'A/440/6-90/005
i States
mmental Protection
Office of Water
(WH-550G)
EPA 440/6-90-005
May 1990
vEPA
A Review Of Sources Of
Ground-Water Contamination
From Light Industry
Technical Assistance
Document
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A REVIEW OF SOURCES OF
GROUND-WATER CONTAMINATION
FROM LIGHT INDUSTRY
OFFICE OF WATER
OFFICE OF GROUND-WATER PROTECTION
U.S. ENVIRONMENTAL PROTECTION AGENCY
MAY 1990
Printed on Recycled Paper
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ACKNOWLEDGEMENTS
This document was prepared for the Environmental Protection
Agency, Office of Ground-Water Protection (OGWP) under contract No.
68-C8-0003. Mr. Kevin McCormack of OGWP served as Task Manager for
this project, with assistance from Mr. Steven Roy and Dr. Norbert Dee.
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EXECUTIVE SUMMARY
This document addresses the potential impact of light industrial activities on wellhead
protection areas. The term "light industry" refers to industrial, commercial, or retail
establishments that manage substances or engage in manufacturing, fabrication, or service
activities that are one step or more removed from the production of primary products from
raw material. These activities, which may pose a potential threat to ground-water quality, are
minimally-regulated or non-regulated by Federal laws.
Several States and local governments have adopted innovative approaches for
controlling light industries. These approaches may involve source identification, zoning and
other controls to limit land uses in wellhead areas, and public education and technology
transfer to encourage industries to adopt management controls. Other jurisdictions have also
placed strict prohibitions on activities that are allowed in wellhead areas, including restricting
specific light industry types. These activities may be adopted as part of a comprehensive
Wellhead Protection Program. Examples of these activities include:
• Watershed Rules and Regulations - Local or State agencies
may adopt land-use plans to protect public water supplies.
• Ground-Water Management Areas - State agencies may
develop management plans for designated areas to institute
land use and source controls to protect ground-water
quality.
• Ground-Water Standards - Many States have adopted
standards to protect their ground water. Standards may be
either numeric, specifying a maximum concentration for a
particular contaminant, or narrative, specifying a general
prohibition on types of discharges or identifying a general
quality goal.
• Ground-Water Classification - Several States have classified
their ground water and specified differential protection
measures according to the classification.
The Federal Safe Drinking Water Act Amendments of 1986 mandated the U.S.
Environmental Protection Agency (EPA) to work with the States to develop Wellhead
Protection (WHP) Programs to protect ground-water supplies of public drinking water.
Under Section 1428 of the Act, each State and Territory was directed to submit a WHP
program to EPA by June 19, 1989. Wellhead Protection Programs have six major
components: (1) designation of roles and duties of State and local agencies; (2) delineation
of wellhead protection areas; (3) identification of contaminant sources; (4) development of
management approaches for the wellhead area; (5) preparation of contingency plans for
replacement water supplies; and (6) planning and siting of new wells. This document
discusses aspects of the third and fourth components outlined above.
A variety of anthropogenic sources may threaten wellhead areas, including heavy
industry, waste disposal sites, light industry, on-site wastewater disposal, and agricultural
practices, as well as others. While heavy industry and agriculture are acknowledged and
increasingly recognized as sources of contamination, light industry and on-site wastewater
disposal are also pervasive contaminant sources and frequently are not subject to the same
types of controls.
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Many types of light industries may threaten wellhead areas. These industries are
found in increasing numbers throughout the United States, as light industrial parks and
suburban developments spread into formerly rural areas. A number of light industry types
are addressed in this document, such as electroplating and polishing services, wood and
lumber treating operations, furniture refinishing and repair services, auto repair shops, road
deicing operations, scrap metal and auto junkyard dealers, and laundry and dry-cleaning
establishments. These light industries manage a variety of contaminants, including heavy
metal-containing solutions and acid baths in electroplating services, pentachlorophenols and
other preservatives in wood treating operations, solvents and varnishes in furniture refinishing
shops, used oils and degreasers in auto repair shops, salts in road deicing operations, spent
battery acids and solvents in scrap dealerships, and detergents and solvents such as
trichloroethylene in dry-cleaning establishments. Because these light industries are found
in large numbers throughout the country, there is a widespread potential for wellhead
contamination from these sources.
A wide variety of constituents have contaminated ground water at light industrial
facilities. The most prevalent groups of contaminants include organics and metals/inorganics.
Typical organic contaminants include benzene, dichloroethylene, dioxins, methylene chloride,
pentachlorophenol, perchlorethylene, toluene, trichloroethane, trichloroethylene, andxylene.
Typical metals/inorganics include arsenic, chromium, copper, lead, nickel, nitrates, and sodium
chloride. These contamination incidents are most frequently associated with waste
management and waste disposal activities.
Following sound management controls can serve as an important component of a
Wellhead Protection Program to control ground-water contamination by light industry.
Many cases of contamination have been documented involving spills and leaks to soil,
improper waste disposal in septic systems, and releases from underground storage tanks and
pipelines. In a number of cases, light industries have prevented or minimized such
contamination incidents by following management controls, such as storing raw materials and
wastes on impermeable pads and in covered areas; collecting runoff from material storage
areas; placing drip pans under machinery and in process areas; segregating hazardous
materials from disposal in septic systems; minimizing the intensive use of contaminants such
as road salts in sensitive areas; inspecting and monitoring underground storage tanks and
pipelines; cleaning up spills promptly after they occur; and training personnel to follow sound
material management practices. Over the long-term, the potential for ground-water
contamination by light industry can also be reduced by adopting waste minimization
practices, such as waste recycling, raw material substitution, and waste treatment.
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TABLE OF CONTENTS
1.0 Introduction
1.1 Overview of this Document 1
1.2 Definition of "Light Industry" 2
1.3 Summary of Data Collection for this Document 6
1.4 Analysis and Conclusions: The Threat to Ground Water
from Light Industry 6
2.0 Overview of the Problem: Raw Material and Waste Management
2.1 Phases of Material Management and Mismanagement and
the Potential for Ground-Water Contamination 11
2.2 Materials Managed by Light Industrial Facilities 13
2.3 Analysis and Discussion 15
3.0 Controls on Light Industry: Federal, State, and Local Roles
3.1 Regulating Material Management by Light Industry under
Current Federal Law 19
3.2 State and Local Approaches for Controlling Light
Industry 24
3.3 Analysis and Discussion 30
4.0 Minimizing Ground-Water Contamination by Light Industry
4.1 Management Controls for Preventing Ground-Water
Contamination 33
4.2 Long-term Solutions: Pollution Prevention - Source
Reduction, Recycling, and Treatment 36
4.3 Analysis and Discussion 39
5.0 Conclusions 41
6.0 References 43
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Page 1
1.0 Introduction
1.1 Overview of this Document
This document is one of a series of Technical Assistance Documents (TADs)
prepared by the Office of Ground-Water Protection of the U.S. Environmental Protection
Agency. This TAD discusses the problem of ground-water contamination caused by light
industrial raw material, production, and waste management practices. While larger industries
have come under increasing Federal and State regulation over the past few years as a means
of controlling activities that can result in ground-water contamination (U.S. EPA, 1987) there
is a growing awareness that other smaller and either unregulated or minimally-regulated
industries and businesses also manage materials that may pose a threat to ground water and
wellhead protection areas (U.S. Office of Technology Assessment, 1987). This TAD is
intended to assist managers in identifying and controlling potential light industrial sources
of contamination that may pose a threat to public water supplies.
EPA prepared this document as part of its ongoing effort to assist State and local
governments in developing Wellhead Protection Programs. Wellhead Protection Programs
have six major components (U.S. EPA, 1988): (1) designation of roles and duties of State
and local agencies; (2) delineation of wellhead protection areas; (3) identification of
contaminant sources; (4) development of management approaches for the wellhead area; (5)
preparation of contingency plans for replacement water supplies; and (6) planning and siting
of new wells. This document is designed to support the third and fourth tasks outlined above
(i.e., the identification of light industrial sources of ground-water contamination and the
development of management programs to control these sources). Specifically, this document
focuses on a group of industries that are increasing in significance in many wellhead areas.
The number of light industries in this country and the corresponding threat to public water
supplies is growing. Furthermore, many of these light industries are locating in rural and
suburban areas which have not previously been host to businesses that manage hazardous
materials. As a result, wellhead areas in these regions may become threatened.
• Organization
This document is a part of the series of technical assistance documents prepared by
EPA to support State and local Wellhead Protection Programs. Companion documents in
this series include Developing a State Wellhead Protection Program: A User's Guide to
Assist State Agencies Under the Safe Drinking Water Act (EPA 440/6-88-003), Guidelines
for Delineation of Wellhead Areas (EPA 440/6-87-010), and Wellhead Protection Programs:
Tools for Local Governments (EPA 440/6-89-002). The information provided in these
previous documents is not repeated in detail in this TAD; however, those documents are cited
where appropriate. Instead, this document focuses on light industries as a potential
contaminant source in Wellhead Protection Areas and broadly discusses approaches for
minimizing potential impacts.
This document is organized in six chapters. In Chapter 1, following this introduction,
Section 1.2 defines what is meant by the term "light industry." Section 1.3 outlines the
methods the Agency used to gather information characterizing light industry, and section 1.4
presents a summary of the results of the initial data-gathering effort for this document,
including findings concerning the extent of ground-water contamination.
Chapter 2 focuses on the materials handled (Section 2.1) and the material
management practices followed (Section 2.2) by light industry that can lead to ground-water
contamination. Section 2.3 outlines general conclusions concerning the light industrial
practices that may threaten Wellhead Protection Areas.
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Chapter 3 contains a discussion of Federal, State, and local controls to address
ground-water contamination by light industry. This discussion first outlines Federal statutes
in Section 3.1. Section 3.2 discusses State and local options for controlling light industry,
which may include land use restrictions or zoning to control the location of light industries
over vulnerable sources of ground water. Finally, Section 3.3 describes an approach that
State and local governments may adopt to develop programs to control light industries in
Wellhead Protection Areas.
Chapter 4 focuses on the technical controls that light industries have adopted to
minimize the potential for ground-water contamination. Section 4.1 describes management
controls that industries have followed to ensure that "good housekeeping" principles are
adopted at facilities, and section 4.2 discusses waste minimization techniques that some
industries have instituted to limit the production of potential contaminants. The chapter
concludes in Section 4.3 with an analysis of the role these management controls and waste
minimization techniques can play in a Wellhead Protection Program.
Finally, Chapter 5 summarizes the findings of this document, and Chapter 6 lists the
references collected by the Agency to support this analysis.
1.2 Definition of "Light Industry"
As used in this document, the term "light industry" refers to industrial, commercial,
or retail establishments that are not generally addressed under Federal hazardous waste or
hazardous material control laws or regulations. This term is not new. It has been used in
the manufacturing and service sectors for many years and has generally been thought to
define those manufacturing, fabrication, or service industries that are one step or more
removed from the production of primary products from raw material. For example, chemical
manufacturing may be thought of as heavy industry, while paint formulating is light industry.
This document takes that definition one step further by also focusing on the waste generation
and management practices of the industry to define its status.
Federal hazardous waste laws and hazardous material control laws and regulations
are discussed in Chapter 3 and generally include the Resource Conservation and Recovery
Act (RCRA), Comprehensive Environmental Response Compensation and Liability Act
(CERCLA or "Superfund"), Safe Drinking Water Act (SDWA), Clean Water Act (CWA),
Toxic Substances Control Act (TSCA), and Federal, Insecticide, Fungicide and Rodenticide
Act (FIFRA). Although these laws have imposed controls on a wide range of industries and
hazardous material handling practices, they have tended to focus only on the larger
manufacturing industries which manage the majority of hazardous wastes and hazardous
materials in this country. Other smaller industries and businesses have not been as
stringently controlled, either because the Federal statutes focus on industries that manage
wastes or materials above a threshold amount or because the materials managed by the
smaller industries are not considered "hazardous." Nonetheless, EPA and many States have
discovered that these lower quantity or "non-hazardous" materials managed by light industry
can still contaminate Wellhead Protection Areas.
In certain hydrogeologic settings, even very small amounts of hazardous material can
contaminate large areas of ground water; both community and private supply wells have been
contaminated by light industries (Ford and Quarles, 1987). Furthermore, materials that are
not generally regarded as hazardous commonly contaminate ground-water supplies. Such
contaminants include nitrates and biological substances, like bacteria and viruses.
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As background for this document, a data-gathering effort was completed to
characterize those light industries that pose the greatest potential threat to ground water (see
Section 1.3). Based on this effort, 20 light industry sectors were identified as potentially
significant sources of ground-water contamination. These sectors include the following:
• Agricultural Products and Services
• Mining and Quarrying
• Highway Deicing
• Textile and Apparel Products
• Lumber and Wood Preserving
• Printing and Publishing
• Chemical Product Blending
• Leather Products
• Mineral Products: Glass and Cement
• Metal Products
• Machine Shops
• Electronics and Electronic Equipment
• Transportation Maintenance
• Scrap Trade and Metal Container Recyclers
• Chemical and Petroleum Storage and Sales
• Automotive Repair, Services, and Parking
• Personal Services: Laundry, Pest Control, and
Photofinishing
• Repair Services: Furniture, Welding, and
Septage Services
• Amusement and Recreation
• Educational, Medical, and Engineering Laboratories
The portion of the American economy represented by these light industries is
growing and dynamic - changing and adapting over time. Hence, controlling these sources
of contamination, especially in wellhead protection areas, is increasing in importance. While
the extent of light industrial practices is increasing, the areas or regions where these
industries are found is also changing. As more and more sections of the country become
"suburbanized," light industries are appearing in formerly rural areas and give rise to more
numerous sources of ground-water contamination. Because public water supply wellhead
areas are often located in these rural or suburban regions, the widespread growth in the
number of contaminant sources is a major concern with regard to wellhead protection.
The growth in light industrial activity is best illustrated by the evolution in industrial
parks from the early developments that contained mainly heavy industries to today's light
industrial or high technology parks. Most current industrial park developments are oriented
toward the needs of light industry, research, and general office-type operations. As a result,
the number of industrial parks that are now being zoned for activities other than heavy
manufacturing has risen dramatically in the last 10 years (Battelle, 1988)
The development of industrial parks has a long history in this country, and the nature
of these parks has changed over time. In general, industrial parks can be characterized in one
of five types, as described below. However, it is difficult to determine precisely how many of
these various industrial park types exist. A "high technology park" may also be described as
a research park, industrial park, science center, technology center, or even an office park.
Hence, these five industrial park types should be thought of as a continuum (Battelle, 1988):
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• Research Parks. The major activities associated with this
type of development include research, engineering, and
certain types of office and administrative activities. In
virtually every case, these facilities exclude any business
related to light manufacturing, distribution, and certain
other associated business activities.
• Technology Parks. The technology park is characterized by
research and development activities, high technology and
light manufacturing activities, office and administrative
functions, and a wide range of services. Technology parks
are similar to research parks, but also contain
manufacturing components. Technology parks are generally
less than 10 years old.
• Office/Mixed Use Parks. These developments provide
facilities not only for office-type operations, but also for a
wide range of light manufacturing, storage, distribution, and
other business support services.
• "AAA" Industrial and Distribution. Standard and "AAA"
industrial parks are oriented toward production, service,
and distribution. The "AAA" implies high grade, relatively
clean industrial and distribution processes. They often
include distribution facilities, rail sidings, outside and
underground storage, and activities that may produce
emissions and wastes. They have flexible land uses and
have less rigorous landscaping and architectural design.
• Industrial. These facilities represent the older type of
industrial park. They consist of basic industrial
components such as oil refineries and heavy manufacturing
facilities. Large volumes of raw materials and wastes are
often stored on these sites. Although managing these
facility types is of critical importance in wellhead areas,
these heavy industrial parks are not addressed in this
document.
Exhibit 1 outlines the continuum of industrial park types. The exhibit illustrates the
range in ages of most parks form older heavy industry to newer light industry parks.
Although not all light industries are found in industrial parks, the move to light industrial
development is increasing. Hence, understanding the potential ground-water impacts
associated with these industrial parks is a critical component of effective wellhead protection.
Wellhead Protection Program managers should be aware that many of these parks contain
businesses and industries that manage hazardous materials. The types and volumes of
contaminants that may be introduced into Wellhead Protection Areas from these light
industrial parks is discussed in the following chapter.
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Exhibit 1
The Evolution from Heavy Industrial to
Light Industrial Parks
AVERAGE AGE (YRS)/
RELATIVE AMOUNT
OF ACRES PRESENTLY
DEDICATED
40 - 60 Yr. Average - Many Old, Large, Semi-Abandoned Projects
20 - 30 Yr. Average, Still Some Demand for Dirty,
Noisy Operations
10-20 Yr. Average, Demand for Light
Industrial Distribution
40-60 Yrs I
I
I 20-30 Yrs |
I
I
10 Yr. to Present, Growing Rapidly
New Concept, Still Evolving,
Most Interest at Present
Type of Park:
Zoning:
Type of General
Activities:
industrial
Heavy
Industrial
Production
"AAA"
Industrial
and
Distribution
Ught
Industry
Distribution
Production
and
Distribution
Office/
Mixed
Office/
Mixed
Use
Distribution,
Office
Administra-
tion
Technology
Research
Mixed
Use
Office
Research
and Devel-
opment,
Office Ad-
ministration
Research
Park
Research
Research
and
Develop-
ment
Decreasing water demand tor process/
decreasing volume ot waste generated
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1.3 Summary of Data Collection for this Document
A limited data-gathering effort was conducted to investigate the light industrial
activities outlined in this document. This effort focused on identifying the nature and extent
of ground-water contamination caused by light industrial facilities. Because of the very broad
scope of the analysis, the data-gathering effort was not designed to serve as a definitive
characterization of either the light industry universe or the extent of wellhead area
contamination caused by light industrial facilities. Instead, the data-gathering effort provided
only a "first-cut" overview of the scope of the problem.
Information was gathered from a variety of sources and included a broad literature
review and series of phone contacts. Many of the information sources, however, provided
either incomplete or poorly-documented case studies. Only those incidents with sufficient
information to identify the characteristics of the contamination event accurately were included
in this review. Furthermore, those cases that could not be identified as involving non-
regulated or minimally-regulated light industrial activities were not included. For example,
if the contamination incident resulted from an illegal activity, such as "midnight dumping" of
hazardous waste shipments, or a release from a regulated underground chemical or petroleum
storage tank, the incident was not included in the review. Information for this document is
based on 182 case studies of ground-water contamination associated with light industrial
facilities.
The cases identified in the review do not, of course, encompass the universe of known
contamination incidents. The difficulties encountered in gathering the case study information
indicate that more cases of ground-water contamination by light industry may have occurred,
but documentation for those cases is not readily available. For example, some cases of
contamination may have been addressed through privately funded and managed cleanups that
involved little or no State or local government activity. As a result, sufficient information to
summarize such incidents is not available. EPA anticipates that more cases of contamination
may yet be discovered as the level of awareness concerning ground-water vulnerability in
Wellhead Protection Areas increases with time. Hence, the number of reported and well-
documented cases of contamination may also increase. Nonetheless, the information gathered
to date does provide a limited indication of the nature and extent of the threat to ground
water posed by light industry. The characteristics of light industrial waste and material
management practices that are associated with ground-water contamination incidents are
described in Chapter 2.
In addition, Chapter 6 of this document lists the references that were identified and
used to characterize the light industry sectors and appropriate management controls and
waste minimization techniques for raw material and waste management.
1.4 Analysis and Conclusions: The Threat to Ground Water from Light
Industry
Over seventy light industries that are associated with documented contamination
incidents were investigated for this document. These light industries include agricultural,
light manufacturing and processing, mining, road maintenance, warehousing and wholesaling,
transportation, personal and business service, research, and entertainment activities. The
incidents of ground-water contamination reviewed by EPA encompass urban, suburban, and
rural settings in over 30 States. Many of the contamination incidents were noted to have
occurred either near public water supplies or in Wellhead Protection Areas. Furthermore,
many of the incidents involved documented contamination of public and private water wells;
however, it is not possible to estimate either the number of wells closed due to light industry
contamination or the number of people exposed to contaminants.
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In response to these findings, a discussion of management controls that have been
used by some light industries is provided in Chapter 4 of this document. That discussion
principally addresses the poor housekeeping practices found in many of the light industry case
studies. In these examples, many light industries have not adequately managed raw and waste
materials by failing to cleanup leaks and spills or by disposing of compounds improperly, such
as discharging industrial wastes to septic systems or directly to the soil. Also, improper
material storage in uncovered or unlined storage areas and handling of container and tank
rinsate from pesticide and chemical storage units was implicated as a contamination source
in a number of cases, as well as leaks and ruptures of underground storage tanks and material
handling pipelines. Finally, the misuse or overuse of materials such as road salts and
pesticides was identified as a contamination source.
Among the light industries reviewed in this report, a few stand out as having a high
potential for contamination of ground water. These light industries include electroplating and
polishing services, wood and lumber treating operations, furniture refinishing and repair
services, auto repair shops, road deicing operations, scrap metal and auto junkyard dealers,
and laundry and dry-cleaning establishments. The potential for ground-water contamination
caused by these light industries is widespread, as these types of businesses are found in large
numbers throughout the country. Their general characteristics are as follows:
• Electroplaters and Metal Fabricators: The industries in
this sector manipulate the form or modify the surface of
metals physically, chemically, and/or electrically. Typical
processes include forging, stamping, etching, engraving,
coating, polishing, grinding, painting, and electroplating.
The by-products of these activities include not only metal
scraps but a wide variety of chemicals and solutions that
pose a threat to ground water. Of special interest are
wastes such as spent solvents and still bottoms, paint
residuals, acid and alkaline solutions, plating and stripping
solutions, waste oils, heavy metal wastewater sludges, and
metal dusts (U.S. EPA, 1986). These wastes may reach
ground water through deliberate and accidental dumps,
accidental spills, leaks, and floor wash (Environment
Canada, 1984).
• Wood Preservers and Treaters: The wood preserving
industry encompasses establishments primarily engaged in
treating wood, sawed or planed in other establishments, to
prevent decay and to protect against fire and insects (U.S.
EPA, 1986). Typical wood preservatives include
pentachlorophenol (PCP), creosote, chromated copper
arsenic, and ammoniacal copper arsenate. These
preservatives are applied to the wood by steaming,
boultonizing, and kiln or air drying either under pressure
or in a vacuum. All of these processes produce wastewater
treatment sludges. Wastewater sludges from creosote and
PCP processes are listed as RCRA hazardous wastes.
Other wastes include leftover preservative material in
delivery containers; process steam condensate containing
water with creosote, PCP, wood fibers and other materials;
sludge from process tanks; storm runoff from work areas
containing spilled and leached preservatives; and process
cooling waters that come in contact with the wood
preservatives. "Kick-back" of preservatives from the wood
frequently occurs resulting in preservatives being spread
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around the treatment area. In addition, preservatives may
leach from treated wood stored in yard storage areas.
While the amount of preservative that leaches from wood
is typically quite low, all preservatives are somewhat soluble
in water. Some preservers have installed drip tracks and
pads in storage areas to collect leached preservatives, but
this practice may not be followed at all facilities (U.S. EPA,
1986)
Furniture and Wood Strippers and Refinishers: Furniture
strippers commonly use methylene chloride to remove the
finish from a piece. Methylene chloride is dissolved in a
solution of methanol or isopropyl alcohol and water;
smaller quantities of acetone, perchloroethylene, and
toluene may also be present. The mixture is applied by
brush, spray, or dipping; the finish is scraped or brushed
off; and the piece is rinsed before refinishing. Some
furniture strippers may use a five-step process that entails
dipping in a methylene chloride stripping solution, followed
by a caustic bath, rinse, neutralization with hydrochloric or
phosphoric acid, and final rinse (Connecticut Dept. of
Environmental Protection, 1984). Methylene chloride
stripping solution is commonly recycled in the furniture
industry; caustic solutions, however, become weaker with
use and must be discarded. These wastes typically contain
high concentrations of methylene chloride along with
alcohols, metals, and other solvents. Many shops engaged
in furniture stripping also conduct furniture refinishing
operations. These shops may handle stains, containing
mineral spirits, pigments and alcohol; varnish, shellac, or
polyurethane, containing denatured alcohol, resins,
petroleum distillates and toluene diisocyanate; or enamel,
lacquer, and acrylic paints, which contain toluene, pigments,
halogenated hydrocarbons, and glycol ether.
Auto Repair Shops: Auto repair activities encompass such
operations as glass replacement, transmission, exhaust
system and engine repair, and tire retreading. Most
businesses in this group are small scale operations
employing less than ten persons. This is especially true for
auto body/paint shops which are specialized and may
employ one to three workers (Tennessee Department of
Economic and Community Development, 1986). Larger
scale operations usually are less specialized and may
provide a full range of repair and maintenance services.
The major threat to ground water posed by these industries
arises from the disposal of such waste products as gasoline,
diesel fuel, oil, and degreasing solvents. Auto body and
paint shops produce spent paint/solvent waste which is
classified as a RCRA ignitable hazardous waste.
Road Deicing Operations: Highway departments, their
contractors, and other private parties stockpile and spread
substantial quantities of deicing materials on streets and
other paved areas. Ground water may be affected by
improper storage or by washoff of these materials from
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road surfaces. Excessive or improper application to street
surfaces adds to the potential for contamination. Salts are
commonly used as highway deicing agents, alone or in
combination with abrasives such as sand, gravel, or ash.
Sodium chloride is by far the most commonly used deicing
agent. Calcium chloride is also used, often together with
sodium chloride. Urea, an organic chemical, is generally
used on airport runways rather than salts because it is less
corrosive.
• Scrap and Junkyards: Scrapyards, salvage yards, junkyards
and metals recyclers, which accept or buy scrap
automobiles, "white goods" such as refrigerators and scrap
metals, are found throughout the country. The vast bulk of
the materials managed in these yards are stored in the
open, often directly on the ground, where metal corrosion
and oil releases can occur. These establishments most
often gather ferrous and nonferrous metals for secondary
smelting and recycling. "Battery breaking," or the
disassembly of automobile storage batteries for recovery of
the lead plates inside, may occur. Barrels or drums used to
contain hazardous materials -- with or without some or all
of their contents ~ may also be handled and recycled by
such facilities. Agricultural chemical and pesticide
containers make up the bulk of recycled drums, especially
in the Midwest. Many recyclers purchase the barrels and
clean them up for resale as trash or storage containers.
Processes used to store, handle, clean, and transport these
containers can cause ground-water contamination.
Substantial quantities of used oil, gasoline, and antifreeze
also may be generated in these yards. PCB-laden oils may
be released from large electric utility transformers and can
be released from small capacitors and transformers included
in household appliances. Combustible fuels may be
recovered for sale or for on-site burning.
• Laundry and Dry Cleaning Establishments: Dry cleaning
entails laundering garments in non-aqueous degreasers and
solvents rather than water and detergents. Typically, the
garments are agitated within large machines containing the
solvents then spun, removed, and dried in a separate
machine. The contaminated solvents are filtered, distilled,
and returned for reuse. Distillation can be done in-house
with the appropriate equipment. Newer dry-cleaning
machines, referred to as dry-to-dry machines, are entirely
self-contained and do not require the transfer of wet
garments to a drier. The threat to ground water from dry
cleaning operations stems from the solvents used for the
cleaning process. The most common solvent used is
tetrachloroethylene (also called perchloroethylene),
although fluorocarbon-113 and petroleum solvents are used
as well (U.S. EPA, 1987). All three of these solvents are
volatile and toxic and capable of contaminating ground
water. The most common routes of solvent release are
through spills during handling and storage (solvent typically
is transported and stored in 55 gallon drums) and leaks
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from cleaning equipment gaskets and other
interconnections (Institute for Local Self-Reliance and
Connecticut DEP, 1984). Spent filter sludges and
cartridges, used for recycling the solvents, also can contain
significant amounts of residual solvent. To a lesser extent,
drying vents allow the condensation and dripping of
solvents onto the ground, and water collected during
solvent distillation (typically less than one gallon per
month) can cause contamination if not collected and
disposed of properly (Institute for Local Self-Reliance and
Connecticut DEP, 1984).
Although many of the above-listed light industries have been identified as past
sources of ground-water contamination, much of this potential threat to Wellhead Protection
Areas is being mitigated through the adoption of improved raw and waste material
management practices. Light industries are instituting these practices as a result of the
enforcement of existing Federal, State, and local laws and through voluntary adoption of
improved material management practices. With regard to existing Federal law, RCRA
standards for hazardous waste management require that generators manage their wastes
properly in tanks or containers and arrange for transport of the wastes to permitted on-site
or off-site disposal facilities. Many of the past cases of improper waste management at dry
cleaners, electroplating facilities, and wood preservers, for instance, are being prevented by
RCRA standards for small and large quantity generators (see Chapter 3).
In addition to controls mandated by Federal law, certain State and local authorities
are enforcing more stringent standards on the siting of light industries and the practices
followed by the industries. The liabilities associated with improper waste management have
also led many industries to adopt management practices that are protective of the
environment. Furthermore, the increasing costs associated with waste management and
disposal have encouraged industries to adopt waste minimization techniques to limit the
generation of waste products. As a result, many of the types of past contamination incidents
reviewed by EPA will be prevented in the future.
Nonetheless, while light industrial management practices are improving, many of the
material handling processes followed by light industry still remain unregulated or minimally-
regulated. As discussed below in Chapter 3, generators of less than 100 kg/month of
hazardous waste are not stringently regulated under the current RCRA program. In addition,
leaks or spills of raw materials or products are not controlled under RCRA and may not be
fully addressed under CERCLA or other authorities. Furthermore, there are no data
available to accurately assess the extent of voluntary adoption of management controls and
waste minimization techniques by light industry. Therefore, Wellhead Protection Program
managers and other State and Local officials should be aware that existing controls may not
be adequate to ensure that hazardous materials are managed in a manner that will prevent
contamination of Wellhead Protection Areas. Protecting these public water supplies may
require local jurisdictions to either impose limitations on the siting of light industries in
Wellhead Protection Areas or encourage the widespread adoption of management controls.
Examples of such State and local programs are discussed in Chapter 3.
The following chapter provides a broad overview of the raw and waste materials
managed by light industries that may pose a threat to Wellhead Protection Areas.
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2.0 Overview of the Problem: Raw Material and Waste Management
This chapter describes the material management phases and potential contaminants
handled by light industries. The chapter concludes with a discussion of the significance of
light industrial material management for wellhead protection.
2.1 Phases of Material Management and Mismanagement and
the Potential for Ground-Water Contamination
EPA has identified five general phases of material management by light industry that
may pose a threat of ground-water contamination:
• Raw material and product delivery, transport, and transfer.
Leaks and spill incidents may occur while managing raw
and waste materials during transport between storage and
use locations, through processing areas, and to disposal
sites.
• Raw material and product storage. Contaminants can be
released into ground water when storage tanks or
containers fail. Rusted barrels can leak; holding tanks can
fail due to faulty design, construction, or maintenance; fires,
collisions, and other accidents may cause spills, and
improper operation may result in unplanned releases.
• Material processing and manufacturing. Production
processes are subject to malfunctions, spills, or leaks or
may involve planned releases of materials.
• Waste Management and Disposal. On-site waste treatment
and disposal may cause ground-water contamination (e.g.,
in septic systems which are poorly designed or
inappropriate to treat the waste products) or may involve
material-handling processes subject to accidents. Disposal
into sewers may lead to contamination if sewers leak.
• Process and site maintenance. Potential contaminants may
be released during the maintenance of buildings,
equipment, or vehicles.
Ground-water contamination can occur at any one of these phases of material
management. Exhibit 2 illustrates the frequency with which the various phases were involved
in the ground-water contamination incidents reviewed by EPA. The exhibit demonstrates that
contamination incidents are most frequently associated with waste management and waste
disposal activities.
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EXHIBIT 2
Distribution of Material Management Phases
in Ground-Water Contamination Case Studies 1
100
M
0>
U
(0
U.
)
0)
M
(0
o
0)
A
3
80
60
40
20
Management Storage
and
Disposal
Processing Unknown Maintenance Transport
and Manu- and
facturlng Transfer
Material Management Phases
1 Data for this exhibit were compiled from the summary of 182 case studies of ground-water
contamination at light industrial facilities.
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Waste management generally involves packaging or preparing wastes for off-site
shipment and transferring wastes to storage areas through pipelines or other conduit.
Releases can occur through leakage from waste containers or temporary storage tanks. In
addition, a number of light industries have experienced releases from pipelines used to
transport wastewaters to storage tanks or containers for further treatment or management.
Because light industries generally do not dispose of their waste materials on-site, proper waste
management prior to off-site shipment is critical for the protection of Wellhead Protection
Areas. Such management practices include inspecting waste storage tanks and containers to
ensure that they are not leaking and maintaining catchment basins and berms to contain
releases. Furthermore, removing waste materials from a light industry site in a timely manner
helps to ensure that the wastes will not be abandoned and left in place.
Improper waste disposal has also occurred at many light industry facilities. Any
occurrence of improper waste or material management that results in a release to soil or
ground water which is not cleaned up constitutes improper waste disposal. For example, light
industries, such as auto repair shops or electroplaters, have experienced releases to soil that
have not been addressed through soil excavation or other remediation. Such improper waste
disposal often leads to ground-water contamination. Some light industries also improperly
dispose of their hazardous wastewaters in septic systems or other on-site wastewater disposal
systems which are not capable of adequately treating many hazardous wastes. As a result,
contaminants discharged into a septic system may pass through the system's soil infiltration
field and into ground water. Properly segregating wastes and preventing hazardous wastes
from entering septic systems is the best means of ensuring that such ground-water
contamination will not occur.
All of the phases of material management at individual light industrial facilities are
also prevalent at light industrial parks, although the nature of the potentially contaminating
activities may differ with the different park types. Furthermore, the layout and construction
of the parks themselves may impact wellhead areas by affecting water runoff patterns and by
introducing fertilizers and pesticides into the area as part of landscaping practices. In general,
the number of potentially contaminating activities, as well as the quantities of contaminants,
increases with the degree or level of industrial activity at an industrial park. The quantity of
contaminants present also generally increases with the degree or level of industrial
orientation, although the hazard posed by even a small volume of contaminants may still be
severe. For example, a small amount of a very hazardous material introduced into a wellhead
area from a mixed use park could be more harmful than large amounts of a less hazardous
substance introduced from a heavy industry park. The industrial park activities with the
potential to contaminate ground water are illustrated in Exhibit 3.
2.2 Materials Managed by Light Industrial Facilities
Light industries manage a wide range of materials that may potentially contaminate
ground water. Virtually all materials managed at larger or heavy industry facilities are also
found at light industry facilities, though in smaller quantities. In general, these contaminants
include the following:
• Petroleum Products. Fuels (e.g., gasoline, diesel) and their
additives (benzene, xylene), grease, oil, and PCBs.
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EXHIBIT 3
INDUSTRIAL PARK ACTIVITIES WITH POTENTIAL TO CONTAMINATE GROUND WATER
Science
Parks
Technology
Parks
Office/
Mixed Use
"AAA"
Industrial
Industrial
Storage, On-Site
Above-ground storage container
or impoundment failure
Underground storage tank failure
Leaks, spills, fires
Disposal
On-site septic tank, treatment
inadequate, seepage lagoon
Sewer leak
Processing/Production
Leaks, spills, overflows
Transporter/Transfer
Spills (large quantity)
Leaks (small quantity from
pipeline or vehicle)
Maintenance Activities
Handling, use, disposal of
cleaning materials
Handling, use, disposal of waste
material (e.g., used oil)
Landscaping
Maintenance and salt
application
Impoundments and streams
Vegetation maintenance
Livestock (ducks and geese)
some
Source: Battelle, 1988
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• Other Organics. Chemicals used as solvents, process
chemicals in printing, photography, textiles, dry cleaning,
electronics, furniture stripping, tanning, refrigerants,
lubricants, dyes, adhesives, preservatives, disinfectants, and
as feedstocks for chemical, pharmaceutical, and plastic
production.
• Pesticides. Organic chemicals used for insecticides,
fungicides, herbicides, and rodenticides.
• Metals and Other Inorganics. Acids, alkalis, metals, salt,
cyanides, detergents, and nitrates.
• Microorganisms. Viruses and bacteria.
Exhibit 4 illustrates the frequency with which contaminants managed by light industry
were reported in the case. As demonstrated in the exhibit, a wide variety of constituents have
contaminated ground water at light industrial facilities. The most prevalent general groups
of contaminants observed in the case studies include organics and metals/inorganics.
Although these categories are very broad and encompass a large number of constituents, the
case study information generally is not sufficiently detailed to support a more specific analysis.
For those case study reports that do contain constituent-specific information, typical
organic contaminants include benzene, dichloroethylene, dioxins, methylene chloride,
pentachlorophenol, perchlorethylene, toluene, trichloroethane, trichloroethylene, and xylene.
Most of these organics appear to be used as solvents in production or cleaning processes.
Typical metals/inorganics reported in the case studies include arsenic, chromium, copper, lead,
nickel, nitrates, and sodium chloride.
The following section analyzes the implications of the case study findings with regard
to wellhead protection.
2.3 Analysis and Discussion
Information from the light industry ground-water contamination case studies
summarized in Sections 2.1 and 2.2 encompasses a wide range of industry types, material
management practices, and contaminants. Although the true extent of Wellhead Protection
Area contamination caused by light industry is unknown at this time, the data gathered for
this analysis reveal certain patterns concerning the threats light industry pose to ground-water
quality.
The most prevalent material management phase associated with the ground-water
contamination cases involved waste management and disposal. Improper storage of raw
material and product storage was cited as the next most common contamination source. The
predominance of waste management and disposal activities in the ground-water contamination
cases is not unexpected. These cases involve activities such as improper disposal in septic
systems and illegal dumping or abandonment of wastes. Although many of these practices
are currently addressed by RCRA requirements (see Chapter 3), illegal or negligent disposal
may still occur. Similarly, raw material and product storage has also come under increasing
regulatory control, especially for those practices involving underground storage tanks (RCRA
Subtitle I). Enforcing existing Federally-mandated standards and controls for waste
management and product storage may serve as one means of limiting contamination resulting
from these material management phases at light industry facilities.
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EXHIBIT 4
Distribution of Materials Managed by
Light Industrial Case Study Facilities l
100
80
U
(0
u_
o
(0
(0
O
.0
3
60
40
20
Other Metals and Petroleum Pesticides
Organlcs Inorganics Products
Unknown Micro-
organisms
Materials Managed
1 Data for this exhibit were compiled from the summary of 182 case studies of ground-water
contamination at light industrial facilities.
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The prevalence of the organic and inorganic constituents observed in the case studies
is also expected. The organic contaminants are primarily solvents used as parts cleaners and
as carriers for other substances. These organics are used in a variety of light industries, such
as wood preserving and dry cleaning, and many of the organics are mobile in the soil and
ground water environments. Similarly, the inorganic constituents observed in the case studies
are also in widespread use by light industry, especially in electroplating and metal fabrication
industries. Most all of the constituents observed in the case studies are regulated as
hazardous wastes by RCRA or hazardous substances by CERCLA. The exceptions include
nitrates, sodium chloride, and BOD, although these contaminants are also addressed under
drinking water criteria.
In sum, the case study findings indicate that: (1) waste management and product
storage processes pose the most prevalent release threats to ground water, and (2) a wide
variety of potentially harmful constituents are managed at light industry facilities and are
involved in release incidents.
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3.0 Controls on Light Industry: Federal, State, and Local Roles
In this chapter, we outline the various Federal controls that may affect light industry
practices. Selected State and local initiatives are also discussed. The chapter concludes with
an analysis of the interrelationships among Federal, State, and local activities and the manner
in which they can be used together to develop an efficient and effective means of evaluating
and regulating ground-water threats from light industrial sources. EPA prepared this
discussion to help Wellhead Protection Program managers and other officials understand and
develop appropriate management controls for light industry within their jurisdictions.
3.1 Regulating Material Management by Light Industry
under Current Federal Law
A variety of Federal laws and regulations control the management of hazardous
materials and wastes. However, many of these Federal requirements impose only limited
controls on light industry, while leaving certain potentially contaminating activities or
substances unregulated. The following section describes several of these Federal laws and
regulations. The discussion highlights the manner in which these requirements either do or
do not apply to certain light industry practices. The major Federal Regulations controlling
the management of hazardous materials are:
• RCRA (Resource Conservation and Recovery Act);
• CERCLA (Comprehensive Environmental Response,
Compensation and Liability Act);
• SDWA (Safe Drinking Water Act);
• CWA (Clean Water Act);
• TSCA (Toxic Substances Control Act); and
• FIFRA (Federal Insecticide, Fungicide, and Rodenticide Act).
The application of each of these regulations to light industry management practices is
discussed below.
• Resource Conservation and Recovery Act (RCRAV RCRA addresses the
management of hazardous and solid wastes under Subtitles C and D of the statute,
respectively. These portions of RCRA address only waste materials and not raw materials
or products. For example, pesticides that are packaged for sale are not a hazardous waste.
The material may become a hazardous waste, however, when the pesticides are discarded. In
contrast, under Subtitle I of RCRA, standards are provided for underground storage tanks
(USTs) that are used to manage chemical and petroleum products. Each of these RCRA
program areas may impose controls on certain activities of light industry.
Subtitle C of RCRA recognizes three classes of hazardous waste generators (40 CFR
262.34): (1) generators of greater than 1,000 kg/month of hazardous waste (large quantity
generators); (2) generators of between 100 and 1,000 kg/month of hazardous waste (small
quantity generators - SQGs); and (3) generators of less than 100 kg/month of hazardous waste
(conditionally exempt small quantity generators or very small quantity generators - VSQGs).
Large quantity generators and most small quantity generators must meet specified
requirements, including: obtaining an EPA ID number, properly managing the waste in tanks
or containers (40 CFR 262.34), manifesting off-site shipments of the waste, and maintaining
records and regular reporting. Generators of less than 100 kg/month of hazardous waste, or
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conditionally exempt small quantity generators, however, are not required to meet the
technical requirements for RCRA generators (40 CFR 261.5). Many of the types of light
industries described in this document fall in this class of conditionally exempt small quantity
hazardous waste generators.
Exhibit 5 illustrates the relative breakdown between the number of small quantity
generators and very small quantity or conditionally exempt generators. Estimates of the
breakdown between SQGs and VSQGs suggest that there are approximately 175,000
generators in the 100 to 1,000 kg/month category and 455,000 generators of less than 100
kg./month (U.S. EPA, 1985). Although EPA estimates that these two groups of generators
represent approximately 98 percent of all hazardous waste generators in the United States,
the total volume of waste managed by these groups amounts to less than 0.5 percent of the
total quantity of waste generated annually. Nonetheless, these small and conditionally exempt
generators still manage approximately 630,000 metric tons of hazardous waste per year (U.S.
EPA, 1985). The vast number of these generators and the relative lack of regulatory contro'
on their operations raises the potential for ground-water contamination.
Concerns that arise from the activities of these operations can be traced, at least in
part, to several factors:
• Many operators of smaller facilities are not aware that they
may be generating hazardous wastes, or that their disposal
practices could result in contamination of ground water.
• Facilities that do not generate large volumes of waste may
nonetheless handle large volumes of hazardous raw
materials which should be of concern to local planners
seeking to protect their water supply. Wood preservers,
furniture strippers, and pesticide applicators are only three
examples of industries that typically do not generate large
volumes of waste, yet may have large volumes of chemicals
stored on site.
• Even small volumes of hazardous raw or waste materials
can contaminate a water supply, particularly if the material
is discharged in a Wellhead Protection Area.
Certain types of wastes that typically might be managed by light industries have been
specifically exempted from regulation under RCRA. These wastes include agricultural
irrigation return flows, materials that are recycled in closed systems, and wastewaters that are
disposed of in sewers or publicly-owned treatment works (POTWs) (40 CFR 261.4 (a)).
Furthermore, recycled materials such as used batteries and used oil are not regarded as
hazardous waste under RCRA However, if these materials are disposed of, they must be
managed as hazardous waste.
RCRA Subtitle D regulates other types of wastes defined as solid wastes, including
household garbage, mining wastes, wastes from oil and gas production, and cement kiln dust
waste (40 CFR 261.4(b)). It is important to note, however, that although these "solid wastes"
must be managed in compliance with the criteria outlined under RCRA Subtitle D, these
criteria apply only to the solid waste management facilities that ultimately dispose of the
waste (40 CFR Part 257). In effect, the light industries that generate solid waste are not
regulated under RCRA Subtitle D. Hence, light industries that are either generators of solid
waste or conditionally exempt generators of hazardous waste are only minimally regulated by
the RCRA hazardous waste controls.
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Exhibit 5
Distribution of Small Quantity Generators by Industry Group:
SQGs and VSQGs
Metal Mfg.
9%
Other Mfg.
5%
Other
Non-Manufacturing
13%
Construction
3%
Other
Non-Manufacturing
22%
SQGs
(>100 kg/mo)
Other Mfg.
9%
Construction
13%
VSQGs
(<100 kg/mo)
Vehicle Maintenance
70%
I I Manufacturing
^H Non-Manufacturing
Vehicle Maintenance
48%
Source: Small Quantity Generator Survey data and analysis of secondary Industries
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The Subtitle I program of RCRA regulates approximately 1.5 million underground
storage tanks that are used to store chemical and petroleum products. The program bans the
installation of unprotected new tanks, requires tank owners to notify EPA of the number of
tanks in use, establishes standards to clean up releases from the tanks, and imposes technical
standards and inspection requirements for existing tanks (40 CFR Part 280). Subtitle I differs
from Subtitle C and D in that it applies technical standards to processes that manage
products, not wastes. The UST program addresses the petroleum storage tanks used by light
industries, such as automobile service stations and dealerships, and the chemical storage tanks
found at light industries, such as agricultural supply services and certain electroplating shops
and electronic equipment manufacturers. However, the UST program applies only to tanks
with at least ten percent of their volume buried underground. Furthermore, the following
types of tanks are specifically exempted from the Subtitle I controls: farm and residential
tanks with a holding capacity of less than 1,100 gallons; on-site tanks storing heating oil;
septic tanks; pipelines regulated under other laws; surface impoundments; systems for
collecting storm water and wastewater; flow-through process tanks; and liquid traps or
associated gathering lines related to operations in the oil and natural gas industry (40 CFR
Part 280). Thus, although Subtitle I presents a level of protection against leakage from
certain types and volumes of hazardous materials containers, non-regulated activities within
a wellhead area can pose an equivalent threat to a water supply. Furthermore, RCRA does
not stipulate provisions that govern raw materials handling practices within an industry.
• Comprehensive Environmental Response. Compensation, and Liability Act
(CERCLA). The best known component of CERCLA is the remedial action program which
addresses past releases of hazardous substances to the environment. Many cases of ground-
water contamination by light industry are currently being addressed under Superfund. In
addition, Title III of the Superfund Amendments and Reauthorization Act of 1986 (SARA)
imposes certain emergency planning and notification requirements on facilities that handle
hazardous materials. The first of these requirements, found in sections 301-303,311, and 312
of Title III, is known as the "emergency planning and community right-to-know" program.
This program requires facilities to notify State officials of the presence of "extremely
hazardous substances" at their location, and to supply local officials with a list of all materials
stored on site in volumes that exceed threshold quantities established by EPA (40 CFR Part
355 and 40 CFR Part 370). These provisions were adopted to enable communities with
participating facilities to establish emergency planning and notification procedures, based on
the materials located within the community. Section 302 authorizes State officials to
designate additional facilities (e.g., those which handle lesser amounts of regulated materials)
as subject to the planning requirements.
Additional provisions within Title III relate to notification requirements for releases
of hazardous materials. Section 304 of SARA requires immediate notification to local and
State emergency planning committees if any of the listed hazardous substances are released
from a facility (40 CFR Part 302.4 and 40 CFR Part 355), as well as follow up emergency
notice. A second program, under SARA Section 313, requires that all releases of hazardous
substances, both routine and accidental, as well as off-site shipments of waste containing
listed toxic chemicals, must be reported to EPA (40 CFR Part 372). Although both of these
programs require light industries to notify EPA of releases of hazardous substances, Title III
contains no explicit cleanup requirements. Title III, like RCRA, does not impose any
conditions on materials handling practices; it only requires inventories and reports.
• Safe Drinking Water Act (SDWAV The SDWA mandates controls on certain waste
management activities to prevent the contamination of drinking water supplies. In particular,
EPA has promulgated regulations under the SDWA to control the disposal of wastes in
underground injection wells (40 CFR Part 144). The SDWA regulates five general classes
of underground injection wells. Class I wells are those that are used to dispose of hazardous
or other industrial waste. Class II wells are used to dispose of materials such as brines and
oil drilling wastes. Class III and IV wells are other types of disposal wells which are far less
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common. Class V wells include the remaining types of waste disposal wells, including shallow
dry wells and certain types of septic systems. Many contamination events caused by light
industry involve the improper disposal of wastes in these Class V wells. Although some
controls are now being imposed on disposal in Class V wells, improper waste disposal by light
industry in these wells still occurs. Changes to the Federal regulatory requirements may
impose tighter controls on disposal in Class V wells in the future.
The 1986 amendments to the SDWA include provisions that require States to
establish Wellhead Protection Areas around public water supply wells. These provisions
require, among other things, the identification of all potential sources of contamination
within the Wellhead Protection Areas and a description of control measures to protect the
water supply. These activities and control measures include light industrial operations.
Clean Water Act (CWAV The CWA addresses the restoration and maintenance of
the chemical, physical, and biological integrity of the Nation's waters through the reduction
and elimination of toxic pollutant discharges; providing States with financial assistance for
the construction of publicly owned waste treatment works; development and implementation
of areawide waste treatment management plans for the control of pollutant sources in each
State; development of technology necessary to eliminate pollutant discharge into oceans,
coastal and navigable waters; and for assessment and management of nonpoint sources of
pollution nationwide.
Provisions under CWA applicable to the control of light industrial sources of ground-
water contamination include nonpoint source pollution control programs (Section 319),
effluent permitting guidelines (Section 304), and stormwater permitting requirements
currently under development under the National Pollutant Discharge Elimination System
(NPDES; Section 402).
• Toxic Substances Control Act (TSCA). TSCA regulates the use of new and existing
chemical substances and mixtures. Under Section 5 of TSCA, manufacturers of new chemical
substances must notify EPA through the submittal of a pre-manufacture notice (PMN) at
least 90 days prior to commencing manufacture or import of the substance for non-exempt
commercial purposes. EPA will then review the new chemical substance and may impose
restrictions on the manufacture, processing, distribution, use, or disposal of the substance.
In some cases, companies may have conducted toxicity testing prior to beginning to
manufacture the substance. As a result of this process, EPA may restrict the use of certain
chemical products either handled or produced by light industries.
TSCA also regulates the use and disposal of polychlorinated biphenyls (PCBs). For
example, EPA is instituting a nationwide program in which the PCB-containing fluids in
electric transformers and capacitors are being replaced with other polyelectrolytes. TSCA
further requires that waste PCBs from these and other applications must be disposed of in
approved landfills or incinerators or EPA-approved alternative disposal technologies. Light
industries that either use machinery containing PCBs or collect scrap materials containing
PCBs must comply with these TSCA controls.
• Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). FIFRA addresses the
registration and use of pesticides in the United States. The act has been used to indirectly
protect ground water through the pesticide registration program. A manufacturer must
generally submit a variety of health and safety data before EPA can register a pesticide (40
CFR Part 152). If EPA determines that use of a pesticide will result in unreasonable adverse
effects on the environment, including ground-water contamination, EPA may deny
registration. Among other options, EPA can impose packaging and labelling requirements
and restrict the use of a pesticide. Cancellation of a registration is also possible if product
use generally causes unreasonable adverse effects on the environment. Each pesticide must
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have a label that contains detailed directions for use. All users, including light industry, must
comply with these requirements.
Applicability of Federal Controls to Light Industry
The preceding discussion illustrates that certain light industrial practices are
regulated by Federal law, principally under Subtitles C and I of RCRA These regulations,
however, are limited to the listed waste disposal and storage practices and materials. While
the regulations do govern most major generators, much of the light industrial sector is
exempt.
Provisions of SARA Title III apply to any facility that uses hazardous materials in
excess of the listed threshold quantities, but even this expansion of the regulated community
does not encompass all light industrial facilities. Furthermore, the statute only requires an
inventory of materials; management practices or guidance are neither provided nor mandated.
TSCA and FIFRA impose restrictions on the use of a limited number of materials
that could pose a threat to a community's ground water, and the SDWA regulates some
activities that affect ground-water quality.
Thus, the Federal programs, although providing comprehensive regulation of major
generators of waste and handling of select materials, provides little regulation of production
processes and small-scale waste management practices. These limitations can be traced in
part to the sheer number of facilities that would be brought under the Federal umbrella, if
it were to become all inclusive. Additional constraints on a Federal role arise from
traditional reliance on State regulation of activities relating to the ground-water resource.
Various States and local governments have taken additional steps to protect their ground
water, which include measures relating to light industrial activities.
Many States and local governments have adopted control programs under the broad
mandates of RCRA, CERCLA, or other Federal or State statutes. A comprehensive
summary of State and local programs is beyond the scope of this document. Nonetheless, in
the following section we briefly describe State and local approaches for controlling light
industries. This chapter concludes with a description of the interrelationship among Federal,
State, and local programs and how the various authorities can be combined to prevent the
occurrence of ground-water contamination from light industrial activities.
3.2 State and Local Approaches for Controlling Light Industry
The Federal government delegates to the States a broad police power to legislate on
behalf of the public health, safety, and welfare. This power can be used to protect ground-
water resources from various forms of industrial contamination. While the authority is broad,
it is tempered by limitations imposed by the principle of Federal preemption, language found
in State constitutions, and rulings of Federal and State courts.
Programs adopted by States that can help to protect ground water from
contamination due to light industrial activities include:
• Watershed Rules and Regulations - Local agencies in New
York State, for instance, are authorized to adopt land-use
plans to protect public water supplies.
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• Ground-Water Management Areas - Washington State's
Department of Ecology will designate areas that have
identified concerns over ground-water quality; a
management plan is tailored to suit the local needs.
• Ground-Water Standards - Many States have adopted
standards to protect their ground water. Standards may be
either numeric, specifying a maximum concentration for a
particular contaminant (see, e.g., Alaska, New Hampshire,
Texas), or narrative, specifying a general prohibition on
types of discharges or identifying a general quality goal
(see, e.g., Arizona, Michigan, North Carolina). Some States
have adopted both types of standards to ensure
comprehensive protection of the resource.
• Ground Water Classification - Several States (e.g.,
Connecticut, South Carolina, Vermont) have classified their
ground water and specified differential protection measures
according to the classification.
A number of States, such as Illinois and Wisconsin, have enacted legislation to
authorize adoption of ground-water protection measures by local government. Illinois'
legislation includes provisions that authorize the creation of setback zones around wells and
an inventory of facilities and activities surrounding the wellhead (Illinois Municipal Code,
Section 11-25-4). Wisconsin municipalities were given authority to adopt zoning ordinances
"to encourage the protection of groundwater resources" by legislation passed in 1984
(Wisconsin Assembly Bill 595).
The town of Rib Mountain in Marathon County, Wisconsin, adopted land-
use regulations to protect its ground-water supplies. The ordinance uses
overlay zoning to create two districts within the recharge basin for municipal
wells. Lands overlying the sand and gravel aquifer have greater restrictions
imposed on use than more upgradient areas in the watershed. Commercial
and industrial uses are prohibited in Zone A, which is in close proximity to
the wells. In Zone B, these uses are allowed as conditional uses, if they
meet certain requirements to protect ground water.
Local governments have other sources of regulating authority in addition to ground-
water specific State legislation; police powers have been delegated to local government in
most States. This authority can be implemented to protect ground-water supplies by means
of direct or indirect controls, such as land-use plans, zoning ordinances, site plan review, and
design standards. Health ordinances are an effective means for communities to regulate
potential contaminants through their police powers. This approach controls materials use
regardless of the location of the facility, as opposed to regulating the location of the facilities.
In 1979, the Cape Cod Planning and Economic Development Commission
(CCPEDC) developed a model health ordinance for use by towns on the
Cape to control the use, storage, and disposal of toxic and hazardous
materials. The model ordinance has three major components:
• Prohibition - Discharges of toxic or
hazardous materials are prohibited.
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• Registration - Owners or operators of
facilities storing a quantity of materials
which exceed a threshold amount
(established in regulations by the town)
must register the type and amount of
materials with the Board of Health
(BOH).
• Inspection/Enforcement - The BOH is
authorized to conduct inspections of sites
where toxic and hazardous materials are
stored or used.
In practice, the BOH identifies all firms or individuals who may be subject
to the ordinance, notifies them of the need for compliance, provides a list
of materials considered to be toxic or hazardous and threshold amounts of
the materials, and supplies a registration form which must be completed
within a specified period of time. The BOH will inspect the facility if the
forms are not completed on time. If inspection reveals that forms are in
error or unsatisfactory practices are observed, the BOH may require
corrective measures to improve storage, use, or disposal practices. Fines for
violation of corrective orders are up to $200 per day.
The Town of Barnstable adopted the model ordinance as a Town Bylaw in
1979, the first community in the nation to adopt a local toxic and hazardous
materials handling bylaw. Barnstable is a major business and population
center located in the middle of the Cape, with the largest concentration of
light industrial and commercial development. Ninety percent of these
establishments are located within a four square mile area and all are within
the zone of contribution for several of Barnstable's public water supply
wells. Since several hundred facilities are affected by the town's bylaw, a
strong implementation program has been undertaken.
Barnstable officials were particularly concerned that the only industrial zone
in the town overlies the zone of contribution for eight public wells supplying
Hyannis. A large part of the industrial area is occupied by a privately-owned
industrial park which, as of 1986, was only five percent developed. The town
does not wish to discourage development, but must act to protect the water
supply, which cannot be moved. Additional facilities of concern are located
outside the industrial park, but within the zones of contribution.
The Barnstable BOH received a technical assistance grant from CCPEDC
to pay for a staff person working with the local health agent for a year to
compile a comprehensive list of materials considered to be toxic or
hazardous, and to develop the registration form. Since then the BOH
procedures and forms have been refined, and the BOH reports that 100
percent compliance with the bylaw by covered facilities has been achieved
with only two visits.
One of the most influential land-use control approaches utilized by local
governments involves zoning. Local governments typically establish zoning and subdivision
requirements that prescribe types of approved uses for land and buildings. Industrial zoning
ordinances traditionally divide industrial areas into "light" and "heavy" districts. The controls
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on heavy industries are generally more restrictive, as these industries are considered most
offensive. Some communities, however, have recognized the potential for contamination from
light industry and have imposed fairly comprehensive controls on these activities when they
are located in Wellhead Protection Areas.
The Dade County, Florida, Wellfield Protection Program is an evolving set
of activities that were initiated in the mid-1970's when volatile organic
compounds were detected in a number of water supply wells. The sources
of these compounds included leakage and runoff, spills and improper
disposal, and effluent from heavy and light industrial activities, domestic and
municipal waste treatment plants, leaking sewer systems, and agricultural
and urban runoff. Development of the program was undertaken primarily
within the Dade County Department of Environmental Management to
ensure long-term protection of drinking water.
Section 208 studies under the Clean Water Act allowed the county to
delineate wellfield areas of influence and establish a basis for regulating
hazardous material use, storage, and disposal. The Dade County Wellhead
Protection Ordinance regulates the type and density of wastewater
discharged within each of five zones in the area of influence, based on soil
conditions. The ordinance prohibits the use of hazardous materials within
the area of influence.
The Dade County program provides the following restrictions on light
industry within the wellfield protection zones:
1. No new hazardous materials activities;
2. No new nonresidential activities except on
sewers;
3. Only "low risk" nonresidential activities
permitted;
4. Annual permitting and inspection of all
nonresidential uses;
5. Density restrictions as a function of travel
time to wells;
6. No expansion of existing uses unless a net
decrease in environmental risk is
demonstrated;
7. Progressively more stringent stormwater
disposal requirements as wells are
approached;
8. Best available technology is required for
sewer construction;
9. Expedited sewering of unsewered areas;
10. Canal construction or improvement to
create hydraulic boundaries between wells
and pollution sources;
11. Expedited cleanup of known pollution
sources;
12. Creation of approved hazardous waste
transfer stations outside of the protection
zones;
13. Limitations on transportation of
hazardous materials through the
protection zone;
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14. Installation of air-stripping equipment at
water treatment plants to reduce volatile
organic compounds which may already be
in the ground water; and
15. Variances require a 4/5 affirmative vote
from the appeals board.
The preceding examples illustrate some of the regulatory tools that can be used by
local officials to protect their water supply from identified threats. Equally important to an
effective program is an understanding of the ground-water system and the potential for
contamination. This understanding and evaluation is critical to ensuring that a regulatory
program addresses potential problems without being overly restrictive.
Citizens of Spokane, Washington formed a planning group in 1977 to
develop a strategy for protecting their underground source of drinking water.
The committee spent their first year developing a data base of ground-water
quality, and reaching a common level of understanding of ground-water
hydrology and water pollution problems before beginning to develop a plan.
Their study showed that water quality was deteriorating due to human
activities, including industrial development and chemical spills resulting from
storage, transportation, and use of chemicals. Specific incidents that could
be traced to industrial sources include the contamination of private wells by
organic cleaning solvents leaching from a county landfill, and contamination
of additional wells by cyanide originating from pot linings disposed of at an
aluminum reduction plant. The citizen's group released a Water Quality
Management Plan in 1979, which included recommendations for controlling
chemical spills and leaks through a combination of land use and zoning
regulations, development and enforcement of best management practices,
and public education.
Ordinances adopted by Spokane County in 1983 established an Aquifer
Sensitive Overlay Zone and established procedures for proper handling and
disposal of hazardous and critical materials in the home and the workplace.
The zoning ordinance encourages business and industry using "critical
materials" to locate outside of the sensitive area by setting performance
criteria for facility design which require the retention of spills or leaks and
the prevention of subsurface infiltration by defined materials, as well as
prohibiting chemical waste disposal in the sensitive area. The critical
materials ordinance and critical materials handbook include requirements for
management controls for handling and storage of materials; spill prevention,
control, and clean up plans; and identifying critical materials and critical
materials use activities. Building permits for new construction are reviewed
to determine chemical use and to check for appropriate design where
chemicals are used or stored. Secondary containment is required for
underground storage tanks and associated piping, and spill response and
shipping requirements have been established for transportation of critical
materials. By adopting the term "critical materials" the committee sought
to avoid confusion or the limitations associated with Federal and State
hazardous waste regulations.
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Projects proposed in the sensitive zone are compared with a Critical
Materials Activity List developed from an Industrial Survey performed by
the Washington Department of Ecology (DOE) and an Industrial Waste
Survey performed for DOE. A review of spills in the Spokane area revealed
that spills generally result from the transfer of liquids between containers or
from material transfer lines. The ordinance, therefore, contains guidelines
that include provisions for materials handling:
• Employee training;
• Materials properties to be considered
when choosing a material for a specific
containment or storage use; and
• Criteria for determining the required
containment volume for secondary systems
(e.g., include potential precipitation and
means for separating precipitation from
chemicals).
The ordinance also requires facilities that elect to locate in the sensitive
areas to prepare a spill plan. The plan is to include facility-specific
information:
• Description of physical facilities and the
nature of operations utilizing critical
materials;
• Notification procedures in the event of a
spill;
• Identification of potential sources of spills;
• Spill control procedures; and
• Training programs for personnel.
The materials manual also contains design concepts to stimulate ideas for
materials containment (e.g., covered loading areas, double walled pipes,
perimeter drains, and floor drains).
Local citizens have voted to create aquifer protection districts, which assess
a monthly user charge of $1.25 per month to all customers located over the
aquifer and an additional $1.25 per month to all those who discharge wastes
through a drainfield system. These funds, supplemented by a $0.0025 sales
tax, defray the costs of new sewerage projects and fund additional aquifer
protection programs. All commercial and industrial customers within a
district are required to connect to a sewer within one year of its completion,
while new facilities are required to connect immediately. Commercial and
industrial facilities outside of service areas must connect to county sewers
unless the utilities district determines that connection is not economically
feasible.
Placing direct limitations on development is only one of the options available to local
officials. Regulators can condition approval of a proposed development on the adoption of
management plans by the developer or property manager. Developers of private industrial
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parks, for example, can be required to (or can voluntarily impose) covenants, conditions, and
restrictions (CC&Rs) on park tenants that serve to supplement zoning restrictions. The
CC&Rs often act in conjunction with zoning controls to impose limits on industrial
"nuisances." For example, the lessee may be required to submit a detailed site plan
containing a report which addresses environmental issues related to the operation, such as
the volume of hazardous wastes produced or the anticipated load on sewage treatment
facilities. CC&Rs may also prohibit discharges of hazardous materials from a site or restrict
the use of underground storage tanks. Wellhead Protection Program managers can use these
public and private controls to assist in ground-water protection.
Additional information regarding the potential tools for protecting ground water can
be found in the publication Wellhead Protection Programs: Tools for Local Governments.
USEPA/OGWP.
3.3 Analysis and Discussion
The preceding sections indicate that there is no single source of authority for
evaluating or regulating light industrial practices. There are, however, a variety of statutes
at both the Federal and State levels which can provide the means for evaluating and
minimizing threats to Wellhead Protection Areas. Local governments have additional options
available to them through their police powers and traditional land-use planning and
regulation techniques.
Two of the initial steps to take in developing a management program for light
industry involve the evaluation and definition of 1) the resource to be protected, and 2) the
potential sources of concern. Resource evaluation is beyond the scope of this document.
The reader is referred to EPA's Guidelines for Delineation of Wellhead Areas (EPA 440/6-
87-010) as a starting point for this effort. Several of the regulatory authorities cited in this
section, however, can be used to ascertain the nature of light industrial operations; an integral
part of evaluating sources.
The permit and notification requirements of RCRA and SARA Title III, respectively,
provide two avenues for identification of light industrial activities in Wellhead Protection
Areas. The files of the State division of hazardous waste contain the name, location, and
materials handled for all RCRA generators in a given State. This source of information can
provide a first level of scrutiny by identifying most of the major and many of the minor
handlers of hazardous materials in the vicinity of a wellfield. The Small Quantity Generator
provisions of RCRA encompass many light industrial facilities. In addition, some States have
used their RCRA authority to regulate Very Small Quantity Generators, those facilities that
generate less than 100 kg/month of hazardous waste. Massachusetts' VSQG program, for
instance, requires such facilities to register with the Department of Environmental Quality
Engineering (DEQE). Although these facilities are not required to obtain a RCRA ID
number or manifest, they must comply with certain reporting requirements:
• Types and quantities of hazardous waste produced;
• Recycling, treatment, or disposal plans; and
• Name and location of facility or generator receiving VSQG waste.
The VSQG requirements effectively expand the available data base to include all
generators of hazardous waste. Although this option provides additional information for
regulators and planners, the program also creates an additional administrative burden - the
ratio of VSQGs to SQGs is approximately 2.6 to 1.
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• Public Participation
Massachusetts has incorporated another feature into its SQG program which could
be of value to any State or community seeking to reduce light industrial contamination of
ground water. The hazardous waste division of DEQE has established a public participation
group that works with industries and local governments looking at behavior patterns and
providing compliance assistance. Fact sheets, videos, information programs, and other
educational materials are all part of the compliance assistance program. As noted in the
Cape Cod experience cited above, industries are often willing and able to eliminate problem
areas once they have the information in hand to recognize and correct potential problems.
The State personnel are able to address a wide audience by providing training and
information to local government officials, who can use these methods in their own
community. These techniques can be used effectively at both the State and local level with
only a limited expenditure of resources.
• Inventorying
The notification requirements of SARA Title III dictate that all facilities handling
quantities of hazardous materials in excess of EPA threshold amounts must provide a list of
these materials to community planners. The significance of these requirements is that they
apply to quantities of materials that are involved in the manufacturing or other processes at
the facility, not just the waste materials. These requirements allow community and State
officials to obtain an expanded picture of the light industrial scene, since many facilities may
handle sufficient quantities of hazardous material to qualify for Title III notification, yet not
generate the amounts of hazardous waste necessary to require filing as a RCRA large quantity
generator. Wood preservers or furniture strippers, for example, may handle or store large
volumes of materials but generate only small amounts of waste. Materials handling is as
significant as waste handling in the vicinity of the wellhead, because poor practices in either
aspect of facility operations can result in contamination of the water supply. Although the
Title III regulations do not include the authority to regulate materials handling, local officials,
armed with the knowledge of storage and use of hazardous materials in the wellhead area,
may decide to impose materials handling requirements through local controls.
• Source Identification
The SDWA Amendments of 1986 require States to develop management plans for
wellhead protection, including identification and control of potential sources of
contamination. Some States have already established programs to accomplish these same
goals. States wishing to adopt a Wellhead Protection Program can utilize the information
available through RCRA and Title III, as described above, to identify sources of
contamination. State initiatives can also provide explicitly for adoption of local ground-water
protection measures. Any of these measures at the State level can incorporate provisions that
include controls on light industry.
Once a community has identified the Wellhead Protection Area and the location of
light industrial facilities that overlie the Wellhead Protection Area, planners will need to
determine the threat that these facilities pose to the water supply. Each community will need
to review and evaluate the existing framework of State and Federal controls and determine
whether additional protection is needed for their water supply. As noted above, few of the
current regulatory programs provide controls on materials handling, production processes,
and management of small quantity waste streams. Localities may determine that local
initiatives are needed to provide adequate safeguards against contamination. This decision
will be based in part on the nature and extent of the Wellhead Protection Area and, in part,
on the governing local politics.
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Communities can use the wide range of planning authorities and police powers
available to fashion a Wellhead Protection Program specific to their own needs. The
examples provided in Section 3.2 illustrate some of the options that local governments have
adopted to protect Wellhead Protection Areas from light industrial contamination. Each
community should refer to these and other examples,,but fashion their own program to meet
their own situation. The appropriate decision for some communities may be to restrict all
industrial activities in the wellhead area through zoning. Other communities may determine
that a limited ban, coupled with controls on activities is appropriate. These controls can be
in the form of design standards for facilities to reduce the chance of contamination in the
event of a release, bans on the use of certain materials, or restrictions on use in the form of
materials handling or best management practices. The following chapter presents descriptions
of some light industrial practices that pose potential threats to Wellhead Protection Areas
and the management controls that have been used by some industries to address the potential
for contamination.
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4.0 Minimizing Ground-Water Contamination by Light Industry
Several control techniques have been used by light industry to prevent ground-water
contamination. These techniques range from low-cost management controls to more
sophisticated technology-based waste minimization techniques. This section presents an
overview, illustrated with case studies, of management controls and waste minimization
practices for protecting Wellhead Protection Areas. The section concludes with an analysis
and discussion of the role of industry groups and local governments in promoting the use of
management controls.
4.1 Management Controls for Preventing Ground-Water Contamination
This section discusses seven management controls that have been recommended by
various State and local governments and that have been adopted by many light industries.
These management controls are directly applicable to wellhead protection. The following
seven management controls illustrate the broad range of activities that many light industries
have adopted to reduce the threat of ground-water contamination in Wellhead Protection
Areas.
(1) Controlling spillage in loading and unloading of raw materials and wastes
(Connecticut Department of Environmental Protection, 1984). Spillage may occur
at material transfer points (e.g., loading and unloading areas) at a variety of light
industries, such as gas stations, small fuel storage facilities, farm co-ops, or chemical
storage facilities. Through poor operating practices, gasoline, oil, pesticides,
fertilizers, and chemical solvents are frequently spilled on the ground. Improper use
of hoses during material transfers also results in spillage. When these spillage
problems can not be avoided, contamination can best be prevented through the
installation of catchment basins beneath material handling areas. These basins may
drain to holding tanks. Spilled material can then be removed to a treatment facility
for final disposal or, if the waste is compatible with the local POTW operations, the
waste may be treated and discharged to municipal sewer lines. These catchment
basins should be coated with impermeable materials to prevent the leakage of
materials through the basin to ground water.
Example: An agricultural supply company in Hospens, Iowa has caused
contamination of nine wells, including two municipal wells. Approximately
31,000 square feet of soil was found to be contaminated at the materials
loading operations area. Contaminants included pesticides and carbon
tetrachloride. The handling practices employed at the loading area were the
primary cause of the ground-water contamination. The threat can be addressed
by installing basins that drain to holding tanks with proper secondary
containment.
(2) Managing contaminated runoff from the rinsing and cleaning of tanks and containers.
Many pesticide applicators, asphalt mixing trucks, crop dusters, and lawn services
clean off their holding tanks and/or spraying equipment on open ground. 'Such
cleaning should only be conducted over catchment basins and contaminated runoff
from the cleaning process should be collected for on-site recycling and reuse or off-
site management (Cape Cod Aquifer Management Project, July 1988)
Example: A crop dusting company in Marianna, Florida routinely purged and
then flushed the airplane's pesticide tanks onto the ground after each dusting
run. This practice resulted in soil contamination and subsequent contamination
of public water supply wells. The contaminant plume is 2,000 feet in length and
contains many different types of pesticides. Clearly linked to the purging and
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runoff from rinsing the pesticide tanks, this ground-water contamination could
have been avoided with minimal runoff control
(3) Preventing improper disposal in septic systems or dry wells. Light industrial
generators of solvents and other hazardous wastes, such as auto repair shops,
electroplaters, furniture strippers, car washes, dry cleaners, and light manufacturing
plants, have been known to dispose of their wastes in septic systems or dry wells.
The types of wastes that are disposed in septic systems and dry wells should be
strictly controlled (U.S. EPA, 1986).
Septic systems generally consist of two units: a septic tank and a leaching system.
Bacteria in the septic tank anaerobically decompose solid material discharged into
the tank. Effluent from the septic tank then flows into the soil leaching system. As
the wastewaters flow through the soil leachfield, some pollutants are filtered, sorbed
onto the soil, or undergo aerobic degradation. Although septic systems can
effectively treat and dispose most domestic wastewaters, these systems cannot treat
all wastes. Nitrates and volatile organic solvents are generally not removed in the
septic tank nor are they bound in the soil. Furthermore, the ability of the soil to
immobilize heavy metals, pathogens, and phosphates can be exhausted over time. As
a result, if these contaminants are introduced into the septic system, they can
migrate relatively easily through the soils and into the ground water. Hence,
disposal of industrial wastewaters containing metals and organic solvents should be
prevented. These types of wastewaters can be disposed either through hook-up to
a sewer system or through the use of "milk-run" pick-ups to gather and transport
hazardous materials for disposal.
Dry and shallow wells have also been cited as an important source of ground-water
contamination. Contamination has occurred through improper disposal of
wastewaters in these wells and through the movement of surface contaminants into
the wells during storm events. These wells include municipal, industrial, irrigation,
and livestock wells and unplugged test holes. Many older wells are improperly
constructed with an absence of casing. Therefore, contaminants that enter the wells
can move into all water-bearing strata. Furthermore, these abandoned wells are
frequently left uncapped, increasing the likelihood for contamination. Disposal in
these wells is controlled by the underground injection control program under the
Safe Drinking Water Act. Discharging to shallow wells should be prevented and the
waste management shifted to recycling or off-site disposal. In addition, all
abandoned wells should be capped to prevent the entry of any contaminants.
Example: A Dutchess County, New York dry cleaner routinely disposed solvent
wastes into the company's septic system. This improper waste management
caused a 1,500 foot long plume of various hazardous solvents and metals that
contaminated wells for an apartment complex. The remedial action cost $2
million. Proper handling and disposal of the wastes could have completely
prevented the ground-water threat.
(4) Minimizing the intensive use or overuse of materials, such as road salts and
agricultural chemicals. Many incidents of ground-water contamination have been
linked to the storage and use of road salts. Furthermore, agricultural chemicals are
frequently used to control vegetation growing in utility or road right-of-ways.
Preventing or limiting the use of these materials in areas of high ground-water
vulnerability or switching to other methods of road and right-of-way maintenance will
help minimize ground-water contamination. For example, abrasives or other road
deicers such as potassium chloride have been substituted for sodium chloride, which
is a common ground-water contaminant. Similarly, in some areas Wellhead
Protection Program managers are returning to mechanical methods of vegetation
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control, such as mowing, to maintain right-of-ways. ( Massachusetts Dept. of
Environmental Quality Engineering, May 1982)
Example: In Wisconsin, a seed culturing facility intensively applied pesticides
with heavy watering. The heavy use of pesticides, such as atrazine, is causing
a threat to ground water. The extent of contamination is not yet determined,
but correctly managing the use of the pesticide and controlling water
applications would reduce the threat to ground water.
(5) Preventing leakage from underground storage tanks and pipelines. Underground
storage tanks are a well known source of contamination. Trucking companies,
highway departments, and auto service stations use underground tanks to store
petroleum products. Other industries, such as agricultural supply services, may use
tanks to store chemical pesticide and fertilizer products. In addition, product
delivery or internal material management pipelines may leak and contaminate ground
water. Many of these underground storage tanks and pipelines are regulated under
Subtitle I of RCRA, but smaller tanks and certain types of pipelines may not be
addressed under current controls. Leaks from underground storage tanks and
pipelines result from defects in materials, improper installation, corrosion, or
mechanical failure of the pipes and fittings. Many underground storage tanks
installed prior to the RCRA Subtitle I controls were simply made of bare carbon
steel. The corrosion of these bare steel tanks is by far the most serious cause of
leaks. In addition, leaks from pipe fittings or tanks damaged during installation are
a serious threat. The following practices can ensure that such leaks are identified
and addressed:
• Closely monitor the inventory in the tanks to determine
whether product is lost through leaks;
• Conduct regular pressure leak testing of tanks and pipe
fittings;
• Require annual testing of unprotected steel tanks and
piping systems, especially for those aged 15 years or more;
• Install leak-detection systems to monitor continuously for
releases;
• Install cathodic corrosion protection systems, especially in
highly corrosive environments;
• For new tanks, conduct a tightness test and inspection for
the complete tank and piping system before the tank is
filled; and
• Install systems to prevent overfilling of the tanks, such as
feed cut-off systems and by-pass systems to standby tanks.
(Massachusetts Dept. of Environmental Quality
Engineering and FR 37082, 1988)
Example: A leaking underground storage tank at a gasoline station in Walpole,
Massachusetts released approximately 3,000 gallons of gasoline. The release
contaminated 23 wells with constituents such as benzene and toluene. Better
controls on the underground tank system could have greatly decreased the
ground-water contamination.
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(6) Controlling improper storage of raw materials or product stockpiles. Materials stored
on the ground and in uncovered areas may leak or leach hazardous materials. Such
problems can be prevented by storing materials in covered areas and on pads with
drains or over catchment basins. These control measures are especially effective for
materials, such as treated lumber, that may leach hazardous materials if they are
exposed to rain or the elements. (Long Island Regional Planning Board, 1983)
Example: Eight well contamination incidents in Rhode Island have been
recorded due to the improper storage of salt used to deice highways. At these
locations, the salt piles were neither covered nor stored on a containment pad.
High levels of chloride and sodium have contaminated the ground water after
leaching from the storage sites. Lack of protection of the salt from the weather
has caused significant loss of salt to and contamination of the ground water.
(7) Following general good housekeeping practices to catch spills and leaks. General
operating procedures should include placing drip pans or catchment basins under
machinery or material storage areas. Released materials captured in this way should
be managed through reuse and recycling or proper containment followed by off-site
disposal. (U.S. EPA, 1988)
Example: A printed circuit board manufacturer in St. Louis Park, Minnesota
contaminated ground water with trichloroethylene (TCE) and heavy metals.
The source of contamination was an unnoticed and uncaptured leak in the
wastewater management system. Ground-water contamination resulted from
the absence of a secondary containment in the wastewater management system.
4.2 Long-Term Solutions: Pollution Prevention - Source Reduction, Recycling,
and Treatment
Combining management controls with technology-based techniques for minimizing
the generation of waste will enhance the prospects for long-term protection of Wellhead
Protection Areas. EPA encourages pollution prevention, i.e., the reduction or elimination,
to the extent feasible, of any waste that is generated and subsequently treated, stored, or
disposed (U.S. EPA/OSWER, October 1987). This section presents the three pollution
prevention categories recognized by EPA. For each category, a "composite" case study is
presented to illustrate the potential threat to Wellhead Protection Areas posed by waste
generation. Each "composite" case study combines a description of a ground-water
contamination case and a description of an applicable pollution prevention technique. These
composite cases illustrate the manner in which the three general pollution prevention
techniques may support wellhead protection activities.
(1) Source reduction. Source reduction often involves changes to input
materials, technology changes, and procedural or organizational changes.
Source reduction techniques include the following:
• Training and supervision, which provides information and
incentives to employees to effectively minimize waste
generation;
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• Production planning and sequencing, which requires
planning to ensure that only necessary operations are
performed and optimized to reduce waste generation;
• Process/equipment adjustment or modification, which
•involves changing process parameters, equipment, or the
process itself to reduce the amount of waste generated;
• Raw material substitution, which replaces existing raw
materials with raw materials that will result in the
generation of less waste;
• Loss prevention and housekeeping, which involves
maintaining and managing equipment and materials in such
a way so as to minimize the opportunity for spills, leaks,
and other undesired releases of hazardous materials; and
• Waste segregation and separation, which involves avoiding
the mixing of different types of hazardous and/or non-
hazardous wastes so as to best utilize any individual waste
stream that is recoverable or usable in its existing
composition.
Example: A Dade County, Florida facility repairs diesel truck fuel injectors.
Before repair, fuel injectors are completely cleaned by removing any fuel, oil,
grease, dirt, or other contaminants that may inhibit the mechanic's ability to
repair the parts. The facility employed strong organic solvents such as
methylene chloride and cresylic acid to remove the dirt and fuel, followed by an
aqueous rinse step to remove any remaining solvent and dirt. The company
produced waste solvents from the initial solvent cleaning step and solvent-laden
rinsewaters from the aqueous rinsing process. The waste solventIdirt mixture
was sent off-site for disposal. The contaminated rinsewaters were routed to the
facility's septic system which was ineffective in digesting the organic chemicals.
These chemicals were then discharged into the septic system soil absorption field
thereby contaminating soil and the shallow water table with methylene chloride
and cresylic acid. The contamination of water in the wellhead area will create
a significant risk to those who consume the ground water if the releases
continue or if a cleanup of the contaminated soil and ground water is not
performed. The cost of contamination removal will be extensive.
The company could employ an in-line heated aqueous cleaning system
to clean the injectors before repair, replacing the solvent cleaning process
involving the organic chemicals. The in-line system cleans the pans with an
aqueous cleaner, then follows with a water rinse. This cleaning system reuses
the aqueous cleaning solution. The system also uses rinsewaters to replenish
the evaporative losses from the cleaning tank, instead of wasting them by
discharge to the septic system. The cleaning system requires a hot gas drying
step after the cleaning process. When replacing the spent cleaning solution, the
vendor maintains the cleaning system by removing the accumulated sludge. The
sludge then is disposed by the vendor as a hazardous waste. This practice
eliminates any discharge to the septic system from the initial cleaning operation.
This waste minimization practice prevents further contamination of the ground
water underlying the facility's septic discharge area. In addition, the sludge is
less dangerous and a smaller quantity than the waste solvents that were
drummed and sent off-site for disposal in the previous practice. If the facility
had used the aqueous cleaning system throughout its life, the initial
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contamination of ground water could have been avoided. Because solvent
discharge to the septic system is stopped, ground-water contamination is
eliminated and health risks to the community are reduced. Additional cost
savings result from eliminated solvent purchase and disposal despite the cost of
the new cleaning system and the drying step. The payback period for the change
is estimated at five years. (Office of Safe Waste Management, Massachusetts,
October 23, 1986)
(2) Recycling. Recycling involves the use, reuse, or reclamation of a hazardous waste as
an effective substitute for a commercial product or as an ingredient or feedstock.
This use, reuse, or reclamation can occur on-site, or it can be done by off-site
recycling services or waste exchanges. Examples of recycling include using a small
on-site still to recover degreasing solvents or selling waste pickling acids as
feedstocks for fertilizer manufacturing.
Example: A facility in Corvallis, Oregon deposits chrome onto the surface of
parts with electroplating. The electroplating process employs a series of tanks
into which the parts are submerged to deposit the chromium onto the part
surfaces (process tanks), and to rinse the excess chromium from the surfaces
(rinse tanks). The facility generated an estimated 1,000 gallons per year of
waste rinsewater from the plating process, with chromium as the hazardous
constituent. There was no attempt to prevent the loss of chromium to the
rinsewaters. The chromium rinsewaters were disposed into a dry well on-site
resulting in the chromium contamination of approximately 350 tons of soil and
2.4 million gallons of ground water. Approximately $2.5 million will be
required to clean up the contaminated soil and ground water.
The company could employ a closed-loop evaporation system to
recover the chromium from the rinsewater (USEPA, March 1989). The system
increases the chromium concentration in the rinsewater effluent by driving off
the water. The concentrated rinsewater solution then is returned to the original
plating bath, thus conserving chromium, and no longer generating the
chromium-bearing rinsewaters. This waste minimization practice prevents
further contamination of the ground water underlying the facility. If the facility
had used this waste minimization practice throughout its life, the initial
contamination of ground water could have been avoided. Additional cost
savings result from chromium conservation (chromium usage is reduced by
more than 97percent). The chromium raw material cost savings alone ensure
a payback period of less than one year for the waste minimization project.
(3) Treatment. Treatment, the least preferred pollution prevention technique, involves
processing the hazardous waste after it is produced to reduce its toxicity or volume.
Waste toxicity can be reduced by destroying certain chemicals the waste contains,
such as volatile organics. Volume reductions may be accomplished by filtering or
drying a waste to reduce its water content. Because treatment still involves the
production of the hazardous waste, source reduction and recycling are preferable
pollution prevention techniques.
Example: A Wausau, Wisconsin facility provides printing and graphic
reproduction services. The facility uses inks and solvents in the development of
the printing and graphics products. Solvents for ink formulation and equipment
cleaning includeperchloroethylene; trichloroethylene; 1,2, trans-dichloroethylene;
toluene; and xylene. Most of the wastes were generated by two unit operations:
(1) residual and unused ink mixtures from the graphics production group, and
(2) solvent wastes from the equipment cleaning operations. Because of the
organic chemicals contained in these wastes, they are a mixture ofRCRA listed
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hazardous wastes. Both the residual and unused inks and the spent cleaning
solvents were disposed in a manner that resulted in ground-water
contamination. The practice resulted in ground-water contamination by
perchloroethylene (100 ppb), trichloroethylene (100 ppb), 1,2,-trans-
dichloroethylene (339 ppb), toluene (concentration unspecified), and xylene
(concentration unspecified). Three high-yield production wells were
contaminated causing a drinking water health threat. The contamination
cleanup expense included cost of a granular activated carbon adsorber to treat
the contaminated ground water, in addition to the labor cost to install, operate,
and maintain the treatment operation.
The company could employ the following techniques in order to reduce
the amount of hazardous wastes produced in the printing process: (1) filtration
and reuse of waste inks for house colors, and (2) distillation of the solvents
from the cleaning process for reuse. The inks are reused in various products
which do not require exact matching of colors (Campbell and Glenn, 1982 and
San Diego Department of Health Services, 1987). This practice reduces to a
large degree the waste and unused inks disposed with the solvent wastes. The
distillation of the cleaning solvents allows reuse of these recycled solvents for
ink preparation and cleaning purposes, which eliminates the bulk disposal of
used inks and organic solvents. The onfy material requiring disposal is the
sludge that forms in the distillation unit. The sludge resulting from the
distillation process is sent off-site for disposal. The waste minimization
practices prevent further contamination of the ground water by reusing inks and
recycling solvents. Direct cost savings result from lowered ink and solvent
purchase and reduced waste and sludge disposal costs. The payback period for
the change is about one year.
4.3 Analysis and Discussion
Management controls and waste minimization techniques often require careful
planning, creative problem solving, changes in perspective regarding material handling, and
some capital investment. Nonetheless, in addition to protecting Wellhead Protection Areas,
light industries have adopted such practices to save money through more efficient use of
valuable resources, reduced regulatory compliance costs, and reduced waste treatment disposal
costs. Other, less tangible benefits to light industry from such practices include reduced
financial liabilities (the less waste generated, the lower the potential for cleanup and third-
party compensation due to environmental releases) and enhanced image in the community
(local residents respond favorably to environmentally responsible behavior by industry).
Industry groups and local governments can and do play a major role in promoting
management controls and waste minimization techniques by helping disseminate information
and transferring technology to light industry regarding management controls (e.g., through
training seminars, workshops, guidance materials). Also, local governments can develop
location and design standards in order to protect Wellhead Protection Areas. For example,
the citizens of Spokane, Washington formed a planning group to develop a strategy for
protecting their ground water and released a Water Quality Management Plan which includes
recommendations for controlling chemical spills and leaks through methods such as land use
and zoning regulations, development and enforcement of best management practices, and
public education.
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Chapter 3 of this document presents several other successful State and local
Wellhead Protection Programs. Most, if not all of these programs encourage and/or require
facilities within the Wellhead Protection Area to implement management controls and waste
minimization techniques. For example, part of the Cape Cod Planning and Economic
Development Commission plan that protects Wellhead Protection Areas involves "milk runs"
to many of the smaller, largely conditionally exempt, generators in the area in order to pick
up wastes produced. Aggregating these waste quantities secures a more reasonable disposal
rate. Without this practice, the generators, which are not otherwise required to dispose of
the waste in any particular fashion, could begin discharging wastes into sewer lines or with
regular solid waste.
In sum, management controls are being applied by light industries in many
jurisdictions as an effective part of Wellhead Protection Programs. Furthermore, waste
minimization techniques that have been adopted by larger industries may also be incorporated
by light industry to better ensure long-term protection of Wellhead Protection Areas.
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5.0 Conclusions
This document has provided a broad overview of the potential impact of light
industrial activities on Wellhead Protection Areas. There are many wellhead areas already
defined throughout the United States and many more will be delineated in the next few years.
Although the precise number of light industries located within and in close proximity to
Wellhead Protection Areas is not known at this time, this document will assist Wellhead
Protection Program managers in identifying and controlling these sources of potential
contaminants. As the number of light industries continues to increase in this country and
more light industries become located in formerly rural and suburban areas, the potential
impact on Wellhead Protection Areas may also increase.
The limited data collection effort conducted to support this analysis indicates that
a broad array of light industry types have been associated with past ground-water
contamination incidents. Waste management and disposal activities are identified as the main
source of contamination, while production processes and raw material and product storage
are also a significant source of contaminant releases. A variety of contaminants are involved
in releases from light industries, with chlorinated solvents and metals identified as the most
prevalent constituents in ground water. However, the actual risk to human health and the
environment posed by light industries is unknown.
Among the issues involved in determining the actual threat to public health and the
environment from light industrial activity is an assessment of the extent of exposure to release
events. The extent of exposure to a population is a function of factors such as the number
of potential points of release, the volume of individual releases, the mobility of released
constituents in the environment, and the proximity of the exposed population to releases.
Light industrial activity in this country is extensive; therefore, there are many potential points
of release. Light industries also have the capability to release materials that are mobile in
the environment and toxic. Furthermore, because many of these light industries are located
in or near Wellhead Protection Areas, there is a high potential for exposure to releases
through drinking water supplies. What is largely unknown at this time is the volume and
frequency of likely releases from light industries. The data reported in this document
provide a limited overview of the topic, but this information is far from conclusive.
Nonetheless, based upon the information available to date, most releases from light
industries appear to be of small to moderate size, compared to those observed from larger
industries. Although this conclusion is very preliminary in nature and may change as more
information is gathered, the data suggest that the potential for small to medium-size releases
from the large number of light industries located in Wellhead Protection Areas may pose a
threat to populations relying on ground water for their drinking water supplies.
Several State and local governments have developed innovative approaches for
protecting Wellhead Protection Areas from these light industrial sources of contamination.
These approaches include aggressive source identification, zoning, other land use controls,
and education and technology transfer activities to encourage light industries to adopt
protective management controls. Several of the management controls and waste minimization
techniques that have been recommended by EPA and State and local authorities and adopted
by certain light industries are presented in Chapter 4. These management controls and waste
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minimization techniques can be adopted as an integral part of a Wellhead Protection
Program. As presented here, these management controls and waste minimization techniques
represent activities that have been or can be applied at light industrial facilities to limit the
threat of releases to ground water. These practices are described as guidance to illustrate
the types of activities that have been adopted by industry; however, they do not represent
techniques that can be applied in all instances or that may be appropriate for all light
industries. References that Wellhead Protection Program managers may use to identify
practices and techniques that may be appropriate for individual light industries are available
on request from EPA.
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6.0 References
The sources listed below were used to develop the discussions in chapters 1 through
4 of this document.
Althoff, W. R, Clearly, R.W., and Roux, P.H. 1981. Aquifer Decontamination for Volatile
Organics: A Case History. Ground Water. 19(5): 495-504.
American Chemical Society. July 1981. Survey of Laboratory Practices and Policies for
Employee Protection from Exposure to Chemicals.
American Chemical Society. September 28, 1982. Report from the CSC/CCPA/CEI Task
Force on RCRA on Clarification and Recordkeeping for Laboratory Waste Chemicals.
American Chemical Society. 1986. RCRA and Laboratories.
Boateng, K., Evers, P.C., Testa, S.M. 1984. Groundwater Contamination of Two Production
Wells: A Case History. Groundwater Monitoring Review. 4(2): 24-31.
California Department of Health Services. July, 1986. Alternative Technology for Recycling
and Treatment of Hazardous Wastes, Third Biennial Report.
Cantor, L.W., Knox, R.C., and Fairchild, D.M. 1988. Ground Water Quality Protection. Lewis
Publishers, Chelsea, MI, 562 pp.
Cape Cod Planning and Economic Development Commission. 1987. Cape Cod Regional
Hazardous Waste Management Plan for Small Quantity Generators. Prepared by SEA
Consultants, Cambridge, Massachusetts.
Central Connecticut Regional Planning Agency. February, 1981. Guide to Groundwater and
Aquifer Protection, Town of Burlington.
Clark, F.W. and Sanborn P.M. 1985. Evaluation of Contamination by Organics and Heavy
Metals in Soil and Bedrock Aquifer. Second Annual Eastern Regional Groundwater
Conference, Proceedings. July 16-18, 1985. pp. 529-542.
Connecticut Department of Environmental Protection. 1984. Protecting Connecticut's
Groundwater - A Guide to Groundwater Protection for Local Officials.
Conservation Law Foundation. 1984. Underground Petroleum Storage Tanks: Local
Regulation of A Groundwater Hazard (A Massachusetts Prototype).
Duffy, W.J., Moose, R., and Tomalavage, S.J. 1980. Contamination of Ground Water Supplies
by Trichloroethylene - Three Case Histories. Third Annual Madison Conference on Applied
Research Practice on Municipal and Industrial Waste, Proceedings. September 10-12, 1980.
pp. 187-200.
Elliot, R.W. 1985. Toluene Loss Investigation and Remedial Action of Two Geologically
Complex Industrial Sites in Eastern Nebraska. Petroleum Hydrocarbons and Organic
Chemicals in Ground Water - Prevention, Detection, and Restoration, Proceedings.
November 13-15, 1985. pp.374-396.
Environment Canada. March, 1987. Catalogue of Successful Hazardous Waste
Reduction/Recycling Projects. Prepared for Industrial Programs Branch, Conservation &
Protection by Energy Pathways Inc. and Pollution Probe Foundation.
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Environment Canada. January, 1984. Technical Manual - Waste Abatement, Reuse, Recycle
and Reduction Opportunities in Industry
Epstein, S., L. Brown, and C. Pope. 1982. Hazardous Waste in America. Sierra Club Press.
Freeze, R.A. and J.A. Cherry. 1979. Groundwater. Prentice-Hall, Inc. Englewood Cliffs, NJ.
Georgia Institute of Technology. April 1985. The Georgia Tech Hazardous Waste On-Site
Consultation Program: Approach and Results.
Illinois Environmental Protection Agency. January, 1988. A Primer Regarding Certain
Provisions of the Illinois Groundwater Protection Act.
Institute for Local Self-Reliance. (no date). Proven Profits from Pollution Prevention - Case
Studies in Resource Conservation and Waste Reduction.
James, R.B., Eisenberg, D.M., and Oliveri, A. 1984. Regulation of Underground Storage
Tanks in the San Francisco Bay Area. Seventh Annual Madison Waste Conferences Municipal
and Industrial Waste, Proceedings. September 11-12, 1984. pp.325-334.
Latsha, J.L. 1987. VOC Removal from Groundwater - A Case History. Water Pollution
Control Association of Pennsylvania Magazine. 20(5) :6-9.
Long Island Regional Planning Board. 1985. Nonpoint Source Management Handbook.
Hauppauge, New York.
Massachusetts Department of Environmental Management, Massachusetts Hazardous Waste
Source Conference Proceedings, October 17, 1984.
Massachusetts Department of Environmental Quality Engineering. July, 1987. The
Management of Toxic and Hazardous Materials in a Zone of Contribution on Cape Cod,
(Tara Gallagher, ed.).
Massachusetts Department of Environmental Quality Engineering. August, 1987. Pesticides
and Drinking Water, Responsibilities of Massachusetts Boards of Health.
Massachusetts Department of Environmental Quality Engineering. May, 1982. Groundwater
Quality and Protection - A Guide for Local Officials.
Massachusetts Department of Environmental Quality Engineering, (no date). Requirements
for Small Quantity and Very Small Quantity Generators of Hazardous Waste; Satellite
Accumulation of Hazardous Waste.
Massachusetts Department of Environmental Quality Engineering. February, 1988. Hazardous
Waste Fact Sheets for:
Vehicle Maintenance and Autobody Repair
Used Oil
Space Heaters (burning waste oil)
Underground Tanks Storing Waste Oil
Graphic Artists, Printers, and Photographers
Laboratories
Construction Companies
Furniture Manufacturers, Finishers, Refinishers, and Woodworkers
Drycleaners
Metal Finishers
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Boatyards and Marinas
Golf Courses
Small Engine Repair Shops
Massachusetts Special Water Commission on Water Supply. December 1986. Contamination
in Municipal Water Supplies.
National Water Well Association - 3rd National Symposium and Exposition on Aquifer
Restoration and Groundwater Monitoring, May 1983.
National Water Well Association - 4th National Symposium and Exposition on Aquifer
Restoration and Groundwater Monitoring, May 1984.
National Water Well Association - 6th National Symposium and Exposition on Aquifer
Restoration and Groundwater Monitoring, May 1986.
National Conference on Control of Hazardous Material Spills, Proceedings, Miami Beach,
FL, April 11-13, 1978.
National Conference on Control of Hazardous Material Spills, Proceedings, Louisville, KY,
May 13-15, 1980.
National Governors Association. June, 1988. State Hazardous Waste Minimization Programs.
Prepared by ICF Incorporated.
New York Department of Environmental Conservation. July, 1988. Regulations for Chemical
Bulk Storage.
New York Department of Environmental Conservation. August, 1983. Report of the Central
Southern Tier Groundwater Critical Recharge Area Project for Erwin, New York.
New York Department of Environmental Conservation. January 1983. Technology for the
Storage of Hazardous Liquids: A State of the Art Review.
New York State Environmental Facilities Corporation: Industrial Materials Recycling
Program Annual Report[s], New York State Environmental Facilities Corporation, 1982,
1983, 1984, 1985, 1986, 1987.
North Carolina Department of Natural Resources. May 1985. Profits of Pollution Prevention
- A Compendium of North Carolina Case Studies.
North Carolina Department of Natural Resources and Community Development, (no date).
Accomplishments of North Carolina Industries - Case summaries.
Office of Management and Budget. 1987. Standard Industrial Classification Manual.
Oliveria, D.P. and Sitar, N. 1985. Ground Water Contamination from Under Ground Solvent
Tanks, Santa Clara, California. Fifth National Symposium and Exposition on Aquifer
Restoration and Ground Water Monitoring, Proceedings. May 21-24, 1985. pp. 691-708.
Ontario Ministry of the Environment. June, 1983. Blueprint for Waste Management in
Ontario.
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Ontario Waste Management Corporation, (no date). Industrial Waste Audit and Reduction
Manual: Case Study 2 -- Steel Pickling.
Patrick, R., Ford, E. and Quarles, J. 1987. Groundwater Contamination in the United States.
University of Pennsylvania Press, Philadelphia, 513 pp.
Pima Association of Governments. May, 1988. Metropolitan Tucson Basin Water Quality and
Pollution Source Assessment (Draft).
Portland, Oregon. May, 1988. Columbia South Shore Hazardous Materials Containment
Facilities Design Handbook. (Also, local ordinance restricting certain high risk and hazardous
materials industry and activities.)
Pyles, D., Stimpson, K., Bowden, R., and Wu, B. 1985. Wausau Wisconsin: A Case Study of
an Immediate Removal Action to Secure and Investigate a Contaminated Water Supply.
Eighth Annual Madison Waste Conference on Municipal and Industrial Waste, Proceedings.
September 18-19, 1985. p. 509.
Quality of Ground Water Symposium - March, 1981: ed. by W. van Duijvenbooden, P.
Glasbergen (Elsevier Scientific Publishing Company, 1981)
Quince, J.R., Ohneck, R.J., and Vondrick, J.J. 1985. Response to an Environmental Incident
Affecting Ground Water. Fifth National Symposium and Exposition on Aquifer Restoration
and Ground Water Monitoring, Proceedings, May 21-24, 1985. pp. 598-608.
Roberts, J.R., Cherry, J.A., and Schwartz, F.W. 1982. A Case Study of a Chemical Spill:
Polychlorinated Biphenyls (PCBs): History, Distribution, and Surface Translocation. Water
Resources Research. 18:525-534.
Schenectady County Planning Commission, (no date). Groundwater Supply Source Protection,
A Guide for Localities in Upstate New York.
Southern California Association of Governments. May, 1985. Hazardous Waste Management
Plan for Small Quantity Generators: Final Report.
Southern Tier Central Regional Planning and Development Board. June 1985. Formal Report
of the Central Southern Tier Groundwater Critical Recharge Area Project.
Spokane Water Quality Management Program coordination Office and Technical Advisory
Committee. July 1986. Critical Materials Handbook.
Tacoma, Washington - Groundwater Protection Ordinance, May, 1988. Contains General
Guidance and Performance Standards for Underground and Aboveground Tanks and for Spill
Prevention and Management.
Tennessee Department of Economic and Community Development, August 1986(a).
Hazardous Waste Management Assistance: Electroplaters.
Tennessee Department of Economic and Community Development, August 1986(b).
Hazardous Waste Management Assistance: Paper Products Manufactures.
Tennessee Department of Economic and Community Development, August 1986(c).
Hazardous Waste Management Assistance: Printers and Publishers.
Tennessee Department of Economic and Community Development, August 1986(d).
Hazardous Waste Management Assistance: Dry Cleaners.
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Tennessee Department of Economic and Community Development, August 1986(e).
Hazardous Waste Management Assistance: Automobile Body Repair and Paint Shops.
Tennessee Department of Economic and Community Development. August 1986 (f).
Hazardous Waste Management Assistance: Furniture Fabricators.
University of Tennessee, Energy, Environment and Resource Center. Measures to Promote
the Reduction and Recycling of Hazardous Wastes in Tennessee.
U.S. Department of Commerce. 1985. Census of Manufacturers.
U.S. Environmental Protection Agency/Office of Water Program Operations. October, 1980.
Design Manual: Onsite Wastewater Treatment and Disposal Manual. EPA 625/1-80-012.
U.S. Environmental Protection Agency/Office of Drinking Water. October, 1983. Sanitary
Survey Training.
U.S. Environmental Protection Agency/Office of Solid Waste. April, 1984. Assessment of
Hazardous Waste Mismanagement Damage Case Histories.
U.S. Environmental Protection Agency. 1985. Protection of Public Water Supplies from
Ground-Water Contamination. U.S. EPA Technology Transfer Publication. EPA/625/4-
85/016.
U.S. Environmental Protection Agency. February, 1985. National Small Quantity Hazardous
Waste Generator Survey.
U.S. Environmental Protection Agency/Office of Solid Waste. July, 1985. Regulatory Impact
Analysis: Proposed Standards for the Management of Used Oil.
U.S. Environmental Protection Agency/Office of Ground-Water Protection. July, 1985. Septic
Systems and Ground-Water Protection: A Program Manager's Guide and Reference Book.
U.S. Environmental Protection Agency. August, 1985. The Scrap Metal Recycling Industry.
U.S. Environmental Protection Agency/Office of Solid Waste. January, 1986. Analysis of the
Combined Impact of Various EPA Regulatory Initiatives on Generators of 100-1000 Kg/Mo.
U.S. Environmental Protection Agency/Office of Solid Waste. October, 1986. Report to
Congress: Waste Minimization Issues and Options, Volume II.
U.S. Environmental Protection Agency/Office of Ground-Water Protection. 1987. An
Annotated Bibliography of Wellhead Protection References, EPA 440/6-87-014.
U.S. Environmental Protection Agency/OSW. February, 1987. Characterization of Releases
from Non-Subtitle C Technologies.
U.S. Environmental Protection Agency Region III, Philadelphia, PA. April, 1987. Hazardous
Waste Minimization Manual for Small Quantity Generators in Pennsylvania.
U.S. Environmental Protection Agency/Office of Solid Waste and Emergency Response.
October 1987. Waste Minimization: Environmental Quality and Economic Benefits. EPA/530-
SW-87-026.
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U.S. Environmental Protection Agency Water Engineering Research Laboratory. March, 1988.
Information for Wellhead Protection Managers on the Potential Impacts of Selected Sources
of Groundwater Contamination with Emphasis on Activities Associated with Agricultural
Irrigation and Light Industrial Parks (Draft).
U.S. Environmental Protection Agency/Office of Ground-Water Protection. April 1989.
Wellhead Protection Programs: Tools for Local Government.
U.S. Office of Technology Assessment. October, 1984. Protecting the Nation's Groundwater
from Contamination (Vols. I and II).
Vermont Department of Environmental Protection. 1984. An Ounce of Prevention -A
Ground Water Protection Handbook for Local Officials.
Virginia Water Resources Center (Margaret Hrezo & Pat Nickinson, eds). Nov., 1986.
Protecting Virginia's Groundwater: A Handbook for Local Government Officials.
Washington Department of Ecology. December 1986. Ground Water Resource Protection -
A Handbook for Local Planners and Decision Makers in Washington State. Prepared by King
County Resource Planning.
Winegardner, D.L., Erickson, M. and Quince, J.R. 1985. Aquifer Restoration: Case Histories.
Fifth National Symposium and Exposition on Aquifer Restoration and Ground Water
Monitoring, Proceedings. May 21-24, 1988. pp. 611-626.
Winegardner, D.L. and Quince, J.R. 1984. Ground Water Restoration Projects: Five Case
Histories. Fourth National Symposium and Exposition on Aquifer Restoration and Ground
Water Monitoring, Proceedings. May 23-25, 1984. pp. 386-393.
Wisconsin Geological & Natural History Survey. September, 1985. Ground Water Protection
Principles and Alternatives for Rock County, Wisconsin.
Wisconsin Geological & Natural History Survey (Born, et. al.). 1988. Wellhead Protection
Districts in Wisconsin: An Analysis and Test Application.
Yoder, Douglas. Protection of Wellfields and Recharge Areas in Dade County, Florida, pp.
183-198.
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