United States
          Environmental Protection
             Office Of
             The Administrator
August 1992
Summary Report Of
The Survey Of Local
Ground Water/Wellhead
Protection Efforts In California
                                     •i± Printed on Recycled Paper


This report was  furnished to the  U.S.  Environmental Protection
Agency by  the student identified  on  the  cover  page,  under a National
Network for Environmental  Management  Studies  fellowship.

The  contents are essentially  as  received from the  author.   The
opinions, findings,  and conclusions expressed are  those of the author
and  not necessarily  those of the U.S. Environmental  Protection
Agency.  Mention,  if any, of company, process, or product names  is
not to be considered as an endorsement by  the U.S.  Environmental
Protection  Agency.

        February, 1992

                              SURVEY OF


                             Summary Report

                             February, 1992
                 Developed and Conducted by: Angela Baranco
            National Network for Environmental Management Studies
               U.S. Environmental Protection Agency, Region IX
                        Water Management Division
              Drinking Water and Ground Water Protection Branch

                   Ground Water Protection Section, W-6-3
                             75 Hawthorne St.
                         San Francisco, CA 94105

This Summary Report of the Survey of Local Ground Water/Wellhead Protection Efforts
in California is intended to provide a look at trends in ground water protection activities at
the local level. Results of the survey will not be used other than to provide insight into ways
that  EPA Region 9 can be more  effective in addressing  the needs of local and state
governments in  their ground water protection efforts.  This report will not affect policy,
funding or other Agency decisions.

                         Table of Contents

Executive Summary                                            1

Background                                                   3

Survey Process                                                5

Overview of Survey Results                                     10

Findings                                                     15

Recommendations                                             19

Explanations of Some Survey Responses                          20

Survey Limitations                                             20

Future Directions                                             21

                           List of Figures

1. Participating Cities/Towns Shown by County                   6

2. Participating Counties                                       7

3. Community Type/Size of County-Level Respondents            8

4. Community Type/Size of Local-Level Respondents             9

5. Reliance on Ground Water for Drinking Water by Community   11

6. Reported Incidents of Ground Water Contamination by         12
    Community Type/Size

7. Breakdown of Responding Communities by Size/Type and by   14
    Regions of California

                                 February, 1992

                                 Summary Report

                                  SURVEY OF


                             EXECUTIVE SUMMARY
      State and county well standards and regulations exist that protect drinking water
supplies in California, but some  aspects of ground water protection have  not yet been
addressed.  The most important issue in ground water protection is to prevent degradation.
of ground water and drinking water resources.  Many of the local governments require
comprehensive measures that are presently unavailable to prevent ground  water  quality

      In order to effectively assist and promote ground water protection efforts, the Ground
Water Protection Section of the Drinking Water and Ground Water Protection Branch of
the U.S.  EPA, Region 9 conducted a survey of existing protection activities and related
problems at the local government levels. Through the information gathered from the survey,
some general trends which may help to direct EPA efforts to provide guidance and other
assistance to local governments became evident.

      One of the most apparent trends recognized in the survey responses is the difference
in reliance  on ground water as the primary source of drinking water between rural areas,
small cities and large urban/suburban areas.  Citizens in rural areas and small cities were
much more dependent on drinking water obtained from ground water (wells) than those in
the larger urban and  suburban areas.

      Other trends evident in the survey such as the difference in potential and actual
threat's to ground water resources, types of contaminants reported,  the need for technical
and funding assistance, and the feasibility of implementing prevention measures to protect
      •Wellhead Protection, as used here refers to any programs used by localities which
protect the area immediately adjacent to and surrounding a water well and which does not
necessarily address the seven elements of a Wellhead Protection Program as defined by
Section 1428 of the Federal Safe Drinking Water Act of 1974.

ground water, also differed for rural areas and small cities and towns as compared to large
urban and suburban areas. These issues are discussed in further detail in this report and
provide the basis for the recommendation that more effort is focused on local level ground
water protection program development, and that assistance  is especially targeted for rural
areas and small cities.

      A number of Federal statutes provide EPA with the authority to prevent and control
sources  of ground water contamination,  as well as to clean up  existing contamination.
During the early 1980s, EPA recognized that these authorities to protect ground water were
fragmented among many different statutes, and were largely undefined. As a result, in 1984
the Agency adopted a Ground Water Protection Strategy to articulate the problem and
EPA's role in a national ground water protection program. Under this strategy, the Agency
has focused its efforts on four major objectives:

      * Building State capacity;
      * Addressing sources of contamination;
      * Establishing ground water policy direction and program consistency; and
      * Coordinating EPA programs.
      While this strategy was effective in creating momentum for
States to develop and implement ground water programs, the passage of time and growing
body of experience indicated that gaps remained in protection efforts across the country.
It became clear that there was a need to assess our progress and adjust our approach to take
into account recent changes in statutory authorities and our  increased knowledge of the
issue by promoting comprehensive protection on the State and local level.1
      Since the adoption of the EPA's 1984 Ground-Water Protection Strategy, the Agency
has been providing technical and financial assistance under the Clean Water Act to build
State capacity to protect ground water in a comprehensive manner.
      Over the last  few years, States have made significant strides in developing and
implementing ground water protection strategies.  Yet, both States and the EPA recognize,
that much remains to be done to ensure comprehensive protection of the nation's ground
water resource.  State ground water programs vary considerably from one state to another,
and are often a patchwork of Federal, State and local source control efforts, focusing on
individual sources of  contamination rather than the resource as a whole. Source control
programs tend to focus on sources that present significant risks on a national basis, but may
not represent the most important threats to drinking water supplies (and therefore human
health) at the local level.

      In 1989, EPA  established the Ground Water Task  Force to review the Agency's
      1Excerpt from  EPA  Ground-Water Task  Force Report,  Executive
Summary;  July 1991.

ground water protection program and to develop concrete principles and objectives to
ensure effective and consistent decision-making in all Agency decisions affecting ground
water.  As a result of the work of the recent Agency Task Force, EPA will take a more
strategic approach to actively assisting States in comprehensively protecting their ground
water resources.  The Task Force identified the need for EPA to step up its efforts to
coordinate  more  fully  Agency programs and authorities at the EPA Regional and
Headquarters levels, to help States build comprehensive, integrated programs that protect
the ground water resource, to provide a framework for  coordinating  multiple Federal
programs and activities at the State and local level, and to make optimum use of EPA grant
authorities to promote Federal and State program coordination.2
      In an effort to address the Agency's objective of Building State Capacity the Region
9 Ground Water Protection Section (GWPS) of the Drinking Water and Ground Water
Protection Branch considered the important role  of local agencies  in augmenting State
programs within this region. Through a special project, GWPS conducted a survey of local
governments and other agencies in one state within Region 9 that have some authority to
regulate various aspects of ground water quality or the activities that may affect ground
water quality. California was selected for this initial pilot study.
      The purpose of the survey was to determine what types of ground water protection
activities exist at the local level, what potential problems may exist, and to identify local
needs in the development of strategies to protect ground water supplies in order to more
effectively provide assistance through information and programs to address those  needs.
Ultimately, it is hoped that strong and  effective ground water protection programs could
help to lessen the increasing burden on State resources.
       2Excerpt  from  Protecting  the  Nation's  Ground  Water:  EPA's
Strategy for the 1990s,  Final Report  of the EPA Ground Water Task
Force;  Federal/State Relationship in Ground Water Protection; 1991.

                               SURVEY PROCESS
      The survey was sent to 593 local agencies in the state.  Each of the 58 California
counties and at least one representative city or town agency within each county were sent
a survey.   Included  were county and city/town planning agencies, water  districts  or
purveyors, and the county Health departments.

      These representatives were selected from The California Planner's 1991 Book of
Lists: EPA Region 9 Ground Water Protection Section and Underground Injection Control
Section mailing lists; and California State Water Resource Control Board contacts.
Respondents to the survey included:

                    216 respondents with ground water sources:
                          * 161 representing 157 cities/towns
                          *  49 representing 44 counties
                          *   6 water districts
                          *   2 other (R.W.Q.C.B., military base)
                   +  36 respondents without ground water sources

          Total: 254

 Response Rate:  43%

      The respondents were given approximately 30 days to complete the survey.

      During the survey response period, 27 respondents called the EPA for assistance in
answering some of the survey questions.

                                        PARTICIPATING CITIES/TOWNS
                                             SHOWN BY COUNTY
                                   •Shown in each county is the number of different cities
                                    or towns responding to the survey in that county.









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                       OVERVIEW OF SURVEY RESULTS
      The most obvious trend in the survey  responses are the differences which exist
between large urban/suburban areas and rural areas/small cities. With virtually every issue,
survey responses indicated or implied that there is a greater need for assistance in local
ground water protection activities for rural areas and small cities.

1.     Reliance on ground water resources.

      The majority  of respondents  from smaller cities  and rural  communities  were
considerably more dependent on ground water for drinking water supplies than the larger
urban and suburban areas. See Figure 5, page 11.

Overall, public and private wells supplied up to 90 percent of drinking water to rural areas
and small cities. Lsirge urban and suburban communities indicated that although public
and/or private wells provided some drinking water, most of the population in these areas
obtained drinking water supplied primarily by other sources.

2.     Existing ground water contamination problems.

      Reported incidents of contamination of ground water was more frequent in the large
urban and suburban  areas. "The lowest frequency of reports of contamination problems
occurred for small cities and towns, with  rural areas falling hi between.  In every case,
reports of contamination were more frequent by county level respondents than at the local
level, however, in rural  areas the difference between the frequency of local agency reports
and county level reports were greatest, almost twice as much.  See Figure 6, page 12.

      There are two important issues to be considered here. First of all, the resources
available to local level  agencies to determine contamination problems, and the feasibility
of implementing prevention activities.

      The greatest ground water and drinking water quality problems in rural areas and
small cities and town come from contamination by agricultural chemicals and from the use
of septic tanks.  The most commonly mentioned pollutants were DBCP, EDB, bacteria and
nitrates.  Ground water protection, especially wellhead protection programs could be very
effective in preventing  contamination of ground  water  sources in such cases.   Large
urban/suburban areas  reported  different  problems  with  contamination,  different
contaminants were listed and different means are necessary for dealing with those sources.

3.     Resources for  ground  water protection.

      Large urban ,and suburban areas generally reported that  sufficient programs and
policies were in place which protect ground water resources and drinking water supplies, and
that the necessary technical information and agencies and other resources for ground water
protection were available.  In contrast, many of the smaller communities, especially in rural




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areas, did not have local ground water protection programs and were dependent on county-
level agencies for management and protection of their ground water and drinking water

4.    Prevention of ground water quality problems.

      Based on responses to the  survey concerning the need and desire to develop
prevention and other ground water  protection programs, and the frequency and kinds of
reported contamination problems which already exist, small cities and rural areas  are in
most need  for assistance  in developing ground water protection and wellhead protection

5.    Interest in developing ground water protection programs.

      Rural communities and the small cities and towns have special needs and problems
concerning the protection of their ground water resources. Because these communities rely
mainly on ground water (public and private water  supply wells) for  their drinking water
supply, ground water protection was highlighted as  a major concern for the health of the
community members as well as to each community's economic and environmental stability.
Almost all  of these communities indicated a strong desire to develop local ground water
protection programs which will address the unique conditions of their communities, and
requested technical and other assistance.

6.    Funding and technical assistance.

      Small cities and towns, and particularly rural communities identified the need for
funding and technical information and assistance in developing ground water and wellhead
protection programs. Almost all respondents from rural areas, and many from the small
cities, had  no local programs  or policies  in place (or that they  were aware  of) which
provided comprehensive and preventive ground water protection measures. These areas
also had  little local ability (resources, expertise) to develop such programs.
Northern versus southern California.

      There are no distinguishable differences in responses to the survey concerning ground
water'protection programs or problems which identify northern versus southern California
respondents.  Overwhelmingly, the differences that do exist correspond more with the type
or size of the community. However, survey responses did reflect some regional differences
in the types of communities existing (or responding). Northern California respondents were
mostly of rural areas or small cities and towns.  The respondents from the central areas of
the state were  predominantly from small urban areas, and respondents from southern
California made up mostly from large urban and suburban areas.  See Figure 7, page 14.

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      The responses to the survey are generally grouped by the level of local government
represented, city/town or county.

General Information about the Communities:

A large majority of all respondents indicated that public or private wells were a source of
drinking water for at least some community members (85% - 98%).  Two-thirds of the
city/town respondents indicated that public wells were their primary source of drinking
water.  The perceruage of public and private wells as primary drinking water sources was
highest for smaller cities  and rural areas, with many rural areas having a larger percentage
of private wells as the primary source.

At the county level, respondents indicated use of private well supplies, however many
indicated that private well usage occurred mostly in predominately rural counties, or rural
areas within some counties. Overall, wells were not the primary source of drinking water
supplies in the counties.  This can probably be attributed to  the fact that the population
distribution is greater in the urban and suburban parts of the counties where drinking water
is supplied through other sources.

Half to three-fourths of the all communities planned to build new drinking water wells at
some future time.
Profile of Community Type Responding:

Most of the respondents were from small urban areas (less than 60 thousand people), 48%;
followed by large urban areas, 20%; rural agricultural areas, 12%; and rural, non-agricultural
areas, 6%.

Nearly half of the county respondents were from rural areas.
Drinking Water Sources:

Of the responses from cities and towns which indicated public or private wells as their main
drinking water source, public water supply wells provided nearly 90% of the drinking water
to the residents.

At the county level, public and private well use was about 50-50%, however, overall, wells
were not the main supply of drinking water.

Contamination Problems:

Just over a third of the cities/towns indicated that their drinking water sources are or have
experienced some contamination problems in the past, but over  two thirds at the county
level indicated that their drinking water sources had similar problems.  Those respondents
with contamination  problems were more often from large urban  and suburban areas,
followed by rural communities.

The most commonly  mentioned pollutants of drinking water sources in rural areas and small
cities were DBCP,  EDB,  bacteria, and  nitrates.  Many of these  areas also indicated
agricultural practices in the areas and the use of septic tanks as the primary method of
household sewage disposal.

In large urban and suburban areas, many other contaminants were often reported including
TCE, PCE, various metals  and minerals, and solvents. The sources of these contaminants
were varied.
Ground Water Protection Activities:

At the city/town level, most respondents answered that a water district/purveyor, the city,
or the regional water quality control board was the main agency responsible for ground
water protection and management.

At the county level, most respondents answered that a county agency, usually the Health
Department was the main agency responsible for ground water protection and management.

Many of the city/tov/n level respondents seemed unclear on exactly which agencies dealt
with ground water quality and management issues; even though they provided an answer
they did not provide the name of the agency.  Many of the respondents indicated that the
EPA should consult the water purveyors  to  find out any information on  ground  water
protection. This was; true even with those respondents which were planning agencies for
that jurisdiction.
Community Programs/Activities:

Household Hazardous Waste Collection
      Most cities and towns answered that they did have such a program. (63%)

      Approximately half of the counties indicated that such programs were available in
their communities. (52%)

Ground Water Protection Program
      Just over half of the cities and towns had no ground water protection programs in
place nor planned. (.52%)


      Most county level respondents indicated that there were ground water protection
programs in place or planned.  (73%)

      Of the city/town  respondents who were  aware of GWPPs  or policies  in  their
communities, most felt satisfied that the policies were sufficient to protect their ground
water resources. (70%)

      At the county-level, only 50% felt that their GWP policies were sufficient.

Wellhead Protection
      At the county level, only 6% had some type of wellhead protection program, and
85% were interested in establishing a WHP to protect their ground water.

      At the more local level, 40% of the communities indicated that they already had
WHPPs, and 50% were interested in establishing  a WHP program.

Water Well Standards
      At the city/town level, 52% answered that  they had local ordinances to enforce the
water well standards required by the State.

      A full 100% of the county-level respondents answered that the community did have
ordinances in place to enforce the State requirements.

Chemigation/Agricultural Well Standards
      Almost all of the city/town respondents answered "no" to having these standards.
This figure  may be tied in to the responses regarding  community type:   few of the
respondents at this level indicated that their communities were agricultural.

      At the county level, 65% of the respondents answered "yes" to having these standards.
This is in line with  the answers to the type of community: many counties indicated that
agricultural areas were included in their jurisdiction.

Underground Injection Control
      For both county and more local level respondents, the majority answered that there
is some type of injection control program or policy for their community.  (74% - county,
94% - city/town)
Nonpoint Source Pollution
      Nearly three-fourths of all respondents indicated having some type of program to
address nonpoint sources of pollution.   Most of these programs  dealt with stormwater
drainage, and few dealt with agricultural or urban runoff.

Potential Ground Water Contamination Problems:

      Of the potential threats to ground water which exist in communities, at all levels the
most common answers were underground storage tanks and septic tanks, abandoned wells,
light industry, and sewer treatment plants.

      Less than hah7 of all communities bad contingency plans in place in the event of
contamination of their drinking water wells.  At the city/town level 48% had contingency
plans, and at the county level only 32%.

      One note-some of the respondents answered that their communities or cities had
contingency plans, but descriptions of the plans indicated that many of the plans were not
sufficient for providing alternative sources of drinking water.
EPA Assistance:

      A small percentage of all respondents indicated that they had received some type of
information or assistance from the EPA regarding ground water or wellhead protection.
Almost all respondents indicated that they were interested in receiving more information
from the EPA.

      One of the most common reply to what kinds of assistance the EPA should provide
was funding for local, government programs.   Many respondents indicated that they would
like the EPA to proride publications with general and technical information and technical
assistance on ground water and wellhead protection.

      Rural communities and small cities and towns have special needs and problems
concerning the protection of their ground water resources. Because these communities rely
mainly on ground water (public and private water wells) for their drinking water supply,
ground water protection is vital to the health of the community members as well as to each
community's economic and environmental stability.

      Most of these areas reported that they were dependent upon county-level agencies
for protection of their drinking water resources, but want and need to develop local' ground
water protection programs which address the unique conditions of their communities.

      The greatest threats to ground water and drinking water supplies in rural areas and
smaller cities and towns, as indicated by survey responses, stem from contamination by
agricultural chemicals and from septic tanks. The most commonly mentioned pollutants
were DBCP, EDB, bacteria and nitrates.  This seems to indicate that these communities
need ground water protection programs which include broader areas than presently covered
by existing well standards. Wellhead protection programs in particular, in addition to other
local planning tools which protect specific geographic areas from certain types of activities,
would be particularly effective in protecting ground water sources from contamination by
these activities.

      Other  common  threats  to  ground water  and  drinking  water sources  such as
underground storage tanks and light and heavy  industries, also pose risks to ground water
supplies in rural communities and small cities  or  towns.   This has  been determined by
survey responses which indicate that these areas have limited ability (technical and financial
resources) to independently regulate and monitor such activities.  Present efforts to protect
their water supplies from these potential threats depend on policies at higher government

      Larger urban and suburban areas generally have sufficient programs and policies in
place which protect their ground water resources.  These areas also  have more technical
agencies and other resources available to address contamination problems which may occur.
     ' Based on these findings from the survey responses, a priority activity should be to
target ground water protection program and  wellhead protection  program technical
assistance and funding to rural communities and small cities.


      One probable reason for  the two different  observations between the city/town
responses and those of counties regarding polluted drinking water sources may be the fact
that county responses included more rural areas, thus including more private well use and
less regulation of those wells. Many county-level respondents indicated that the occurrence
of pollutants was probably higher, but could not be accounted for since many private wells
are undocumented and have never been tested.

      From this survey, it was also evident that what constitutes good ground water and
wellhead protection  programs is unclear  or inconsistent  between the different  local
governments, especially at the city/town level.

      Many of the respondents, especially at the city/town level, were unfamiliar with the
regulations and policies regarding ground water issues, or were not aware of the existence
of those policies in their communities.

      There were  a  few cases where more than one respondent answered items to the
questionnaire and provided inconsistent answers. This indicates varying familiarity with the
question topic by  each respondent,  or possibly  misinformation on the part of one

      As  the  questions  became more technical,  fewer  respondents  (especially at the
city/town level) were able to answer those survey items.

      Some respondents did not know which agencies were involved in the protection and
management of ground water and drinking water sources, what the agencies' responsibilities
were, or how the various agencies interacted.
                             SURVEY LIMITATIONS

      The sponsors of this survey recognize that some items in the questionnaire may have
posed problems for some respondents and may have led to somewhat inconsistent answers.
Where this occurred, when possible, consideration was given to other answers to items on
the questionnaire which were related to those items that were unclear.   In no manner do
answers to any of the survey questions negatively affect a respondent, or negatively influence
any EPA decisions. Ml information obtained in the survey will be used to help focus efforts
to improve ground water protection activities at the local levels.

                              FUTURE DIRECTIONS

      This survey provides general information  on what  ground water  and wellhead
protection programs and policies exist at the local level and generally, where the greatest
need for assistance is.
      It is hoped that the results of this survey will be helpful in providing a basis for more
involvement to protect ground water and develop wellhead protection programs since survey
responses  indicate a large interest at the local levels.