'A/570/9-91/014
'ates
lental Protection
Office Of Water
(WH-550G)
570/9-91-014
December 1991
lide For Conducting
Contaminant Source Inventories
For Public Drinking Water
Supplies
Technical Assistance Document
-'.-''i* •.•?-!»•* JU
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GUIDE FOR CONDUCTING
CONTAMINANT SOURCE INVENTORIES FOR
PUBLIC DRINKING WATER SUPPLIES:
TECHNICAL ASSISTANCE DOCUMENT
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GUIDE FOR CONDUCTING
CONTAMINANT SOURCE INVENTORIES FOR
PUBLIC DRINKING WATER SUPPLIES:
TECHNICAL ASSISTANCE DOCUMENT
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ACKNOWLEDGEMENTS
This document was prepared for the Environmental Protection Agency, Office of
Ground Water and Drinking Water under contract No. 68-CO-0083. Kevin
McCormack served as Task Manager for this project, with assistance from Janette
Hansen and Dr. Norhert Dee.
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TABLE OF CONTENTS
EXECUTIVE SUMMARY i
1.0 INTRODUCTION 1
1.1 Overview of this Document I
1.2 Definition of Contaminant Source Inventory and a
Description of the Process 1
1.3 Other Federal Requirements tor Source Inventories 3
1.4 Purpose of This Technical Assistance Document 4
1.5 Organization of this TAD 4
1.6 Additional Information on Wellhead Protection 4
1.7 Additional Information on Source Inventories 5
2.0 GROUND-WATER CONTAMINATION SOURCES OF CONCERN 7
2.1 Review of Contamination Sources of Concern 7
2.2 Prioritizing Risks 10
3.0 DESIGN OF SOURCE INVENTORY PROGRAMS 11
3.1 Characterizing the Area's Needs 11
3.2 Establishing Clear and Attainable Goals 11
3.3 Administering the Program Efficiently 11
3.4 Allocating Sufficient Resources 11
4.0 SOURCE IDENTIFICATION METHODS 13
4.1 Existing Data Sources 13
4.2 Surveys 20
4.3 Field Studies 29
5.0 IMPLEMENTING METHODS FOR SOURCE IDENTIFICATION 33
5.1 Consult Existing Sources of Information 33
5.2 Share Information with Other WHP Elements and Tools 33
5.3 Compile a List of Sources 33
5.4 Access Unknown Sources 34
5'.5 Modify a Program to Support Individual Community Needs 34
6.0 DATA MANAGEMENT 37
6.1 Why Do You Need It and What Do You Do With It? 37
6.2 Current Approaches to Data Base Management 37
6.3 Maintaining CIS and Data Bases 41
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TABLE OF CONTENTS (continued)
Page
7.0 USING THE INVENTORY TO PROTECT WATER SUPPLIES 43
7.1 Priority Setting 43
7.2 New Zoning and Health Regulations 44
7.3 Developing a Pollution Prevention Program 45
8.0 SUMMARY ' 49
9.0 CASE STUDY REFERENCES 51
.APPENDIX A BIBLIOGRAPHY A-1
APPENDIX B CASE STUDIES : B-l
APPENDIX C REGULATORY DATA BASES C-l
APPENDIX D STATE AND U.S. INSULAR AREA
WELLHEAD PROTECTION AGENCIES D-l
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Page i
EXECUTIVE SUMMARY
This Technical Assistance Document (TAD) assists state and local water managers in
developing and refining methods and procedures for inventorying existing and potential sources or
contamination within Wellhead Protection Areas. The Source Inventory Process is an integral
part of EPA's Wellhead Protection (WHP) Program, established under the 1986 Amendments to
the Safe Drinking Water Act. The Wellhead Protection Program was developed primarily to
protect the ground waters that supply wells and wellfields that contribute drinking water to public
water supply systems. The basic purposes of the program are to recognize and address the
essential need to protect ground-water drinking water supplies, and to meet the goals of the Sate
Drinking Water Act.
The program uses a combined approach that allows state and local water managers to take
into account the individual needs of their public water supply systems, in particular the diverse
nature of hydrogeologic settings and the nature and extent of potential sources of contamination
that may threaten municipal drinking water supplies. In addition, development of a Wellhead
Protection Program at the State and local level preserves the right of these entities to determine
how matters of land use and water allocations arc best resolved for individual locations.
The vulnerability of ground-water supplies to existing or potential sources of
contamination within wellhead protection areas underscores the need for a systematic, detailed
process by which these potential threats can be inventoried. The use of a comprehensive,
detailed inventory allows the water manager to prioritize these sources according to the level of
risk to public drinking water supplies, and to develop differential management strategies to deal
with these sources, thereby safeguarding the public health.
This Technical Assistance Document discusses the design, structure, and function of
contaminant source inventories. Within this document you will find detailed discussions of
contaminant sources of concern and methodologies for identifying these sources. You will also
find suggestions on how to manage the information collected on these sources, and how to use
this information to protect public drinking water supplies. Throughout the document are actual
case studies of contaminant source inventories, which are excellent examples of wellhead
protection in action.
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Page 1
1.0 INTRODUCTION
1.1 Overview of this Document
This document is one in a continuing series of Technical Assistance Documents prepared
by the Ground-Water Protection Division, Office of Ground Water and Drinking Water of the
U.S. Environmental Protection Agency. This TAD discusses the process by which State and local
water managers can develop and implement methods and procedures for inventorying existing and
potential sources of ground-water contamination within wellhead protection areas (WHPA). A
WHPA is a defined area surrounding or immediately adjacent to a well or wellfield from which
public drinking water supplies are drawn, and through which contaminants may be expected to
move, potentially endangering the drinking water supply from that well.
EPA prepared this document as part of its ongoing effort to assist State and local
governments in developing Wellhead Protection (WHP) Programs. WHP programs have six
major elements: (1) designation of roles and duties of State and local agencies; (2) delineation of
WHPAs; (3) identification of contaminant sources within WHPAs; (4) development of
management approaches for the WHPA; (5) preparation of contingency plans for replacement
water supplies, and (6) siting of new wells to maximize yield and minimize potential
contamination. In addition, WHP programs must include a statement of purpose and a
mechanism by which the public participates in the development of the program. This document
focuses specifically on element (3) above, thd identification of contaminant sources within
wellhead protection areas.
1.2 Definition of Contaminant Source Inventory and a Description of the Process
Simply put, identifying and inventorying contaminant sources within WHPAs involves a
process of recording existing data, describing sources within the WHPA, targeting likely sources
for further investigation, collecting and interpreting new information on existing or potential
sources through surveys, and verifying accuracy and reliability of the information gathered.
Depending on the availability of resources and the level of information desired on
contaminant sources, the State or local water manager can develop a source inventory process
ranging in detail from very elementary to quite complex. Source inventory procedures submitted
to EPA in the past as part of WHP programs have ranged from simple lists of potential
contaminant sources or activities compiled from telephone directories and paper files, to revision
of old maps and creation of new and sophisticated map overlays utilizing specific data elements
(e.g., latitude/longitude) from multiple computer data bases. Whatever the level of detail
selected, the source inventory process should incorporate the basic steps in gathering and
interpreting information as outlined below.
1.2.1 Recording Existing Data
In most municipalities, a substantial amount of information on existing or potential
contaminant sources exists in the form of routine records or documents recorded or assembled in
the day-to-day operation of local government. Included in these are federal, state, and local data
bases, either computerized or manual, dealing with commercial operating, discharge, and disposal
permits, construction permits, zoning records, real estate title searches, health department records,
aerial photographs, telephone directories, and historical records. Examination of these records
relative to locations and activities within WHPAs allows the water manager to select existing or
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Page 2
potential sources of contamination within the WHPA, and assess the need for gathering additional
data.
1.2.2 Targeting Likely Sources Within the WHPA
The initial information-gathering phase of the source inventory process may have a
number of results in terms of documenting existing or potential sources. In some cases, all the
data or information necessary may be available during this first step to conclude that a source of
activity is or will be a significant contamination problem for a nearby public water supply well or
wellfield. In this case, the source or activity can be immediately prioritized for special attention
by the water manager.
In most cases, however, it is likely that existing data or information will simply indicate
that the source or activities may be (or may become) a problem. In these instances, it is
important for the water manager to identify the specific information necessary to provide an
adequate assessment of how significant the problem is or may become. This information can
include such data as discharge rates to ground or surface water from permitted facilities, climatic
or seasonal influences on operations or activities, and hydrogeologic settings. Once these
parameters are identified, the process of filling in the information gaps can be developed.
1.2.3 Collecting und Interpreting New Information
Data gaps and information needs can exist for individual contaminant sources within
WHPAs, or for the entire WHPA as a discreet ground-water management unit. After the
additional information needed for either is identified, the most comprehensive means of securing
it is usually by a survey of some type. Surveys include mail questionnaires, door-to-door
canvassing of neighborhoods, voting districts, or city and town limits, windshield surveys involving
visual identification or verification of sources or locations, and personal interviews with individuals
selected at random or chosen because of firsthand knowledge of an activity or occupation (e.g.,
factory workers involved in handling and disposal of wastes from manufacturing plants).
These surveys can be as simple as having volunteer groups such as Boy or Girl Scout
troops or senior citizens conduct "walking tour" type surveys, where any and all existing or
potential threats to WHPAs are recorded, either by category or individually. Alternatively, the
survey may involve a pre-selected cross section of individuals engaged in or having knowledge of
particular occupations or activities, with each of these persons interviewed individually and in
detail. Telephone surveys can also be productive, particularly with proper advance notice to the
public through the local news media.
Interpretation of newly-collected information from surveys is an important component of
any source inventory project, and should involve some type of hazard ranking system relative to
ground-water contamination and subsequent impact on public drinking water supplies. For
example, medium to low-level threats from seasonal or climatic occurrences would clearly not
present the same level of potential contamination of public drinking water supplies as an
abandoned, uncovered chemical drum disposal site. By accurately inventorying existing and
potential contaminant sources within the WHPA, and correctly interpreting the probability or
likelihood of ground-water contamination associated with the source or activity, the local water
manager can properly prioritize and develop management strategies to deal with these sources in
a timelv and efficient manner.
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1.2.4 Verifying Accuracy of Information Gathered
The best way to assure accuracy of information gathered during contaminant source
inventories is to "ground truth," or field check the assembled data. In the case of aerial
photographs of early or unknown vintage, updating photo files is an accurate (but costly) option.
Follow-up telephone confirmation is inexpensive, and can be used to verify mail survey
questionnaire information. Telephone confirmation also can be useful where access to a property
or facility is denied (e.g., purposes of national security), or where the facility or activity is
unmanned (e.g., remote oil well pumping stations). Information gathered by personal interview
can also be verified by actual site visit.
A vital and continuing function of the WHPA source inventory process is the refinement,
expansion, and updating of information gathered during the initial inventory. These periodic
checks assure that the information gathered is kept current and accurate, and are usually
performed on a scheduled basis, anywhere from every 6 months to 2 years. While permitting
provisions of State and local governments automatically add new activities or locations to the
inventory list (fuel storage tanks, etc.), periodic checking is necessary to modify, reprioritize, or
delete existing and older sources identified early on in the process.
U Other Federal Requirements for Source Inventories
In addition to the Wellhead Protection Program, there are other federal requirements for
the maintenance and updating of contaminant source inventories. For example, owners and
operators of all underground injection wells are required by rule (40 CFR 144.26) to submit
contaminant source inventory information to EPA. For permitted underground injection wells,
the location of the well must be reported as a.potential contaminant source under 40 CFR 144.31.
Another important Federal statute, the Emergency Planning and Community Right-to-
Know Act of 1986, enacted as Title III of the Supeffund Amendments and Reauthorization Act
(SARA), requires the inventory of potential contaminant sources as a part of an overall response
mechanism for releases of hazardous chemicals. Title III establishes a network of State
Emergency Response Commissions (SERCs) and Local Emergency Planning Committees
(LEPCs) charged with planning for responses to such releases. Title III requires extensive public
reporting by industrial facilities concerning the nature, presence, quantity, and management of
hazardous chemicals. Title III complements the SDWA contaminant source inventory
requirements for public water supplies in several important ways:
• The "community right-to-know" reporting (Section 311 and 312) and toxic
release inventory (Section 313) requirements of Title III provide a valuable
source of information concerning potential contamination threats to
ground-water supplies; and
• Public interest and participation generated by Title III implementation
efforts should provide a strong foundation for similar public involvement in
ground-water protection and planning efforts, particularly voluntary
participation in WHPA contaminant source inventory at the local level.
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1.4 Purpose of This Technical Assistance Document
This TAD will assist state and local water managers with responsibilities for public
drinking water supply systems in designing and conducting contaminant source inventories within
WHPAs. Through the development of selective differential management -techniques and
procedures, the TAD will also assist States and local communities in satisfying the WHP Program
requirements under the 1986 SDWA Amendments, as well as SARA Title III requirements and
the monitoring and vulnerability assessment activities required of Public Water Supply Systems
(PWSSs).
In addition, this TAD is designed for use primarily by smaller communities that lack
extensive planning or technical resources, with the belief that larger communities will have the -
resources necessary to develop contaminant source inventory plans specialized for their own
particular needs. The TAD does not provide a specific planning recipe that must be followed to
ensure success. Instead, it suggests a number of planning alternatives and possibilities to states
and local communities under a structured process, whereby resources and capabilities available to
the community can target those options most appropriate to local needs and conditions.
1.5 Organization of this TAD
This TAD is divided into eight sections. After the Introduction (Section 1.0), Section 2.0
reviews selected sources of ground-water contamination, and discusses the application of Risk
Ranking Systems to source categories. Section 3.0 describes the design of the source inventory
process. Section 4.0 outlines source identification methods, including accessing existing data, types
of surveys, and Held studies. Section 5.0 presents a process for implementing source identification
methods. Section 6.0 outlines Data Management needs, exploring manual and computerized
systems, Geographic Information Systems (GIS), and the maintenance of both conventional and
CIS systems. Section 7.0 discusses the use'of contaminant source inventories in the protection of
public water supplies. Section 8.0 summarizes information presented in the TAD, with some
suggestions for beginning the source inventory process at the local level. Section 9.0 provides
references to case studies used throughout the document. The Appendices follow with a
bibliography, case studies, a description of regulatory data bases, and a listing of State reports and
contacts.
1.6 Additional Information on Wellhead Protection
In response to the 19S6 SDWA Amendments, EPA's Ground-Water Protection Division,
Office of Ground-Water and Drinking Water, has developed several TADs in addition to this
document for states and local governments interested in developing Wellhead Protection
Programs:
• Managing Contamination Sources in Wellhead Protection Areas: A
Priority Setting Approach (January 1992)
• "Why Do Wellhead Protection?" Issues and Answers in Protecting
Public Drinking Water Supply Systems (November 1991)
• Protecting Local Ground-Water Supplies Through Wellhead Protection
(May 1991)
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• Guide to Ground-Water Supply Contingency Planning for Local and State
Governments (May 1990)
• A Review of Sources of Ground-Water Contamination From Light
Industry (May 1990)
• Local Financing for Wellhead Protection (June 1989)
• Wellhead Protection Programs: Tools for Local Governments (April 1989)
• Developing a State Wellhead Protection Program: A User's Guide to
Assist State Agencies Under the Safe Drinking Water Act (July 1988)
• Model Assessments for Delineating Wellhead Protection Areas (May 1988)
• State Wellhead Protection Program Question and Answer Fact Sheet
(June 1987)
• Guidelines for the Delineation of Wellhead Protection Areas (1987)
• Guidance for Applicants for State Wellhead Protection Program Assistance
Funds Under the Safe Drinking Water Act (June 1987)
• Wellhead Protection: A Decision Maker's Guide (May 1987)
EPA also has developed a simplified computer model, the WHPA code, that can he used
to delineate local WHPA's. Copies of this model and the documents referenced above can be
obtained from Regional EPA Ground Water offices.
1.7 Additional Information on Source Inventories
Cross, Brad L., 1991, A ground water protection strategy: The city of El Paso: Texas Water
Commission Report 91-01, 200 pp.
Cross, Brad L., et al., 1991, A ground water protection strategy: The city of Houston: Texas
Water Commission Report. 225 pp.
Cross, Brad L, 1991, A guide to local ground water protection: Texas Water Commission
Unnumbered Report, 25 pp.
Texas Water Commission, et al., 1989. Texas wellhead protection program: Texas Water
Commission Report, 123 pp.
Texas Water Commission, 1990, If your public water supply depends on ground water - consider
establishing a wellhead protection area: Texas Water Commission Publication C88-04.
Texas Water Commission, 1991, Recruiting volunteers for ground water protection programs:
Texas Water Commission Publication.
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Texas Water Commission, 1991, WHPDATE - A quarterly newsletter published by the Texas
Water Commission.
The documents listed above can be acquired through the following address:
Texas Water Commission
P.O. Box 13087
Austin, Texas 78711-3087
ATT: Library
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2.0 GROUND-WATER CONTAMINATION SOURCES OF CONCERN
Before a source identification process can begin, water managers should review the field
of potential sources of concern. This can best be achieved by reviewing a comprehensive list of
sources of concern, matching those that apply to specific WHPAs. Once water managers have
identitied the potential threats to their water supply, they will need to prioritize those threats by
ranking the risks associated with each source.
2.1 Review of Contamination Sources of Concern
Various government agencies and organizations have developed lists that identify a wide
variety of potential sources of ground-water contamination. The sources included in these lists
are based primarily on land-uses or activities that occur within WHPAs. The vast majority of the
potential sources of contamination identified in these lists relate to industrial, manufacturing, or
commercial activities that involve the handling or disposal of contaminants that can degrade
ground-water quality.
The Office of Technology Assessment (OTA) has developed a comprehensive and often
cited list of potential sources of contamination. This list classifies different types of potential
sources of contamination into major categories, based on the general nature of the contaminants
that could be released to the ground water. Another list, based on this OTA list, is organized by
an alphabetical listing of sources. Both of these lists are provided in Exhibits 2-1 and 2-2.
These lists, like many others, are not exhaustive collections of sources of contamination.
Local WHPA managers may recognize some activities as sources of concern that were excluded
from a particular list. Likewise, not every source that is identified on the attached lists will be a
concern to every WHPA manager. For a discussion of another categorization of sources of
contamination, see the EPA Office of Ground-Water Protection's A Review of Sources of
Ground-Water Contamination from Light Industry -- Technical Assistance Document. Local
water managers may wish to contact state ground-water or drinking water officials to discuss the
most appropriate universe of sources to consider for their source identification survey.
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Exhibit 2-1: Sources of Ground-Water Contamination
I. Sources Designed to
Discharge Substances
II. Sources Designed to
Store, Treat, and/or
Dispose of Substances;
Discharges through
Unplanned Release
III. Sources Designed to
Retain Substances
During Transport or
Transmission
Subsurface percolation
Septic tanks
Cesspools
Injection wells
Hazardous waste
Non-hazardous waste
(brine disposal and
drainage)
Non-waste (enhanced
recovery, artificial recharge
solution mining and in-situ
mining)
I^ind application
Wastewater (spray
irrigation)
Wastewater byproducts
(sludge)
Hazardous waste
Non-hazardous waste
Landfills
Industrial hazardous and
non-hazardous waste
Municipal Sanitary
Open dumps
Surface impoundments
Hazardous &
nonhazardous
Waste tailings & piles
Hazardous &
nonhazardous
Materials stockpiles
Non-waste
Animal burial
Under and Aboveground storage
tanks
Hazardous, nonhazardous
and non- waste
Containers
Hazardous, nonhazardous
and non- waste
Open burning sites
Detonation sites
Radioactive disposal sites
Pipelines
Hazardous, nonhazardous
and non-waste
Materials transport and
transfer operations
Hazardous,
nonhazardous, non-waste
IV. Sources Discharging
Substances as a
Consequence of Other
Planned Activities
V. Sources Providing
Conduit or Inducing
Discharge through
Altered Flow Patterns
VI. Naturally Occurring
Sources whose
discharge is created
and/or exacerbated by
Human Activity
Irrigation practice
Applications
Pesticide
Fertilizer
De-icing salts
Animal feed operations
Urban run-off
Percolation of atmospheric
pollutants
Mining and mine drainings
Surface mine-related
Underground mine-related
Production wells
Oil and gas
Geothermal and heat
recovery
Water supply
Other wells
Monitoring
Exploration
Construction excavation
Ground and surface water
interactions
Natural leaching
Source: U.S. Office of
Technology Assessment,
Protecting the Nation's
Groundwater from
Contamination, October 1984.
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Exhibit 2-2: Sources of Ground-Water Contamination
Sources of Contamination
Aboveground storage tanks:
hazardous and non-hazardous waste treatment
hazardous and non-hazardous waste storage
hazardous and non-hazardous material storage
Animal feedlots
Containers:
hazardous and non-hazardous waste storage
hazardous and non-hazardous material storage
Deep injection wells:
wastewater disposal wells
oil and gas activity disposal wells
mineral extraction disposal wells
De-icing salts storage piles
Fertilizer applications
Graveyards
Ground water/surface water cross contamination
Irrigation practices (return How)
Land application:
wastewater application (spray irrigation)
wastewater byproduct (sludge) application
petroleum refining waste application
hazardous and non-hazardous waste application
landfills:
industrial hazardous and non-hazardous landfill
municipal sanitary landfill
Material transter operations:
hazardous and non-hazardous waste transfers
hazardous and non-hazardous material
transfers
Materials stockpiles:
hazardous and non-hazardous material
Mining and mine drainage
Natural leaching
Open dumps
Pesticide applications
Pipelines:
hazardous and non-hazardous waste (sewers)
hazardous and non-hazardous material
Radioactive disposal sites
Salt-water intrusion
Septic tanks:
houses
apartments
small businesses
Shallow injection wells:
agricultural drainage wells
automobile service station disposal wells
industrial process water disposal wells
Storm water drainage wells
Surface impoundments.
hazardous and non-hazardous waste cesspools,
ponds, lagtxms, and other impoundments
Transportation ot materials:
hazardous and non-hazardous waste
hazardous and non-hazardous material
Underground storage tanks
hazardous and non-ha/ardous waste treatment
hazardous and non-hazardous waste storage
hazardous and non-ha/ardous material storage
Urban runolt
Waste tailings:
heap leaching piles
non-heap leaching piles
Waste piles:
hazardous and non-hazardous waste piles
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2.2 Prioritizing Risks
Once a community has identified the potential threats to its water supply, there is usually
a need to prioritize those threats. A number of governmental agencies and other organizations
have developed risk ranking systems that allow WHPA managers to assess the risks posed by
potential sources of contamination within a WHPA.
EPA's Office of Ground-Water Protection has developed a ranking system for Wellhead
Protection Areas entitled. Managing Contamination Sources in Wellhead Protection Areas: A
Priority Setting Approach. The system is designed in workbook format and is capable of the
following:
(1) Determining a risk score for each potential source of wellhead contamination;
(2) Ranking sources according to the level of risk associated with the source; and
(3) Determining the level of threat that a given source poses (high, medium, or low).
The system allows WHPA managers to conduct a simple screening of potential
contamination sources on the basis of risk, without having to conduct complicated risk
assessments. In this way, local managers will be able to target their efforts to provide maximum
environmental protection within specific budgets.
This ranking system will be available to local WHPA managers in January 1992. For more
information on the system, contact Janette Hansen at EPA's Office of Ground-Water Protection,
(202) 260-7077.
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3.0 DESIGN OF SOURCE INVENTORY PROGRAMS
In order to design an effective source inventory program, it is important to understand the
unique characteristics of the community. Local officials may conduct an initial area assessment to
identify the community's particular needs and the most effective and appropriate identification
techniques. At the same time, an effective program is dependent upon a carefully administered
process and clearly defined goals.
3.1 Characterizing the Area's Needs ,
Because most communities vary in size, composition, and location, it is important, as the
first step in designing a source identification program, to understand the unique needs of the
community. The most effective set of methods to use in conducting an inventory will depend
greatly on the particular characteristics and situation of the community involved. Specific
characteristics that may affect the choice of source inventory methods, include:
• Local Geography
• Community size
• Land use
• Resources
3.2 Establishing Clear and Attainable Goals
A community that intends to conduct an inventory of potential ground-water
contamination sources needs to formulate a clear statement of their purposes and goals in
initiating this process. These goals should he achievable given the community's resources, time,
and staff available. Once officials clarify the goals-of the inventory, they can select the source
identification methods that will fulfill these goals and are most appropriate to the community's
situation.
3.3 Administering the Program Efficiently
A successful inventory requires attention to many administrative details. Inventories
typically generate large amounts of data, which officials must collect, compile, and manage in an
organized manner. (For a discussion of data management, see Section 6.0.)
The staff responsible for conducting the inventory must be identified and trained. If
volunteers are to be used for portions of the inventory, other staff must be identified or recruited
to train them. It is particularly important that the inventory be well organized when volunteer
workers are used. Officials must communicate accurately and clearly their goals and instructions
on how to properly conduct the inventory to their staff. Failures in communicating instructions
are a prime cause of implementation failures.
3.4 Allocating Sufficient Resources
No matter how clear the instructions, however, if the personnel responsible for conducting
the inventory do not have the proper resources, the inventory is likely to be unsatisfactory.
Critical resources include adequate numbers and training of staff, clear and correct information on
how to carry out the inventory, the authority to properly conduct the inventory, and the necessary
equipment and facilities (inventory forms, cars, computers, etc.). The use of volunteers available
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from various public service organizations and activist groups such as the Boy Scouts, Lions Club,
and Retired Senior Volunteer Program (RSVP) should always be considered when resources are
a major issue in designing an effective source inventory program (see page 5, Section 1.7,
Additional Information on Source Inventories.)
Budgetary concerns are also important. As noted above, the selection of inventory
methods involves a consideration of the amount of resources available to conduct the inventory.
During the inventory process, the project will require oversight to be kept within budget. The
calculations of a source inventory budget must take into account the expenditure of resources
required to set up and maintain the inventory data management system, as well as to conduct the
inventory.
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4.0 SOURCE IDENTIFICATION METHODS
Many states and communities have already undertaken inventories to determine the actual
or potential sources of contamination within their WHPAs. As the following discussion reveals,
there are a variety of techniques that can he used to identify sources, either independently or in
conjunction with one or more other approaches. The technique(s) that is most appropriate for an
individual community will depend on site-specific factors, such as the size of the community, the
amount of resources that the community can expend on the inventory, the amount of information
that is readily available, and other considerations.
We present in this section discussions of some of the commonly used techniques:
• Existing Data Sources
• Surveys
• Field Studies
Incorporated within the discussions of the individual techniques, we have included
abbreviated examples of how the technique has been applied by a State or community; full case
studies that illustrate techniques in the context of a community program or in combination with
other techniques are included in Appendix B. Section 5.0 will discuss how a community can
implement a source identification program that is appropriate for local needs.
4.1 Existing Data Sources
The information compiled by government agencies can help wellhead managers identify
the materials managed by industrial and commercial facilities in a WHPA, as well as preliminary
information concerning material management practices. Regulatory agencies at the state and local
levels maintain a variety of information data bases to track permitted activities or facilities that fall
within their jurisdiction. These data bases range from computerized systems that identify the
location and materials handled at each permitted facility to a file drawer in the local health
official's office containing permits for septic system installation.
4.1.1 Regulatory Reporting Requirements
Various federal regulator,' programs require facilities that manage or dispose of specified
quantities of hazardous materials or wastes, petroleum or chemical products, and other materials
to file notifications and/or obtain permits for these activities. Notifications or permits will be filed
with the state or federal government, depending on which level of government has the lead
responsibility for the regulatory program. Once the reporting data has been collected, it often is
stored on electronic data bases. Facilities' owners or operators are required to notify regulatory
agencies of activities that are subject to the following programs, among others:
• Resource Conservation and Recovery Act (RCRA) Subtitle C - Generators
of more than 100 kg/month of hazardous waste must file a notification of
hazardous waste generation activities; some states also require notifications
from smaller volume generators under "small quantity generator" (SQG)
regulations. The notification contains a description of the facility location,
the generated wastes, and the primary waste material management practice.
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The siting and operation of facilities for the treatment, storage, and
disposal (TSD) of hazardous wastes also is subject to RCRA regulation.
The permit information for TSD facilities in some states is available
through an electronic data base and could be sorted by geographic location;
other States may have only "hard copy" files that will require the physical
review of extensive materials in order to identify the relevant information.
RCRA Subtitle I - Owners and operators of underground storage tanks
containing petroleum or chemical products are required to notify EPA or
the states of their activities. This notification consists of the location, age,
size, type, and use of the tank. .
Superfund Amendments and Reauthorization Act (SARA) Title III - The
"Emergency Planning and Community Right to Know Act of 1986" requires
the owner or operator of any facility to prepare a list of any "extremely
hazardous" substances on hand in amounts of 2 pounds or more. In
addition, certain releases of hazardous chemicals to the environment must
be reported.
Underground Injection Control - The UIC program requires a permit for
certain classes of injection wells. Injection wells allow the underground
disposal of fluid wastes through a drilled well. Injection wells are divided
into Class I, Class II, Class III, Class IV, and Class V wells. Perhaps the
most numerous and the most obscure, Class V wells that dispose wastes
above underground sources of drinking water pose a serious threat of
contaminating wellheads. Some types of Class V wells that EPA has
identified as having a high potential for contamination include automobile
service station waste disposal wells and industrial process water and waste
disposal wells. Automobile service station disposal wells are often wells
that collect dangerous or toxic wastes drained from service repair bays.
Industrial process water and waste disposal wells are used to dispose of a
variety of wastewaters from a number of industrial or commercial processes
including chemical plants, pharmaceutical plants, car washes, laundromats,
and dry cleaners.
National Pollution Discharge Elimination System - Under the Clean Water
Act, no discharge into any navigable water is allowed unless it has a
National Pollutant Discharge Elimination System (NPDES) Permit from
the EPA or the counterpart State Pollutant Discharge Elimination System
(SPDES). Some states also regulate discharges to ground water under this
program. The permits include information about the permit fee, effluent
units and monitoring requirements.
Spill Prevention Control and Countermeasure - Under Section 311 of the
Clean Water Act, Spill Prevention Control and Countermeasure (SPCC)
plans must be prepared by facilities that store bulk quantities of petroleum.
These regulations apply to facilities that store more than 42,(K)() gallons
below ground or 1320 gallons above ground (or a single above ground tank
in excess of 660 gallons).
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Page 15
In addition to these federal regulatory requirements, individual states may have developed
their own regulatory requirements that generate a wealth of information related to potential
sources of contamination.
4.1.2 Regulatory Data Bases
Once the reporting data has been collected, it often is transferred and stored on electronic
data bases. A summary of several federally maintained data bases is provided in Appendix C.
Existing data sources may be accessed through EPA offices. State environmental agencies,
or, in the case of the Title III data, through the State Emergency Planning Commission or
through the national Toxics Release Inventory (TRI). Because each of these data bases usually
contains information on the location of facilities, the data can be sorted to find those facilities
located within the WHPA.
Data bases are often large and complex, so local officials may need to request the
assistance of the data base manager to conduct the information retrieval. The information and
accessibility of some data bases may vary greatly from state to state. Some states may not have
the information organized in a readily accessible manner; other states may not have enough
information relating to the area of concern to justify a search. It may turn out that other sources
can provide equivalent information for less effort depending on the structure and amount of
information built into the data base. For this reason, local officials should discuss with the data
base manager the ability of the data base to meet their intended needs, prior to undertaking a
search.
NEW YORK DATA BASES
Officials in New York State indicate that their primary source identification
method is an industrial chemical survey data base in which all industries report average
annual uses. Local governments have access to the industrial chemical surveys and a
number of localities are using them. Another data base used as a source identification
method is a bulk chemical storage data base. New York also is planning to develop
better pesticide usage data. Although the existing .data bases used for source
identification in New York overlap each other, the State is working towards unifying
existing data bases with a long-term GIS objective for State-wide information.
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Even if information from data bases is readily available, the listings will only identify
facilities that have complied with the requirements to file notifications or obtain permits. Other
inventory approaches must be used to identify unpermitted facilities.
In addition to environmental program data bases, other data bases within each state can
be used as a method of source identification. One example could involve looking to the state
agency responsible for administering the sales tax. Each business that registers with the state is
given an identification number that retlects the type of business and materials used; this source
would provide information on all businesses that are involved in retail trade, ranging from solitary
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shopkeepers and crafts-people to major merchandisers. Similar information can be obtained for
another class of facilities through the state unemployment insurance and/or workers compensation
offices. This information is generally organized according to SIC codes; thus, a search can focus
on particular industry types.
FLORIDA DATA BASES
The Florida Department of Environmental Regulation primarily relies on two
major State data bases to identify potential sources of wellhead contamination under its
Wellhead Protection Program:
• The Ground Water Pollution Source Inventory COPS!) locates all facilities
that have received a DER permit allowing discharges to ground water. The GPSI also
includes information on the type of discharge, volume of waste, and point of discharge.
The data base is computerized and localities have access to the information through
local DER district branch offices. Retrievals can be made by site location, type of
facility, or category of the source.
• The Water Quality Assurance (WQA) data base contains information on all
other "non-permitted" sources. Data sources include ground-water monitoring
information, investigations of ground-water contamination sites. State hazardous waste
sites, underground storage tank sites, pesticide contamination sites, and Superfund and
RCRA sites.
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4.13 Zoning and Health Regulations
Zoning and health regulations are adopted at the local level to control development and
to safeguard the welfare of the community. In general, these programs will stipulate the types of
activities that arc permitted within an area or may restrict certain activities or facilities. Although
the regulations themselves may not establish a system for source identiilcation, they may simplify a
screening of activities that could potentially result in ground-water problems.
In many jurisdictions, a review of existing and past zoning ordinances and maps can help
WHPA managers identify local land use patterns. In their simplest form, zoning ordinances
control the general types of activities that can occur within a specified area; for example, an area
may be zoned tor heavy industry, light industry, commercial, residential, or agricultural uses.
Discussing land use classification or evaluating zoning maps with local officials can help to focus
identification efforts or suggest a starting point. A review of existing zoning regulations can
indicate which parcels should be thoroughly inventoried for contaminant sources. Site plan
submissions or amendments also may help to screen facilities or activities that merit additional
attention.
Areas zoned for specific land uses can be categorized by the activities and sources of
contamination associated with that land use (Exhibit 4-1). A priority scheme for investigating
each area can then be developed. For example, if a parcel of land is zoned for heavy industry, a
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Paee 17
Exhibit 4-1: Sources of Contamination
QUANTITIES ANT) TYPES OF CHEMICALS TYPICALLY USED, STORED OR
TRANSFERRED BY LAND USE ACTIVITIES
Large Amounts of Chemicals
Industrial Activities:
Chemical manufacturing; electronics; petroleum
retimng and storage; metal treating; food processing;
wood and pulp processing; textile manufacturing;
warehousing
Commercial Activities:
Gas stations; furniture stoppers; drum cleaning
Chemical Categories:
Oreanic solvents:
petroleum; other oreanics;
metals
Petroleum; organics
Moderate Amounts of Chemicals
Commercial Activities:
Dry cleaners; junk yards; auto repair and body shops;
pes't controllers; photographic processing; machine
shops; auto pans stores; lawn and .garden/farm stores;
paint stores; hardware stores; medical facilities
Agricultural Activities:
Heavy chemical use agricultural (fruits and vegetables)
Residential Activities:
Urban housing; high density (greater than 2 dwelling
units per acre) using septic'systems
Chemical Categories:
Organic solvents;
petroleum; pesticides;
metals; nitrates; other
organics
Nitrates; pesticides
Nitrates; pesticides;
petroleum; other organics
Small Amounts of Chemicals
Commercial Activities:
Grocery stores; department stores; office buildings;
laundromats; food service; shoe repair, barber and
beauty shops
Agricultural Activities:
Low chemical use agriculture (forage crops)
Residential Activities:
Moderate and low density (less than 2 dwelling units
per acre) using septic systems
Chemical Categories:
Organics; petroleum
Nitrates
Nitrates; petroleum;
pesticides; other organics
Underlying the protection program objectives is the concept of reducing or eliminating the risk to
groundwater posed by various land use activities. Such nsk is usually a function of these factors:
• The types and amounts of chemicals/wastes used, stored, discharged or transferred at a site;
• The safeguards used to minimize contamination potential; and
• The location of the site relative to sensitive aquuer areas, tributary land areas and
tributary surface water bodies.
Generalizations about the magnitude of the risk posed by a given development activity can be made
by evaluating these factors. However, two notes of caution are in order. First, a great disparity of
nsk can occur within the same category of land use; and second, no level of sateguard short of
prohibition can remove all nsk from certain activities.
Source: Ground Wner Supply Source Protection. A Guide for Localities in Upstate New Yort Prepared by ihe
Schenecudv County Planning Department in cooperation with tne Capital Duma Regional Planning Commission and the
New Yort State Department of Environmental Conservation.
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windshield survey, field search, or door-to-door survey could be conducted to identify specific
potential sources of contamination associated with the industries in that zone. These source
categories may include pipelines, storage tanks, landfills, and similar activities. In areas zoned for
commercial or residential use, the survey might focus on assessing on-site wastewater disposal
practices or smaller raw material and waste storage sites.
MASSACHUSETTS' LAND USE DATA BASES
The Cape Cod Aquifer Management Project (CCAMP) is an inter-agency
project initiated in 1985 to develop a comprehensive, resource-based approach to
ground-water protection. During this project, an intensive land-use study was completed
within one wellhead protection area in the town of Barnstable, Massachusetts. A
detailed inventory of the land-use data within the Zone of Contribution (ZOC) was
gathered from the data available through existing regulatory programs at all levels of
government. CCAMP's inventory of potential contamination sources provided an
extensive characterization of the use of hazardous materials and the risk posed to public
water supply with this ZOC. The most overwhelming conclusion was the high potential
threat posed by petroleum products; there are 186 USTs within the entire zone, a large
majority clustered close to three of the public supply wells.
Community public water suppliers in Massachusetts are required by Department
of Environmental Protection (DEP) regulations to report annually on land use in their
water supply areas. Instructions for the land use inventory require public water
suppliers to obtain a base map of each water source and locate Zones I and II; each
land use activity that might threaten water quality must be identified by water suppliers
and researched through contact with local Boards of Health, Fire Departments, Zoning
Boards of Appeals or the DEP.
During the past three years the DEP has awarded over $75(),(X)0 in grants, under
a Federal grant provided to the DEP under Section 2()5(j) of the Clean Water Act, to
regional planning agencies to develop wellhead protection projects with their member
communities. Much of this funding was used for mapping wells and pinpointing
potential contamination sources. Ten of the thirteen regional planning agencies are
participating in these projects.
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In a manner similar to zoning regulations, health regulations often are developed and
implemented at the local level to control the siting of waste management areas or wastewater
disposal facilities in sensitive areas, such as near surface waters or in regions with wet soils. Such
regulations could be used to target regions where material management practices may have a
direct impact on ground-water quality. In addition, health regulation violation records could help
officials target areas to inventory and inspect thoroughly. These records also could identify
building use types, such as restaurants or hospitals, which would correspond to certain types of
potential contamination.
The local sewer authority maintains records of those parts of the community that are
serviced with sanitary sewers. This information can help to focus a source identification process if
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Page 19
septic or other on-site disposal systems, domestic or commercial, are a major concern. In
addition, the sewer authority will know which businesses in the community have a permit tor
discharge of industrial wastes to the sewer system; this information can be useful to identify
facilities that use potential contaminants on site and it can help to identity actual sources of
contamination. For example, materials that are discharged to a sanitary sewer can corrode the
sewer line or leak from cracks in seams or pipes.
Most localities require any new development to obtain a building permit and "perc" test
for any size of residential or commercial septic system. Local health departments also often
require permits for the siting and construction of wells. Officials can consult these permit records
to identify specific potential sources of contamination and potentially improperly constructed
wells. In areas where the quantity of ground-water withdrawal is of concern, due to limited
ground-water resources or known contamination, locations of wells can be as significant as
locations of septic fields.
In some communities health regulations also may apply to other potential sources of
contamination such as hazardous and toxic materials, road salt, fertilizers, and pesticides. These
regulations can be used to identity general areas where these activities take place or, for
permitted activities, can identify specific potential sources of contamination.
VERMONT HEALTH DEPARTMENT SURVEYS
Health department surveys of public water supplies in Vermont provide a first
cut determination of a well's vulnerability to contamination. Surveys of all public water
supply wells are done on a three year basis. The sanitarian who investigates the well
notes any obvious potential sources of contamination and gives a preliminary evaluation
of the well's vulnerability to contamination by VOCs, sewage, or other contaminants.
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With zoning and health regulations, as with federal and state data bases, the quantity and
quality of information available to a particular community may vary substantially. The accessibility
to this information may vary as well. In many cases zoning and health regulations may be most
useful as a means of identifying areas to survey more thoroughly with another inventory method.
In some communities, however, it may be possible to identify specific potential sources of
contamination through examination of these records.
4.1.4 Literature and Historical Records Searches
Information documenting past and present land uses also may be maintained at the local
level. This information is primarily of three types: 1) local registries of commercial and industrial
activities; 2) property transfer records, titles, and deeds; and 3) historical perspectives, such as
revised and updated ("before-and-after") aerial photos, interviews or statements from senior
citizens living in the area for long periods of time, including verification of anecdotal evidence
("storytellinn") related to past activities in the area that could be a source of contamination.
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The first source of information may be maintained by local Chambers of Commerce or
taxing authorities, or could be as basic as the local yellow pages. Such lists may be organized by
industry type or by industry size and they often are maintained regularly by the local authority.
These lists, however, probably will not contain information characterizing the materials
management practices within the industry.
FLORIDA'S LAND USE LOCATOR" SYSTEM
In addition to using State data bases as a source identification method, the
Florida Department of Environmental Regulation will use a land use locator system
developed for Florida's ground-water monitoring network. This system is based on the
property tax system and will enable officials to track historical land use of property by
counties and likely help localities identify and locate potential sources of contamination.
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Property transfer records typically are maintained at the county level; investigating these
sources of information would be most useful for determining past ownership and potential past
waste disposal practices, where material releases may be suspected.
Some states require environmental audits for certain classes of property transfer actions.
Massachusetts and New Jersey, for example, both require that a seller complete an environmental
audit in order to certify that the property is clean when commercial real estate changes hands.
These records can be used to identify the types of activities that have occurred at individual sites.
Local registries have the advantage that some type of list will exist for all communities;
although in some communities the only registry may be the yellow pages. These lists are fairly
easy to obtain access to, and a directory such as the yellow pages can be searched in a short time,
with no travel outside the office required. Property and environmental records, however, as with
many state data bases, may not be organized in a way that allows for easy access. In such a case,
it is often more useful to speak directly with agency personnel who are involved in reviewing and
maintaining the information; they often will be able to identify problem sites within a given
geographic area.
4.2 Surveys
Successful water managers conduct surveys and personal interviews to identify potential
sources of contamination. They design these surveys by combining a number of discrete steps,
including designing the survey, obtaining the list of contacts, mailing the survey or telephoning the
contacts, following up on responses to the survey, and, finally, tabulating and interpreting the
results.
Survey designs vary in the jurisdictions that use them. The design of the survey is tailored
to the types of discharge sources, water supplies, and contamination problems commonly found in
the surveyed region and allow for uniform data reporting to facilitate data management.
Nebraska's Source Identification Report, for example, contains a sample questionnaire that
includes informative questions such as the name of the owner and operator of the well or facility
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MAINE SOURCE INVENTORIES
To inventory sources of contamination in South Paris, Oxford, and Norway, the
Maine Department of Health Services (DHS) recommended that wellhead operators
"review any printed materials that indicate the location of ... potential sources of
contamination" including "telephone directory yellow pages, business records (such as
fuel oil delivery services), State and municipal and county records and permit files,
historic records, and news articles." For the initial inventory, a contractor reviewed
State and EPA data bases on CERCLA and RCRA waste sites. For all three towns,
the contractor identified 18 major sources of contamination, including tanning
operations and pulp processing facilities, and 23 to 24 minor sources of contamination
including underground storage tanks at small automobile garages.
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and the name of the person completing the form (Exhibit 4-2). This survey form also requests
information concerning the distance to the nearest public supply well and the types of materials
handled on site. Exhibit 4-3 presents another sample survey format. Many localities use
telephone directories, including the business-to-business Yellow Pages, to identify commercial
facilities and residences for mail and phone surveys, personal interviews, and other source
identification methods such as door-to-door surveys.
4.2.1 Mail and Phone Surveys
Mail and phone surveys have the advantage of enabling a community to contact a large
number of locations at relatively low cost. Mail surveys have an advantage over phone surveys in
that the costs associated with data collection are derived primarily from postage, as opposed to
telephone costs; likewise, the time requirement is less than that necessary to conduct individual
calls. Although the labor associated with a telephone approach can be significant, the costs can
be reduced by use of volunteers. In an area with a small population, however, a telephone survey
can be conducted with only a few people. Telephone surveys have an advantage over mail
surveys in that respondents are somewhat of a captive audience; response rates likely will be
higher. A telephone survey of a residential or agricultural area may need to be conducted after
business hours in order to tlnd the residents at home. Phone surveys can be used effectively to
"fill in the gaps" left from a mail survey.
Both phone and mail surveys have the advantage that they may obtain information on
sources that were previously unknown. The direct contact with the public which is involved in
conducting each of these types of surveys can also promote public education about the potential
of ground-water contamination. Media involvement in these surveys can promote public
education as well as increase the survey response rate by preparing the public for the survey and
explaining its purpose. A preliminary mailing to explain the survey effort may be helpful when
conducting phone surveys.
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Exhibit 4-2: Nebraska Survev Form
SITE QUESTIONNAIRE FOR INVENTORY OF POTENTIAL GROUND WATER
CONTAMINANT POINT SOURCES
Subcacegory (from list)
Proper Name of FaciLicy Address_
Owner: Name Address^
Operator: Name Address
Registration or ID number, or Local name of nearest public supply
well
Owner of nearest puolic suoply well.
Name Address
Telephone Number
Distance to nearest public supply well, if less than 300':
Taped distance
Compass direction
if .T.ore than 300' name of nearest map reference point
Distance co nearest Tiap reference point
if less than 300' taped distance
compass direction
if more than 300'• Reach A Reach B Reach C
Odometer or paced distance
Road name
Road direction
Date of inventory
Name of person doing inventory
Name(s) of person(s) supplying information
Year facility began operation
Previous use of site
Macerial(s) Handled On-Site cPlease Circle)
2
3
4*
«
i
T
3
•?
13
PCS
Olonn
Crude Oil
Gatolin*
OieseL Oil
Other Oisti.late Fuel
Asphalt or Qttiar residual
Anmal or '•'•gtt.abl* Oil
Waste Oil
Other Oil
2 slptha'"" S0i'"n"
3 «iner»l 3piri'.»
•• '/erann Poisons
i '.r.secticides
o -iemat-cides
' Herbicides
3 Fungicides
3 .'Uiibiotics
3 Fertilizers
22
23
2k
2 5
26
27
23
29
20
Acids
Organic Solvents
Caustics
Alconols
•mines
Aldehydes
Radiological
Brines
Other
'Jnxnown
Source Nebraska Source Identification Inventory Report, p.32.
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Source Number
Inventory Person
Exhibit 4-3: EPA Sample Survey Format
PWS Well Number
See Attached Map No.
SUGGESTED INVENTORY FORM
A.
B.
C.
D.
E.
Landowners Name
Address
Phone: ( )
City:
Zip Code
County:
Description of Location:
Residential
Commercial
Nature of Property
Agricultural
City Gov't Site
State Gov't Site Other (
Potential Sources of Contamination
Industrial
)
Circle the potential sources listed below that you have identitled at this site. In the space
provided, indicate how many. (EXAMPLE: 2 )
POTENTIAL SOURCE
Abandoned Water Well
Above Ground Storage Tank
Airport
Animal Feedlot
Artificial Recharge
Auto Salvage Yard
Cemetery
Cesspool
Chemical Storage Facility
Drainage Well/Canal
Dump
Fertilizer/Pesticide Application
Golf Course
Grain Storage Bin
Highway
Notes:
QUANTITY POTENTIAL SOURCE QUANTITY
Holding Pond/Lagoon
Injection Well
Landfill
Mine
Municipal Sewage Line
Oil/Gas Well
Quarry
Railroad
Septic Tank
Service Station Disposal Well _____
Sewage Plant Sludge Disposal
Stream (Lake, River, Creek)
Underground Storage Tank __,
Water Well
Other
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SUGAR LAND. TEXAS
The community of Sugar Land, Texas, conducted a mail survey to identify
potential sources of contamination for their wellhead protection program. Community
officials planned to use the mail survey as a preliminary base of information for their
source identification efforts. They prepared a survey form that included questions on
land uses and sent it to recipients with their water bill. Officials were very pleased with
the 45 percent response rate obtained with this survey; they completed the source
inventory process using a door-to-door survey.
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Mailing lists can be obtained from a number of sources. Rhode Island defines its list from
property owner names obtained through the tax assessor and supplements this list with addresses
and phone numbers from the local telephone directory. Other sources of mailing lists include
voter registration lists, Chamber of Commerce rosters, tax rolls, and utility records. The use of
lists organized by zip code or voter registration lists grouped by precincts can facilitate the
identification of contacts within a particular geographic area (e.g., a WHPA); mailing lists
arranged by zip code can be purchased from a number of companies.
Once the surveys are mailed, they must be collected and tabulated. The collection effort
may be as simple as enclosing a self-addressed stamped envelope with a mailed survey, or as labor
intensive as a door-to-door collection; for telephone surveys the collection is accomplished by
compilation of survey sheets from the interviewers. After the collection is completed, a data base
may be constructed to compile the information obtained by the survey. Data base management
systems are discussed in Section 6.0.
CENTRAL AND NORTHEASTERN SOUTH CAROLINA
The South Carolina Departmeat of Health and Environmental Control (DHEC),
UIC Program conducted an evaluation of potential sources of ground water
contamination near public water supply wells in live cities and towns. After DHEC staff
collected information from various State and local government agencies, and conducted
detailed windshield surveys, they contacted by telephone each facility suspected as a
source of potential contamination. Staff questioned responsible parties regarding the
operations of the facilities to determine if they engaged in activities that could lead to
ground-water contamination. Officials surveyed over 230 facilities by telephone. DHEC
identified and inspected a total of 485 potential sources of ground-water contamination;
219 were identified as sources which could potentially contaminate public water supply
wells.
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4.2.2 Door-to-Door Surveys
Door-to-door surveys, as a source identification method, generally involve canvassing the
residences and businesses within the WHPA to determine the activities and materials that exist in
the area of concern. Door-to-door surveys allow for visual observations which mailed surveys do
not; however, door-to-door surveys are subject to response bias, just as are mail and phone
surveys.
The design of the survey can be much like the mailed survey design, although it can be far
more extensive. When staff are trained prior to conducting the survey, the answers to the survey
will be more concise, complete, and uniform than those of mailed surveys. The design of the
survey should be tailored'for the potential contamination sources relevant to the particular local
area. Basic site information to be collected through a door-to-door survey at a minimum should
include the following:
• The landowner's name, address, and phone number;
• The waste management company's name, address, and phone number;
• The facility name and street address;
• The type and number of potential sources;
• An identification number; and
• History of any discharges.
Additional information could include a physical description of the property and source
location, latitude and longitude, distance from the nearest well, status of the source (active or
inactive), and characteristics of the potential pollutant; in El Paso, Texas, the surveyors took
photographs of potential sources of contamination.
CUBA. MISSOURI
A door-to-door survey was designed to help identify Class V well types and
other sources of contamination in Cuba, Missouri. It included questions addressing
possible residential, commercial, and industrial contamination sources such as: the
location of active or abandoned wells, cisterns, fuel oil tanks, heat pumps or septic
systems, and the location and storage of chemicals used in businesses. Surveyors also
noted any wells, cisterns, and storage tanks that they spotted while conducting the
survey.
Information from State and local agencies was combined with the results of the
door-to-door survey to develop a comprehensive listing. The revealed 465 possible
sources of contamination that were unknown previous to the investigation. These
sources included: 103 above ground storage tanks, 73 underground storage tanks, 115
Class V wells, 149 active water wells, and 21 chemical storage locations.
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Recruiting and training workers to conduct a door-to-door survey can be both a costly and
labor intensive process. Nebraska addresses the question of inventory personnel saying,
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"Finding a low-cost solution of trainable labor is the most difficult question in
source inventory. Some possibilities are: tax assessors, emergency services,
sheriffs deputies, property appraisers, 'Save the World' volunteers under EPA
grant, city health departments, service organizations, and temporary workers
hired by public water suppliers."1
Another option for low-cost survey workers is to use volunteers and local service
organizations in the inventory process. The Texas Water Commission recommends this option as
a method which "not only will conserve resources at both the local and State levels of
government, but provides for local public education and participation." Retired professionals
such as engineers or others with technical backgrounds have the expertise needed to identify
sources and conduct the survey, and they bring the added advantage of their own historical
knowledge of the area.
The survey should be conducted after a period sufficient tor the media to inform the
public about the survey process and purpose. Surveys should not be conducted during holiday
periods when landowners may be on vacation and businesses may be closed. If volunteer workers
are used to conduct the survey, particularly if they are senior citizens, efforts should be made to
avoid sending them out in inclement weather.
Surveyors should be trained and given detailed maps of the areas they are to survey, lists
of potential sources, and survey forms which they will complete with information describing land
uses and potential contamination sources. A system of numbering sources should be developed so
that surveyors can assign each source a unique identifier. If volunteers are conducting the survey,
it is helpful for them to be given badges which identify them as WHP volunteers.
Once all of the survey data has been collected, the results need to be tabulated and
analyzed. It is helpful to produce detailed maps of the surveyed area which include the locations
of all identified potential sources of contamination; street addresses should be converted to
latitude and longitude. A transverse Mercator grid system can be used to locate potential
contamination sources on USGS topographic maps. In a South Carolina study, all identified
sources were given a pollution potential rating based on the type of source, historical and current
practices at the facility, and proximity to the public water supply wells. Communities that have
conducted door-to-door surveys frequently find sources which are unpcrmitted or otherwise not in
compliance with current regulations. These instances should be brought to the attention of the
relevant regulatory authority.
The advantages of a door-to-door survey include the increased accuracy and uniformity of
data collected by trained surveyors, the opportunity to promote public education about ground-
water contamination, and the increased likelihood of identifying previously unknown sources.
Door-to-door surveys are, however, time consuming and require a staff of trained surveyors,
although these staff requirements may be met with the use of volunteers. These surveys require
organization to be successful and may need to be conducted outside of regular work hours.
1 Nebraska, Source Identification Inventory Personnel, p. 33.
~ Texas Water Commission, A Ground Water Protection Strategy: The Citv of El Paso.
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TEXAS CASE STUDIES
Senior volunteers were used to conduct El Paso's inventory, while extensive
media coverage or" the inventory process in Houston led to a multi-generational range of
volunteers, including junior high school science classes (working with the school's
corporate sponsor), families who have "adopted" a particular wellhead protection area,
and college students. Three cities in Texas used Boy Scouts to conduct the inventories;
a wellhead protection inventory could be used as an Eagle Scout project. Recruiting
volunteers from the community has the advantage of establishing a team of surveyors
who are familiar with their area and contributes to the public education and
involvement which are necessary for a successful wellhead protection program.
The Texas Water Commission recommends that local governments intending to
conduct door-to-door inventories work closely with'the media to inform the community
what is being done and why: this will help ensure that information is accurately
disseminated. Media coverage is essential for public cooperation; an understanding that
these efforts are lit protect everyone's water supply can help diffuse resistance by those
who may feel threatened by survey questions.
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4.23 Windshield Surveys
A windshield survey c;m be conducted in much less time than a field search and can be
effective in identifying a large percentage of potential sources present in an area. To conduct a
windshield survey, the surveyor obtains detailed maps of the survey area and drives through all or
parts of the area, noting the potential sources of contamination that they observe. Windshield
surveys work best in areas where most of the sources can be located from the road. They are
more difficult to conduct in rough terrain.
Conducting a windshield survey requires access to a vehicle and one or two people. It
may be easier to conduct this type of survey with two people, so one can drive while the other
records information about the .sources spotted. Windshield surveys can be used effectively to
identity sites for further investigation, either through a mail or phone survey, or by field searches
or site visits. These types of follow-up contacts can obtain information about waste management
practices which often can not be obtained simply by observing a site from the road.
There are many advantages to conducting windshield surveys. They do not require as
much time, as many people, or as many steps as other types of surveys or fields searches.
Windshield surveys would probably work well in most communities and a large amount of useful
information can be gained from them. Unlike Held searches, windshield surveys are conducted
without entering private property so access is not a problem. Windshield surveys may not be as
effective an inventory method in some rural or mountainous areas where many sources will not be
visible from the road.
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NORTH KINGSTOWN AND HQPKINTQN. RHODE ISLAND
The Rhode Island Department of Environmental Management (DEM), Division
of Groundwater and Freshwater Wetlands used seven different methods, including a
"windshield or field survey" to identity potential sources of contamination in the city of
North Kingstown and the rural town of Hopkinton. DEM staff used road maps and an
automobile to conduct a detailed street-by-street windshield survey of land uses, touring
each road in both study areas. Staff found that, although time consuming, the
windshield survey alone identified the highest percentage of total sources found among
the source inventory methods used. Of the universe of potential sources identified, the
windshield survey identified 77 sources or 86 per cent of all sources in Hopkinton and
105 sources or 95 per cent of all sources in North Kingstown. DEM staff found that
this method worked well in both an urban and a rural community.
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4.2.4 Personal Interviews
Personal interviews are an extremely valuable source of information to identify and.locate
sources of potential contamination. Personal interviews differ from telephone or door-to-door
surveys in that interviewers often do not have a prearranged list of contacts; they informally
gather names of potential contacts as they are conducting their source inventories. Contacts are
often long-term residents with a wealth of knowledge about past commercial operations and
practices. Personal interviews of a specific type of individual, such as facility operators, fire
marshals, planning board members or secretaries, building officials, or health inspectors can
provide a great deal of information often not available through other source identification
methods. Local officials can often supply names of such contacts.
SOUTHWESTERN MAINE
A contractor hired by the towns of South Paris, Oxford, and Norway, Maine
interviewed long-term residents who were identified as people who cither worked at a
facility or lived near a particular site for many years. These people provided valuable
and detailed information on the types and amounts of chemical products used at
facilities, site operations, and waste management practices. The contractor noted that,
of all the source identification methods used for their study, the personal interviews
provided the best source of information, in part because the information gathered from
the interviews was not available anywhere else.
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The advantage of conducting personal interviews is that a large amount of useful
information may be obtained which is not available from any other source. These interviews may
be particularly useful in small communities with long-term residents who are very familiar with the
area. It may, however, require several contacts to find the most helpful people to interview, and
a fair amount of time may need to be spent making preliminary contacts.
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Although surveys and interviews are a relatively straightforward means of identifying
potential contamination sources, they are subject to certain deficiencies. For example, data
obtained through mail and telephone surveys ot personal interviews may be tainted by response
bias. People who have an interest in responding to surveyors' questions will respond, while those
who feel they may be affected adversely by the results of the survey will not respond in full.
Another problem is that a survey will be only as complete as its list of contacts. For example, if
the list of addresses for a mail survey includes only residences and not commercial or industrial
facilities, a large sector of potential contamination sources may be missed. Conversely, a list of
only commercial establishments could miss such potential sources as public works garages, fuel
depots for school buses, or many private-home activities. These problems may be remedied by
using mail or phone surveys, or personal interviews in conjunction with other source identification
methods such as historic records, door-to-door surveys, and field searches.
4.3 Field Studies
Thorough inventories of potential ground-water contamination sources often include field
studies of some or all of the area being inventoried. Field studies allow the persons conducting
the inventory to look at the survey area themselves to determine if potential sources are present,
without relying on landowners to identify and provide information about sources.
SPRINGFIELD. OHIO
The Ohio EPA, Division of Ground Water (DGW) scheduled interviews with
various local and county officials to supplement other source identification methods and
gather information about past, current, and proposed commercial and residential
activities. DGW also interviewed managers of local industries, area business people, and
farmers; interviewers obtained detailed information on industry processes, management
practices, and potential wellhead protection area contaminants. DGW used the
interviews to inform these individuals about Springfield's ground-water resources, its
wellhead protection efforts, and how land uses could contaminate the wellhead
protection area.
DGW staff found the personal interviews in Springfield to be very successful.
The business people interviewed were surprised to learn of the potential impacts their
activities and management practices have on the city's wellhead drinking water.
Although DGW found that conducting personal interviews was very labor and time
intensive, the exchange of information that it entails makes it a critical component of
the source identification process.
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4.3.1 Field Searches
Field searches are conducted much like door-to-door surveys and require the same amount
of planning, but often require more time to complete. Field searches consist of an extensive loot
survey of an area, and are often used when a particular situation calls for a detailed inspection of
land uses. Field searches are best used in relatively small study areas with relatively easy access.
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Field searches are often used in conjunction with other source identification methods, such as
aerial photographs, to complete a detailed source inventory.
Conducting a field search involves a number of steps much like those required for
telephone, mail, or door-to-door surveys: designing a data collection form, coordinating and
training workers to conduct the survey, mass producing the data collection form, conducting the
survey, constructing a data base, and interpreting the results. The data collection form must be
designed to easily record the observations of the surveyor and should contain information on the
presence, location, and number of known or suspected contamination sources or activities; type
and quantity of chemical products used on site; site-specific characteristics, such as gasoline odors
or soggy ground; name of the surveyor; and date of site visit.
Much like the door-to-door survey, field searches can be costly and labor intensive
because of the surveyor training that is involved. These costs may be reduced by using local
professionals such as tax assessors, property assessors, or city and county health department
workers that have a good working knowledge of the study area. Although field searches are
costly and time consuming, they are one of the most accurate inventory methods as they allow
little room for surveyor or respondent error, misconception, or interpretation. Officials managing
a field search can help minimize potential problems by securing permission for access to the study
area from the property owners or operators. Surveyors should also wear name tags identifying
their affiliation with the agency responsible for the source identification study. The responsible
agency should take these and other precautions, as necessary, to help avoid problems with access
or liability that may arise.
TALLAHASSEE. FLORIDA
U.S. Geological Survey (USGS) personnel are participating in a pilot study to
identify previously unknown Class V wells that threaten to contaminate Tallahassee's
underground source of drinking water. Because of" their widespread use and little data
on Class V wells in Florida, officials have found that these potential sources of ground-
water contamination are difficult to identify. As a result, USGS personnel have
developed a field survey to locate undocumented Class V wells. Officials note that in
this situation, a field search is the best method to identify this potential source of
wellhead contamination.
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43.2 Aerial Photographs
Aerial photographs can be useful particularly for surveying large geographic areas or areas
that are not easy to access on foot or by vehicle. Many localities will have some aerial photos on
file available through the local soil conservation service, survey firms, or in the local historical
archives. Aerial photos come in a variety of formats, ranging from high altitude satellite images at
small scale to photographs taken from small planes for custom applications, such as marketing or
evaluating individual pieces of property. Although the entire United States is catalogued through
various satellite image libraries, these photographs are, for the most part, at a scale too small for
mapping or identifying activities at the detail required for a source inventory. Medium scale air
photos in the range of 1:12,000 to 1:50,000 are considered to be the most suitable widely available
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resource for mapping land use; color and color infrared aerial photos at a 1:8,000 scale have been
used successfully to detect failing septic systems. Aerial photos can be used to identify particular
sources or to screen large areas for follow-up investigations. A review of updated aerial
photographs should be conducted to develop a historical perspective of the changes in surface
features of a given area. These "before-and-after" comparisons are very important in revealing
the location of sources or activities (e.g., landfills, railyards, etc.) that may contribute to ground-
water contamination.
WAVERLY. NEBRASKA
Officials from a variety of agencies in Nebraska worked together in November,
1989 to develop and test techniques to identify and locate sources of wellhead
contamination in Waverly, a town of approximately 2,000 people. Officials used an
extensive list of potential contamination sources in conjunction with air photos of land
uses in the town to conduct the source inventory. Particular land uses were identified
from the air photos and checked against the list of potential sources to determine if
they merited additional consideration. Officials found the air photos were effective,
especially where the landscape had sufficient reference points that were also specified
on local topographic maps.
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5.0 IMPLEMENTING METHODS FOR SOURCE IDENTIFICATION
Implementation of source inventory techniques requires not only careful planning upfront,
but appropriate selection of one or many source identification methods. The following section
discusses a progression of steps that could be used in conducting the inventory. For a discussion
of specific aspects of inventory methods, consult the descriptions in Section 4 of this document.
The flow chart in Exhibit 5-1 further illustrates the possible progression of steps involved in
conducting a thorough source inventory.
5.1 Consult Existing Sources of Information
The amount and quality of existing information will vary greatly from community to
community; however, all localities will have at least some existing information available to them.
These information sources include aerial photos, various types of existing lists, and published
information. An investigation will determine the availability, accessibility, and potential usefulness
of local, state, and federal data bases. If the information is easily available, it is generally
worthwhile to consult these data bases. If it is not easily available, the community may wish to
consider whether its resources might be used more effectively on another inventory method, or
may choose to wait until near the end of the inventory process and then consult the data bases if
resources allow. In the latter case, information from the data base can be used to confirm that
gathered through other methods.
5.2 Share Information with Other WHP Elements and Tools
Tasks associated with identifying sources of contamination in a WHPA may overlap with
other elements of the wellhead protection process. For example, information gathered during
wellhead delineation may be useful in directing water managers to appropriate source
identification locations; likewise, once the WHPA has been delineated, the geographic area to be
inventoried will be limited. In the same way, potential sources of contamination identified during
the source identification process may help decision-makers focus on the areas of concern in a
Contingency Plan.
Wellhead protection managers may choose to utilize the source identification process to
enhance many of the community's management tools (e.g., zoning ordinances, design standards,
source prohibitions, ground-water monitoring, public education). These tools, whether combined
or used alone will benefit from source identification efforts. For example, if the local water
agency has been able to identify the sources of contamination in a WHPA, they can target
appropriate rules and ordinances to that community.
5.3 Compile a List of Sources
Once a community has consulted the available existing sources of information, officials can
compile a preliminary list of sources. It is generally a good idea to check the sources identified by
different methods against each other to confirm that the listings are accurate and current. At this
point interviews and windshield surveys can be helpful in identifying additional sources not
included on existing lists. Interviews and windshield surveys may take more time than that
required to consult lists of existing information, but they can be conducted by a small number of
people and may provide more current information. Interviews may provide an historical view of
potential sources and may provide information unavailable by other methods, while windshield
surveys provide a limited visual inspection of the entire survey area.
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5.4 Access Unknown Sources
After these stages in a source inventory, officials will likelv have identified most known
o * *
sources of contamination. Known sources are those which are already known to local authorities
or which are included in files or data bases, while unknown sources generally have not been
brought to the attention of authorities due to oversight, lack of regulatory controls, or lack of
concern. The later steps in the inventory process, i.e., surveys and site visits, will help identify
information on sources which were unknown previous to their identification by the inventory.
Collecting information on unknown sources generally requires some type of direct contact with
landowners as they are likely to be the only ones who know about a source.
WQODBURY. CONNECTICUT LAND USE SURVEY
One surveyor was hired to conduct an inventory of land uses in Woodbury,
Connecticut's aquifer recharge area. The surveyor's source inventory identified
approximately 130 high risk sources of potential wellhead contamination. The Health
District Director estimated that the land use survey took the one surveyor approximately
6 weeks to complete.
The surveyor used yellow pages phone directories for a broad identification of
current potential sources, and reviewed a number of data bases maintained by the
Connecticut Department of Environmental Protection. The surveyor also reviewed
historical land use maps and aerial photos maintained by the tax assessor's office. The
aerial photos were particularly helpful because of their large size and detail. The most
informative source identification method, however, was conducting personal interviews
of the fire marshal! and the town planner. Finally, the surveyor conducted a windshield
survey of land uses in the recharge area to identify any potential sources that may have
escaped identification through the other surveying methods.
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5.5 Modify a Program to Support Individual Community Needs
Probably no community needs to conduct mail, phone, door-to-door surveys, and field
searches, as this would gather a large amount of repetitious information; however, the choice of a
particular configuration of methods to be used will depend on the situation of the community
conducting the inventory. If resources are not available for some of the more labor intensive
methods (e.g., surveying all landowners and businesses in a given area), various means may be
used to reduce the efforts without losing their value (i.e., pare down the survey contact list or
area).' Also, the use ot volunteer organizations or local public service groups should always be
considered where resources are a major issue (see Section 3.4, Page 11).
A windshield survey could be used to identify locations to contact via a mail or phone
survey; conversely, a mail or phone survey could identify locations for follow-up site visits.
Although a door-lo-door survey combines the advantages of both allowing a visual inspection of
sites and involving direct contact with the landowner to discuss potential sources and waste
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management practices, these same two elements could be gained from a thorough windshield
survey of an area, followed by phone contacts with all the landowners.
The resources available to a community also will have an important effect on the process
of conducting a source inventory. If resources are limited, a community may choose to stop the
inventory process midway through the idealized flow process, although this will increase the
likelihood that some potential sources will not be identified. Ideally, each community should
strive to conduct the most complete inventory possible given their situation and the resources
available to them.
WAVERLY. NEBRASKA SOURCE INVENTORY DEMONSTRATION
To conduct Waverly's source inventory, officials from a variety of agencies
used an extensive list of potential contamination sources in conjunction with air
photos of land uses in the town. Particular land uses were identified from the air
photos and checked against the list of potential sources to determine if they merited
additional consideration. Officials found the air photos were effective, especially
where the landscape had sufficient reference points that were also specified on local
topographic maps. Once a source of concern was identified, officials attempted to
interview, by telephone or in person, at least one person who was knowledgeable
about that source to collect specific information on it.
Officials found that identifying sources of potential contamination in the town
of Waverly was not very difficult. The inventory took two person-days to complete,
with gathering information on potential sources being the most time consuming task.
Waverly's source inventory identified 33 potential sources of ground-water
contamination.
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Exhibit 5-1
Sequence of Methods used for Source Identification
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6.0 DATA MANAGEMENT
6.1 Whv Do You Need It and What Do You Do With It?
A successful WHP program requires accurate and timely information that is capable of
defining problems and evaluating prevention strategies within WHP areas. Such an information
base can be developed by identifying the goals and objectives of the WHP and source •
identification programs. It is, therefore, essential to clearly define the objectives of the data
gathering effort prior to any data collection activities. The collection and management of source
identification data should be viewed in the context of other WHP and ground-water protection
programs and projects (e.g., RCRA, SARA, NPDES, and VST). It can be beneficial to take into
account compatible objectives from other projects in the data gathering and management scheme,
so as to avoid the duplication of efforts.
Data are the raw material from which information is extracted. Conceptually, data are
assembled into records and files for management purposes. A data record is made up of a small
group of related data items, and a collection of data records is known as a data file or data set. A
data record which belongs to a particular data file also can be cross-referenced to other data files
that contain additional information. For example, land-use categories can be linked to a file
containing typical chemicals found within these land-use categories.
Data management is the process of maintaining data in a logical fashion to facilitate
information retrieval and analysis. It begins with a set of procedures for entering the data in a
systematic fashion and to check, sort, and classify the data. Under a proper data management
scheme, the data must be securely stored to minimize any chances of accidental destruction or
gradual degradation over time. It also should not be possible for any unauthorized persons to
alter the content of the data.
The purpose of this chapter is to provide an overview and a working guideline for
managing data collected Tor the source identification process. Issues and problems that arise in
the storage and management of data in both manual and computer compatible forms are also
discussed.
6.2 Current Approaches to Data Base Management
A data base is a collection of records and files that are logically organized to facilitate the
analysis and processing of data. The purpose of collecting and maintaining information in a data
base is to uncover relationships among facts and situations that were previously separate. The
development of a data base should follow a series of procedures such as:
1. Data collection;
2. Data investigation;
3. Data base design;
4. Data base implementation; and
5. Data base evaluation and modification.
Managers and technical staff need accurate and correct information at the right time to
make decisions that will protect the resource, and to ensure adequate QA/QC measures are in
place during the collection, processing, and interpretation of data.
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The primary objective of developing a data base is to enable the analysis and processing of
data to reveal relationships among various facts and situations. A data base on potential sources
of contamination within a WHPA. therefore, should contain and be organized using information
on: types of land-use activities, the spatial location of the identified sources, the quantities and
chemical composition of the material stored or processed at the identified sites, the name of the
facility and the owner or operator, and other information that may be collected as part of a
survey.
Ideally, this information on potential sources of contamination should be analyzed in
conjunction with hydrogeological data and water supply information to provide a basis for
decision-making on source reduction, aquifer protection, and water quality monitoring. A data
base on the spatial distribution of chemical use and disposal is essential for determining the type
and location of monitoring activities for potential contaminants. If a contamination event is
detected, a data base on the distribution and use of chemicals would allow for a timely and
efficient allocation of resources to determine the source or sources of contamination.
The types and qualities of data that are to be incorporated into the data base need to be
specified and evaluated. Data base design involves the formation of a conceptual model of the
data (i.e., relationships between different data fields) taking into account all the basic facts and
constraints under which the data base will have to operate. Once a data base design is selected,
detailed decisions are made on the logistic and physical organization and the layout of data
records to facilitate the entering of data to create the data base. Finally, through the data base
monitoring phase, the data management system can be fine tuned and modified to increase the
effectiveness and efficiency of the system for data retrieval and analysis.
6.2.1 Manual Systems
Prior to the advances of electronic data processing, most data were managed through
manual filing systems. Data sheets, index cards, maps, and aerial photographs were stored in file
folders and filing cabinets according to some specific criterion or criteria. For a small amount of
data, a manual filing system may well be adequate; however, when dealing with a larger amount of
data, a manual filing system is very slow in data retrieval and highly limited in its analytical
capabilities.
A manual filing system is inexpensive, however, and does not require special equipment
and specialized training. Filing cabinets can be kept under lock to limit access by unauthorized
persons. As long as the data base is not going to be shared and updated frequently, a manual
filing system is generally sufficient to manage a limited amount of data from a source
identification process.
The disadvantages of manual filing systems can be summarized as follows: information in
a manual filing system cannot be easily shared by other programs due to its strictly defined file
structure; a high degree of redundancy may result from different applications; and, the system has
very limited data analysis and processing capabilities.
In a manual filing system, data records are generally organized in a particular order. For
example, records could be organized according to land-use categories. Thus, if given a category of
land-use activity, one can quickly find out all land parcels that are associated with that category of
land-use activities. If given a parcel number, however, it would be necessary to go through the
entire file, record by record, until that particular land parcel number is located to reveal its land-
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use category. To speed up the search by land parcel numbers, it would be possible to have a
second file containing all parcel numbers listed in an ascending order, and beside each parcel
number would appear the associated land-use category and other data items. This second file
would contain much of the same information as the first data file but organized in a different
order. .This high degree of redundancy can be reduced using index files. Instead of duplicating
everything, index files containing key fields and addresses can be generated. For example, an
index file can be set up using the parcel number' field as a key field and data sheet numbers as
addresses. In this way, given a parcel number, the particular data sheet could be located quickly
to reveal the associated land-use category. A major drawback of this approach is that systems
with even this amount of data redundancy are expensive to maintain. For instance, if the land-use
status of a parcel was changed, corrections would be required in two different files.
Because of the inflexible structures of manual filing systems, it is very difficult to deal with
large data files and conduct complicated data retrievals. In addition, it often too labor intensive
for an individual to manually cross-reference even a small number of data files in a timely manner.
Depending on the particular needs and circumstances of individual localities, however, a
manual data base may be sufficient'. Data collected through the source identification process can
be entered on data sheets and organized according to land-use categories, U.S. Standard
Industrial Classification (SIC) codes, or parcel identification numbers. It is, however, highly
desirable to generate index files to facilitate efficient data searches. Furthermore, a data
maintenance procedure should be developed to keep the data file up-to-date and to protect the
integrity of the data base.
6.2.2 Computerized Data Base Management Systems
Data Base Management Systems (DBMSs) were developed to manage the sharing of data
in an orderly manner. The primary objective of a DBMS is to permit a user to deal with a large
quantity of data and to perform complex data processing tasks. In addition, with DBMSs, data
from many sources can be integrated and presented in reports that are concise and
understandable.
The advantages of DBMSs include their great flexibility, which permits existing data to be
used for purposes that were not envisioned when it was collected; data usage is less restricted
than with manual filing structures; centralized control of data helps ensure the integrity of the
data base: the ease of conducting unique data base searches; the lessening ol data redundancy as
a DBMS can be used to monitor and update multiple copies of data files; and the increased
overall control over data security and the accessibility of the data base to various individuals.
Conversely, there are a number of disadvantages associated with DBMSs. These
disadvantages include the added costs of hardware and software acquisition and maintenance, the
additional training of users that is often needed to make the DBMS operational, and the
centralized risk of losing or corrupting the data due to insufficient backup and recovery
procedures.
6.2.3 Spreadsheets and Data Base Management Systems
Electronic spreadsheets and structured data base management systems can both be
considered computerized data base management systems, although spreadsheets are more limited
in their data processing capabilities. Using the sorting and limited data searching capability of a
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spreadsheet program, a data base can be used effectively to provide information for analysis and
decision-making.
Setting up a data base management system is complicated and expensive. However, the
long-term benefits of using DBMS technologies can easily outweigh the costs, because these
systems provide a much better basis for complex data processing, decision-making support, and
cross program integration.
Cape Cod Aquifer Management Project
An intensive land-use study within a WHPA in the town of Barnstable,
Massachusetts was undertaken by the Cape Cod Aquifer Management Project
(CCAMP). The goal of the study was to obtain a more detailed understanding of the
information necessary for an effective resource-based ground-water management plan.
A thorough inventory of the land-use data within the WHPA was conducted on the data
from existing regulatory programs at all levels of government. Information gathered
from the various programs was organized in a hierarchical set of dBase III files; dBase
III is the trademark of a computerized DBMS. A master dBase file contains the parcel
number, map number, land-use category, business name and address, sewer information,
and the presence of various land-use regulatory programs associated with that particular
parcel. Additional data files containing specific program information were developed on
the basis of map number, parcel number, and business name. By linking these data files
together, CCAMP was successful in providing an excellent characterization of the use of
hazardous materials and the risk posed to the public-water supply within the WHPA.
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6.2.4 (ieographic Information Systems
A Geographic Information System (GIS) is an integrated DBMS that presents a graphic
picture of the locations of sources in relationship to other data elements (e.g., longitude/latitude,
water supply wells, underground storage tanks, pipelines, land parcels, buildings, ponds, etc.). The
GIS contains a base map and several layers, representing land-use activities, soil types, and
vegetation types.
A GIS is capable of performing input, storage, retrieval, analysis, output, and display of
geographically or spatially-indexed data. An operational GIS allows users to encode, analyze, and
display data layers from a variety of sources, such as field notes, land-use and zoning maps,
topographic maps, aerial photographs, and satellite images.
The first step in implementing a GIS project is to obtain base maps and source maps ol
the area(s) of interest. It is of great importance to evaluate these maps based on the following
criteria: scale, accuracy, level of detail, date the map was produced, and consistency with other
maps. Once a base map is selected for the GIS project, spatial data can be encoded based on a
commonly used coordinate system. Similar to spatial data, attribute data may also vary greatly in
quality. Generally, a large volume of attribute data is available in paper format without proper
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geo-reference. Once a GIS data base is completed, data verification must be carried out to
determine if the data are accurate, truthful, and free of data entry errors.
With an operational GIS, spatial data searches can be performed on the GIS data base
using a variety of commands (e.g., locate all small quantity generators within a WHPA). In
addition, encoded geographic data may be manipulated by users to extract and display desirable
information in a variety of ways (e.g., maps, tables, and statistics). GIS technology was used in the
CCAMP project in Massachusetts to assess the risk of contamination to public water supply wells
from a number of different sources. (See Appendix B for this case study.)
The establishment of a GIS is a major undertaking. A fully functional GIS is often very
expensive and costly to implement, although less expensive desktop mapping systems have become
increasingly sophisticated and user-friendly. It is important to point out that for most GIS
applications, the development of data is often the most resource intensive part of the system.
The dynamic nature of most physical and cultural phenomena make data base development a
continuous process for every operational GIS. In addition, training of users often is required to
make a GIS functional.
A fully functional GIS can be an extremely useful resource. Wellhead protection
managers can use the system to scan a particular area for potential sources of contamination (e.g.,
industrial structures, underground tanks). The system is a useful tool for managing and organizing
information from a variety of sources. In this way, several environmental protection programs
could utilize and contribute to the data contained on GIS.
6J Maintaining GIS and Data Bases
All data management systems, including GISs, require some sort or' periodic maintenance.
Data maintenance for a source inventory can begin when a preliminary list of potential sources
has been compiled. Since a successful WHP program is dependent on data of known quality,
locational and source attribute information must be verified to meet established data standards.
Once an inventory has been completed, the data must continue to be updated. The dynamic
nature of most physical and cultural phenomena make data base development ;i continuous
process. It may be necessary to reinventory the WHPA every few years. Under a proper data
management scheme, the data must be securely stored to minimize any chances of accidental
destruction or gradual degradation over time. It should also not be possible for any unauthorized
persons to alter the contents of the data.
Through data base verification and updating, a computerized data management system can
be fine tuned and modified to increase the effectiveness and efficiency of the system for data
retrieval and analysis. Maintenance of a computerized data base also can involve training of new
users and updating the skills of previous users whenever modifications are made to the system. In
addition, backups and recovery procedures should be well established to minimize the risk of
losing data due to error or malfunction.
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7.0 USING THE INVENTORY TO PROTECT WATER SUPPLIES
The ultimate purpose of a source inventory is to protect underground supplies of drinking
water. This section discusses a number of ways in which officials can use the information from
the source inventory to protect their wellheads. We organize this section into three different
tools for wellhead protection:
1. Priority Setting
2. New Zoning and Health Regulations
3. Developing a Pollution Prevention Policy
7.1 Priority Setting
Officials can use the information gathered through the source inventory process to help
them to establish action priorities within their WHPA. WHPA managers can evaluate the risks
posed to the WHPA and prioritize their management efforts. For example, managers can use
risk-based source ranking systems to identify which of many potential sources of contamination
pose the greatest risk to the well. Such tools, however, require a great deal of input data, such as
a complete list of potential sources, that officials can gather through a well-structured source
inventory.
Priority-setting techniques can vary from simple screening and ranking tools to
sophisticated, site-specific risk models. If managers are interested in a tool to help them plan
land-uses within a WHPA, a simple risk ranking tool may be sufficient. If the ground-water is
already contaminated, however, a full, sophisticated risk assessment may be necessary to choose
the appropriate remedial action technique. EPA has developed several risk-based tools for
different applications. These tools include the following:
• DRASTIC, which evaluates ground-water vulnerability to
contamination;
• the ground-water pathway ol the Hazard Ranking System;
• the Office of Ground Water and Drinking Water's abandoned well risk
assessment methodology; and
• GWPD's Managing Contamination Sources in Wellhead Protection
Areas: A Priority Setting Approach.
The results from such assessments can be used to assist managers in a number of ways
including:
• prioritizing source management efforts; e.g., site inspections, monitoring,
data collection, enforcement actions, and education;
• identifying planning and zoning approaches aimed at controlling the siting
of new potential contamination sources; and
• - conducting vulnerability assessments.
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7.2 New Zoning and Health Regulations
Identification of potential sources of contamination will be meaningless unless steps are
taken to prevent the potential threat from becoming an actual problem. Most states have
delegated to local authorities the right to adopt and enforce laws that are necessary to protect the
public health and welfare. At the local level, the major tools that are used to accomplish these
goals include zoning and health regulations. Once individual threats have been identified through
the source inventory process, a community can determine the most appropriate techniques to
regulate their future use or location.
Zoning regulations are used throughout the U.S. to control or prohibit conflicting land
uses within a jurisdiction. Zoning is most useful for directing future land use, rather than altering
present use or existing development. Furthermore, zoning controls are generally adopted for an
area only after development pressures grow. Because pre-existing land uses and their associated
materials management practices may become "grandfathered" under a new land use management
plan, zoning ordinances can not be relied on to remedy all past and present activities that pose a
threat to ground-water quality. Furthermore, as a result of differences in administrative time and
staff, planning expertise, political will, and statutory authority, the ability of local jurisdictions to
develop and enforce zoning programs varies significantly across the country.
MASSACHUSETTS' STATE ZONING ACT
In Massachusetts, the State Zoning Act (M.G.L. ch.40A and ch. 808) specifically
includes the conservation of natural resources as a purpose of zoning. At least 75
communities in Massachusetts have adopted the use of overlay district zoning to further
control potential contaminant sources in sensitive natural resource areas. Several
Massachusetts towns have instituted large lot zoning for water supply protection and
other conservation purposes. These types of zoning initiatives can help to regulate
sources and potential sources of contamination within sensitive natural resource areas.
Several Massachusetts towns have instituted large lot zoning for water supply protection
and other conservation purposes. These types of zoning initiatives can help to regulate
potential sources of contamination.
CS-19
A thorough source inventory will serve lo identify the potential activities of concern within
the wellhead area. Although zoning can provide only limited relief from sources that are already
located within a WHPA, zoning regulations can be used effectively to limit future land use
activities within sensitive natural resource areas or WHPAs. Zoning regulations can prohibit
incompatible uses within critical areas, incorporate density limits which may affect the number of
septic systems in a given area, require special use permits, or set performance standards for
specified activities.
In areas that are not developed to the full potential of their existing zoning classification,
communities can seek to "downzone" or to impose restrictions, such as management practices, on
specific activities within the area of concern.
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Municipalities and counties are generally delegated wide-ranging authority to adopt rules
and regulations to prevent threats to the public health. Standards for septic systems and
requirements for sewage hook-up are common examples of the use of this authority. More recent
applications of this power are found in the adoption of local ordinances that govern the storage
and handling of hazardous substances specifically to prevent contamination of ground-water
supplies. As with zoning regulations, health regulations are most effective when applied in a
prospective manner; that is, before a situation or activity within the wellhead area becomes a
problem. Moreover, health regulations may be able to impose restrictions on existing activities or
practices within a wellhead area, depending on the nature of the threat and the specific powers
that have been delegated to local government.
PORTLAND. OREGON'S WATER QUALITY PROTECTION PLAN
The City of Portland, Oregon, reiies on an wellfield that draws from an aquifer
along the South Shore of the Columbia River for emergency and supplemental water
supply. Due to limited areas for economic growth, the city is also promoting industrial
growth in this area. Recognizing the potential incompatibility between these two uses,
Portland developed a water quality protection plan. The plan includes prohibitions or
controls on specified high-risk activities, land use and building regulations, traffic
controls, and specifications for control and treatment of runoff. An integral part of the
plan is the Columbia South Shore Hazardous Materials Containment Facilities Design
Handbook which includes specifications for facilities that are located within the water
protection area.
CS-20
For a more detailed discussion of the role of zoning and health regulations as a part of
your WHP program refer to the USEPA publication Wellhead Protection Programs: Tools for
Local Governments (EPA 440/6-89-002).
7.3 Developing a Pollution Prevention Program
Once communities have identified potential sources of contamination in their WHPA, they
can use that information to control future contamination by developing a pollution prevention
program. In addition to the steps discussed earlier in this chapter, such as priority setting and
development of local land use controls, EPA encourages communities to adopt a Pollution
Prevention Strategy. Pollution prevention is a long-term, proactive waste management technique
that aims to reduce or eliminate any waste at its source. Using data from the source inventory,
oli'icials can target facilities that will benefit from pollution prevention techniques; benefits to
individual facilities will advance the overall community goal of protecting the water supply. The
following discussion presents three categories of pollution prevention techniques recognized by
EPA that officials can use or seek help in implementing at these targeted facilities. These
techniques include the following:
• Source reduction. Involves several process modifications designed to
reduce the amount of waste generated, such as changes to input materials.
chanties to equipment and other technological changes, re-designing
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processes to reduce waste generation, maintaining and managing equipment
and materials to minimize the opportunity for accidental releases, waste
separation to improve recovery of usable materials, and employee waste
minimization training and supervision.
• Recycling. Involves the use, reuse, or reclamation of a waste product as a
substitute for raw materials or ingredients. Recycling can occur on-site, or
it can be done off-site by 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 raw materials for fertilizer
manufacturing.
• Treatment. This least preferred pollution prevention technique involves
processing hazardous waste after it is produced to reduce its toxicity or
volume. Source reduction and recycling are preferable over treatment
since treatment still involves the production of wastes. Nonetheless,
treatment is preferred over the disposal of raw waste materials.
Localities can seek help in developing and implementing these pollution prevention
techniques through a variety of sources. Many states and inter-state authorities have organized
pollution control offices or programs that play a critical role in providing technical assistance to
localities.
NEW ENGLAND WASTE MANAGEMENT AUTHORITY
OFFICIALS' ASSOCIATION
The New England Waste Management Officials' Association (NEWMOA) is a
regional organization comprised of state environmental agencies in the Northeast.
NEWMOA serves Northeastern states, academic institutions, and the private sector with
pollution prevention efforts. The organization is developing a regional, centralized
waste reduction clearinghouse and data bank to facilitate technology transfer throughout
the region. In addition, it provides states with direct technical assistance on facilitating
source reduction measures at specitlc industries common throughout the region. To
support this effort, NEWMOA recently published brochures for the dry cleaners and
automanufacturers educating them specifically about techniques for preventing pollution.
With support from area experts from the academic, government and industrial sectors,
NEWMOA is developing a program that will reduce pollution before it is generated.
CS-21
EPA is encouraging the establishment and expansion of such State programs through its
Pollution Prevention Incentives for States grant program. In fiscal years 1989, 1990, and 1991,
EPA awarded a total of $15 million to 56 State and interstate organizations to conduct
demonstration projects, provide direct technical assistance to local governments, industry, and
businesses, and institutionalize multi-media pollution prevention as an environmental management
priority.
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EPA has established the Pollution Prevention Information Clearinghouse (PPIC) to help
disseminate information on pollution prevention opportunities. The PPIC can help States and
localities establish pollution prevention programs, identify technical process options to reduce
pollution, discover grant and project funding opportunities, locate and order documents, as well as
other activities. Additional details regarding this resource can be found in Appendix C. As noted
in our discussion of source identification techniques, business owners are often unaware of the
potential impacts of their activities on the local water supply. A community that can not only
identify the potential problems, but also help to formulate solutions will go a long way towards
ensuring the long term quality of their water supply.
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8.0 SUMMARY
This Technical Assistance Document (TAD) provides a range of suggestions for state and
local water managers to develop and refine methods for inventorying existing and potential
sources of contamination. The intention of this document is to identify several methods that
make up a comprehensive source identification program. This TAD is not meant to provide an
exact recipe for conducting source identification activities, hut a resource of valuable source
identification options.
A community's unique situation will dictate the composition of source identification
methods it chooses to pursue. If resources are limited, a community may choose to alter its
inventory process to fit its specific needs. Ideally, each community should strive to conduct the
most complete inventory possible given its situation and the resources available to it.
By using this.TAD as a guide states and local water managers can assess their existing
abilities and available resources, while implementing one or many of the suggestions identified in
this document. By examining the case study examples provided, lead agencies can interpret the
organizational and environmental circumstances in their state, and consider how these examples
provide analogies for building their own source identification programs.
Inventorying contamination sources is one of six elements in the Wellhead Protection
program. Although this document has focused on the techniques associated with only one of
these elements: source identitlcation, it is evident that the achievements gained during source
identification will contribute to progress in other areas of a Wellhead Protection program. For
example, knowledge gained through a source inventory process will provide water managers with
valuable information when preparing contingency plans or siting new wells. In the same way,
progress made in other element areas may further source identification efforts. For example,
wellhead delineation will limit the area for which a source identification search need be applied.
Wellhead protection managers also may choose to utilize the source identification process
to enhance many of the community's management tools (e.g., zoning ordinances, design standards,
source prohibitions, ground-water monitoring, public education). These tools, whether combined
or used alone will benefit from source identification efforts. For example, if the local water
agency has been able to identify the sources of contamination in a WHPA, they can target
appropriate rules and ordinances to that community.
In whatever capacity state and local water managers choose to use the source
identification method, it can contribute to overall ground-water protection. By identifying existing
or potential sources of contamination, water managers can prevent the spread of contamination
into the Wellhead Protection Area and ultimately, the ground-water supply.
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9.0 CASE STUDY REFERENCES
The sources listed below were used to develop the case studies included in this document.
1. New York Data Bases
Kevin Roberts
New York State Department of Environmental Quality
Water Quality Division
(518) 457-3656
2. Florida Data Bases
Rodney Dehan
Florida Department of Environmental Protection
(609) 488-3601
3. Massachusetts' Land Use Data Bases
Mary Wheeler
Massachusetts Department of Environmental Protection
(617) 292-2929
4. Vermont Health Department Surveys
David Butterfield
Vermont Department of Water
Resources and Environmental Engineering -- Water Quality Division
(802) 244-5638
5. Florida's Land Use Locator System
Rodney Dehan
Florida Department of Environmental Protection
(609) 488-3601
6. Maine Source Inventories
Terry Mingel
Maine Division of Human Services
Department of Health Regulations
(207) 289-5694
7. Sugar Land, Texas
Brad Cross
Texas Water Commission
(512) 371-6321
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8. Central and Northeastern South Carolina
Stanley M. Swartzel
Assessment and Development Section
Ground-Water Protection Division
South Carolina Department of Health and Environmental Control
(803) 734-5465
9. Cuba, Missouri
Evan A. Kifer
Missouri Department of Natural Resources
Division of Geology and Land Survey
P.O. Box 250
Rolla, MO 65401
10. Texas Case Studies
Brad Cross
Texas Water Commission
(512) 371-6321
11. North Kingstown and Hopkinton, Rhode Island
Terry Simpson
UIC Inventory Coordinator
(401)277-2234
12. Southwestern, Maine
Terry Mingel
Maine Division of Human Services
Department of Health Regulations
(207) 289-5694
13. Springfield, Ohio
Dick McClish
Ohio Environmental Protection Agency
Division of Ground Water
(614) 644-2894
14. Tallahassee. Florida
Rodney Dehan
Florida Department of Environmental Protection
(609) 488-3601
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15. Waverly, Nebraska
Bruce Hanson
Nebraska Department of Environmental Control
Ground Water Section
(402) 471-2186
16. Woodburv, Connecticut Land Use Survey
•f ' S
Fred Banach
Connecticut Department of Environmental Protection
(203) 566-7049
17. Waverly, Nebraska Source Inventory Demonstration
Bruce Hanson
Nebraska Department ol Environmental Control
Ground Water Section
(402) 471-2186
18. Cape Cod Aquifer Management Project
Mary Wheeler
Massachusetts Department ol Environmental Protection
(617) 292-2929
19. Massachusetts' State Zoning Act
Mary Wheeler
Massachusetts Department of Environmental Protection
(617) 292-2929
20. Portland, Oregon's Water Quality Protection Plan
City of Portland, Department of Water
(503) 796-7770
21. New England Waste Management Olficals' Association
Terri Goldberg
New England Waste Management Olficals' Association
(617) 367-8558
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APPENDIX A
BIBLIOGRAPHY
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Page A-l
APPENDIX A
BIBLIOGRAPHY
Association of State and Interstate Water Pollution Control Administrators. May 1990.
Proceedings of the State Congress on Pollution Prevention.
Clean Water Act. 33 United States Code §1251-1387. Title IV, §402, Permits for National
Pollutant Discharge Elimination Systems.
Clean Water Act.' 33 United States Code §1251-1387. Title IV, §311, Spill Prevention Control
and Countermeasures.
Davis, Micheal, J. August 1989. Unregulated Potential Sources of Groundwater Contamination
Involving the Transport and Storage of Liquid I-'ueh: Technical and Policy Issues. Argonne
National Laboratory, Argonne, Illinois.
Management Information Service. 1990. (Jroiindwatcr Protection: Local Success Stories.
International City Management Association: Washington D.C. Vol. 22, No. 2, February
1990.
Nebraska Wellhead Protection Program. 1989: Source Identification Inventory Report. Nebraska
of Environmental Control, Water Quality Division. Groundwater Section.
Resource Conservation and Recovery Act. 42 United States Code §6091 et seq. Subtitle C,
Managing Hazardous Wastes.
Resource Conservation and Recovery Act. 42 United States Code §6091 et seq. Subtitle I,
Underground Storage Tanks.
Safe Drinking Water Act. 42 United States Code §3001'et seq. Underground Injection Control
Program.
Supcrfund Amendments and Reauthorization Act. 42 United States Code §6091 et seq. Title III,
Emergency Planning and Community Right to Know.
Schenectady County Planning Department. Ground Water Supplv Source Protection: A Guide for
Localities in Upstate New York. Prepared in cooperation with the Capital District
Regional Planning Commission and the Ne\v York State Department of Environmental
Conservation.
Texas Water Commission. 1989. A Ground Water Protection Strategy: The City oj El Paso.
Austin. TX.
The Underground Injection Practices Council and The United States EPA, Oft ice of Drinking
Water. 1989. Slate and Local Solutions for the Protection of Underground Sources of
Drinking Water: A Success Story in the Making ... The Shallow Injection Well Program: A
Ground Water Protection Approach.
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Page A-2
United States EPA, Office of Ground-Water Protection. 1985. Septic Systems find Ground-Water
Protection: A Program Manager's Guide and Reference Book.
United States EPA, Office of Ground-Water Protection. 1987. An Annotated Bibliography of
Wellhead Protection References. EPA 440/6-87-014.
United States EPA, Office of Ground-Water Protection. 1989. Wellhead Protection: Tools for
Local Governments. EPA 440/6-89-002.
United States EPA, Office of Ground-Water Protection. May 1990. A Review of Sources for
Ground-Water Contamination from Light Industry - Technical Assistance Document. EPA
440/6-90-005. ' '
United States EPA, Office of Ground-Water Protection. May 1990. Guide to Ground-Water
Supply Contingency Planning for State and Local Government. EPA 440/6-90-005.
United States EPA. Otfice of Ground-Water Protection. May 1991. Protecting Local
Ground-Water Supplies Through Wellhead Protection. EPA 570/9-91-007.
United States EPA. Office of Drinking Water. July 1990. Revised Risk Assessment Methodology
for Abandoned Oil and Gas Wells -- Field Test Draft.
United States EPA. Ollice of Drinking Water, State Programs Division. 1990. Shallow Injection
Well Initiatives Program: Project Summaries. August 1, 1990.
United States EPA. Ollice of Ground-Water and Drinking Water. November IW1. Managing
Ground-Water Contamination Sources in Wellhead Protection Areas: A Priority Setting
Approach.
United States EPA. 1W5. DRASTIC A Standardized System for Evaluating ('•round-Water
Pollution-Potential Using Hydrogeologic Settings. EPA 600/2-85/018.
United States EPA. 1990. Final Rule on Hazard Ranking System, 40 C'FR 300. f-'cdeml Register,
vol. 55, no. 241, December 14, 1990.
United States Office of Technology Assessment. October 1984. Protecting the Nation's
Groundwater from Contamination (Vols. I and II).
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APPENDIX B
CASE STUDIES
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Page B-l
APPENDIX B
CASE STUDIES
TITLE:
EPA REGION:
CASE HISTORY:
Woodbury, Connecticut Land Use Survey for Aquifer Protection
Region 1 (CT, MA, ME, NH, RI, VT)
Woodbury is a small town of approximately 8,000 people located in
Western Connecticut. The town relies on ground water for 100 percent of
its drinking water supply. Ground water is produced from an extensive
stratified drift aquifer that is hydrologically connected to the Pomperaug
River that flows through Woodbury.
Under Connecticut law, municipalities are required to inventory land uses
within the delineated wellhead area to identify potential sources of ground-
water contamination.
Woodbury completed this requirement in the Summer of 1990 by hiring
one surveyor to conduct an extensive inventory of land uses in the town's
aquifer recharge area. The surveyor used a variety of methods and
resources to complete the inventory including phone directories, State data
bases, historical land use maps and aerial photos, personal interviews, and a
field search.
The surveyor used yellow pages phone directories including the "Business
to Business Yellow Pages" for a broad identification of current potential
sources. For additional information the surveyor reviewed a number of
data bases maintained by the Connecticut Department of Environmental
Protection (DEP). These data bases include data on water pollution
compliance, underground storage tanks, hazardous waste generators, and
community subsurface sewage disposal. Although the surveyor found the
DEP data bases helpful, they were difficult to use because of their number,
size, and they were often maintained at a variety of different locations.
To supplement information gathered from these resources, the surveyor
also reviewed historical land use maps and aerial photos maintained by the
tax assessor's office. The aerial photos were particularly helpful because of
their large size and detail. The most informative source identification
method, however, was conducting personal interviews of the fire marshall
and the town planner. The fire marshall was particularly helpful because as
a long-term resident of Woodbury and the nature of his occupation he was
very knowledgeable about commercial activities and operations in the town.
The fire department is also responsible for inspecting replacement
underground storage tanks, and receives lists under Title III of SARA
regarding the commercial use of hazardous materials in the town. Finally,
the surveyor conducted a windshield survey of land uses in the recharge
area to identify any potential sources that may have escaped identification
through the other surveying methods.
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The surveyor's source inventory identified approximately 130 high risk
sources of potential wellhead contamination. Although the town is
relatively small, the Health District Director explained that the large
number of sources is a result of the fact that nearly all commercial activity
is centered along the river which is in the aquifer's recharge area. The
Health District Director estimated that the land use survey took the one
surveyor approximately 6 weeks to complete.
CONTACT: Fred Banach
Connecticut Department of Environmental Protection
(203) 566-7049
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TITLE:
EPA REGION:
CASE HISTORY:
CONTACT:
Source Identification for Wellhead Protection in Florida
Region 4 (AL, FL, GA, KY, MS, NC, SC)
The Florida Department of Environmental Regulation (DER) will rely
primarily on two major State data bases to identify potential sources of
wellhead contamination under its Wellhead Protection Program. These
two data bases are the Ground Water Pollution Source Inventory (GPSI)
and the Water Quality Assurance (WQA) data base.
The GPSI locates all facilities that have received a DER permit allowing
discharges to ground water. In addition to facilities' locations, the GPSI
includes information on the type of discharge, volume of waste, and point
of discharge. The data base is computerized and localities have access to
the information through local DER district branch offices. Retrievals can
be made by site location, type of facility, or category of the source.
The WQA data base contains information on all other "non-permitted"
sources. Data sources for this data base includes ambient ground-water
monitoring information, investigations of ground-water contamination sites,
State hazardous waste sites, underground storage tank sites, pesticide
contamination sites, and Superfund and RCRA sites.
In a few pilot studies in the State, USGS is under contract to identify
previously unknown Class V drainage wells. To complete this task, USGS
is conducting detailed field searches and interviewing key personnel. DER
notes that Class V drainage wells are numerous in Florida and are
responsible for a significant amount of ground-water contamination.
In addition to these methods, DER will use a land use locator system
developed for Florida's ground water monitoring network. This system is
based on the property tax system and will enable officials to track historical
land use of property by counties and likely help localities identify and
locate potential sources of contamination.
Rodney Dehan
Florida Department of Environmental Protection
(609) 488-3601
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TITLE:
EPA REGION:
CASE HISTORY:
Wellhead Contamination Source Identification in South Paris, Oxford,
and Norway, Maine
Region 1 (CT, MA, ME, NH, RI, VT)
The towns of South Paris (approximately 4,000 people), Oxford
(approximately 2,500 people), and Norway (approximately 12,000 people)
share a very long, discontinuous aquifer from which they draw their
drinking water supply. Collectively, the towns hired a contractor to identify
and locate potential sources of wellhead contamination and map the
hydrogeologic setting of the aquifer and its recharge area.
In undertaking this effort, the contractor followed the guidelines for
inventorying sources of contamination established by the Maine
Department of Human Services (DHS). DHS recommends that wellhead
operators inventory potential sources in two stages: (1) conduct an initial
source inventory to characterize all potential threats to the wellhead, and
(2) after the WHPA has been delineated, conduct a more detailed
investigation of those sources of particular concern.
To inventory sources of contamination, DHS recommended in their
Wellhead Protection Program that wellhead operators "review any printed
materials that indicate the location of ... potential sources of
contamination" including "telephone directory yellow pages; business
records (such as fuel oil delivery services), state, and municipal, and county
records and permit files, historic records, and news articles." For the initial
inventory, the contractor conducted a broad review of State and EPA data
bases on CERCLA and RCRA waste sites.
After delineating the WHPA, the contractor began the detailed inventory
of sources using a variety of methods. The contractor conducted
windshield surveys, examined historical land use maps and air photos,
interviewed long-term residents, and reviewed newspaper articles. The
contractor noted that the best source of information came from long-term
residents. These people were identified by town officials as people who
may have worked at a particular facility or lived near a site for many years.
These people provided the most detailed information on a variety of
questions, including the types and amounts of chemical products used at a
particular site, site operations, and waste management practices. The
contractor also noted that reviewing newspaper articles provided the least
amount of information. The contractor concluded the detailed inventory
by interviewing at least one person for each contamination source and
conducting a detailed site inspection of each facility.
The contractor categorized each source of contamination identified as
either a potential major or potential minor source of contamination. For
all three towns, the contractor identified 18 major sources of contamination
and 23 to 24 minor sources of contamination.
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The contractor used two employees to conduct the source inventory.
These employees spent an estimated one week to identify all sources of
contamination and from one to three hours to inspect each facility.
CONTACT: Terry Mingel
Maine Division of Human Services
Department of Health Regulations
(207) 289-5694
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TITLE:
EPA REGION:
CASE HISTORY:
Massachusetts - Source Identification Case Studies
Region 1 (CT, MA, ME, NH, RI, VT)
The Commonwealth of Massachusetts has done and is in the process of
doing a variety of work regarding source identification lor Wellhead
Protection programs. Methods for identifying sources of contamination
have included mapping, regulations, and community outreach efforts.
Mapping
Cape Cod Aquifer Management Project - During the Cape Cod Aquifer
Management Project (CCAMP), an inter-agency project initiated in 1985
to develop a comprehensive, resource-based approach to ground-water
protection, an effort was made to develop a more detailed list of potential
and actual contamination sources. The CCAMP project involved
participation of Massachusetts DEP, USEPA Region 1, USGS, and the
Cape Cod Planning and Economic Development Commission. The Aquifer
Assessment committee, composed of hydrogeologists from each
participating agency, undertook the task of preparing a detailed list of
categories of sources of contamination. The committee also wanted to
determine the relationship between potential sources of contamination and
the actual contaminants that each might release. Committee members
reviewed all available literature and their personal experience to compile a
full list of potential contaminants.
A scries ol reports was published as a result of the CCAMP study,
including a "Guide to Contamination Sources for Wellhead Protection"
which provided detailed information on each land use; and regulatory
controls that may be useful to prevent contamination. The DEP currently
is distributing these reports to all ground-water dependent towns in the
State.
Additionally, the CCAMP undertook an intensive land-use study within one
wellhead protection area in the town of Barnstable. A detailed inventory
ol the land-use data within the Zone of Contribution #1 was gathered
from the data available through existing regulatory programs at all levels of
government. CCAMP's inventory ol' potential contamination sources
provided an extensive characterization of the use of hazardous materials
and the risk posed to public water supply with this ZOC. The most
overuhelming conclusion was the high potential threat posed by petroleum
products. Underground storage tanks are the most pervasive potential
contaminate source in this ZOC. There are 186 USTs within the entire
zone, a large majority clustered close to three of the public supply wells.
Further, the investigation of spills and leaks indicates that 43% of all such
incidents were due to leaking USTs and all six of the confirmed hazardous-
waste sites are the result of petroleum-product contamination.
On a site-specific basis for a particular well or waste source, the major tool
used for risk assessment statewide is the Water Supply Protection Atlas
which consists of 4 transparent overlays for nearly all of the USGS
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Page B-7
quadrangle maps for the state, including a waste sources overlay. The
Atlas is used heavily by DWS staff, other DEP divisions, consultants, local
governments, and the public in order to assess threats posed by individual
waste sources to supply wells and aquifers. The waste sources overlays
inventory major waste sources, including landfills, surface impoundments,
and hazardous waste disposal sites, but these overlays and the Atlas have
not been updated and do not include smaller potential sources of
contamination.
The DEP is also currently planning a project in the Merrimack River area
("Merrimack River Basin Municipal Capacity Building Demonstration
Project"), where parcel-level mapping of land use on a GIS will be
completed for 2 to 3 towns. A few goals identified for this project include
delineating and mapping wellhead and watershed protection areas using a
GIS and inventorying land uses and activities located within protection
areas that threaten water supplies.
The DEP has mapped, or is in the process of mapping, onto their GIS
system RCRA facilities, landfills, NPDES permit locations, ground-water
discharge permit locations, public wells, and either interim Zone Us (1/2
mile around a well) or DEP approved Zone IIs (primary recharge areas).
About 95 Zone IIs have been approved thus far.
Finally, the DEP recently completed a demonstration project which
mapped under-ground storage tanks on their GIS using street addresses.
About 10-12 towns were done on that project.
Outreach
In addition to mapping, the DEP has also provided outreach and technical
assistance to communities where they have identified underground storage
tanks at wellheads. The identification of.towns was done through a review
of Water Management applications which requested UST information on
the permit application forms.
The DEP also has an underground injection control program which works
directly with communities to identity illegal floor drains and have them
either sealed or drained to a tight tank.
Finally, the DEP has a technical assistance and outreach program which
provides towns with information and recommendations on land use and
reducing risks to public supply wells. Staff members work with
communities to identify and assess land use impacts in recharge areas of
drinking water supplies. They encourage the water department, local
boards, business interests, and residents concerned with water quality and
quantity to work together in establishing comprehensive water supply
protection measures.
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Page B-8
Regulations
In Massachusetts, community public water suppliers are required by DEP
regulations to report annually on land use in their water supply areas.
Instructions for the land use inventory require public water suppliers to
obtain a base map of each water source and locate Zones I and II for wells
and Zones A and B for surface water sources. Each land use activity that
might threaten water quality also must be identified and researched.
In addition, DEP's updated regulations for new public water sources
require the municipality to pass regulations that prohibit or restrict certain
land uses in Zones IIs prior to the source being approved for use.
During the past three years the DEP has awarded over $750,000 in grants
under a Federal grant provided to the DEP under Section 205(j) of the
CWA to regional planning agencies to do wellhead protection projects with
their member communities. Much of this funding was used for mapping
wells and pinpointing potential contamination sources. Projects are being
done by ten of the thirteen regional planning agencies.
Also in Massachusetts, community public water suppliers are required by
DEP regulations to report annually on land use in their water supply areas.
Instructions for the land use inventory require public water suppliers to
obtain a base map of each water source and locate Zones I and II for wells
and Zones A (400 ft from the 100 year floodplain) and B (1/2 mile
upgradient of Zone A) for surface water sources. Each land use activity
that might threaten water quality must be identified by water suppliers and
researched through contact with local Boards of Health, Fire Departments,
Zoning Boards of Appeals or the DEP. In addition, the Massachusetts
DEP's updated regulations for new public water sources require
municipalities to pass regulations that prohibit or restrict certain land uses
in Zones IIs prior to the source being approved for use. Examples of high
risk land use activities which are prohibited include landfills, open dumps,
junkyards, wastewater treatment plants, and facilities that treat, store or
dispose of hazardous waste.
Finally in Massachusetts, during the past three years the DEP has awarded
over $750,000 in grants, under a Federal grant provided to the DEP under
Section 205(j) of the Clean Water Act, to regional planning agencies to
develop wellhead protection projects with their member communities.
Much of this funding was used for mapping wells and pinpointing potential
contamination sources. Ten of the thirteen regional planning agencies are
participating in these projects.
CONTACT: Mary Wheeler
Massachusetts. Department of Environmental Protection
(617) 292-5929
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Page B-9
TITLE:
EPA REGION:
CASE HISTORY:
The Cuba Project
Region 7 (IA, KS, MO, NE)
A door-to-door survey was used in Cuba, Missouri to help identify Class V
well types and other sources of contamination. Cuba is a small town in
southeast Missouri with a population of about 2,000. The Cuba Project
was designed in two phases. Phase I was a door-to-door survey, while
Phase II was a dye tracing experiment.
The door-to-door survey was designed specifically for Cuba. It included
questions addressing possible residential, commercial, and industrial
contamination sources such as: the location of active or abandoned wells,
cisterns, fuel oil tanks, heat pumps or septic systems, and the location and
storage of chemicals used in businesses. The surveyors also noted any
wells, cisterns, and storage tanks that they spotted while conducting the
survey.
As a supplement to the door-to-door survey, State and local agencies were
consulted for pertinent information or existing data bases that applied to
this study.
The information from the State and local agencies was combined with the
results of the door-to-door survey to develop a comprehensive listing. The
door-to-door survey revealed 465 possible sources of contamination that
were unknown previous to the investigation. These sources included: 103
above ground storage tanks, 73 underground storage tanks, 115 Class V
wells, 149 active water wells, and 21 chemical storage locations.
Phase II of this study focused on the effect that septic tanks in unregulated
areas have on local ground-water quality. Ten houses participated in this
study in which two gallons of liquid dye were flushed down each toilet.
Dye detectors were then placed in each toilet to monitor the presence of
dye in the incoming water supply. This study revealed that although no
dye was present in the drinking water, septic tanks often overflowed during
periods of wet weather. This indicates that septic tank effluent may be
leaching into and contaminating the ground water.
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Page B-10
TITLE:
EPA REGION:
CASE HISTORY:
Waverly, Nebraska Source Inventory Demonstration
Region 7 (IA, KS, MO, NE)
Officials from a variety of agencies including the Nebraska Department of
Environmental Control (NDEC), Nebraska Department of Health, and the
City of Waverly w6rked together in November 1989 to develop and test
techniques to identify and locate sources of wellhead contamination in
Waverly, a town of approximately 2,000 people. The NDEC plans to use
the lessons learned from the Waverly demonstration to train public water
suppliers across the State to identify sources of wellhead contamination in
their localities.
To conduct the source inventory officials used an extensive list of potential
contamination sources in conjunction with air photos of land uses in the
town. Particular land uses were identified from the air photos and checked
against the list of potential sources to determine if they merited additional
consideration. Officials found the air photos were effective, especially
where the landscape had sufficient reference points that were also specified
on local topographic maps.
Once a source of concern was identified, officials attempted to interview at
least one person who was knowledgeable about that source. This was done
to collect specific information on that source. Interviews were conducted
either in person or by telephone.
Officials then plotted the source of concern on a WHPA map using a
variety of measuring methods including measuring tapes, the surveyor's
wheel, the pace and compass method, and the optical range finder.
Overall, officials found that identifying sources of potential contamination
in the town of Waverly was not very difficult. The inventory took two
person-days to complete. The most time consuming task was gathering
information on potential sources. They recommend that to save time a
local inventory worker should conduct the personal interviews because they
are more familiar with the locale.
The source inventory in Waverly identified 33 potential sources of ground-
water contamination. Sixteen of these sources belonged to source
categories known to have contaminated ground water in Nebraska,
including eight underground storage tanks. The potential contaminants
present at these sources included waste oil, organic solvents, acids,
pesticides, gasoline, diesel fuel, and a variety of other chemical products.
The closest source was within a 60 day time-of-travel zone to one well
while other sources were more than a 20 years time-of-travel distance away
from another well.
The results of the source identification and location inventory enabled
officials to design a ground-water monitoring schedule for each well that
will serve as an early warning system for the public water supply system. In
conjunction with the monitoring program, the town will use the findings of
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Page B-ll
the inventory to assist with their contaminant source management and
contingency planning efforts.
CONTACT: Bruce Hanson
Nebraska Department of Environmental Control
Ground Water Section
(402) 471-2186
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Page B-12
TITLE:
EPA REGION:
CASE HISTORY:
Source Inventory for the Town of Meridith, New Hampshire
Region 1 (CT, MA, ME, NH, RI, VT)
Two pilot projects have been conducted in New Hampshire. The first, in
the town of Merrimack, officials indicate was successful, but the second, in
the town of Meridith, was more extensive, more thorough, and should
prove to be more successful. The purpose of the Meridith project was to
develop procedures for towns to use in inventorying their sources of
contamination. The project included using existing data-bases as well as
doing field surveys. The ultimate goal of this project is to have all towns
use these procedures in order to maintain consistency.
CONTACT:
Paul Curry
New Hampshire Department of Environmental Services
(603) 271-3503
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Page B-13
TITLE:
EPA REGION:
CASE HISTORY:
New Jersey Data Base and Mapping Efforts
Region 2 ( N.I. NY, PR, VI)
New Jersey uses a State-wide data base as a method for.identifying sources
of contamination. Although New Jersey is in the draft stage of
inventorying sources, currently, an Arc-Info based GIS is being used that
contains data on Superfund sites, known and suspected pollution lists,
NJPDES (ground and surface water discharges) and SARA Title III.
Gathering the data, however, is too big a job for the New Jersey
Department of Environmental Protection (NJDEP) alone because there
are so many entities from which to gather data. The NJDEP relies on
those being regulated to provide them with information for their local GIS.
New Jersey Mapping Efforts
Although no law requires municipal involvement with WHP, the New
Jersey Department of Environmental Protection (NJDEP) has been
encouraging local action for source identitlcation. The NJDEP has
provided localities with a base map of their area as a starting point for
local inventories. However, integrating existing NJDEP maps with those of
created through municipal inventories will be needed but has not been
planned to date. Officials have indicated a problem yet to be faced with
these maps is accuracy. Locations on the maps are based on latitude and
longitude, but more accurate global positioning would result in better
quality maps.
CONTACT:
Dan Van Abs
N.J. Department of Environmental Protection
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Page B-14
TITLE:
EPA REGION:
CASE HISTORY:
New York
Region 2 (NJ, NY, PR, VI)
New York's Wellhead Protection submittal indicated that there was no
uniform method for inventorying sources of contamination, but that their
priority would be on known sources of public water contamination.
However, officials indicate that the key source identification method used
is an industrial chemical survey data-base in which all industries report
average annual uses. It is a very broad data-base but can be manipulated
in various ways, e.g., to search for a single chemical. Local governments
have access to the industrial chemical surveys and a number of localities
are using them. Another data-base used as a source identification method
is a bulk storage data-base. In addition, New York is in the planning
process for developing better pesticide usage data. The existing data-bases
used for source identification overlap each other, but work is being done
towards unifying existing data-bases and a GIS objective is being
maintained.
Site-specific inventories are in the process of being completed with the
help of funding under Section 205(j) of the CWA; however, no
documentation is available regarding those inventories until those projects
are completed.
Officials indicate that a major problem of WHPPs will be funding,
particularly given the current economic situation which forces programs to
reevaluate their priorities. However, ground-water and aquifer protection
programs are considered very important to New York and it has been
suggested that those programs would not be tremendously affected.
CONTACT:
Kevin Roberts
NYSDEC, Water Quality Division
(518) 457-3656
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Page B-15
TITLE:
EPA REGION:
CASE HISTORY:
Butler, Clennont, Hamilton, and Warren Counties, Ohio
Region 5 (IL. IN, MI, MN. OH, WI)
In June 1988 the Ohio-Kentucky-Indiana Regional Council of
Governments (OKI) conducted an extensive review of potential sources of
aquifer contamination in four counties in southwestern Ohio. The ground-
water resources of the greatest concern are those of the Great Miami
River buried valley aquifer system which supplies drinking water to two-
thirds of a million people, or one-half of the area's population.
OKI categorized potential pollution sources into nine different areas: liquid
waste disposal sites, solid waste disposal sites, hazardous waste generators
and/or disposal sites, concentrations of onsite wastewater treatment
systems, land application, road salt storage sites, animal feedlots, sand and
gravel extraction sites, and cemeteries. OKI relied primarily on existing
State and Federal data bases to identify sources in each category and
supplemented this information with personal interviews, maps, and
telephone directories. Source identification methods for each category are
detailed below.
Liquid Waste Disposal Sites - OKI identified liquid waste disposal sites
from the pits, ponds, and lagoons that are listed in Ohio EPA's Surface
Impoundment Assessment file.
Solid Waste Disposal Sites - OKI identified active and closed sites from a
list of Licensed Solid Waste Disposal Facilities maintained by Ohio EPA's
Division of Solid and Hazardous Waste Management. OKI identified
demolition landfills through conversations with each county's Board of
Health. OKI also recommends contacting building trade associations for
additional information on the location of demolition landfills. OKI
identified closed dumps from existing lists it maintains as well as the
CERCLIS list. OKI further recommends interviewing county engineers
regarding location of illegal dumps.
Hazardous Waste Generators and/or Disposal Sites - OKI used the
CERCLIS list and sites subject to RCRA regulations to identify potential
sources in this category.
Onsite System Concentrations - OKI used previous studies it conducted as
well as soils suitability maps developed tor onsite septic treatment systems
and conversations with county health department staff to locate potential
sources in this category.
Land Application of Sludge - OKI identified sites in this category by
reviewing Sludge Management Plans filed with Ohio EPA. OKI
recommends however that each management agency should be contacted
tor the most current information because new land application sites can be
added to an existing sludge management plan.
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Page B-16
Road Salt Storage Sites - OKI interviewed personnel from the Ohio
Department of Transportation and from county engineer, township, and
municipal offices to identify sites under this category. OKI also
recommends contacting commercial sellers of road salt and airports for
.'.dditional information if necessary.
Animal Feedlots - OKI obtained the locations of animal feedlots from each
county's Soil and Water Conservation District and/or Soil Conservation
Service office.
Mineral Extraction Sites - Mineral extraction site locations and
owner/operators were identified from a report prepared by the Ohio
Department of Natural Resources (ODNR). OKI recommends that this
information be verified through questionnaires sent to all facilities. More
specific locations and other information were provided by ODNR's
Division of Reclamation. OKI also recommends that the U.S. Army Corp
of Engineers permit system be reviewed for sites not permitted by ODNR.
Cemeteries - OKI identified cemeteries through the most recent yellow
pages phone directories for a number of cities/towns. OKI contacted these
sites for additional information. OKI recommends that a cemetery trade
association should be contacted, if possible, regarding a complete list of
active cemeteries including minor cemeteries that are often overlooked.
A.S a result of OKI's inventorying methods, its June 1988 survey identified
403 sites lying directly over local aquifers. Thirty-five of these sites are
considered medium or high priority sites listed under CERCLA.
In continuation of this work, OKI is currently developing a ground-water
protection and management strategy. As part of that effort it has
identified five new categories of potential aquifer pollution sources:
hazardous material sites, sites of reported spills, auto salvage sites,
commodity transfer points, and wastewater treatment plants. The majority
of information identifying sites under these new categories will come from
existing lists and data bases, including data filed under SARA (for
hazardous material sites and commodity transfer points) and records from
Ohio EPA's Division of Emergency Response (for sites of reported spills).
OKI points out, however, that such sources of information are being
located only now and may likely change as staff actually begin to identify
and locate sources.
CONTACT: Jane Wittke
OKI Regional Council of Governments
(513) 621-7060
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Page B-17
TITLE:
EPA REGION:
CASE HISTORY:
CONTACT:
Ohio
Region 5 (IL, IN, MI, MN, OH, WI)
The Ohio Division of Ground Water conducted an inventory of potential
pollution sources in Springfield's wellhead protection area. An initial
inventory was conducted by a windshield survey of all roads in the area.
Notes were taken on existing facilities and land uses and then were located
on USGS 7'/2 minute topographic maps. Meetings were held with various
local and county officials to gain more information about past, current, and
proposed activities in the area. Division staff found each of these
individuals very helpful and received a large amount of useful information
from them. Ohio EPA offices and other State agencies also were
consulted.
The second stage of information gathering and inventorying consisted of
personal interviews which were conducted with several local industry
managers, farmers, and commercial businessmen. An introductory letter
was sent to each facility followed by a phone call and site visit. Although
this process was time consuming, it served several valuable purposes. Staff
were able to obtain detailed information on industry processes,
management practices, and pollution threats, but these visits were equally
valuable as an educational and public involvement tool. The individuals
visited were given a basic understanding of Springfield's wellfield and local
aquifer, and how their activities could potentially impact the quality of the
ground water resource. Ohio EPA staff found that, although most people
they talked with were aware of the wellfield, they had little idea that their
activities and management practices could affect the water quality of these
wells. These interviews introduced them to the concept of wellhead
protection.
From its studies, the Ohio EPA found that the inventory process need not
be costly, but it may require considerable labor. The key to a successful
and cost effective inventory is identification of existing sources of
information. A large amount of data already exist and duplication of effort
should be avoided. Although conducting individual site assessments is
extremely time consuming, it is believed to be a critical component of the
inventory. The ultimate success or failure of a local wellhead protection
program depends on the education and cooperation of the individuals
located within the protected area.
Dick McClish
Ohio Environmental Protection Agency
Division of Ground Water
(614) 644-2894
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Page B-18
TITLE:
EPA REGION:
CASE HISTORY:
CONTACT:
Rhode Island
Region 1 (CT, MA, ME, NH, RI, VT)
Of the seven methods used in the pilot project on methods of inventorying
sources, the director of the project highly recommended the windshield
survey, although there might be restrictions on this method depending on
the size of the area to be surveyed, terrain, or the surveyor's access to a
vehicle. It is a fairly easy method to use, although it is recommended that
two people go together in the car so one can take notes while the other
drives. This method gave the most complete information of any single
method used alone and was fairly time efficient when compared with the
number of other information sources which must be consulted to come up
with a similar number of potential sources of contamination. In the pilot
project, this method worked well both in a rural and in an urban
community.
Terry Simpson
UIC Inventory Coordinator
(401) 277-2234
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Page B-19
TITLE:
EPA REGION:
CASE HISTORY:
South Carolina
Region 4 (AL, FL, GA, KY, MS, NC, SC)
The South Carolina UIC program conducted a project to evaluate Class V
wells and other potential sources of ground-water contamination near
public water supply wells in five South Carolina communities. The study
was conducted in areas deemed to have geology particularly vulnerable to
ground-water contamination. Two of the study communities were small,
rural areas, while the other three had moderate to high population
densities. The study in the most densely populated area involved an
extensive wellfield with 27 public water supply wells.
For this inventory, information about potential sources was first obtained
from various government agencies, offices within the South Carolina
Department of Health and Environmental Control, county officials, and
various private businesses and professional associations. After this
information was compiled, a detailed drive-through visual survey of each
area was conducted. Every road in each study area was travelled and the
pertinent information recorded. Every facility which was suspected of
containing a potential contamination source was then contacted by
telephone. Facilities inaccessible by telephone and those for which visual
inspection was deemed necessary were visited in order to conduct personal
interviews and inspections.
All of the potential sources of contamination within 2 miles of the selected
public water supply wells were mapped and rated as low, medium, high, or
very high, according to their potential for impacting the water supply. A
distance of 1000 feet from each well circumscribed an area of greater
concern, and facilities within this area increased their pollution potential
rating by one degree.
A total of 485 potential sources were identified and examined. Of these,
219 were identified as sources which could potentially contaminate public
water supply wells. It was discovered that 101 facilities were in need of
corrective or compliance actions ranging from submittal of the proper
permit applications to permanent system abandonment with possible
assessment and remediation requirements. As a result of this project, the
SC UIC Program has added 41 injection wells to its inventory and the SC
UST Program became aware of 35 unpermitted underground storage tanks.
In conducting this survey, the initial time allotted for deciding which types
of facilities to direct the most attention to, and the most reliable sources to
approach for information, greatly increased project efficiency. Government
contacts at the local level proved especially valuable and relatively efficient
for the amount of information gained. The proposed personnel resource
allocation of one-half work year was exceeded by two months, and the
amount of follow-up work needed to bring the 101 facilities into regulatory
compliance is estimated at two work years.
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Page B-20
CONTACT: Stanley M. Swartzel
Assessment and Development Section
Ground-Water Protection Division
S.C. Department of Health and Environmental Control
(803) 734-5465
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Page B-21
TITLE:
EPA REGION:
CASE HISTORY:
CONTACT:
South Dakota
Region 8 (CO, MT, ND, SD, UT, WY)
The East Dakota Water District conducted a Class V demonstration
project in a predominantly agricultural area. Over approximately 100
square miles, all landowners were contacted by telephone and asked about
potential sources of contamination such as abandoned wells, irrigation and
chemigation systems and livestock. Data was collected for all locations
which contain livestock, not just those qualifying as feedlots.
Jerry Siegel
Manger, East Dakota Water District
(605) 692-5185
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Page B-22
TITLE:
EPA REGION:
CASE HISTORY:
Texas
Region 6 (AR, LA, NM, OK. TX)
El Paso
In El Paso, Texas, door-to-door surveys of all potential contamination
sources around public water supply wells wer-c conducted by senior citizen
volunteers. The city of El Paso has a population of about 590,000 and is
located in the far western tip of Texas. El Paso's geology consists of
aquifers which exist in basins filled with non-uniform deposits of clay, sand,
and gravel. Aquifers exist at shallow, intermediate, and deep levels, and
there is no impermeable geologic stratum of regional extent, so ground
water moves between them in response to hydraulic pressure.
The Texas Water Commission delineated WHP areas around El Paso's
PWS wells using the calculated fixed radius method with a travel time of
five years. The completion of the inventories of potential contamination
sources within these areas was the responsibility of the local government.
In El Paso, members of the Retired Senior Volunteer Program (RSVP)
were used to help complete the inventory. This organization was found to
have the best mechanism for recruiting volunteers, as opposed to other
organizations for senior citizens which arc more socially oriented. Senior
volunteers were used because they possessed the maturity and the historical
knowledge needed for a complete inventory.
The volunteers first attended a seminar which described the WHP program,
fundamentals of ground water protection, source identification and
inventory procedures. Then, when actually conducting the inventory,
volunteers were sent out with maps of their assigned area,"inventory forms,
lists of sources, and name tags identifying them as volunteers. Extensive
media involvement had prepared the public and the volunteers did not
encounter any uncooperative individuals. Volunteers who were unable to
go door-to-door searched city and county records. .
El Paso's efforts were extremely successful. Twenty-three volunteers
inventoried sources around 138 wells in three and one-half days. They
inventoried over 1900 potential contamination sources. Alt previously
known contamination sources were identified by the volunteers. The
volunteers were very enthusiastic and wanted to survey the entire city, not
just the WHP areas. After the inventory was completed, several of the
volunteers formed a WHP Task Force committee to assure that BMP's
exist on the local level to control potential sources of contamination.
Houston
The Texas Water Commission is currently conducting a WHP source
inventory in Houston. This area has 204 public water supply wells, with 98
protection areas being delineated.
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Page B-23
The Houston Retired Senior Volunteer Program is providing volunteers to
conduct the inventory. Additionally, extensive media coverage has led to
many other sources of volunteers of all ages. For example, junior high
school classes, families working together, and college students have all
become involved as volunteers. Media involvement is important both in
recruiting volunteers and in creating a cooperative attitude in the public.
Sugar Land
This community conducted a mailed survey inventory of potential
contamination sources. The inventory form was included with the
recipient's water bill. The city obtained a 45 percent response rate for
these inventory forms. A door-to-door survey was then used to complete
the WHP inventory.
Atlanta, Silsbee. Queen City
These cities used Boy Scouts to conduct WHP inventories. The inventory
makes an excellent Eagle Scout project.
CONTACT: Brad Cross
Texas Water Commission
(512) 371-6321
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APPENDIX C
REGULATORY DATA BASES
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Page C-l
APPENDIX C
REGULATORY DATA BASES
TITLE:
DEVELOPED BY:
TIME SPAN:
UPDATING:
DESCRIPTION:
AVAILABILITY:
Toxic Chemical Release Inventory (TRI)
U.S. Environmental Protection Agency, Office of Toxic Substances,
Emergency Response Division
Data available for 1987 through 1989. Information is available two years
after the reporting date.
Annually
TRI contains a compilation of the annual release reports required under
Section 313 of the Emergency Planning and Community Right-to-Know
Act (Title III of the Superfund Amendments and Reauthorization Act of
1986). Data are required from all manufacturing facilities (SIC codes
20-39) with 10 or more full-time employees that (1) manufactured,
imported, or processed more than 75,000 pounds of any SARA Section 313
toxic chemical in 1987, more than 50,000 pounds in 1988, or more than
25,000 pounds in 1989; or (2) "otherwise used, more than 10,000 pounds of
any SARA Section 313 toxic chemical in any calendar year. Information
contained in TRI, includes:
• Facility identification: name, address, public contact number. Dun &
Bradstreet (D&B) number, and EPA Identification Number;
• Substance identification: names, uses, Chemical Abstracts Service
(CAS) Registry Number, and maximum amount onsite;
• Environmental release information: estimates of the amounts of
chemicals released into the air, water, land, and injected
underground, and the source of these releases;
• waste treatment information: condition of the general wastestream,
method, treatment efficiency, and waste minimization data; and
• off-site waste transfer information: names and addresses of wastes
transferred, estimated amounts transferred, and basis for these
estimates.
TRI is maintained on EPA's NCC and the National Library of Medicine's
TOXNET on-line service. Access via these systems would require resources
for data retrievals and analyses. TRI information is available on various
mainframes. Electronic extracts also are available for public reference.
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Page C-2
CONTACT: Mr. Bill Wallace
Information Management Division, Public Data Branch (TS-793)
U.S. Environmental Protection Agency
401 M St., SW
Washington, D.C. 20460
(202) 260-8680
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Page C-3
TITLE:
DEVELOPED BY:
TIME SPAN:
UPDATING:
DESCRIPTION:
AVAILABILITY:
CONTACTS:
CERCLA Information System (CERCLIS)
U.S. Environmental Protection Agency, Office of
Emergency and Remedial Response, Office of Solid Waste and Emergency
Response
1980 to date
Daily
CERCLIS provides an inventory of potential hazardous waste sites in the
United States. The database contains information on approximately 30,000
releases of hazardous substances reported to EPA by any interested party
(municipal authority or citizen). CERCLIS covers incidents of hazardous
chemical spills as well as hazardous waste sites nominated or selected for
cleanup under the provision of the Superfund Amendments and
Reauthorization Action of 1986 (SARA). For each site, the following
information is included:
• Site identification: EPA identification number, name, alternate
name (if applicable), geographic location (e.g., street address, city,
county, state, and ZIP code), EPA Region;
• Action taken at the site: precleanup investigations, cleanup activity
status, and for some sites, descriptions of environmental problems
encountered. During the Preliminary Site Investigation, if the site is
found to pose no environmental threat and require No Further
Action, a NFA flag, appears in this column;
• Project dates: actual start and completion dates; and
• Lead agencies.
Appropriate portions of the CERCLIS database in either electronic or
printed copy can be obtained through EPA's Freedom of Information
(FOI) office. Online services are also available through the EPA's
contractor for an annual subscription fee of $3(X).
Ms. Jeralene B. Green
FOI Officer (A-101)
U.S. EPA
401 M Street, SW
Washington, D.C. 20460
(202) 260-4048
Ms. Gloria Brooks
U. S. EPA
Office of Emergency and Remedial Response
401 M Street, SW
Washington, D.C. 20460
(202) 260-9833
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Page C-5
TITLE:
DEVELOPED BY:
TIME SPAN:
UPDATING:
DESCRIPTION:
AVAILABILITY:
CONTACT:
Hazardous Waste Data Management System (HWDMS)
RCRA Information System (RCRIS)
U.S. Environmental Protection Agency, Office of Planning, Policy, and
Information and Office of Solid Waste
1980 to date
Monthly. Information on waste types, estimated annual quantities, and
management processes contain data derived from Part A permit
applications. This data may have been updated since the Part A
information was entered, and therefore the updated information may not
be included in HWDMS/RCRIS. HWDMS data entry capabilities will be
discontinued on December 31, 1991 and final implementation of *RCRIS
will take place on January 1, 1992.
RCRIS will replace HWDMS as the national data base for tracking RCRA
Subtitle C facility-specific data as well as accomplishments.
HWDMS/RCRIS is maintained by Regions and States who submit monthly
updates to the data base. National, regional and state personnel utilize
HWDMS/RCRIS to support the implementation and oversight of RCRA
programs. The database contains permitting and compliance monitoring
activities for all generators, transporters, and TSDFs.
HWDMS/RCRIS is maintained on mainframe by EPA contractor.
Electronic extracts are available and can be converted to Lotus or dBase.
Printed output is also available. Initial information can be obtained through
written request from the EPA Work Assignment Manager through the
EPA contact listed below; followup communication occurs directly between
the requestor and the database contractor. Cost associated with data
retrieval are covered under the contractor's work assignment to maintain
the database.
Dina Villari
U.S. EPA
401 M Street, SW
Washington, D.C. 20460
(202) 260-4670
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Page C-6
TITLE: Water Management Permit Compliance System
DEVELOPED BY: U.S. Environmental Protection Agency
TIME SPAN: Mid-70s to date
UPDATING:
DESCRIPTION:
AVAILABILITY:
CONTACT:
Twice a week
The system monitors the NPDES process for permits. The amount of
relevant ocean pollution data and other data varies greatly among
approximately 2700 permits in this database. The system includes:
• Information about permittee and application process to issue
permit;
• Information on diluent units;
• Monitoring requirements for permittees.
Printed reports, CRT read outs, microforms, tapes, plots and charts are
available through EPA. Interested parties may access the database with an
account in indirect/hatch mode. Non-automated interface in the project
office is also available at no charge.
Ms. Dela Ng
Permit Compliance System
Waste Management Division
U.S. EPA
401 M Street, SW
Washington, D.C. 20460
(202) 260-8313
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Page C-7
TITLE:
DEVELOPED BY:
TIME SPAN:
UPDATING:
DESCRIPTION:
AVAILABILITY:
CONTACT:
Hazardous Material Incident Reporting System
U.S. Department of Transportation, Research and Special Programs
Administration, Information Systems Branch
1976 - present
Every 90 days
This database provides a statistical compilation of all accidents and
incidents involving hazardous materials. The system contains the following:
• Information on each reported incident; and
• Data elements: the date of the accident, location, shipper, carrier,
commodity Involved and other detailed information concerning the
packaging and nature of the incident.
Customized searches are available upon request from the Department of
Transportation. There is a $30.00 minimum charge for this service.
Ms. Evelyn Gainey
U.S. Department of Transportation
Research and Special Programs Administration Information Systems
Branch
DHM-63, Room 8112
401 M St., SW
Washington. D.C. 20460
(202) 366-4555
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Page C-8
TITLE:
DEVELOPED BY:
TIME SPAN:
UPDATING:
DESCRIPTION:
AVAILABILITY:
CONTACT:
Underground Storage Tanks Case History File
U.S. Environmental Protection Agency
Continuously
The database system is a compilation of factual data from site coordinators,
detailing corrective action methods to guide leaking underground storage
tank corrective actions. Case studies available in the database provide
technical information to Federal, State, and local officials in response to
UST releases. The database will include the following information:
• Documentation of hazardous materials spills;
• National overview of remedial and removal actions at Superfund
sites and corrective actions for UST problems;
• Alternative approaches to respond to leaking underground storage
tanks, cost estimates for these approaches, and information on the
successes/failures of alternative corrective action approaches; and
• Rationale for the selection of site characterization techniques,
various corrective action technologies, and termination of individual
corrective actions.
The system is comprised of two components, a narrative section and a
database. The data base allows the user to conduct file searches by 27
criteria to select incidents of interest. The narrative section is comprised of
ten subsections in text format which contain detailed information on
various UST incidents. Several of these subsections that may be
appropriate for source identification include: general information, chemical
information, effects, and site characterization.
The system is available tree of charge to anyone who requests it from U.S.
EPA, The system is easily accessible with a personal computer, modem, and
a telecommunications software package.
Robert Hilger
U.S. Environmental Protection Agency
Edison, New Jersey
(201) 321-6639
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Page C-9
TITLE:
DEVELOPED BY:
TIME SPAN:
UPDATING:
ABSTRACT:
AVAILABILITY:
CONTACTS:
The Pollution Prevention Information Clearinghouse (PPIC)
U.S. Environmental Protection Agency, Office of Environmental
Engineering and Technology Demonstration and the Pollution Prevention
office
1989 to date
Continuously
PPIC is a clearinghouse dedicated to reducing industrial pollutants through
information transfer. The clearinghouse contains technical, policy,
programmatic, legislative, and financial information. The following
information on various pollution prevention options also is included in the
network: periodic assessments, inventory control, housekeeping and
preventative maintenance, training, production planning and sequencing,
process/equipment modification, product substitution, waste segregation,
and recycling.
The clearinghouse can he accessed by the following four information
exchanges.
• Repository - A hard copy reference library containing exemplary
case studies; pollution prevention training and educational
materials; a compilation of successful program, legislative, and
policy initiatives at the local, state, and federal government levels;
and fact sheets.
• Pollution Prevention Information Exchange System (PIES) - A
computerized conduit to information databases and document
ordering accessible by any PC equipped with a modem.
• Hotline - A free telephone service to answer or refer questions and
provide a link to PIES for users without access to a PC; and
• Outreach Efforts - Information packets containing general and
industry-specific materials on prevention opportunities as well as
workshop training sessions.
Myles E. Morse
Office of Environmental Engineerint: and Technology Demonstration
U.S. EPA
401 M St., SW
Washington, D.C. 20460
(202) 260-3161
Priscilla Flattery
Pollution Prevention Office
U.S. EPA
401 M St., SW
Washinsiton, D.C. 20460
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Page C-10
CONTACTS: PPIC Technical Support
continued 8400 Westpark Drive
McLean. VA 22102
(703) 821-4800
The RCRAySupertund Hotline
(800) 424-9346
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Page C-ll
TITLE: Federal Reporting Data System (FRDS)
DEVELOPED BY: U.S. Environmental Protection Agency, Office of Drinking Water
TIME SPAN:
UPDATING:
DESCRIPTION:
AVAILABILITY:
The data base contains information from 1980 to the present.
Quarterly
FRDS organizes and stores information on public water supply systems
(PWSS). This information includes:
• Inventory information, including physical characteristics of water
supply, well-specific information, location and source of well; and
• Compliance-related information, including violations, enforcement
actions, variances, and exemptions.
States may either update the system directly or send EPA changes/updates
for the Agency to input. The information is available to state or municipal
users and can be accessed on a PC system with a telecommunications
package. Fees for useage vary from user to user.
CONTACT:
Larry Weiner
U.S. Environmental Protection Agency
Office of Drinking Water
401 M Street, SW
Washington, D.C. 20460
(202) 260-2799
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APPENDIX D
STATE AND U.S. TERRITORIES
WELLHEAD PROTECTION AGENCIES
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Page D-l
APPENDIX D
STATE AND U.S. TERRITORIES
WELLHEAD PROTECTION AGENCIES
Alabama
AL Dept. of Environmental Mgmt.
Water Supply Branch
1751 Congressman W. L. Dickinson Drive
Montgomery, AL 36130
(205) 271-7773
Alaska
AK Dept. of Environmental Conservation
Ground Water Program
3601 C Street. Suite 1334
Anchorage, AK 99503
(907) 563-6529
Arizona
AZ Dept. of Environmental Quality
Groundwater Monitoring Unit
2005 North Central, Room 202-A
Phoenix, AZ 85004
(602) 257-2278
Arkansas
AR Dept: of Health
4815 West Markham
Little Rock, AR 72205
(501)661-2623
California
CA State Water Resources Control Board
Ground Water Unit
Div. of Water Quality
901 P Street, P.O. Box 100
Sacramento, CA 95814
(916) 445-1788
Colorado
CO Dept. of Health
Water Quality Control Div.
4210 East llth. Avenue
Denver, CO 80220-3716
(303) 331-4556
Connecticut
CT Dept. of Environmental Protection
Bureau of Ground-Water Mgmt.
122 Washington Street
Hartford, CT 06106
(203) 566-7049
Delaware
DE Dept. of Natural Resources &
Environmental Contamination
Div. of Water Resources
Ground-Water Mgmt. Section
P.O. Box 1401
Dover, DE 19903
(302) 739-4556
District of Columbia
D.C. Dept. of Consumer & Regulatory
Affairs
Water Hygiene Branch
5010 Overlook Ave., S.W.
Washington, D.C. 20032
(202) 767-7370
Florida
FL Dept. of Environmental Regulation
Bureau of Drinking Water & Ground-
Water Resources
2600 Blairstone Road
Tallahassee, FL 32301
(904) 488-3601
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Page D-2
Georgia
GA Geological Survey Branch
Environmental Protection Division
Room 400 19 M.L.King, Jr. Drive, S.W.
Atlanta, GA 30334
(404) 656-3214
Hawaii
HI Dept. of Health
Groundwater Protection Program
P.O. Box 3378
Honolulu, HI 96901
(808) 543-8338
Idaho
ID Dept. of Environmental Quality
Water Quality Bureau/Wellhead Protection
ID Dept. of Health & Welfare
1410 N. Hilton Street
Boise, ID 83706
(208) 334-5860
Illinois
ILEPA
2200 Churchill Road
P.O. Box 19276
Springfield, IL 627794-9276 °
(217) 782-3397
Indiana
IN Dept. of Environmental Mgmt.
Ground Water Section
105 S. Meridian/P.O. Box 6015
Indianapolis, IN 46206
(317) 233-4222
Iowa
IA Dept. of Natural Resources
Surface & Ground Water Protection
Bureau
Henry Wallace State Office Bldg.
900 East Grand
Des Moines, IA 50319
(515) 281-8869
Kansas
KS Dept. Health & Environment
Bureau of Water
Building 740, Forbes Field
Topeka, KS 66620
(913) 296-5502
Kentucky
KY Dept. for Environmental Protection
Ground Water Branch
18 Reilly Road
Fort Boone Plaza
Frankfort, KY 40601
(502) 564-3410
Louisiana
LA Dept. of Environmental Quality
Ground Water Protection Division
P.O. Box 44274
Baton Rouge, LA 70804
(504) 342-8950
Maine
ME Dept. of Human Services
Drinking Water Program
Div. of Health Engineering
State House Station 10
Augusta, ME 04333
(207) 289-5685
Maryland
MD Dept. of the Environment
Water Supply Program
2500 Broening Highway
Baltimore, MD 21224
(301) 631-3702
Massachusetts
MA Dept. of Environmental Quality
Engineering
Div. of Water Supply
1 Water Street
Boston, MA 02108
(617) 292-5529
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Page D-3
Michigan
MI Dept. of Natural Resources
Stevens T. Mason Building
P.O. Box 30028
Lansing, MI 48909
(517) 373-1220
MI Dept. of Public Health
3432 N. Logan
P.O. Box 30035
Lansing, MI 48909
(517) 335-8000
Minnesota
MN Dept. of Health
925 Delaware Street, S.E.
Minneapolis, MN 55459
(612) 623-5000
Mississippi
MS Bureau of Pollution Control
Ground-Water Division
P.O. Box 10385
Jackson, MS 39209
(601) 961-5119
Missouri
MO Dept. of Natural Resources
Public Drinking Water Program
P.O. Box 176
Jefferson City, MO 65102
(314) 751-1300
MO Dept. of Natural Resources
Division of Geology & Land Survey
P.O. Box 250
Rossa, MO 65401
(314) 364-1752
Montana
MT Dept. of Health & Environmental
Sciences
Environmental Science Division
Cogswell Building, Room A206
Helena, MT 59620
(406) 444-2406
Nebraska
NE Dept. of Environmental Control
Ground Water Section
Statehouse Station
P.O. Box 98922
Lincoln, NE 68509-8922
(402) 471-4230
Nevada
NV Div. of Environmental Protection
Ground-Water Protection Program
123 West Nye Street
Carson City, NV 89701
(702) 687-4670
New Hampshire
NH Dept. of Environmental Services
Ground-Water Protection Bureau
6 Hazen Drive/P.O. Box 95,
Concord, NH 03301
(603)271-3645
New Jersey
NJ Dept. of Environmental Protection
Bureau of Water Supply, Planning & Policy
CN029
Trenton, NJ 08625-0029
(609) 633-1179
New Mexico
NM Environmental Improvement Division
1190 St. Francis Drive
Santa Fe, NM 87504
(505) 827-2981
New York
NY Dept. of Environmental Conservation
Div. of Water, Room 306
50 Wolf Road
Albany, NY 12233-3508
(518) 474-2121
North Carolina
NC Dept. of Environmental Health &
Natural Resources
Ground-Water Section
P.O. Box 27687
Raleigh, NC 27611
(919) 733-3221
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Page D-4
North Dakota
ND Dept. of Health & Consolidated Labs
Div. of Water Quality
Environmental Health Section
P.O. Box 5520
Bismarck, ND 58502-5520
(701) 224-2354
Ohio
OH EPA
Div. of Ground Water
1800 Water Mark Drive/Box 1049
Columbus, OH 43266-0149
(614) 644-3020
Oklahoma
OK Dept. of Pollution Control
Pollution Control Coordination Board
P.O. Box 53504
Oklahoma City, OK 73152
(405) 271-4877
Oregon
OR Dept. of Environmental Quality
Water Quality Div.
811 S.W. Sixth Avenue
Portland, OR 97204
(503) 229-5945
Pennsylvania
PA Dept. of Environmental Resources
Bureau of Community Environmental
Control
Div. of Water Supplies
P.O. Box 2357
Harrisburg, PA 17105-2357
(717) 787-5017
Rhode Island
RI Dept. of Environmental Mgmt.
291 Promenade Street
Providence, RI 02908-5767
(401) 277-2234
South Carolina
SC Department of Health &
Environmental Control
Ground-Water Protection Division
Supply & Special Programs Dept.
2600 Bull Street
Columbia, SC 29201
(803) 734-5465
South Dakota
SD Dept. of Water & Natural Resources
Div. of Environmental Regulation
Joe Foss Building
523 E. Capitol
Pierre, SD 57501
(605) 773-5049
Tennessee
TN Dept. of Health & Environment
Div. of Water Supply
T.E.R.R.A. Building
150 Ninth Avenue, North
Nashville, TN 37203
(615) 741-6636
Texas
TX Water Commission
Ground-Water Conservation Section
Capitol Station
P.O. Box 13087
Austin, TX 78711-3087
(512) 371-6320
TX Dept. of Health
1100 West 49th Street
Austin, TX 78756
(512) 458-7497
Utah
UT Dept. of Health
Bureau of Drinking Water & Sanitation
288 North 1460 West Street
P.O. Box 16690
Salt Lake City, UT84116
(801) 538-6350
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Page D-5
Vermont
VT Dept. of Health
Div. of Environmental Health Water
Supply Program
60 Main Street/P.O. Box 70
Burlington, VT 05402
(802) 863-7230
Virginia
VA Water Control Board
Ground Water Program
Office of Water Resources Mgmt.
P.O. Box 11143
Richmond, VA 23230-1143
(804) 367-6347
Washington
WA Dept. of Health
Wellhead Program
LD-11
Olympia, WA 98504
(206) 588-9041
West Virginia
WV Office of Environmental Health
Services
Environmental Engineering Division
Capital Complex, Bldg 3, Room 550
1900 Kanawha Boulevard, East
Charleston, WV 25305
(304) 348-2981
Wisconsin
Wl Dept. of Natural Resources
Div. of Environmental Standards
101 S. Webster
Madison, WI 53707
(608) 267-7610
Wyoming
WY DEQ - Water Quality Div.
Herschler Building, 4th Floor
122 West 25th
Cheyenne, WY 82002
(307) 777-7090
American Samoa
American Samoa EPA
Office of the Governor
Pago Pago, Am. Samoa 96799
(684) 633-2682
Guam
Guam EPA
Government of Guam
Harmon Plaza Complex Unit D107
130 Rojas Street
Harmon, Guam 96911
(671) 646-8863
Mariana Islands
Commonwealth of Northern Mariana
Islands
Div. of Environmental Quality
P.O. Box 1304
Saipan, Mariana Isl. 96950
(670) 234-6114
Palau
Palau Environmental Quality Protection
Board
P.O. Box 100
Koror, Palau 96940
(680) 488-1639
Puerto Rico
PR Environmental Quality Board
Water Quality Area
Box 11488
Santurce, PR 00910
(809) 767-8181
Virgin Islands
VI Dept. of Planning & Natural Resources
179 Altona & Welgunst
St. Thomas, VI 00820
(809) 774-3320
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