansburgh Bldg.
    420 7th Street, N.W.
    fashington, DC  20004
   *Mr. Albert mnnun
    (202) 727-6533

    Metropolitan Washington
      Council of Governments
    1875 I Street, N.W., Suite 200
    Washington, DC  20006
    Mr. John McCLain
    Ms. Susan Kalisn
    (202) 223-6800

 .FLORIDA

    Division of Local Resource
      Management
    Florida Deparnnent of
      Coonunity Affairs
    2571 Executive Center Circle, !
    Tallahassee K PL  32301
   •Mr. Matthew Brady
    (904) 488-2356

 GEORGIA

    Georgia Office of Planning
      ftpd Budget
    270 Washington St., S.W.
    Atlanta, GA  30334
    Mr. ClarJc Stevens, Director
   •Mr. Tom Wagner
    (404) 656-2191

    Documents Librarian
    Georgia State University
    University Plaza
    Atlanta, GA  30303
    Mr. Jay McNaoara
    (404) 658-2185

    Robert W. Woodruff Library
      for Advanced Studies
    Emory University
    Atlanta, GA  30322
    Ms. Elizabeth McBride
    (404) 329-6872
    •Denotes key contact person
                                       F-1 1

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Main Library
University of Georgia
Athena, GA  30602
Vs. Susan C. Fields
(404) 542-8949

Georgia Dept. of Comnunity Affairs
Office of Research % Information
40 Marietta Street, Jf.W., 8th Floor
Atlanta, GA  30303
Mr. Dave Wiltsee
(404) 656-3873

Documents Librarian
State Data Center Program
Albany State College
504 College Drive
Albany, GA  31705
Ms. Gold* Jackson
(912) 439-4065

Docuaents Librarian
State Data Center Program
Georgia Southern College
Statesboro, GA  30458
.Sis. Lynn Walshak
(912) 356-2183

State Data Center Program
Vfercer University Law Library
Mercer University
Macon, GA  31207
Mr. Reynold Xosek
(912) 745-6811

University Computer Center
University of Georgia
Athens, GA  30602
Ms. Hortense L. Bates
(404) 542-3106

Price Gilbert Memorial  Library
Georgia Institute of Technology
Atlanta, GA  30332
Mr. Richard Leacy
(404) 894-4519
 HAWAII

   State Departaent of Planning
     and Economic Development
   P.O.  Box  2359
   Honolulu,  HI  96804
  •Mr. Robert Scbmitt
   Ms. Maureen St. Michel
   (808) 548-3082

   Electronic Data. Processing Divis
   State Department of Budget
     and Finance
   Kalanimoku Building
   1151  Punchbowl Street
   Honolulu,  HI   96813
   vQT9 TOO ZCtQBSi^^^PO
   (808) 548-4160

   Hawaii Cooperative Health Systen
   University of Hawaii
   Moore Hall, #427
   1890  East-West Road
   Honolulu,  HI   96822
   Mr. Bain Henderson
   (808) 948-6977

IDAHO

   Division of  Economic and
     Cooounity Affairs
   700 W State Street
   State Capitol Bid*., Hm. 108
   Boise, ID  83720
   Mr. Dan Emborg, Administrator
   (208) 334-2309
  *Mr. Alan Porter
   (208) 334-3416

   University Research Center
   Boise State  University
   1910  University Drive
   Boise, CD  33725
   Dr. Richard Hart, Director
   (208) 385-3576
   Mr. Basil Dahlstrom
   (208) 385-1573
•Denotes key contact person
                                     F-12

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   Ibe Idaho State Library
   325 West State Street
   Boise, ID  83702
   Ms. Belen Miller,  State librarian
   Sir. Gary Bettls
   (208) 334-2150

ILLINOIS

   Division of Planning and
     Financial Analysis
   Illinois Bureau of the Budget
   William Stratton Bldg., Rm. 605
   Springfield, IL  62708
  •Ms. Kathy Roberts
   (217) 782-3500

   Ccnmunity Research Services
   Department of Sociology, Anthro-
     pology, and Social Work
   Illinois State University
   Normal, IL  61761
   Dr. Vernon C. Pohlmann
   (309) 438-2387

   Center for Governmental Studies
   Northern Illinois University
   DeEalb, IL  60115
   Us. Ruth Anne Tobias
   (815) 753-0322
IMDIANA
   Center for Urban and Environmental
     Research and Services
   Southern Illinois University at
     Sdwardsvllle
   Box 32
   Edwardsvllle, IL  62026
   Mr. Charles Kofron
   (618) 692-3032

   Chicago Area fl*» 
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   Census Services
   Iowa State University
   318 East Hall
   taes, LA  50011
   Dr. Willis Goudy
   (515) 294-8370

   Laboratory for Political Research
   University of Iowa
   321 Schaeffer Hall
   Iowa City, IA  52242
   Mr. Jim Grtfhorst
   (319) 353-3103

   Census Data Center
   Department of Public Instruction
   Grimes State Office Building
   Des Moines, IA  50319
   Mr. Steve Boal
   (515) 281-4730

   Census Data Center
   Iowa Department of Hunan Services
   Hoover State Office Raiding
   Des Moines, LA  50319
   Mr. Sent Westaas
   (515) 281-4694

   Ballou Library
   Buena Vista College
   Strom Lake, IA  50588
   Dr. Barbara Palling
   (712) 749-2127

KANSAS

   State Library
   State Capitol Building, Rm. 343
   Topeka, B3  66612
  •Mr. Marc Galbraith
   (913) 296-3298
   Division of the Budget
   State Capitol Building, Rm.
   Topeka,  KS  66612
   Mr.  Daina Farrell
   (913) 296-2436

   Institute for Economic and
     Business Research
   325  Nichols Hall
   The  University of Kansas
   Lawrence, KS  66044
   Mr.  Robert Glass
   (913) 864-3123

   Center for Urban Studies
   Box  61
   Wichita State University
   Wichita, S3  67208
   Mr.  Mark Glaser
   (316) 689-3737

   Population Research Laboratc
   Department of Sociology
   Kansas State University
   Manhattan, KS  66506
   Mr.  Donald
   (913) 532-5984

KEHTOCKY

   Urban Studies Center
   Department SDC
   University of Louisville
   Gardencourt Campus
   Alta 7ista Road
   Louisville, KY  40292
  *Mr. Vernon Staith
   (502) 588-6626
•Denotes key contact person
                                     F-14

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   Office for Policy * Management
   State of Kentucky
   Capitol Annex
   Frankfort, £T  40601
   Mr. William Hlnty*
   (502) 564-7300

   State Dept. of Library & Archives
   State Library Division
   300 Cbffeetree Road, P.O. Box 537
   Frankfort, KT  40602
   Mr. James Nelson, Director
   (502) 875-7000

LOUISIANA

   Louisiana State Planning Office
   P.O. Box 44426
   Baton Rouge, LA  70804
   Mr. Wallace L. Walker, Director
  •Mr. Thornton Cofield
   (504) 342-7410

   Division of Business and
     Economic Research
   University of New Orleans
   Lake Front
   New Orleans, LA  70122
   Ms. Jackie Hymel
   (504) 286-6248

   Division of Business Research
   Louisiana Tech University
   P.O. Box 5796
   Ruston, LA  71270
   Dr. Edwd 0'Boyle
   (318) 257-3701

   Reference Department
   Louisiana State Library
   P.O. Box 131
   Baton Rouge, LA  70821
   Mrs. Blanche Cretin!
   (504) 342-4918
   Experimental Statistics Department
   173 Agriculture Admin. Building
   Louisiana State University
   Baton Rouge, LA  70803
   Dr. Nancy Keith
   (504) 388-8303

MAINE

   Division of Economic Analysis
     and Research
   Maine Department of Labor
   20 Union Street
   Augusta, ME  04330
  •Mr. Raynold Fongemie
   (207) 289-2271

 MARYLAND

    Maryland Dept. of State Planning
    301 West Preston Street
    Baltimore, MD  21201
    Ms. Constance Lieder, Secretary
      of the Md. Dept. of State Ping.
   •Mr. Arthur Benjamin
    (301) 383-5664

    Computer Science Center
    University of Maryland
    College Park, MD  20742
    Mr. Eli Schunao
    Mr. John McKary
    (301) 454-4323

    State Library Resource Center
    Enoch Pratt Free Library
    400 Cathedral Street
    Baltimore, MD  21201
    Ms. Anne Shaw Burgan
    (301) 396-5328
    •Denotes key contact person
                                      F-15

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MASSACHUSETTS
MINNESOTA
   Center- for Massachusetts Data,
   Executive Office of Coomunities
     and Development
   IX Cambridge Street, Rm. 904
   Boston, MA  02202
  *Mr. Charles McSweeney, Coordinator
     of Center for Massachusetts Data.
   (617) 727-3253

   University Office of Center for
     Massachusetts Data.
   University of Massachusetts
   117 Draper Hall
   Anherst, MA  01003
   Dr. George R. McDowell, Director
     of Center for Massachusetts Data,
   (413) 545-0176

 MICHIGAN

    Michigan Information Center
    Department of Management
      and Budget
    Office of -the Budget/LLPD
    P.O. Box 30026
             MIV 48909
   •Dr. Laurence Rosen
    (517) 373-7910

    MIMIC/COS
    Wayne State University
    5229 Cass Avenue
    Detroit, MI  48202
    Mr. William Simoons
    (313) 577-2180

    The Library of  Michigan
    Government Documents Division
    P.O. Box 30007
    Lansing, MI  48909
    Ms. F. Anne Diamond
    (517) 373-0640
   State Demographic Unit
   Minnesota State Planning Agea
   101 Capitol Square Building
   550 Cedar Street
   St. Paul, MN  55101
   Mr. Thomas Gillaspy
  •Ms. Eileen Barr
   (612) 296-4886

   Minnesota Analysis and
   Planning System
   University of Minnesota-St.Pa
   475 Coffey Hall
   1420 Eckles Avenue
   St. Paul, MN  55108
   Ms. Patricia Kbvel-Jarboe
   (612) 376-7003

   Office of Public Libraries an
   Interlibrary Cooperation
   Minnesota Department of Educa
   301 Hanover Building
   480 Cedar Street
   St. Paul, MN  55101
   Mr. Bill Asp
   (612) 296-2821

MISSISSIPPI

   Center for Population Studies
   The University of Mississippi
   Bondurant Building, Room 3W
   University, MS  38677
   Dr. Max Williams, Director
   •Ms. Michelle Ratliff
   (601) 232-7288

   Governor's Office of Federal
      State Programs
   Department of Planning and Pi
   Walter Sillers Building
   Jackson, MS  39202
   Mr. George Parsons,  Director
   Ms. Jeanie E. Smith
   (601) 354-7018
   •Denotes key contact person
                                     F-16

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MISSOURI
NEBRASKA
   Missouri State Litany
   308 High Street
   P.O. Box 387
   Jefferson City, to  65102
   Mr. Charles O'Halloran
  •Mr. Jon Harrison
   (314) 751-4552

   Office of Administration
   124 Capitol Building
   Jefferson City, MO  66101
   Mr. Ryan Burson
   (314) 751-2345

   B and PA Research Center
   University of Missouri
   10 Professional Building
   Colunbia, MO  65211
   Or. Ed Robb
   (314) 882-4805

MONTANA

   Census and Economic Information
     Center
   Montana Dept. of Coranerce
   1429 9th Street
   Capitol Station
   Helena, MT  59620-0401
  •Ms. Patricia Roberts
   (406) 444-2896

   Montana State Library
   Capitol Station
   Selena, MT  59620
   Mr. Harold ("^l<"T*fci*ra
   (406) 449-3115

   Bureau of Business and
     Economic Research
   University of Montana
   Missoula, MT  59812
   Ms. Mazine Johnson
   (406) 243-5113
   Center for Data Systc
     and Analysis
   Office of the Vice President
     for Research
   Montana State University
   Bozeman, MT  59717
   Ms. Lee Piulkner
   (406) 994-4481
   Bureau of Business Research
   200 CBA
   The University of Nebraska-Lincoln
   Lincoln, NE  68588
   Dr. Donald Pursell, Director
  •Mr. Jerry Deichert
   (402) 472-2334

   Policy Research Office
   P.O. Box 94601
   State Capitol, Rn. 1321
   Lincoln, NE  68509
   Mr. Andrew Cunningham
   (402) 471-2414

   Nebraska Library Commission
   1420 P Street
   Lincoln, NE  68508
   Mr. John L. -Kopischke. Director
   Ms. .Patricia Sloan, Fed. Doc.
   (402) 471-2045

   The Central Data Processing Divisi
   Nebraska Department of Adminis-
   .  trative Services
   1306 State Capitol
   Lincoln, NE  68509
   Mr. Robert S. Wright, Administrate
   Mr. Skip Miner
   (402) 471-2065

 NE7ADA

   Nevada State Library
   Capitol Complex
   401 North Carson
   Carson City, N7  89710
   Ms. Joan  Kerschner
  •Ms. Valerie Andersen
   (702) 885-5160

   Department of Data Processing
   Capitol Complex
   Blasdell Building, Rm. 304
   Carson City, NV  89710
   Mr. Bob Rigsby
   (702) 885-4091
  •Denotes key contact person
                                   F-17

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NEW HAMPSHIRE
NEW MEXICO
   Office of State Planning
   State of Nev Hampshire
   2 1/2 Beacon Street
   Concord, NH  03301*
  •Mr. Jim Mclaughlin
   (603) 271-2155

   Sev Hampshire State Library
   Park Street
   Concord, NH  03301
   Mrs. Shirley Gray Adamovlch
   (603) 271-2392

   Institute of Natural and
     Environmental Resources
   University of New Hampshire
   James Hall, 2nd Floor
   Durham, NH  03824
   Mr. Oven Ourgin
   (603) 862-1020

NEW JERSEY

   Nev Jersey Dept. of Labor
   Division of Planning & Research
   CN 388 - John Fitch Plaza
   Trenton, NJ  08625-0388
  *Ms. Connie 0.* Hughes
   (609) 984-2593

   Nev Jersey State Library
   185 West State Street
   Trenton, HI  08625
   Ms* Beverly Railsback
   (609) 292-4282

   Prlnceton-Rutgers Census Data Project
    Princeton University Computer Center
   87 Prospect Avenue
   Princeton, NJ  08544
   Ms. Judith S. Rove
   (609) 452-6052

   Princeton-Rutgers Census Data Project
   Center for Computer & Info.  Servic
   Rutgers University
   CCIS-flill Center, Busch Campus
   P.O. Box 879
   Piscatavay, NJ  08854
   Ms. Gertrude Levis
   (201) 932-2483
   Economic Development
     Tourism Department
   Bataan Memorial Building
   Santa Fe, NM  87503
   •Mr. John Velasco
   (505) 827-6200

   Nev Mexico State Library
   P.O. Box 1629
   Santa Fe, NM  88003
   Ms. Sandra Faull
   (505) 827-2033

   Bureau of Business and
     Economic Research
   University of Nev Mexico
   Albuquerque, NU  87131
   Dr. Lee Brovn, Director
   (505) 277-2626

   Center for Business Research
     and Services
   Box 3CR
   Nev Mexico State University
   Las Cruces, NM  88003
   Dr. Ken Novotny
   (505) 646-2035

 NEW YCflK

   Division of Economic Research
     and Statistics
   Nev York Deparoaent of Commerce
   Twin Towers, Room 1005
   99 Washington Avenue
   Albany, NY  12245
   Mr. Peter Ansell, Assistant
     Deputy Commissioner
  •Mr. Mike Batutis
   (518) 474-6115

   Lav and Social Sciences Unit
   Nev York State Library
   Cultural Education Center
   Empire State Plaza
   Albany. NY  12230
   Us. Elaine Clark
   (518) 474-5128
    •Denotes key contact  person
                                        F-18

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NORTH
   North Dakota State Library
   North Carolina Office of State
     Budget and Management
   116 West Jones Street
   Raleigh, NC  27611
  •Ms. Francine Ewing, Director
      of State Data Center
   (919) 733-7061

   State Library
   North Carolina Dept. of
     Cultural Resources
   109 East Jones Street
   Raleigh, NC  27611
   Ms. Earlean Strickland
   (919) 733-3343

   Institute for Research in
     Social Science
   University of North Carolina
   VtonrHng tfrU Q26A
   Chapel Hill, NC  27514
   Us* Judy Moses
   (919) 966-3346

NORTH DAKOTA

   Dept. of Agricultural Economics
   North Dakota State University
   Agricultural Experiment Station
   Merrill Hall, Roan 207
   P.O. Box 5636
   Fargo, ND  58105
   Highway 83N
   Bisnarck, ND  58505
   Us. Ruth Uahan
   (701) 224-2490

OHIO

   OMo Data Users Center
   Ohio Department of Economic  and
     CornuQiey Development
   P.O. Box 1001
   Colunbus, OH  43216
  •Mr. Jack Brown
   (614) 466-7772

OKLAHOMA

   Oklahoma State Data Center
   Depar*ODent of Scorv^pi<» and
     Ccnnuoity Affairs
   Lincoln Plaza Building,  Suite 285
   4545 North Lincoln Boulevard
   Oklahoma City, OS  73105
   Ms. Cindy Rambo, Director
  •Mr.« Harley Lingerfelt
   (405) 528-8200
  •Dr. Richard Rathge
   (701) 237-8621

   North Dakota State Planning Div.
   State Capitol,  17th Floor -
   Bisnarck, ND  58505
   Mr. Ronald Bostick, Director
   (701) 224-2818
   Ms. Kathy Lindquist
   (701) 224-2094

   Department of Geography
   University of North Dakota
   Grand Forks, ND 58202
   Mr. Floyd Hickok
   (701) 777-4593
     •Denotes key contact person
          aa Department of  Libraries
   200 N.E. 18tb Street
   (Tflahnmi City, OK 73105
   Ms. Virginia Collier
   (405)  521-2502

OREGON

   Intergovernmental Relations Div.
   Executive Building
   155 Cottage Street, N.E.
   Sala, OR  97310
   Mr. Jack Carter
  •Mr. Jon Roberts
   (503)  373-1996

   Bureau of Governmental  Research
     and  Service
   School of Ccmmunity Service and
     Public Affairs
   University of Oregon
   Sendricks Hall,  Room  340
   P.O. Box 3177
   Eugene, OR   97403
   Ms. Karen Seidel
   (503)  686-5232
                                      F-19

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   Center for Population Research
     •jfrj Census
   Portland State University
   P.O. Box 751
   Portland, CR  972^7
   Mr. Ed Shafer
   (503) 229-0922

   Oregon State Library
   State Library Building
   Salon, OR  97310
   Sir. Craig Smith
   (503). 378-4502

PENNSYLVANIA

   Institute of State and
     Regional Affairs
   Pennsylvania State University
   Capitol Campus
   Middletown, PA  17057
  •Mr. Bob Sutridge
   (717) 948-6336

   Department of Education
   State Library of Pennsylvania
   Forum Building
   Harrisburg, PA  17120
   Mr. John Gerswindt
   (717) 787-2327

   Governor's Office of Budget
     «rvj Administration
   Bureau of Management Services
   903 Health and Welfare Building
   Harrisburg, PA  17120
   Mr. Ray Jfo.spar
   (717) 787-1764

 pumru RICO

    Puerto Rico Planning Board
    Minillas Government Center
    North Bldg., Avenida Oe Diego
    P.O. Box 41119
    San Juan, PR  00940
   *Mr. Suriel Sanchez
    (809) 726-5020

    General Library
    University of Puerto Rico
    .Road #2
    Mayaguez, PR  00708
    Dra. Luisa Viga-Cepeda, Director
    (809) 832-4040
   DepmrtJfient of Education
   Carnegie Library
   P.O. Box 759
   Hato Rey, PR  00619
   Ms. Carmen Martinez
   (809) 724-1046

RHODE ISLAND

   Rhode Island Statewide
     Planning Program
   265 Melrose Street, Rm. 203
   Providence, RI  02907
   Mr. Daniel Varia, Chief
  *Mr. Chester Symanski
   (401) 277-2656

   Rhode Island Department of
     State Library Services
   95 Davis -Street
   Providence, RI  02908
   Mr. Frank lacono
   (401) 277-2726

   Social Science Data Center
   Department of Sociology
   Brown University
   Maxcy Hall, Angel Street
   P.O. Box 1916
   Providence, RI  02912
   Dr. Janes
   (401) 863-2550

   Rhode Island Health Services
     Research, Inc.
   56 Pine Street
   Providence, RI  02903
   Mr. Lawrence Manire
   (401) 331-6105

   Rhode Island Department of
     CcoBunity Affairs
   Division of Bousing and
     Government Services
   150 Washington Street
   Providence, RI  02903
   Mr. Joseph G. Simeone
   (401) 277-2892
                                        F-20

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SCDTH CABCLIXA
   Division of Research and
     Statistical Services
   Bixiget and Contrel Board
   State of South Carolina.
   Ranbert C. Dennis ELdg., B/341
   1000 Assembly Street
   Colunbia, SC  29201
   Mr. Bobby Bowers, Chief,
     Demographic Statistics
  *Mr. Mike Macfarlane
   (803) 758-3986

   South Carolina State Library
   P.O. Box 11469
   Cblunbia, SC  29211
   Mary Toll, Documents Librarian
   (803) 758-3138
                                    Vital Records Program
                                    South Dakota Dept. of Health
                                    Foss Building
                                    Pierre, SD  57501
                                    Mr. William D. Johnson
                                    (605) 773-3353

                                    Rural Sociology Department
                                    South Dakota State University
                                    Scobey Hall, 226
                                    Brookings, SD  57006
                                    Or. Marvin P. Riley
                                    Dr. Jim Satterlee
                                    (605) 688-4132

                                 TENNESSEE
SOJTH DAKOTA

   Business Research
   School of Busl
Bureau
   Patterson Hall
   University of South Dakota
   Vennillion, SD  57069
   Ms. Karen Bihlmeyer
   (605) 677-5287

   The State Planning Bureau
   South Dakota Deparonent of
     Executive Management
   Stat« Capitol Building
   Pierre, SD  57501
   Mr. Tony Merry, Cotanlssioner
   (605) 773-3661

   Documents Department
   The South Dakota State Library
   Department of Education and
     Cultural Affairs
   800 N. Illinois Avenue
   Pierre, SD  57501
   Ms. Rose OaLevekl
   (605) 773-3131

   Research and Statistics Unit
   South Dakota Dept. of Labor
   607 North 4th Street
   Aberdeen, SD  57401
   Ms. Mary Susan Victors
   (605) 622-2314
            •State Planning Office
   Janes K. Polk State Office Bldg.
   505 Deadrick Street, Suite 1800
   Kashville,  TM  37219
   Mr. Lewis Lavine, Executive Direct
  *Ur. Charles Brown
   (615) 741-1678

   Center for Business and
     Econcnic Research
   University of Tennessee
   Room 100, Glocker Hall
   KncacTine, TN  37916
   Ms. Betty Vickers
   (615) 974-5441

TEXAS

   Data Management Program
   Governor's Office of Planning
     and Intergovernmental Relations
   P.O. Box 13561
   San Houston ftrnH'*"gl Rm.  411
   Austin, IX  78711
  *Ms. Bonnie Young
   (512) 475-8386

   Department of Rural Sociology
   Texas A and M University Systen
   Special Services Building
   College Station, TX  77843
   Dr. Steve tfurdock
   (409) 845-5115
    'Denotes key contact person
                                       F-21

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                                              VERMONT
   Texas Natural Resources
     Information System
   P.O. Box 13087
   Austin, TX  78711 j.
   Mr. John Wilson
   (512) 475-3321
   Texas State Library
     Archive Conndssion
   P.O. Box. 12927
   Capitol Station
   Austin, TX  78711
   Mr. Allen Quinn
   (512) 475-2998
UTAH
   Office of Planning and
     Budget
   State Capitol, Boom 116
   Salt Lake City, OT  84114
   Mr. Kent Brlggs, Director
   Mr. Brad Barker
  *Mr. Jim Eobsoa
         533-6082
   Bureau of Economic and
     Business Research
   Business Building
   University of Utah
   Salt Lake City, UT  84112
   Rooda Brlnkerhoff
   (801) 581-6333

   Population Research Laboratory
   Utah State University
   Logan, OT  84322
   Mr. William Stinner
   (801) 750-1242

   Department of Employment Security
   174 Social Hall Avenue
   P.O. Box 11249
   Salt Lake City, UT  84147
   Mr. Sen Jensen
   (801) 533-2436
   Denotes key contact person
   Vermont State Planning Office
   Pavilion Office Building
   109 State Street
   Montpelier, VT  05602
   Mr. Bernard Johnson
  •Mr. David Healy
   (802) 328-3326

   Center for Rural Studies
   University of Vermont
   25 Colchester Avenue
   Burlington, VT  05401
   Mr. Fred Schmidt, Director
   Mr. Sam McReynolds
   (802) 656-3021

   Vermont Department of Libraries
   111 State Street
   Montpelier, VT  05602
   Ms. Patricia Klinck, State Librarian
   (802) 828-3265

   Vermont Agency of Development
     *nt\ ComoBunity Affairs
   Pavilion Office Building
   109 State Street
   Montpelier, VT  05602
   Mr. Barry Driscoll
   (802) 828-3211

VIRGINIA

   Department of Planning % Budget
   445 Ninth Street Office Bldg.
   P.O. Box 1422
   Richmond, VA  23211
   Mr. Stuart V. Connock, Director
  *Ms. Julie Henderson
   (804) 786-7843

   Tayloe Murphy Institute
   University of Virginia
   Dynamics Building, 4th Floor
   2015 Ivy Road
   Charlottesville, VA  22903
   Dr. Charles Meiburg, Director
   Dr. Julie Martin
   Dr. Michael Spar
   (304) 371-2661

   Virginia State Library
   12th and Capitol Streets
   Richmond, VA  23219
   Ms. T.
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 THGIN ISLANDS

   Department of Cctnnerce of the
     virgin Islands
   P.O. Box 6400
   Charlotte Araali*
   St. Tbofflas, VI  00801
  **r. Richard Moore
   (809) 774-8784 z2I4

WASHINGTON

    Forecasting & Estimation Division
    Office of Financial Management
    400 East Onion
    Mall Stop 51-13
    OlympU, WA  96504
   *Ur. Lawrence Weisser
    (206) 754-2808

    Washington State Library
    State Library Building
    Olympia, Washington  98504
    Mr. Roderick G. Swarcz
    Mr. Rushton Bnndis
    (206) 753-5424

    Urban Data Center
    University of Washington
    Seattle, WA  98195
    Mr. Edgar Hot-wood, Director
    Mr. Bob Shavcroft
    (206) 543-7625

    Social Research Center/
      Department of Rural Sociology
    Room 133, Wilson Sail
    Washington State University
    Pullman, WA  99164
    Dr. Annabel Cook
    (509) 335-1511
           «
    Department of Sociology/
      Demographic Research Laboratory
    Western Washington University
    BellinghJUB. WA  98225
    Mr. Lucky Tedrow, Director
    (206) 676-3617
   Technical Information Services/
     University Library
   Eastern Washington University
   Cheney, WA  99004
   Mr. Jay Rea
   (509) 235-2475

   Office of Institutional Studies
   Central Washington University
   Ellensburg, WA  98926
   Dr. John Purcell, Director
   Mr. John R. Dugan
   (509) 963-1856

WEST VIRGINIA

   Goonwity Development Division
   Governor's Office of Economic
     and CcoBuaity Development
   Capitol Complex
   Building 6, Room 553
   Charleston, WV  25305
   Mr. Miles Dean. Director,
   Gov.'a Office of Econ & Conn Dev.
   Mr. Fred Cut lip, Director,
   Community Development Division
  *Ms. {Catherine Shiflet
   (304) 348-4010

   Reference Library
   West Virginia State Library Commissi
   Science and Cultural Center
   Capitol Complex
   Charleston, WV  25305
   Ms. Karen Goff
   (304) 348-2045

   Office of Health Services Research
   Department of Community Health
   West Virginia University
   900 Chestnut Ridge Road
   Morgantovn, WV  26505
   Ms. Virginia Petersen
   (304) 293-2601
    •Denotes key contact person
                                      F-23

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WISCCH5IN

   Demographic Services Center
   Department of Administration
   101 South Webster St., 7th Floor
   P.O. Box 7864
   Madison, VI  53707
   Mr. Don toll
   (608) 266-1067
  •Mr. Robert Naylor
   (608) 266-1927

   Applied Population Laboratory
   Department of Rural Sociology
   University of Wisconsin
   1450 Linden Drive
   Madison, WI  53706
   Us. Doris Slesinger
   Mr. Stephen Tbrdella
   (608) 262-1515
     •Denotes key contact person


                                       F-24

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                   APPENDIX G

ECONOMIC TESTS FOR DETERMINING CLASS I - IRREPLACEABLE
     AND CLASS III - UNTREATABLE GROUND WATERS
                        G-l

-------
                         INTRODUCTION

I.   Economic Tests for  Class  I-Irreolaceable  and Class III-
     Untreatable Ground Waters

     Ground-water classes are designed to provide a basis for
differential  protection  of  ground  waters:   Class  I  ground
waters  are those  warranting  higher  degrees  of control  to
provide  extraordinary levels  of protection,  and Class  III
ground  waters  are those  warranting  the  lesser levels  of
protection due to  their  use  and  value.   Protection of ground
water  has  both  social  benefits  and  social  costs.    The
principal  social  benefits  of  ground-water  protection  are
protection of human health and the  environment and preserva-
tion  of   socially and   economically-valuable  ground-water
resources.   The social  costs  of protection result  from the
loss  of the  economic and other benefits  of  using the  re-
source .

     The Agency's  Ground--Water Protection  Strategy  is  based
on the principle that the  highest value  of a ground water is
as a current  or potential  source of drinking water.   Certain
ground waters warrant a  high level  of protection because the
value of protecting their  use as a source of  drinking  water
far exceeds the  potential  social costs of protection.   Con-
versely, the value of protecting certain  other ground waters
is very limited because it would be infeasible or inordinate-
ly  expensive or  impractical  to use them  as  a source  of
drinking water due to contamination or other factors,  and so
these ground waters warrant a lower level of protection.  The
economic  tests  for  Class  I-irreplaceable and  Class  III-
untreatable  ground waters are  designed  to identify  ground
waters  that warrant  higher  or  lower levels of protection
based on their economic  value  as a  source of drinking water.
These tests  are,  however,  only  several of many class-deter-
mining factors.

     The economic test for Class I  complement the technical,
institutional and  hydrogeological  assessments  of irreplace-
ability  and untreatability.    The need  to  include  economic
considerations can  be illustrated by considering the  result
of performing classifications  without applying  the proposed
economic tests.    Failure  to  include  the economic  tests  in
determining class  designations could  result in some undesir-
able Class II designations.  For example, ground waters that
are replaceable  based on technical and  institutional  crite-
ria, but are  highly valuable economic sources  of water for a
substantial  population  because  they would  be  excessively
expensive  to  replace, would be  designated  as Class II  (in
lieu of  Class III)  without the  economic  test.   Similarly,  a
                              G-2

-------
ground water that can be treated to drinking water standards,
but only  at such excessive  expense,  by national  standards,
that  its  use  as drinking  water  is  an  extremely  remote
possibility,  would  be  designated  as  Class II  (in lieu  of
Class  III)  without  the economic  test.    Incorporating  the
economic test would  promote more appropriate class designa-
tions and corresponding levels of protection in such circum-
stances .

     The economic tests for determining Class I-irreplaceable
and Class  III-untreatable  ground water have similar  struc-
tures  and  components.   They  are both  simple,  implementable
proxies  for an  exhaustive socioeconomic  evaluation of  the
benefits of protection.  These tests  are  intended for use as
"screening" tools only.  Classifiers may employ more detailed
analyses  in making a  Class III untreatable classification,
depending  on the availability  of  data  and  site-specific
factors.   In whichever level of analyses is performed,  site-
specific  factors should  be  considered  in determining  the
socioeconomic value of protection.

     Each test  involves comparing site-specific water supply
costs with a cost threshold based on local or regional income
levels.  The  cost of a replacement  or alternate water supply
system is estimated to approximate the value of ground water
that is currently used as  a drinking  water source (a Class I
candidate ground  water).   When the costs  of replacement  are
high,  the economic value of protection is high and the ground
water, therefore, warrants a high level of protection.  Using
a similar approach,  the cost  of using the  ground  water as a
source of  drinking water  is  estimated as  a measure of  the
value  of protecting contaminated  ground  water that is  not
currently  used   as  a  drinking  water  source  (a  Class  III
candidate ground  water).   In this case,  the cost of treating
the  ground  water  is   inversely related   to  the  value  of
protection.   If this cost is extraordinarily high and other
sources are available, the economic value  of protecting  the
ground water  is low  because the ground water is unlikely to
be utilized or  provide other beneficial uses and the ground
water, therefore, warrants limited protection.

     The  tests  utilize  a  percentage of  local  or regional
household income  as  a  cost threshold  for comparison with the
estimated  water  supply  costs  to make the  class determina-
tions.    The use of  a local  household  income  measure  to
establish a cost  threshold, rather  than a national standard,
allows  the  tests to  reflect  variations  in local economic
conditions,  and thus,  provides  a  measure  of local economic
"burden"  associated  with  a particular cost.   Variations in
cost estimates  among ground waters  will,  in general, be much
                            G-3

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more significant  than  variations in income levels  for class
determinations using these tests.

     The  percentages  of  household income  proposed as  cost
thresholds are based  on typical water  supply  costs relative
to household income of the service communities.  Current data
show that  annual  water supply costs typically range between
0.1 percent  and  1.0 percent of household  income.   Mean or
average  costs are  about  0.3 percent.   Therefore,   a  cost
threshold  exceeding 0.3  percent  of household income  will
identify inordinately high costs, and so thresholds exceeding
0.3 percent  are proposed  for both the  Class I and  Class III
economic tests.

     The  percent  threshold  proposed for  the  Class  I-irre-
placeable  ground  water  test approximates  the very  highest
costs that people pay  for a  water  supply.   Water supply cost
data show this level  to  be between 0.7  and  1.0 percent of
household  income.    For  Class  III,   the  overall  percent
threshold  is based on  more  average percentage  of  household
income that  people  typically pay,  i.e., 0.3 to 0.4 percent.
For Class III an additional  "treatment  cost  threshold" is
also proposed, however, to focus the classification decision
on whether or  not the ground water is  untreatable.   If both
cost assessments  are  above  this level, the ground  water is
unlikely to be developed of a source of drinking water or for
other beneficial uses.  This portion of the test is essential
in that,  according  to the Ground  Water Protection  Strategy,
Class III  is reserved  for areas  of untreatable ground water.
Thus,  the  economic  test must focus on  this, to avoid desig-
nating as Class  III,  clean ground  waters  which are  merely
expensive  to develop  because of their  depth  or distance-to-
population factors only.

     The  Agency  has  conducted  sensitivity  analyses  of the
effects  of  varying the  thresholds.   Varying the  percent
threshold  has the  effect of  varying   the  number  of  ground
waters designated as  either Class I and Class III  under the
tests.    Increasing the  percentage thresholds  decreases the
number of  Class I and  Class  III  designations  and visa versa.
These analyses  show that the percentage  thresholds identify
inordinately high costs, and set a balance so that the number
of Class  I or Class III designations that will be  made will
correctly  identify  ground waters deserving either  higher or
lower levels of  protection.   By setting  thresholds at these
levels, classifiers would not be  overprotective  by creating
an unnecessarily  large Class I  group,  or  underprotective by
making  too  many  Class  III  designations.    The  analyses
indicate  that  this balance is best  achieved  by using  a
                           G-4

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different percentage of income threshold for the Class I test
than the threshold proposed for the Class III test.

     The use of a Class III threshold  of between 0.7 and 1.0
percent thus  accords with the  objective of  restricting the
Class  I designations  to  "special"  ground  waters,  yet  one
which results in a sizeable Class I.

     In summary, the economic test criteria  for  Class  I are
met when:

Water Supply System Replacement >  0.7-1.0 percent of mean
Costs  (on an annualized basis)     annual household income

     A  threshold  of 0.3 percent  to 0.4 percent  is  proposed
for  analyzing  total system costs  in the Class  III  economic
test.    Additional   "treatment  cost"  thresholds  are  being
proposed to focus the Class III test on the economic "treata-
bility  of  the  ground waters  being  classified."    Recent
studies by  EPA's Office of Drinking Water  show  that ground
water drinking-water  supplies in  water-scarce western states
can cost as much as $300 per household per year.  An informal
survey  of  water  utility  rate  increases  that  have  been
approved in recent  years,  indicates that rate increases over
100  percent  of current rates have been proposed  and rarily
granted.   These  data  provide  indicators  of  when  the  ad-
ditional costs  of  treating a  particular ground  water may be
inordinately high.  Therefore, the economic test criteria for
Class III are met when:

     Annualized System  Costs  of an  Alternative  Water Supply
     exceed 0.3-0.4  percent  of mean annual  household income
     and

     The  Treatment   Costs  of   an  Alternate  Water  Supply
     increase household water rates  by more than 100 percent
     or a total of $300/household/year.

The  treatment  cost  threshold  may  be  adjusted to  reflect
regional or statewide treatment costs  in comparable systems.
Classifiers may wish to  incorporate more  detailed  economic
analyses  which  express  the  tradeoffs  and/or  benefits  of
protecting  a candidate  Class  III ground  water for  future
uses.

     Ranges of  values are  being proposed so that classifiers
will have the  flexibility  to  apply a threshold value that is
most  appropriate for  the  situation.   EPA  is  interested in
receiving comments on the use of these economic tests, and/or
other threshold values.
                             G-5

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II.  Rationale  for  the Economic  Test  of  Irreplaceability
     (Class I)

     The classifier  may apply an economic test  to determine
whether  ground waters  that  currently  serve  a  substantial
population (among other factors) warrant the special protec-
tion of a Class I designation.

     The  economic   test  of   ground-water  irreplaceability
complements  the assessment  of  the  availability and  suit-
ability of an  alternative  water  supply source by considering
the  economic   feasibility of  utilizing  the  alternative.
Economic feasibility is determined by comparing typical costs
of drinking water supplies to  the  income of service communi-
ties.   The test designates a  ground water  as  Class I-irre-
placeable if  (among  other factors) the  cost of  utilizing an
alternative water source is excessive relative to the income
of the service community.  Specifically, a potential replace-
ment source  is defined to be  economically  infeasible if the
annual  cost  to a  typical  household  user would exceed  a
percentage of the mean household income in the community.

     The economic test, thus,  identifies ground-water sources
that are replaceable by technical and institutional criteria,
but have a particularly high economic value because potential
replacements are very costly,  and therefore warrant a high or
special level of protection.

Percentage of Income Threshold for the Class I Economic Test

     The proposed threshold for  the  economic test is a range
of 0.7 to 1.0 percent of annual household income.  This range
has  been  chosen by  comparing  typical water supply  costs to
the  average  annual household  income of the service popula-
tions.  Exhibit A presents data on typical water supply costs
relative to national average household income.  The data show
that costs are  typically between 0.1 percent and 0.3 percent
of  average  annual  household  income.    Water supply  costs
rarely exceed one percent of average household income.  These
data  suggest  that  the threshold percentage  of  household
income for the economic test should be  chosen to exceed 0.3
percent to  accord with the  objective of  identifying ground
waters that are particularly  costly  to replace as sources of
drinking  water.    Furthermore,  sensitivity  analysis of  the
effects of employing alternative thresholds  on the number of
Class I designations indicates that:

        Class  I  representation  is  fairly  insensitive  to
        economic  thresholds  between  1.0  percent  and  0.5
        percent
                             G-6

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                          EXHIBIT A

                 TYPICAL WATER SUPPLY COSTS
        RELATIVE TO NATIONAL AVERAGE HOUSEHOLD INCOME
 Typical water supply costs per         $450 - 1,500
 million gallons*

 Typical water supply costs per         $ 27 - 90
 household per year*5

 Average annual household               $26,500
 income0

 Typical water supply costs as          0.1 percent •
 percentage of average                  0.3 percent
 household income
aSource:  Temple, Barker, and Sloane,  Inc.   1982,  Inflated to
          1984 dollars.

bAssumes annual household usage of 60,000 gallons.

cSource:  Average  household  income,  1983,  Statistical  Ab-
          stract  of  the  U.S..  1986.     Inflated  to  1984
          dollars.
                            G-7

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        At a threshold of 1.0 percent, Class I representation
        is dominated by non-economic Class I criteria; and

        Class I  representation is  very sensitive to reduc-
        tions in the threshold value below 0.5 percent.

     The use  of  0.5 percent or  above thus accords  with the
objective  of restricting  Class  I  designations  to  ground
waters  for which  the  socioeconomic value  of protection  is
particularly  high,  but  the  designation  is  not  so  overly
restrictive that it would result in a negligible Class I.

Implementation of•the Economic Test

     Implementation  of  the economic  test has two  principal
steps:

     (1)  Estimating the cost of  developing an alternative
          source to  provide drinking  water  to the population
          currently  served  by  the ground water  under review;
          and

     (2)  Comparing  the  costs  of  the  alternative  for  a
          typical  user  household to  the test percentage  of
          average household income for the population.

Estimation of Costsfor Alternative Water Source

     The  classifier must  calculate  the  cost  of   the  most
economical alternate systems.  He or  she may base the system
cost  estimates  on a system the same  size  as the  one being
classified,  or  he/she may estimate the  size of the system
that would be needed.

     Water supply  system costs can be  broken down  into four
major components:

     (1)  Acquisition;
     (2)  Treatment;
     (3)  Distribution and Transmission; and
     (4)  Support Services.

Each of these costs  elements may be incurred  in developing an
alternative source to supply a community with drinking water.
Acquisition  costs  are  the costs of  producing  or  acquiring
water,  and can  be thought of as the  costs of  getting the
water  to  the treatment plant.    These costs  include  the
capital,  operating,  and maintenance  costs of wells, reser-
voirs and  aqueducts, and payments to  suppliers for purchased
water.  Treatment  costs  include  the costs of treatment plant
                             G-8

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and equipment, and  the  costs of chemicals that are  added to
the water.  Distribution and transmission costs are the costs
of pumping the water from the treatment  plant  to  the service
population,  and  the  capital and  maintenance  costs of  the
piping  network.   Support  services  costs are  the  costs  of
administrative and  customer services that  are not  directly
related to the physical process of delivering water.

     Exhibit B shows the average cost structure of the small
and large systems  surveyed  by  ACT  Inc.  (ACT  Systems  Inc.,
1977,   1979).    Costs   are   separated  into  the  four  major
components,  with the  exception of  interest expenses  which
were not  allocated  to  particular  cost  components,  and have
been shown separately.

     Water system costs vary depending  on  the scale  of  the
system.   Exhibit C  shows average costs  for  ground-water  and
surface-water  systems   serving  populations   in various  size
categories, based on survey  data collected by  Temple,  Barker
and Sloane Inc.  (Temple, Barker and  Sloane Inc.,  1982).  The
data were collected in 1981 and  have  been  inflated to 1984
dollars.

     These data  show that there are  significant economies of
scale  in  systems operation.   Systems serving  populations of
approximately  300,000  have  average  costs of about  $600  per
million gallons  whereas systems serving  populations between
2,000  and 20,000 have  average costs in the  range of $1,000-
$1,500.   Also,  for  systems  serving  over  5,000 people,  there
appears to be  little difference between  the  average costs of
systems that use predominantly  ground water  and systems that
use  predominantly  surface  water.   Cost estimates for  an
alternative  source  should, therefore, reflect  the considera-
tion of the  size of the system  (determined by the population
currently served by the ground water under review).

     Cost estimates should also reflect the scope of measures
that  would  be  needed  to   supply   the  population  from  an
alternative  source.   Three basic  possibilities   arise when
developing an  alternative water source:   the first possibil-
ity  is that  only  the  acquisition  component  of   the  system
would  be  needed; the  second  is  that  both acquisition  and
treatment components would  be needed;  the third  is  that, in
addition  to  acquisition and treatment  components,  a  trans-
mission and  distribution network would need  to be construct-
ed.  These situations would lead to different costs.

     Acquisition costs  only would be incurred when existing
treatment  and  distribution  capacity could  be used  with  the
alternative  source.    Source  development may include such
                            G-9

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                          EXHIBIT B

      TYPICAL COST STRUCTURES FOR WATER SUPPLY SYSTEMS
                     Small Systems
                 Percentage Percentage
                     of         of
                 Operating  Operating
                 Expenses   Expenses
                            Excluding
                            Interest
     Large Systems

Percentage Percentage
    of         of
Operating  Operating
Expenses   Expenses
           Excluding
           Interest
Acquisition
Treatment
Distribution
and Transmission
Support Services
Interest Charges
Total

19
15
36
14
16
100
Charges
22
18
43
17
MM
0

15
10
31
25
19
100
Charges
19
13
38
30
-
aServing between 300 and 75,000 people.

^Serving over 75,000 people.

SOURCE:  ACT Systems Inc., 1977, 1979
                           G-10

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                          EXHIBIT C

                 TYPICAL WATER SYSTEM COSTSa
             (1984  $/million of gallons produced)
                                          Source
Population Served by System     Surface Water  Ground Water
1,000 -
3,300 -
10,000 -
25,000 -
75,000 -
over 500,
3,300
10,000
25,000
75,000
500,000
000
1,085
1,063
795
727
596
457
1,493
924
718
710
606
574
aOperating expenses (including depreciation and capital
 charges), inflated to 1984 dollars.

SOURCE:  survey of Operating and Financial Characteristics of
         Community Water Systems, Temple,  Barker and Sloane,
         Inc., 1982
                            G-ll

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measures  as  locating  and drilling a  new well  field  in  an
alternative aquifer, or  switching  from a ground-water source
to a surface-water source.

     Both  acquisition  and  treatment   costs  may be  incurred
when a  difference  in water quality between  existing  and the
alternative water  source requires that  additional treatment
processes be added in  order to  meet water quality standards.
For  example,  the  ground-water  supply for  a community  may
require  no  treatment  other  than   chlorination;  however,
switching  to  a  nearby  surface-water  supply  may  require
addition of unit processes  such a  coagulation, flocculation,
sedimentation, and filtration to the existing treatment plant
to remove  contaminants entering the reservoir with surface-
water run-off.

     Distribution and  transmission costs may  be  incurred  in
situations  where  the  installation  of  a  new  distribution
system  is necessary in  order to  supply the  community with
drinking  water  from an  alternative  source.    Such extensive
measures  would  generally be  required  in situations  where a
population is currently  served by a number  of private wells
and the  alternative  would require a centrally located water
supply system.  This situation  is  particularly applicable to
rural settings.

     Estimation  of  costs  for  an alternative water  source
should  be conducted using  site-specific information  to the
fullest extent possible,  because the costs  of developing the
source  can vary widely  depending  on  site-specific factors,
and because the purpose  of  the  test is to measure the effect
of these factors  on costs.   However,  the  data  on  average
system costs and cost  structures presented  in Exhibits B and
C may  be used  to  estimate costs  for the  system components
that  are  likely  to  have  similar  costs  to the  national
average.   In  these  cases,  national average  system component
costs  for certain  components would be combined  with site-
specific  or  source-specific  estimates  for  other  system
components.

     For example, development of an alternative source for a
community  of  4,000 people currently served  by private wells
may  require  development  of all of the components of water
supply system in order to utilize a nearby lake, which is the
only suitable alternative source.  In  this case,  the distri-
bution  and transmission  and  support   services components  of
the  system that would  be  required to  develop  this source
might be  typical of  systems of  similar size nationwide.  The
national average cost  estimates  could  be used  to estimate the
costs of these components.  From Exhibit B we  note that these
                           G-12

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components typically  comprise  60 percent of  the costs  of  a
small system  (43 percent  for  distribution and  transmission
plus 17  percent  for support services).   From Exhibit  C,  we
note that average costs per million gallons for surface water
systems  that  serve  between   3/300  and  10,000  people  are
$1,063.    Thus  $638 (60 percent  of $1,063)  could be  used as
the  estimate  of  distribution  and  transmission and  support
service costs.   (These costs would need to be inflated to the
base year for which  cost estimates are  required.   Further
discussion of  inflation  adjustments can be found  in  Section
III  of  this  Appendix  and  Appendix  E,  which  discuss  the
economic  test  for Class  III  ground-waters.)   This  estimate
would then be added to source-specific estimates of acquisi-
tion and treatment costs.   Acquisition  costs  might differ
from  national  averages,  for  example, because  use  of  the
alternative source  may involve  purchase  of  expensive  water
rights and rights-of-way.  Treatment costs might be high, for
example,  because  the  alternative source  contains  fertilizer
and pesticide run-off from nearby agricultural land.

     A  number  of  information   sources   are  available  to
estimate  site-specific  component  costs.     These  sources
include   Federal   and  State  agencies,   architectural  and
engineering consulting firms,  trade associations, and  local
water utilities.   Various  EPA reports on  water  supply and
water treatment  are  also good  sources of cost information
(e.g., Gulp, et.  al.,  1978).   (Specific discussion of the use
of data  from Gulp, et.  al.,   is  provided in section III of
this Appendix  in  the context of  cost  estimation   for  the
economic  test  for  Class III).   Other sources include  the
National  Water  Well  Drilling  Cost Survey  (NWWA,  1979)  for
cost estimates of ground-water source  development (acquisi-
tion costs).   When utilizing  cost estimates  from disparate
sources that refer to different  time periods,  care should be
taken to  allow for  inflation  (as  well  as  local variations in
labor and energy costs).  EPA  is expected to release updated
cost information over the coming years in preparation for the
implementation of the public water supply requirements of the
Safe Drinking Water Act Amendments of 1986.  Until these data
are available, cost indices published  quarterly by Engineer-
ing News Record can be used for this purpose.

     Engineering  costs   are  usually  estimated   in  three
components:    capital  costs  (e.g.,  construction,  capital
equipment),  operation and  maintenance  costs  (e.g.,  labor,
equipment  replacement & maintenance,  utilities, administra-
tion) , and  other costs (e.g.,  legal fees).   Costs estimated
in this  way should be converted  to equivalent annual costs.
Annualization  of  capital costs  is  based  on  the  expected
lifetime  of the  capital  and the  cost of finance.  As a first
                            G-13

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approximation, capital costs may be annualized by multiplying
by a factor of 0.1.  Thus:

     Annualized Capital Costs - Capital Costs x Annualization
                                                (Factor (0.1)

and

     Annualized Costs - Annualized Capital Costs + o&M costs.

     Appendix E provides  further discussion of annualization
methodology.

     For  cost  estimation,  the  required  system  size  is
determined by the  substantial  population currently served by
the  ground  water  under  review.    The  following  standard
assumptions  may  be  used  to   estimate  the  water  capacity
required to serve the population:

     Average Household Size       * 2.75 persons

     Average Annual Household     » 150,000 gallons
     Water Usage1


     For example,  a population of 4,000  people would require
a  system with  an  annual  capacity  of  218 million  gallons
(4,000/2.75 x 150,000 gallons per annum).  This is equivalent
to a  capacity of  approximately 0.6  million gallons  per day
(MGD).

     Estimated costs of system components should be expressed
on a common basis  before  they  are combined.  Typically costs
are expressed on a per  thousand gallon or per million gallon
basis.   (Exhibit  C presents costs on a per  million gallon
basis).   Annualized  costs can  be easily expressed  on this
basis by dividing annual costs by the capacity of the system.

Comparison of Costs with Average Household Income

     Once the costs  to utilize  an  alternative  source have
been  estimated,  the  economic  test  can  be  performed  by
comparing the annual  cost  to  a typical user  household with
the  average  household  income  of the population  currently
served by the ground water under review.
1150,000 gallons  is used here  to provide capacity  for uses
other  than residential  uses.    This  figure  is  based  on  an
assumption of 150 gallons per person per day.
                            G-14

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     The estimated costs to a typical user should be based on
the assumption  that annual household  water usage  is  60,000
gallons.    (Note  that a  higher  assumption  of  water  use
(150,000  gallons)   is  used  when determining  system  size.)
Thus,  if total estimated system  costs  are $1,000 per million
gallons, the  annual costs for a typical household  would be
$60 per household  ($1,000/1,000,000  x 60,000).   This  figure
is then compared with  the  average annual  household income of
the population served  by  the ground water under  review.   If
data on the average household income  of this population is
not readily available, data  for  the  county average household
income may be used instead.  These data are readily available
from the  Bureau of the  Census publication entitled "County
and City  Data Book",  which can usually be  found  in  local
libraries.    Exhibit  D  presents  state  average  household
incomes, for reference.  These aggregated data should be used
instead only  if more  specific county data are  unavailable.
Again,  income data should be inflated to the base year of the
test.

     When  cost  and  income  data  have  been  compiled,  the
following division can be performed:

     Per Household Costs of UtilizingAlternative Source
                   Average  Household  Income


     The division  will generally yield a  ratio  between 0.05
and l  percent.   If less  than 0.7 percent, the  ground water
should be designated as Class II.  If the result falls within
or above  the  range of 0.7 to 1.0 percent, the  ground water
should be designated as Class I.

Example

     A  population  of  6,000  (2,182  households)  is currently
served by individual wells in the Classification Review Area.
The only viable alternative water source is a reservoir which
is currently  used  largely for agricultural purposes,  and is
slightly   contaminated   by   fertilizers  and   pesticides.
Utilization of this alternative  would require development of
an  acquisition system to pipe  water to the population,  a
treatment  plant capable  of treating  the water  to drinking
water standards, and distribution system to deliver the water
to  the service  population.    Thus,  all  of the  system com-
ponents would be required.  The distribution and transmission
component of the system and support services are likely to be
similar to systems  of similar  size nationwide  so national
cost estimates  may be used  for  these components.   However,
                            G-15

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                           EXHIBIT D

                MEAN HOUSEHOLD  INCOME BY STATE
                             (1980)
State

Alabama               $21,200
Alaska                $37,700
Arizona               $25,100
Arkansas              $19,700
California            $28,100
Colorado              $27,200
Connecticut           $29,500
District of Columbia  $26,300
Delaware              $26,400
Florida               $23,500
Georgia               $23,200
Hawaii                $30,900
Idaho                 $22,600
Iowa                  $24,600
Illinois              $28,400
Indiana               $25,400
Kansas                $25,000
Kentucky              $21,500
Louisiana             $23,900
Maryland              $30,100
Massachusettes        $26,100
Michigan              $27,900
Minnesota             $26,100
Mississippi           $19,800
Missouri              $23,500
State

Montana
North Carolina
North Dakota
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wyoming
$22,600
$21,800
$22,800
$24,100
$27,600
$24,800
$29,400
$22,200
$26,000
$25,600
$23,000
$24,900
$24,800
$23,900
$22,200
$20,000
$21,700
$25,800
$28,700
$22,100
$26,400
$26,700
$21,800
$27,700
SOURCE: Bureau of the Census (1980), inflated to 1984 dollars.
                              G-16

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acquisition  and treatment  must be  estimated  based on  the
specific circumstances.

     Evaluation of this situation should proceed as follows:

     i) Determine the system size.
     The system would be required to  supply a community with
approximately 2,182 households.  The system capacity required
would be 327 million gallons annually, or 0.9 million gallons
per day  (2,200  x 150,000 /  365 days).  150,000  gallons per
household represents  a system  size  with capacity  to supply
residential, commercial, and other uses.

     ii)  Determine system components required.
     In the case, all of the basic system components would be
needed.

     iii)  Estimate costs of the system.
     Distribution  and  transmission   and   support  services
components  are  typical  of national  costs,  so  they may  be
estimated using average values  from Exhibits B and C.  These
costs  are  estimated  as  60  percent  (43  percent  plus  17
percent)  of  $1,063  per  million  gallons,   i.e.,  $638  per
million  gallons.   Based on  consultation with a  local  water
utility, this 1981 dollar figure is inflated by 45 percent to
reflect  cost  changes  between  1981   and   the year  of  the
analysis.   A cost estimate  of $925 per million  gallons is,
therefore, used for these components.

     A  local  engineering firm  provides  estimates of capital
costs of $850,000 to construct  a pipeline from the source and
a treatment  plant  capable of treating  the  water to drinking
water  standards,  and  operation and maintenance  expenses of
$100,000  for the  plant  and  pipeline  in   current  dollars.
Thus, approximate annual acquisition and treatment costs are:

        Annualized Capital Costs          $ 85,000
         (Calculated by multiplying
        capital costs; $850,000, by
        annualization factor; 0.1)

    +   Annual O&M Costs	      $100.000

    -   Total Annual Costs                $185,000


     In  addition,  fees of $200 per million gallons would be
charged  for use of  water from the  reservoir.   Thus,  total
acquisition  and treatment  costs would  be  $795  per million
gallons  ($185,000 divided by 327 million gallons, plus $200).
                           G-17

-------
     Totalling the costs for the system gives:

        $765 + $925 - $1,690 per million gallons.

     iv)  Comparing costs for a typical user household to the
          average household income.

     Costs to the typical household are based on annual usage
of 60,000 gallons  per household.  The  cost  estimate implies
an annual cost  of  $101 for the  typical  user ($1,690 divided
by 1,000,000 X 60,000).

     Recent census  data shows that average  household income
for the county is about $12,000.  Thus,  the test ration is:

                 $101
                           0.8 percent
                $12,000

     In this  case, the  costs of  utilizing the  alternative
source are  so high that the  ground water  is  irreplaceable
according to the economic test criteria, and so it warrants a
Class I designation.
                           G-18

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III. Economic Test to Indicate that Contaminated Ground Water
     is Untreatable (Class III)

     The economic test can be applied to determine  whether a
contaminated ground  water should  be provided  the  level  of
protection of  a Class II  or Class III ground  water.   This
test is provided for comment as a more rigorous  test than the
"reference  technology   approach"   discussed  in   the  main
sections  of  these  guidelines.    Economic  feasibility  is
determined in  this test with  reference to typical costs  of
drinking water supplies  relative  to the  income of  service
communities.    Data   show that annual  water  supply  costs
typically represent  between 0.1 percent and 0.3 percent  of
the  annual  average  income of  the service  community.   The
economic  test  designates the  ground water as  Class  III-
untreatable  if the cost  of treating the  water to drinking
water  standards and developing it as a  source of drinking
water is excessive.   Specifically,  the use of a contaminated
ground water as a source of drinking water  is  defined to be
economically infeasible  if the annual total  cost   (including
treatment) to  a hypothetical user household would exceed a
percentage  of  the  mean  annual  household  income  in  the
hypothetical user population.  A hypothetical user population
must be used because, by definition,  the potential  Class III
ground water  is not  currently used and, therefore,  the test
must be based on a hypothetical user population.

     The economic test,  thus, identifies ground-water sources
which have particularly  low  economic  value (under present or
foreseeable future conditions), because treatment and use of
such  ground  waters   for  drinking purposes  would  be  very
costly,  and  highly  unlikely,  even  though  there  may  be
technical procedures  available to  render  these of drinking
water  quality.   Such ground waters, therefore,   warrant a
lower  level  of protection than other ground waters.   Since
this  a two-step  process, the  actual cost  of  treating the
ground water will be of utmost importance;  again to avoid the
bias of designating "clean" ground waters as Class III due to
non-quality factors.

     The  first threshold  test  examines total  costs  over a
range of 0.3 to 0.4  percent of household income.   This level
has been chosen with  reference  to  typical  water supply costs
relative  to  the  mean  household  incomes  of  the  service
populations.  Typical water supply costs relative to national
average  household  income  show  that  costs  are  typically
between  0.1 percent  and 0.3 percent  of  the mean  household
income.  These data  suggest that the threshold  percentage of
household income for the  economic test  should be  chosen to
exceed 0.3 percent to accord with the objective of identify-
                          G-19

-------
ing contaminated  ground waters that are  particularly costly
to treat and use as sources of drinking water.

     The  second step  focuses  on treatment  costs when  they
increase total  system  costs to a  level  which exceeds a total
household cost of $300 per year or when they increase current
rates  more  than  100  percent.   These  criteria  are  being
proposed  for  assessing  "treatability."    EPA  is  seeking
comment on these criteria.

Implementation of the Class III Economic Test

STEP 1;  Determine Size of Hypothetical User Population

     The  first  step  in  the  economic  burden  test  is  to
determine  the  size  of the  "hypothetical user  population",
that  is,   the population  that could  use  (on a  conceptual
basis) the ground water as a source of drinking water.   The
size  of  the  hypothetical  user  population  is  determined
through two  approaches,  with the second  being the controll-
ing:
     1) the mean population served by ground-water systems in
        the state, and

     2) a  population  that  could be  served  by the maximum
        sustained yield of the aquifer in question.

     Exhibit  E  presents the mean size population  served by
ground-water  supply  systems in each state.   For example, the
mean population served by ground-water systems  in the State
of Maryland  is  3,916.   These data may  be used for the first
estimate.

     The second estimate is determined based on the estimated
sustained yield of  the aquifer.   The U.S.  Geological Survey
office  (e.g.,  District  Office)   in the  state or the state
geological or water surveys will often have hydrogeological
information   (e.g.,  maps,  reports,   and  surveys)  on  most
aquifers within a state.   Consultation with these and other
individuals  with  local expertise and experience  can likely
provide  a  reasonable  estimate   of  an  aquifer's  sustained
yield.   For  more detailed assessments,  a  review  of boring
logs, geotechnical evaluations or other data sources will be
needed.   Field assessments  and  ground-water  monitoring may
also be needed  to assess  not  only aquifer yield,  but quality
parameters as well.  Once the sustained yield is estimated, a
population equivalent  can be  determined  based on  an annual
water use of 150,000  gallons  per household per year.   For
example,  geotechnical  and hydrogeological data  may indicate
that an area in Maryland, which  is being classified,  has an
                           G-20

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                           EXHIBIT E

      MEAN POPULATION SIZE SERVED BY GROUND-WATER SYSTEMS
                     BY STATE OR TERRITORY
State

American Samoa
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Guam
Hawaii
Idaho
Iowa
Illinois
Indiana
Kansas
Kentucky
Louisiana
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
          State

1,360     North Carolina
2,136     North Dakota
  492     Nebraska
2,202     Nevada
1,848     New Hampshire
1,799     New Jersey
  732     New Mexico
  582     New York
1,083     Ohio
2,435     Oklahoma
1,050     Oregon
3,370     Pennsylvania
8,438     Puerto Rica
  769     Rhode Island
1,492     South Carolina
2,707     South Dakota
2,141     Tennessee
1,614     Texas
  903     Trust Territory
1,473     Utah
3,916     Vermont
3,072     Virgin Islands
1,297     Virginia
2,513     Washington
1.557     West Virginia
1,270     Wisconsin
  278     Wyoming
  422
  665
  839
  466
  610
5,639
1,702
1,779
2,085
1,109
  540
  742
3,037
1,690
  841
  930
5,269
1,384
  306
1,287
  433
   65
  388
  848
  842
1,331
  508
SOURCE:  ICF,  Inc.  Analysis,  based on  the Federal  Reporting
         Data  System   Interactive   (FRDS/Interactive),   which
         identified public  water supply systems  (ground water
         and surface water).
                             G-21

-------
estimated  sustainable yield  of  50  gallons  per  minute  or
72,000 gallons per day (gpd).   The population equivalent that
could be served by  this  yield is 480  (72,000 gpd  divided by
150 gpd/person).  Because  the latter,  hydrogeological factor
is  controlling,  the  hypothetical  user population  for  the
aquifer under review is assumed to be 480 persons.   Using the
national average of 2.75 people/household, the user popula-
tion of 480 is equivalent to 175 households (i.e.,  480 people
divided by 2.75 people/household).

STEP 2;  Determine the Mean Annual Income Per Household

     The  second step in  the  economic burden  test  is  to
determine the mean  annual  household income of the  hypotheti-
cal  user population.    This  determination  may be  made  by
assuming it to be  equal  to the mean household income in the
county where  the  ground water is  located.   These  data are
readily available from the Bureau of  the  Census publication
entitled "County and  City  Data  Book", which can  usually be
found  in  local libraries**  When  county-level  data  are not
available, state-level data may  be used as  default values.
Exhibit F  indicates the  mean annual income per household in
each state as provided by  the 1980 Census inflated to 1984
dollars.   In the  State  of Maryland,  for example,  the mean
annual income per household is $30,000 (1984 dollars).

STEP 3:  Estimate The Cost of theWater Supply system

     The next step is to  estimate the  cost of the ground-
water  supply  system which  could  serve the hypothetical user
population size determined in Step 1.  In  order to  do this,
it is important to consider the four major cost components of
a  newly  developed  water supply  system: acquisition,  treat-
ment, delivery, and support service.

     Acquisition costs are primarily  the  costs of acquiring
and physically developing  a water supply at  the site.   They
include the cost of the  land, rights  of way, and  well field
development costs.  The  latter can vary depending on hydro-
geologic conditions,  particularly  the depth of the aquifer
and the geologic formation overlaying the aquifer.

     Treatment costs include the costs of the treatment plant
and equipment, and  the costs  of the chemicals that are added
to the water.  For a water  of  given quality,  the  costs of
treatment  depend  on  the quantity  of  water treated  and the
treatment  technologies used.    The  capacity  of a treatment
plant is determined by the size of the population.  (Much of
the  cost  analysis  for  Step  3  will pertain  to  treatment
costs.)
                            G-22

-------
                           EXHIBIT F

                MEAN HOUSEHOLD INCOME BY STATE
                             (1980)
State

Alabama               $21,200
Alaska                $37,700
Arizona               $25,100
Arkansas              $19,700
California            $28,100
Colorado              $27,200
Connecticut           $29,500
District of Columbia  $26,300
Delaware              $26,400
Florida               $23,500
Georgia               $23,200
Hawaii                $30,900
Idaho                 $22,600
Iowa                  $24,600
Illinois              $28,400
Indiana               $25,400
Kansas                $25,000
Kentucky              $21,500
Louisiana             $23,900
Maryland              $30,100
Massachusetts         $26,100
Michigan              $27,900
Minnesota             $26,100
Mississippi           $19,800
Missouri              $23,500
State

Montana
North Carolina
North Dakota
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wyoming
$22,600
$21,800
$22,800
$24,100
$27,600
$24,800
$29,400
$22,200
$26,000
$25,600
$23,000
$24,900
$24,800
$23,900
$22,200
$20,000
$21,700
$25,800
$28,700
$22,100
$26,400
$26,700
$21,800
$27,700
SOURCE: Bureau of the Census (1980), inflated to 1984 dollars.
                                 G-23

-------
     Delivery  costs  include transmission  and  distribution
costs.  Transmission costs are the costs of pumping the water
from  the  treatment plant  to the main  distribution network.
Distribution costs  include the  cost  for the  piping  network
which provides the water to the water users.

     Support   services   are  primarily   administrative  and
customer service  costs  that are associated with  the  manage-
ment of a water supply system.

     Because  a  Class  III  candidate  ground  water  is  not
currently used,  it would  typically  be necessary  to  include
all four of the system  components  in  estimating the costs of
developing this resource as a water supply source.  Each cost
component needs  to be  evaluated  on  a  site-specific  basis.
However, default values can  be  used  to estimate acquisition,
and support services  costs if it can be  shown that the site
has no extraordinary  characteristics that  would  result  in
costs  which are  substantially  different  from the national
average costs  for  a system of that size.   Because the class
III candidate  ground water  is  contaminated,  default  values
should  not  be used to  evaluate treatment costs.   Treatment
costs  are  strictly site-specific  and  are determined  by the
nature and level of contamination of the ground water.

     Default values for  acquisition,  delivery,  and  support
service costs  can be  derived from  Exhibits  G and H.  Exhibit
G  presents  annualized  costs  (i.e.,  annualized  capital and
O&M)  for ground-water  systems  of various  sizes, based  on
nationwide data.  The costs are  expressed as 1984 dollars per
million  gallons   ($/MG).   Thus,  if the  total annual water
demand  is known, Exhibit H can be used to estimate the annual
system  cost (excluding  treatment costs).   Exhibit H presents
the relative   contribution  of cost  components to  the total
water  supply   system  cost.    These percentages are based on
water  supply  systems  across the nation  and  grouped into two
size  categories:   300 to  75,000 population  and greater than
75,000  population.   For  example, acquisition  costs  for  a
system  serving a  population  of  5,000  typically represent 22
percent of total costs.

     As an  example of how to use  Exhibits  G and H, assume a
user  population  of  5,000  (1,800  households).    Exhibit  G
indicates that for  a user population of this size, the annual
cost   of  ground-water   supply  systems  equals  $924   (1984
dollars) for each million gallons produced.  Because acquisi-
tion, delivery/ and support  services costs make up  82 percent
of  this  total  cost  (Exhibit  H) ,  total  costs,  excluding
treatment costs, to the hypothetical user population of using
the ground water as a source  of  drinking water amount to $758
                            G-24

-------
                          EXHIBIT G

            COSTS OF GROUND-WATER SUPPLY SYSTEMS2*
                 BY POPULATION SIZE CATEGORY
              (1984 $/xnillion gallons produced)
Population Served by System                Annual Cost


    25  -    1,000                            4,616

 1,000  -    3,300                            1,493

 3,300  -   10,000                              924

10,000  -   25,000                              718

25,000  -   75,000                              710

75,000  -  500,000                              606

over 500,000                                    574


aOperating expenses (including depreciation and capital
 charges, inflated to 1984 dollars.

SOURCE: Survey of Operating  and  Financial Characteristics of
        Community Water  Systems.  Temple,  Barker  and Sloane,
        Inc., 1982
                           G-25

-------
                          EXHIBIT H

                COST COMPONENTS AS  PERCENTAGES
                OF WATER SUPPLY  SYSTEM COSTS
                     System Serving       System Serving
                       300-75,000       Greater than 75,000
                       Population           Population
Cost Component     (% of total costs)a  (% of total costs)a
Acquisition
Delivery
Service
Total
22
43
11
82
19
38
30
87
aTotal costs are the sum of annualized capital costs and O&M
 costs.

SOURCE:   ACT Systems, Inc., 1979.
                              G-26

-------
(1984 dollars) per million gallons produced  (i.e.,  $924  x 82
percent).    The  total  annual  water usage  is  270  million
gallons  (i.e.,  1,800  households   x   150,000   gallons   per
household per year), so the annual costs  to  the hypothetical
user  population  for  acquisition,  delivery,   and  support
services are $204,660 (i.e.,  $758/mg x 270 mg).

     Determining the most economic treatment system involves
a series  of assessments.    First,  the  specific  ground-water
contamination problem in the  Classification  Review Area  must
for a Class-Ill determination be fully characterized.   Again,
the  contamination  problem  should  be  areal   in extent,  and
cannot  be  attributed to  a  specific disposal  site or  other
activity.    Much  of the  data  may  be  provided in  program-
specific permit applications, although  supplemental informa-
tion may be available from US6S, local authorities, and local
research organizations.

     Once  the  contamination  has   been  characterized,   the
desired water  quality  levels should be determined for  each
chemical constituent of concern.   If all  chemical constitu-
ents  of concern  are present  at  less than drinking  water
standards  (MCLs) or Health Advisories,  the water requires no
treatment.

     The next step is to identify all of the  treatment trains
which are  capable  of reducing  contaminant concentrations to
the desired range.   Exhibit  I  tabulates  contaminant  removal
efficiencies for common  treatment  technologies.   Any treat-
ment  technology which does   provide  removal of  any of the
contaminants  of  concern  may  be  eliminated  from  further
consideration.   The  process  of identifying  the  treatment
trains  which are capable  of  achieving  the desired concentra-
tion  levels can  be done systematically  by evaluating all
possible  combinations  of treatment  technologies  from  among
the  non-eliminated  choices,  or may be   done  heuristically
using expert judgement.

     The treatment trains identified in this process can then
be costed  out,  and the  least costly selected.   Any of these
treatment  trains  that   includes another of  the  treatment
trains  as  a   subset,  can  be  disregarded  because  it  will
clearly be inefficient.    (In  some cases, public water systems
add  apparently  redundant technologies  to  remove  chemical
constituents  for  'aesthetic' reasons,  or to provide backup
treatment  to  accommodate fluctuations  in influent quality.)
If no treatment trains can  be identified,  the  ground water
will automatically be Class III.
                           G-27

-------























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-------
     To cost out the treatment trains,  the individual system
components  should  be  listed.    Exhibit J  lists the  system
components typically required with each treatment technology.
When using published cost curves, it is important to read the
accompanying  test  which  describes  the  system  components
included in  the  cost curve, and  identifies  which components
must be  costed separately.   The following  reference (along
with Gulp et al.)  provide cost curves for a  range  of treat-
ment technologies and system sizes:

        Estimating Water Treatment Costs. Gummerman, Gulp and
        Hansen, EPA 600/2-79-162a.

        Treatability  Manual.  Technologies For  the  Control
        Removal of Pollutants, EPA 600/2-82-001C; and

        Estimation of Small System Water Treatment Costs. EPA
        600/2-84-184a.

Again, updated cost assessments will likely be available from
EPA or  the  water  utility industry,  under the  public  water
supply provisions  of  the Safe Drinking  Water Act Amendments
of  1986.    The costs  references  generally provide separate
estimates of capital  costs and annual O&M costs.   These can
be annualized  based  on the expected  lifetime  of the capital
and the cost of  finance.  As a  first approximation, capital
costs may be annualized by multiplying  by a  factor of 0.1.
Thus:

     Annualized Capital Costs » Capital Costs x Annualization
                                Factor (0.1)

and

     Annualized Costs = Annualized Capital Costs + O&M Costs

     Appendix  E provides further discussion  of annualization
methodology.

     Costs  calculated  in this way for  eight standard treat-
ment technologies are presented in Exhibit K.

     As an  example,  the annualized costs  to  treat  a ground-
water  contaminated with air  stripping,  precipitation,  and
rapid sand  filtration  for a system  supplying a population of
5,000  (or  1,800  households) would be approximately $159,800
(the sum of  $28,000 for  air stripping, $62,700 for precipita-
tion, and $69,100 for rapid sand filtration)  in 1982 dollars.
This  figure should be  inflated to a dollar  figure for the
base-year of the analysis.   It  should then be divided by the
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                          EXHIBIT J

       DEFAULT COMPONENTS OF EACH TREATMENT TECHNOLOGY
Aeration/Air Stripping

  Aeration tower
  In-plant pumping
Activated Carbon

  Carbon columns
  Backwash pumping
  Washwater surge basin
Chemical Precipitation

  Lime feed system
  Contact clarifier
  Sludge pumping
  Sludge drying beds
  Slugde hauling
Desalination

  Reverse Osmosis
  In-plant pumping
Filtration

  Granular media filtration
    beds
  Granular media
  Backwash pumping
  Washwater sewage basin
Ion Exchange

  Pressure Ion Exchange System


Ozonation

  Ozonation system

Ancillary Operations

  Administrative
  Raw water pumping
  Polished water pumping
  Clearwell storage
Flotation

  Dissolved air flotation
  Sludge pumping
  Sludge drying beds
  Sludge hauling
                           G-30

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                          EXHIBIT K

      ANNUALIZED COSTS OF TYPICAL TREATMENT COMPONENTS
                FOR TOUR TYPICAL PLANT SIZES
Population Served
Component
Aeration/
Air Stripping
Activated
Carbon
Chemical
Precipitation
Desalination
Flotation
Filtration
Ion Exchange
Ozonation
Ancillary
Operations
500
$16,500

$18,800

$35,200
$43,900
$30,100
$56,200
$10,100
$6,000
$25,900
2.500
$20,700

$27,000

$51,500
$109,500
$37,300
$61,400
$26,400
$7,000
$24,000
5.000
$28,000

$33,900

$62,700
$171,500
$48,900
$69,100
$38,900
$9,300
$46,200
25.000
$70,200

$113,900

$127,700
$595,600
$109,800
$107,700
$74,800
$19,200
$110,900
All figures are in 1982 dollars.
                            G-31

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number  of  households  in  the  hypothetical  population  to
calculate an annual  cost  per household.  This value  in turn
is divided by the annual  average  (mean)  household income and
a percentage is then derived.  This value is then employed in
STEP 5 to classify the ground water.

STEP 5;  Classify the Ground Water

     Two threshold  values must be considered in completing
the Class III test:   first, the total  system  cost threshold
and then secondly,  the treatment  cost threshold.   If  the
value  estimated in  STEP  4 exceeds  the proposed range  of
"total system  cost threshold" percentages  (0.3-0.4  percent)
and  the  treatment  cost   component of  total  system  costs
increase water  rates more than 100 percent or  establish a
rate  greater than  $300  per household  per year, than  the
ground water  is Class  III.   If the value  is less than the
proposed  range  of  economic criteria  percentages  and  the
treatment cost threshold,  then the ground water is Class II.

     Because the Class  III test must focus  on  whether or not
a particular ground  water source  is untreatable,  the classi-
fier  must  focus  on the  treatment  costs  associated  with
similarly-sized  or  comparable  systems.   Current data  show
that treatment costs nationwide typically comprise 18 percent
of the total cost  of systems serving  300-75,000 population
and 13 percent  of  the  total costs of systems  serving more
than 75,000 population  (ACT Systems, Inc.,  1979).  In making
a  Class  III  designation the  classifier  must   compare  the
effect that  treatment costs  of  the system  being classified
will  have on  household  water bills.    If treatment  costs
produce a household rate greater than $300 per year or a rate
increase greater than 100 percent  over  current rates (or any
other  baseline  percentage as established for similarly-sized
or comparable  systems  within a  state or  region) then the
ground water is Class III-untreatable.

     In  some  cases the   classifier may wish to undertake
additional analyses of the treatment  costs.    If,   for in-
stance,  a  ground water resource  is being  classified  in the
arid   southwestern   United  States  where   acquisition  and
delivery costs  comprise a  major  part  of total  system costs
and,  yet, very costly treatment technologies would need to be
employed, the  classifier   may wish to compare the treatment
costs  associated  with  the  system  being  classified  with
typical  treatment  costs   of similarly-sized  or comparable
systems  elsewhere  in the  state  or EPA  region,  instead  of
comparing  them  against  a national  standard.    Again,  the
objective of  this  test is to determine which systems would
                            G-32

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require treatment processes which are so costly that they are
"economically" untreatable.

Example

     A  Class  IIIA determination  is being  considered  for  a
hypothetical site in Maryland.  Past industrial activity and
urban recharge have resulted  in generally poor water quality
of the  aquifer.   As a  result,  an application  for continued
land disposal  activity  includes  a Class IIIA determination.
The five steps of the Class III economic test are examined in
this hypothetical problem.

STEP 1:  Determine Population Size/Number of Households

     Due to widespread industrial contamination, local ground
water in the area has been not used for drinking in more than
30 years.   Public  water  is  supplied  from  a  surface water
source.   Since the ground  waters  are shallow, a  Class IIIB
assessment is unlikely.

     The  US  Geological  Survey  District  Office  has  been
consulted to obtain old water supply reports for the area as
to estimate the yield of  the  aquifer under  review.  Based on
these reports, the Classification Review Area would support a
sustained yield of approximately 625 gallons-per-minute (gpm)
which is equivalent to 0.9  mgd.   This yield could reasonably
serve  a population  of  6,000,  assuming water  usage  of  150
gpd/person.

     Exhibit E indicates that the mean population size served
by ground-water  systems  in Maryland is 3,900.   Because the
3,900  average  is less  than  the  6,000 population  (based on
yield), the classifier may choose which hypothetical popula-
tion  figure is  most  appropriate.   If,  for  instance,  the
ground-water  resource  being  classified is   in  the  path of
encroaching development   (even though such  development will
not  utilize local  ground  water)  the  higher figure  may be
selected for analysis.  In this  example,  the 6,000 figure is
used  as the hypothetical  user  population.    This population
figure  represents about 2,182 households (i.e., 6,000 people
divided by 2.75 people/household).

STEP 2;  Determine the Mean Annual Income Per Household

     In Maryland,  the mean  annual  income  per  household is
$30,100 (see Exhibit F).  This income estimate  is used  in the
absence of more specific  survey data.
                            G-33

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STEP 3;  Estimate the Cost of the Water Supply System

     The first part of this  step  is  to estimate the acquisi-
tion, delivery, and service costs of the water supply system.
These system components are assumed to be typical of national
average  costs,  so  they  may be  estimated  using data  from
Exhibits G  and H.   A  population of  6,000 people  will  use
about  329  million gallons  of water  per annum  (i.e.,  6,000
people x 150 gpd/person  x 365 days) .  The  annual cost for a
typical ground-water system  to produce this  amount  of water
is about $303,996  (i.e.,  329  MG x $924/MG from Exhibit G)  in
1984 dollars.  Finally, the estimated system cost apportioned
to   acquisition,   delivery  and   service  is  approximately
$249,277 (i.e., $303,996 x 82 percent from Exhibit H).

     To determine  the  system  treatment  cost,  the procedure
described in the  preceding section should  be  used.   Samples
of  ground-water  from  old  industrial  supply,  wells  were
obtained.   The ground water  contains a non-volatile,  non-
biodegradable organic  compound,  a set  of volatile organics,
and  elevated levels  of heavy metals.   In  order  to  use this
contaminated ground water as  a  drinking   water source,  a
relatively  sophisticated  treatment   train   would likely  be
employed, consisting  of:  (1)  air stripping;  (2)  precipita-
tion;  and   (3)   filtration.    An  estimate of  the annualized
costs  of treating  this ground-water source with  a treatment
plant  using these  processes  (with a capacity  to  serve 5,000
people) were developed in the preceding  discussion, and are
$159,800 in 1982 dollars.  This cost is inflated from 1982 to
1984,  assuming  an inflation  factor of  35  percent, to give
1984 costs  of  $215,700.    This  figure can  then be pro-rated
(assuming  that  treatment   costs remain  constant)   for  a
population of  6,000  to yield an  estimate of $258,840  (i.e.,
$215,700 X 6,000/5,000).

     Estimated total annual  costs for the  system are  there-
fore:

     Acquisition,  Distribution and          $249,277
     Transmission, and Support Services

   + Treatment                              $258.840

     Total Annual Costs                     $508,117

     Total  annual costs per  household  are  $233  ($508,117
divided by 2,182 households).
                           G-34

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STEP 4;  Compute the Economic Test

     The economic test is as follows:

          annualized water system cost per household
              mean annual income per household

substituting the  numbers estimated from Steps  1,  2,  and 3,
the economic test becomes:

                $233      - 0.77 percent
                $30,100


STEP 5;  Classify the Ground Water

     The threshold value range of the Class III economic test
is  0.3 percent  to  0.4 percent,  which  is  less  than  0.77
percent, so the ground  water  is determined  to be a potential
Class IIIA.

STEP 6;  Compare Comparable Treatment Costs;

     Because the Class III — untreatable designation depends
on  the costs  of treating  water  as  drinking  water,  it is
necessary to examine the effect that  treatment costs have on
total system cost.  In  this example the treatment cost alone
comprises 51 percent  of the total cost.  When compared with
the treatment costs of  similarly-sized  or comparable systems
where treatment  costs  are  typically 18 percent  of the total
system  costs,  it can  be determined  that  in this  case the
treatment costs are relatively high.  Further, data show that
the  current  average  residential   water  bill   is  $101  per
household  per  year.   The  new  cost of $233  represents  more
than a  100 percent increase in costs, therefore, the resource
being classified  is  economically  untreatable and,  therefore,
Class IIIA.
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                         REFERENCES
Act, Systems,  Inc., 1979.   Volumes I  & II,  Managing Small
     Water  Systems:    A Cost  Study Prepared  for U.S.  EPA,
     Water Supply Research Division.  Municipal Environmental
     Research Labs, MERL.

Act, Systems,  Inc., 1977.   Volumes  I  and  II,  The  Cost  of
     Water Supply  & Water Utility Management,"  Prepared for
     U.S. EPA Water Supply Research Division, MERL.

National Water Well Association,  1979.   Water Well  Drilling
     Cost Survey.  NWWA, Worthington, Ohio.
                           G-36

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 U.S. Environmental Protection Agency
 Region 5, Library (PL-12J)
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U,S. Environmental

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