PREPARED BY THE


                     FOR THE


                   FEBRUARY 1980

This document was prepared by a special staff of the Wisconsin Department
of Natural Resources.  The conclusions of this report are those of the
Surface Impoundment Assessment staff and should not be taken as a strict
representation of departmental policy as established by the department
administrators or the DNR board.
This publication is financed by the U.S.  EPA funds, pursuant to Section
1442 (b) (3) (C) of the Safe Drinking Water Act (P.L. 93-523).

                           TABLE OF CONTENTS

Chapter 1:  Executive Summary
     1.1  Introduction
     1.2  Scope and Purpose of SIA
     1.3  SIA Findings
     Table 1-1
     1.4  Conclusions and Recommendations

Chapter 2:  Recommendations and Conclusions
     2.1  Conclusions
         2.1.1  Achievements of Wisconsin SIA
         2.1.2  Potential Pollution Hazard of Surface Impoundments
         2.1.3  Status and Effectiveness of State and Federal Programs
     2.2  Recommendations
     Figure 2-1

Chapter 3:  Methodology
     3.1  SIA Organization, Funding and Staff
     3.2  Inventory Procedures
         3.2.1  Types of Facilities Inventoried
         3.2.2  Inventory Categories
         3.2.3  Source of Data
    Industrial, Municipal and Mining
    Agricultural  Facilities
         3.2.4  Data Collection
         Figure 3-1 Inventory Data Form Used by Wisconsin SIA
     3.3  Assessment Procedures
         3.3.1  Random Selection of Impoundments
         3.3.2  Assessment of Contamination Potential
    SIA Rating System
    Confidence Scores
    Miscellaneous Identifiers
     3.4  Verification of Identifiers
     3.5  Methodology of Data Analysis
     Table 3-1 Variables Used in Data Analysis

Chapter 4:  Presentation and Analysis of the Data
     4.1  Inventory Statistics
         4.1.1  Summary of Count
         4.1.2  Estimates of Total Number of Sites/Impoundments
         Table  4-1 Statistical Summary of Wisconsin SIA
                4-2 Estimates on Surface Impoundments in Wisconsin
         4.1.3  Characteristics of Facilities Using Impoundments
         Table  4-3 Industries Utilizing Impoundments
                4-4 Livestock Maintained at Agricultural Facilities
                4-5 Definition of  Concentrated Animal Feeding Operations
                4-6 SIA Facilities Defined as Concentrated Animal  Feeding Operations
     4.2  Operating Characteristics of Impoundments
         4.2.1  Impoundment Purposes
         Figure 4-1 Population Basis of Municipal Facilities
                4-2 Purposes of Randomly Selected Impoundments
         4.2.2  Impoundment Liners
         4.2.3  Groundwater Monitoring Programs
         Figure 4-3 Liner Use at Non-Disposal Impoundments
          Table  4-7  Liner  Use  at  Randomly Selected  Impoundments

     4.3  Assessment Results
         4.3.1  Summary of Scores
         Table  4-8  Rating of the Unsaturated
               Scores  for  Step  1 :
               Scores  for  Step  2:
               Scores  for  Step  3:
               Scores  for  Step  4:
               Scores  for  Step  5:
                                         The Unsaturated Zone
                                         The Saturated Zone
                                         The Groundwater Quality
                                         Waste Hazard Potential
                                         Groundwater Pollution Potential
         4.3.2  Groundwater Pollution Potential of Absorption Ponds
         Table  4-14 Waste Hazard Potential for Disposal Impoundments
         4.3.3  Pollution Potential  of Storage and Treatment Impoundments
        Agricultural Impoundments
         Table  4-15 Step 1 Scores and Liner Use in Agricultural Non-Disposal
                Imp-v jndments
                4-16 Step 1 Scores and Liner Use at "Concentrated Animal Feeding
                4-17 Step 1 Scores and Liner Use in
                4-18 Step 4 Scores (Waste Hazard) for Industrial
                Impoundments With Liner Information
                4-19 Step 1 Scores and Liner Use in Municipal Non-Disposal
                                                    Industrial Non-Disposal

Chapter 5
            Water Table Aquifers
          Precambrian Aquifers
          Cambro-Ordovician Aquifer (Sandstone Aquifer)
          Niagara Aquifer
          Sand and Gravel Aquifers
     Figure 5-1 Bedrock Geology of Wisconsin
     5.6  Source of Data on Wisconsin Groundwater
     Figure 5-2 Areal Extent of the Cambro-Ordovician Aquifer
            5-3 Areal Extent of the Niagara Aquifer
            5-4 Areal Extent of the Sand and Gravel Aquifer
            5-5 U.S. Geological Survey Hydrologic Investigations Atlas Series

Chapter 6:  Instances of Groundwater Pollution from Surface Impoundments
     6.1  DNR-USGS Report on Groundwater Contamination Incidents
     6.2  Study on Groundwater Impacts of Manure Storage Ponds
Chapter 7
                 of  Existing  State Programs
     7.1  Introduction
     7.2  DNR Programs
         7.2.1  Programs Administered by the Bureau of Water Quality
       Wisconsin Pollutant Discharge Elimination System
       Wastewater Facility Plan Approval Process
       Environmental Fee Program
       Wisconsin Nonpoint Source Water Pollution Abatement
         7.2.2  Programs Administered by the Bureau of Solid Waste Management
       Non-hazardous Solid Wastes (Residuals)
       Hazardous Wastes
       Mine Tailings
       Servicing of Septic Systems
         7.2.3  Groundwater Monitoring and Data Utilization

       Monitoring Requirements
       Use of Monitoring Results in Regulatory Program
       Management of Monitoring Data
     7.3  Areas of Overlapping Authority
         7.3.1  Sludge
         7.3.2  Fly Ash and Other Suspended Solids
         7.3.3  Leachate and Seepage from Solid Waste Sites
     7.4  Gaps in Program Coverage
         7.4.1  Agricultural Waste Impoundments
         7.4.2  Other Concerns

Chapter 8:  Evaluation of Existing Federal Programs
     8.1  State Perceptions
     8.2  Federal Water Pollution Control Act and Clean Water Act
     8.3  Resource Conservation and Recovery Act
     8.4  Safe Drinking Water Act (P.L. 93-523) 1974
     8.5  Surface Mining Control  and Reclamation Act


                     CHAPTER 1:  EXECUTIVE SUMMARY
1.1  Introduction

This report summarizes the activities and findings of Wisconsin's Surface
Impoundment Assessment (SIA).  The SIA was begun in September 1978 under
a grant from the United States Environmental Protection Agency (U.S.
EPA) to the Wisconsin Department of Natural Resources (DNR).  Work was
carried out by a special project staff in the DNR Bureau of Water Quality,
with extensive assistance from the regular staff of the DNR, who provided
much needed information and advice throughout the course of the project.
The Wisconsin staff of the U.S. Soil Conservation Service (SCS) gave freely
of its time in providing extensive data to the SIA, and the Department of
Agriculture, Trade and Consumer Protection provided valuable assistance
on several occasions.  Personnel of the Wisconsin Geological and Natural
History Survey (WGNHS) and United States Geological Survey (USGS) worked
closely with SCS staff on some aspects of the project.

This report was prepared at the request of U.S.  EPA, and its organization
and subjects follow EPA guidance.  Material from this report is to be
included in a national report on the results of the SIA projects carried
out by every state.

1.2  Scope and Purpose of SIA

"Surface impoundments" are frequently described as "pits, ponds, or lagoons
used to contain liquid waste."  Some examples are absorption ponds for
disposal of industrial or municipal waste, stabilization lagoons, aerated
lagoons, manure storage ponds, mine tailing ponds, and fly ash settling
ponds.  All are located on the land surface and all share a potential to
leak contaminants to the groundwater; structures of concrete or steel
were excluded from the SIA.

The SIA was carried out to determine the extent to which surface impoundments
are used in Wisconsin, estimate the potential for groundwater contamination
from impoundments, and review the status and effectiveness of existing
government programs to control surface impoundments.

1.3  SIA Findings

Table 1-1  summarized the Wisconsin SIA.   Data for the inventory were
compiled from several existing sources of information, including DNR's
files on the Wisconsin Pollutant Discharge Elimination System (WPDES)
permit program, wastewater facility plan approval  program, and SCS records.
Inventory procedures are described in sec. 3.2.

Assessments of the groundv/ater contamination potential of 635 randomly
selected sites were completed using a system for rating the relative
hazards of waste disposal  sites that was developed for the SIA by U.S.
EPA.  Site geology and waste type are among the  factors considered in
this rating system, which is discussed in sec.  3.2.  The results of the
assessment, discussed in sec. 4.3, show that the wastes contained in the
state's surface impoundments generally have low hazard potential, but
that impoundment sites are highly susceptible to groundwater contamination.

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Chapter 5 is a review of hydrogeologic conditions abound the state,
including data on the shallow water tables and permeable aquifers that
make Wisconsin's groundwater a vulnerable resource.  Section 6.1 reviews
22 incidents of groundwater contamination traced to impoundments.

A review of state and federal programs that address impoundments is
presented in Chapters 7 and 8.  All non-agricultural waste impoundments
in Wisconsin are subjected to some form of regulation under one or more
of several programs administered by Wisconsin DNR.  Wastewater absorption
ponds must be permitted under the Wisconsin Pollutant Discharge Elimination
System (WPDES).  Such permits may be contingent on compliance with
certain requirements, such as limitations on the concentrations of
contaminant waters discharged to absorption systems.  Plans for wastewater
treatment facilities, including any treatment, storage or absoprtion
impoundments must be reviewed and approved by DNR water quality personnel
prior to construction.  A few impoundments are subject to regulation as
solid waste sites, and are subject to requirements for preliminary plan
approval  and periodic licensing.  Agency personnel report that impoundment
operators have generally cooperated with their efforts to enforce these

Agricultural waste impoundments are not subject to state regulation because
the state legislature, which has consisently opposed regulation of animal
wastes, has preempted the authority to make rules in this area.  Government
involvement with agricultural impoundments has been limited to the provision
of financial and technical assistance for design and construction.  Proposed
revisions to current state water supply regulations may include provisions
to control agricultural  impoundments to protect groundwater supplies from

1.4  Conclusions and Recommendations

The conclusions and recommendations of the Wisconsin SIA are detailed in
Chapter 2 of this report.

The State of Wisconsin has taken the initiative to regulate the use of
impoundments through several environmental protection programs (discussed
in Chapter 7), so the SIA sees no need at this time for federal regulations
to assist Wisconsin in this area.  However, the SIA has made several
suggestions on needs for improved record-keeping relative to impoundments,
for improved coordination of the requirements imposed by several programs
addressing impoundments, for improved control  over the closure or reuse
of abandoned impoundments, for research on land disposal  of wastewater,
and for improving the DNR's organizational and technical  capabilities in
the areas of groundwater protection and management.  Financial assistance
from EPA may be needed to implement some of these recommendations, and
the SIA recommends that EPA give high priority to state requests in this
area.   Animal  waste ponds are a subject of special concern to the SIA,
since these are proliferating, and there is little opportunity for government
involvement in assuring that groundwater protection is provided for, in
the design of construction of these ponds.  Several alternatives for
reducing  the threat to groundwater posed by animal waste ponds have been
discussed within DNR, and are reviewed in sec.  7.4.1.   No alternative
approach  is favored by the SIA.

Chapter 2:  Recommendations and Conclusions

2.1  Conclusions

2.1.1  Achievements of Wisconsin SIA

The Surface Impoundment Assessment (SIA) is the only comprehensive
inventory to date of waste impoundments in Wisconsin.  This inventory is
now available to state water quality and solid waste personnel for use
in reviewing the scope of certain disposal practices, identifying
facilities potentially subject to RCRA and state solid and hazardous
waste regulations and evaluating and planning for protection of the
state's groundwater quality.

The chief sources of data for the inventory were the records of the
Wisconsin Pollutant Discharge Elimination System (WPDES), which regulates
point source discharges of industrial and municipal wastes to state
surface waters and to land absorption systems from which liquids eventually
seep to the groundwater.  The inventory is deemed to be most complete in
the categories of active industrial and municipal impoundments, in which
almost 95% of the facilities are believed to have been located.  Coverage
of agricultural facilities is much poorer because no agency is responsible
for monitoring or regulating them.  The SCS personnel who supplied most
of the data for this category have reported that there are many impoundments
on which they have no information.  Data on abandoned impoundment facilities
is spotty.

2.1.2  Potential Pollution Hazard of Surface Impoundments

As discussed in Chapter 5 of this report, Wisconsin's permeable soils
and bedrock form productive aquifers that provide the state with an
abundant groundwater resource.  However, the same permeable materials
present few barriers to contaminant movement, leaving the state's
groundwater vulnerable to contamination.  This vulnerability is reflected
in the relatively high scores assigned to Wisconsin impoundment sites in
the first two steps of the SIA assessment process, which rate a site's
geologic susceptability to contamination.  Because of the nature of the
geologic environment, any waste handling or disposal practice (including
surface impoundments) that places wastes on (or in) the land must be
regarded as a significant potential hazard to Wisconsin's groundwater
quality.  The Wisconsin SIA has not reached any conclusion on the
relative magnitude of the potential hazard from impoundments, as compared
to other potential  contamination sources.  It is expected that Mr.
Thomas Calabresa will address the relative magnitude of various contamination
problems and make recommendations on future state priorities in reports
from his ongoing study (discussed in sections 6.1 and 8.2 of this report).

Impoundment use appears to be increasing, particularly in agricultural
and municipal  categories.  Farmers are increasingly using ponds to store
animal wastes for later field spreading, while municipalities required
to upgrade sanitary treatment often include ponds (for stabilization or
other purposes) in their new facilities.  Up to now reported contamination

problems traced to impoundments (see sec.  (6.1) have been local  in
nature.  Unless adequate design and construction features are provided
to prevent leakage, increased use of ponds can be expected to bring an
increased number of these local contamination incidents.   The Wisconsin
SIA is concerned that land disposal and treatment practices that place
wastes on the land surface (e.g.  in impoundments) are being oversold to
the public, that federal and state activities aimed at improving surface
water quality may be giving the public a false impression that these
alternative practices are pollution-free.    Animal  waste  storage ponds
are a practice of particular concern since these are frequently installed
without provision for groundwater protection, and tend to be relatively
close to private water supply wells which  are not routinely checked for
contamination.  Proliferation of agricultural ponds in susceptible
geologic settlings may also result in some groundwater degradation of
regional extent.

2.1.3  Status and Effectiveness of State and Federal Programs

Though there has been no federal  mandate for regulation of surface
impoundments, programs exist (or are being developed) to  monitor and
regulate all actively used impoundments at non-agricultural facilities.
However, there is no single program for impoundment regulation,  and
existing controls to protect groundwater vary with waste  type and waste
volume.  Government involvement in the design and operation of agricultural
impoundments is currently limited to design assistance provided on a
voluntary basis by the U.S. Soil  Conservation Service and financial
assistance available from special  state and federal sources, which can
make their grants contingent on conformance with design requirements.

A detailed review of the state and federal programs with  jurisdiction
over surface impoundments can be found in  Chapters 7 and  8 of this
report.  Though the SIA has identified a few problems, the overall
record of these programs in controlling potential sources of pollution
is an impressure one.  The SIA's recommendations include  several suggestions
for modifications in the administration of existing state programs, to
complete the development of a strong, integrated program to prevent (or
minimize) the contamination of groundwater by seepage from wastewater
impoundments.  The SIA has not identified  any areas in which new federal
regulations are needed to supplement or strengthen Wisconsin's program
for controlling the impacts of surface impoundments.

2.2  Recommendations

1)   Informatjon maintena n c e - Availability and maintenance of records
     on impoundments were subjects of particular interest to the SIA
     staff, since files recording data on  waste disposal  activities were
     consulted extensively in compiling the SIA inventory and preparing
     assessments.  Of more significance are the uses to which records
     may put in the future.  As illustrated by Fig. 2-1,  the residence
     times of groundwater contaminants are much greater than those of
     contaminants introduced to air or surface waters, and problems
     resulting from a discharge to groundwater may appear many years
     after the actual discharge occurred.   It is important, therefore,
     that records of groundwater discharges or storage of wastes on the
     land surface be available to be used by future generations who may
     have to deal with the unforeseen consequences of current disposal

As noted in sec.  3.2 of this report, the SIA staff found that important
items were frequently unrecorded in the DNR wastewater files, which were
the principal source of data for the SIA.  For example, as shown in
Table 4-17, information on impoundment liners was available for only
about 40% of the assessed industrial treatment of storage impoundments.
Other construction data and records on site geology were also frequently
unavailable.  Because the waste inventory files of the Environmental Fee
Program (NR 101)  include detailed waste characterizations for many
industrial factilies, availability of data on the wastes in impoundments
is excellent.  To improve the availability of data on waste disposal
practices that may affect future groundwater quality, the SIA recommends:

     Materials to be retained in microfilmed records of wastewater plan
     approvals should be specified in writing, to ensure consistency in
     this area.  This material should include (at minimum) records of
     any soil borings, descriptions of any impoundments or other surface
     arrangements for disposal or storage of wastes, including liners to
     be used, and characterization of wastes to be treated, stored or
     discharged at the facility.

     WPDES permit records ought to include a brief synopses of facility
     ownership and activities, permit requirements, and other information
     likely to be needed by persons (e.g., new employees, DNR legal
     staff, person engaged in special  projects) reviewing the file.  The
     Industrial Wastewater Section employs a "briefing memo" to convey
     this information; a similar system is being adopted by the Municipal
     Wastewater Section.  Information identified as important by the SIA
     staff includes:

          Facility location maps (preferably on a topographic map or air
          photo base).

          Description (or flow chart)  of treatment and disposal  practices.

          List of permit limitations and monitoring requirements, with
          references to any regulations or technical documents used in
          developing requirements.

     A list of other DNR records on the facility's disposal practices
     should be displayed in a prominent place, such as the inside cover
     of the file  folder.  Former facility names or owners should be
     noted here,  as well as applicable plan approval numbers and NR 101
     file numbers.

2)   Coordination among programs - Surface impoundments are currently
     regulated by both the wastewater and solid waste programs of the
     DNR.   While  the different waste types have different handling
     requirements and may pose different degrees of hazard to the
     groundwater, the existence of overlaps in program jurisdiction (see
     sec.  7.3) is evidence of basic similarities between wastewater
     treatment lagoons and solid waste disposal  lagoons.   As detailed in
     Chapter 7, the different sections administering these programs have
     different operating policies on such matters as lagoon liners and

     groundwater monitoring schedules for approved facilities or permits.
     Now that agreements have been reached to minimize program overlaps
     (discussed in Sec.  7.3), the SIA recommends that the wastewater and
     solid waste programs work together to coordinate teclmical  guidelines
     for solid waste disposal and wastewater treatment facilities that
     will guarantee regulatory consistency by providing equivalent
     levels of groundwater protection.   Such guidelines would not be
     uniform, but would  be designed to  provide levels of protection
     appropriate to differing waste hazards and mobilities,  while allowing
     special provisions  for special treatment needs (e.g., minimum
     depths for effective operation of  stabilization lagoons).

3)   Animal waste ponds  - Animal  waste  ponds are a particular concern of
     the SIA, for reasons outlined in sec. 7.4.1.   The SIA recommends
     the continuation of efforts  by personnel of the DNR and other
     agencies to ensure  that manure is  not stored in ponds with high
     potential for polluting groundwater.  This goal might best be
     achieved through a  combination of  activities, including improvements
     in SCS guidelines for animal waste ponds, expansion of cost-sharing
     programs or other incentives, revisions in the state water well
     code, enforcement of design  or siting criteria by the Grade A
     producers permit program, zoning or building regulations at the
     county level, and/or public  education efforts aimed at increasing
     farmers' awareness  of the potential  threats to water quality posed
     by poorly designed  waste ponds.

4)   Absorption ponds -  Section 4.3.2 notes the existence of several
     absorption ponds that once received relatively hazardous wastes,
     but now receive only treated wastewaters.  Continued discharge of
     any liquid to any absorption area  where there is a residual hazardous
     sludge or where the soil or  aquifer has been contaminated with such
     a material promotes the continued  migration of a potentially
     hazardous material  unless it can be shown that all sludges and
     contaminated soils  have been removed and disposed of safely.

5)   Research needs - Land disposal of  wastewater, including use of
     absorption ponds, is usually regarded as an acceptable method for
     disposing of organic wastes  (domestic waste, food processing waste,
     etc.)  These systems rely on aerobic decomposition and other processes
     in the soil to provide treatment of wastewaters.  DNR's technical
     guidelines, discussed in sec. 7.2.1 of this report, were prepared
     in 1975 based on data available at that time, before many of the
     existing systems were built.  Questions are sometimes brought to
     the DNR regarding the groundwater  impacts of land disposal  systems,
     but the technical information needed to answer them is not always
     available.  The SIA recommends to  DNR that a re-evaluation of the
     behavior of land disposal systems  be undertaken to provide information
     on the efficacy of waste treatment under different field conditions.
     This information should be useful  in selecting optimal  designs and
     operating schedules (for use in preparing plan approvals and system
     permits) to minimize groundwater impacts, and in providing the
     desired information to concerned members of the public.

One important component of this study would be the analysis of the
groundwater monitoring results submitted to DNR by WPDES permittees.
Development of computerized systems for management of these data
(as discussed in sec. should be given high priority, as a
means of improving the department's capabilities for analysis of
monitoring results, as well as for coping with the sheer volume of
data.  A review of recent technical literature should be a part of
this effort, but most recent work has taken place in other regions,
so the principal effort must be aimed at developing data that is
specific to Wisconsin conditions.  To supplement data from routine
monitoring intensive field study (involving more extensive groundwater
and seepage monitoring) should be undertaken at a few sites to
analyze the impacts of different hydraulic loading rates, vegetation
management practices, hydrogeologic conditions and other factors on
the quality of the liquids reaching the groundwater.  Existing
systems will allow ample selection of study sites representing a
broad range of site conditions, and it may be possible to manipulate
some operating factors as an experiment to provide additional data
on system behavior.  The study described might be carried out as a
cooperative effort with one or more of the agencies charged with
groundwater-related or engineering activities.  Outside financial
support would probably be needed for such an effort, so the SIA
recommends that U.S. EPA make funding available for this research
if DNR chooses to pursue it.

Groundwater r e s po ns i b i 1 i t i e s - Responsibilities for groundwater
protection are now spread out across several jurisdictional areas
of DNR, without specific central coordination, and several sections
with responsibilities in this area now lack direct access to
personnel with the necessary expertise in the groundwater area.
The SIA found, for example, that some wastewater personnel are
poorly prepared to evaluate hydrogeologic data, and suggests (sec. that present wastewater personnel with appropriate training
could provide needed assistance in this area.  Some other needs
would require additional staff (or reassignment of present personnel).
For example, several DNR staff members with groundwater responsibilities
have expressed a need for a staff scientist to specialize in ground-
water chemistry, to assist in tracing contamination problems and in
interpreting monitoring data from some landfills and wastewater

Several different strategies have been proposed within the state to
meet perceived needs for coordination of groundwater policy,
development of improved staff expertise in the groundwater area,
and for ensuring that technical resources are available to provide
advice and to carry out special analyses.  The SIA recommends that
the DNR give high priority to resolving questions on the best means
of providing for coordination of groundwater planning and for
improved access to groundwater expertise and to implementing any
changes in organization or staffing needed to achieve these ends.
The SIA also recommends that U.S. EPA provide the DNR with financial
assistance to implement these changes, particularly if additional
personnel are required.

      A b a r^d oried _imp o undments - Unless all solid waste residues are
      removed, old impoundments for disposal, storage or treatment of
      liquid waste may threaten groundwater quality through continued
      leaching.  As described in sec. 7.2.2 of this report, Wisconsin's
      solid waste laws and regulations include several provisions to
      ensure that closed or abandoned solid waste sites are closed according
      to established procedures and cared for after closure.  Though most
      wastewater impoundments do not contain biodegradable wastes and do
      not carry a long-term threat, the DNR should explore means of
      ensuring that impoundments containing persistent wastes are cleaned
      out when they are abandoned, even if the owner or operator has
      declared bankruptcy.  (It is hoped that most or all such sites will
      be subject to jurisdiction of the hazardous waste program, which
      would require both proper closure and some assurance of long-term
      financial responsibility.)

      Water quality planning - To ensure that the public is not mislead
      in this area, the potential groundwater impacts of any proposed
      land disposal systems, surface impoundments for waste treatment,
      and similar practices should be addressed along with their advantages
      whenever plans for reduction of surface water pollution are presented
      for public consideration.  Because available financial sources
      appear to be fully allocated for other purposes, additional financing
      under programs such as section 208 may be needed if the state is to
      make groundwater evaluations a part of its water quality planning
          Fig.  2-1   Time of pollutant residence in vicinity of discharge site
Decades    Centuries





                      CHAPTER 3:  METHODOLOGY

3.1  SIA Organization, Funding and Staff

The Bureau of  Water Quality of the Wisconsin Department of Natural
Resources (DNR) received a grant of $80,900 from U.S. EPA to complete
the Surface Impoundment Assessment for Wisconsin.  The SIA staff comprised
seven employees of the Wisconsin DNR, one Wisconsin Geological Survey
hydrogeologist and one independent consulting hydrogeologist.   Three SIA
staff members attended the SIA training session held in Minneapolis in
September 1978.

The following persons were members of Wisconsin's SIA staff:

David Daniel, SIA project coordinator
     Engineer IV, Wisconsin DNR, Bureau of Water Regulation and Zoning.
     BS Agricultural Engineering.
     MS Water Resources Management.
     MS Agricultural Engineering.
     Six years experience as an Environmental Engineer.
     Attended SIA training session.

Michael Collentine, Natural Resource Specialist I (part time),
     Wisconsin DNR Bureau of Water Quality.
     BS Geology.
     MS Water Resources Management.
     Attended SIA training session.
     SIA tasks:  Inventory of industrial and mining
          facilities.  Assessments.  Evaluation of federal and state
          programs.  Final report.

 Timothy Kessenich, Natural Resource Specialist I (full time),
     Wisconsin DNR Bureau of Water Quality.
     BS Geology.
     Post graduate study in Quaternary Geology.
     Three years experience as a Research Physical  Scientist at the
          Great Lakes Environmental Research Laboratory.
     SIA tasks:  Inventory of industrial facilities.  Assessments.
          Research on water table aquifers.  Aerial  photo and  topo-
          graphic map verification of inventory.  Final report.

Anthony Mellini, Natural Resource Specialist I (part time),
     Wisconsin DNR Bureau of Water Quality.
     BS Geology.
     SIA tasks:  Assessments.  Study of the potential value of a new well log
          retrieval system for use in the assessment process.

Ellen D. Smith, Natural Resource Specialist I (full  time),
     Wisconsin DNR Bureau of Water Quality.
     BA Geology.
     MS Water Resource Management.
     MS pending, Geology.
     SIA tasks:  Assessments.  Data analysis.  Evaluation of state
          programs.  Final report.


Mary A. Soderberg, Natural  Resource  Specialist I  (full  time),
     Wisconsin DNR Bureau of Water Quality.
     BS Rural Sociology.
     SIA tasks:  Inventory and assessment of agricultural  and  municipal
          facilities.   Preliminary drafts for final  report.

Janet Eberhart, Planning  Analyst (part time),
     Wisconsin DNR Bureau of Water Quality.
     BA Music.
     Three years experience as a data processor at Madison Academic
          Computing Center.
     SIA tasks:  Computer data entry and editing.

Bruce L. Cutright, Hydrogeologist (part time),
     Wisconsin GeolCjical and Natural History Survey.
     BS Geology.
     MS Geology.
     PhD candidate Geology (Hydrogeology).

SIA tasks:   Independent review of state and federal  programs.   Review of
     impoundment liner performance.   Liaison with  research project
     on manure storage impoundments.

Steve Smith, Consulting Hydrogeologist.
     BS Geology.
     MS Geology (Hydrogeology).
     MS Water Resources Management.
     Attended SIA training session.
     SIA tasks:  Coordinated assessment procedures.   Shallow aquifer map.

The SIA project was completed in three phases:  inventory, assessment
and verification.  The inventory included locating,  counting,  and describing
wastewater facilities which use surface impoundments.   Additional data for
Section II of EPA's data form, relating to physical  description, operational
characteristics and types of waste,  were gathered  for each facility

Facilities to be assessed were then  randomly selected from the inventory.
One randomly selected impoundment at each of 635 randomly selected
facilities was assessed,  using the procedures outlined in "A Manual for
Evaluating Contamination Potential of Surface Impoundments"  (Silka
and Swearingen, 1978).

Verification was accomplished by topographic map and aerial photo study
and from information supplied by DNR staff.  Additions and corrections
to the  inventory were submitted to EPA up to August 1979.

3.2  Inventory  Procedures

3.2.1   Types of Facilities Inventoried

For the inventory, a surface  impoundment was defined as a natural topo-
graphic depression, artificial excavation or dike arrangement which:
1) is  used primarily for storage, treatment, or disposal of wastes in
the form of  fluid and  2)  is constructed above, below or partially in
the ground,  and 3) may or may not have a permeable bottom and/or sides
allowing  infiltration of its contents.   Examples of surface impoundments
are waste storage ponds, treatment  lagoons and seepage pits.


In accordance with EPA technical guidance #6 certain structures and
types of facilities were excluded from the inventory because it was felt
that they posed minimum threat to ground water.   Structures built entirely
of poured concrete, such as clarifiers, trickling filters, sludge drying
beds or aeration basins, were not included.   Sand and gravel washing
operations, cranberry bogs, irrigation pits, fish rearing ponds, and
impoundments built for erosion and runoff control were also excluded.

Ridge and furrow irrigation systems, parallel  trenches used to dispose
of wastewater by soil infiltration and evapotranspiration, were not
considered to be impoundments.  A properly operated ridge and furrow
systems does not contain standing water.  An overloaded system, however,
takes on the characteristics of a seepage pond.   Because of this potential
for ponding, the Wisconsin SIA collected data on ridge and furrow systems
for use by the DNR, but did not include these systems in the SIA inventory.

Spray irrigation facilities for disposal of wastewater were also excluded
from the inventory.  As with ridge and furrow systems the potential for
hydraulic overloading and temporary ponding exists.

Facilities on Federal or Indian lands are not subject to state regulation,
so information on these sites is not available from Wisconsin DNR records.
There are estimated to be 15 such facilities using impoundments in the
state, none of which were inventoried.  Information on these sites may be
added at a later date.

3.2.2  Inventory Categories

Facilities inventoried were placed into one of six major categories
based on principal SIC (Standard Industrial  Classification) code.
Facilities within each category were then placed into an Active or
Abandoned subcategory depending on whether or not the facility's im-
poundments are currently used.  If a  facility had multiple impoundments,
some of which were currently used and some not currently used, it was
classified as an active site.  Unfortunately,  the status of an abandoned
impoundment within an active facility could not be noted in the inventory
unless it was randomly selected for assessment.   The inventory categories
established by EPA are:

                                        Active       Aba ndo ned

Municipal                                MUN            AMU

Industrial                               IND            AIN

Mining                                   MNG            AMG

Agricultural                             AGR            AAG

Oil and Gas                              OAG            AOG

Other                                    OTR            AOT


The municipal category included privately owned facilities with waste flows
made up exclusively of sanitary waste water, as well  as publicly owned
sewerage treatment works which may or may not treat industrial  waste
with the domestic flow.   Municipal facilities have been assigned the SIC
code of 4952 to designate the waste as domestic sewerage.

The industrial category included public and private facilities  engaged
in food processing, stone quarrying, manufacturing, transportation, crop
services, electric power generation and water supply.

In Wisconsin the mining category was limited to metal  mining,  SIC codes
1000 through 1099.  Quarrying and dimension stone production were placed
in the industrial category, and, as noted in sec. 3.2.1, sand and gravel
operations were excluded from the inventory.

Agricultural facilities were defined as those with impoundments used for
liquid wastes or slurrias from crop and animal production, major SIC
codes of 01 and 02.

Oil and Gas facilities are defined as those with liquid wastes  from the
extraction of oil and gas, major SIC code of 13.  None are found in
Wisconsin.  Refineries and petroleum terminals were classified  as IND.

The Other category was established by EPA to include those facilities
with impoundments for uses of an unusual nature or where a category was
uncertain.  This category was not used by the Wisconsin SIA.

3.2.3  Sources of Data  General

Data for the inventory of facilities in the Municipal, Industrial and
Mining categories were gathered from Wisconsin Pollutant Discharge
Elimination System (WPDES) permit files and Facility Plan Approval files
maintained by the DNR Bureau of Water Quality.  No central file exists
for agricultural facilities in Wisconsin, but a partial inventory was
compiled from DNR records, through a survey of USDA Soil Conservation
Service (SCS) county offices, and from records of the Wisconsin Department
of Agriculture, Trade and Consumer Protection.  Many abandoned sites
were identified from old correspondence records maintained by the Wisconsin
DNR and its predecessors in the  water quality area (State Committee on
Water Pollution and State Department of Health).  Industrial, Municipal and Mining

Since most industrial, municipal or mining facilities that use impoundments
hold WPDES permits for their discharges to surface waters or land disposal
systems, initial lists of facilities for the SIA inventory were prepared
from DNR files on WPDES permittees.  The Municipal Wastewater Section had
reviewed its files in 1978 to compile a list of all permitted facilities,
showing the treatment processes and disposal methods used at each
facility.  The SIA used this list to compile a preliminary list of municipal
impoundment sites.  No such list was available for industrial permittees,
so SIA staff systematically reviewed all the permit files of the  Industrial
Wastewater Section to identify industrial and mining facilities using
surface impoundments.

Additional facilities were located through review of card files compiled
in 1969 and 1972 by the Bureau of Water Quality, listing wastewater
facilities existing in those years.   Futher information on sites located
in this manner could usually be obtained from the microfiched records
of facility plan approvals.  Additional industrial sites were located
through the assistance of the DNR Bureau of Solid Waste, which requested
that its district solid waste coordinators provide the SIA with lists
of licensed solid waste sites that include impoundments.

Descriptive data for the inventory came from several sources.

The WPDES permit files were a good source of data on type of treatment,
location, and ownership of inventoried facilities.  Since Municipal and
Industrial permits are administered by separate sections within the
Bureau of Water Quality, there were minor differences in the format of
records available for the two categories.  Each industrial permit record,
for example, contained a one page summary or "Briefing Memo" which
greatly speeded up the inventory process.

Under WPDES each facility is required to monitor its discharge and
submit self-monitoring reports (SEMORE's) to the DNR.  These were the
chief source of influent and effluent data available to the SIA.  Flow
monitoring data varied from facility to facility and were often incomplete.
For municipal facilities the total average waste stream entering a plant
was recorded as the "average daily influent to all impoundments".  Monitoring
of effluent flow rates is not required of most municipal facilities.
For industrial facilities, monitoring data were most complete for total
inflows to seepage pond systems and for total effluents at the outfalls
of treatment systems.  Virtually none of the facilities with multiple
impoundments had flow data broken down by individual impoundment, as
requested on EPA data forms,

Field inspections, or "Compliance Monitoring Surveys," of dischargers
are conducted by DNR on a regular basis.  Major dischargers are surveyed
once per year.  All others are surveyed at least once every 5 years,
though 3 years is a more normal interval.  Records of compliance monitoring
inspections maintained in Industrial and Municipal Wastewater files
were of great value to the SIA.

The primary source of impoundment descriptions and on-site soil boring
records was the facility plan approval file.  These files contain microfiche
copies of plans, specifications, and correspondence relating to the
construction or modification of wastewater treatment plants.   Over 90%
of the municipal facilities inventoried were included in the plan approval
files.  Initially, the state's wastewater plan approval requirement did
not apply to industries, so plans for fewer than 50% of the industrial
sites were on microfiche.  On-site soil boring records were available
for only a few facilities.  Agricultural Facilities

There is no comprehensive permit system for agricultural facilities in
Wisconsin, so there is no one central file of agricultural facilities.
Data were collected from three different agencies:  Wisconsin DNR, the
Wisconsin Department of Agriculture, Trade and Consumer Protection, and
the U.S. Soil Conservation Service.


The DNR Industrial  Wastewater Section has a correspondence file containing
agriculture] wastewater facility plan approvals  for those farms that
have requested that the DNR review their plans.   The plans are not
retained by  the DNR; only details mentioned in  the letter of approval
are on file. Letters of complaint and correspondence on any follow-up
action involving agricultural waste problems occasionally mention the
method of waste handling on a farm.  These files provided partial information
on 35 agricultural  sites in the state.

The U.S. Soil Conservation Service (SCS) does maintain records of those
agricultural waste ponds that the agency has assisted in designing.   The
SCS provided the SIA with information on 365 farms using surface impoundments
To protect the privacy of the farmers who voluntarily asked for SCS
assistance, SCS did not release the names of the owners of the farms.

Dairy farmers applying for Grade A milk ratings  must submit to the De-
partment of Agriculture, Trade and Consumer Protection plans of their
farms, showing waste handling areas and manure ponds (if any) and well
location, as well as descriptions of their livestock.  The department
was cooperative but much of its information was  incomplete.

A large number of impoundments have been constructed without any governmental
involvement.  Because of the difficulty in locating these ponds and
because there appears to be little variation in  the size of agricultural
impoundments or in the waste characteristics, no effort was made to
inventory these impoundment sites.  However, SCS district personnel  made
estimates of the total numbers of agricultural ponds in their areas, and
the SIA used these to derive an estimate of the  statewide total.

Most of the agricultural sites were located by quarter, quarter section
in the records of the three reporting agencies.   In order to better
locate and assess the site the SIA asked for information on the distance
from each pond to nearby wells and surface water bodies.  Plat maps,
topographic maps, or air photos were used in locating each site.

Flow is not monitored at any of the agricultural impoundments.  The  SCS
was asked to estimate the influent of SCS designed ponds based on the
number and type of livestock reported during the year of construction.

3.2.4  Data Collection

The Wisconsin SIA set up an in-house computer file for inventory and
assessment data.  A one page form  (Figure 3-1) was designed to include
all items on the EPA forms, as well as additional information gathered
at the request of the Bureau of Water Quality.  Data were entered on DNR
computing facilities and transmitted by phone lines to US EPA.

The additional data for in-house use included the design population
basis, design flow, daily design loading rate of BOD, and mode of operation
for each municipal facility.  The USGS quadrangle, DNR facility plan
approval number, and WPDES monitoring requirements were recorded for all
categories.  Wisconsin's modified form also allowed the listing of each
impoundment at a facility, including its purpose, size and liner type.


Facility locations were entered by Town/Range coordinates to the nearest
% of % section.  Latitude and longitude were calculated from these
values by computer program, resulting in a location accuracy within 10
seconds of arc (approximately 200 m).  Facility location maps for most
of the Industrial sites are contained in the permit files.   The locations
of municipal facilities had to be determined from the plan  approval
files, which usually include maps.  The location of each impoundment was
plotted on the proper USGS quadrangle to provide a permanent inventory
record and for later use in the assessment process.

Owner/operator information was available for each facility  with a WPDES
permit.  For abandoned sites the name of the entity which had last
operated the facility was used regardless of present ownership of the

The amount and quality of section II (impoundment description) data
varied greatly from facility to facility.  Influent and effluent flow
volumes were rarely monitored (for individual impoundments) in systems
with multiple impoundments.  In the municipal category, total influent
to all impoundments was usually monitored, but total effluent flow
volume was not.  In the industrial category, total influent to seepage
cells was usually monitored, as was total effluent from treatment systems.
Flow volumes for those industries which operated seasonally (i.e. vegetable
processors' canning factories)  were recorded as the rate in gallons per
day averaged over the period of operation rather than the entire year.  Liner
information is frequently incomplete within the state files.  When
possible, liner type was noted.  Frequently, however, the thickness was
not recorded in facility plans.  Absorption or seepage ponds were assumed
to be unlined.

The exact date that any given facility commenced operation  was often not
recorded in department files.  If a facility had a plan approval its age
was estimated at 1.5 years after date of approval to give allowance for
contract bidding and actual construction.

3.3  Assessment Procedures

3.3.1 Random Selection of Impoundments

When the file search inventory was complete, sites to be assessed were
randomly selected by use of the random number generator in  the Minitab
statistical computing package.

Initially 600 sites were selected, comprising 200 municipal, 200 industrial
and mining and 200 agricultural sites.  (No oil and gas sites were
located or assessed.)  Abandoned sites within each category were included
in the selection process.  As time permitted an additional  35 industrial
sites were assessed, bringing the total to 635 facilities.

Only one impoundment was assessed at each randomly selected facility.
If a facility has multiple impoundments, the impoundment to be assessed was
selected by a random number technique.

3.3.2  Assessment of Contamination Potential  SIA Rating System

Wisconsin employed the uniform SIA rating system to assess  the pollution
hazard potential  of surface impoundments, as  described by Silka and
Swearingen, 1978.  This system was developed  by the US EPA  Office of
Drinking Water, based on work originally done by H.E.  LeGrand.   The SIA
rating system was designed to be used without field investigations of the
impoundment sites.  Activities such as earth  material  sampling, ground
water sampling, measuring ground water elevations and  flow  directions,
etc., are too costly and time consuming to be undertaken at each of the
impoundments assessed in this study.   Therefore, geologic information for
SIA impoundment ratings was derived from existing data sources, such as
construction and engineering reports  (where available), USDA county soil
surveys, driller's logs from nearby water wells, USGS  Hydrologic Atlases,
USGS Water Supply Papers, and topographic maps.

The assessment scores do not indicate the existence or the  degree of
groundwater contamination at any assessed impoundment.  The scores do
provide a first order approximation of the groundwater contamination
potential for a particular impoundment relative to that of  other assessed

Step 1, Rating of the Unsaturated Zone, provides a measure  of the
relative potential for contaminants to reach  the water table.  Scores for
this step range from 0 to 9, with higher scores indicating  greater
potentials for waste movement.  Scores are assigned according to the
thickness and permeability of the earth materials between the bottom of the
impoundment and the top of the saturated zone.  If the unsaturated zone
consisted of strata of different permeabilities, the score  was based on
the thickness and permeability of the least permeable  layer.  Liner
materials were not rated as part of this step, which addresses site
characteristics only.

Step 2, Rating of the Saturated Zone, provides a measure of the relative
groundwater availability and the potential rate of movement of contaminants
in the saturated zone beneath the impoundment.  Scores are  based on
aquifer permeability and aquifer thickness, with higher scores indicating
greater thicknesses and permeabilities (thus  greater potential rates of
movement).  In cases where the saturated zone consisted of strata of
different permeability, the rating was based  on the texture and thickness
of the most permeable material.  Scores for step 2 range from 0 to 6.

EPA guidance (Silka and Swearinqen, 1978) established  hydrologic types
of aquifers for purposes of this  step in the  assessment.  Type I aquifers,
the most highly permeable, consisted of unconsolidated sand and gravel,
fractured or cavernous dolomite, and poorly cemented sandstone.  Most of
Wisconsin's shallow aquifers fall into one of these groups  and are of
sufficient thickness to rate scores of 5 or 6.  Type II and III aquifers
are of progressively lower permeability and consisted  of lacustrine silt
and clay, glacial till, siltstone, shale, and dense crystalline rocks.

The greatest difficulty in determining Step 1 and Step 2 scores was lack
of site-specific data for small industrial sites and agricultural
impoundments.  Private water supply well logs were often the next best

source, but, they had to be used with caution.   In the glaciated areas
of Wisconsin surficial  geology is often too complex to permit reliable
extrapolation of well log data to the impoundment site.   Drillers'
descriptions and terminology are often inadequate to characterize the
hydrologic properties of materials in the unsaturated zone.   In addition,
finding appropriate logs was difficult because  the present DNR filing
system does not enable log retrieval  by well  location.

Scores for Step 3, Rating of Groundwater Quality, indicate the potential
for using the local groundwater as a  water supply.  Generally, scores
are based on the total  dissolved solids (IDS) concentration of ground-
water at an impoundment site, with the highest  scores (5) assigned sites
with high quality water (IDS5.500).  However, if the groundwater is used
as a source of drinking water the maximum rating was assigned regardless
of IDS.  A potable water well located within 1600 meters of an impoundment
was taken as evidence that groundwater was being used.  The locations of
municipal water supply wells with respect to an impoundment were readily
available from DNR records.  In rural areas, farmsteads  and homesites
shown on topographic maps, plat maps  and orthophoto quads were assumed
to represent the approximate locations of water wells, since virtually
all rural and suburban homeowners in  the state  rely on private wells.
Based on available groundwater quality studies  and well  location data,
all assessed impoundments in Wisconsin received Step 3 ratings of 5.

Step 4, the Rating of Waste Hazard Potential, rates contaminants that
may enter groundwater on the basis of their potential for causing harm
to human health.  Scores ranging from 1 to 9 were assigned according to
guidance in Silka and Swearingen (1978), based  on the identification of
the waste contained in the assessed impoundment.  If this was not
known, or if waste characteristics could not be matched  to the list
provided, the score was estimated on  the basis  of Standard Industrial
Classification (SIC) of the discharger.  Where  a range of hazard values
was given for a specific waste type or industry, the score was determined
by the extent of pretreatment or on chemical  analyses contained in self
monitoring reports submitted under WPDES.

Since the NR 101 files (discussed in  sec. of this report) were
not used in the assessment process, specific waste characterizations  or
chemical analyses were not available  for the majority of industrial
impoundments.  As a result most were  rated according to  the general
waste type, as defined by the SIC code.  For food processors (cheese
factories, vegetable canneries, and meat packers) this was not con-
sidered to be a problem, since process wastes for these  industries are
reasonably uniform and have a comparatively low hazard potential (2-4).
In a deviation from EPA guidance, cheese factory ponds known to receive
untreated whey were rated at 3 (instead of the  EPA recommended value  of
2 for the dairy product SIC group, 202) to reflect the greater strength
of the waste.  In a few cases where industrial  impoundments had at one
time received more hazardous wastes than they now receive, scores were
based on the highest hazard wastes ever contained in the pond.

Detailed -information was not readily available  concerning  the  type  of
industrial  wastes entering a municipal  facility.   A  polishing  pond  or  an
impoundment with a flow of less than 10,000 gpd where there  was  no
evidence of industrial  waste was given  a  rating of '2'.  Most  municipal
facilities  received a '3', '4', or '5', depending  on the flow  volume,
known wastes and the amount of pretreatment.   For  example,  if  greater
than 50% of the flow was known to be canning  wastes, the impoundment was
rated according to the  canning wastes.

Virtually all  of the assessed agricultural  impoundments are  used for
manure storage.  Impoundments at dairy  farms  were  assigned  a Step 4 rating
of 4 based  on the waste ID, 1702 (Dairy Wastes).   Concentrated animal
feeding operations (defined in Table 4-5) were  assigned the  higher  waste
hazard score of 5 listed for waste ID 1703, feedlot  wastes.

Step 5, The Groundwater Contamination Potential,  is  the sum  of scores
for Steps 1 through 4,  and represents the overall  groundwater  contamination
potential of the impoundment.

Step 6  of  the assessment was a rating  of Potential  Endangerment to
Current Water Supplies.  Groundwater contamination presents  a  hazard
to health if the anticipated flow of a  waste plume from an  impoundment
is likely to intersect  either a well or surface water supply.   Step
6 ratings estimate the  potential for contaminants  from an  impoundment  to
reach currently used drinking water supplies.  Factors considered in
this step are anticipated direction of  waste plume movement  and distance
from the impoundment to wells or surface  water  sources.

Since very  few detailed hydrogeologic studies of assessed  impoundment
sites were  available, the direction of  waste plume movement  was most
often inferred from site topography.  It  is difficult to retrieve precise
information on private  well locations without field  visits,  so well
locations were inferred from the locations of rural  farmsteads or homesites
as shown on topographic maps or orthophoto quadrangles.   "Surface water
supply" was defined as  any lake or stream.   Intermittent streams were
included if they are known to have base flow during  part of  the year.  Confidence Scores

As directed by EPA, confidence levels of  A, B,  or C were assigned to
each step in the site evaluation process  to reflect the  quantity and
presumed quality of the data used in determining the score for that
step.  In general, those Step 1, 2 and 3  ratings based on  site specific
data, such  as soil boring logs, on-site well  logs  or detailed  hydro-
geologic studies, received the confidence score of  'A1.  This  score was
also assigned in areas  of uniform geologic conditions (e.g., glacial out-
wash plains or river terraces, or thick Paleozoic bedrock  aquifers)
where local or regional data was available.  The B confidence  level was
assigned to ratings based on local or regional  data such as  county  soil
surveys, USGS Water Supply Papers, etc.  The lowest confidence level,  'C',
was assigned to ratings based on generalized data, such  as state-wide
geologic and aquifer maps, and hydrogeologic interpretations derived
from USGS topographic maps.   'B' and 'C'  scores were sometimes assigned
in Step  1 where data availability was quite good,  but highly variable
surficial materials reduced the confidence of the person  preparing  the

If the waste hazard score (Step 4) was determined on the basis of actual
waste characteristics (or chemical analyses) the "A" confidence level was
assigned.  If it was estimated from the Standard Industrial Classification
(SIC) of the industry using the impoundment, the "B" confidence level
was used.  Miscellaneous Identifiers

EPA's data system for the SIA allows for several "miscellaneous identifiers"
to be used to designate special site conditions.  The Wisconsin SIA
used two miscellaneous identifiers in addition to those defined in the
EPA guidance.  The identifier "X" was used when well locations in the
general area of the impoundment were not known.  Any impoundment which
had highly variable influent/effluent volumes due to seasonal  use or
fill and draw operation was identified with a "V".

3.4  Verification of Inventory

Verification of the location and count of impoundments included a topographic
map and aerial  photo investigation, some field visits by SIA staff, and a
review of facility lists by both DNR headquarters and district engineers.

During the inventory all facilities with impoundments located  in the
file search were plotted on the largest scale U.S.G.S. topographic map
available.  County plat maps were consulted if ownership or location of
a facility was in doubt.  Additional sites noted on the maps were rechecked
against WPDES files, and if a site was not covered  by a permit, DNR
district personnel were contacted to aid in identification of  the site.
As a means of verifying the completeness of the SIA inventory, a special
search of the most recently issued 7.5 minute quandrangles was made.
Forty-six 1:24,000 quadrangles published in 1978 became available
late in 1979, after the inventory was closed.  The inventory included
118 facilities located in the areas covered by these new maps.  The
topographic maps were of limited value for verifying the SIA inventory.
Over 70% of the known 118 impoundment sites in the mapped areas were  not
depicted on the maps.  But the study of these maps did reveal  5 additional
sites not included in the file search and 2 additional ponds at sites already
counted in the initial search.

Sauk County was selected for a test of aerial photo verification.   The
imagery available was black and white infrared, flown in August 1978  at
a print scale of 1:20,000.  Sauk County had a total of 32 impoundment
sites in the inventory.  Study of the aerial  photos found that 14 municipal
sites and 6 industrial sites were accurately located and described in
the original inventory.  No additional sites were found in these two
categories.  Of the 12 agricultural sites reported by SCS, one could  not
be found on the imagery at the location given.  Two additional sites  in
the agricultural category were located on the photos.  There are no
metallic mining or oil and gas facilities in Sauk County.


The main problem encountered in the aerial  photo survey was determining
whether or not rural  impoundments contained wastewater.  Most of the
impoundments were used for stock watering or runoff control and thus
excluded from the inventory.  Also, during  the summer months some of the
manure storage ponds  were empty and thus difficult to detect on the
infrared imagery.

Further verification  of the SIA inventory was accomplished through the
cooperation of field  personnel  at the DNR Southern District Office.  An
SIA inventory list of all industrial  and municipal facilities in the
Southern District, a  14 county area of southern Wisconsin, was sent to
the district offices  for review, comments,  additions and deletions.  As
a result of this review, three additional active municipal facilities,
with a total of six impoundments, were located, and are to be transmitted
to EPA at a later date.  The construction of two of the facilities
postdated the original inventory.

The files maintained  by the NR 101 (Environmental Fee) Program (see sec. of this report) include data  on industrial facilities that
discharge to municipal wastewater treatment plants and are not required
to have WPDES permits.  Because they are not included in the WPDES
permit system, some sites in the NR 101 files may have been overlooked
in the original inventory.  A search  of NR  101 records on industries
which discharge to municipal treatment works uncovered one active industrial
facility using two impoundments for wastewater treatment.  Since the NR
101 system does not cover most facilities which discharge less than
10,000 gpd, there may be several small industries using impoundments
that have not yet been identified.

3.5  Methodology of Data Analysis

Data from Wisconsin's SIA were entered into a Wisconsin DNR computer
file and transmitted  by phone lines to U.S. EPA.  The computer file
retained in Wisconsin was intended for use  in in-house data analysis, as
well as to form a permanent state record of wastewater impoundments.

Twenty-nine variables were selected from the SIA data base for use in
data analysis.  (See  Table 3-1).  While the 16 variables describing
assessment results were available only for  the 635 assessed sites, the
data analysis used site descriptive data and variables describing a
single randomly selected impoundment at each site in the inventory.

Data analysis was carried out on the facilities of the Madison Academic
Computing Center (MACC) of the University of Wisconsin - Madison.

Sites were sorted into groups for further analysis using Miser, a data
handling package developed by MACC.  Miser  is capable of handling large
data sets, and could  be used to sort through the SIA data using either
alphabetic or numeric variables.  Miser generated lists of sites fitting
certain characteristics for use in field verification and for other
purposes.  Miser output was also directed to the Minitab statistical
package (developed at Pennsylvania State University), which was used to
display histograms and cross-tabulations of specified variables.

                          S'/hFACE  IMPOUNDMENT  ASSESSMENT  STUDY

                          «          3.FACILITY NAME
      SI A •
      SIC «
               I 1
                                  I  I
                  <>. CATEGORY
                                     7 . ADDKESS
                                                                1. DA I L phEp AftEDI
                  1. PLAN  APPROVAL    10. CITY
               I I   -         /  /   I I
                                                              II.  STATE-ZIP   12. • OF  IMPb
                                                             I I              It         )

I             I
                   1 1 .  COUNT T

 00. 0. SEC.  T,N.  RN.
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                           I MPO'UNDMENT DESCRIPTION DATA
18.  IMP >
                 19.  PURPOSE OF IMPOUNDMENT (COOEI
                 i     ) (
                                                          20. SPECIFY IF OTHER OH TREATMENT
                                                        I I                             I
21.  AGE IN Yrts
                   22.  PRESENTLY USED?

                 IYESI  YRS IN OPERATION!    I

                 I  NOI  YR LAST OPERATED!    I
                                            23. SURFACE AREA ALL IMPIACRESI  I

                                            21. SURFACE AREA THIS  lnFIAtHESH
1 rp 1 II)
1 HP I II)
IHP ( 1(1
IMP I ) ( I
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 I                II                  II           II
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   ON DR INKiNO VATER i     i
Figure  3-1    Inventory data form used by  Wisconsin  SIA

Table 3-1.  Variables Used in Data Analysis


     Category code
     County code
     SIA site number
     SIC code
     Number of impoundments
     Number of livestock at facility
     Code for type of livestock
     Number of monitoring wells


     Number of this impoundment
     Purpose of this impoundment
     Surface area of this impoundment
     Influent to this impoundment
     Type of bottom liner in this impoundment


     Step I - Numerical score
            - Alphabetic identifier
            - Confidence
     Step II- Numerical score
            - Alphabetic identifier
           • - Confidence
     Step III- Numerical score
             - Confidence
     Step IV - Numerical score
             - Confidence
     Step V  - Numerical score
     Step VI - Numerical score
             - Alphabetic identifier
             - Confidence

Miscellaneous identifiers(s)
Waste identification code

Chapter 4:  Presentation & Analysis of the Data

4.1  Inventory Statistics

4.1.1  Summary of Count

Table 4-1 displays the numbers of impoundments and impoundment sites
located in the Wisconsin SIA inventory, as well as the numbers assessed.

4.1.2  Estimates of Total Number of Sites/Impoundments

Table 4-2 compares the numbers of sites and impoundments located by the
Wisconsin SIA with preliminary estimates reported by Geraghty and Miller,
Inc. in 1978 and with recent SIA estimates of the total numbers of sites
and impoundments.

While the Wisconsin SIA inventoried only 86 more sites than were included
in the 1978 estimate, the SIA's estimate of almost 1900 active sites is
nearly twice the earlier estimate of 985 sites.  The discrepancy between
the SIA inventory and estimate is due primarily to difficulty in ob-
taining data on the majority of the state's agricultural impoundments.

The SIA's estimates of total numbers of sites and impoundments are
based on information and perceptions collected by the SIA staff over the
course of the project.

SCS field staff supplied most of the data for the agricultural inventory,
and provided estimates of the numbers of impoundment sites in their
areas for which they have no records.  The estimated total of 1200
active agricultural sites was arrived at by summing county-by-county
estimates supplied by SCS personnel.  (This should probably be regarded
as a minimum estimate, since the SIA has recently received unconfirmed
reports of much greater numbers of impoundments than SCS estimated in a
few counties.   Some persons knowledgable in this area estimate that there
may be as many as 5000 agricultural  impoundments in Wisconsin.)  The
estimate of the total number of agricultural  impoundments was then
derived from the estimated number of sites by assuming that uninventoried
sites have about the same average number of impoundments per site as
those sites located for the inventory.   The number of abandoned agricultural
impoundments is estimated to be quite small because the use of animal
waste storage ponds is a relatively new practice.  Given the reported
estimate of 1200 active agricultural sites, the SIA inventory is seen to
have achieved coverage of roughly one-third of the agricultural impoundment
sites in the state.

Estimated numbers of active industrial  and municipal  facilities were de-
termined by estimating the numbers of additional  sites that might be
located if verification activities described  in sec.  3.4 were expanded
to the remainder of the state,  and adding a small allowance for "unlocatable"
facilities.   These estimates include allowances for a few active facilities
located since the inventory was closed, as well as for impoundments used
for sanitary wastes on Federal  and Indian lands,  which were not initially
inventoried.   The inventory total  of 329 active industrial sites represents
94% of the estimated total  of 350 active sites in this category.  If

sites on Federal  and Indian lands are excluded from the estimate of 330
active facilities in the municipal  category, inventory coverage in this
category is about 95%.

The numbers of abandoned facilities in these two categories are not
readily ascertainable,  but the reported estimates represent a  consensus
of the SIA staff based  on observations during the inventory process and
subsequent conversations with state personnel familiar with the history
of state water pollution control  activities.  Several  countervailing
trends in the use of wastewater impoundments have been identified, and
were taken into account in developing estimates of the numbers of abandoned
impoundments.  Many of  the uses of impoundments for waste treatment or
storage appear to have  been developed in the last two  or three decades
as efforts to "clean r~" surface waters required development of economical
methods of treating wastes prior to discharge.  Similarly, some absorption
ponds were constructed  as alternatives to the historical  practice of
discharging wastes to surface waters.  It is assumed that the  majority
of impoundments built for modern water treatment facilities are still  in
use, and that, of those that have been abandoned, a significant percentage
of the relatively modern abandoned industrial impoundments were located
by the SIA because they were referenced in recent DNR  records  describing
subsequent changes at the facilities.  The files on municipal  facilities
contain little information on a community's past disposal  practices, so
few abandoned municipal facilities were located and the estimate of the
number of abandoned municipal facilities is quite rough.

Some uses of impoundments are no longer regarded as acceptable, but are
known to have been practiced in Wisconsin in the past.  Judging from the
sampling of abandoned sites located for the inventory, these practices
date back many years, but the extent of their use is unknown.   The
practices include discharge of untreated industrial process wastes
(chiefly organics, such as whey) to natural depressions which  drained by
seepage and seasonal overflow, use of pits for storage and disposal of
crop residues (silage)  and silage leachate at canning  facilities, and
discharge to absorption ponds of paper industry sulfite liquors or
untreated plating wastes.  Most of the estimated number of abandoned
industrial facilities are believed to fall into this group, with facilities
that handled organic wastes predominating.  Twentieth  century  trends
toward the consolidation of industrial production have closed  many of
the small cheese factories, breweries, and canneries that were once
quite numerous in Wisconsin, adding an additional intangible variable to
be considered in estimating the numbers of abandoned impoundments.

Since at the time of the inventory there were only three active mines in
the state (two have since closed), it is doubtful that any active mining
impoundment sites were  overlooked.   According to data  supplied by the
Wisconsin Geological Survey, about 400 mines (370 lead-zinc, and the re-
mainder iron mines) have operated in the state at one  time or  another.
It appears that, historically, liquid wastes generated in these operations
were discharged directly to streams, and the use of impoundments (mostly
settling ponds) was introduced in the 1950's.  The low estimate for
abandoned mining impoundment sites reflects low levels of mining activity
in the last 20 to 25 years.  Recent discoveries of massive sulfide
deposits in the northern part of the state can be expected to  lead to
renewed mining activity and use of additional impoundments.

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Since no commercial oil or gas supplies have ever been located in Wisconsin,
there are estimated to be no active or abandoned facilities in the oil
and gas category.

The "Other" category was not used in the Wisconsin SIA inventory.
However, lagoons are known to be used by septic haulers for storage of
septage, though there are no records of their numbers.  These storage
lagoons fall into the "Other" category.  The SIA does not have enough
information on this practice to hazard a guess on the number of impound-
ments in this category.

4.1.3  Characteristics of Facilities Using Impoundments

Industrial - The principal SIC codes of industrial (IND and AIN) facilities
with wastewater impoundments are displayed in Table 4-3.  Food processors
are by far the most numerous industrial users of impoundments.  In
keeping with Wisconsin's nickname, "America's Dairyland," dairy processors
(chiefly small cheese factories) form the largest subclass of the food
processors, followed by fruit and vegetable processors.  Forest products
industries (the timber and paper industries) and electric and sanitary
services are the only other industry groups that account for more than
10% of the inventoried industrial facilities.

Agricultural - All of the agricultural facilities (AGR and AAG) in the
inventory are used in connection with livestock or dairy production.
The types and numbers of animals maintained at inventoried agricultural
facilities are summarized in Table 4-4.

Most of the agricultural impoundment users are facilities that maintain
cattle.  Breakdowns of SIC codes for agricultural facilities indicate
that 317 of the 325 cattle farms (almost 98%) are dairy farms.  The
median size of cattle herds at inventoried facilities is 90 animals,
which is somewhat larger than the average Wisconsin dairy herd.  Hogs
are maintained at 13 facilities, with a median of 1,100 animals per
facility, suggesting that the hog farms using impoundments are relatively
large-scale operations.  The six poultry farms in the inventory are also
quite large, with a median of 26,600 birds.  At 48 sites, the type of
livestock was not reported.  No sheep farms or raisers of "other" livestock
types were found to be using wastewater impoundments.

Several proposals to regulate agricultural  waste sources have focused on
large facilities, primarily large feedlot operations.  To identify
facilities of this type that have impoundments and are included in the
SIA inventory, the criteria used to define "concentrated animal feeding
operations" in regulations proposed in 1976 by Wisconsin DNR were adopted
for use with SIA statistics, as shown in Table 4-5.   Using these criteria,
19 inventoried farms would be classified as concentrated animal feeding
operations (Table 4-6), including significant fractions of the hog and
poultry producing groups.   (Some additional SIA sites may also fit these
criteria, but data on livestock numbers at some sites were not available.)

Table 4-3
Industries Utilizing Impoundments
SIC Major
Group Code











Number of
Industry Description Facilities
Crop Production
Agricultural Services
Fishing, Hunting and Trapping
Nonmetallic Mineral Extraction
Food and Kindred Products
Meat Products 10
Dairy Products 125
Preserved Fruits and
vegetables 52
Grain Mill Products 5
Bakery Products 1
Sugar and Confectionary
Products 2
Fats and Oils 4
Beverages 2
Misc. Food and Kindred
Products 2
Timber and Wood Products
Paper and Allied Products
Pulp Mills 19
Paper Mills 8
Paperboard Mills 2
Misc. Converted Paper
Products 4
Paperboard Containers
and Boxes 1
Printing and Publishing
Chemicals and Allied Products
Petroleum and Coal Products
Rubber and Misc. Plastic Products
Stone, Clay and Glass Products
Primary Metal Industries
Fabricated Metal Products
Machinery, except Electrical
Electric and Electronic
Transportation Equipment
Instruments and Related Products
Miscellaneous Manufacturing
Transportation: Railroads
Electric and Sanitary Services
Wholesale and Retail Trade
Lodging; Personal and Business
Legal, Educational and Social






% of Industrial







             Table 4-4

             Livestock Maintained at Agricultural Facilities
Not reported
Number of
Range 1n number
of animals*
Median number
of animals*
             *Numbers of animals per site at sites where animal numbers were reported.
Table 4-5

Definition of concentrated animal feeding operations
Type Recorded
By S1A



Livestock types specified
1n proposed NR 200.12
Slaughter of feeder cattle
Mature dairy cattle
Swine weighing 55 Ibs or more
Laying hens or broilers at
operations with continuous
overflow monitoring
Laying hens or broilers at
operations with liquid
manure handling
Number of animals
specified by
NR 200.12*



Number used



*Size threshold of herd or flock subject to code  requirements.   Listed  figures  were  to  apply  to
facilities discharging directly to surface waters.


Table 4-6

SIA facilities defined as Concentrated Animal  Feeding Operations
of sites
           Total                 19
Municipal - Of the 299 municipal  facilities inventoried,  14 (5%)  are
operated by agencies of the State of Wisconsin,  237 (79%)  are operated
by local governmental units (municipal  and county governments, sanitary
districts and school districts),  and 48 (16%) serve various non-public
entities, including private subdivisions, mobile home parks, health care
facilities, religious organizations, private schools, industries, motels,
restaurants, and other public accomodations.  None of the  inventoried
municipal impoundments are operated by Federal  agencies though several
Federally-operated facilities that mightuse impoundments were identified
after the inventory record was closed.   As shown by Figure 4-1, the
facilities using impoundments are generally designed to serve small
populations, usually in the state's smaller communities.   Of the  facilities
for which design populations were reported, 72% serve 1000 people or
less, while only 1% serve populations greater than 50,000.

Mining - Two of the three "active" mining facilities and all three of
the abandoned mining facilities in the inventory are lead-zinc mines in
southwestern Wisconsin.  As of October 1979, all five of these mines had
been closed down, though some impoundments may still contain liquids.
The remaining active mining facility is a taconite (iron)  mine in northwestern
Wisconsin.  Avaiable information  indicates that wastewater impoundments
were never used in abandoned iron mining operations in other parts of
the state.

Oil ajid Gas - The oil and gas category was defined to include impound-
ments used in connection with production and exploration activities.
Since no commercial oil or gas deposits have ever been found in the
state, and since the chance of their occurrence is rated as virtually
nil, it is not surprising that no.oil and gas impoundments were found in
the inventory.

4.2  Operating Characteristics of Impoundments

4.2.1  Impoundment Purposes

Figure 4-2 summarizes the purposes for which impoundments  are used by
facilities listed in Wisconsin's  inventory.  Both active and abandoned
facilities are included in this tabulation.  Only one impoundment at
each facility was described, so this listing, as well as others that
follow, underrepresents the impoundments used at facilities with multiple
impoundments.  The use of disposal impoundments by industry might be
overrepresented, since industries with only one impoundment are likely
to have a seepage pond or seepage area.

Figure k-I
Population Basis of Municipal Facilities*
   i 500






     Based on reports  of design  populations  for
     252  of 299 municipal facilities

 Fig.  4-2  Purposes of Randomly  Selected Impoundments
(391 sites)
(372 sites)
                                          unknown /  other
(305 sites)
  (6  sites)

Agricultural impoundments are seen to be used primarily for the storage
of waste (usually maure, feedlot runoff or milkhouse washings ultimately
destined for field spreading or other on-land disposal).  The treatment
and disposal of wastes are listed as the predominant purposes of impound-
ments at municipal and industrial facilities, while all of the mining
impoundments described are designated for treatment.

Most of the impoundments intended for "Disposal" are absorption or
seepage ponds, in which waste disposal occurs by means of soil absorption.
A few of the "disposal" impoundments are designated for other disposal
mechanisms, such as sludge disposal or wastewater evaporation.  The
principal processes utilized in "Treatment" ponds are settling, stabilization,
aeration, polishing and oil skimming.  Cooling ponds make up the majority
of the impoundments classified as "Other."

4.2.2  Impoundment Liners

Data on liners used in the described impoundments are listed by site
category in Table 4-7.  The several categories of clay liners and of
membrane liners are combined in this list.  The designation of "Other"
liner type was used primarily to describe agricultural impoundments with
concrete bottoms (or concrete ramps to facilitate manure hauling) and
earthen sides.  "Other" liners also include a few arrangements that
combine two or more different liner types, such as clay and asphalt
combinations.   (The SIA did not rate the presumed effectiveness of the
liners installed at inventoried facilities.  Though there is great
vanability in liner thickness and the integrity of liner materials, any
impoundment where the presence of any liner was reported was recorded as
"lined" for use in data anlaysis.)

While most of the "Disposal" sites are expected to be unlined to facilitate
the process of waste infiltration, liners are the principal construction
feature for reducing leakage from "Storage" or "Treatment" impoundments,
so their use at these sites is one index of the attention paid to ground-
water protection in the planning of impoundments.  Figure 4-3 displays
the proportions of lined and unlined nondisposal  impoundments in the
various SIA facility categories.  While a majority of the impoundments
for which information is available are line, liner information for over
a third of the impoundments is not available.

Examination of Figure 4-3 reveals some striking differences among
facility categoires.   A high proportion of the industrial  (and, to a
lesser extent, municipal) impoundments lack liner data.  For some older
sites, this information may never have been received by DNR because the
facilities never underwent a formal plan approval process.  Liner
information for facilities developed in recent years is presumed to have
been submitted to DNR, but is often not retained in DNR's permanent
microfiched records of facility approvals, which are rather inconsistent
in their inclusion or exclusion of various items.  Liner information for
a few of the unassessed sites may be omitted even though it is present
in DNR files,  because it may have been overlooked during initial  file
searches aimed primarily at locating  Section  I data for the SIA in-

Liner use also varies among the different facility types.   In the category
of active municipal  facilities, nearly 90% of the impoundments for which
liner information is shown in Figure 4-3 are lined.   In the active
industrial and agricultural categories, the comparable figures are only
56% and 52%, respectively.

Liners are neither the only nor the best available barrier to leakage
from impoundments; natural soils at many sites may provide greater pro-
tection against contaminant migration.   Thus, not all  of the unlined
impoundments present a significant hazard to groundwater quality:  the
decision not to line a pond may be based on combinations of soil  and
groundwater conditions and waste characteristics that  permit a determination
of minimal contaminat,jn hazard.  Aspects of site geology and waste
character were addressed by the SIA assessments, and the relationships
between these factors and liner use are discussed in a later section of
this report.

4.2.3  Groundwater Monitoring Programs

If natural soil barriers or einplaced liners form a first line of  defense
against groundwater degradation due to wastewater impoundments, groundwater
monitoring programs can act as a second line of defense by facilitating
early detection of contaminant migration, thus allowing the implementation
of measures to protect water users. Data in the SIA inventory indicate
that 7.5% of the active industrial sites and 7% of the active municipal
sites have installed groundwater monitoring systems.  (No agricultural
or mining facilities were reported as having groundwater monitoring;
however, groundwater monitoring programs have recently begun at a few
agricultural impoundment sites as part of the Wisconsin Geological
Survey study discussed in sec. 6.2, and will soon be implemented  as a
permit condition at the state's only active metals mine.)   Most  of
these systems are at facilities discharging large flows to absorption
ponds or other land disposal systems (e.g., spray irrigation), for which
groundwater monitoring is required under the WPDES permit program.  A
few monitoring systems are associated with solid waste disposal sites,
and a few others were installed for special studies and may no longer be
useable.  According to data in SIA files, the majority of the monitoring
systems at SIA sites use only two observation wells, placed in positions
determined to be up- and down-gradient of the disposal site, as recommended
in DNR guidance for land disposal systems (Wisconsin DNR, 1975).

                          Fig.  4-3   Liner  use at  Non-Disposal Impoundments
        200 -
      u 150
      f 100

         50 -
                                                                                     Active facilities
                                             \ YT
                                                     Table 4-7
                                     Liner Use at Randomly Selected  Impoundments
  Number      % of
of sites     category



of sites



                                 Number    % of
                                 of sites  category

                             Number   % of
                             of sites  category

of sites


 % of


 Includes bentonites.
 Percentages do not always total  to  100  because of rounding error.

4.3  Assessment Results

4.3.1  Summary of Scores

Assessments were completed for 635 impoundments at 635 inventoried
facilities.  Scores for the individual  steps in analysis of groundwater
pollution potential are summarized in Tables 4-8 through 4-13.

Table 4-8 is adapted from Table I of Silka and Swearingen (1978)  to show
the distribution of earth material types and thicknesses encountered in
the rating of the unsaturated zone (Step 1 of the assessment procedure).
All possible combinations of materials  and thicknesses were found at
Wisconsin sites.  Thir diversity of scores reflects the diversity of the
soils of Wisconsin, which are composed  of glacial tills of several
distinct textures and lithologies, glaciofluvial and glaciolacsutrine
sediments, loess, recent alluvium, and  residual soils formed on sand-
stones, dolomites and crystalline rocks.

Numerical scores for Step 1, which shows the most variability of the
first four assessment steps, are listed by SIA category in Table 4-9.
Observed differences between categories may reflect differences in the
geographical distribution of particular activities.  For example, the
high frequency of  '9' scores in the municipal category appears to reflect
the historic preference for river terraces or floodplains, where sediments
are apt to be coarse-grained and water  tables shallow, as the sites of
sewage treatment facilities.  Similarly, the abundance of '9'  scores in
the industrial category may be related  to a preference for river locations
by industries (e.g. the paper industry) that have employed hydropower
or that (as in the case of electrical generating facilities) requires
large volumes of cooling water.  Scores of '0' are also unusually common
in the industrial category possibly as  a relic of the concentration of
industry near Wisconsin's Lake Michigan Coast, an area characterized by
clayey tills and glacial lake sediments.

Scores for Step 2  (Table 4-10), the rating of the saturated zone, show
much less variability than those of Step 1.  About 88% of the assessed
sites received scores of 5 or 6, indicating the presence of a Type I
aquifer (relatively high permeability)  at least 3m thick.  These two
scores were applied to Paleozoic sedimentary units, glacial and alluvial
aquifers and some fractured crystalline units, thus including most of
the state's shallow aquifers.  Type II  and Type III aquifer designations
were used infrequently, generally for low-yielding crystalline units,
Precambrian arkose, and sites where saturated clays were rated as the
saturated zone.

Step 3 scores are displayed in Table 4-11.  Scores of '5' were assigned
to all sites assessed, indicating the relatively high quality of Wisconsin's
groundwater and the almost universal  reliance on groundwater for private
domestic supplies.

        As might  be  expected, there  are marked differences  among SIA categories
        in the distribution of Step  4  ratings on waste  hazard potential  (Table 4-12),
        Among municipal  facilities,  '2'  and '3' are the most common scores,
        probably  reflecting the small  sizes of many of  the  communities using
        impoundments,  as well as the increased use of industrial pretreatment
        and secondary  treatment for  municipal  wastes.   The  scores of industrial
        sites cover  a  broader range  thatn the scores assigned in other categories,
        though (as in  the municipal  category) scores of '2'  and  '3' predominate.
        These scores are specified for most food processing activities,  which
        make up the  bulk of the industrial  category.  The model waste hazard
        score for agricultural facilities is '4', the rating listed for  dairy
        from wastes  by Silka and Swearingen (1978).  This score  is higher  than
        those assigned most organic  wastes handled by industrial and municipal
        facilities.  The wastes in the assessed impoundments in  the mining
        category  result primarily from mine dewatering  and  ore beneficiation,
        and did not  fit readily into any waste class specified in the guidance.
        The scores of  '4' and '5' assigned in this category are  those EPA  de-
        signated  for the iron and lead-zinc mining industries.

        According to Silka and Swearingen (1978), the possible range of  Step 5
        scores is from '!' to '29',  based on the ranges of  possible scores for
        the previous steps.  Step 5  scores from Wisconsin assessments range
        from  '10' through  '28', as recorded in Table 4-13.
                       TABLE 4-8 - Ratings of the Unsaturated Zone
Earth Material
            No. of  Score?  No. of Score   No. of  Score  No. of Score   No. of  Score2   No. of  Score2
            Sites         Sites         Sites         Sites        Sites         Sites
Thickness >30m
>1 ^3m

               TABLE 4-9  Scores for Step 1:   The  Unsaturated Zone

Agricul tural
No. of Percent
4 2.0
11 5.5
14 7.0
22 11.0
23 11.5
17 8.5
24 12.0
31 15.5
9 4.5
45 22.5
200 100.0

No. of Percent
2 1.0
13 6.5
10 5.0
31 15.5
144 72.0
200 100.0
No. of Percent
24 10.4
15 6.5
21 9.1
11 4.8
16 7.0
10 4.3
17 7.4
21 9.1
15 6.5
80 34.8
230 99.9
TABLE 4-10 Scores
No. of Percent
1 0.5
7 3.5
5 2.5
7 3.5
34 17.0
146 73.0
200 100.0
Municipal Mining
No. of Percent No. of Percent
sites sites
6 3.0
11 5.5 1 20.0
25 12.5
16 8.0
7 3.5
14 7.0 1 20.0
7 3.5 1 20.0
13 6.5 1 20.0
8 4.0
93 46.5 1 20.0
200 100.0 5 100.0
for Step 2: The Saturated Zone
Municipal Mininfl
No. of percent No. of Percent
sites sites
5 2.2 -
5 2.2 - -
10 4.3
12 5.2
38 16.5
160 69.6 5 100.0
230 100.0 5 100.0
No. of Percent
34 5.4
38 6.0
60 9.4
49 7.7
46 7.3
42 6.6
49 7.7
66 10.4
32 5.0
219 34.5
635 100.0

No. of Percent
6 0.9
14 2.2
28 4.4
29 4.6
103 16.2
455 71.7
635 100.00
TABLE 4-11 Scores for Step 3: Ground-Water Quality
Municipal Mining
No. of Percent No. of Percent No. of Percent No. of Percent
sites sites sites sites
No. of Percent
200    100.0

                           TABLE  4-12   Scores  for  Step 4:  Waste  Hazard  Potential
Numerical No. of Percen
Score sites
3 14 7.0
4 178 89.0
5 8 4.0
8 - -
TOTALS* 200 100.0
*Percentages do not always
No. of Percent
Score sites
14 5 2.5
15 8 4.0
16 15 7.5
17 11 5.5
IB 22 11.0
19 21 10.5
20 18 9.0
21 28 14.0
22 23 11.5
23 23 11.5
24 22 11.0
25 4 2.0
t No. of Perce
84 36.5
81 35.2
21 9.1
10 4.3
21 9.1
3 1.3
7 3.0
3 1.3
230 99.8
sura to 100 due to
4-13 Scores for
No. of Percent
3 1.3
1 0.4
2 0.9
12 5.2
14 6.1
19 8.3
10 4.3
16 7.0
11 4.8
21 9.1
18 7.8
18 7.8
32 13.9
27 11.7
5 2.2
7 3.0
9 3.9
2 0.9
3 1.3
TOTALS* 200 100.0 230 99.9
Municipal Mining
nt No. of Percent No. of Percent
sites sites
39 19.5
141 70.5
10 5.0 1 20.0
5 2.5 4 80.0
3 1.5 - -
2 1.0 v
200 100.0 5 100.0
rounding error.
Step 5: Groundwater Pollution Potential
Municipal Mining
No. of Percent No. of Percent
sites sites
3 1.5 -
5 2.5 - -
3 1.5 -
9 4.5 - -
16 8.0
15 7.5
12 6.0 1 20.0
6 3.0 - -
15 7.5
10 5.0
7 3.5 1 20.0
31 15.5 1 20.0
59 29.5 1 20.0
6 3.0 1 20.0
2 1.0 - -
1 0.5 -
200 100.0 5 100.0
No. of

No. of


* Percentages do not always  sum to  100 due  to  rounding  error.

4.3.2  Groundwater Pollution Potential  of Absorption Ponds

Since liquids discharged to absorption  (or "seepage") ponds eventually
reach the groundwater, (though usually  after some attenuation has
occurred), the character of the wastes  disposed in these ponds is probably
the most important factor determining the hazard they pose to groundwater
quality.  The waste hazard scores (Step 4 of the assessment) assigned to
assessed "disposal" impoundments are listed according to SIA category in
Table 4-14.  Almost all  of these are absorption ponds, so this tabulation
serves as an indication  of the nature of the wastes discharged to absorp-
tion ponds in Wisconsin.

All of the municipal  (MUN) disposal  impoundments assessed received low
waste hazard scores of '2' and '3',  apparently because use of absorption
ponds is generally limited to systems serving small populations and
receiving no industrial  inflows.

While the bulk of the industrial  disposal impoundments in this summary
received "low waste hazard scores, in the SIA assessment, over 10% received
scores of '5' or more, which generally  designate potentially hazardous
wastes.   Ten of the industrial facilities receiving scores of this level
are identified in Table  4-14 as active.  DNR permit records for these
ten facilities were reviewed to determine whether the high waste hazard
scores accurately reflect current disposal practices.  One of the
impoundments was found to be a sludge disposal site, and is discussed
along with sludge holding and dewatering ponds in another section of
this report.  Three of the absorption ponds are no longer used for
absorption or are scheduled to be abandoned soon, one is no longer
receiving process wastes, and two others are used for disposal of treated
wastewaters in which concentrations  of toxic materials (e.g. metals,
cyanide) are supposed to have been reduced to levels approaching drinking
water tolerances (USEPA, 1975, Federal  Register 40, pp.  59566-59588).
In these cases the high  waste hazard scores were assigned on the basis
of past waste disposal practices or  on  potential hazards associated with
the industry producing the waste (as identified by SIC number).  One of
the remaining impoundments, while described as a "seepage area" and
given a waste hazard score of '6', is on a tight clay soil and appears
to serve as a settling area (with natural surface drainage) for a fly
ash waste of unknown characteristics.  Its waste score also was based on
the identification of the industry,  since a detailed waste characterization
was not available during the assessment process.  The other two absorption
ponds are used for wastes that appear to have merited their high waste
hazard scores, but since these discharges violate WPDES effluent limitations,
both facilities are targets of on-going DNR enforcement activities aimed
at bringing them into compliance.

From these data, then, it appears that, under the WPDES system in Wisconsin,
use of absorption ponds  is generally limited to low hazard wastes,
including dairy and food processing  wastes, noncontact cooling water and
treated wastewaters.   (Scores from Step 4 of the assessment process do
not distinguish among these waste types.)  Where absorption ponds are

 still receiving more hazardous materials, existing regulatory programs
 appear to be capable of effecting changes in disposal practices.  The
 relatively low hazard wastes cannot, however, be regarded as innocuous.
 Discharge of treated wastewaters from industries with high hazard potentials
 may promote the migration of hazardous waste constituents remaining in the
 ground from former discharges.  Low hazard wastes, such as organic wastes
 from food processors or municipalities, may themselves introduce BOD,
 nitrates, and other troublesome waste components into the groundwater.

 Degradation of groundwater quality beneath absorption ponds receiving
 low hazard wastes may be minimized by attention to several pond design
 and operational  factors.   For example, ponds ought not be sited in areas
 of shallow groundwater, hydraulic loading rates should be limited, and
 resting  periods  should be provided to renew the soil's capacity for
 aerobic  decomposition of waste.   DNR guidelines for design of absorption
 ponds (Wisconsin DNR, 1975)  provide for a minimum depth to groundwater
 of 10 feet and specify appropriate soil  types and loading rate limits to
 enhance  waste attenuation and prevent system clogging, offensive odors
 and other problems.   A review by the SIA of the land disposal guideline
 document found that the technology of land disposal  was not very well
 developed at  the time of  its  preparation, so guidelines provisions are
 generally not based on "hard" data on the performance of these systems.
 For this reason,  the SIA  recommends that a study of the performance of
 land disposal  systems be  undertaken,  combining a reviews of current
 technical  literature and  the  results  of several  years of groundwater
 monitoring  with  intensive field  investigation at selected sites, to
 improve  technical  understanding  of land  disposal  processes and allow
 refinement  of guidelines  for  siting and  operation of land disposal

 Since guidelines  for  siting of absorption ponds  can  generally be applied
 only to  new facilities  subject to  the  plan approval  process,  the protection
 provided  by limits  on  soil type  and  depth to groundwater is  not  present
 at  some  existing  facilities.   For  example,  according  to  their Step  1
 assessment  scores,  10%  of the assessed  industrial  absorption  ponds  and
 19%  of the assessed municipal absorption  ponds are  1m or less from  the
water table, and  therefore provide  for very  little aerobic decomposition
 before wastes reach the groundwater.   (These figures  may overrepresent
 somewhat the proportion of absorption  ponds  without adequate  provision
for waste decomposition,  since several of these  ponds receive waste
streams  in which  the main contaminant  is  inert suspended  solids,  (e.g.,
at stone quarried), which can be filtered  effectively in  the  saturated

                               Table 4-14
                  Waste Hazard Potentials of Disposal Impoundments

Number Percent
Number Percent
 Totals*       104    100.0      7    100.0     37     100.0    148    100.2

 •Percentages do not always sum to 100 due to rounding error.

4.3.3  Pollution Potential  of Storage and Treatment Impoundment  Introduction

As indicated in Figure 4-3,  many impoundments intended for purposes
other than waste disposal  do not have liners.   Tables 4-15, 4-17 and 4-19
relate data on liner use in assessed non-disposal  impoundments to scores
assigned in Step 1  of the  assessment, which rates  the capacity of the
unsaturated zone for retardation of waste movement.   Since relatively
impermeable soils usually  provide at least as  effective a seal  as arti-
ficial liners, liners would generally be redundant at impoundment sites
with low Step 1 scor, _,.  Agricultural  Impoundments

According to Table 4-15, agricultural impoundments on sites with high
scores for Step 1 are only slightly more likely to be lined than those
on sites with low scores for this step.   The numerical  results suggest
that there are many agricultural impoundments  with high potential for
leaking wastes to the groundwater.  Failure to line agriculture impoundments
on sites with lew waste retardation capacity is probably related to the
prevalent belief that manure ponds seal  themselves biologically and by
the settling out of suspended solids.  Unfortunately, the evidence from
on-going research on groundwater impacts of Wisconsin manure storage
ponds (discussed in sec. 6.2 of this report) indicates  that the self-
sealing process (if it occurs) is not effective in preventing waste

It should be noted that the assessed sample of agricultural impoundments
is not a representative sample of the agricultural inventory with respect
to liner use, but underrepresents the true proportion of lined impoundments.

For this reason, the proportions of lined and  unlined ponds at specific
Step 1 score levels should not be extrapolated to  the entire inventory.
If the assessed sample accurately reflected the proportions of lined and
unlined impoundments in the agricultural inventory, there would be 78
unlined ponds and 84 lined ponds in the  sample.  The underrepresentation
of lined impoundments in the assessed sample appears to have developed
because random selection in the agricultural category was carried out
before inventory returns became available from two counties which eventually
reported unusually large numbers of impoundments,  many  of them lined.  A
Chi-square comparison of the assessed and non-assessed  agricultural
impoundments found the assessed arid non-assessed groups to be significantly
different with respect to  liner use at 99% confidence.

Concentrated Animal Feeding Operations - Fourteen  of the 19 agricultural
facilities identified as "concentrated animal  feeding operations" were
assessed.  Table 4-16 compares the Step  1 scores on liner use in the
assessed impoundments.  It is disturbing to note that impoundment sites
with the lowest natural capacities for retardation of waste movement (as
indicated by scores of  '9') are unlikely to have their  retardation
capacities augmented by artificial liners.  However, impoundments on
sites with moderate scores in Step 1 generally appear to be lined.

Table 4-15
    Step 1 scores and liner use in agricultural non-disposal
Step 1 Score
No liner data
Table 4-16

     Step 1 scores and liner use at "Concentrated Animal  Feeding Operations"

Step 1 Score      No liner data      Unlined      Lined       Totals
Industrial - Data on liner use are available for a minority of the
assessed industrial impoundments.   From the limited data available,
Table 4-17 does not show any notable trend toward consistent use of
liners on sites rated as having low capacities for retardation of waste
Table 4-18 displays the Step 4 (waste hazard) scores of industrial
impoundments with available liner  data.  There appears to be a slight
tendency toward more consistent use of liners where high hazard wastes
are impounded,  but this trend is not statistically significant.  Three
of the four unlined impoundments that received waste hazard scores of
'6' or greater  also received Step  1 scores of '9'.  In each case, the
material of the unsaturated zone was classified as Type I (gravel,
medium to coarse sand, or fractured limestone), with a depth to groundwater
of 10m or less.  Groundwater monitoring is reported at only one of these
three facilities.  At another facility, the impoundment in question  is
no longer used  for high hazard wastes, but the continued discharge of
lower hazard materials may exacerbate known groundwater contamination

problems.   Review of records on  non-disposal impoundments receiving  high
waste hazard  scores indicates  that the majority of  these high hazard
wastes are  paper mill  or air emission sludges.  Mhile these semi-solid
wastes lack the extreme mobility of liquids, the  potential  for leaching
makes their impoundment in unlined lagoons on sites susceptible to waste
migration a matter of significant concern.

Municipal - Table 4-19 compares  Step 1  scores with  data on  liner use at
assessed municipal non-disposal  impoundments.  Where liner  data are
available,  the  great majority  of impoundments are lined.  However, a
sizeable percentage of the unlined impoundments are on site where the
assignment  of high S^ep 1 scores indicates that liner use would be
advisable.  The  Step 4 waste hazard scores of the  unlined municipal non-
disposal impoundments are generally low.
        Table 4-17
        Step 1 Scores and liner use in industrial non-disposal impoundments
Step 1 Score
No liner data
        Table 4-18

        Step 4 scores (Waste Hazard)  for industrial non-disposal impoundments with
        Uner information
        Table 4-19

        Step 1 Scores and liner use 1n municipal non-disposal impoundments

        Step 1 Score	No Uner data	Unlined	Lined	Totals
          Totals            62          11        89       162

                  Chapter 5:  Water Table Aquifers

5.1  Introduction

Shallow water table aquifers have a high potential for contamination by
seepage from leaky impoundments.  In most areas of Wisconsin the water
table is close to the land surface.  Over 75% of the impoundments rated
by the SIA are located at sites where the depth to the water table is
less than 10 meters.   At only 5% of the sites does the depth to the
saturated zone exceed 30 meters.  Total thickness of the saturated zone
ranges from less than 20 meters in north central Wisconsin to over 300
meters in southeastern Wisconsin  (USGS Report to Senate Committee on
Interior and Insular Affairs, 1976).

Wisconsin's near surface aquifers comprise several different geologic
units:  1) fractured crystalline rocks of Precambrian age, 2) marine
sandstone and carbonate strata of Cambro-Ordovician age, 3) marine
carbonate strata of Silurian and Devonian ages, and 4) unconsolidated
glacial deposits and recent alluvium.   Figure 5-1 summarizes the generalized
geology of Wisconsin.

5.2  Precambrian Aquifers

Precambrian crystalline rocks underlie the entire state and form the
near surface bedrock of northern Wisconsin.   Where weathered or fractured,
these rocks provide some storage and conduction of groundwater.  Precambrian
rocks are rarely used to supply water when overlain by a more productive
aquifer, and are thus regarded as the base of the saturated zone in

Despite low yields to wells, Precambrian rocks are often the only source
of groundwater in those parts of north central Wisconsin where glacial
drift is thin or absent.  In parts of Wood,  Marathon, and Clark counties
well yields from Precambrian rocks range from .02 to over 50 gpm.
Eighteen percent of those wells yielded less than 2 gpm while only 1«
yielded over 50 gpm (Bell and Sherill, 1974).  Similar yields are re-
ported for wells penetrating Precambrian basalt and andesite lava flows
of northwestern Wisconsin (Young and Skinner, 1974).

In extreme northern Wisconsin, adjacent to Lake Superior, sandstone and
conglomerate of the Bayfield and Oronto groups may yield up to 500 gpm.
Specific capacities of wells finished in these units are low, ranging
from 1-3 gpm/ft. (Young and Skinner, 1974).   Mineralization is a problem
in this aquifer with reported total dissolved solids values exceeding
1,500 ppm (Holt and Skinner, 1973).

5.3 Cambro-Ordovician Aquifer (Sandstone Aquifer)

The Cambro-Ordovician Aquifer system overlies the Precambrian basement
complex and is the major aquifer in the southern two-thirds of the
state.  The principal water bearing formations are sandstones and
dolomites.  Discontinuous siltstone and shaley units within this sequence
form zones of lower permeability producing localized artesian conditions.
However, the various units are hydraulically connected and are considered

as a single aquifer system.   Over most of its area!  extent the Cambro-
Ordovician aquifer is the uppermost bedrock aquifer  except in eastern
Wisconsin where it is confined by the Maquoketa shale.

Potential well yields in the Cambro-Ordovician aquifer vary with thick-
ness.  In southeastern Wisconsin total thickness exceeds 1,500 feet with
yields greater than 1,000 gpm.  The aquifer becomes  progressively
thinner towards the Precambrian upland of northern Wisconsin where
yields are less than 50 gpm (Devaul, 1975a).   Yields of certain wells
may be higher than average due to intersecting joints or fractures
(Cline, 1965).

In eastern Wisconsin the Maquoketa shale forms a confining layer between
the Cambro-Ordovician and the overlying Niagara aquifer.  The Maquoketa
shale ranges in thickness from 90-540 feet, produces little or no
water, and must be cased to prevent caving.  In the  Milwaukee area many
wells penetrating the shale are open to both the Cambro-Ordovician and
Niagara aquifers.  This interconnection allows considerable recharge of
the sandstone from the overlying Niagara dolomite (Foley et  al., 1953).

5.4  Niagara Aquifer

The Niagara aquifer consists of fine to medium grained dolomite forma-
tions of Silurian and Devonian age.  It overlies the Maquoketa shale and
forms the near surface bedrock of eastern Wisconsin.  Maximum reported
thickness is 750 feet.  Water is yielded to wells by vertical and hori-
zontal joint systems which are often enlarged by solution.  The distribution
of jointing is not uniform, thus yields are variable and difficult to
predict.  Individual wells developed in the Niagara  may produce from as
little as 10 gpm to over 1,200 gpm (Skinner and Borman, 1973).  Total
dissolved solids range from 200-500 ppm of which 80% is due to carbonate
hardness.  In eastern Manitowoc County wells with high sulphate concen-
tration have been reported (Holt and Skinner, 1973).

5.5  Sand and Gravel Aquifers

The sand and gravel aquifer covers over three fourths of the state and
consists of unconsolidated, permeable glacial drift and recent alluvium.
It is actually a composite of numerous local and sub-regional aquifers
which can vary greatly in thickness and lithology within short distances
(Cline, 1^65).  Over most of  its areal extent the sand and gravel aquifer
is in hydraulic connection with the underlying bedrock aquifer.  Saturated
thickness of sand and gravel  deposits range from near zero in areas of
shallow bedrock to over 150 meters in buried pre-glacial valleys.  Ap-
proximately one-fourth of Wisconsin's municipalities obtain water from
this aquifer.  In northern Wisconsin, where Precambrian rocks lie near
the surface, sand and gravel  aquifers provide the only significant
source of groundwater (Devaul, 1975).

The highest yields from the sand and gravel aquifer are obtained from
glacial outwash deposits.  Thus, most of the state's high capacity ir-
rigation wells are developed  in areas of extensive  outwash plains or
valley alluvium, where yields to individual wells may exceed 2,000 gpm.
Because of the high permeability and high water table conditions associated
with outwash  aquifers they are especially  susceptible to  contamination
(Holt and Skinner, 1973).

                                                                             BEDROCK  GEOLOGY OF WISCONSIN

                                                                                             UNIVERSITY OF WISCONSIN  EXTENSION
                                                                                         Geological and Natural History Survey
         Devonian Formations
          (dolomite and shale)
         Silurian Formations
         Maquoketa Formations
          (shale and dolomite
         Sinmpee Group
          (dolomite with some limestone and shale)
         Ancell Group (mainly St Peter Fm )
          (sandstone, shale and conglomerate)
         Upper Cambrian Formations
          (sandstones with some dolomite and shale)
          pper Keweenawan Formations
          (sandstones with some shale and

         Quartzite Sla
         Granite and Undifferentiated
         Igneous and Metsmorphic Rocks
           sparse data)
----  Border of Wisconsin (Gary) Drift

         Borderof Older Drift
                                                                                                                              Elevation Above and Below
                                                                                                                                  Sea Level In Feet

                              SHORT GEOLOGIC HISTORY  OF WISCONSIN

  The bedrock of Wisconsin is separated into two major divisions: (1) older,  predominantly crystalline rocks  of  the
Precambrian Era; and (2) younger relatively flat-lying sedimentary rocks of the Paleozoic Era.

  The Precambrian Era lasted from the time the earth cooled, over 4,000 million years ago, until the Paleozoic Era
which began about 600 million years ago.  During this vast period of 3,400 million years sediments,  some of which
were rich in iron and which now form iron ores, were deposited  in  ancient  oceans; volcanoes spewed  forth ash and
lava;  mountains were built and destroyed,  and the  rocks of the upper crust were intruded by molten rocks of deep-
seated origin. Only a fragmentary record of these events remains but, as tree stumps attest to the presence of former
forests, the rocky roots tell the geologist of the presence of former mountains. Nowhere does any trace of the original
crust  remain, and  the oldest rocks yet found  in the state are about 2,000 million years old. With the exception of the
Upper Keweenawan formations that outcrop in the northwest, all of these rocks have  been  extensively deformed,
and in many areas they are so highly altered that their original nature and origin are extremely difficult to  inter-

  In the north-central part of the state surface outcrops are so sparse, due to a cover of  glacial deposits, that details
of the bedrock are obscured. In such areas the only clues to the underlying rocks are obtained indirectly by such geo-
physical methods as airborne  magnetics. In  the past much high-grade iron ore was produced from the Precambrian
rocks of northern Wisconsin, and much low-grade ore ("taconite'')  awaits development.  Recent geologic  work indi-
cates  that the area has a high potential for finding ores of other metals such as copper.

  At  the close of the Precambrian Era most of Wisconsin had been eroded to a rather  flat plain upon which stood
hills of more resistant rocks as those now exposed in the Baraboo bluffs. There were  still  outpourings  of basaltic lava
in the north and  a trough formed in the vicinity  of Lake Superior  in which great thicknesses of sandstone were

  The Paleozoic Era began with the Cambrian Period, the rocks of which indicate that Wisconsin  was twice sub-
merged beneath the  sea. Rivers  draining  the land carried sediments which were deposited in the sea to form sand-
stone and shale. Animals and  plants living  in the  sea deposited calcium  carbonate and built reefs to  form rocks
which are now dolomite—a magnesium-rich  limestone. These same processes continued into  the Ordovician Period
during which,  as indicated by the rocks, Wisconsin was submerged three  more times. Deposits built up in the sea
when  the land was submerged were  partially or completely eroded at  times when they were  subsequently elevated
above sea level. During  the close of  the Ordovician Period, and in  the succeeding  Silurian  and Devonian Periods,
Wisconsin is believed to have remained submerged.

  The youngest rocks outcropping in Wisconsin are of Devonian age and  are about 850 million years  old. Absence of
younger rocks  makes interpretations of post-Devonian  history in Wisconsin a matter of  conjecture. If the dinosaurs
roamed Wisconsin, as well they might have  some 200  million years ago,  no  trace of their presence  remains. Avail-
able evidence from  neighboring areas, where younger  rocks are present, indicates that towards the close of the Paleo-
zoic Era,  perhaps some 250 million years ago, a period of gentle uplift began which has continued to the present. Dur-
ing this time the land surface was carved by rain, wind and running water.

   The final  scene  took  place during  the last million years when  glaciers invaded  Wisconsin from  the north  and
sculptured the  land  surface. They smoothed the  hill  tops, filled the valleys and left a deposit of debris  over all ex-
cept the  southwest quarter of the State where we  may now still see the land as it might have  looked a million years

                                            University of Wisconsin - Extension
                                     GEOLOGICAL AND NATURAL HISTORY SURVEY
                                         M.E. Ostrom, Director and State Geologist
                                                1815  University Avenue,
                                               Madison, Wisconsin, 53706

                                                                                              Reprinted June 1979

Glacial till and lake sediments are of low permeability and yield little
water to wells.  However, these deposits often contain lenses of well
sorted sand and gravel which are highly permeable and may be thick
enough to supply domestic needs.  Where sufficiently thick, clayey tills
or lake sediments may significantly retard the migration of contaminants
to lower, more permeable aquifers.

5.6  Sources of Data on Wisconsin Groundwater

Generalized groundwater data is available for the entire state.  State
aquifer maps are published at a scale of 1:1,000,000 by the Wisconsin
Geological and Natural History Survey (Devaul 1975 a, b, c, d, e, f).
These maps show the areal extent, probable yield to wells and dissolved
solids concentration of groundwater in three principal aquifers.  Other
generalized maps which may be of use in groundwater investigations

1)   Geologic Map of Wisconsin.  (Bean 1949, 1965) 1:1,000,000.

2)   Soils of Wisconsin.  (Hole et al.  1968) 1:710,000.

3)   Depth of Bedrock in Wisconsin.  (Trotta and Cotter, 1973) 1:1,000,000.

4)   Glacial Deposits of Wisconsin:  Sand and Gravel Resource Potential.
     (Hadley and Pelham, 1976) 1:500,000.

Generalized statewide groundwater conditions are summarized in the
Hydrologic Investigations Atlas series published by the US Geological
Survey in cooperation with the Wisconsin Geological and Natural History
Survey.  The atlas comprises twelve reports, one for each major river
basin (Fig. 5-5).  Each report contains maps (1:1,000,000) of aquifer
units, bedrock geology, piezometric surface, soil infiltration rates and
drift thickness.  Also included are data on water quality, availability
and useage.  Special problem areas such as nitrate contamination and
salinity are discussed.  Individual reports in the series were published
between 1968 and 1975.

Regional or county groundwater studies provide greater detailed infor-
mation for groundwater management and planning.  Seventeen of Wisconsin's
72 counties are covered by USGS Water Supply Papers or WGNHS Information
Circulars.  Numerous additional reports address specific groundwater
topics, regions, or aquifers.

Local and special groundwater studies are available from diverse sources
such as student theses, journal articles, and committee reports.  Since
these sources are widely scattered and many of them are unpublished a
"Bibliography of Wisconsin Groundwater" has been prepared.  Zaporozec
(1974, 1978 a,b) lists 905 citations to publications on various aspects
of Wisconsin1s groundwater resource.  Numberous additional unpublished
reports and studies, committee reports and student theses are also
reference.  Articles are included which contain any information
pertaining to Wisconsin's groundwater, its occurrence, movement,
quality, quantity, use, management and protection.  Each entry
includes the location of libraries or agency data files in the Madison
area where the information may be found.

Figure 5-2. Areal extent of the Cambro-Ordovician aquifer,
          Generally unconfined.
          Confined by the Maouoketa Shale.
          Absent(Precambrian rocks).

Figure 5-3. Areal extent of the Niagara aouifer.

         Figure 5-U. Areal extent  of  the  Sand and Gravel aquifer.
                 'HA-/         /EA-/!.

                     }   HA-386  /-, 536/-<,  "flA-

                                        /  S
                                       /    \
                    \          / rHA-36T      \
                       r	•*•  \     (       ]
                                 •     •         '

                                X     JlA-321'
                               /      /        I
                               -     r
                              •-• ----  -
Figure 5-5. U.S. Geological Survey Hydrologic  Investigations Atlas series,

Chapter 6:  Instances of Groundwater Pollution from Surface Impoundments

6.1  DNR-USGS Report on Groundwater Contamination Incidents

As mentioned in the July Interim Report to EPA, the content of this
Chapter of the SIA State Report overlaps with that of an on-going seven
year study of groundwater quality and availablity in Wisconsin by the
Department of Natural Resources in cooperation with the US Geological
Survey.  A summary of some preliminary findings from the DNR - USGS
study is included below.

The study consists of two parallel projects:  a groundwater quality,
availability and management project staffed by DNR personnel and a USGS
staffed project relating groundwater quality to groundwater recharge and
movement.  One part of the study involves the appraisal of known groundwater
contamination incidents in Wisconsin.  A preliminary inventory of known
groundwater contamination cases in the state was developed by Mr. Thomas
Calabresa and Mr. Steve Smith and completed in 1978.  For the purpose of
the inventory, "contamination" is defined as any human-induced increase
above background levels of any groundwater quality parameter.  For each
incident, the inventory identifies:  1)  the dates and locations of the
incidents,  2)  the cause of contamination,  3)  tha nature of contaminant,
4)  the means by which it was identified and  5)  the geologic setting.

Of the 121 inventoried contamination incidents, 22 (or 18%) were attributed
to wastewater ponds and lagoons.  Approximately one half of these
incidents were associated with seepage from holding, settling or stabili-
zation impoundments designed to retain wastewater for subsequent spreading
or treatment.  The remainder involved absorption or seepage lagoons
designed to discharge to the groundwater system.  Water quality parameters
affected by lagoon leakage include total dissolved solids, chlorides,
nitrogen, BOD, sulfate, hardness, heavy metals, lignin (and other components
from spent sulfite liquor), iron, COD, pH, alkalinity, fluoride and

In 21  of the 22 cases, unconsolidated shallow aquifers were affected.
Seventy-five percent of the inventoried incidents occurred where the
surficial material was coarse-grained sand and gravel.  The depth to
water table was ten feet or less in 15 of the cases.

In order to avoid duplication of the time and effort that has been
expended by DNR and USGS personnel on this study, the SIA team has not
been directly involved in researching contamination cases.

6.2  Study on Groundwater Impacts of Manure Storage Ponds

Another study being carried out concurrently with the SIA addresses the
topic of this chapter.  In the latter part of 1979, the Wisconsin
Geological and Natural History Survey (WGNHS) and the University of
Wisconsin - Madison Department of Soil Science initiated a cooperative
research project on "Infiltration and Subsurface Water Quality in Dairy
Barnyard  and Animal Waste Storage Areas."  Tentative findings from the
early stages of the investigation of several dairy farm impoundments
have been provided to the SIA as a courtesy by two of the participants
in the study, soil scientist Fred Madison and hydrogeologist Ron Hennings,
both of the WGNHS.

Preliminary reports are available on the investigations at four north-
western Wisconsin dairy farms, where impoundments have been constructed
on soil types ranging from coarse, clean glacial  outwash to relatively
tight clayey silt.  A series of monitoring wells  was  positioned around
each pond, including both up and down gradient directions from the pond.
Samples from the wells have been analyzed for conductivity, chloride and
nitrate (reported as N03-N).

Early monitoring results from this study must be  regarded as inconclusive,
because runoff from animal exercise yards and farm fields adjacent to
manure ponds may contribute contaminants to the groundwater, and monitoring
wells installed in barnyards, fields or exercise  areas may have been
accidentally contaminated during installation. While early sampling
around three ponds (both lined and unlined) on sandy  soils found NC^-N
values in some wells to exceed the drinking water standard of 10 mg/1,
it is expected that continued sampling will help  to indicate what fraction
of the nitrate is attributable to ponds, and what is  due to other sources.
Future studies for this project will include monitoring around a manure
pond to be built on a site that has not been farmed in many years, which
should provide an opportunity to test the impact  of ponds independent of
other sources.

Though monitoring results are inconclusive, some  observations made by
investigators and pond owners bear on the effectiveness of the "self
sealing" mechanism discussed in SCS technical  guidelines for pond design
(see sec. 7.4.1 of this report)..  One unlined pond on sandy soil had not
filled to capacity, nor had it been pumped to remove  waste, despite
continuous use over a year's time.  This indicated to researchers that
fluids were seeping readily into the ground.  The owner of this pond has
observed no reduction in the rate of decline in the pond's liquid level
since it was first installed, suggesting that no  self sealing process
has yet begun to operate.  The owner of another pond, located on medium
to coarse-grained outwash sand and lined with soil described as "fine-
grained sand and silt, with minor amounts of clay," also reports a
continuing decline in fluid levels.  Other research has indicated that
self sealing usually does occur eventually, but that  the seals are
frequently lost, particularly on pond sides, when wastes are removed
from the pond for field spreading, allowing natural processes such as
drying and freeze-thaw to cause cracking or erosion of exposed portions
of the pond seal.

Chapter 7:     Evaluation of Existing State Programs
Summary:  All non-agricultural waste impoundments in Wisconsin are
subject to some form of regulation under one or more of several programs
administered by Wisconsin DNR.  Wastewater absorption ponds must be
permitted under the Wisconsin Pollutant Discharge Elimination System
(WPDES).  Such permits may be contingent on compliance with certain
requirements, such as limitations on the concentrations of contaminants
in waters discharged to absorption systems.  Plans for wastewater treatment
facilities, including any treatment, storage or absorption impoundments,
must be reviewed and approved by DNR water quality personnel prior to
construction.  A few impoundments are subject to regulation as solid
waste sites, and are subject to requirements for preliminary plan approval
and periodic licensing.  Agency personnel report that impoundment operators
have generally cooperated with their efforts to enforce these regulations.

Agricultural waste impoundments are not subject to state regulation
because the state legislature, which has consistently opposed regulation
of animal wastes, has preempted the authority to make rules in this
area.  Government involvement with agricultural impoundments has been
limited to the provision of financial and technical assistance for
design and construction.  Proposed revisions to current state water
supply regulations may include provisions to control agricultural
impoundments to protect groundwater supplies from contamination.

7,1  Introduction

In 1977, a memo prepared by the Legislative Council staff (Greenberg,
1977) identified seven state agencies and one federal agency having some
responsibility for the regulation, investigation or management of groundwater
resources in Wisconsin:

     A.    Wisconsin Department of Natural Resources (DNR)
     B.    Wisconsin Geological and Natural History Survey (WGNHS)
     C.    University of Wisconsin Water Resources Center
     D.    The State Laboratory of Hygiene
     E.    Wisconsin Department of Health and Social Services (DHSS)
     F.    Wisconsin Department of Administration (DOA)
     G.    Wisconsin Public Service Commission (PSC)
     H.    United States Geological Survey (USGS)

The USDA Agricultural Stabilization and Conservation Service (ASCS) and
Soil Conservation Service (SCS) and the State Board of Soil and Water
Conservation Districts (BSWCD) also have indirect involvement with
groundwater through their soil and water conservation programs.

Six of the listed agencies are now directly concerned with surface
impoundments as they may affect groundwater quality.  Most of the programs
that address impoundments are under the authority of the DNR, which has
responsibility for a broad range of natural resource functions.  The

ASCS and BSWCD are involved in agricultural  waste ponds  by providing
cost-sharing assistance for their installation.   The SCS's involvement
is in providing technical  assistance for the design  and  installation of
manure ponds.   Both the WGNHS and USGS are currently engaged in research
activities addressing the groundwater impacts of impoundments.

7.2  DNR Programs

The Wisconsin DNR was created in 1967 to consolidate the state  govern-
ment's natural resource functions within a single department.   The
agency is governed by the Natural Resources Board, comprising seven
citizens nominated hy the governor and approved by the Wisconsin Senate.
The DNR's regulatory authority over surface impoundments is based primarily
in Chapters 144 ("Water, Sewage, Refuse, Mining and  Air Pollution")
and 147 ("Pollutant Discharge Elimination") of the Wisconsin Statutes.
Programs addressing impoundments are administered by the Bureau of
Water Quality and the Bureau of Solid Waste Management,  both in the
Division of Environmental Standards.

7,2.1     Programs Administered by the Bureau of Water Quality

The wastewater regulatory programs of the DNR, administered by  the
Municipal and Industrial Wastewater Sections, oversee most of the
regulated impoundments in Wisconsin, through the federally-mandated
Wisconsin Pollutant Discharge Elimination System (WPDES) and the state's
own wastewater plan approval program.  In addition,  the Environmental
Fee program, in the Pretreatment and Fees Section, maintains an inventory
of industrial waste disposal activities, including partial data on
impoundment use,  Water quality planning under section 208 of the Federal
Water Pollution Control Act is carried out under the direction  of the
Water Quality Planning section (this program is described in Section 8.2
of this report), and the Special Studies section administers state cost-
sharing grants for agricultural waste impoundments and other practices
to abate nonpoint-source pollution of surface waters.

7,2,1.1   Wisconsin Pollutant Discharge Elimination System

The Wisconsin Pollutant Discharge Elimination System (WPDES) was esta-
blished by Chapter 147 of the Wisconsin Statutes as a state pollutant
discharge system meeting the requirements of P.L. 92-500.  WPDES regulates
municipal and industrial wastewater discharges to surface waters and to
land areas (from which pollutants may percolate, seep or be leached  to
groundwater) by means of "permits to discharge".  WPDES permits are
issued on condition that discharges meet all effluent quality and quantity
limitations, monitoring and reporting requirements and schedules of
compliance specified in their permits.  Effluent limitations, standards
of performance for new discharges, and pretreatment standards for specific
industries are defined in a series of administrative codes pursuant  to
Chapter 147.  Under Section 147.021, such rules and standards must
"comply with and not exceed" federal regulations under P.L. 92-500.
WPDES is administered by the Municipal and  Industrial Wastewater Sections.

Wastewater absorption ponds are  regulated under WPDES as  land disposal
activities that may result  in indirect discharges to the  groundwater.
Natural Resources Code 214  (NR 214) establishes special effluent quality

limitations and other requirements for liquid waste discharges to land
disposal systems, as well as groundwater monitoring requirements and
provisions for requiring pretreatment prior to land disposal.   NR 214
contains specific limits for discharges from municipal  treatment plants,
canneries, dairies, meat processing facilities, and the production of
sand, gravel, stone or concrete.  Limitations on discharges to land
disposal systems from sources not included in these five categories may
be applied by the department on a case by case basis.   Under NR 214,
municipal facilities may not use absorption ponds for waste streams that
have not undergone secondary treatment and pretreatment of any industrial
inflows.  A limit of 50 mg/1 of 6005 (which may be exceeded in no more
than 20% of the effluent samples in a year) is specified for discharges
to any newly constructed absorption ponds; existing municipal  (but not
industrial) absorption ponds must meet the same limit by July 1, 1983.

The WPDES program is designed to regulate discharges to the "waters of
the state", and has no jurisdiction over the contents of artificial
impoundments for the storage or treatment of wastes.  However, some
program provisions have indirect effects on the use of impoundments for
these purposes.  For example, industries which discharge pollutants to
publicly owned treatment works are regulated under NR Code 211, which
establishes standards for pretreatment and prohibits the transfer of
certain wastes to treatment works (NR 211.10).  Non-disposal surface
impoundments (e.g., aeration or settling lagoons) are often utilized
in the pretreatment process to remove or reduce the pollutants con-
sidered incompatible with the normal operation of municipal treatment
works.   Specific pretreatment standards (as well as effluent limits) for
these industries are included in Wisconsin Administrative Code Chapters
NR 221  through NR 299.   Wastewater Facility Plan Approval Process

Sec. 144.04, Wisconsin statutes, requires all entities that own or
operate water supply, sewerage or water systems, or sewage and refuse
disposal plants in the state to submit any plans for new facilities or
facility modifications to the DNR for review and approval prior to
construction. Natural Resources Administrative Code 108 sets out procedures
and other rules for the plan approval process.  The Industrial and
Municipal Wastewater Sections administer the wastewater plan approval

In general, plans are checked to ensure that facilities are adequate to
provide required treatment, are not in conflict with any area-wide waste
management plans, meet requirements for minimum distances from water
wells and other protected uses, and comply with currently accepted sound
engineering practice.

A DNR guideline document for land absorption systems (Wisconsin DNR,
November 1975) contains technical information and standards for siting,
construction, operation and groundwater monitoring of absorption impound-
ments and other land disposal systems.  This document provides technical
guidance on concerns to be addressed in reviewing plans for these systems,
as well as some specific standards to be followed in their design (e.g.,
depth to groundwater or bedrock beneath an absorption pond must be at
least 10 feet).


Sec.  NR 110.28, a portion of the Natural  Resources  Code respecting
sewage systems, sets out procedures and standards for the design and
siting of treatment lagoons used in municipal  facilities.   Though its
use is not legally required, Industrial Wastewater  Section personnel
report that they apply NR 110.28 in the review of plans for industrial
wastewater lagoons, too.  Sec.  NR 110.28(3)(b) requires that "'Lagoons
shall  be located to minimize the potential  of groundwater pollution".  A
note to this clause recommends  that pond bottoms be at least 3 feet
above the "high groundwater" level and 5 feet above bedrock, and requires
that primary stabilization cells "and the first 2 cells of an aerated
lagoon shall be adequately sealed to prevent loss of liquid such that
the design operating depth can  be achieved and maintained".  Also,
consideration is to be given to the types of subsoil  and bedrock beneath
the pond.  New reguiations for the design of municipal facilities are
currently being developed in the Municipal  Wastewater Section.

Where specific standards are not written into current Wisconsin waste-
water regulations, the recommendations outlined by the Great Lakes-Upper
Mississippi River Board of State Sanitary Engineers (1978) (commonly
known as the "Ten States Standards") are often used for guidance in the
plan approval process in both the Municipal and Industrial Wastewater
Sections,  One area in which Wisconsin wastewater personnel often deviate
from these recommended standards is in specifications for bottom seals
in treatment lagoons.  Rather than following GLUMRB's recommendation
that the ratio of liner material permeability (cm/sec) to liner thickness
(cm) be 3.0 x 10~9 or less, informal policies permitting somewhat less
stringent (more readily attainable) permeabilities  are used.  The Municipal
wastewater Section seeks to reduce leakage to a volume that will not
significantly affect lagoon water depth.  In seeking to provide water-
tight systems, the Industrial Wastewater Section has required liner
permeabilities of 10"^ to 10~8 cm/sec in recent facility approvals, with
more stringent standards (e.g., involving concrete and/or manufactured
liners) applied to lagoons holding persistent or potentially toxic waste

Because administration of the WPDES program and review of waste treatment
plans require substantial expertise in sanitary engineering, water
chemistry,  and chemical engineering, the staffs assigned to these  tasks
consist primarily of people trained in these areas, who may be poorly
prepared to evaluate geologic and groundwater conditions at the sites of
planned impoundments.  However, a few staff members have backgrounds in
geology or hydrology, and are available to review these aspects of
facility plans.  Currently their expertise is not used consistently  in
all plan reviews, and the SIA found that some impoundments may have  been
sited or designed without proper regard for hydrogeologic conditions
(see Chapter 4). One of the SIA's recommendations is that a hydrogeologic
evaluation by a person  competent in this area be made a part of any
wastewater plan review  involving land  disposal or use of any impoundment.

Records of plan approvals  (some dating back to 1919, when  they were
first required for some facilities) have been placed on microfiche  and
are on file at the DNR.  Though much useful information on  the design
and construction of  facilities  is  available, the files are often incon-
sistent  in  the types of information retained.  This situation has improved
in recent years, but the SIA recommends that  a standard policy be adopted
regarding the  types  of material to be microfiched, so that  consistency
in this  area  is maintained over time.

                                6o  Environmental Fee Program

The Environmental Fee program of the Wisconsin DNR has no federally
mandated analogue, but was established by section 144.54, Wisconsin
Statutes.   The program operates under the Wisconsin Administrative
Codes, Chapter NR 101, and is known informally as the "NR 101  program."

Under the provisions of section 144.54, Stats., and Chapter NR 101, non-
municipal  facilities that discharge industrial wastes, toxic or hazardous
substances, or air contaminants to a surface water, a land disposal
system, a publicly owned treatment works or the atmosphere must report
annually on the volume and composition of their waste discharges.
Reports on wastewater discharges are required of all facilities with
effluent volumes of 10,000 gpd or more, as well as lower volume dis-
chargers whose effluents are covered by a pretreatment standard adopted
pursuant to section 147.07, Stats., or whose WPDES permit requires
monitoring of the effluent or groundwater (for land disposal systems).
Fees are assessed according to the amounts of pollutants discharged.
Wastewater discharge fees collected under the Environmental Fee program
are designed to generate sufficient revenue to recover 30% of the state's
cost for the administration of most pollution control related functions.

The Environmental Fee program is not intended to regulate waste disposal
practices; rarely are its fees high enough to act as significant incentives
for reduction of pollutant discharges.  The waste inventory maintained
by the program is, however, a valuable resource for other state programs
dealing with waste disposal.  Each industry must supply this program
with the results of chemical analyses of its waste stream, providing a
higher degree of detail than would otherwise be available on discharges
to surface waters, land disposal (absorption) systems, and municipal
treatment works.  Though there are no reports on the actual contents of
impoundments, these reports provide the best available data on the
nature of the wastes that enter absorption impoundments and leave treatment
impoundments.  The NR 101 files, containing waste reports and small-
scale maps of facilties, form a compact and accessible source of information
on industrial waste disposal.  Long-term maintenance of these files may
prove useful in future groundwater contamination investigations, as well
as for similar, as yet unforeseen, uses.  Wisconsin Nonpoint Source Water Pollution Abatement Program

Section 144.25 of the Wisconsin Statutes, established by the legislature
in 1977, sets up a program of grants (part of the Wisconsin Fund,  which
also provides grants for point source water pollution abatement and
solid waste management assistance) to provide financial assistance to
individual landowners, operators and municipalities for abatement of
nonpoint source water pollution.  Appropriations for the first three
years of grant funding under this program (beginning with the 1978-79
fiscal year) exceed $4 million.

Policies and procedures for administration of the grant program are
contained in Chapter NR 120 of the Wisconsin Administrative Code.
Primary responsibility for program administration is assigned to the

Special  Studies Section of the DNR Bureau of Water Quality.   The  State
Board of Soil  and Water Conservation Districts and several  "local  desig-
nated management agencies", including county soil  and water conservation
districts (SWCD's), share responsibility for program implementation.

Grants are intended for implementation of projects expected to achieve
significant improvements in water quality.   Project participants  may
receive cost-sharing grants for implementation of "best management
practices", defined in sec. 144.25(2) to mean "practices,  techniques  or
measures, identified in areawide water quality management  plans,  which
are determined to be the most effective, practicable means  of preventing
or reducing pollutants from nonpoint sources to a level compatible with
water quality goals."  Section 144.25 and NR 120 describe  a complex
process for selection of projects to receive funding.  Funding priorities
are based in part on statewide priorities identified through the  section
208 basin planning process and related water quality planning activities;
also, local designated management agencies may submit applications for
funding of "local priority" projects in smaller areas outside of
"priority watersheds."  Cost-sharing conditions of Wisconsin Fund projects
are coordinated with ASCS cost-sharing programs to assure  compatibility
with federal programs.

Animal waste storage impoundments are identified as a best  management
practice for abatement of pollution due to manure carried  in runoff from
fields, and thus may be eligible for cost-sharing assistance as part  of
an eligible project.  During the 1978-79 fiscal year, 36 proposed animal
waste management facilities (mostly impoundments) were approved for
cost-sharing assistance as parts of local priority projects in eight
counties.  The four priority watershed projects approved to date  could
include as many as 408 animal waste impoundments when project implemen-
tation is complete; another priority watershed project now awaiting
state approval would utilize 23 impoundments.

One condition of cost-sharing assistance under the Wisconsin Fund
nonpoint source water pollution abatement program is compliance with
applicable standards, specifications and design criteria contained in
the 1978 edition of the SCS technical guide.  This means that appropriate
SCS or SWCD technical personnel must be consulted for design assistance,
and their recommendations must be followed in construction.  The requirements
of the technical guide that address groundwater protection in the design
of manure ponds are reviewed in section 7.4.1 of the present report.

7.2,2  Programs Administered By the Bureau of Solid Waste Management

State programs for the regulation of solid wastes, hazardous wastes,
mining wastes and servicing of septic systems are administered by the
DNR Bureau of Solid Waste Management.  Though the Bureau of Water Quality
has authority over most regulated impoundments, some types of impound-
ments fall under the jurisdictions of these four "solid waste" program

                               52  Non-hazardous Solid Wastes (Residuals)

Statutory authority for State regulation of solid waste handling and
disposal is contained in Chapter 144, Wisconsin Statutes.   Chapter 144
was amended in 1977 to bring the State's solid and hazardous waste rules
into conformance with the U.S.  Resource Conservation and Recovery Act of
1976 (RCRA).  The relevant administrative rules have also been updated
in the form of a new code, NR180, which will  replace the old solid waste
code,  NR151, early in 1980.

Though only a few existing impoundments have  been regulated as solid
waste sites in the past, new definitions of "solid waste" included in
RCRA and the new State rules are expected to  increase Solid Waste's
jurisdiction over surface impoundments.  Under section 144.30 of the
statutes, "solid waste" now includes "liquid, semisolid, or contained
gaseous materials",  as well as traditional solid wastes.  However,
wastewater operations permitted under WPDES or approved under section
144,04 are specifically excluded from NR180,  so the majority of impound-
ments will remain in the jurisdiction of the  wastewater program.  Current
policies on the resolution of jurisdictional  conflicts between the
wastewater and solid waste programs are detailed in section 7.3 of this

Since NR180 is not yet in effect, all of the  inventoried impoundments
that are regulated as solid waste sites have  been subject to the requirements
of NR151.  There are no specific provisions for surface impoundments in
NR151,  so impoundments have been regulated according to the provisions
of NR151.12,  which sets forth criteria for siting, design, operation
and closure of land disposal operations (principally landfills).

Under NR151, impoundment operations classified as solid waste sites are
required to obtain operating licenses.   These are issued initially upon
approval of facility plans, and renewed annually on condition of continued
compliance with all applicable regulations.  The key requirement of
NR151.12 relative to groundwater protection is section NR151.12 (4)(d):
"Solid waste land disposal operations are prohibited...within an area
from which the Department finds that leaching from solid waste may have
a detrimental effect on groundwater quality."  This clause gives the DNR
some discretion in reviewing license applications and in seeking closure
of existing facilities that are found to be endangering groundwater
quality.  To aid in site review, NR151.12 (5) lists specific information
(including geologic data)  to be included with applications for approval
of new or expanded sites.  In addition to approving or rejecting proposed
sites, the DNR is authorized by NR151.12 (5)(e) to require groundwater
monitoring and/or "provisions for protection  against possible detrimental
effects of leachate...production," but the regulations do not list any
specific requirements for liners, leachate collection systems, monitoring
set-ups,  etc.

Section NR151.12 (10) specifies procedures to be followed in closing a
land disposal facility that has filled to capacity or that has been
required by DNR to cease operation.  This section requires a final soil
cover and establishment of vegetation,  and authorizes the DNR to require


continued groundwater monitoring, if this is deemed necessary.   Under
section NR151.12  (11), responsibility for clean-up and closure of
unlicensed land disposal  operations is assigned to the site operator or
to the property owner who permitted the disposal  to take place.

Unlike NR151, NR180 will  include  specific mention of surface impound-
ments,  and provides for their regulation either as non-containerized
waste storage facilities (section NR180.07) or as land disposal facilities
(section NR180.13).   Siting criteria, requirements for license applications,
and operating standards listed in NR180 are much more detailed than
those of NR151,  though the codes are generally similar in substance.  A
preamble to the Natural Resources Board order creating NR180 indicates
that most of the technical  detail in the new code simply reflects procedures
under which the sond waste program has operated for several years.

The requirements that will  apply  to licensing of impoundments under the
solid waste program are contained in section NR180.13.  The specific re-
quirements for initial site investigations listed in the code include
minimum numbers of soil borings  (also listed in NR151), minimum boring
depths, specifications for soil permeability tests and development of
observation wells, and procedures for abandonment of observation wells.
Some analysis of the data is required, and license application packets
must include interpretations of subsurface stratigraphy, water table
maps with predicted seasonal changes, cross-sectional groundwater flow
nets, and predictions of leachate generation rates based on site-specific
water budgets.  Specifications for site plans and other included materials
are similarly detailed.

Under NR180, the DNR's authority  to reject license applications because
of possible groundwater contamination appears to be slightly broader
than under NR151.  NR180.13 (3) prohibits land disposal sites  "within an
area where the Department after  investigation finds that there is a
reasonable probability that disposal of solid waste within such an area
will have a detrimental effect on groundwater quality'.  (The  principal
changes from NR151 are the deletion of "leaching from solid waste" as
the only cause of a "detrimental  effect" and the substitution  of "reasonable
probability (.of an effect)" for  "may have (an effect)")-  However, the
courts (and NR 180) have defined  "detrimental effect on groundwater
quality" to encompass only groundwater "for present or future
consumptive or nonconsumptive use," possibly hampering the DNR's ability
to order site closure under this  clause.

Section 180.13 (11) authorizes DNR to require groundwater monitoring
programs at any solid waste site.  This section also outlines  minimum
requirements for monitoring programs, including numbers of wells (three
or more are needed), monitoring  frequency and sampling parameters.

Under NR180, closure requirements for disposal sites will be similar to
those existing under NR151.  Impoundments licensed as  non-containerized
solid waste storage sites (under section NR180.07) will be subject to
special closure rules set out in section NR180.07  (9).  Under  these
rules,  all waste must be removed from the impoundment  (and properly
disposed of) and  the site restored.

Section 144.441, Wisconsin statutes, provides for long-term care of
solid waste land disposal  sites.   Site owners are responsible for care
for the first 20 to 30 years after site closure.   Section NR180.15
establishes requirements for bonding, deposits with the DNR, or payments
to escrow accounts to ensure that funds will  be available to execute
this responsibility.   To provide for site care beyond the term of the
owner's responsibility, and to pay for "repair of environmental damage
caused by a site as a result of occurrence not anticipated in the plan
of operation",  the same section of the statutes  calls for establishment
of a State Waste Management fund.  The fund,  to be operated under
section NR180.16, is  to build up through periodic payments from the
owners and operators  of solid or hazardous waste  disposal sites, assessed
according to the amounts and types of wastes  received.

The solid waste codes do not specify standards for acceptable sites or
designs for land disposal  systems to minimize groundwater impacts.
However,  in recent years, NRlSl's prohibition of disposal where it may
have detrimental effects or groundwater has been  used to support rigorous
"technology based" controls (e.g., requirements for clayey subsoils
and/or thick liners)   on leachate migration.   The staff of the Land
Disposal and Residuals Management section of the  Bureau of Solid Waste
Management, consisting primarily of civil engineers and hydrogeologists,
gives high priority to groundwater concerns in investigating disposal
sites, though chronic understaffing in this section often hampers its
ability to administer the full program effectively.   Hazardous Wastes

Wisconsin's Hazardous Waste Management Act comprises sections 144.60 to
144,74 of the state statutes.  The Act, passed in 1977, incorporates the
hazardous waste provisions of RCRA into Wisconsin law, expanding state
jurisdiction in this  area and allowing the state  to administer RCRA
hazardous waste rules when they become effective.  A new administrative
code, NR 181, will incorporate EPA's hazardous waste rules, as well as
additional regulations to be developed by the state.  The Hazardous
Waste Management Section of the Bureau of Solid Waste Management will
administer these regulations.  Section 8.3 of this report discusses the
expected role of the  new hazardous waste rules in the regulation of
surface impoundments.

Until new regulations go into effect, the disposal of hazardous wastes
will continue to be regulated under sec. NR 151.12, which includes
special provisions for hazardous waste disposal.   Other portions of the
interim program for hazardous waste management operate under other
sectons of Wisconsin  law.   Mine Tailings

Under the 1977 amendments to Chapter 144 of the Wisconsin Statutes, mine
tailings are to be defined as solid waste, and their disposal regulated
tinder the solid waste program.  Previously, sec.  NR 151.12(1) specifically
exempted these wastes from the provisions of NR 151.  (Discharges from

tailings ponds have been regulated under WPDES,  and Chapter  144  will  not
affect jurisdiction over these discharges).   Under the revised  statute,
mining wastes are included in the definition  of  "solid waste",  and sec.
144.43(lm) requires DNR to adopt (subject to  approval  of the state's
Metallic Mining Council) rules for the regulation of metallic mining
wastes.  Until such regulations are developed, NR 180 is to  govern the
handling and disposal  of metallic mining wastes,  including  any  impoundments
used for mine tailings.  Only one metals mine is  currently  active, and
therefore subject to such regulation,  but recent  ore discoveries have
created a potential for greatly increased activity in this  area.   Servicing of Septic Systems

Section 146.20 of the Wisconsin Statutes provides that "The  Department
of Natural Resources shall adopt rules relating  to the business  of
service septic tanks,  seepage pits, grease traps  or privies," and provides
for licensing of persons engaged in servicing these systems.  The adminis-
trative code implementing sec. 146.20  is NR 113,  and administration of
NR 113 is currently assigned to the Bureau of Solid Waste Management.
Though this code is being revised, this report will address  primarily
the current NR 113 program and the provisions of  the existing code.

The provisions of NR 113 that are potentially applicable to  surface
impoundments are those respecting the  storage and disposal  of septage
and the handling of any liquid industrial wastes  hauled by NR 113

Sec.  NR 113.07 addresses the disposal  of domestic wastes (primarily
septage) by persons engaged in servicing domestic waste systems.  The
preferred method of disposal is discharge to  a  public sewerage  system
(with approval of the municipality accepting  the waste), with discharges
to licensed sanitary landfills listed  as the  best alternative if no
public sewerage system is available for use.   Where these choices are
unavailable, burial, "plowing in" or landspreading of wastes are permitted.
Requirements for proper use of these methods  are listed.  Use of surface
impoundments for disposal of these wastes appears to be barred by
statements prohibiting the accumultion of "pools  of waste"  (s.  NR 113.07(3))
and the discharge of waste to "any ditch,,..pond, lake,...sinkhole, mine,
gravel pit, or quarry,"  However, sec. NR 113.07(7) provides for the use
of lagoons for waste storage, with prior DNR  approval of lagoon plans.
In the past, such approval has been granted on  an informal  basis, and no
records have been kept concerning the  numbers,  locations, owners or
specifications of lagoons used for storage of septic waste.   Under
current administration of the NR 113 program, formal applications for
approval of storage lagoons are required.  The  first such formal
application was received in 1979 (after the closure of the SIA

Some septic pumpers and waste haulers  also handle  liquid industrial
wastes.   In order to allow regulation of the handling and disposal of
these wastes under the NR 113 program, the statute's definition of
"septic tank"  (sec. 146.20(2)(b)) lists "industrial wastes" among
the waste types that might be contained in a septic tank.  Sec.
NR 113.08 lists regulations for the handling of  liquid industrial
wastes by NR  113 licensees, and provides that "the approval of  liquid

industrial waste disposal by servicing vehicles shall  be considered on
a case-by-case basis by the department" (Sec.  113.08(1)).   A note of
this section points out that liquid industrial  waste disposal could also
be governed by WPDES or the solid waste program.   A 1979 status report
on the industrial waste provisions of NR 113 (Updike,  1979) indicates
that these programs (which have expanded their jurisdictions since 1975,
when NR 113 was intended to regulate.  For this and other reasons, it is
expected that provisions addressing the disposal  of liquid industrial
waste will be substantially modified in the next revision of NR 113.

7.2.3     Groundwater Monitoring and Data Utilization   Introduction

Though DNR regulatory programs emphasize "technology based" controls to
prevent groundwater contamination, groundwater monitoring is also
utilized at some land disposal sites.  As discussed below, the different
regulatory programs place differing levels of emphasis on monitoring
activities, and use monitoring results in different ways.   All programs,
however, report problems in managing data from groundwater monitoring,
and are developing new approaches to data management that should allow
more efficient use of monitoring results.   Monitoring Requirements

Land disposal facilities permitted under WPDES are required to have
groundwater monitoring if wastewater inflows exceed threshold volumes
specified in NR 214, and monitoring may be required at other sites on a
case-by-case basis.  Monitoring schedules are included in the WPDES
permits of those facilities where monitoring is required.   The normal
reporting schedule requires monthly monitoring for the first three
months after a system is installed, with semi-annual reporting thereafter.
More frequent sampling may be required where discharge volumes are
unusually large, pollutant loading rates are high, or waste streams
could contain potentially hazardous materials.

The Industrial Wastewater Section currently requires groundwater moni-
toring at approximately 60 permitted land disposal facilities.  Forty-
six of the monitored sites utilize spray irrigation land disposal systems.
Monitoring is also done around nine absorption impoundments and five
ridge and furrow systems.  The number of monitoring wells at each site
ranges from two to ten, with a reported average of about five wells per
site.   (Data collected for the SIA inventory indicated that most monitored
industrial impoundment sites use only two wells.   This discrepancy may
reflect actual conditions at absorption pond systems,  which tend to be
smaller in area than other land disposal systems, but it may be due in
part to difficulties the SIA had in recovering data on monitoring from
DNR files.)

Sixteen facilities with land disposal systems permitted by the Municipal
Wastewater Section are currently required to report on groundwater
i :onicoring results,  A few others operate groundwater monitoring
systems of their own volition, and monitoring will be required at
several facilities now in the plan review process.  The numbers of
monitoring wells at these 16 facilities range from two to five, with an
average of three per site.


Wastewater plan approvals for non-disposal  lagoons  do not ordinarily
require groundwater monitoring programs to  detect contamination due to
seepage.   However, a least one industrial  facility  has been required to
implement monitoring for this purpose as a  condition of plan approval.

SIA staff members reviewed plans for several  WPDES  groundwater moni-
toring installations and visited a few impoundment  sites with ground-
water monitoring.  These activities revealed  problems with monitoring
system design and installation, such as monitoring  wells located extremely
close to the absorption pond (even in the pond dike), a shallow ground-
water flow pattern delineated on the basis  of several old engineering
borings located no closer than 0.4 miles from the site, and upgradient
"background" wells that record significant  contamination (not necessarily
due to the monitored impoundment).  A DNR staff guidance memorandum,
"Requirements for Groundwater Monitoring Installations , drafted December 4,
1979, contains guidance for delineating groundwater flow directions,
siting wells, well construction and related topics.  This document is to
be consulted during the review of monitoring  system plans, and should
help to improve the design of future monitoring installations.

The solid waste program currently requires  some 119 licensed land
disposal sites to conduct groundwater monitoring programs.  Others have
inactive monitoring installations.  Virtually all newly licensed sites
are required to install monitoring systems  as a condition of their
licenses.  Frequency of sampling varies, though most licenses call for
sampling four times a year.  Solid waste personnel  estimate that the
average monitoring system uses about six wells.  Since very few inventoried
impoundment sites are licensed under the solid waste program, the SIA
did not conduct a review of groundwater monitoring practices at solid
waste sites,

7.2,3,3   Use of Monitoring Results in Regulatory Program

Monitoring results submitted to DNR by WPDES  permittees and solid waste
licensees are first checked for compliance with permit or license require-
ments specifying sampling frequency and parameters to be sampled.
Results are then compared with available background water quality data,
results from previous sampling of the same wells, etc., to determine
whether contamination problems exist.

To date, most monitoring reports submitted by municipal wastewater
facilities have shown low levels of most monitoring parameters (i.e.
below all drinking water tolerances; some parameters are even below
background concentrations).  When higher values have been reported, the
section has not taken action because the high results appear to be
attributable to improper sampling or analytical procedures or to con-
taminant sources other than wastewater disposal.

The industrial wastewater and solid waste programs have generally used
rapid or abrupt increases in levels of sampling parameters as indicators
of contamination problems,   (No groundwater quality standards are used
in Wisconsin; rather, DNR policy  is to attempt to prevent all degradation
of groundwater quality.)  When monitoring results suggest that contamination

has occurred, additional sampling is carried out to gauge the accuracy
of the results and the seriousness of the situation, and to determine
the rate and direction of movement of any contaminant plume.   If this
extended investigation shows that contamination is occurrinn, DNR nersonnel
meet with facility operators to develop a plan for further action.
Industrial wastewater personnel report that operators generally have
been cooperative with the department's requests for modifications in
their operations when groundwater contamination has been detected.
Though no case involving groundwater contamination at a lagoon site
permitted and monitored under WPDES has ever reached litigation, the DNR
could order site closure or clean-up under sees. 144.025(k) and 146.14
of the statutes, which authorize the department to act to "order or
cause the abatement of any nuisance affecting the waters of the state".
The solid waste program has sometimes resorted to litigation (under
authority of sec. NR 151.12(4)(d), as discussed in sec. of .this
report) to force closure or other action to abate groundwater contamination
at land disposal sites; it is not known whether any litigated cases have
involved impoundments.

7,2.3.4   Management of Monitoring Data

The use of groundwater monitoring has increased markedly in recent
years, and resulting problems in data management have hampered efforts
to make optimal use of monitoring results.

In the WPDES program, tracking of data submittals to ensure that facilities
are complying with groundwater monitoring requirements is tied in with
tracking of facility self-monitoring reports on effluent parameters and
other permit requirements.  A computerized system is used effectively to
keep track of permit requirements and data submittals.   However,
groundwater monitoring results are not stored in a computer data system,
so data retrieval and analysis must be carried out manually.   The
Municipal Wastewater Section, receiving a relatively small volume of
monitoring data on a group of highly similar facilities, has been able
to analyze monitoring results manually to identify trends in groundwater
quality around monitored land disposal sites, with findings that should
have useful application in the regulatory program.  The Industrial
Wastewater Section has not been able to perform any analysis more
sophisticated than recording site-specific trends in water quality, and
is currently exploring the development of a computerized data management
system to improve its capabilities for storage, access and analysis of
groundwater monitoring data.  The Municipal Wastewater Section may also
use such a system to increase analytical efficiency.

The Bureau of Solid Waste, with much more monitoring data than either of
the wastewater programs, has had difficulty in the past in tracking
compliance with its groundwater monitoring requirements, and its analysis
of groundwater data has been limited to following trends at specific
sites.  An extensive system for computerized data management is  now in
the final stages of development, and is expected to improve compliance
tracking and to allow detailed analysis of the groundwater impacts of
specific types of disposal practices or groups of hydrogeologically
similar disposal sites.

7.3  Areas of Overlapping Authority

Regulatory authority for a few types  of impoundments is  shared by the
DNR wastewater regulation and solid waste programs.   New definitions of
"solid waste" introduced by RCRA and the 1977 amendments to Wisconsin
solid waste statutes have increased the possibility of overlaps.   The
differing requirements of the two programs have sometimes confused
permittees and resulted in different design requirements for impound-
ments that are essentially similar.  Most areas of overlap involve
wastes that are part solid and part liquid:  water treatment sludges,
wastewaters containing fly ash, leachate collected at landfills,  etc.
About 5% of the inventoried impoundments are designated as "sludge
lagoons," "leachate collection ponds," or "fly ash pits;'  many more may
contain these materials but are not so clearly designated.  Current
policies and proposed policies concerning these types of impoundments
are summarized below.

7.3.1  Sludge

The management of waste sludges (primarily generated by water and
wastewater treatment processes) frequently involves the use of impound-
ments for treatment, storage or disposal.  According to legal opinion,
the Wisconsin Statutes can be interpreted as assigning authority for
sludge management to both the wastewater and solid waste programs of
DNR, and each program now administers some controls on sludge handling
and disposal.  An ad hoc interbureau committee of the DNR has reviewed
the current administration of sludge management and recommended policies
for a coordinated program in this area.  The present review of program
provisions affecting sludge impoundments draws heavily upon the report
of this sludge management committee (submitted October 3, 1979).   Statutory
authority for regulating sludge management under the solid waste program
is found in sec. 144.30(4), which defines sludge as a solid waste,
thereby potentially subject to solid waste disposal regulations established
under Ch, 144.  Section 147.02(1) prohibits "the disposal of sludge  from
a treatment work .   . . unless such .  . . disposal is done under a permit
(WPDES) issued by the Department," apparently assigning sludge disposal
responsibilities to the wastewater sections of the Bureau of Water
Quality.  Sec. 144.04, in requiring that proposals for construction  or
expansion of wastewater treatment facilities be submitted to DNR, also
gives the wastewater sections  (which have traditionally administered
plan approvals) authority over water treatment facilities which generate

Currently, municipal sludge management is handled by the Municipal
Wastewater section  under the WPDES program.  Under the section's  "Sludge
Management Planning Program," municipalities are assisted in developing
sound sludge treatment handling and disposal practices, and  schedules
for  implementation  of sludge management  programs are included in  the
compliance schedules in WPDES  permits.

Responsibilities for industrial  sludges are divided between the solid
waste and industrial wastewater programs, under a series of formal  and
informal agreements.  The Industrial  Wastewater Section is responsible
for plan review and approval of treatment facilities, including settling
lagoons, clarification equipment and facilities for other processes.
The Solid Waste program regulates the permanent disposal of sludges in
municipal landfills and in separate sludge landfills.  Definition of
responsibilities becomes somewhat hazy in the area of sludge settling
lagoons, and is based on the long-term intentions of the lagoon operator.
If solids are to be removed periodically and disposed of at a licensed
solid waste site, no solid waste license is needed for the lagoon itself.
However, if settling lagoons are to be abandoned after they are filled
with solids, they must be licensed as solid waste disposal facilities.
When two DNR permits are required for a single facility (both WPDES and
Solid Waste), only a single plan review is to occur, under the direction
of the  Industrial Wastewater Section.  (The sludge management committee
noted that in spite of the stated policy, both sections frequently
conduct separate plan reviews.)

Implementation of the recommendations of the sludge management committee
would not change the assignment of responsibilities for non-hazardous
sludge  impoundments, though policies would be formalized.  A training
program and formal lines of interbureau communication would be established
to coordinate sludge management activities and to ensure equivalency in
the two programs' approaches to environmental protection in the area of
sludge management.  Sludges classified as hazardous wastes would be
regulated by the Hazardous Waste section of the Bureau of Solid Waste

7.3.2   Fly ash and other suspended solids

Wastewaters containing large quantities of suspended material are frequently
routed  through impoundments (e.g., settling ponds) in which solids are
removed from suspension.  Wastewater discharged from these ponds may be
discharged to surface waters or land disposal, or recycled in the generating
facility.  Solids either remain in the ponds or are removed and disposed
of as solid waste.

WPDES permits are required for any discharges from these ponds to surface
waters  or land disposal systems (including seepage pits), and all impoundments
that have such discharges are subject to plan approval by the Industrial
Wastewater Section under the provisions of sec. 144.04.  If solids are
removed periodically, the impoundment is classified as a water treatment
impoundment, so no solid waste license is required for the solids temporarily
contained in the pond.  If, however, the impoundment is to be abandoned
after it fills with solids, it is regarded as a solid waste disposal
facility, and must be approved and licensed by the Bureau of Solid Waste
Management, as well as the Industrial Wastewater Section.  Impoundments
that are used for nprmanent disnosal  nf solids (e.a.. flv ash drpdapd

7.3.3  Leachate and seepage from solid waste sites

Impoundments for the permanent disposal of mine tailings, sludges, fly
ash and other semisolids are licensed as solid waste disposal  sites, and
were generally excluded from the SIA inventory.  Since waste liquids may
seep from these impoundments and reach the groundwater, some such impoundments
have also been required to obtain WPDES land disposal  permits  for their
seepage.   These sites were included in the SIA inventory because of
their WPDES permits.

In the past, the issuance of two separate DNR permits for one  facility's
waste disposal har confused facility operators, sometimes with the
result that environmental protection has suffered.  This has happened
because the two DNR programs have not always coordinated their activities,
and have sometimes appeared to impose conflicting requirements on a
single facility.  A few confused facility operators have taken actions
in direct violation of one program's rules in order to satisfy the
apparent demands of the other program.  To increase the efficiency of
the DNR regulatory program, a policy has been adopted that sets out the
division of responsibilities in this area.  As explained in a  departmental
memorandum (Thomas Kroehn, November 14, 1979), no WPDES permit will be
required for seepage or leachate from any licensed solid waste facility
(including tailings disposal areas, fly ash pits, and sludge landfills).
However, if leachate is collected and subsequently discharged  to surface
water or a land disposal system, a WPDES permit is required for the
discharge, and any facilities for treatment of leachate are subject to a
wastewater plan review.

7.4  Gaps in Program Coverage

7.4.1  Agricultural waste impoundments

The single major use of surface impoundments that is not now subject to
state regulation is the use of impoundments for animal wastes  generated
in agriculture.  Manure storage ponds are becoming an increasingly
common type of animal waste handling facility  in Wisconsin.  Attempts by
DNR to regulate animal waste facilities were thwarted by the Wisconsin
legislature in 1972 and 1976, acting under sec. 13.565(1) of the Wisconsin

     "...Prior to adopting any rule relating to animal waste treatment,
     the state agency proposing the rule shall submit it to a senate and
     assembly committee dealing with agriculture...  The rule shall take
     effect only upon approval by a joint resolution of  the legislature."

State and federal involvement in assuring the  sound siting, design,
construction and operation of agricultural waste  impoundments has
generally been limited  to programs providing cost-sharing and technical
assistance for their construction.  Since financial assistance is generally
contingent upon the acceptance of technical assistance and conformance
with technical recommendations, these  programs provide a significant

degree of control.   The Wisconsin Fund nonpoint source water pollution
abatement grant program, discussed in Section of the present
report, will be an important source of financial  assistance for construction
of agricultural waste ponds.  In some counties, funds from ASCS (administered
by county Agricultural Stabilization and Conservation Committees) are
also available for cost-sharing of manure pond construction.  As with
Wisconsin Fund assistance, ASCS cost-sharing assistance is dependent on
cooperation with the technical recommendations of appropriate SWCD or
SCS personnel.  Technical  assistance is also available on a voluntary
basis to farmers who wish to construct waste ponds without financial
assistance.  Many animal waste impoundments (probably most) are, however,
constructed without any government involvement.

The adequacy of the groundwater protection afforded by use of SCS (or
SWCD) technical assistance in manure pond design  is called into question
by the results of analysis of SIA data (presented in sec. 4.3.3 of this
report) and by the preliminary findings of research into the impacts of
impoundments (discussed in sec. 6.2).  Requirements of the Wisconsin SCS
technical guide respecting groundwater protection in the design of
storage ponds are abstracted below:

     1.   A minimum distance of 250 feet (76 m) must be provided between
     a waste pond and any source of a water supply used for human consumption.
     This requirement assures consistency with the Wisconsin well code,
     NR 112.  (Future revisions to the technical  guide and to NR 112 may
     allow for some variation in the minimum distance requirement if
     strict requirements respecting pond siting and construction are
     met. )

     2.   A preliminary investigation of soils and groundwater must be
     made, and should include borings or backhoe  test pits "to an elevation
     below the maximum depth of excavation".  (A  proposed revision would
     specify a boring depth of 3 feet below the depth of excavation.)

     3.   "Locate on soils of slow to moderate permeability or soils
     which will seal through sedimentation and biological action.  Avoid
     gravelly soils and shallow soils over fractured or cavernous rock."
     (A proposed revision would make this requirement more specific,
     requiring 2 1/2 feet or more of clay loam material (or equivalent)
     between the pond bottom and bedrock surface, with greater thicknesses
     required if more permeable soil is present.   If minimum required
     soil thicknesses could not be attained, the  site would be prepared
     by excavating to bedrock, cleaning the bedrock surface, filling any
     fractures with dental grout, and covering with at least 2 feet of
     compacted clay loam.)

     4.   Soil drainage systems should be provided "where necessary", as
     determined through soils and groundwater investigation.  Ponds
     should not extend "to an elevation below the seasonal high water
     table unless considered as a special design."

     5.    Where "self sealing  is not probable"  or "the potential  for
     groundwater pollution exists",  the pond "shall  be sealed by  mechanical
     treatment or by the use of an impermeable  membrane".

As reported in sec.  6.2, researchers have observed that the "self sealing"
process cited in the SCS guidelines  is not effective in retarding waste
migration, at least in the early years of a pond's use.  The SIA  found
(in data reported in sec.  4.3.3 of the present  report) that a significant
fraction of SCS-designed impoundments are located on sites identified by
the assessment as highly susceptible to groundwater contamination, but
are not provided with liners to help retard contaminant movement, perhaps
because of belief in the effectiveness of the self sealing mechanism.

Leakage from manure ponds  is a potential  threat to the health of  the
farm families who own ponds, as well as of their neighbors, since
downgradient water wells may be contaminated with nitrate (which  is
highly mobile in aquifers  and which  may be toxic to infants), high BOD
or COD, chlorides, microorganisms, and other undesirable characteristics,
such as colors, odors, or bad tastes.  To protect private water supplies
near agricultural waste impoundments, the SIA recommends that SCS guidelines
for waste storage ponds be modified to discourage reliance on self
sealing, and recommend that some barrier to leakage (formed by natural
soils or by imported liner material) be provided in all new ponds.  (It
should be noted that seepage barriers appear to be quite inexpensive
relative to the total cost of a manure storage  pond and related manure
handling installations.  However, agencies providing technical assistance
must be careful to avoid imposing so many costly design requirements that
farmers choose to ignore their advice.)  Recently proposed changes to
provide more specific guidance on groundwater protection are commendable,
but further modifications should be made to ensure that farmers who rely
on SCS expertise receive advice based on the best available information.

Some form of control of animal waste ponds may be evolved from programs
to control the quality of water supplies.  Chapter 162, Wisconsin Statutes,
authorizes DNR to "prescribe, publish and enforce minimum reasonable
standards and rules and regulations for...the establishing of all
safeguards deemed necessary in protecting the public health against the
hazards of polluted sources of impure water supplies intended or used
for human consumption."  Administrative rules governing well construction
and pump installation established under this authority are published as
Chapter NR 112, and currently contain a requirement that water supply
wells or reservoirs be located at least 250 feet away  from any waste
storage pond (sec. NR 112.07(2)(m)).  A proposed revision to this chapter
would modify this requirement, allowing reduced separation distances if
pond design included specified groundwater protective  features (e.g.,
specified liners and minimum depths to groundwater) and prohibiting well
owners from maintaining or constructing any waste pond (at any distance
from the well) without allowing a specified minimum vertical distance
(expected to be 3 feet or more) between the pond bottom and the  ground-
water table.  Though difficulties in ascertaining depths  to groundwater
are expected to make enforcement of this rule somewhat more difficult
than that of the horizontal distance rules specified elsewhere in the
well code, this rule would give the DNR Private Water  Supply Section
some authority to require sound design practices for animal waste ponds.
Also, Wisconsin SCS guidelines would be revised so as  to  be consistent
with the  requirements of NR 112.

Another potential source of state authority over animal waste storage
ponds is the "Grade A" milk permit program, administered by the Department
of Agriculture, Trade and Consumer Protection.   Federal and state law
(sec. 97.24, Wisconsin Statutes) require that producers of milk or milk
products marketed as "Grade A" comply with uniform sanitation requirements
and obtain Grade A producer permits from a regulatory authority.  Under
this program, animal waste facilities must meet certain sanitation
requirements, and are subject to plan approval  and periodic inspections.
Groundwater protection has not been a priority concern for the Grade A
program in the past, but this program does provide a potential mechanism
for implementing or enforcing regulations (e.g., proposed changes in
NR 112) for protecting groundwater supplies from contamination due to
animal waste ponds.  Since some dairy products (e.g., most cheeses) do
not require Grade A ratings, some Wisconsin dairy farmers do not hold
Grade A producer permits and would not be subject to this program's
jurisdiction.  The SIA does not have statistics on the proportion of the
state's dairy farmers or impoundment users who have Grade A ratings.

One alternative that may be available to DNR for abatement of proven
groundwater pollution from an existing animal waste source is to declare
the source a nuisance and order its abatement under the authority of
sees. 146.14 and 144.025(k), Wisconsin Statutes.  This option would be
viable only in rare cases where pollution has actually been detected,
reported and proven beyond the boundaries of the offending property

Because uncontrolled development of manure ponds poses a potentially
serious threat to the quality of private water supplies in the state,
the SIA encourages the continuation of and expansion of efforts to
ensure that groundwater protection is built into all newly installed
ponds.  No single program can reach every farmer, so significant results
might be achieved through a coordinated effort involving improved SCS
guidelines, expanded cost-sharing programs or other financial incentives,
the state Private Water Supply and milk producer permit programs,
county zoning or building permit systems (now used in a few areas), and
public education efforts aimed at increasing farmers' awareness of the
potential for groundwater pollution from poorly designed ponds.

7.4.2  Other concerns

The state regulatory programs outlined in previous sections of this
chapter appear to provide mechanisms for regulation of all non-agricultural
waste impoundments.  While some problems have been noted by the SIA, the
state appears to be able to make the needed adjustments to develop a
sound program to protect the groundwater from pollution due to waste

One remaining area of concern is that class of industrial non-disposal
impoundments at facilities that are subject to the wastewater plan
approval requirement, but are not liable for regulation as wastewater
dischargers under WPDES because wastes are either never discharged or
they are discharged only to public treatment works.  Once facility plans

are approved, these facilities are not currently subject to continuing
state surveillance that might detect any facility inadequacies.   This
lack of continuing surveillance should be a matter of minimal  concern in
the future, since there are few facilities of this type, and most will
be regulated under new pretreatment rules (if they discharge to public
treatment works) or hazardous waste rules (if contained materials are
classified as hazardous wastes).   Those facilities not covered by these
programs are generally recycling  the impounded wastewaters, which must
thus be of relatively high quality, posing little or no threat to groundwater


         Chapter 8: Evaluation of Existing Federal Programs

8.1 State Perceptions

As regulators of the "waters of the state" of Wisconsin, the Department
of Natural Resources (DNR) feels that the groundwater resource in
Wisconsin is one of the state's major natural assets and has taken many
positive steps in recent years to insure that the quality of the resource
is not degraded by man-induced contamination.  In some instances the
state has acted without the motivation of federal programs and guide-
lines, e.g., setting state standards for the disposal of municipal
sludge.  In other areas, Wisconsin has adopted federal guidelines and
has implemented or is in the process of implementing those programs.
Where the state has set its own standards there is a feeling that federal
regulations, because of their more general nature, could weaken state
standards as as a result of the requirement that state standards not
exceed federal standards (Section 147.021 of the Wisconsin Statutes).

8.2 Federal Water Pollution Control Act and Clean Water Act

The Federal Water Pollution Control Act of 1972 (PL 92-500) and the
Clean Water Act of 1977 (PL 95-217) that amended the FWPCA, provide for
uniform, enforceable national standards for clean water.  The Wisconsin
DNR administers two programs established in response to this legislation,
the Wisconsin Pollutant Discharge Elimination System (WPDES) and the state
and area-wide planning and management activities under sec 208 of PL

Chapter 147, Wisconsin Statutes, grants to the DNR:

     "All authority necessary to establish, administer and maintain a
     state pollutant discharge elimination system . . . consistent with
     all the requirements of the federal water pollution control  act
     amendments of 1972, PL 92-500; 86 Stat. 816."

This chapter enables the DNR to operate the WPDES permit program, which
regulates wastewater discharges to the surface waters and groundwaters
(via land absorption systems) of Wisconsin.  The operation of this
program and its impact on surface impoundments are described in Chapter
7 of this report.

Section 208 established a planning process for area-wide water quality
management plans to analyze the water quality problems of each state and
outline actions necessary to bring the waters up to fishable and swirnmable
standards by 1983.   Each plan must include three major features:   (1)
The means of implementation of the plans, including the responsibilities
of management agencies and necessary control programs, (2) Integrated
information about point and nonpoint source pollutants and recommended
controls, and (3)  Encouragement for the interested public to participate
in the development, revision and implementation of the water quality
plan in their area.

In Wisconsin, the 208 Planning Program is well  on the way to completion.
By March 1980, all  but three of the 16 basins will have at least the
non-point source portion of the plan completed.

Section 208(b)(2)(k) requires that the 208 planning process address
"disposal of pollutants on land or in subsurface excavations ...  to
protect ground and surface water quality".  However, surface water
quality is the primary focus of most 208 basin plans in Wisconsin,  and
groundwater quality problems have usually been addressed only as  they
directly affect surface water.   Where a surface discharge to groundwater
is in close proximity to,  and/or is having a detrimental  effect on
waters in a stream or lake, the discharge and problems  associated with
it will be examined.

The exception to the above is in the Upper Wisconsin River Basin  Plan.
Included in this plan will be a report on the effects of nutrients  and
municipal sludge disposal  on the groundwater in the Central Sands Area
of Wisconsin.

In 1978 the DNR and the USGS initiated a special  Groundwater Management
Study under the direction  of Mr. Thomas Calabresa.   A 208 planning  grant
was used to fund the DNR's role in this study for the first 18 months.
This effort has been given a high priority in the DNR program, and  has
received continuing state  funding for the next two  years.  (See Chapter
6 of this report for a discussion of this study.)

8.3 Resource Conservation  and Recovery Act

The Resource Conservation  and Recovery Act (RCRA) of 1976 requires  a
regulatory system for the  treatment, storage and disposal of solid  and
hazardous wastes.  Chapter 144 of the Wisconsin Statutes has been
amended to incorporate changes made by RCRA.  Natural Resources Code
180, an update and replacement of NR 151, will  be the state's version of
solid waste management rules under RCRA.  The hazardous waste standards
will affect up to 5,000 waste handling, storage and disposal operations
in Wisconsin (DNR, Bureau  of Solid Waste, May, 1979).  When EPA completes
publication of criteria for hazardous waste identification and management,
these will be incorporated in NR 181, which will  also contain state
hazardous waste rules.  Chapter 7 discusses the role of these programs
in controlling pollution from surface impoundments.

Congress defined disposal  as ". . .the discharge, deposit, injection,
dumping, spilling, leaking or placing of any solid  waste or hazardous
waste into or on any land  or water so that such solid waste or hazardous
waste or any constituent thereof may enter the environment. . . or
discharged into any waters, including groundwaters."  This statement
ties RCRA to active surface impoundments.  It is not yet clear what
changes will be made in the regulation of impoundments  in Wisconsin,
since RCRA rules on impoundments have not been published in final form.

Currently, the DNR Bureau  of Solid Waste is conducting an inventory of
open dumps and sanitary landfills throughout the state in order to  upgrade
the quality of these operations to a level at which they will, ideally,
pose no threat to public health or the environment.

It is estimated that 95% of the 380,000 tons of potentially hazardous
waste produced annually in the State of Wisconsin is disposed of  in
landfills (DNR Bureau of Solid Waste, May, 1979).  For this reason  the
Wisconsin Hazardous Waste Management Act licensing and regulation program

is expected to focus primarily on landfill sites.  Surface impoundments
harboring hazardous wastes will also be regulated and are expected to
receive a priority equal to that of landfill sites.

Among the standards that hazardous waste impoundments must meet if
preliminary drafts of RCRA regulations are adopted are those of location,
design, construction and operation in order to prevent contamination of
an underground drinking water source.  The permeability, structural
stability and integrity of dikes, soil barriers and synthetic liners are
the main concerns in regulating such impoundments.

Within six months of promulgation of state hazardous waste codes, all
pits, ponds and lagoons in the State of Wisconsin that receive such
wastes must be meeting standards and be licensed by the Department of
Natural Resources.  Each facility must submit a feasibility report and
plan of operation to the DNR within three months of the publication of
EPA hazardous waste definitions.  The self-identification system is
expected to cover most of the facilities discharging hazardous wastes.
SIA inventory data will be used to help identify facilities that may be
disposing of hazardous wastes but have not submitted feasibility reports
and operation plans.  SIA assessments may be used to evaluate facilities
and to set priorities for regulatory activities.

8.4 Safe Drinking Water Act (P.L. 93-523) 1974

The Safe Drinking Water Act of 1974 provided the states with the primary
responsibility for the establishment and enforcement of minimum standards
for drinking water in the state.  It also required EPA to develop
regulations for state underground injection programs.

In Wisconsin, the Department of Natural Resources had already established
minimum quality standards for drinking water supplies in the state by
the time the Safe Drinking Water Act became law.  The standards were
developed by the same study group that worked on the EPA standards, so the
two sets of standards are essentially identical.

One of the positive effects of the Safe Drinking Water Act was to broaden
the definition of a public water supply to include those supplies with
at least 15 service connections or serving 25 or more people.  The
definition change resulted in an expanded surveillance program of public
water supplies.

The reglations for underground injection do not apply to the State of
Wisconsin because underground injection is prohibited under the Wisconsin
Administrative Code (NR 112.20).

8.5 Surface Mining Control and Reclamation Act

The Surface Mining Control and Reclamation Act of 1977 is expected to
result in state legislation that deals most directly with reclamation of
tailings waste piles.  It is not expected that this legislation will
have any direct impact on surface impoundments used at mining facilities
for the treatment or disposal of mining wastes or wastewater.  Waste
disposal in tailings ponds and settling and seepage lagoons are presently
dealt with under the WPDES Permit Program and will, in the future, be
regulated under the Solid Waste and the WPDES programs.

Though there is currently only one active mining operation in the state
(Jackson County Iron Mine), the future mining operations in northern
Wisconsin are an issue that will  require both forethought and foresight
if ground and surface water is to be effectively protected from the
discharges of tailings ponds»  mine dewatering ponds and seepage lagoons.
It is expected that new mining regulations will  be developed to consolidate
or coordinate the regulatory responsibilities of the Industrial Wastewater
Section of the Bureau of Water Quality and the Bureau of Solid Waste.



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                       OUR M SSION:
                    To protect and enhance our Natural Resources —
                     our air, land and water-,
                     our wildlife, fish and forests.
                      To provide a clean environment
                       and a full range of outdoor opportunities.
                        To insure the right of all Wisconsin citizens
                          to use and enjoy these resources in
                          their work and leisure.
                           And in cooperation with all our citizens
                            to consider the future
                            and those who will follow us.
                                 Dept. of Natural Resources