rtes        Robert S Kerr Environmental Research EPA-600/9-79-029
intal Protection    Laboratory          August 1979
         Ada OK 74820
             Research and Development
             Proceedings  of the
             Fourth National
             Ground Water
             Quality Symposium
                      i, TEXAS 7520?


Research reports of the Office of Research and Development, U S Environmental
Protection Agency have been grouped into nine series These nine broad cate-
gories were established to facilitate further development and application of en-
vironmental technology Elimination of traditional  grouping was consciously
planned to foster technology transfer and a maximum interface in related fields
The nine series are
      1   Environmental Health  Effects Research
      2   Environmental Protection Technology
      3   Ecological Research
      4   Environmental Monitoring
      5   Socioeconomic Environmental Studies
      6   Scientific and Technical Assessment Reports (STAR)
      7   Interagency Energy-Environment Research and Development
      8   "Special" Reports
      9   Miscellaneous Reports
 This document is available to the public through the National Technical Informa-
 tion Service, Springfield, Virginia 22161.

                     PROCEEDINGS OF

                     Cosponsored by the
              U.S. Environmental Protection Agency
                          and the
                 National Water Well Association
                    September 20-22, 1978
                    Minneapolis, Minnesota
                      Grant No. R805747
                      Project  Officer

                      Jack  W.  Keeley
     Robert S.  Kerr Environmental  Research Laboratory
                   Ada,  Oklahoma   74820
                   ADA,  OKLAHOMA  74820

     This report has been reviewed by the Robert S.  Kerr Environmental
Research Laboratory, U.S. Environmental Protection Agency, and approved for
publication.  Approval does not signify that the contents necessarily reflect
the views and policies of the U.S. Environmental Protection Agency, nor does
mention of trade names or commercial products constitute endorsement or
recommendation for use.

     The Environmental Protection Agency was established to coordinate
administration of the major Federal programs designed to protect the
quality of our environment.

     An important part of the Agency's effort involves the search for
information about environmental problems, management techniques, and new
technologies through which optimum use of the Nation's land and water
resources can be assured and the threat pollution poses to the welfare
of the American people can be minimized.

     EPA's Office of Research and Development conducts this search through
a nationwide network of research facilities.

     As one of these facilities, the Robert S.  Kerr Environmental Research
Laboratory is responsible for the management of programs to:  (a)  investi-
gate the nature, transport, fate, and management of pollutants in ground
water; (b) develop and demonstrate methods for treating wastewaters with
soil and other natural systems; (c) develop and demonstrate pollution con-
trol technologies for irrigation return flows;  (d) develop and demonstrate
pollution control technologies for animal production wastes; (e) develop
and demonstrate technologies to prevent, control  or abate pollution from
the petroleum refining and petrochemical industries; and (f) develop and
demonstrate technologies to manage pollution resulting from combinations
of industrial wastewaters or industrial/municipal wastewaters.

     This report contributes to that knowledge which is essential in order
for EPA to establish and enforce pollution control standards which are
reasonable, cost effective, and provide adequate environmental protection
for the American public.
                                        William C.  Galegar

     The Fourth National  Ground Water Quality Symposium was  held  in
Minneapolis, Minnesota, September 20-22,  1978, in conjunction  with  the
annual convention of the National Water Well  Association.

     The Symposium was dedicated to the late  George Burke  Maxey and the
keynote address was given by Courtney Riordan, Associate Deputy Assistant
Administrator, Office of Air, Land & Water Use, Office of  Research  and
Development, U.S. Environmental Protection Agency.

     A debate format on "The Issues of Our Time" featured  national
authorities presenting neutral, pro, and  con  views  followed  by audience
reaction, and addressed nine topics:










     The Transactions of this Symposium are submitted in fulfillment of
Grant No. R-805747 by the National Water Well Association  under the sponsor-
ship of the U.S. Environmental Protection Agency.

                    TABLE   OF   CONTENTS

  2  EPA's New Emphasis on Ground-Water Research	  Courtney Riordan
  5  George Burke Maxey. A Lasting Influence
     on the Course of Modern Hydrology	Gilbert F. Cochran
  9  Ground-Water Pollution - A Status Report	   David E. Lindorff
 18  Ground-Water Pollution - An Imminent Disaster	Wayne A. Pettyjohn
 25  Ground-Water Pollution - A Limited Problem	  D. Theodore Clark
 28  Audience Response to  Session I — Ground-Water Pollution
 30  Ground-Water Quality  Standards - A Neutral View	 Donald K. Keech
 35  Ground-Water Quality  Standards - Relevant	  James H. McDermott
 39  Ground-Water Quality  Standards - Irrelevant 	Frank A. Rayner
 45  Audience Response to  Session II — Ground-Water Quality Standards
 47  Land Application of Waste - State of the Art	K. R, Wright & C. K. Rovey
 62  Land Application of Waste - Important Alternative	 John R. Sheaffer
 69  Land Application of Waste — An Accident Waiting to Happen	  Charles C. Johnson, Jr.
 73  Audience Response to  Session III —  Land  Application of Waste
 75  The Federal Ground-Water Protection Program — A  Review  	Victor J. Kimm
 80  The Federal Ground-Water Protection Program - Today's Hope	Charles W. Sever
 83  The Federal Ground-Water Protection Program — Tomorrow's  Undoing	  Dale C. Mosher
 87  Audience Response to  Session IV - The Federal Ground-Water Protection Program
 89  State Ground-Water Protection Programs — A National Summary	  Richard E. Bartelt
 94  State Ground-Water Protection Programs - Adequate	Edwin H. Ross
102  State Ground-Water Protection Programs — Inadequate	James W. Dawson
109  Audience Response to  Session V — State Ground-Water Protection Programs
110  The 208 Planning Approach to Ground-Water
     Protection — A Program Overview	Merna Hurd
116  The 208 Planning Approach to Ground-Water
     Protection — A Foot in the Door	Donna Wallace
122  The 208 Planning Approach to Ground-Water Protection -
     What Is Wrong and  What Can Be  Done About It? 	Kenneth D. Schmidt
128  Audience Response to  Session VI — The 208 Planning Approach
     to Ground-Water Protection
130  Controlled Degradation and/or  Protection  Zones — The Way It Looks	  David W. Miller
133  Controlled Degradation and/or  Protection  Zones — Sense	  Ronald A. Landon
136  Controlled Degradation and/or  Protection  Zones — Nonsense	Herman Bouwer
139  Audience Response to  Session VII - Controlled Degradation
     and/or Protection Zones
141  Ground-Water Computer Models — State of the Art	Thomas A. Prickett
148  Ground-Water Computer Models - Practical  Tools	  Russell E. Darr
151  Ground-Water Computer Models — Intellectual Toys	  Henry A. Baski
154  Audience Response to  Session VIM — Ground-Water Computer Models
157  Waterborne Disease — A Status Report Emphasizing
     Outbreaks in Ground-Water Systems  	Guntner F. Craun
166  Waterborne Disease - Current Threat	Robert C. Cooper
171  Waterborne Disease - Historical Lesson	»	Ira M. Markwood
172  Audience Response to  Session IX — Waterborne Disease


                       September 20-22, 1978
Reprinted from GROUND WATER, Vol.  17,  Number 1,  January-February,
1979, and Vol. 17, Number 2, March-April,  1979,  with  permission  of
Water Well Journal Publishing Company, Jay H.  Lehr, editor.

by Courtney Riordan
     It's a pleasure to be in Minneapolis with the country's leading
ground-water authorities as you meet to discuss the pressing issues
which we are likely to face during the coming decade. The timing
for this Symposium is auspicious. It comes at a time when EPA
is accelerating its efforts to protect the quality of the country's
ground-water resources under both the Safe Drinking Water Act
and the Resources Conservation and Recovery Act.
     For those of you who have spent professional careers in the
ground-water development and protection field, this must be an
exciting time. Over the  years you have persisted in telling the world
of this valuable resource and of the need for protecting its quality.
You have tried to place our underground water in proper perspective
as a valuable renewable resource. Your efforts and words sowed the
seeds that are now bearing fruit.
     The 1977 Report to Congress on Waste Disposal Practices and
Their Effect on Ground Water pointed out that there are at least
17 million waste disposal  facilities placing over 1.7 trillion gallons
of contaminated liquid  into the ground each year. While the
expansive  nature of ground water makes it available in various
quantities at almost any location, it is also subject to contamination
from a wide variety of sources distributed widely  throughout the
country. Moreover, restoration of underground-water quality is
difficult, time consuming, and expensive. In almost every situation,
the cost of restoring the integrity of ground water once contaminated
exceeds its marginal value in use. It follows that our goals must
focus primarily on the protection of ground-water quality rather
than its restoration. This is in fact the mandate that has been given
to EPA by the Safe Drinking Water Act enacted in December 1974
and the Resources Conservation and Recovery Act of 1976.
     As we have gone about  implementing these Acts, we have
discovered how little we actually know about our vast underground-
water reservoirs, particularly in light of the potential stresses posed
     Presented at The Fourth National Ground Water Quality Symposium,
Minneapolis, Minnesota, September 20-22, 1978.
     ^Associate Deputy Assistant Administrator, RD-682, Office of Air,
Land and Water Use, Office of Research and Development, U.S. Environmental
Protection Agency, 401 M Street SW, Washington, D.C. 20460.

by the millions of waste sources which threaten their quality. It is
appropriate therefore that our initial efforts be directed toward
the collection of information to form a foundation for future
action, particularly in the development of rules and regulations
called for in the Acts. In this way, we hope that the intent of
these Acts can be carried out giving adequate consideration to the
full range of social, economic, and technical implications involved.
     The 1977 Report to Congress was an example of these efforts.
It was an attempt to collect all of the available information on the
impact of waste disposal practices on ground water in order to place
the problems in proper  perspective.  Nothing raises the quality of
the level of discussion about a problem more than hard data. My
experience is that in technical  discussions we have something like
the reverse of Gresham's law, i.e., good data chases out bad opinion.
Another study is just now getting under way which is aimed at
describing the nature of the drinking water of the Nation's rural
population. Still another study has recently been completed
which describes the effects of the abandonment of wells—oil, gas,
water, and others on ground-water quality.
     A major project has begun to evaluate the effects of pits,
ponds, and lagoons on our Nation's ground water. It is a five million
dollar effort being carried out  by EPA's Office of Drinking Water in
cooperation with our Regional Offices and the States. An inventory
of these impoundments will be determined for a great many using
a method developed by one of your distinguished associates,
Harry LeGrand.
     Although the Office of Research and Development has had a
role in each of these projects, our efforts have been hampered by
limited resources in the ground-water research area. About two
years ago we became convinced that ORD must expand these efforts
as a primary means of improving our technical capability to deal
with ground-water quality problems. We decided to accomplish
this by adding to our existing program at the Robert  S. Kerr
Environmental Research Laboratory at Ada, Oklahoma. I think
many of you are familiar with this group, particularly since they
have worked with the National Water Well Association in presenting
this series of ground-water quality symposia.
     Our plans for developing  this Center have been thoroughly
prepared and we expect will be carefully executed. Plan preparation
began two years ago by asking a selected group of your peers to
advise us on the goals of this new initiative so that they would fill
the needs of EPA's Operating Programs and the non-federal user

community, yet not duplicate or compete with the research of
other Federal agencies.
     We developed a research strategy based on the suggestions
and recommendations by broad  user groups and professional
participation. This strategy was adjusted after considerable
consultations within the Agency, our Science Advisory Board, the
Drinking Water Advisory Council, and the Subcommittee on the
Environmental and Atmosphere of the House Committee on
Science and Technology. Our actions have followed a deliberate
step-by-step progression to assure that this important initiative
will, to the greatest extent possible, be directed toward the needs
of the user while maintaining scientific integrity and quality.
     Our research efforts will address the development of monitor-
ing and measurement methods and transport and transformation
characteristics of contaminants in the subsurface environment. This
will allow us to prepare guidance documents for use by other parts
of the Agency in developing sensible waste source control criteria.
Of course, a considerable part of our activities  will continue to be in
the form of technical assistance to the Agency and others.
     This year we have supported the establishment of a center
for ground-water information at the offices of  NWWA in Columbus.
We are confident that this center will provide computer literature
search services on specific topics to all of you in the ground-water
industry. We have also worked with the U.S. Geological Survey to
establish a clearinghouse for ground-water models at the Holcomb
Research Institute in Indianapolis. This effort is aimed at assisting
water resource managers and others in selecting the proper models
for their particular needs while sponsoring worldwide workshops
to bring the managers and modelers closer together.
     This Fourth  National Ground Water Quality Symposium is
another example of our efforts to assure that information, ideas,
and opinions are made available to you in public forum. Each of
the symposia has been constituted with a different format geared
to the needs of the time. I find this year's format particularly timely
and exciting. The time could not be better suited in light of the
growing nationwide interest in our valuable ground-water resources.
The  issues for debate have been wisely selected. They will
undoubtedly serve as our constant companions for at least the next
     I am confident that, by working together and sharing our
knowledge, we can do a creditable job  in providing the best
technical and scientific advice that is available.

George  Burke  Maxey: A  Lasting  Influence
on  the  Course  of Modern  Hydrologya
by Gilbert F. Cochrarr
    It is difficult to summarize in these few pages
a life of nearly 3 score years that began April 3,
1917 in Bozeman, Montana and ended so suddenly
and unexpectedly on February 6, 1977, in Reno,
Nevada, a life that encompassed a professional
career spanning nearly 35 years. All I can hope to
do is portray a little of what George Burke Maxey
did and maybe something of who he was, because
the latter is what remains for so many of us in
    Each of us as we go through life will leave
some mark upon the world, however small. Some
will be remembered for what they did, others for
what and who they were. Few, I think, will have a
greater or more lasting impact on a field of science
than did George Burke Maxey on hydrology and
water resources. He touched a great many lives
and was many different things to so many different
people. To some of us he was Burke, to many more
he was George and to even more, Dr. Maxey. Born
     Memorial address presented at The Fourth National
Ground Water Quality Symposium, Minneapolis, Minnesota,
September 20, 1978.
    ^Research Professor, Water Resources Center, Desert
Research Institute, Reno; and Nevada State Science Advisor,
Governor's Office of Planning Coordination, Carson City,
in Bozeman, Burke grew up and attended school
in nearby Livingston, a picturesque little town in a
stimulating, vigorous and beautiful environment.
He always remained in love with that country and
throughout his life returned often, drawn back by

family, friends, the people and the country itself.
     Burke began his academic career at the
University of Montana at Missoula where in 1939
he received a B.A. in Geology. It was there also
that he met Jane Clow who later in 1941 became
Jane Maxey, his lifelong companion and supporter.
He continued his education at Utah State
Agricultural College in Logan, receiving an M.S. in
Geology in 1941.
     Like so many prominent hydrologists, Burke
began his professional career with the U.S.
Geological Survey. He started out in 1941  as a
Student Aide in the Water Resources Division in
Salt Lake City and in 1942 became Junior Geologist
working in Utah's Pavant Range and Flowell areas.
From Utah he was assigned for a brief period to
Louisville, Kentucky before being promoted to
Assistant Geologist and reassigned in 1944 to
Las Vegas, Nevada. This assignment was the start
of a long and intimate relationship in that beautiful
and arid State. Burke remained  in  Las Vegas from
1944 to 1946, and during that time conducted a
hydrologic evaluation of the Las Vegas Valley
that was to lay the foundation for Nevada's
eventual development of its Colorado River
allotment through the Southern Nevada Water
     During the 1940's the entire population of
Nevada was less than 150,000 people and it was
known that the State's  160-odd valleys were dry
but no one knew how dry or  how much water there
really was. While in Las Vegas, Burke became fast
friends with the Assistant State Engineer of Nevada
who was then on his way to becoming "Mr. Water"
in the State, Hugh A. Shamberger. Burke worked
with Hugh and promoted the concept of a State-
USGS cooperative ground-water reconnaissance
program to determine a first estimate of the State's
water resource—a massive undertaking. Burke's
study of the Las Vegas  Valley formed  the basis
and the starting point of that program through
his formulation of a methodology to deal with
the tremendous paucity of hard data and to
squeeze the last possible drop of information from
general hydrologic principles and relationships.
     In 1946 Burke was promoted to Associate
Geologist and transferred to Ely, Nevada where he
worked with Tom Eakin and  others on a series of
reconnaissance studies of 13 valleys in eastern
Nevada. In these studies he and Tom refined
Burke's Las Vegas approach to estimating natural
ground-water recharge and formulated a set of
relationships that are used yet today (and virtually
unchanged) to determine the limit of appropriable
ground water under Nevada water law. This early
work in Nevada also laid the foundation for a
paper Burke was to write nearly a quarter of a
century later and for which he was presented the
O. E. Meinzer award in  1971. The title of that
paper was "Hydrogeology of Desert Basins"
(Ground Water, V. 6, No. 5, 1968).
     In  1948 Burke took leave of the Geological
Survey to complete his  academic training at
Princeton University where in 1950 he received an
A.M. in Geology and in 1951 his Ph.D.
     The Princeton decision was a turning point in
Burke's career, for from that time on except for
some brief interludes, he became a member of the
academic community. In 1949 he joined the
faculty of the University of Connecticut at Storrs
as an Instructor of Geology advancing to Associate
Professor before leaving in 1955. Burke was always
a builder and collector of things. He built programs
and organizations. He collected everything—stamps,
books, coins, friends and students, to name only a
few. And it was at Connecticut that Burke began
collecting and building from rough stock one of
the things he most dearly loved—graduate students
with ability and an interest in water. It was also
while at Connecticut that Burke became involved
with water resources and hydrogeology at the
international level.
     From 1952 to 1954 Burke took leave from
the University to accept foreign assignments with
the U.S. Geological Survey and what is now the
U.S. Agency for International Development in
Tripoli, Libya. He served as Geologist and then  as
Acting Chief of the Natural Resources Division  of
the Point 4 program.
     In 1955 Burke left the University of
Connecticut to join the Illinois Geological Survey
as Geologist and Head of the Division of Ground-
Water Geology and Geophysical Exploration and to
also become Professor of Geology at the University
of Illinois. Several of Burke's students followed
him to Illinois, and while there he found and
attracted additional talent to add to his  growing
collection of students.
     Burke remained at Illinois until 1962 when
he was sought out to head up the Hydrology
Department of the newly created Desert Research
Institute at the  University of Nevada, and to
assume  the position of Professor of Geology. At
that time Burke returned to Nevada and Reno to
begin creating a successful and innovative hydrologic
research program. And  again, as when he left
Connecticut, several of Burke's students followed
him to both study and work in Nevada.

     Though Burke did not return to live in Nevada
until 1962, he had never lost contact with the State,
its problems or its people. Through his good friend,
Hugh Shamberger, and those many others he had
befriended in the '40's, Burke had been retained
since 1951 as a consultant to the Nevada Depart-
ment of Conservation and Natural Resources. In
this capacity he had helped  to shape and direct
the reconnaissance program he had promoted
while with the Geological Survey.
     One of his first activities at the University of
Nevada was to begin building an interdisciplinary
graduate program in hydrology and hydrogeology.
His activities resulted in this land grant school's first
Ph.D. program and its first Ph.D. degree recipient,
Roger Morrison. Since that  time there has been
a steady outpouring of M.S. and Ph.D. recipients
well schooled and trained in the hydrological
sciences—not geologists, not engineers, not
economists,  but hydrologists with varying
undergraduate academic training.
     At the Desert Research Institute, Burke
simultaneously built a water research program that
first focused on his love—ground water—but that
broadened to one encompassing surface water, water
chemistry, water resources engineering and water
resources planning—a true center for study and
research in hydrological sciences.
     Burke came back to Nevada at a time when
this nation was awakening to the fact that a more
vigorous and far reaching program was needed in
water research and training. This was the period
of time that  saw the creation of Universities
Council on Water Resources (UCOWR), the
Federal Interagency Committee on Water Resources
Research (COWRR), the passage of the Water
Resources Research Act of 1964 and the Water
Resources Planning Act of 1965. In each of these
Burke played a significant role as an active
proponent and instigator.
     Burke's professional career was full and active.
He was a member of, and in several instances
helped to establish, over 16  professional organiza-
tions and societies, and in each he vigorously worked
to promote advances in hydrology and enlighten-
ment in water resources management. He also
served as chairman or member of over a dozen
important national or regional committees
including those of the American Geophysical
Union, International Union  for Geodesy and
Geophysics,  Geological Society of America,
National Academy of Sciences, and
the International Hydrological Decade. Burke
was Distinguished Lecturer for the American
Association of Petroleum Geologists, Visiting
Geoscientist for the American Geological
Institute, Visiting Professor of Hydrogeology at
Indiana University, and Visiting Scientist in
Geophysics (Hydrology) for AGU.
     Burke was a U.S. Delegate to many inter-
national symposia, Vice President and President
of the Commission on Groundwater of the IUGG,
consultant on ground-water problems to the U.S.
Atomic Energy Commission, and American
Editor of the Journal of Hydrology. And in his
spare time, Burke was author or coauthor of over
60 published articles, papers and reports dealing
with hydrogeology, hydrology and water
resources planning. His individual accomplish-
ments and activities are too extensive to enumerate
here. Suffice it to say he was busy and productive.
     One activity that Burke especially enjoyed
was that of being a water resource planner. This
was a job he did well, not only in the U.S. but
worldwide. This role took him from Montana and
Nevada to Poland, Kenya, Mexico, the Sudan and
Egypt. Burke's foreign assignments left behind a
spirit of goodwill and international cooperation in
each of these countries and  resulted in the coming
of many foreign students to study in the United
     These are only some of the things Burke
Maxey did; they are not who he was. To have
known him was an experience, and to each who
did I am certain that experience was different.
Burke was a man of great compassion, who had
undying faith in the ability, of young people to
produce. His true lasting legacy and contribution to
hydrology grew from that compassion and faith in
the form of the large number of students,  under-
graduate and graduate, that he trained.
     Burke liked to refer to his graduate student
academic progeny as his "sons," and when some of
them began teaching he was blessed with "grand-
sons" and even eventually "great-grandsons." This
reference was not empty but rather reflected the
true feeling of kinship that Burke developed with
his students, a feeling that was mutual. Burke was
an excellent teacher who continually challenged
his students and through this and his own
knowledge, opened doors to knowledge. But
equally important was the fact that Burke forced
his students to think and act for themselves.
     However, not only did Burke produce excellent
scientific minds, he helped to develop men of
compassion and understanding through his own
example. Burke was always ready to share what he
had,  to give a student money to get home  on, to

provide a place to eat and sleep. His home was
always open. These students that Burke inspired,
cajoled and pushed to succeed are now spread
throughout this country and the world in
prominent positions and as leaders in the
hydrological sciences.
     I do not know the full number of students
Burke trained, let alone the number of "grandsons"
and "great-grandsons," but at the risk of offending
many, I mention  some few whom I know and who
are proud to have known Burke: Bob Farvolden,
Pat Domenico, John Bredehoeft, Martin Mifflin,
Bill Back, Dave Stephenson, Richard Parizek,
Richard Cooley, Jerold Behnke, Art Ziezel, Bill
Dudley, Bill Greenslade, Jim Hackett . . . and the
list goes on and on. In fact it is difficult to go to
any meeting where there  are hydrologists, and not
find a significant  number of them who have been
directly influenced by Burke or one of his students.
Burke left a lasting and indelible imprint on his
adopted State of Nevada and through his many
students, has left his mark on the course of modern
hydrology, a mark that will last, I think, for a very
long time.
    Burke made people think, whether it was in a
classroom, in the field, or in a meeting such as this.
He was always perceptive and offered up difficult
questions—not infrequently of one word—why?
Often Burke would team up with friends such as
Ray Kazmann and Jim Warman to let a speaker
know when he was off-base. Those were exciting
meetings for everybody—except the speaker.  It
seems that many meetings are quieter now. There
is a need  for someone to step  forward to help fill
that role  to ensure that we keep trying to answer
the question of "why."

Ground-Water  Pollution  —  A  Status  Report
by David E. Lindorffb
     Recent research has expanded our understanding of
the suitability of waste disposal in various hydrogeologic
settings. Although more research is needed, our knowledge
can provide a basis for preparing guidelines for action that
will protect ground water from waste disposal practices. It
is impossible, however, to prevent accidental spills, unlawful
dumping, and ground-water contamination or pollution
resulting from some old, unregulated waste disposal
practices. Therefore, more than 170 case histories of
subsurface contamination or pollution were studied to
evaluate the effectiveness of remedial action in different
geologic environments. The case studies indicate that the
severity and extent of ground-water contamination is
determined by (1) the hydrogeologic setting, (2) the nature
of the contaminant, and (3) the effectiveness of regulatory
     Industrial wastes are the most common sources of
ground-water contamination. The most serious incidents
are those that pollute or threaten water supplies and those
that cause a fire or explosion. Once ground water is
contaminated, remedial action is time consuming and
expensive. Each incident must be handled as a separate
problem. Although prompt action is essential to limit
contamination and minimize remedial action, no strategies
have been established for rapid response to contamination
or pollution  problems.
     Ground-water contamination will continue, but its
impact can be reduced. The role of hydrogeologists in
regulatory agencies should be strengthened to provide
proper evaluation of potential sources of contamination and
to aid  in remedial action when ground water is contaminated.
Cooperative  efforts to develop strategies will ensure proper
handling of future emergencies.
      Presented at The Fourth National Ground Water
Quality Symposium, Minneapolis, Minnesota, September
20-22, 1978.
     blllinois State Geological Survey, Urbana, IL 61801.
     More than 170 documented case histories of
ground-water contamination or pollution were
studied to develop an understanding of the status of
ground-water pollution. The case histories indicate
that once ground water is contaminated, remedial
action is time consuming and expensive. Therefore,
protection of ground water from contamination is
essential. For this reason, extensive research in
recent years has focused on the movement and
attenuation of contaminants in various hydro-
geologic settings. We have come a long way in
understanding the behavior of contaminants in the
subsurface and in understanding the suitability of
waste disposal in various geologic environments.
Although more research is needed, we now have a
basis for preparing guidelines that will protect
ground water from waste disposal practices. Ground-
water contamination or pollution can be reduced,
but cannot be totally eliminated. Accidental spills
and unlawful dumping will continue to occur.
     This paper will examine the status of ground-
water pollution through examples of ground-water
contamination and pollution and by summarizing
some of the research in recent years. Finally, some
options are considered for limiting future ground-
water contamination problems.
     Before proceeding further, the terms
contamination and pollution require definition.
Contamination of water is defined as the alteration
of water quality in an undesirable manner and
pollution as the contamination of water to the point
where  it is unfit for a particular use.

     Contaminants may reach ground water from
a variety of sources (see Table 1). Some wastes are
by design discharged to the subsurface; examples

              Table 1. Classification of Sources of Ground-Water Contamination (after USEPA, 1977)
 Sources designed to discharge
    •waste to the land and
       ground water
 Sources that may discharge
   waste to the land and
ground water unintentionally
     Sources that may discharge a
 contaminant (not a waste) to the land
          and ground water
Spray irrigation
Septic systems, cesspools, etc.
Land disposal of sludge
Infiltration or percolation basins
Waste disposal wells
Brine injection wells
 Surface impoundments
 Animal feedlots
 Acid mine drainage
 Mine spoil piles and tailings
Buried product storage tanks and pipelines
Accidental spills
Highway deicing salt stockpiles
Ore stockpiles
Application of highway salt
Product storage ponds
Agricultural activities
include septic systems, spray irrigation, and land
disposal of sludge. Other wastes may reach ground
water unintentionally. Wastes may, and often do,
migrate to ground water from impoundments,
landfills, animal feedlots, leaky sewer lines, and
other sources.
     Not only wastes may adversely affect ground
water, however. Petroleum products may enter the
ground-water flow system from a leak in a pipeline
or storage tank. Ground water also may be con-
taminated from the storage or application of
highway salt.
     Increased regulation may reduce but not totally
eliminate the potential for ground-water contamina-
tion. To identify the most critical factors for pro-
tection of ground water, examples or case histories
of ground-water contamination must be evaluated.
Over the past three years, 173 case histories of
subsurface contamination or pollution were
studied (Lindorff and Cartwright, 1977). A few
cases came from environmental agencies and
personal experience.
     The information presented in the case studies
found in the literature varied considerably, partly
because the articles were written for a variety of
purposes. Many contained little or no documenta-
tion of geologic and ground-water conditions.
Some incidents were well documented, however,
and they provide a useful base of information.
     The case studies indicate that the severity
and extent of ground-water contamination is
determined by: (1) the hydrogeologic  setting,
(2) the nature of the contaminant, and (3) the
effectiveness of regulatory action.
     The ground-water setting determines the
potential extent of contamination or pollution.
As shown in Figure 1, contaminants introduced into
the subsurface on an upland  recharge site
                  potentially may move a great distance and may
                  affect a major portion of an aquifer. This is
                  especially true in areas underlain by coarse-grained
                  sediments or fractured rocks, where contaminants
                  may move rapidly through the subsurface with little
                  or no attenuation.
                       In Nassau County on  Long Island, pollution
                  of a well in the 1940s was traced to disposal of
                                    RECHARGE   ZONE
                               Zone of ground-water contamination
                                  DISCHARGE  ZONE
                               Zone of ground-water contamination
                  Fig. 1. Extent of ground-water contamination from
                  pollutant entering recharge and discharge zones (Bergstrom,
                  1968; Lindorff and Cartwright, 1977).

plating wastes in three unlined lagoons overlying a
sand and gravel aquifer. As of 1970, the plume of
contaminants was 4,000 feet long, 1,000 feet
wide, and up to 70 feet thick (Perlmutter and
Lieber, 1970).
     If the source of contamination is in or near a
discharge zone (Figure 1), the potential extent of
ground-water contamination is much more limited.
This was noted in northeastern Illinois (Hughes,
Landon,  and Farvolden, 1971) and later in Iowa
(Palmquist and Sendlein, 1975) in studies of the
migration of leachate from landfills located in or
near discharge zones. Leachate discharged to an
adjacent  river in each case. If a stream or river is
unable to assimilate the leachate by dilution, the
quality of surface water may be adversely affected.
     In fine-grained environments adsorption and
filtration and low hydraulic conductivity limit the
extent of contamination. In southeastern Illinois,
a train derailed in 1969 and spilled 15,000 gallons
of cyanide. The fine-grained surficial material
limited the penetration of the cyanide to a depth
of 3 to 4 feet [Illinois Environmental Protection
Agency (IEPA) files] . The contaminated soil was
excavated; this may be the most effective option
in similar environments. Fine-grained environments
reduce the spread of contaminants, but also limit
the options for recovery of contaminants if this
action becomes necessary.
     The extent of ground-water contamination
or pollution is likely to be more extensive in areas
underlain by coarse-grained materials or fractured
bedrock. Contaminants may move a great distance
in fractured bedrock with no attenuation. Earlier
this year  in southern Missouri, the collapse of a
sinkhole  beneath a sewage lagoon permitted
thousands of gallons of sewage to enter the
dolomite aquifer and to migrate some  20 miles
before discharging to the  surface (James Williams,
Missouri  Geological Survey, personal communica-
tion). The hydrogeologic  setting, therefore,
determines the potential extent of contamination.
     The severity of a pollution incident also is
dependent on the volume and nature of the
contaminant. Table 2 lists the contaminants for
each of the case studies and the environmental
impact. Of the 173 case histories, 116 were studied
in an initial investigation (Lindorff and Cartwright,
1977), and the remaining 57 were studied later.
The first  column indicates the total number of
cases involving each contaminant. The number and
percentage of incidents affecting or threatening
ground-water supplies are tabulated in the second
column. The third column lists the number and
   Table 2. Summary of Ground-Water Contamination
        Incidents — Contaminants and Impacts

                   No. of     Water       Fire or
   Contaminant    incidents  supplies (%)  explosion (%)
Industrial wastes
Landfill leachate
Petroleum products
Organic wastes
Radioactive wastes
Mine drainage
31 (62)
18 (67)
13 (81)
3 (100)
1 (33)


91 (53)
percentage of cases that threatened or produced
fires or explosions.
     The most common category of contaminant
was industrial wastes. This category includes a
wide spectrum of wastes from all types of
industries, such as acids, various solvents,
plating wastes, and others, including some
unidentified wastes. Most but not all of the
contaminants were waste products. Various
chemicals were discharged to the subsurface from
accidental spills. Industrial wastes reached ground
water from impoundments or lagoons, spills,
pipeline breaks, land disposal of wastes, and
improper disposal. Impoundments were the most
common sources of contamination. In the past,
industrial lagoons and impoundments typically
have been monitored poorly if at all.
     Landfill leachate was the second most common
contaminant. Only about 15 percent of the landfills
that were studied produced well pollution, however;
this suggests that landfills are a less serious hazard
than other sources of contamination. Many of the
case studies were research investigations concerned
with the migration of leachate from landfills. In
most cases the extent of ground-water contamina-
tion was limited to the site itself or to a small area
adjacent to the landfill. The  geologic materials
have generally  been able to attenuate the  con-
taminants or to reduce leachate concentrations by
     An exception is a landfill in northern Delaware
that has contaminated  a major regional aquifer
and has threatened municipal and industrial supplies.
The refuse was placed in an abandoned sand quarry
separated from the regional alluvial aquifer by a
thin clay layer. Excavation of the clay for cover

material permitted leachate movement to the
underlying aquifer with little or no attenuation
(Apgar and Satterthwaite, 1975).
     Of 27 cases involving petroleum products, 18
polluted or threatened water supplies and 10
produced a fire and/or explosion. Although the
contaminant in only a few cases, petroleum products
potentially are a  more serious environmental threat
than landfill leachate or most industrial wastes.
Early in 1978, a  number of explosions and fires
resulted from extensive gasoline pollution of an
alluvial aquifer along the Mississippi River near
East St. Louis. Although three refineries are present
in the area, the source of pollution has never been
identified. The gasoline apparently has been in the
ground for many years. Heavy rainfall this spring
and reduced pumpage of the sand  and gravel
aquifer raised ground-water levels and forced
explosive concentrations of gasoline into several
basements and sewers in the area (IEPA files).
     Petroleum products may enter the subsurface
as a result of pipeline breaks, storage tank leaks,
spills, and from unknown sources. In nine cases, the
source of contamination was never identified
positively. In 1968 a large volume of gasoline was
discovered on a relatively flat portion of a water
table between  two pumping cones for municipal
ground-water supplies in the Los Angeles-
Glendale area. Preliminary estimates suggested as
much as 250,000 gallons of gasoline were present
in the subsurface. Again the exact source was never
identified positively (American Petroleum Institute,
1972; Williams and Wilder, 1971).
     Organic wastes were the fourth most common
contaminant (Table 2). Of the 21  cases involving
various organic wastes, 15 resulted in ground-water
supplies being affected or threatened. Sources of
contamination included sewage impoundments,
septic tanks, feed lots, and improper waste disposal.
Some problems develop over a long period of time.
For example, the use of septic tanks and cesspools
since 1910 in Nassau County, Long Island, has
resulted in the widespread deterioration of ground-
water quality and the subsequent abandonment
of the upper glacial aquifer as a source of water
supply (Sulam and Ku, 1977).
     Chlorides are a potential threat to ground
water because they generally are not attenuated in
the subsurface. Of the 16 cases involving chlorides,
13 contaminated or threatened water supplies.
Chloride entered ground water from salt storage
areas, oil-field brine ponds, brine injection  wells,
and improper land disposal. In West Virginia,
chloride concentrations rose steadily in several
shallow wells when road salt was stored in an area
nearby. The affected wells were all finished in a
highly permeable carbonate aquifer within a zone
located 1,500 feet downgradient of the salt pile
(Wilmoth, 1972).
     The other four contaminants in Table 2 were
involved in significantly fewer incidents. Radio-
active wastes, pesticides, fertilizers, and mine
leachate were detected collectively in 17 cases, 8 of
which affected or threatened water supplies.
     Some contaminants pose a potentially serious
hazard just because of their character. The most
dangerous contaminants are petroleum products
and toxic and/or explosive chemicals and industrial
wastes that can threaten or produce fires or
     The case  histories indicate two categories of
ground-water contamination incidents. Some
problems such as accidental spills are detected within
a short period of time. In such situations, quick
response is necessary to limit ground-water
contamination and to minimize the remedial
action. Only six of the case histories were detected
as a spill, however, and less than 10 percent were
discovered within the first 24 hours (Lindorff and
Cartwright, 1977).
     Most contaminants are detected some time
after entering the subsurface. Weeks,  months, or
years may pass before a problem is noted. The
contaminant may travel a great distance and may
affect a large portion of an aquifer before pollution
is recognized. In Colorado, industrial wastes were
discharged to unlined lagoons for about 11 years
before ground-water pollution was detected.
Several square miles of a shallow aquifer were
affected  (Walton, 1961; Walker, 1961).
     Even if the source is identified and removed,
and no further contaminants enter the ground-water
flow system, contaminants can continue to adversely
affect ground  water for a long time. With no
remedial action, tens, hundreds, or thousands of
years may be necessary to flush the contaminants
out of the ground-water flow system. In Arkansas,
chloride  contamination of a sand and gravel aquifer
was traced to a brine disposal pit in an oil field.
About one square mile of the aquifer was affected.
An evaluation of possible renovation techniques
concluded that an estimated 250 years would be
needed for natural flushing to remove the chlorides
from the aquifer (Fryberger, 1975).
     When contamination is detected immediately
after the incident, prompt response is important.
When contaminants have been in the subsurface a
long time, however, quick action may not be

warranted. Conditions will not change dramatically,
so more effort can be devoted to an evaluation of
the extent of contamination and determination of
the proper remedial action. Alternatives may include
ground-water renovation, identification and elimina-
tion of the source of contamination, efforts to
alleviate the problem for those affected, or perhaps
no action at all. Time is available to gather the
necessary expertise to fully consider all the options.
     Responding too hastily may create more
serious problems. In  Rockford, Illinois, contamina-
tion was initially detected in an industrial well near
a landfill. Use of the well was ordered discontinued;
this permitted the contaminants to migrate to
other wells in the area, including a municipal supply
well and several private wells. These ground-water
supplies then had to  be abandoned (Illinois State
Geological Survey files). Perhaps an early technical
evaluation in response to the initial contamination
would have resulted in successful remedial action
and minimal ground-water degradation.
     Regulatory agencies, therefore, should be
equipped to respond promptly in those instances
where contamination is detected at an early stage.
The agency must also be able to draw together all
necessary expertise to evaluate long-term pollution
problems. Environmental agencies in the United
States and Canada were surveyed in 1975 to
discover what procedures had been developed for
dealing with ground-water pollution emergencies
(Lindorff and Cartwright, 1977). The responses
indicated that no established strategies had been
developed for rapid response to ground-water
contamination or pollution problems. The survey
also suggested that not all States have available the
technical expertise to offer advice and assistance
for incidents of ground-water contamination.
Only about one-third of the States responding
indicated that they possessed the expertise,
geological and otherwise, to respond effectively
to ground-water contamination problems.
     Illinois is perhaps typical of most States.
Currently, the Illinois Environmental Protection
Agency (IEPA) responds to air and water
emergencies through an Emergency Response
Program, which maintains a hotline 24 hours a day.
Upon notification of an emergency, an IEPA
representative visits the site and offers assistance.
However, no specific strategy has been developed
for handling ground-water emergencies.
     The staff of the IEPA includes geologists,
chemists, soil scientists, and others who can provide
expertise in the event of a ground-water contamina-
tion incident. Assistance is also available from a
variety of other State agencies, such as the Illinois
State Geological and Water Surveys, the State Fire
Marshal, the Illinois Department of Public Health,
and the Illinois Emergency Services and Disaster
Agency. Although Illinois does have many pertinent
resources, they are not organized to respond to
ground-water contamination problems. This is
probably true of most States.

              RECENT RESEARCH
     The best way to minimize ground-water
contamination is to prevent it. Therefore, the
regulation of waste disposal to protect ground water
is especially important. To effectively regulate
potential sources of contamination, we must
understand the behavior of contaminants in the
subsurface. Then we can predict the environmental
impact. Recent research can now provide much of
the needed information.
     The following discussion of research is not
meant to be complete but to highlight some of
the information regarding the movement and
attenuation of contaminants in the subsurface.
     Much of the research has concentrated on
landfills in various geologic environments.
California has researched landfills since the early
1950s. Several studies investigated the generation
and movement of leachate and gases (California
State Water Pollution Control Board, 1952, 1954,
1961). The research suggested that, in a dry climate,
landfilling above the water table would not impair
ground-water quality but that subsurface con-
tamination is very likely when refuse is in
continuous or intermittent contact with ground
water. We know now that leachate forms even in
landfills above the water table; however, because
evaporation exceeds precipitation under arid
conditions, leachate formation is a slow process.
     Research in Pennsylvania (Apgar and Langmuir,
1971), in Illinois (Hughes, Landon, and Farvolden,
1971), and elsewhere has shown that the rate of
leachate production in a humid environment is
almost unaffected by refuse disposal above or
below the water table. The leachate enters the
ground-water system in all cases. In northeastern
Illinois, approximately one-half of the annual
precipitation infiltrates into the refuse to produce
leachate (Hughes, Landon, and Farvolden, 1971).
     Where refuse is placed in fine-grained materials,
a ground-water mound is likely to form within the
refuse, because infiltration and leachate formation
are more rapid than is migration into the surrounding
less permeable, fine-grained sediments (Figure 2).
Ground water may discharge as seeps along the


Springs /

~\ "


\ 1


I ^
Fig. 2. Ground-water mound developed in landfill refuse
(after Hughes, 1972).
edge of the landfill where the ground-water mound
intersects the land surface. Because of the mound,
ground water flows away from the landfill in all
     Fine-grained environments appear to be the
most suitable for landfill siting. Clay minerals
limit the  rate of leachate migration and remove
chemical constituents by cation exchange, thereby
providing a natural renovation of the leachate.
Cations in solution replace calcium and magnesium
on the clay structure and increase their concentra-
tion in the leachate; this is the "hardness halo"
that has been noted at several landfills (Griffin et al.,
     Sites underlain by coarse-grained sediments
are usually considered poor choices for landfills.
Recent investigations of six landfills in sandy
environments in Wisconsin and Illinois, however,
indicated that little leachate migrated beyond the
perimeters of the  landfills themselves (Gerhardt,
1977; Johnson and Cartwright, 1978). Even though
leachate  is quite undesirable, leachate concentra-
tions may be reduced within a relatively short
distance, even in less desirable environments, by
attenuation  and/or dilution.
     The importance of understanding the
hydrogeologic conditions to permit evaluation of
potential environmental impact has been stressed
in research to date. Knowledge of the position of
the landfill in the ground-water flow system and of
the nature of the  surrounding earth materials
provides  a basis for determining the degree of
natural renovation offered by the site. To be aware
of the ground-water resources and the existing or
potential uses of local aquifers is also essential.
     Although there is no substitute for site
evaluation, geologic mapping  can provide a guide
for the planning and siting of disposal sites
(Kempton, Bogner, and  Cartwright, 1977). As we
gain knowledge of the surficial geology and the
hydrogeologic properties of the materials,  maps
can be prepared to show, in general, the
suitability of an area for solid waste disposal
(Figure 3).  In Illinois., 9  to 15 meters (30-50 feet)
of relatively impermeable material provides a
mappable base for sanitary landfill suitability
(Cartwright and Sherman, 1969). In DeWitt
County (Figure 3), only the upland areas covered
by clayey glacial till meet this requirement
consistently. The upland portion of DeWitt
County (area 1) is generally considered suitable for
solid waste disposal. Portions of area 2a may be
suitable, but it locally includes sand and gravel or
silt zones within 6 meters (20 feet) of land surface.
Only a few suitable areas may be found in area 2b
because of  the proximity to streams and sand and
gravel deposits. Areas where loess overlies shallow
sands and gravels are included in area 3a-, area 3b
includes land in the stream valleys. Both areas are
unfavorable for waste disposal. This map provides
a general guide to landfill suitability, but more
information would be necessary for a specific site.
    Where geologic factors are inadequate to
provide for natural renovation of leachate, the site
can be engineered to protect the subsurface
environment. Site design may include a liner or a
well to collect leachate, a treatment or recycling
system, an  impermeable cover to minimize
infiltration, wells for venting of gases, or some
combination of techniques (Hughes,  1972). An
understanding of the hydrogeologic conditions
is necessary to determine which approach might be
most effective.
     The behavior of other potential contaminants
in the subsurface also has been investigated.
Researchers at Pennsylvania State University have
been studying the environmental aspects of spray
irrigation of sewage effluent for more than ten
years (Parizek et al.,  1967; Sopper and Kardos,
1973). Work in Illinois (Hinesly, Braids, and
Molina, 1971) and elsewhere has focused on the
impact of land disposal of sludge. The U.S.
Geological  Survey is currently studying the impact
of sludge disposal on reclaimed strip  mine land in
western Illinois (Gary Patterson, U.S. Geological
Survey, personal communication). Because
nitrates are weakly adsorbed by soils, the nitrogen
loading rate is an important factor in protecting
ground water. Heavy metals may be of concern in
sewage sludge; excessive loading rates may permit
metal uptake by crops or migration of heavy metals
into the  subsurface.
     Workers in Canada have been studying the
migration of radioactive wastes since the early
1960s (Parsons,  1960,  1961, 1962; Cherry, 1973).
The research to date improves our understanding of
low-level waste migration. Although detailed
information for each site is needed concerning



                                    g silt zones within
                              the till may occur within 20 feet
                              (6 m) of the land surface; may be
                              near sand and gravel deposits
                         Area 2b. A few suitable disposal sites prob-
                              ably available; till at or near
                              surface, land surface may be slop-
                              ing, frequently close to streams
                              and sands and gravels associated
                              with streams
                         Area 3a- Gene ally unsuitable for landfill
                              oper tions without significant site
                              modi ications, loess over shallow
                              wate -bearing sand and gravel de-
                              posi s
                         Area 3b  Gene ally unsuitable for landfill
                              oper tions, shallow sand and
                              grav 1  deposits and flowing streams
Fig. 3. Geologic conditions for solid waste disposal, Oe Witt County, Illinois (Hunt and Kempton, 1977).
predicted flow paths and rates of nuclide transport,
public acceptance of such sites may be a more
serious problem than site selection. There is still
uncertainty as to the most suitable geologic settings
for high-level radioactive waste disposal; more
research is needed.
     Time does not permit a complete review of
all research investigating the migration of
contaminants in the subsurface. Although research
must continue, much valuable information has  been
generated in recent years that can provide a logical
and reasonable scientific basis for the regulation of
waste disposal to protect ground water.

               FUTURE  TRENDS
     Regulations can reduce but not totally
eliminate ground-water contamination. Accidental
spills and unlawful dumping will continue. Because
of the  impossibility of monitoring all pipelines
and storage facilities of the oil industry, petroleum
products will continue to be a significant source of
ground-water contamination. We are also likely to
continue to face contamination problems from
old, abandoned, unregulated waste disposal sites.
     Increased land disposal of wastes will require
effective regulation to minimize environmental
degradation. Recent environmental regulations
limiting disposal of industrial wastes into the air
and surface water will increase use of land disposal
because it is a cheaper disposal alternative. Spray
irrigation and land disposal of sewage sludge will
also increase because federal guidelines require
consideration of all alternatives for sewage treatment
and disposal. The increasing volume of radioactive
wastes will necessitate action to locate  favorable
sites for disposal—especially for high-level wastes.

     We can reduce ground-water contamination by
thoroughly evaluating and monitoring waste
disposal facilities and by responding quickly and
effectively when a contamination problem is

detected. The case histories and research suggest
several steps that can be taken to minimize the
incidence of ground-water contamination and limit
the extent of contamination once discovered:

     1. An inventory, and subsequent evaluation,
in a State or a particular area of existing and
potential sources of contamination would determine
the relative significance or contamination potential
of the various sources. Such an inventory might
include septic systems, spray irrigation systems, land
disposal  of sludge, municipal and industrial
impoundments or lagoons, landfills, feedlots, acid
mine drainage, salt stockpiles, and perhaps others.
Some potential sources may be poorly regulated if
at all. Such information would provide a basis for
developing guidelines  or regulations to evaluate
potential sources.
     2. Equally important is the delineation of those
areas geologically most sensitive to environmental
degradation. This would include areas in which
geological materials are naturally unsuitable for
waste disposal and those in which existing or
potential aquifer use might be jeopardized if
contaminants reach ground water.

     3. In addition to ground-water protection,
plans or  strategies must be developed to limit
contamination once it is discovered. Cooperative
efforts are needed to develop a plan for an early
evaluation of each incident and an  appropriate
response based on the hydrogeologic setting, the
nature of the contaminant, and the extent of
contamination. A regulatory agency may have the
expertise to respond to emergency situations, but
may seek consultation with outside resources to
properly evaluate remedial action for a long-term
pollution problem. Each incident must be handled
as a separate problem.
     4. The role of hydrogeologists in regulatory
agencies should be strengthened to provide proper
evaluation of potential sources of contamination
and to aid in remedial actions when ground water
is contaminated.

     5. Several lines of needed research are suggested
by the evaluation of the case histories:
       a. The movement of contaminants in the
unsaturated zone.

        b. Ground-water monitoring and sampling
        c. Techniques for removal of contaminants,
especially of hydrocarbons, from the subsurface.
        d. The migration of radioactive nuclides in
various hydrogeologic environments.
        e. Documentation of ground-water
contamination cases for possible application to
future problems.
American Petroleum Institute. 1972. The migration of
     petroleum products in soil and ground water-
     principles and countermeasures.  American Petroleum
     Institute Publication 4149, 36 pp.
Apgar, Michael A., and Donald Langmuir. 1971. Ground-
     water pollution potential of a landfill above the water
     table. Ground Water, v. 9,  no. 6, pp. 76-94.
Apgar, Michael, and W. B. Satterthwaite, Jr. 1975.
     Ground-water contamination associated with the
     Llangollen landfill, New Castle County, Delaware.
     Proceedings of Research Symposium, "Gas and
     leachate from landfills-, formation, collection, and
     treatment," New Brunswick, New Jersey, March
Bergstrom, R. E. 1968. Disposal of wastes: scientific and
     administrative considerations. Illinois Geological
     Survey Environmental Geology Notes 20, 12 pp.
California State Water Pollution  Control Board. 1952.
     Report on the investigation of ash dumps. California
     State Water Pollution Control Board Publication 2,
California State Water Pollution  Control Board. 1954.
     Report on the investigation of leaching of a sanitary
     landfill. California State Water Pollution Control
     Board Publication 10, 92 pp.
California State Water Pollution  Control Board. 1961.
     Effects of refuse dumps on ground-water quality.
     California State Water Pollution Control Board
     Publication 24, 107 pp.
Cartwright, Keros, and F. B. Sherman. 1969. Evaluating
     sanitary landfill sites in Illinois. Illinois Geological
     Survey Environmental Geology Notes 27, 15 pp.
Cherry, J. A., G. E. Grisak, and R. E. Jackson. 1973.
     Hydrogeologic  factors in shallow subsurface radio-
     active waste management in Canada. Proceedings of
     the International Conference on Land for Waste
     Management, Ottawa, Canada, October 1-3, 1973.
Fryberger, John.  1975. Investigation and rehabilitation of a
     brine-contaminated aquifer. Ground Water, v.  13,
     no. 2, pp. 155-160.
Gerhardt, Roger A. 1977. Leachate attenuation in the
     unsaturated zone beneath  three  sanitary landfills in
     Wisconsin. Wisconsin Geological and Natural History
     Survey Information Circular 35, 93 pp.
Griffin, R. A., Keros Cartwright, N. F. Shimp, J. D. Steel,
     R. R. Ruch, W. A. White, G. M.  Hughes, and R. H.
     Gilkeson. 1976. Attenuation of pollutants in
     municipal landfill leachate by clay minerals: Part
     1 — Column leaching and field verification. Illinois
     Geological Survey Environmental Geology Notes
     78, 34pp.
Hinesly, T. D., O. C.  Braids, and J. E. Molina. 1971.
     Agricultural benefits and environmental changes
     resulting from the use of digested sewage sludge on

      field crops. Interim Report SW-30d, U.S. Environmental
      Protection Agency, 62 pp.
Hughes, G. M., R. A. Landon, and R. N. Farvolden. 1971.
      Hydrogeology of solid waste disposal sites in north-
      eastern Illinois. U.S. Environmental Protection
      Agency Report SW-12d, 154 pp.
Hughes, George M. 1972. Hydrogeologic considerations
      in the siting and design of landfills. Illinois Geological
      Survey Environmental Geology Notes 51, 22 pp.
Hunt, Cathy S., and J. P. Kempton.  1977. Geology for
      planning in De Witt County, Illinois. Illinois Geological
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Illinois Environmental Protection Agency open files,
Illinois State Geological Survey open files, Urbana.
Johnson, Thomas M., and Keros Cartwright. 1978. Monitor-
      ing the unsaturated zone in the vicinity of sanitary
      landfills. Geological Society of America, North-Central
      Section, Abstracts with Programs, v. 10, no. 6,
Kempton, John P., Jean E. Bogner and Keros Cartwright.
      1977. Geology for planning in northeastern  Illinois,
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      Illinois Geological Survey for the Northeastern Illinois
      Planning Commission, 77 pp.
Lindorff, David E., and Keros Cartwright.  1977. Ground-
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      Illinois Geological Survey Environmental Geology
      Notes 81, 58pp.
Palmquist, Robert, and L.V.A. Sendlein. 1975. The configu-
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Parizek, R. R., L. T. Kardos, W. E. Sopper, E. A. Myers,
      D. E. Davis, M. A. Farrell, and J.  B. Nesbitt. 1967.
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      products from high-ionic liquids deposited in soil.
      Atomic Energy of Canada Limited no. 1325, 46 pp.
Parsons, P. J. 1962. Movement of radioactive wastes through
      soil: Part 4, Migration from a single source of liquid
      waste deposited in porous media. Atomic Energy of
      Canada Limited no. 1485, 22 pp.
Perlmutter, N. M., and Maxim Lieber. 1970. Dispersal of
      plating wastes and sewage contaminants in ground
      water and surface water, South Farmingdale,
      Massapequa Area, Nassau County, New York. U.S.
      Geological Survey Water Supply Paper 1879-G, 67 pp.
Sopper, William E., and Louis T. Kardos, eds. 1973.
      Recycling treated municipal wastewater and sludge
      through forest and cropland. The Pennsylvania State
      University Press, 479 pp.
Sulam, Dennis J., and Henry F. H. Ku. 1977. Trends of
      selected ground-water constituents from infiltration
      galleries, southeast Nassau County, New York.
      Ground Water, v. 15, no. 6, pp. 439-445.
U.S. Environmental Protection Agency.  1977. The report
      to Congress: Waste disposal practices and their
      effects on ground water: Executive summary. U.S.
      Environmental Protection Agency, 43 pp.
Walker, T. R. 1961. Ground-water contamination in the
      Rocky Mountain arsenal area, Denver, Colorado.
      Geological Society of America Bulletin, v. 72, no. 3,
      pp. 489-494.
Walton, Graham. 1961. Public health aspects of the
      contamination of ground water in  the vicinity of
      Derby, Colorado. Proceedings of the 1961 Symposi-
      um, "Ground-Water Contamination," U.S. Depart-
      ment of Health, Education and Welfare, Public Health
      Service Technical Report W61-5, pp. 121-125.
Williams, Dennis, and Dale Wilder. 1971. Gasoline pollution
      of a ground-water reservoir—a case history. Ground
      Water, v. 9, no. 6, pp. 50-54.
Wilmoth, B. M. 1972. Salty  ground water and meteoric
      flushing of contaminated aquifers  in West Virginia.
      Ground Water, v. 10, no. 1, pp. 99-104.
     David E. Lindorff received a B.A. in Geology from
Augustana College, Illinois in 1967. He attended the
University of Wisconsin-Madison and received a Master's
degree in Geology (1969) and Water Resources Management
(1971). Mr. Lindorff then worked as a Geologist for the
Pennsylvania Department of Environmental Resources, he
became involved in a wide variety of ground-water
contamination problems in the Philadelphia area. In  1975,
he returned to Illinois, joining the Illinois State Geological
Survey. His work at the Survey has included review of case
histories of ground-water contamination and a study of
migration of heavy metals in the subsurface. He has been
a member of NWWA since 1972.

Ground-Water  Pollution  —   An  Imminent  Disaster
by Wayne A. Pettyjohn
     The significance of ground-water pollution depends
on our perspective. To those individuals who are directly
affected, it is an imminent disaster. Once contaminated,
ground water may remain in an unusable or even hazardous
condition for decades or even centuries as illustrated by
situations in central Ohio, New York, London and many
others. All polluted water can be treated to make it
potable, but the expense may far exceed the resources of
the individual homeowner.

     For millennia, man has disposed of his waste
products in a variety of ways. The disposal method
might reflect convenience, expedience, expense, or
best available technology, but nevertheless in many
instances, leachate from these wastes have come back
to haunt later generations. This is largely because we
have not thought out the consequences of our
actions. Several short circuits commonly exist in
our planning procedures. In particular these boil
down to four major unknowns that someone
eventually may have to deal with: (1) the composi-
tion and volume  of the waste, (2) the exact
location of its disposal, (3) estimates of the
potential detrimental effect of the leachate on the
environment and (4) the hydrogeology of the
     Presented at The Fourth National Ground Water
Quality Symposium, Minneapolis, Minnesota, September
20-22, 1978.
     ^Department of Geology and Mineralogy, 125 S.
Oval Mall, The Ohio State University, Columbus, Ohio
     The volume of waste produced annually is
increasing at an exceedingly rapid pace and, since
land disposal is becoming more popular, there is an
even greater potential for ground-water pollution.
Many wastes are long-lived and chemically
complex and when mixed may form new compounds
of unknown characteristics whose potential effects
on health are largely unknown. It is imperative that
we realistically examine methods of waste disposal
and possible aftereffects. Further we cannot depend
solely on federal, State or local controls.
     In most instances no well-established strategies
have been developed for rapid response to alleviate
ground-water pollution problems and in many cases,
agencies do not even have technical expertise
available to them for advice and assistance.
Furthermore, how can anyone accurately predict
what might happen at some future date at a
ground-water contamination site since installation
of other wells, variable discharge rates and changes
in land use all may influence overlapping cones
of depression and drastically change the configura-
tion of the water-level surface?
     Individual polluted ground-water sites generally
do not include extremely large areas. The problem
cannot be compared to a modern day example of
On the Beach. On the other hand, ground-water
pollution is certainly a disaster to those individuals
who depend on ground water as their source of
supply and who awake some morning to find it
contaminated. Moreover, regulatory agencies,
industries and the courts have paid but little
attention to the problems of individual homeowners
who usually must bare the sole burden of cost and
inconvenience, perhaps for years.
     Ground-water pollution may lead to problems

 of inconvenience, such as taste, odor, color,
 hardness, or foaming but some cases are far more
 serious when pathogenic organisms, flammable or
 explosive substances or toxic chemicals or their
 by-products are concerned, particularly when
 long-term health effects are unknown.
     The purposes of this report are to point out
 that (1) ground-water pollution is an imminent
 disaster to those individuals who are directly
 affected, and that (2) once polluted, ground water
 may remain in an unusable or even  hazardous
 condition for decades or even centuries. Granted,
 any water supply can be treated to  make it
 potable, but can the individual homeowner pay
 the cost and should he be required to do it? The
 examples briefly described herein are few in
 number only because of space constraints. The
 illustrations are highly generalized,  but nearly all
 are adequately described in the literature.

            1968 - CENTRAL OHIO
     An oil-field brine holding pond was constructed
 adjacent to a producing well in central Ohio in
 1968. Two years later when the well was plugged,
 the holding pond was filled, graded and seeded.
 The chloride concentration in the ground water
 in the vicinity of the former pond still exceeds
 36,000 mg/1 some 10 years after the operation
 began and 8 years after reclamation.

            1964 - CENTRAL OHIO
     Scores of brine holding ponds  were constructed
 in central Ohio during an oil boom in 1964; many
 are still in use. Recently a number of test holes
 were constructed within 200 feet of one such pond.
Within its vicinity shallow ground water contains
 as much as 50,000 mg/1 of chloride  and reflects a
 problem that began more than 14 years ago.
Moreover, brine-contaminated ground water
provides part of the flow of many streams and this
has caused degradation of surface-water quality
(Pettyjohn, 1971, 1973, 1975).

         1954 - BAVARIA, GERMANY
     Documentation of the migration of leachate
plumes originating at garbage dumps and landfills
is becoming increasingly abundant. Data show
that under certain hydrologic conditions leachate
plumes can move considerable distances and
degrade ground water throughout wide areas.
Furthermore, the problem is worldwide. Exler
(1974) described a situation in southern Bavaria,
Germany where a landfill has been in operation
since 1954. The wastes are dumped  into a dry
            BAVARIA, GERMANY
                           --  -      ,^--,—ry
                More than 2 miles
 Fig. 1. Leachate from a landfill in Bavaria has migrated
 more than 2 miles and the ground water has been degraded
 for nearly 25 years.
gravel pit. Data collected from 1967 to 1970
showed the narrow lense-shaped plume had
migrated nearly 2 miles (Figure 1). The ground
water in the vicinity of this site has been
degraded for nearly 25 years.

          1945 - KEIZER, OREGON
     Incompletely processed aluminum ore was
dumped into a borrow pit in Keizer, Oregon from
August 1945 to July 1946 (Price,  1967). The ore
and mill tailings had been treated with sulfuric
acid and ammonium hydroxide. First recognized
by local residents in 1946, the contaminated
ground water locally  contained more than  1,000
mg/1 of sulfate; many shallow domestic wells
tapping the Recent alluvium were  contaminated
(Figure 2).
     In the Spring of 1948 the waste was removed
from the borrow pit. Two wells, reportedly capable
of producing more than 700 gpm (gallons per
minute) were installed near the pit and for  several
months pumped to waste the contaminated ground
water.  By 1964 the contaminants had migrated
more than a mile. No doubt some  of the waste is
still in  the ground water at Keizer, and although
               KEIZER, OREGON
                      processed Al ore
Fig. 2. Thirty-three years after disposal began the leachate
from aluminum ore and mill tailings is still a problem in
Keizer, Oregon.

considerably diluted, its effects remain noticeable
some 33 years after disposal began.

     Hooker Chemicals & Plastics Corp. began to
bury chemical-filled drums in and along the margin
of Love Canal in Niagara Falls 36 years ago. In 1953
the 16-acre site was sold for $1.00 to the Niagara
Falls Board of Education (Anon., 1978). The area
was soon developed. By 1976 an abnormally high
water table caused some of the chemicals to seep
to the surface  and form pools; fumes seeped into
     So far more than  80 chemicals have been
identified and at least 7 are carcinogenic. There
are at least 30 sites like Love Canal in New York
alone. Nationally, according to the U.S. Environ-
mental Protection Agency, there are more than a
     Are examples of ground-water pollution by
industrial  wastes a rarity? Not likely, if the situation
in Michigan is typical.
     "Declared bankrupt  in August, the Story Chemical
Company left a disarray of improperly stored chemicals on
its site in Muskegon. Lakeway Chemical's contamination
results from 13 years of discharges to seepage lagoons. In
April, Systech Waste Treatment Center reported that
500,000 gallons of sodium formate wastes were missing
from their underground storage facility and presumed to
be in the ground. Contamination at the Hooker Chemical
site consists of hexachlorobenzene, C-56, carbon tetra-
chloride, and tetrachloroethylene. Ground waters at the
Central Sanitary Landfill near Pierson in Montcalm County
were contaminated when Approved Industrial Removal, a
licensed liquid industrial waste hauler, illegally buried a
truck tank plus a 10,000-gallon tank in the ground and
filled them  with 8,000 gallons of C-56 wastes from Hooker
Chemical. Later removal of the tanks disclosed damage and
leakage. Production Plated Plastics, Inc., a company that
metal plates plastic automotive components such as
hubcaps and headlamp housings, doubled their production
without increasing their waste-water treatment capacity.
As a result, residential wells in the area are contaminated
with high levels of chromium. At the Gratiot County
Landfill, Michigan Chemical disposed of 270,000 pounds
of waste containing 70 percent PBBs. Preliminary studies
show traces of PBBs in the ground water." — (Water Well
Journal,  1978, p. 15.)

      1942  - LONG ISLAND, NEW YORK
     A well-documented study by Perlmutter  and
others (1963) showed  that disposal of chromium
and cadmium-rich plating wastes from an aircraft
plant on Long Island during a  20-year period
contaminated a shallow aquifer (Figure 3). The
contamination was first discovered in 1942, and
by 1962 the degraded  ground-water zone was  about
4,200 feet long and  1,000 feet wide. The 1962
study demonstrated that the chromium-cadmium
enriched cigar-shaped plume "had not only reached
Massapequa Creek but was present in the stream as
well as in the beds beneath it" (Perlmutter and
others, 1963, p. C183).
     Now, more than 36 years after disposal began,
these plating wastes are still  slowly migrating with
the ground water.

        1936 - WESTERN MINNESOTA
     During the middle and  late 1930's grasshopper
infestations were stripping the vegetation through-
out wide areas in the Northern Great Plains. In
western Minnesota partial control was obtained
by a grasshopper bait consisting of arsenic, bran
and sawdust. Eventually the leftover bait was
buried. In May 1972, a  contractor drilled a well
near his office and warehouse on the outskirts of a
small town. During the  next two and a half months
11 of the 13 individuals employed at the site
became ill; two were hospitalized. They were
suffering from arsenic poisoning. One sample of
water from the well contained 21 mg/1 of arsenic.
Analysis of soil from  the site revealed arsenic
concentrations ranging from 3,000  to 12,000 mg/1.
Apparently the well was drilled in the near vicinity
of the grasshopper bait  disposal site, the location of
which had long been forgotten by the local
residents who had been bothered by grasshoppers
some 40 or so years earlier  (AWWA,  1975).

       1914-1918 -  LONDON, ENGLAND
     Wastes from munitions works  include picric
acid, a toxic, intensely bitter, pale yellow substance.
Picric acid is not readily removed by traditional
water treatment methods and its migration through
the unsaturated or saturated zone does not appear
to neutralize it.
     During the critical World War  I years of
1914-1918, wastes from the manufacture of
explosives at a plant near the Thames River just
         LONG ISLAND, NEW YORK 1942
 Massapequa Creek
 Fig. 3. More than 36 years after disposal of plating wastes
 began, the ground water remains polluted in South

   A  A
          More than 1 mile
 Fig. 4. The picric acid, which has been found in the ground
 water near London for decades, originated at a World War I
 munitions plant.
northeast of London, England were placed in
abandoned chalk pits (Figure 4). In the early
1920's water from a nearby well was first reported
to have a yellow tint (Essex Water Co., 1974).
Additional water samples collected between 1939
and 1955 also contained a characteristic yellow
picric acid tint. Sampling ceased in 1955 when the
pump was removed.
     By 1942 the pollutants had migrated at least
a mile as indicated by another contaminated well.
There is no reason to believe that the picric acid
has been flushed from the aquifer within the
past 23  years. The ground water has certainly been
polluted for 40, quite probably for more than 60,
and very likely for many more years to come.

        1910 - BARSTOW, CALIFORNIA
     Because of high evaporation and low recharge,
waste disposal in arid regions can lead to long-lived
ground-water quality problems. In the first place,
salts are concentrated by evaporation to form highly
mineralized fluids. Secondly, water supplies may not
be readily available and, therefore, every effort must
be made to protect existing supplies.
     Ground-water contamination in the desert
environment near Barstow, California was described
by Hughes (1975). Beginning around 1910, waste
fuel oil  and solvents from a railroad system were
discharged to the dry floor of the Mojave River near
Barstow. The first municipal sewage treatment plant
was constructed in 1938; the effluent was
discharged to the riverbed. Sewage treatment
facilities were enlarged in 1953 and  1968. Effluent
disposal was dependent on evaporation and direct
percolation into the alluvial deposits.
    At the U.S. Marine Corps base near Barstow,
industrial and  domestic waste treatment facilities
first became operational in 1942; effluent disposal
relied on direct percolation and evaporation. Some
of the effluent was used to irrigate a golf course.
Other sources of ground-water contamination were
two nearby mining and milling operations.
     Analysis of well waters collected during the
Spring of 1972 indicated the existence of two zones
of contaminated ground water in the alluvial deposits
of the Mojave River (Figure 5). The deeper zone,
originating from the 1910 disposal area, exceeded
1,800 feet in width and extended nearly 4'/2  miles
in a downgradient direction. Its upper surface lies
60 or more feet below land surface. The second or
shallow zone originates at the sewage treatment
lagoon installed in 1968 and at the Marine Corps
golf course. This zone consists of two apparently
separate plumes. The upgradient plume extends
nearly 2 miles downstream, while the plume
originating at the golf course is nearly a mile long.
They are about 700 feet wide. Hughes estimated
that the pollution fronts are moving at a rate of
1 to 1.5 feet  per day. The Marine Corps well field
lies in the path  of these plumes; several domestic
wells  have already been contaminated. In this
instance poor waste disposal practices, beginning
nearly 70 years ago and coupled  with subsequent
inadequate methods, may cause water-supply
problems at the Marine Corps base unless expensive
corrective measures are undertaken.

          1905 - LONDON,ENGLAND
     From 1905 to 1967 wastes  from a gasworks
plant were deposited in abandoned gravel pits
along the Lee River near Waltham Cross, a few
miles northwest of London, England (Toft, 1974).
The tar acids, oils, and sulfate sludge infiltrated to
contaminate  the ground water over a wide area
(Figure 6). Apparently the pollution was first
detected in 1935, some 30 years after disposal
began. At this time oil, floating on the ground
water, emerged at land surface. Continual but slow
accumulation of oil on the land led to hazardous
conditions and, in 1943, the oil was ignited.
    Industrial wastes,
    fuel oil, solvents
                  BARSTOW, CA
Barstow waste
disposal ponds
   US MC
  golf course
sewage irrigation
         More than 4 miles
Fig. 5. Waste disposal beginning nearly 70 years ago at
Barstow, California is now threatening an important well
field at the nearby Marine base.

                   LONDON, ENGLAND
Fig. 6. Ground-water pollution by wastes from a gasworks
plant near London has even created a fire hazard.
Contaminated ground water was also encountered
in new excavations where it appeared as high
concentrations of sulfate in 1958 and as oily waters
in 1961. Oily liquids also seeped into Pymmes
Brook and the River Lee Navigation channel in
1965 following a substantial rise in the water
table after heavy rains. In 1966 additional surface-
water degradation occurred because of the
discharge of oil from streamside seepage zones.
     Ground water in the surficial sand and gravel
deposit was contaminated over a wide area.
Fortunately, most water supplies in this area are
pumped from an underlying chalk, which through-
out much of the region is separated from the gravel
by the London Clay. It is evident from this
example that waste disposal, which began more
than 70 years ago, continues to be troublesome
and that ground-water contamination can indeed
become a fire hazard.

     All ground-water pollution is not necessarily
bad. Inhabitants of Crosby, a small village in
northwestern North Dakota, believed they produced
the best coffee in the State because the water from
which it was made contained "body." The rather
highly mineralized water (dissolved solids = 2,176,
sulfate =  846, chloride = 164, and nitrate =150 mg/1)
used for brewing the coffee was obtained exclusively
from an old dug well. The well, however, was
constructed, probably near the turn of the century,
at the site of the local livery stable. Apparently
it was livestock wastes that provided the peculiar
flavor so  characteristic of the coffee made in
Crosby (Pettyjohn, 1972).

          1899 - BARBERTON, OHIO
     The manufacture of soda ash, caustic soda,
chlorine and allied chemicals began at Barberton,
Ohio shortly before the turn of the century. The
plant discharged a mixture of calcium and sodium
chlorides directly to the Tuscarawas River and to
retention ponds. The discharge of chloride in 1966
averaged 1,500 tons per day (Rau, 1975). These
wastes have led to serious ground-water pollution
problems in eastern Ohio and have necessitated
abandonment of streamside well fields at Barberton
in 1926 and at Massillon and Coshocton in 1953.
     Municipal wells at Zanesville, more than 135
river miles downstream from Barberton, have also
been adversely affected by the  chloride induced
into the watercourse aquifer from the contaminated
Muskingum River. Due to high treatment costs
Zanesville officials considered abandoning their
well field in 1963. At the confluence of the
Muskingum and the Ohio Rivers, about 220 river
miles below Barberton, is the city of Marietta.
Almost 20 years ago, Marietta officials were
concerned over the marked increase in chloride in
municipal wells during the preceding 10 years
(Parker, 1955). The cause, of course, was induced
infiltration of the chloride-rich Muskingum River
water (Pettyjohn, 1971).
     It is evident that decades of poor waste-
disposal practices at Barberton have grossly
contaminated or seriously impaired streamside
aquifers and well fields for a distance of over 200
river miles. The soda ash plant  at Barberton was
closed in 1973 and waste discharges substantially
reduced. Presumably, these water-quality problems
will decrease in severity over the  next several years,
after a history of nearly 80 years.

       1887 - COEUR d'ALENE, IDAHO
     According to Mink and others (1972), mining
operations in the Coeur d'Alene district of northern
Idaho have been continuous for more than 90 years.
Unfortunately, leaching of the ancient mining and
milling wastes is now affecting the chemical
quality of ground water in several areas, including
Canyon Creek basin near Wallace. Here high
concentrations of zinc, lead, copper and cadmium
occur in both ground water and soil samples.

     Ninety-four years ago, striking miners set fire
to several deep mines in the vicinity of New
Straitsville, Ohio. Still burning uncontrollably, the
fires were started by disgruntled workers who rolled
burning wood-filled coal cars into the shafts that
honeycomb the ground under the town. In the
years since, many wells have become contaminated,
dried up or produce water hot enough to make
instant coffee.

           1872 - BELLEVUE, OHIO
     Disposal of domestic, industrial and municipal
wastes, which probably began around 1872 through
wells and sinkholes tapping a permeable limestone
aquifer, was the birth of a contaminated area that
now encloses some 75 square miles. By 1919 the
practice of disposing of sewage at the northern
Ohio town of Bellevue was well established and
many wells had been contaminated. In the early
1960's some wells were reported to yield easily
recognizable raw sewage, including toilet tissue
and a variety of unmentionables (Ohio Division of
Water, 1961). This problem began more than a
hundred years ago and remains to this day.

         1815 - NORWICH, ENGLAND
     A gasworks plant was built at Norwich in
1815 and abandoned  in 1830. Phenolic compounds,
originating from whale oil, infiltrated and remained
in the underlying chalk for at least 135 years
when it contaminated a newly drilled well in 1950
(Wood, 1962; Pettyjohn, 1972). These organic
compounds, no doubt, are still there more than
160 years later.

     A well drilled into the chalk at a gasworks
plant in southern England produced hydrogen
sulfide. Although questionable, officials claimed
that the hydrogen sulfide was derived from drainage
from a 17th Century Black Plague burial pit.
     For centuries man has tolerated inadequate
waste disposal and even when the resulting
contamination leads to great expense and incon-
venience, generally no one is greatly concerned
except, perhaps, those immediately affected. This
is not always the case, however, and sometimes the
reaction is swift and effective. My colleague Stig
Bergstrom has provided an example. The popularity
of many European health spas is closely interwoven
with the spa's reputation, a slight blemish on which,
either real or implied, can be disastrous. A few years
after World War I, a small town in central Sweden
became well known for the mineralized waters at
their extremely popular spa. The water, pumped
from a well, was distributed to specific-use sites,
including an open basin or fountain used
exclusively for drinking water.
     Following a formal ball and a good deal of
eating and drinking, officers from a nearby  military
installation gathered in the vicinity of the
drinking fountain. The next morning a rumor
quickly spread that one of the drunken officers had
urinated in the fountain. Within hours of this
unsubstantiated event, spa guests began a mass
exodus and reservations were cancelled. The spa
never regained its popularity and shortly thereafter
it was forced to go out of business.
     The Swedish reaction, however, is certainly
not universal. Bill Back of the U.S. Geological
Survey described an interesting example of
complacency. Near the center of a village in the
Yucatan is a large-diameter dug well that
apparently is used for more than just a water
supply. One public spirited individual painted in
large bold letters the following request: NO
ORINAR EN ESTE POZO. Neither the sign nor
what  it implies has had much effect on the
population or the use of the well.

     Our concept of the seriousness of ground-water
pollution is related to our perspective. Generally
we overreact, underreact,  or simply don't react at
all. On the other hand, ground-water pollution is
indeed an imminent disaster for those who are
directly affected or those  who will be affected
some  time in the future. The problem is further
compounded by a general lack of adequately
trained regulatory personnel, ineffective legal
controls and primitive but expensive  cleanup
procedures. The few cases cited above conclusively
show  that, once polluted,  an aquifer may remain
in an unusable or even hazardous condition for
decades or even centuries.

American Water Works Association. 1975. Status of water-
    borne diseases in the U.S. and Canada. Jour. Amer.
    Water Works Assn. v. 67, no. 2, pp. 95-98.
Anonymous. 1978. A nightmare in Niagara. Time Magazine.
    Aug. 14, 1978, p. 46.
Essex Water Co. 1974. Enduring pollution of groundwater
    by nitrophenols. In Groundwater Pollution in Europe.
    Water Information Center, Port Washington, New
    York, pp. 308-309.
Exler, H. J. 1974. Defining the spread of groundwater
    contamination below a waste tip. In Groundwater
    Pollution in Europe. Water Information Center, Port
    Washington, New York,  pp. 215-241.
Hughes, J. L. 1975. Evaluation of ground-water degradation
    resulting from waste disposal to alluvium near Barstow,
    Cal. U.S. Geol. Survey, Prof. Paper 878, 33 pp.
Mink, L. L., R. E. Williams, and A. T. Wallace. 1972. Effect
    of early day mining operations on present day water
    quality. Ground Water, v. 10, no. 1, pp. 11-26.
Nash, G.J.C. 1962. Discussion  of paper by E. C. Wood.
    Proc. Soc. Water Treatment and Examination, v. 11,
    p. 33.
Ohio Division of Water. 1961.  Contamination of underground
    water in the Bellevue area. Ohio Dept. Nat. Resources,
    Mimeo Rept., 28 pp.

Parker, G. G. 1955. The encroachment of salt water into
     fresh. In Water, Yearbook of Agriculture: Dept.
     Agriculture, pp. 615-635.
Perlmutter, N. M., Maxim Lieber, and H. L. Frauenthal.
     1963. Movement of waterborne cadmium and
     hexavalent chromium wastes in South Farmingdale,
     Nassau County, Long Island, New York. U.S. Geol.
     Survey Prof. Paper 475-C, pp. C179-C184.
Pettyjohn, W. A. 1971. Water pollution by oil-field brines
     and related industrial wastes in Ohio. Ohio Journal
     Sci. v. 71, no. 5, pp. 257-269.
Pettyjohn, W. A. 1972. Good coffee water needs body.
     Ground Water, v. 10, no. 5, pp. 47-49.
Pettyjohn, W. A. 1973. Hydrologic aspects of contamination
     by  high chloride wastes in Ohio. Jour. Water, Air and
     Soil Poll. v. 2, no. l,pp. 35-48.
Pettyjohn, W. A. 1975. Chloride contamination in Alum
     Creek, central Ohio. Ground Water, v. 13, no. 4,
     pp. 332-339.
Price, Don. 1967. Rate and extent of migration of a
     "one-shot" contaminant in an alluvial aquifer in
     Keizer, Oregon. U.S. Geol. Survey Prof. Paper
     575-B,pp. B217-B220.
Rau, J. L. 1975. Effects of brining and salt by-products
     operations on the surface and ground water resources
     of the Muskingum basin, Ohio. Fourth Symp. on Salt,
     Northern Ohio Geol. Soc., pp. 369-386.
Toft, H. P. 1974. Pollution of flood plain gravels by gas
     works waste. In Groundwater Pollution in Europe:
     Water Information Center, Port Washington, New
     York, pp. 303-307.
Water Well Journal. 1978. Michigan begins in-depth study
     on ground water. Water Well Journal. March 1978,
     p. 15.
Wood, E. C. 1962. Pollution of ground water by gasworks
     waste. Proc. Soc. Water Treatment and Examination.
     v. 11, pp. 32-33.
      Wayne A. Pettyjohn is a Professor of Geology at The
Ohio State University, an attorney and consultant. He holds
degrees in Geology from the University of South Dakota (2)
and Boston University. Joining the U.S.G.S. in 1963, he
resided in North Dakota until 1967, when he left for Ohio
State, although continuing WAE with the Survey. While
with the  U.S.G.S., Dr. Pettyjohn read law with the Supreme
Court and was admitted to the bar in 1968. His research
and investigations span a wide spectrum. He has authored
or coauthored more than 80 books and reports. Wayne has
served two terms on the Board of Directors of the Ground-
Water Technology Division, and is on the Editorial Board for
Ground Water.

Ground-Water  Pollution  —  A  Limited  Problem"
by D. Theodore Clarkb
     Few would argue that ground-water pollution is a
problem and that serious ground-water pollution problems
do exist. As serious as some isolated ground-water pollution
problems are, regionally and nationally, it is only a
limited problem. An industrial landfill may result in a
leachate plume contaminating ground water over an area of
up to several square miles downgradient from the disposal
site. Municipal landfills or chemical/petroleum spills can
result in polluted ground water over areas measured in
square miles. Surrounding these areas of ground-water
pollution, however, are tens and hundreds of square miles
of area where the ground water moving through the aquifers
maintains its natural good quality. The ratio of good quality
to contaminated water is such that ground-water pollution
can really only be considered as a limited problem.
     The problem will most likely remain limited as
existing and future regulations continue to restrict the poor
disposal practices that have been responsible for much of
the past and existing pollution problems. Technology
has advanced to  the point that with proper management
and sound governmental regulations, control, isolation and
cleanup of contamination sources and areas of polluted
ground water can be so effective that migration of the
pollution front can be stopped and actually reversed with
      Presented at the Fourth National Ground Water
Quality Symposium, Minneapolis, Minnesota, September
20-22, 1978.
     bsenior Hydrogeologist, Dunn Geoscience Corporation,
5 Northway Lane, North, Latham, New York 12110.
     The same technology that provided us with the new
chemicals and the wastes that show up in water analyses,
has also provided us with the means of detecting many more
contaminants at much lower levels of concentration in a
water sample than was possible 50, 25 or even 10 years
ago. One must  thus ask, has ground-water pollution really
become a national crisis, or do we just know more about an
old problem made apparently more complicated by our
own technological advances?

     I am here for two reasons: first, I find the
NWWA Technical Sessions worth my time because
they are very well done and informative. And,
secondly, I am here because of the initial announce-
ment of this  Symposium I picked  up at last year's
Technical meetings in Boston. A quick review of
the announcement started me thinking, how can
"ground-water pollution—a limited problem" be
considered the negative side of the issue? Can
"ground-water pollution—an imminent disaster"
really be the  positive side of the issue? So, in a way,
I'm here to defend the issue that ground-water
pollution is a limited problem and, in some respects,
it can be considered the positive side of the
     In support of the limited problem of ground-
water pollution, I will concentrate my discussion on
two basic concepts: first, the ratio of nonpolluted
to polluted ground water; and, second, the role of
technology in ground-water quality.
     Dr. Pettyjohn has given us some examples of
serious ground-water pollution and the problems
that can result. Most of us have either seen or heard

about serious ground-water pollution problems—
they do exist. There are thousands of municipal,
industrial, and private landfills across the country.
Many of these landfills have the potential for
pollution, and, in some cases, they in fact do
pollute the ground water below and adjacent to the
disposal areas. Hundreds of additional pollution
problems have resulted from storage tank and
pipeline leaks of petroleum products. Many of
these leaks and spills are serious because of the
volume of product involved and the effort that
must be expended to correct the problem.
     Not many of these problems, as serious as they
are, however, affect large areas. Most of the serious
ground-water pollution problems that I am aware of
affect areas measured in the tens to hundreds of
acres with a few  involving several square miles. Let's
put the ratio of polluted ground water to natural,
nonpolluted ground water  into perspective. I will
use the State of Ohio to illustrate my point. The
land area of Ohio is 41,000 square miles. Ground
water is produced from high yielding sand and
gravel deposits, carbonate and sandstone aquifers,
and poor yielding shale aquifers. Ohio ranks high as
an industrial State and has a  high population that is
spread fairly uniformly across the State. For one
percent of the State to have a serious ground-water
pollution problem, it would require 410 individual
sites creating ground-water contamination each
averaging a square mile, or 2,600 individual sites,
if we use a more  realistic size of 100-acre sites.
     Here's another way to look at it. In north-
western Ohio, individual wells will yield 100 to
1,000 gpm from  the carbonate aquifer. It is possible
that the water may be high in hardness or contain
some H2S or iron, making it poor quality water, a
natural problem, but the water is generally of good
quality. The point is, wells yielding adequate
amounts of good quality, natural ground water
can be drilled almost anywhere in northwestern
Ohio. If local landfills, chemical plants, or petroleum
terminals cause a local ground-water pollution
problem, some adjacent area residents may have  to
have new wells drilled or have to relocate to obtain
a satisfactory water supply. But, these steps can
be done and have been done. Sure it's a serious
problem, but I would not consider it a disaster.
     Technological advances over the past  10 to  20
years have provided us with many new products,
chemicals, synthetics, and  ever increasing quantities
of waste. Environmental concerns raised during the
past decade have made us all aware of the problems
resulting from unchecked discharge and disposal
of our waste products. The same technology that
developed the new products has also provided the
capability of detecting an increasing number of
chemicals, metals and minerals in smaller and
smaller concentrations. A water sample 10 years
ago that was tested and reported as "pure, natural
ground water," today could be considered as
polluted because of our ability to measure traces
of a metal or chemical now known to be harmful if
consumed in large quantities. The point is that
ground-water pollution is not new; what is new is
how and what is causing the pollution and the fact
that sources of past and present pollution can be
detected more readily.
    There will be a tendency in the future for
ground-water pollution to be abated for several
reasons. Federal, State and local regulations covering
the handling, storage, use, and disposal of chemicals
and wastes have initiated increasing control over
the rising rate of ground-water pollution. Improved
regulations and disposal methods should decrease
the potential for future ground-water pollution.
As we become more aware of the cost of improper
disposal practices and the resulting wasting of our
natural resources, there will be a more conscious
effort toward improved waste disposal and pollution
    A second reason why serious ground-water
pollution will be decreased is the improved under-
standing and capability of controlling and contain-
ing sources of ground-water pollution. Many of
the serious ground-water pollution problems that
exist today are the result of past waste disposal
practices or a leak that went undetected for a long
period of time. Some of the problems are being
controlled to limit the migration of contaminated
water. In some cases, efforts are underway to
totally confine or even remove the source of the
problem. And, of course, many of the causes for
such pollution are being controlled now that the
nature of the results is better known.
     The control and the restoration  of ground-
water pollution are the keys to solving the most
serious problems without the situation becoming a
disaster. The disaster may result from the cost
and effort involved in the control  and restoration
of the problem. A case in point is  the Love Canal
problem in Niagara Falls, New York.
     Several additional examples may better
illustrate how  applied technology has been used to
limit or solve the problem of ground-water pollution.
In the first situation, an abandoned sand and gravel
pit was used initially as a dump until regulations
prohibited such operations. To become an
"approved landfill," burning of trash stopped and

waste was covered with sand located on the site.
Several truck loads of sewerage treatment plant
sludge and an industrial liquor are also disposed of
at the site each day. About 6,000 feet downgradient,
but east of the normally expected ground-water
flow paths, are two municipal water-supply wells
drawing water from the same glacial aquifer complex
in which the landfill is located. The position of the
two wells altered the ground-water flow path by
drawing landfill leachate-contaminated ground
water into the wells. Chlorides and nitrates reached
a high level resulting in a total shutdown of the
two wells. Evaluation of the ground-water flow
paths indicated that with time, the water quality
adjacent to the wells should improve and that the
wells could be pumped for short intervals to help
meet peak demands. Consideration is being given
to diversion pumping  as a means of offsetting the
effect of the pumping wells. In this case, alternate
actions are taking place to deal with a pollution
problem created by poor waste disposal activities
of the past.
     The second example involves past disposal
activities of industrial chemical waste. The disposal
site had not been used for several years and, in
fact, had been reclaimed to the extent that part of
the area is the site of a modern chemical waste
treatment facility. A preliminary  ground-water
monitoring program of the site indicated
contaminated ground  water, the source most likely
being the abandoned disposal area. A more detailed
study confirmed the source and the extent of the
problem. Due to the chemical nature of the source
and the fact that the problem would not go away in
a short period of time, it was concluded that the
source area should be contained to stop the
migration of contaminated ground water beyond
the property. A containment system was installed
and followup monitoring has demonstrated its
effectiveness. The source has been isolated and
ongoing work outside the containment area is in the
process of achieving almost complete ground-water
quality restoration. In this example, a ground-water
pollution problem has been brought under control
and the potential of it becoming a more serious
problem averted.
     The objective of this Symposium and the three
points of view presented are to generate interest
resulting in an exchange of ideas and comments. It
has been my pleasure to be a part of this program.
Thank you.
     D. Theodore Clark has been employed by the
consulting firm of Dunn Geoscience Corporation, Latham,
New York, as Senior Hydrogeologist since 1973. His
responsibilities include ground-water exploration and
development, aquifer tests and analysis, hydrologic water
budget analyses, and ground-water pollution studies.
During the past two years, Mr. Clark has worked extensively
on ground-water pollution monitoring and evaluation of
industrial and chemical landfills.-

Audience  Response   to  Session  I  —  Ground-Water  Pollution
Wayne Jackman, Ontario Ministry of the Environment,
Stoney Creek, Ontario, Canada L8E 3H2:  I'd like to give an
example of what confronts our government. It shows the
frustration we have in regard to environmental impact
      Locations of a landfill site must have proper hydro-
geologic evaluation done by consulting firms. When it
involves an  environmental hearing board, the opponents
are given a say. In many cases the regional  governments, as
well as individual public groups, hire hydrogeologists to
oppose the landfill sites, resulting in hydrogeologists
arguing against hydrogeologists.  In many cases, you end up
with a committee trying to decide what  is  right and wrong,
becoming so confused that they submit to political pressures,
and landfill sites go down the tubes, although it may have
been a very good site to begin with. Then the cycle starts
all over again.
      In the meantime, old and out-of-date landfill sites are
being  over-taxed, built too high, industrial wastes are being
put into them, in many cases illegally-, but, because a number
of areas where deep well disposal has been cut off or
alternative types of treatment have not gone in because of
the local opposition from citizens' groups, we end up with
a situation where industrial wastes aren't allowed to be
disposed of anywhere, but it has to be disposed of some-
where, so illegal operations result.

Ray Kazmann, Professor, Department of Civil Engineering,
Louisiana State University, Baton Rouge,  Louisiana
70808: This session is going to set the tone for this
Symposium. What we say here will influence legislation and
will influence attitudes.
      I'd like to take the negative side of this argument that
the ground-water pollution problem is a relatively limited
problem. Anytime someone points to a major pollution
problem and has to bring in illustrations 130 years old—
that's stretching to make a case. None of the problems that
have been brought forth are insolvable from an engineering
standpoint. It's a question of money. Who pays how much?
That's important, but there are also costs involved in writing
legislation based on hard cases, because that means that
you're involving the entire country in unnecessary costs
for things that may not ever happen.
      There's also a necessity to place a  priority system on
contamination cases. Biodegradable compounds—sure they're
important, but they're  relatively easy to treat. Once you
get the leachate out of  the ground, you can treat it with
almost normal municipal sewage practices—either lagoons
or some other relatively cheap method. Poisons, like these
PCB's, are another problem and they need to be monitored
and collected. Exactly what to do with it I don't know
because nobody seems  to come forth with a chemical
solution. But I can collect it for you at least.
      Metals, heavy metals, chromium and hexachromium,
primarily are difficult but they might be considered  as oil
bodies. Pump the water out, treat it, and get the cadmium
or other metal out. So I don't consider hard cases to be a
good basis for passing legislation. I think the problem is
more local, and if you can associate future mistreatment
of wastes, make the perpetrator pay; that's really the purpose
of legislation. We need more education; we  need more maps
showing areas favorable for waste disposal and unfavorable
for waste disposal. It's education and a matter of priority.
Keith G. Kirk, Partner/Hydrogeologist, Environmental
Exploration, Inc., Box 795, Morgantown, WV 26505:
I put forth to you that there is no imminent disaster of
ground-water pollution, but in fact an ongoing catastrophe.
In the coal mining areas of the Appalachians and eastern
coal measures, ground water has already been irreversibly
contaminated and depleted by fossil fuel extraction, i.e.
coal mining, oil and gas production. In the three-county
area surrounding Pittsburgh, the major aquifer, other than
alluvial deposits adjacent to the rivers, is the Pittsburgh
sandstone. This aquifer has been polluted by acid mine
drainage or dewatered entirely from the mining of the
valuable Pittsburgh coal seam.
      In the highly acid-producing coal measures of central
Pennsylvania, near  Brookville, Pennsylvania, over 500
square miles of land are all but devoid of potable ground
water because of over half a century of mineral extraction
that has again either polluted or depleted the ground water
in that area. Example after example of such contamination
could be cited. This contaminated ground water adversely
affects rural Appalachia and helps to compound its
problems of unemployment and rural poverty.
      Now, in the name of energy independence, much
of the ground water in the western States will soon fall
victim to the shovels of the energy extractors, just as much
of the ground-water resources in the Appalachians has.
Action must be taken by hydrogeologists and contractors
immediately to insure that the ground-water protection
section of the recently passed Federal Surface Mine
Reclamation Act is enforced. The Office of Surface Mine
Reclamation, the agency in charge of enforcing this act, is
already  backstepping because  of pressure from the  coal
industry. Citizens of the western coal  measures, you have
been put on notice!
Jim Waltz, Associate Professor of Hydrogeology, Colorado
State University, Fort Collins: I'd like to talk about number
four on the Scoreboard of contaminant incidents; the
organic contaminants. I think it was at the First Ground
Water Quality Symposium in Denver that I addressed the
topic of contamination from sewage disposal through
septic tank systems. Contamination from septic tank
systems, particularly in areas of igneous and metamorphic

crystalline rocks, constitutes a type of contamination that
is geologically sensitive.
      Because it has to do with individuals, it is seldom
monitored adequately. I think this problem is more intense
than would be indicated by the fourth ranking ahead of
industrial landfills, petroleum, and organics which was the
order in which the wastes were listed according to incidents.
I feel that there are many more incidents of organic waste
contamination from septic tank systems that are never
discovered because it has to do only with private
individuals. The conventional septic  tank sewage system,
the leach field system, is designed to be used for soils
that are about 6 feet thick. In the mountainous terrain,
the igneous and metamorphic terrain, where I've had most of
experience, soils are rarely over a foot  thick. The weathered
rock can be altered and dug, and it's considered by county
sanitarians to be soil. It has the percolation characteristics
of a good soil, but not a filtering characteristic, and I think
that is the critical point in the errors that are made
permitting absorption fields to go in where they should not.
      The aspect of this problem which makes me think that
it is not an imminent disaster is that in some of the mountain
communities in Colorado, where I've done my studies,
where perhaps 50 percent of the wells  are contaminated by
this source of contamination, the residents are uninformed
about having X number of bacteria in their well. They say,
"I've been drinking it  for 20 years. I feel great." Perhaps
that clearly underlines the fact that there is no disaster in
this type of contamination, but there are also cases
where contamination has occurred, and where serious illness
results. If a person is drinking his own  sewage, perhaps
that's not a serious problem, but I do think it deserves
more attention than it's getting.

Brad Caswell, Maine Geological Survey, Augusta, Maine:
I represent Maine. We  don't have too many ground-water
regulations at this time. In fact, we don't have much ground
water but I'd like to speak about the bureaucracy doing the
regulating, as being part of what I see as the ground-water
pollution  disaster. We're all looking up to these institutions
to protect our ground water. We give them a little science,
they give us back the bureaucracy to do it, and it has begun
to scare me.  I had something to do with setting up or
suggesting ways of disposing of solid waste in Maine about
7 years ago. We have all kinds of forms, all kinds of people
hired, and there's a definite procedure  of waste regulation
going on in Maine. It's come to me now that some of our
procedures are wrong. We need to change them. I go back
to that bureaucracy and I'm having a heck of a time getting
people to  listen, getting them to change their style. Maine
is just now starting to  talk about more  regulations because
we're becoming more  interested in ground water. We
recently had our biggest pollution disaster in Maine's history.
      I'm  quite frightened that we may now regulate
ground water to a point where the bureaucracy gets so
intransigent that it is not going to be able to change
with the times. I'd like to relinquish  the rest of the time  to
the panel members to  make comments.
      Ted Clark, Dunn Geoscience Corp., Latham, New
York:  I indicated that I thought one of the reasons
ground-water pollution would be a limited problem, or
remain a limited problem, was that some State, Federal and
local regulations, put somewhat of a damper on what I feel
was an increasing rate  of ground-water  pollution. I think
some of the proper steps, some of the work we've been
doing implementing regulations, evaluations and monitoring
programs are helping and some precautions are now being
      Properly managed and operated landfills today
certainly don't cause the same sort of problems that the
old dumps in abandoned gravel pits did. They certainly did
contribute to ground-water pollution.
      I feel that some of the regulations, controls and
requirements that are being implemented definitely do
have some  real benefit. We are seeing it already, and in the
future, we  will not be running across as many examples that
we know about today that Wayne described.
      Wayne Pettyjohn, The Ohio State University,
Columbus:  If you think that the laws are going to stop
ground-water contamination, you're out of your mind. Let
me give you an example. In Ohio, which is  a good place to
be from we have a fair amount of oil production. When
these wells were drilled, they used oil brine holding ponds.
Now  they used to call these evaporation pits, because  they
put this brine in there, maybe an inch or so with a layer of
oil on the top and all the water would evaporate. Now
we know that because the water level in those things
continued to drop. Those things were contaminating
streams, so they passed the law. They said that  we will no
longer use oil field brine holding ponds for evaporation
pits. They are now called temporary storage structures, but
they work  the same way.
      We have drilled over 200,000 oil wells in Ohio, and
nearly every one of them has had a pit. Now maybe the
contamination route would cover half an acre. Well, about
half an acre times 200,000, that's a good many  acres where
the chloride content, as  I showed you, might well exceed
30, 40, 50,000 mg/1 many years later.
      The passing of laws isn't necessarily going to solve
any of our  problems.

David Farlow, Water Resources Engineering, Stanley
Consultants, Muscatine, Iowa: I'd like to ask a question
that is based on a trend that I've observed to be taking
place. This is that any change in ground-water quality
seems to be defined as pollution.
      Now, what about the case of a landfill where the
natural ground-water quality has a pH of 8, and due to the
acid for example, the pH drops to 7. Is that pollution? We
see, perhaps, a situation where the TDS level of ground
water naturally might be 300 mg/1, and it goes to 400. Is
that pollution? So, the question I want  to ask here is,  if a
change does occur in ground-water  quality, but the
ground-water quality still meets drinking water  standards, is
it polluted?
      Wayne Pettyjohn: My immediate reaction to that
would be no. Somewhere recently I read the definition
that contamination occurs when the water  quality has been
changed from one quality standard to another generally
considered  less desirable. Pollution  is where it becomes such
quality that it's really not fit for the normal use, such  as
drinking or some processing or something that involves the
use by mankind. I think, in this case, where maybe the
quality or the chemistry is changed to some extent with
solids or something increased by a couple hundred parts
or something like this, it still may not be altering the
natural ground-water quality enough to be  considered

Ground-Water  Quality  Standards  —  A  Neutral  View
by Donald K. Keech
     An objective view of the need for ground-water
quality standards requires that an individual recognize the
value that ground water contributes to the water supply
needs of our nation. A vast number of people living in
rural areas and a large number of communities are
dependent upon ground water as their sole source of
water for domestic, industrial, commercial, and
agricultural needs.
     This large use and dependency upon ground water
dictates that these resources are valuable and must be
protected for both present day and future uses. There are
many examples where present methods of disposal of
wastes generated in America have not been satisfactory
from an environmental standpoint, with an exception of
projects where disposal sites have been properly designed,
operated, and managed for protection of the ground water.
     One possible solution for ground-water protection is
the establishment of ground-water quality standards. The
purpose of such standards is to protect the public health
and welfare and maintain the quality of ground waters in
all usable aquifers for individual, public, industrial, and
agricultural water supplies. A legal basis must exist and
      Presented at The Fourth National Ground Water
 Quality Symposium, Minneapolis, Minnesota, September
 20-22, 1978.
      bP.E., Chief, Ground Water Quality Control Section,
 Michigan Department of Public Health, P.O. Box 30035,
 Lansing, Michigan 48909.
the prescribed steps must be followed as dictated by the
rule making process. The primary aim of such standards is
to prevent the degradation of ground waters such as they
will not become a public health hazard or harm the users
of the ground water.
     The backbone of such a standard rests on the
completion of a hydrogeological study which is necessary
to determine background water quality information, set up
the monitoring program and outline sampling to determine
when water quality changes are taking place and what is a
significant change.

     Ground water provides the only usable source
for a potable water supply for many parts of the
nation. In Michigan over 2.3 million people depend
upon ground water as their source of water for
drinking and other domestic needs plus meeting the
need of a vast number of second homes, commercial
and industrial developments, and a growing agri-
cultural need. Nationally,  35% of all water used by
municipalities comes from underground aquifers
and ground water furnishes 80% of water used in
rural areas for domestic needs and livestock  watering.
Thus it is evident that every person in the  United
States  with any background in the many uses of
ground water is concerned about protecting the
ground water as a valuable natural resource.
     The question is then how to protect these
valuable underground-water resources. Even a
cursory review of ground-water literature indicates
that many aquifers across the United States  have

been rendered unusable for production of a safe,
wholesome water supply due to one type of
pollution or another. It is evident that existing
policies and disposal methods have not been success-
ful in protecting the ground water.
     The complex society in which we live generates
all types of waste: chemical, liquid and solid,
sanitary, industrial, hazardous, toxic, and
undoubtedly many others. How can we dispose of
these wastes safely? It is obvious that some of the
practices in the past cannot be permitted and new
methods of disposal are being looked at. At the
present time there is an emphasis to use the ground
surface as a disposal medium for liquid wastes,
sludges, and solid wastes. It is obvious that
materials leak from these disposal sites and end up
in the ground waters. On the other side of the coin,
there are examples where disposal sites are properly
designed, constructed, operated, and monitored to
protect the ground waters from the leachate.
     One solution to consider is ground-water
quality standards. If ground-water criteria is the
answer, then consideration must be given to a large
number of factors. It is evident that every drop of
ground water will not be maintained in pristine
quality, but ground-water rules would be
established to protect the ground water as a
valuable resource. A decision must be made as to
exactly what is to be accomplished with a clear
definition of purpose. One statement of purpose for
ground-water quality standards follows: "to
protect the public health and welfare and maintain
the quality of ground waters in all usable aquifers
for individual, public, industrial, and agricultural
water supplies." After the purpose is agreed upon
then a decision must be reached as to how to
accomplish these goals. The intent is to provide a
mechanism to provide for nondegradation of
ground-water quality in all usable aquifers. These
are aquifers that are currently being used or have a
potential for production of water for drinking
purposes, and various industrial or agricultural
applications. Such rules would not generally apply
to the highly mineralized brine or oil and gas
producing aquifers. To  assure that aquifers are not
degraded or that they will not be degraded it is
necessary to require a hydrogeological study
procedure and establish ground-water monitoring
requirements. From a practical standpoint it is
undoubtedly desirable to provide for variances or
exceptions to specific rules due to any one of a
number of circumstances.
     I would like to make a few comments
regarding the above noted principles. First, it is
absolutely necessary that a legal basis exist for
adoption of a rule or standard of this nature and
that the required steps be followed as dictated by
the rule making procedures. This normally includes
a process where public hearings are held that are
open to all segments of the population to speak
either pro or con regarding the proposed criteria
and procedures. Written comments should also be
received and justification must be provided for
those that feel the rules may be too strict and for
others who feel they do not satisfactorily protect
the ground-water resources.
     I am confident that all public health
professionals in the ground-water field believe that
ground water should be protected from nondegra-
dation since any degradation may be a public health
hazard or at least harm a user of that resource. It is
obvious that any degradation must be measured
from some background level. This presents at least
two problems:  (1) how is the background water
quality determined, and (2) when does a change
become significant. The sophisticated technology
available to water chemists today permits
measuring substances down into the parts per
billion range. This opens the door to valid  questions
regarding how an agency  will determine  a measurable
change from background levels to indicate degrada-
tion is taking place. It is nearly impossible to ascribe
finite values to determine significant changes, such
as a certain percent increase or an increase of some
precise value. Toxic chemical levels are mandated
by the Federal  EPA Safe  Drinking Water
Regulations. However, from a  realistic point of view,
these decisions must be made on professional
judgment based on the facts at hand, public health
hazards, and experience in ground-water chemistry.
     It is obvious to obtain a nondegradation
condition, that proper engineering based on correct
hydrogeological studies must be done prior to
permitting a discharge of any type of waste. There
are several avenues to accomplish this—through
proper treatment, site selection, provision of barriers
to control percolation and seepage, use of underdrain
systems, or complete containment of a discharge
within the disposal site. Public health workers
recognize that the aquifers directly underlaying the
disposal site are no longer usable as potable water
supplies and thus are relegated to waste disposal.
     To regulate discharges of waste materials for
the protection of ground water, in addition to legal
basis for such regulation, it is necessary to know
who legally owns the ground water. Some people
believe that not all ground water is necessarily
water of the State, but a property owner has an

inherent right to utilize ground water in a way that
does not threaten or impair the public interest.
The regulating agency must be prepared to answer
questions regarding the right to regulate ground
water if it cannot be demonstrated that a substantial
public interest, public use or necessity for ground-
water standards exist. If not, then the argument is
advanced that the regulations constitute unneces-
sary and unconstitutional expropriation of a
property owner's rights to utilize his property and
the ground  waters underlying such property. This
issue may present an  interesting legal discussion in
some States.
     Probably the most important tool in making
any determination in the area of ground-water
quality standards is the completeness and thorough-
ness of the  hydrogeological study and report. This
study will form a basis for any discharge permit
and perhaps even renewal of an existing permit when
the potential exists for contamination of ground
water. The  hydrogeological study forms a basis for
all decisions in matters relating to protection of
the ground-water quality. Problems are encountered
in determining the degree or sophistication of a
study, which would vary depending on the volume
and potential hazardous nature of the waste.
Representatives from the fields to be regulated,
both the private and  public sector, are concerned
about the economic impact of the cost of these
studies and question  who is capable or qualified
to conduct such a study. It has been pointed  out
that the small number of firms generally available
for conducting hydrogeological studies minimizes
choice of contractors and could affect meeting
required timetables. A lack of an adequate number
of qualified firms could present problems in
obtaining the required study in an acceptable
economic and time framework.
     The purpose of  the hydrogeological study is
to obtain all known information in the hydro-
geological field, define the engineering modifica-
tions that may be necessary, design a ground-water
monitoring program, delineate the usable aquifers,
and establish the impact a discharge may have on
ground water contained in any usable aquifer. This
type of report must contain sufficient data
presented in a logical and understandable manner to
support the conclusions and recommendations.
     Another major aspect of ground-water quality
control relates to monitoring ground water to
observe for changes or any degradation that may be
taking place or to assure that no contaminants are
entering a useful aquifer. Both water quality  and
water level data should be collected in a monitoring
system which must be specifically designed to
adequately assess the impact of any discharge on
ground water. It cannot be over-emphasized that
the design of a monitoring system must be based
on the geology of the area and the type of waste
discharge. This means that exact details of the
design and construction of monitoring wells must
be specified. Criteria to be considered would be
drilling methods to assure that water samples will
be obtained from the precise depth anticipated
where the leachate might occur and that the wells
are constructed to assure  prevention of vertical
leakage between aquifers  or leakage of surface
water into the well. Another area of concern is
that the monitoring wells be designed so that
practical methods can be  used for collection  of
water samples and measurement of water  levels.
In other words, the monitoring system must  be
able to accomplish what it was intended to do.
     Monitoring is another area where those  to be
regulated can express concern since various aspects
of monitoring are extremely difficult to define.
This relates to the specific chemicals or other tests
to be made, the number of samples to be  collected,
the frequency of collection, and the time  period
to be covered by the monitoring program.
     Another concern will be expressed in this
whole area regarding activities that perhaps should
be excluded from the hydrogeological study  and
monitoring requirements. Obviously, if a  specific
activity may pose a threat or be injurious  to  the
protected uses of the aquifer, such studies will
be required. On the other hand, it is not practical
to require an indepth study for a home sewage
disposal system, application of dust suppressant or
deicing chemicals which are used within normally
accepted or regulated practices, controlled applica-
tion of chemicals for domestic or agricultural uses
when used in normally accepted or regulated
practices, disposal of untreated noncontact cooling
water, and undoubtedly other activities may be
excluded from these requirements.
     The nondegradation principle is certainly a
lofty idea and desirable for protection of  ground-
water resources. On the other hand, there will be
instances when a variance will be requested to
allow a reasonable degradation in a usable aquifer.
Obviously when variances are granted, the
degradation cannot preclude the  use of the aquifer
for its protected uses and will not become injurious
to the public health, safety or welfare. Such
variances would only be granted in exceptional
circumstances where it is determined that strict
conformity is not economically or technically

feasible and no prudent alternative exists. Granting
variances must be consistent with promotion of
the public health, safety, and welfare in light of
the State's paramount concern for the protection
of its natural resources. This is an area that must
be handled technically correct and the criteria,
limitations, or conditions spelled out completely to
protect the users of ground water.
     I believe that it is pertinent to discuss both
positive results and problem areas when the question
of ground-water standards is viewed from an
objective standpoint. The Muskegon County area of
Michigan, which is located on the shore of Lake
Michigan, makes a good study area. The geology is
fairly simple with sandy materials generally over-
lying deep clays extending to a depth where
mineralized water is then encountered. This means
the upper sands are used both as a source for
drinking water and for disposal of all types of
wastes. Muskegon County is an industrial area
serving as a home for several large chemical plants
with the resultant need for disposal of numerous
by-products from the chemical production which
are oftentimes hazardous. Muskegon County also
operates one of the largest lagoon-irrigation systems
presently being operated for disposal of waste
waters. I think it is interesting to note that this
facility provides treatment by three separate
eight-acre area cells, with a treatment capacity
of 42 million gallons per day and is presently
handling an average daily flow of 27 million
gallons. The treated waste water is disinfected and
irrigated over 5400 acres with much of the land
being planted to corn. Fifty-four center pivot
irrigation rigs are being operated for disposal
purposes. This site was developed on an area of
marginal farm land, basically sandy in nature and
generally with an extremely  high water table.
Concern was expressed for protection of the
usable aquifers outside of the specific disposal site
and accordingly the design was developed to
dewater and underdrain the disposal area. An
elaborate monitoring system was developed and is
being actively administered to assure that contain-
ment of the waste is being obtained. It should be
noted, however, that this entire disposal site has
been relegated to disposal of waste water and the
aquifers underlying this site are not considered a
source for drinking-water supplies. Additionally it
is recognized  that many universities across the
nation have water resource research projects
whereby waste water is being treated and the soils
are being used for renovation and  disposal of the
waste water. The disposal of the waste water is
generally through an irrigation type system to
provide usable irrigation water and for nutrient
use through renovation of the waste water through
the upper soils.
     Muskegon County has other disposal sites
where the highly toxic and hazardous industrial
wastes are being disposed of. The unknown
nature of these wastes present several problems
and sometimes it is practically impossible for the
laboratory to analyze for specific components. In
the past, disposal of such wastes was virtually
uncontrolled and sometimes it appeared to be
willful waste disposal into the ground without
consideration of their effect upon ground water.
     An example of this type of problem relates to
a chemical plant that went bankrupt a few years
ago but their disposal practices had already
contaminated the ground water. Wells that had
been installed to purge the aquifer were then
disconnected. This resulted in the contaminated
ground water moving from the industrial site and
contaminating many drinking water wells in  the
area. At the present time Muskegon County is
actually hauling water for drinking and domestic
purposes to 50 homes in the affected area. The
Michigan legislature passed legislation allocating
1.2 million dollars (a portion of the money came
from a settlement with new owners of the chemical
plant) to be used for cleaning up this ground-water
contamination, for disposal of the chemicals left
in storage, and sludge buried on the site. Eighty
seven hundred 55-gallon drums plus over 2000
smaller containers containing toxic chemicals and
chemical wastes remained on the site when
abandoned by the defunct chemical company. In
addition it is estimated that 8000 cubic yards of
sludge stored in lagoons must also be removed and
properly disposed of. A total of 10 pages were
required to simply list the various chemicals  used
by this manufacturing plant.
     A portion of the money is being provided to
Muskegon County for their problems in dealing
with the pollution and for extension of a central
water system into the affected area. It is evident
from this incident that the general public has to
pay part of the cost of the damages caused by
uncontrolled disposal into the ground water. In
addition the ground waters have been contaminated
to a point where they are no longer usable for
potable water purposes.
     A cursory review of the literature indicates
that most if not all industrialized States have
recorded incidents where improper disposal
practices for toxic chemicals have polluted under-

ground aquifers to a point where they are no
longer usable for production of potable water. Some
of these aquifers are fairly small in extent and
simply are written off and forgotten as a source
of ground water. Others are much larger and affect
a larger number of people. I know of instances
where the only usable productive water-bearing
aquifer in the area has been contaminated
necessitating a small rural community to extend a
pipeline a distance of over 20 miles. These types of
incidents result in economic hardship to individual
persons on private wells or even communities
depending upon ground water for their municipal
supply. In some cases industries can no longer
depend upon the use of ground water for their
industrial processes.
     Another interesting area to review relates to
irrigation of crops in the farm belt areas. Michigan
farmers have found that is economically feasible to
install large irrigation systems (which I believe were
developed in the arid West)  in an area where the
average rainfall is approximately 35 inches per
year. Production of corn through proper irrigation
and fertilization in Michigan can rival the produc-
tion from the rich corn belt areas in Indiana and
Illinois. A record corn production for one irrigated
acre approached 400 bushels. It is recognized that
this is not a practical yield, but is not unusual for
corn production to be increased from 7 5 bushels per
acre to 150 and perhaps even exceeding 190
bushels per acre through irrigation.  These excellent
crop yields not only in corn, but soybeans,
potatoes, and even alfalfa also require larger
quantities of fertilizer which is oftentimes mixed
with the irrigation water. To obtain these high
yields excess nitrogen fertilizers are applied  and
sometimes through what appears questionable
procedures for the most beneficial use of the
fertilizer. There is evidence that the nitrogen is
leached below the recovery zone of the root systems
and thus eventually ends up in the ground water.
Many areas in Michigan  have evidenced an increase
in the nitrate level in ground water  to a point where
they far exceed the EPA maximum contaminant
levels for public drinking water supplies. A recent
ground-water publication stated that a research
project is being conducted  by the University of
Nebraska at Lincoln to study a means of controlling
water pollution resulting from irrigation practices
in the central plains States. The report goes  on  to
state that 13 States will be studied for nonpoint
pollution resulting from irrigation. It is recognized
that irrigation is necessary for the abundant crop
production which we expect from our farmlands
but the question must be answered, what can be
done to safeguard the ground waters?
     There is another problem that has recently
come to light in Michigan. Ground water has become
contaminated from disposal of laundry wastes that
contained perchloroethylene. Perchloroethylene is
used as a dry cleaning fluid and many of the small
laundromats provide a coin operated dry cleaning
facility in conjunction with their coin operated
laundromats. A nagging ground-water quality
problem has been under investigation for the last
3 or 4 years and it wasn't until last year that
perchloroethylene was discovered as the con-
taminant. This  chemical has contaminated many
private wells along with a few noncommunity public
water supplies,  including a food  service establish-
ment and an elementary school. At the present
time the solution for providing a safe, potable
drinking water  has not been resolved. However,
many homeowners, as well as the commercial
establishments, have been harmed by having their
source of ground-water supply contaminated by the
perchloroethylene. It is recognized that the
individual ownership and operation of small
laundromat-dry cleaning establishments is desirable
and a needed commercial venture in our
communities. However, the problems we have
encountered in Michigan indicates that operation
and disposal of waste generated  from these
facilities must be regulated.
     The question today is are ground-water
quality standards necessary, and if necessary, how
can they be effective to assure that the ground
water is not being  degraded? It is necessary to
protect ground water for users of today and
tomorrow from economic harm  and to assure
protection of their public health and welfare.
     Donald K. Keech is a Registered Professional
Engineer in the State of Michigan with a B.S. degree in
Agricultural Engineering from Michigan State University in
1951 and an M.S. m Engineering in 1961 from the University
of Florida. He started his ground-water work with a large
water well drilling contractor in 1954 as an assistant
engineer working in all phases of ground-water development,
particularly in geophysical aspects and aquifer analysis.
Since 1956 he has been an engineer for the Michigan
Department of Public Health and assumed his current
position as chief of the Ground-Water Quality Control
Section in 1965. Current responsibilities include registration
of all water well drilling contractors operating in Michigan,
administration of a State-wide construction code, submission
of water well drilling records, and in general, supervision of
water well drilling activities for the protection of the
public health.

Ground-Water  Quality  Standards  —  Relevant
by James H. McDermott
     The opportunity to begin formulating a national
ground-water quality protection program is at hand. In
building the new program we should use the host of lessons
learned in the experience of related environmental
programs. This is necessary so that the new program will be
realistic at the outset and congruent with the integrated
planning and management of the ground- and surface-water
resources of the nation.
     The keystone of program development, implementa-
tion, and evaluation is and will continue to be water
quality standards. To the extent that the goal "Safe Drinking
Water for Americans" has already been established, the
point-of-use regulations (IPDW Regs and the RPDW Regs),
should serve as water quality objectives thus facilitating
ground-water program formulation and evaluation. The
major regulatory thrust of the program, the water quality
standards, must be technology-based site selection,
construction and operational standards, with only limited
monitoring in a conventional water supply and water
pollution control context.

     Ground-water regulations are necessary to
provide a framework within which this nation can
move towards integrated management of surface-
and ground-water resources for both quantity and
quality. The need for an integrated approach has
been learned in selected instances at the local level.
It has not yet been accepted on a national basis,
but we must prepare the way.
      Presented at the Fourth National Ground Water
Quality Symposium, Minneapolis, Minnesota, September
20-22, 1978.
     b Associate Deputy Assistant Administrator, Office of
Drinking Water, Environmental Protection Agency, 401 M
Street, SW, Washington, D.C. 20460.
     President Carter's recent water resource policy
review served to demonstrate that ground water is a
neglected resource from a forward-looking manage-
ment point of view. Ground water continues to be
out-of-sight and out-of-mind. This is likely to
continue until three problems are addressed:

     1. The extent of quality degradation and
quantity depletion must be better defined and the
causes articulated.
     2. The potential threat and consequences of
degradation and depletion must be delineated.

     3. A national policy and program must be
advanced and gain widespread support
acknowledging existing ownership and institutional
     Few will argue with falling ground-water levels
as a prima facie case demonstrating depletion. Most
people can recognize and accept surface-water
analogies including falling lake levels as a rational
explanation of what is occurring at least insofar as
quantity is concerned.
     Ground-water quality is, however, another
issue. Many people have difficulty visualizing the
significance of water quality. For instance, it has
taken the public 30 or more years to support water
pollution control efforts. The need to protect,
conserve, and manage ground-water  quality, by
comparison with surface-water quality, will be a very
large step for the public at large until such time as
the above three problems are addressed on a
consistent basis.
     The process must begin with a goal which can
be readily understood by the public and a set of
common national standards which acknowledge
critical uses and are accepted and supported by the

technical and professional community. Common
bench marks, water quality standards, are needed
today to facilitate the technical debates which are
now gaining momentum, as evidenced by this
Symposium, leading towards eventual problem
definition and program development.
    And in a larger sense, ground-water regulations
will be essential to the conjunctive management of
the nation's ground- and surface-water resources
in the future.

    From  the recent water resource policy review
we have learned that past  categorical water resource
planning and development not only neglected
ground water but that the categorical priority given
to surface-water development also frequently led
to adverse environmental consequences and
economic excess. Similarly, the last twenty years of
ever increasing national priority for water
pollution control, ostensibly a comprehensive
cleanup of  the nation's water resources in the name
of current and future generations, has neglected
ground-water quality. Indeed past surface-water
cleanup priorities have been responsible for,  and
recent land treatment initiatives (Session III)
threaten in  the minds of many, yet additional
endangerment to ground-water quality.
    Thankfully these imbalances in categorical
approaches and loopholes in legal authorities have
been identified and articulated in professional
journals and Congressional hearings during this
decade. Assisted by  scientists, engineers, and
environmentalists, the Congress has moved to
provide an  array of statutes which provide at least a
starting point to articulate the problems (Session I)
and begin managing the quality of the nation's
ground-water resource (Session IV).
     The fact that awareness and opportunity occur
in an era of budget deficits, the inflationary  spiral,
the energy  crunch and the regulatory backlash
should not  dissuade us. There has never been a
"good" time to increase the regulatory burden
or the Federal, State, and local financial burden in
the last twenty years. Only now that the program is
well advanced are the real benefits of surface-water
cleanup becoming apparent. And, only now  that
the adequacy of surface-water resource is being
questioned is the concern for ground-water
resources growing. So those among us who are
concerned  with the  environment  and public  health
and see the future need for conjunctive manage-
ment, should learn from the lessons of the past
and move to formulate a ground-water strategy
which goes beyond water resource planning and
development, beyond ground-water quality
protection, to fully integrated water resource

              WHERE TO START
     To begin to manage ground-water quality we
must (1) first set an achievable goal, (2) move to
define the problem, (3) examine and select control
options, (4) set objectives, (5) augment or
establish institutions when and where needed,
(6) provide for evaluation and feedback, and
(7) communicate the problem and solution to the
     Acceptance of these basic principles, which
must be accounted for at the birth of all new
programs, highlights the importance of
     The goal must make sense, both  common sense
and economic sense. For my part the  goal is clear-
safe  drinking water for all Americans. What is less
clear with respect to ground water is whether or
not there is a threat. And, if there is a threat, who
should pay for remedial action and regulatory
     The common view in the past was that ground
waters are safe if drinkable. Today, largely because
of the public notice provisions of the Interim
Primary Drinking Water Regulations and public
awareness associated with  EPA's proposed synthetic
organic contaminant regulations, the American
public is beginning to recognize that our senses of
taste and smell are no longer adequate.
     If ground-water quality is questionable, there
will  emerge a recognition that someone is going to
have to pay for cleanup  or for quality control. It
is also  clear that those who are dependent upon
ground water will conclude that they should not
have to pay for treatment because of someone
else's current or potential  "abuse" of ground-water
     If we are to legitimately capitalize on the
emerging recognition of ground-water pollution
and  the safety of drinking water issue we must be
prepared to  define "abuse" and to identify, select
from, and communicate control options that make
sense—common sense and economic sense. P.L.
93-523 provides a mechanism to define safety
through point-of-use regulations. The abuse-safety
test  at the consumers' tap is thus established by
maximum contaminant levels (MCL's) and potential
treatment requirements specified in the IPDW
regulations.  At this point in the program evolution
we must address several questions.

     • Should the burden of proof of pollution be
 on the user, or the Federal, State, or local
     • Should the cost of monitoring be shared
 among users and waste disposer, or be the sole
 responsibility of the waste discharger?
     • Can we or must we depend on technology-
 based regulations to control potential ground-
 water pollution?
     • Is monitoring even necessary?
     The user, in a community, commercial,
 agricultural and industrial sense must continue to
 bear the responsibility and cost of routine monitor-
 ing of his source of  supply be it surface or ground
 water. This is the only way that he can assure the
 quality  of the product, modify or install additional
 treatment, or spot the signals identifying the
 occurrence of unexpected changes in water quality.
 These costs are now being borne by users, but have
 led many people to  jump to the erroneous
 conclusion that the  nation's ground-water-
 dependent systems should also serve as a National
 Ground-Water Pollution Network. After all, goes
 the argument, why increase the monitoring cost by
 requiring additional observation wells or by adding
 to the burden of potential ground-water polluters?
     Unfortunately, the establishment of a national
 program to manage  and enforce ground-water
 protection based on monitoring at the point of
 use is doomed to fail. Lessons from the history of
 the surface-water pollution  control program
 support this reality.

                REALITY ONE
     One reality which has been mentioned this
 morning, and will be mentioned time and time again
 during this Symposium, is that once polluted, an
 aquifer is extremely difficult and  costly to clean
 up. Neither dilution nor natural purification can be
 counted on. Once ground waters are polluted (i.e.,
 exceed one or more MCL's in  the IPDW Regs) the
 nation's self-supplied homesteads, public drinking
 water systems, and other users will incur:

     1. Additional monitoring costs in attempts to
 isolate the cause and examine alternative control
     2. Treatment costs to meet quality require-
ments; or

     3. The cost of using alternative sources of
supply; while
     4. Continuing to pay off the cost of existing
wells and pumping facilities, with interest, which
 are being financed and installed at a $3 billion
 annual rate.

     Such likely consequences did not make sense
 to the Congress when it established the initial scope
 of the Underground Injection Control Program in
 the Safe Drinking Water Act of 1974. And the
 prospects will not appeal to the nation's citizens
 who pay the bills, either the local water bill or
 through price  increases in food, fiber and service
 upon which the country is so dependent.
     But there is yet another more subtle reason
 for not burdening the water user with responsibility
 for monitoring pollution which can be prevented.
 Economics argues against burdening the ground-
 water user with searching for the emergence of
 one or more of thousands of potential pollutants.
 Moreover, the provision for treatment requirements
 in lieu of MCL's was created in recognition of the
 fact that many exotic pollutants can only be
 measured in research laboratories. Thus, total
 dependence upon point-of-use measurement would
 be both economically unreasonable and techno-
 logically dangerous.

                REALITY TWO
     A second reality is that pollution prevention
 must begin and end at the source. A generation of
 experience with concepts like "enforceable" stream
 quality standards highlighted economic and legal
 realities that cannot be dismissed. Control at the
 source is the only viable basis upon which to proceed
 in the United States.
     But even this principle, forged on the anvil of
 surface-water quality control efforts,  creates
 dilemmas when efforts are made to translate this
 lesson from surface water to ground water. For
 instance, how  do we translate the "zero discharge"
 principle to the prevention of ground-water
 pollution? And how can we avoid making someone
 responsible for monitoring, to signal the early
 violations of technology standards, when we know
 that once polluted by pits, ponds, fills, dumps or
 injection practices, the aquifer could stay polluted
 for generations?

               REALITY THREE
    To those  who cry for control and prevention
 at any price, a third reality must be communicated.
No activity conceived  and implemented by man can
be certified as  100 percent perfect or risk free.
There will always be risks in design and in the
construction of physical facilities. Moreover, many
design and construction issues are in fact created by

the nature of the earth itself. The earth and its
aquifers are seldom homogeneous or continuous.
Further, the often heralded natural attenuation
phenomena (applicable to certain pollutants), while
effective in degree, provide no lifetime guarantee.
     Accepting these realities means that the only
reasonable approach is to move to a technology-
based standard calling for  "virtual zero discharge"
for pollutants. This, in my view, will require
evaluation of a series of tradeoffs which are clearly
beyond the scope of this paper. For instance, the
cost of the construction-modification-operation of
a facility must be brought into balance with site-
monitoring cost, the quality of the aquifers
potentially impacted, the number of current or
potential users at risk, and the economic impacts
which users might sustain.
     Again, in my view, site  monitoring will require
keen professional judgement. There are activities
where, because of clear knowledge and experience
with the waste in question, the method of disposal
and the geology involved,  no monitoring will be
needed. There will be other circumstances where
simple surrogates such as pH, temperature, pressure
or color tests will be judged  necessary at the site.
In other situations involving dangerous wastes
those responsible for disposal should be required to
install and monitor observation wells for specific
contaminants. Finally, selected waste  disposal
operations involving dangerous materials should
bear the cost of monitoring for specific supple-
mental analysis, including those  contaminants
designated under the Safe Drinking Water Act.

             THE FINAL REALITY
     The questions and issues I have been
addressing (and indeed, concepts like  "virtual zero
discharge" and "professional judgement") were
purposefully chosen to stimulate this debate. Yet
great care must be exercised to avoid the
misunderstanding and divisions which these terms
may inadvertently create.  Thus,  we  must recognize
a final reality: the problem of communication.
     Many of the concerned and involved parties
enter the debate from different poles. Some people
tend to deal in stereotypes or are trained in
absolutes. Others function in a physical, chemical
and economic world where absolutes cannot be
predicted, designed, or constructed. If new ground-
water quality standards are to be developed and
ultimately integrated into a comprehensive water
resource management program, mutually agreeable
standards which are feasible and economically
viable must be negotiated. Thus all parties must
be prepared to listen and to compromise so that
a start can be made. Parties at each pole must move
to forge a workable consensus so that a credible
program can be presented to the public at large.
     For our part, we at EPA are moving to identify
for consideration and to integrate for implementation
numerous available pollution control authorities.
Vic Kimm's presentation during Session IV
articulates the substantial progress being made
within EPA toward  issuing a revised version of
the Underground Injection Control Regulations as
part of a comprehensive, agency-wide strategy to
control ground-water quality.

     The opportunity to begin formulating a
national ground-water quality protection program
is at hand. In building the new program we should
use the host of lessons learned in the experience
of related environmental programs. This is
necessary so that the new program will be realistic
at the outset and congruent with the integrated
planning and management of the ground and
surface-water resources of the nation.
     The keystone of program development,
implementation, and evaluation is and will
continue to be water quality standards. To the
extent that the goal "Safe Drinking Water for
Americans" has  already been established, the
point-of-use regulations  (IPDW Regs and the
RPDW Regs) should serve as water quality
objectives thus facilitating ground-water program
formulation and evaluation. The major regulatory
thrust of the program, the water quality
standards, must  be technology-based site selection,
construction, and operational standards, with only
limited monitoring in a conventional water supply
and water pollution control context.
      Let's not repeat the errors of the past. Let's
do it  right. Let's start now.
             *        *      *       *
     James H. McDermott is the Associate Deputy
Assistant Administrator of the new Office of Drinking
Water -which was formed following the passage of the Safe
Drinking Water Act. He was previously the Director of
the Water Supply Division, which was established when
EPA was formed in 1970. Prior to joining EPA, Mr.
McDermott had been the Director of the Bureau of Water
Hygiene, Environmental Control Administration, in the
Department of Health, Education and Welfare since
1969. Mr. McDermott received his B.S. in Civil Engineering
from the Rensselaer Polytechnic Institute in 1955 and his
M.S. from Purdue  University in 1957. He has published
numerous articles and reports on various aspects of water
supply, pollution control, and water resource development
and management.

Ground-Water  Quality  Standards  —  Irrelevant
by Frank A. Rayner
     Proposals to establish national ground-water quality
standards appear to be premature, and redundant because
of the geohydrologic and geochemical factors governing the
occurrence and development of ground water. Although it
can be reasoned that there is no "good time" to establish
additional governmental standards (and the resultant
additional governmental regulations), it can also be
strongly argued that now is a "bad time" to consider
establishment of  the proposed standards.
     First, a present mood of the general public is away
from more governmental involvement in the business and
private sectors, and a rebellion against the increasing cost
of government. Second, the applicability and workability of
present Federal (and some State) laws that could be used
to adequately protect ground-water quality, have yet to
be implemented or otherwise sufficiently tested.
     The full force and effect of the Water Pollution Control
Act (PL 92-500 with amendments) has yet to be imple-
mented, and Congress is still considering its "oversights" in
their drafting of same.
     The Safe Drinking Water Act (PL 93-523), particularly
those sections designed or usable to protect ground-water
quality, have yet  to be tested by the EPA. Like PL 92-500,
the deadline for implementation of parts of PL 93-523
has long since passed.
     And the far-reaching effects on ground-water quality
protection that three other federal laws—the Resource
Conservation Recovery Act (PL 94-580); the Toxic
     Presented at The Fourth National Ground Water
Quality Symposium, Minneapolis, Minnesota, September
20-22, 1978.
     bConsulting Engineer and Geologist, 1706 26th St.,
Suite 1, Lubbock, Texas 79411.
Substances Control Act (PL 94-469); and Surface Mining
Control and Reclamation Act (PL 95-87)-are totally
unknown, since the procedures for full implementation of
these acts have yet to be developed.
     Therefore, it appears that establishing a new ground-
water quality control act prior to testing existing law and
thereby learning from their flaws or shortcomings, could
result in unnecessary proliferation of law without its
reasonable testing.
     This appears to be a good time to interrupt the
geometric progression that tends to spawn additional laws
when laws are developed ahead of their established need.
     Equitable and workable ground-water quality
protection could be fostered through the enactment  of
the long overdue requirements for the integration of surface-
and ground-water  development and management programs,
without widening  the existing gap between present ground-
water and surface-water management structures. This
integration would  decrease inefficiency of use of these
water resources—which are actually inseparable in identity
to their users, the  American taxpayers.

     Several years  ago I proposed that there was no
such thing as naturally pure water, particularly in
the Texas water community, and that the formula
for water should be changed from H2O to H2O2—
that  is, two parts hydrogen, one part oxygen, and
one part opinion.
     At about the  same time I suggested to my
Texas colleagues that we could advance the causes
of water conservation, protection and development
10 years by simply establishing a one-year
moratorium on  water meetings. I reasoned that such
a moratorium would enable those that attend the
water meetings—which are usually the same people,
all employed by water agencies—to work

uninterruptedly for at least one year, which
would be equivalent to 10 years of normal water-
meeting-interrupted work. The first proposal met
with blank stares, and the latter with hostile ones.
     But, today, with this presentation, I will
probably prove the first contention, and possibly
hasten the institution of the latter.
     My circumstance  of habitat makes it very
difficult for me to take the position I find myself
in today—opposing the creation of new laws and
rules that may offer the potential to fully protect
one of the nation's most useful and essential
resources—ground water.
     Assaulted by the bleatings of the rabid,
so-called, conservationists, I tend to turn a deaf
ear to their cause; but I am forced to recall my
youth in the hills of West  Virginia. Born and raised
through high school on a small hillside farm (here I
have used the term "farm" generously, because
the size of that West  Virginia farm would be about
that of a Texas family's vegetable garden plot) on
the Monongahela River, Morgantown, West Virginia,
I lived through the era of  the rape of that beautiful
land's abundant bituminous coal.
     Hillside and  strip mines belched blood-red
mine acid waste into all of the area's many streams.
Strip (now called surface) mining was practiced
without any land reclamation requirements. The
giant earth movers skirted the contours of the hills
leaving ugly yellow scars,  devoid of any ground-
protecting vegetative cover; uprooting and covering
millions of tall, stately hardwood trees, when the
coal-bed overburden  of yellow clay and rock was
simply pushed over the side of the hill. The area's
over-abundant rainfall did the rest,  carrying the
loose yellow earth into the nearest stream.
     Mine acid drainage kept most of the streams'
water, and their rocky beds, colored a brilliant
orange, and the larger (navigable) Monongahela
River a light pink. Sewage outfalls were always
elevated to protect them from rising water, and
totally untreated  sewage,  comprised of an enormous
amount of solids, formed waterfalls of changing
hues and varicolored large objects splashed into
the Monongahela's waters.
     Living between  the confluence of Sulphur
Creek (a local name given to Dunkards Run,
because of its brilliant orange, or at low flow, blood
red, color) and the Monongahela River, if we chose
to go swimming, it was best to be in the River. A
dip in the Sulphur Creek made our  skin look like
the Red Man. But, swimming in the Monongahela
was not without risk, and it was always with a
tightly closed mouth; if you swam therein, you were
the only living thing so doing; the Monongahela
was completely devoid of fish and other aquatic
     Large slate dumps smoldered during my entire
18 years at home, and their sulphur gases and ash
paniculate matter combined with that of whole
hillsides full of black smoke-producing coke ovens,
kept the entire area covered with raindrop-size
black, oily soot gobs. White snow only existed
below its top layer, and sulphur gases ate the metal
off cars and  other objects with considerably more
efficiency than does salty ocean spray. To an
outsider, rust would appear to be the residents'
mania for choice of color.
     From mountain momma I moved (in military
service) to the arid West, where the economy is
almost totally dependent upon the development of
ground water and petroleum resources; and the
exploitation of these resources was like no change at
all in habitat from my native West Virginia; the
only difference between the two habitats being
two-thirds less rainfall, and 100 percent fewer trees.
     Brine produced with oil and natural gas was
being discharged onto the very permeable soils
at the land surface, to simply migrate downwards
from the so-called  (unlined) evaporation pits (some
conveniently fitted with wells at their bottom) to
enter and contaminate beyond use, the near-
surface aquifers which in most cases, were the
only fresh-water supply available.
     Since stream flow, in most of the area, only
occurred after storms, they were undependable as
a fresh-water supply—ground water being the only
dependable supply—so such streams were used as
waste disposal dumps. The Trinity River between
Fort Worth and Dallas was visible for miles on the
darkest night—by smell. The Houston Ship Channel
was claimed to contain the most buoyant water
in Texas, suspended and dissolved solids adding
greatly to its waters' density.
     These are only a few examples, but conditions
were similar throughout our Nation—the rape of
the environment was accepted as a way of life.
     But today, my former habitats have changed.
It is no longer considered foolish to wish to live on
the banks of the Monongahela River; pleasure
boating, swimming and fishing have returned
thereto. The slate dumps have disappeared and
coke ovens are fast disappearing also. White snow,
several days old, attests to the new atmosphere.
Surface mining must be followed by land reclama-
tion and removed overburden is not allowed to
despoil the hillsides or enter the streams. Some of
the choice, and usually the only flat, lands in the

Appalachians are now reclaimed surface mined
     Although improper waste disposal is still
practiced in some areas, most aquifers are protected
from surface disposal of brines, and other
contaminants, and even the Trinity River and the
Houston Ship Channel are not easily located by
the nose.
     Who, or what, is responsible for this remarkable
reversal in our respect for our environment? Of
course, it is not one person, or one thing or one
entity, but a change in public attitude; but what
helped change public attitude? If I were to choose
the major motivating force, I would have to
honestly pick the Environmental Protection Agency,
and its predecessor, the Federal Water Quality
Administration; and further laud the Agencies'
dedicated and conscientious scientists, adminis-
trators, and  other staff personnel.
     This choice does not ignore the contribution
of the numerous State and local agencies that have
also been in this fight for a better environment,
but even they must admit that the major catalyst
has been the EPA; its relative immunity from
political pressure, its conscientiousness, its laws,
its rules, and its money.
     This realization, this admittance, of having,
thankfully, lived through a forced change of attitude
to that of a respect for our environment, and
protection for that which we will leave to our
successors, makes it most difficult to  oppose
proposals for increased quality protection of
ground-water supplies; protection I realize is, in
some cases and areas, needed and overdue.
     Specifically, however, my presentation here
and my negative stand regarding proposals for
the establishment of ground-water standards  stems
from Dr. Lehr's request that I take this position
on this program, as a replacement speaker, and,
perhaps, influenced from my reading  of the present
mood of the public regarding increased government
spending and taxation.
     The suggestion for establishing ground-water
quality standards is not fully understood by this
author. There are already water quality standards
that apply to ground water (and all other water)
at the point  of use of such water.
     My interpretation of the suggested standards
is that they would apply to in situ ground water. If
such is the case, no one group of standards could
be made applicable. The quality of in situ ground
water is the quality of the in situ ground water;
therefore, standards would have to be adapted to
existing conditions, and since there are greatly
varying ranges of individual dissolved constituents
in each aquifer, and within segments of the same
aquifer, the magnitude of the number of different
standards that would have to be formulated is
staggering.  No one list, or possibly even hundreds
of lists, of standards could be developed to satisfy
all ground-water quality conditions.
     Only one type of standard could be developed
to cover all aquifers. That standard would simply
state that "the present chemical character of the
existing ground water shall not be altered. " Although
such a standard would be easy to develop, its
application and usefulness are impossible and
worthless. Some will argue that standards could
be developed that would set the maximum amount
of degradation (change) permitted, but how (or by
whom) could such in situ changes be monitored
effectively  and economically enough to provide a
means to control or limit degradation then in
     If ground-water standards are to be based upon
potable-water considerations, (human consumption
standards) the implementation of such standards
would wreak havoc on the ground-water economy
of many regions of the Nation.
     As examples, the major segment of the
agricultural economy of the western United States
is based upon irrigation, primarily from ground
water. Most of this ground-water development is
depleting the aquifers so developed, and any
means of aquifer augmentation (artificial recharge)
is assumed  beneficial—including recirculated
irrigation water and sewage effluent.
     Everyone is familiar with the Old West saga of
a gunfight at the water hole; where  some rancher
dammed up the stream or fenced off the spring and
maintained his acquisition (his water right) with a
gun. In the West, the streams have long been over-
appropriated and the springs fully claimed, and
gunlaw has given way to some of the most lengthy
and costly water-rights litigation known to civilized
man. But, there is a new water hole spurring
renewed legal ramblings in the West; that is, the
rights to city sewage effluent. In the eastern U.S.,
how to get  rid of sewage may be a problem, but in
the West how to acquire and keep the rights to it—
the new fight at  the water hole—is the main problem.
Irrigation with sewage effluent is  a major enterprise,
and now the irrigators sometimes find themselves
in  conflict with other would-be users, such as
thermoelectric power plants, who want to divert the
irrigators' rights  to sewage effluent to their own
     In nearly every case the irrigator who has a

right to sewage effluent also has an obligation to
dispose of same when he cannot utilize it ail-
primarily during the winter months. Such surplus
effluent, since its disposal into streams is now
prohibited by the Water Pollution Control Act
(PL 92-500), is usually accomplished through over-
irrigation of crops, or onto fallow farmland, or into
surface ponds. All such methods of "disposal"
provide for significant downward percolation, and
recharge to any water-table aquifer underlying such
areas—and such areas usually have underlying
     A classic example of this type of case is the
Frank Gray operation using the City of Lubbock,
Texas, sewage  effluent. Irrigation on the  Frank
Gray farm has recharged the formerly limited (in
thickness) aquifer until the water table is now near
the land surface, in some areas, and some playas
are now water-table lakes. This type of recharge has
made possible  the perpetuation of large capacity
irrigation wells on the Frank Gray, and surrounding
farms,  and the development of numerous wells on
the recharged land to supply a new power plant,
and to maintain a series of recreational lakes in
the City of Lubbock. But the  aquifer now contains
water much higher in dissolved solids, and probably
unpotably high in nitrates, //the original quality of
the water in the aquifer had been maintained, the
obvious benefits of sewage effluent recharge would
have been foregone, and untold millions  in
economic benefits unrealized.
     The Frank Gray case is typical of thousands of
similar situations throughout the western United
     Similarly, strictly adhering to existing ground-
water quality would also prevent most other
artificial recharge and subsurface water storage
programs, particularly if such  standards are based
upon potability parameters, and it would deal a
death blow to  effective conjunctive management of
surface and ground-water resources—which,  in most
cases, must be  based upon  exchange of storage
between the two regimens.
     Another classic example  of increasing ground-
water storage at the sacrifice of ground-water quality
is the Orange County (California) Water District
recharge program. The Orange County district, faced
with depleting ground-water supplies and sea- (salt-)
water encroachment (due to ground-water pumpage),
recharged the aquifer with the much lower quality
water from the Colorado River. The result was the
reversal of the movement of the salt-water/fresh-
water interface, and a replenished aquifer with
water storage larger than that  of historical record;
but, with notable degradation in water quality.
     These are only two examples of the numerous
ongoing recharge projects that utilize poorer (but
useful) quality water to recharge aquifers containing
better quality water, or water with different ratios
of specific dissolved solids.
     Standards that would prevent the recharging
of a near-depleted or depleting aquifer with poorer
quality water (but usable for most all of the present
uses of the native aquifer water) would be ill
conceived and natural resource wasteful, and to
further limit recharge water to a quality to meet
strict potability requirements would be even more
restrictive, and counter-productive to water
conservation efforts.
     It is appropriate to note here that the NWWA's
successful efforts to generate interest in the use of
ground water and aquifers as a heat or cooling sump
could be jeopardized by ground-water standards
that would consider heat (or cold) as contaminants,
such as does PL92-500 in respect to  surface water.
And  the use of aquifers for such purposes would be
suspect due to the possibility of ground-water
quality changes due to the increased mineral
solubility of warm injected water, and the presence
of oxygen or algacides and bacteriacides or other
disinfectants, and solvents that may be added to
injection water.
     Mr. McDermott has correctly noted that there
is no good time to initiate new government  programs.
Continuing the reasoning along this line would  lead
to a further conclusion, that there is a "bad time"
to initiate new government programs; and with the
new wave  of anti-taxation sweeping the country,
now does appear to be the worst of the "bad
times" to initiate new governmental spending.
     The deep feelings (hidden like an iceberg) of
the general public's  discontent with the magnitude
of governmental taxation (local, State and National)
is exemplified  by the type of leader they have
rallied behind. To me the creator of the latest
"ism"—Jarvism—is repugnant. He does not appear
to me to exercise any reasoning, compassion, or
understanding for the need for some (even if
reduced) taxation, and his lack of finesse in his
treatment of opponents is appalling. Yet he is the
chosen leader of the formerly silent masses opposed
to taxation. My reasoning is that if a man
exercising the  tact exhibited by Mr. Jarvis is emer-
ging as an  antitax leader, then the antitax feeling is
a major force to be reckoned with, hence a reason
to not initiate new government regulation, and
increased—tax supported—regulatory activities. In
other words, it appears to be a good time to "cool it."

     However, in support of Mr. Jarvis' aims I note
my record of recent public service to show that
taxes can be reduced while governmental services
are expanded. In 1976 and 1977, as the manager of
a Texas ground-water district, I initiated a 40
percent reduction in the district's taxes while
expanding the district's services. This was attained
by expecting district employees to perform their
jobs commensurate with their pay, and to require
those individuals violating district rules, and those
demanding special  services not provided by law, to
pay for the cost for rectifying the violations, and
for such special services.
     In lieu of initiating new water quality laws, it
appears to be a good time to concentrate on the
application and evaluation of the workability of
those parts of existing laws that treat ground-water
quality considerations, and there are a  lot of
existing Federal laws still left untested.
     The applicability and workability of present
Federal (and some  State and local) laws that could
be used to adequately protect ground-water
quality have yet to be implemented, or otherwise
adequately tested.
     The full force and effect of the Water Pollution
Control Act (PL 92-500, with  amendment, the
Clean Water Act-PL 95-12) has yet to be imple-
mented, and Congress is still considering its
"oversights" in the drafting of same.
     The Safe Drinking Water  Act, (PL 93-523)
and the 1977 amendment (PL 95-190), particularly
those sections of same that were designed or are
usable to protect ground-water quality, have yet
to be tested by their implementation by the EPA.
Like PL 92-500, the deadlines for implementation
of parts of PL 93-523 have long since passed.
     And, the far-reaching effects on ground-water
quality protection that three other Federal Laws;
the Resources Conservation and Recovery Act
(PL 94-580); the Toxic Substances Control Act
(PL 94-469); and Surface Mining Control and
Reclamation Act (PL 95-87) are totally unknown,
since the procedures for the implementation of
most of these acts have yet to  be developed.
     I would particularly note that the title of
PL 94-469 is misleading. This act includes all
chemical substances in any form, including pure
water, and possibly H2O2, and is not limited to
substances of the toxicity classification. The
potential powers of the EPA provided by this act-
including ground-water quality protection—are
awesome. Therefore, it appears that establishing
a new ground-water quality control act prior to
testing existing law, and thereby learning from
their flaws or shortcomings, if any, could result
in unnecessary proliferation of law.
     This appears to be a good time to interrupt
the geometric progression that tends to spawn
additional laws when laws are developed in haste
of their established need.
     The results of Federal  (and State and local)
agency hearings, Congressional hearings, studies by
commissions, and public and private interests,
have shown that the full implementation of
PL 92-500—particularly the no-discharge
provision  of same—constitutes a major threat to
both the quantity and quality of ground-water
supplies. Since Congress is aware of the shortcomings
of this law, and since it has  been successfully
amended in the past, it appears likely that Congress
would be  more apt to amend PL 92-500 to provide
for more ground-water quality protection, in lieu
of establishing new and separate ground-water
laws. This would be one of  my recommendations
to proponents for new laws establishing ground-
water quality standards.
     The rigidity of interpretation and application
of Federal rules, by some agencies, is of particular
concern to me, should they be so applied to new
ground-water law. Also, in my opinion, the flimsy
and/or irrational reason for  invoking rigid imple-
mentation of some rules are very disturbing.
     The numerous excesses within the powers
granted by the Endangered  Species Act are particu-
larly noteworthy. Tales of the impropriety  of the
rules enforcement activities of OSHA abound. The
posting of warning signs at'the entrance of grocery
stores wherein products containing saccharin are
sold is absurd. I get the impression that saccharin
may be a mad dog, and a dietetic soft drink may
jump off the shelf and attack me!
     In regard to ground-water quality standards—
at the time of the Congressional debate on HR
13002 (now PL 93-523), the hysteria about the
existence of carcinogens (which may cause  cancer)
in the New Orleans water supply hit the headlines.
These carcinogens were detected in quantities of
parts per billion and parts per trillion. In a letter to
Congressman George Mahon, of Texas, I noted that
for a person to ingest one pint of a substance in the
quantity of one part per billion, by drinking the
New Orleans water, such a person would have to live
a total of 456,621 years to do so! (If we are to be
concerned with parts per billion and parts per
trillion, we might as well consider the last year of a
theoretical lifetime of nearly one-half million years).
     Dr. Doris Thompson (then the Director of
the New Orleans Health Department) noted that

drinking from the New Orleans public water supply
is one of the safest things you could do in New
Orleans. Having been to New Orleans many times,
and nearly always visiting Bourbon Street, I
heartily agree with Dr. Thompson. I have  not had
any extensive experience with drinking New
Orleans water, but I  am sure it does not implant
the headaches other  liquids there do.
     New ground-water laws will only widen the
existing chasm between the development, conserva-
tion, and protection regimes adhered to by the
existing ground-water and surface-water management
entities; a condition  that needs to be eliminated,
not fostered. Amendment of PL 92-500 would help
in this regard.
     If new laws must be proposed, I would suggest
that they embody conjunctive management,
conservation and  development, and quality
protection of both water sources—ground and
surface. Equitable and workable ground-water and
surface-water quality protection could be fostered
through the enactment of long overdue laws
requiring the integration of ground- and surface-
water development and management.
     Both the surface-water and ground-water
interests are firmly entrenched, and apparently
determined to maintain the status quo in regard to
their specific interests; therefore, any proposed
law requiring conjunctive management of these two
regimes is going to receive concerted opposition
from both interests.  However, neither self-protect-
ing interest can argue the obvious merits for the
conservation, environmental protection, quality
of water protection, safety, dependability, con-
venience, and economics of conjunctive management
of ground and surface water—which, in the eyes of
the consumer and taxpayer, are indistinguishable
from each other, and they are indeed one resource,
both being only water.
     In conclusion, I believe that the time has not
yet come for the establishment of quality standards
specifically for in situ ground water, and to those
carrying the ball for this proposal I say, you are
faced with a first-down problem—punt!
     Frank A. Rayner received a B.S. degree in Geological
Engineering from Texas A & M University in 1958. He has
also completed graduate level courses in Geology and
Hydrology at Texas A & M and Texas Tech University.
After graduating from Texas A & M be was employed as a
Geologist by the then Texas Board of Water Engineers,
Austin, Texas. Prior to joining the staff of the High Plains
Underground Water Conservation District No. 1 (District),
Lubbock, Texas, as its Chief Engineer, he was the Assistant
Director of the Groundwater Division of the Texas Water
Development Board. In 1969 he was appointed the General
Manager of the District and served in that capacity until
September 1977, when he established a private practice as a
consulting engineer and geologist, specializing in ground-
water development, quantity and quality evaluation,
management and research. He is the author of more than
100 books, bulletins, handbooks, rulebooks, papers,
articles and brochures.

Audience Response  to  Session  II  — Ground-Water
Quality  Standards
Bruce S. Yare, Senior Hydrologist, Peabody Coal Company,
301 N. Memorial Drive, St. Louis, MO 63102:  Establishing
federal or State ground-water quality standards will have
a severe impact on current methods of coal recovery,
especially if a nondegradation standard is adopted. Surface
mining for coal creates a large volume of disturbed
overburden which often has a greater porosity and
permeability than the original rock materials. As ground-
water levels recover in this spoil material, the water
becomes highly mineralized, containing at the very least
objectionable amounts of sulfate, hardness and total
dissolved solids. This degradation of local ground-water
quality is unavoidable, since infiltrating water is bound to
react to some degree with freshly exposed rock surfaces
in the spoil material, producing mineralized ground water.
To give some idea as to the amount of degradation, sulfate,
hardness and total dissolved solids concentrations  are
reported to increase as much as 621, 1366, and 3286 mg/1,
respectively, over background levels after surface mining
operations in Muhlenberg County, Kentucky (Herring, W. C.,
1977, Ground-water re-establishment in cast overburden:
NCA/BCR 7th Symposium on Coal Mine  Drainage Research,
Louisville, KY, pp. 71-87).
      In 1977, a total of 689 million tons of coal were
mined in the United States and nearly 61  percent of this
tonnage was produced by surface mining methods. The
potential for a great deal of localized ground-water
degradation is apparent. If a nondegradation ground-water
quality standard is adopted on either a State or federal
level without allowance for a variance from the standard,
surface mining for coal will not be possible. Given the
amount  of coal produced by this mining method, approxi-
mately 417 million tons in 1977, the impact of a nondegrada-
tion standard on energy production in the country is

Mark P.  Zatezalo, D'Appolonia Consulting Engineers, Inc.,
10 Duff Road, Pittsburgh, PA 15235:  I appreciate the
opportunity to respond to this question and present two
statements in support of ground-water quality standards
that were not brought out in the presentation.
      First, I believe ground-water quality standards are
obviously a necessity now and will be even more necessary
in the future due to overpopulation and subsequent
exhaustion of ground-water resources. Due to increased
demand on ground-water reserves, what a person does with
or to his or her privately-owned ground-water resource
will, with increasing frequency, directly impact the
availability of some other person's source of potable water.
To me, there is no question that ground-water quality
standards are necessary to help insure potable ground-water
supplies in the years to come.
      Second, and less obvious, is the effect that such
standards could have in the area of waste recycling.
Individuals that are forced to find ways of using materials
once discarded as waste are finding that it actually can be
more economical to reuse the resources contained in the
waste rather than disposing of them (the recovery of mercury
at Minimata Bay, Japan is a most striking example).
      In my opinion, ground-water quality standards will
"aid" (i.e., force) industry to find new  ways to recycle waste
and thus utilize our natural resources more efficiently,
since as a professor once told me, "There is no such thing
as pollution-only wasted resources."

Ginia Wickersham, Assistant Ground Water Division Chief,
Oklahoma Water Resources Board, Oklahoma City:
I disagree with Mr. Rayner's statements that ground-water
quality standards are unnecessary because the "public does
not want more governmental involvement in their private
affairs." The public does not always know what is necessary
or best, especially in the protection of natural resources.
Oftentimes people forget or overlook the importance of
underground-water supplies. A responsibility of the
ground-water professional and regulatory agencies is  to
foresee potential pollution problems for the public, and
prevent further degradation of water quality. A way this
can be done is through the development of ground-water
quality standards.
     Only by developing standards for ground water can
the natural chemical quality of aquifers be maintained. In
Oklahoma, we  have received and investigated numerous
complaints of ground-water pollution. These include pollu-
tion  by landfill operations, herbicides, salt  water, oil  and gas
drilling activities, and even one case where  cottonseed hulls
were pumped into the fresh-water zone of a major aquifer
in western Oklahoma to restore pressure in the drilling of
a gas well. Our  major ground-water basins are being

constantly threatened and we cannot afford to let this
situation continue.
     Without ground-water quality standards it is very
difficult to prevent or abate pollution. In Oklahoma over
60% of the population depends upon ground water for
water supply, and 80% of the irrigation needs are met by
ground-water resources. However, when a water well is
polluted it is almost impossible to prove in court that
pollution has taken place. Without a standard to compare
with, how can you prove to a judge or jury  that ground
water has been degraded? With ground-water standards we
can classify the ground waters of a State and establish
baseline water quality conditions.
     The States must take the lead in establishing ground-
water quality standards; not the Federal government. Only
with the States in charge can we have the flexibility needed
in developing standards for ground water. States already
have the mechanism for establishing standards, since it is
the State's responsibility to protect the water quality of
the State's waters. Only the States can develop standards
which maintain water quality, prevent pollution, and permit
management of the ground-water resources for beneficial
use by all citizens. The Federal government can assist, by
making Federal funds available and establishing minimum
guidelines in the  establishment of ground-water quality
standards. It is essential, however, that the first step be
taken toward protecting our  ground-water resources
through the development of  water quality standards, as
soon as possible.

Daniel P. Waltz, Hydrogeologist, Layne-Western Company,
Inc., 6909 Johnson Drive, P.O. Box 1322, Mission, KS
66222:  My comment is in response to the use of sewage
sludge on farmland which is used to grow cash crops or
animal fodder. I would not be very interested in eating food
grown on such a  farm, whether I was consuming it directly
or through meat  which was raised on feed from such a
farm. I am familiar with studies of how trace metals such
as zinc, cadmium, mercury, lead and others become concen-
trated in sewage sludge and can be passed up the food
chain. I am also familiar with studies on organics such as
fertilizers and insecticides,  i.e. D.D.T., Paraquat and others,
which also may be passed up the food chain in a similar
manner. Also many human diseases caused by viruses such
as hepatitis can go through a water treatment plant without
being removed. It just seems to me that there has not been
enough research completed in the field of sewage sludge
application to fertile soil and that the unsuspecting
consumer public may already be consuming products with
dubious background.

Ted Clark, Dunn Geoscience Corp., Latham, NY:  Sitting
here I developed a couple of concepts. First, I agree that
we do need to  hold together our basic concept in the
understanding  of hydrology and geology  in the movement of
ground water. We must try to develop sound standards,
so that we aren't faced with a kind of minimum standard
or requirement, like zero discharge. This concept of zero
discharge may  tend to concentrate contamination at the
source area. Ground-water pollution problems that
we are faced with today have often developed from
concentrated point source areas. We need to look at how we
can better regulate with standards, how we might eliminate
some of these concentrated sources that are causing so
many problems.

Richard Dalton,  Principal Geologist, Division of Water
Resources, Trenton, IMJ:  I think New Jersey is getting
involved in some of  these problems we're discussing today
in an area known as the Pine Barons. Many of you have
probably heard the pros and cons on this area. There is a
major aquifer there which has been delineated and regula-
tions were set up for septic discharge. Unfortunately the
people who drew up the regulations were not geologists,
geochemists, or anyone involved with ground-water
movement, and now we in the State must live with the
procedures they  set. These standards are mainly with
regard to nitrate nitrogen—two ppm of nitrate nitrogen
and if anyone here has looked at septic tanks, it's almost
impossible  to meet these standards. Ground-water quality
standards should be drawn up by geologists and geo-
hydrologists, rather  than by lawmakers. We have to know
what is happening underground. We're finding we have
two public supplies already threatened by organic
chemicals, even more so than nitrate. Here, you're talking
ppm which is detrimental. One supply involves a community
of several hundred thousand people. These are the things
we  have to address.

Land   Application  of  Waste  —  State   of the  Art
                     h                             c
by Kenneth R. Wrightu and Catherine Kraeger Rovey
     Land application of treated waste water can provide
unique opportunities, not only for a final high level of
waste-water treatment but for reuse of nutrients as well.
Recent laws passed by Congress have made it necessary
to consider land treatment when planning and designing
new waste-water treatment facilities. The three types of
land treatment commonly used are (1) irrigation,
(2) overland flow, and (3) rapid infiltration. Selection of
the most appropriate type of land treatment for a specific
site is based on several considerations, including soil
conditions, geology, topography, proximity to surface
and subsurface water, and climate.
     Ensuring the protection of ground water is essential
when siting or designing a land treatment system. Ground
water is an important natural resource, having considerable
impact on human life and well-being as well as high economic
value. Safeguarding this important resource from contamina-
tion includes careful site selection, appropriate pretreatment
of waste water prior to its application, and a program of
regularly scheduled monitoring to ensure that the waste
water is being properly renovated for safe release to the
     Utilization of municipal sludge on land for agri-
cultural production is encouraged by federal law, as is
land treatment of waste water. Sludge contains concentrated
wastes, and there are practical limitations on the levels of
      Presented at The Fourth National Ground Water
Quality Symposium, Minneapolis, Minnesota, September
20-22, 1978.
     bpartner, Wright-McLaughlin Engineers, and President,
Wright Water Engineers, Inc., 2420 Alcott St., Denver,
Colorado 80211.
     cWater Resources Engineer, Wright Water Engineers,
Inc., 2420 Alcott St., Denver, Colorado 80211.
heavy metals, salts, and toxic substances in sludges applied
to agricultural lands. Sludge is generally stabilized before
being applied, to destroy pathogens, and reduce weight,
volume and odor.
     Several case studies of successful land treatment
systems presently in operation are presented to demonstrate
the viability of the land  treatment concept.

     The application of treated waste water to land
can provide a final high level of pollutant removal.
It also provides the opportunity for recycling of
nutrients. Land treatment is'not ad hoc dumping of
waste water hoping that it somehow will purify
itself. Land treatment systems must be well planned
and designed and carefully managed and monitored
to ensure that problems do not develop.
     The land application of waste water entails
the use of growing plants, the soil surface and the
soil matrix for removal of certain waste-water
constituents. Sunlight and air make it possible
for the plants to grow, the soil to remain aerobic,
as well as assisting in  disinfection and decomposition
of organic solids  and  organisms.
     The subject of land treatment cannot be
considered in an abstract, academic or theoretical
basis such as professionals did only a few short
years ago. During the last 12 months, the U.S.
Congress has passed a law, which the President has
signed, and the Environmental Protection Agency
(EPA) has promulgated rules and regulations which
make land treatment a fact of life. The EPA is
pressing  public waste-water agencies to use land
treatment, and if they do not, their construction
grant applications must provide complete

justification for rejection of land treatment. Further,
these agencies cannot require overly strict pre-
application treatment for the effluent to obtain
EPA funding. (1)
     It was in late 1977 that Congress passed
PL 95-217, the Clean Water Act, with incentives for
increasing the use of less costly, less energy-intensive
technology. Specifically, the federal government
has identified innovative and alternative technology
sewage treatment works as being necessary and
desirable. To encourage selection of such tech-
nology, EPA will provide an additional 10 percent
bonus to its usual 75 percent grant for innovative
or alternative technology, i.e., a total of 85 percent
would be forthcoming from the federal government,
leaving a local share of only 15 percent. While only
350 out of the 2,700 sewage treatment projects
funded during the past decade have used land
treatment, the percentage during the next decade
is expected to rise markedly, if for no other reason
than that local agencies will want to receive 85
percent federal grants.(l) Land treatment, according
to EPA, qualifies under both innovative
and alternative technology .(2)
     Arguments, often bitter, have taken place
within the engineering profession during the last
decade over land treatment in general and over its
components and impacts specifically. On one side
have been public interest groups, advocates of
conservation, sporting associations and advocates
of clean streams. On the other side have been
municipal and public works engineers and various
sewerage associations and waste-water agencies.
One good question to ask is "Why has this
controversy existed, and why has it lasted so
long?" Furthermore, one might ask why the
decision was made by politicians in  Washington
rather than waste-water professionals. A third
question which should be discussed today between
the pro and con speakers is whether or not Congress
made the right decision on land treatment in the
1977  Clean Water Act.
     A wide range of design possibilities is available
in land treatment to suit specific site characteristics.
There are different types of land treatment, as
described following.

    The three types of land application in common
usage are-. (1) irrigation, (2) overland flow, and
(3) rapid infiltration, as schematically represented
in Figure 1. Each can be adapted to different site
conditions, can satisfy different objectives, and
can produce renovated water of varying quality,

                                        P PERCOLATION
                 (A)  IRRIGATION
               IB)  OVERLAND FLOW
                   WRIOHT-MC|_AUaHI-IN    •NOIN
                   BABO ALCOTT mr.  omnvin, COLO.
Fig. 1. Types of land application in common usage.
depending on design parameters and operation.
There are numerous variations and combinations
which can be used to optimize the system.O)

Irrigation Method
     The irrigation method is the application of
waste water to agricultural lands where a crop is
grown. This method can produce an economic
return on the crop as well as renovating the waste
water. The minimum application is normally
enough  to satisfy the evapotranspiration of the
crops with a 30 percent excess for deep percolation.
However, some installations operate at 8 to 10 feet
of application per year, which provides for deep
percolation of 80 to 90 percent of the total
amount applied.
     The water is subjected to several processes
including physical filtering, adsorption, biological
activity  and natural uptake, as it percolates down
through the soil. A natural disinfection caused by
air and sunshine may also  occur.
     The soil matrix filters out suspended particles
in the waste water, and soil bacteria break down the

soluble organics and nitrify nitrogen in the waste
water. Some of this nitrogen is taken up by the
plants, some is stored in the soil, and the remainder
is either denitrified (N2 gas) or percolates downward
with the renovated waste water. Soil particles also
absorb phosphorus and heavy metals while
filtration and adsorption remove bacteria and
viruses. Macro-nutrients, nitrogen, phosphorus and
potassium, are subjected to uptake by the growing
vegetation along with micro-nutrients such as
copper, zinc, cadmium and nickel. By reading the
fine print on a package of household plant fertilizer,
one will note that the same constituents are
sometimes colored and then packaged to sell for
the equivalent of several thousand dollars per ton.
     This method of land treatment is most widely
used. The managers of the Bortnichy State Farm in
the Ukrainian Republic of the U.S.S.R. have found
irrigation land treatment very satisfactory. This
Farm which serves Kiev is 16 years old, and has
been extensively studied by the Ukrainian govern-
ment. The Farm is described later in this text.(4)

Overland Flow
     Overland flow is the application of waste water
to a vegetated slope where the waste water travels
along the soil-vegetation interface. The bacteria
growing at the interface and on the vegetation treat
the waste water in a manner similar to a trickling"
filter plant. While the treatment mechanism is
primarily biological, there is also physical treatment
caused by the filtering action of the grass. Waste
water also penetrates the top few inches of soil
and flows longitudinally through it, and metals,
phosphorus and other nutrients are adsorbed on
soil particles. The growing plants also uptake
nitrogen, phosphorus and potassium.(I/
     With overland flow, application rates often
range between 10 and 25 feet per year and,
therefore, as much as 90 to 95 percent of the
applied waste water can be recaptured for recycling
and reuse or discharged to the stream in a near
pollutant-free condition.
     Overland flow was "invented" in Ohio by a
food processing company. It is generally used on
very  tight soils where there is essentially no
downward percolation capacity. Figure 2
demonstrates how overland flow is related  to the
other two types of land treatment in terms of soil

Rapid Infiltration
     Rapid infiltration requires very little land
area  and high permeability. The renovated  water
                                 INFILTJ ATION
                  SILT   LOAM  SANDY  LOAMY  SAND
                  	        LOAM  SAND
                   84BO ALCOTT «T.  OBNVBH, COLO. K»T1
Fig. 2. Compatibility of land application types with different
can be recovered by underdrains or adjacent wells.
The main goal of rapid infiltration is treatment of
the waste water.
     This method operates by merely flooding the
grassed surfaces of shallow basins and allowing the
waste water to seep into the ground. Application
rates range from 100 to 400 feet per year.(5)
     An ad hoc rapid infiltration system has been
used satisfactorily on the Widefield Aquifer near
Colorado Springs for some 15 years. Municipal
water wells are located adjacent to the infiltration
ponds. Monitoring of the municipal  water supplies
has been careful. The water tap foaming problems
encountered were from detergent in the days prior
to the introduction of biodegradable detergents.
Occasional nitrogen problems have been reported.
There have been no reported cases of illness
related to virus or bacteria transmitted through
the aquifer.(6)

     Ground water throughout the world is an
important natural resource with high economic
value and sociological impact. It is important not

only to protect ground-water aquifers from being
polluted beyond maximum levels, but also to
enhance the quality of ground water whenever
feasible through proper management.
     Alluvial aquifers along streams and rivers
have frequently been allowed to degrade as a
result of recharge with polluted surface stream
water. Degradation of deep ground water has
occurred as a result of human activities in aquifer
recharge areas.
     At Thornton, Colorado, old gravel pits and
alluvial wells are used as the main water source for
two cities during the winter and as a supplemental
source during the summer.
     The Thornton well field area lies several miles
downstream from the direct surface discharge point
for the Denver Metro Sewage Treatment Plant. Late
in 1977, an emergency arose as a result of nitrite
(NO2) contamination of the potable water supply
being delivered through the distribution system.(7)
The problem was noted when a local aquarium
owner reported that his fish were dying. Analyses
showed that the alluvial aquifer was being recharged
with effluent containing 16 mg/1 of ammonia
nitrogen. The treatment plant was suspected of
converting ammonia  to toxic nitrite between the
well pumping and the delivery to the  distribution
system. To alleviate the problem, the water wells
located immediately  adjacent to the surface stream
were shut down and a monitoring program was
     It is important to note that  no effort was
made to decrease the ammonia concentrations in
the effluent discharged to the South Platte River.
The City of Brighton, further downstream, derives
its municipal supply from the same alluvial aquifer.
High concentrations of nitrate (NO3)  have been
reported  there for at least 20 years.
     Wells, infiltration galleries, and floodplain
gravel pits are used for withdrawing ground water.
An evaluation of the aquifer and its character-
istics is of special importance when planning and
designing a land application system so that
potential problems can be identified and preventive
actions taken.
     On any land application project, a monitoring
program is essential so that trends in ground-water
quality and possible escape of pollutants can be
identified early.
     Prior to land application, waste water usually
undergoes secondary treatment. Such treatment is
  Table 1. Expected Quality of Renovated Water from
            Land Treatment Systems (10)

                             Value, mg/l
Infiltration-  Overland
Percolation   Flow
Suspended Solids
Ammonia Nitrogen as N
Total Nitrogen as N
Phosphorus as P
1 to 2
1 to 2
0.5 to 1
2 to 4
0.1 to 0.5
2 to 5
1 to 2
0.5 to 1
10 to 15
1 to 3
5 to 10
8 to 10
0.5 to 1
2 to 5
3 to 5
recommended, but with relaxed criteria for
suspended solids.(8)
     The quality of waste water applied to the land
varies significantly. For example, in Melbourne,
Australia, the waste water receives only primary
treatment prior to either irrigation or overland
flow. In the Ukraine, the waste water is given full
secondary treatment.(9) It is important that waste
water not be overtreated prior to land application,
not only because of the extra cost involved, but
also because too much treatment can remove
valuable nutrients. The quality of renovated  water
is not significantly affected by the organic quality
of the water applied, that is, by BOD and
suspended solids. The renovated water can generally
be expected to fall within the ranges of water
quality as shown in Table 1.

               SITE  SELECTION
     Selection of a suitable land treatment site
should involve a thorough investigation of physical
characteristics, including soil texture and permea-
bility, underlying geology, topography, and
proximity to ground water and surface water. A
land treatment site should have the capabilities of
transmitting water either over land or through the
soil at some desired, controllable rate, and to provide
sufficient treatment so that water leaving the site
does not cause degradation  of the environment.
     When  evaluating  the site characteristics and
the related  water reclamation capabilities, one
should keep in mind that present land application
facilities generally are not stressing the  soil treatment
system. Investigations by the Public Works
Association Research  Foundation indicated that
most land application systems provide a large factor
of safety .(11)

Soil Characteristics
     In most areas, the Soil Conservation Service
has summaries of physical and chemical properties

of soils. Knowledge of these properties is necessary
for selecting the optimum land application site
and for properly designing the system. Typically,
the data provided by the SCS includes:
     a. Depth to bedrock or gravel.
     b. Depth to seasonal water table.
     c. Thickness of the soil zones.
     d. Sieve analyses.
     e. Permeability of each soil zone.
     f. Available water capacity of each zone.
     g. pH of each soil zone.
     h. Salinity.
     i. Shrink/swell potential.
     j. Corrosivity.
     The depth to ground water should generally be
5 feet or more to ensure proper renovation and
root development. However, if the depth to the
water table is less than 5 feet, artificial water-table
control can generally be instituted by using drains
or by well pumping.
     For rapid infiltration systems, well-drained
soils such as sandy clays, sandy loams, loamy  sands
and gravels are preferred, with depth to water
table from  10 to 15 feet unless underdrains are
     Soils with limited permeability such as clays
and clay loams are best suited for overland flow

     Underlying geology is an important considera-
tion in selecting a land treatment site, because it
must provide a structural base for the site and, for
the irrigation and rapid infiltration methods, a
repository or conveyance medium for the treated
water leaving the soil zone. Limestone or dolomite
areas may be suitable land treatment sites of the
soil zone is sufficiently thick and well graded.
The pH of the waste water should receive special
evaluation when limestone forms the bedrock.
Karst areas should generally be avoided because of
the potential for sinkhole collapse. Areas underlain
by fractured rock can be suitable land treatment
sites if the soil overlying the rock is sufficiently
thick to prevent piping, which can short-circuit
partially treated or untreated water.

     A wide variety of topographical conditions
can be incorporated into land application sites;
however, unusual topography can lessen the
application operation and increase costs. For
cultivated agriculture, a land surface slope should
not exceed approximately 15 percent. However,
when center pivot sprinkling systems are used,
slopes of up to 20 percent are feasible. Sometimes
wooded terrain is used for land application
because of the nature of the soil cover. Wooded
slopes of up to 30 percent are suitable. For
overland flow systems, slopes of 2 to 8 percent are
satisfactory .(10)

Proximity to Water
     The water table underlying an irrigation site
should be deep enough to ensure aerated soil
conditions. Generally, 5 feet is considered
adequate. Periodic increases of the water table
resulting from irrigation application can bring the
water table closer to the surface. In this case,
special analyses are required to determine the length
of time that the root zone is saturated. With a
shallow water table, it is often economical to
install underdrains to provide positive water-
table control and to provide for easy monitoring
of reclaimed water.
     Valley bottom land can provide good land
treatment sites for all three methods. The frequency
and extent of floods should be analyzed, but other
than for low lands which are frequently flooded
(2 to 5 years), floodplain lands often make ideal
land treatment sites.(13)
     The designer should avoid potential short
circuiting of waste water directly to surface water,
streams or lakes. In many areas, minimum distances
from land surface waste disposal sites to surface-
water bodies are specified by law.

     Waste-water application, except for rapid
infiltration, is often restricted to the growing
season which is usually defined by that period
between the first and last killing frost; however,
for pasture, hay and woods irrigation is often
beneficial during the months preceding and
following the killing frosts.
     Warm climates provide special advantages for
land treatment. Nevertheless, many successful
projects have been operated at northern latitudes.
Some rapid infiltration systems operate year-round
in cold climates with the waste water being applied
under the ice cover, such as at Lake George, New

     Public health concerns relate to:
     • Viruses and pathogenic bacteria.
     • Dissolved chemical constituents.
     • Crop quality and pollutant uptake potential.

     • Propagation of insects.
     Sprayed aerosol droplets have been a concern
in the public health field because of their potential
to carry viruses long distances under windy

Pathogenic Organisms
     Pathogenic organisms can survive in the soil
and on vegetation for a long time; some have
potential lives measured in months. The survival
time of organisms outside their natural habitat
depends on many factors. Their survival in soil is
a relatively unexplored  field, though Bouwer et al.
reports a very high degree of virus removal in their
Phoenix studies under conditions which would be
conducive to virus transmittal.(l4)
     EPA reports that "The effects of working
around and handling waste water on land applica-
tion sites are minimal—the health hazards appear
to be no different than  for activated sludge and
trickling filter plants."
     In Melbourne, Australia, the waste-water
agency has had several generations of workers
directly connected to the Werribee Wastewater
Farm (a discussion of the Werribee Farm will
follow later in the text). For instance, one top
official with the agency was born and grew up on
the Werribee Wastewater Farm. Both his father
and grandfather had been farm workers. Medical
records of the present 500 residents of the farm
show no special problems with the waste-water
farm users. In addition, the absenteeism/sick leave
records all indicate normal health for the farm
workers, even those who are second or third
generation employees of the 28,810-acre
     The Russians report that their public health
studies on the Kiev 60,000-acre site showed no
public health problems to workers or to consumers,
even though 16 percent of the crop is  for direct
human consumption, i.e., potatoes.(4)
     The Scientific Advisory Committee to
Governor Lamm  of Colorado has reported:
     Land application treatment of waste water is a viable
alternative means to tertiary treatment in Colorado, provided
proper site conditions are available. Advantages offered in
the synergistic use of water, fertilizer and land resources
make the potential for land treatment applications promising
and the consideration of the land treatment  alternative
should be mandatory in waste-water treatment planning.
Advantages may also exist, for gravity distribution systems,
in lower energy consumption. Land treatment is highly site
specific and the possible range of site conditions within
the State is very broad, varying from relatively long
growing seasons in plains areas, to extremely short seasons
in high mountain locations. Therefore, blanket prescriptions
of the technique cannot be made, but each alternative
proposal must be separately considered. Further, site
specificity not only means that land application treatment
might not work for some situations but also that it might
be the most well adapted technique for others. It also
means that each community needs to explore a variety of
land treatment adaptations before it can say definitely
that no viable alternative exists.(16)

Heavy Metals
     The fate of heavy  metals in land treatment
systems is the item which is often of most concern
to the  regulatory agencies. For this reason,  it is
important to evaluate the uncertainties of heavy
metals in waste-water effluent following secondary
treatment and to analyze the long-term buildup in
the soils over a long period of time.  Generally, one
or more of these constituents is more critical than
others. Because the soil will remove and store most
of the  heavy metal concentrations, heavy metal
buildup can,  in some cases, limit a particular site to
a finite number of years of operation. Normal
municipal effluent does not contain any significant
degree of heavy metals. If they  are found in the
effluent at levels which are of concern, it is
appropriate to trace the contribution back  to its
source so that pretreatment or recycling of metals
can be instituted at that particular source.(3)

Toxic  Substances
     A well designed land application system has
the capability of removing a high percentage of
organic compounds, halogens and carcinogenic
materials. With the advent of the Safe Drinking
Water  Act and its resulting regulations, removal of
these materials should receive special evaluation
and economic consideration.

     Nitrogen, phosphorus and potassium are macro-
nutrients found in municipal waste water. Land
treatment removal efficiencies are indicated in
Table 2.
     Soil has the capability of removing and fixing
 Table 2. Expected Municipal  Effluent Removal Efficiency
             Land Treatment System (5)

                         Value, Percent Removal
           Overland     Rapid
Irrigation     Flow     Infiltration
Suspended Solids
Total Nitrogen as N
Phosphorus as P
85 +

 nearly all potassium and phosphorus contained
 in the waste water. However, nitrogen is more
 mobile and, for this reason, the amount of nitrogen
 applied by the land on an annual basis should
 receive special evaluation to ensure that the potential
 concentration of nitrate nitrogen does not result
 in ground-water contamination. Generally, a nitrate
 nitrogen limit of 10 mg/1 is used as an upper limit
 in renovated waste water.

     Sludge utilization on land for agricultural
 production is encouraged by Federal law.(17)
 It is considered to be the ultimate disposition of
 sludge in a manner which will not cause environ-
 mental degradation if it is done in a planned and
 managed way.
     Presently, the Colorado Department of Health
 and the State Health Board concluded that
 utilization  of stabilized sludge on land for
 agriculture, silviculture or reclamation purposes
 is an environmentally acceptable alternative for
 solving the current sludge problem.(18)
     Municipal sludge contains the concentrated
 wastes of the community. Certain components
 may be toxic and/or hazardous, depending on their
 concentration and method of application. Such
 application must not degrade the surface or ground
 waters. The salt content of sludge  can inhibit
 plant growth if it is applied in high concentrations  or
 at the wrong time.  Thus, the key to a proper sludge
 application project is to have the right quality
 sludge applied at agronomic rates.
     The nominal reason for stabilizing the sludge
 is to obtain pathogenic destruction, volume and
 weight reduction, and odor control. Stabilization
 can be by chemical treatment, digestion, or
 composting, the most common form being digestion
 by aerobic  or anaerobic means. Stabilization in a
 lagoon bottom under anaerobic or facultative
 conditions  is a low cost and effective method.
     The Colorado Board of Health allows sludge
application without a permit if minimum standards
 are met relating to nutrient concentration and trace
element content. For instance, nitrogen is limited
to 60,000 mg/1, zinc is limited to 3,000 mg/1, and
cadmium to 30 mg/1. If standards are exceeded, the
State  reviews and approves on a case-by-case basis.
     Colorado recommends subsurface application
of sludge as a nitrogen conservation measure. With
surface spreading, they estimate that 80 percent of
the ammonia nitrogen may be lost.
     Crops should not be fertilized with sludge if
they may be eaten raw by humans unless the sludge
is first stored for one year. In addition, the Colorado
Health Board allows application on ice-covered or
frozen land without a permit if the land slope is
5 percent or less. On land sloping in excess of
5 percent, annual soil loss must be limited to
5 tons per acre.
     To protect the ground water, Colorado requires
that the mean annual depth to water table be
greater than 7 feet and that no domestic well be
closer than 150 feet. Sludge can be applied in the
floodplain as long as it is outside of the area
flooded more often than once in 10 years. If
these conditions are not met, then special review
is needed with issuance of a permit.
     Monitoring is required for municipal treatment
plants  of up to 10 mgd with at least one sample taken
each 3 months. For larger plants, sampling each
month is required.

     Monitoring of a land application facility is
required to ensure that the waste water is being
properly renovated and that the environment is
being protected. The influent waste water should
be analyzed in the same  manner that conventional
waste-water treatment plants are monitored so
that the operator knows the specific quality of
effluent being applied to the land. In addition,
monitoring of the quality of renovated water, the
vegetation, and the soils is recommended. This
should be considered a part of the management of
a land  treatment facility.
     Renovated water should be analyzed for those
parameters normally monitored  in drinking-water
supplies, those parameters required by regulatory
agencies, and specific parameters required by the
engineer for quality control. Typically, nitrate
nitrogen is the parameter most closely monitored.
     Crops grown on the land application site
should be analyzed periodically both to optimize
growth and yield and to  determine crop intake
level of micro and macro-nutrients.
     Soils should be tested periodically (quarterly)
for salinity, pH, cation exchange capacity and
infrequently (yearly) for considerations of various
elements such as heavy metals.

               CASE STUDIES
Bortnichy/Kiev State Farm, U.S.S.R.W
     The Bortnichy State Farm outside of Kiev,
U.S.S.R., is a successful land application project.
The Minister of Land Reclamation and Water

Management in the Ukrainian Republic of U.S.S.R.
has transmitted a report stating that "since the
start of operation of the (waste-water) irrigation
system the productivity of agricultural crops has
doubled." (Personal communication with N. A.
Garkusha dated September 24, 1976, transmitting
report by A. I. Nasushkin.)
     The Bortnichy Farm has 24,300 ha (60,000
acres) under production with irrigation water
derived from municipal and industrial waste water
generated by Kiev, a city having a population of
1,900,000. Cost of the irrigation system
amounted to $47,000,000 (32,000,000 Rubles)
in 1968.  Unit cost was $l,940/ha ($780 per acre),
which includes transmission canals, laterals,
pumping plans, and all field sprinkler equipment.

Description of the System
     The industrial waste-water treatment uses
physical-chemical processes at the industrial
sources prior to its being combined with the
municipal waste water. Approximately 60 percent
of the waste water is derived from industrial
sources. Primary treatment consists of screening
and pulverizing, followed by settling. The waste
water is then routed to the secondary activated
sludge plant for aeration and clarification prior to
irrigation. The waste water is not disinfected prior
to irrigation so as not  to waste chlorine or ozone.
     The sludge resulting from the primary and
secondary treatment operation, which contains
3 percent solids, is carried by pipeline to sludge
drying beds where it is digested using natural
processes of sunlight and drying. The U.S.S.R.
government is presently studying methods of
direct application of the wet sludge to the fields.
Currently, the dried sludge is used as a field
fertilizer with good crop response. Direct application
of the 3 percent solids wet sludge would reduce
costs and result in reduced land use for natural
drying beds.
     Waste water is supplied to 300 irrigation rigs
by 32 pumping stations for 24 hours per day. The
rigs include the self-propelled power sprinklers
DKSh-64, the  "Volzhanka," which operate from a
closed irrigation system. Irrigation occurs 7 months
per year, from April to October. Total length of open
canals amounts to 41  kilometers (25 miles) with a
1975 flow of 7.2 mVsec (163 million gallons per
day). During the growing season 45,200,000 m3
(36,600 acre-feet) of treated waste water is used for
irrigation. There is no mixing with fresh water. All
irrigation is via sprinkler system to maximize
efficiency of application. The soil cover in the
       Table A. Use of Bortnichy Irrigated Lands
Irrigated Pasture
Other Crops
system is mainly gray or dark gray light clayish
loamy podozols.
     The various types of crops in the irrigated
lands are summarized in Table A. Application rates
average  1,500 m3/ha (0.5 acre-feet per year) per
season to supplement the natural precipitation of
500 to 580 mm/year (23 inches per year). Average
temperature during the year is +7°C.  The period
with average daily temperatures exceeding 15° C is
115 days. Above freezing temperatures prevail for
165 to 170 days. The average for the freezing-free
period ranges from April 19-25 to October 6-10.

Environmental Effects
     Officials of the U.S.S.R. report no health
problems. All effluent is regularly tested and is safe
for irrigation. Fourteen years of health records of
farm employees have been analyzed and no indica-
tion has been found that workers are subject to
health hazards. The quality of the waste water is
constantly controlled by laboratories of various
     The ground-water table ranges from 3 to 16
meters (10 to 52 feet) in depth below ground
surface. By carefully controlling application rates,
the recharge to the ground-water table is strictly
limited; however, care is exercised to insure against
salinity buildup in the soil zone, for salinity
increase would  be sure to cause damage to the
productivity of the soil in this rich agricultural
region. The dissolved constituents in  the waste
water used for irrigation do  not exceed 1,000
milligrams per liter.
     The objectives of the use of waste water for
the Bortnichy State Farms are to increase crop
production and to reduce pollution of the Dneiper
River which flows through Kiev and which provides
environmental and recreational opportunities to the
citizens of Kiev and the 49,000,000 residents of the
Ukraine. The Bortnichy State Farm is in the vicinity
of the Kiev airdrome. It provides a natural buffer
against  development in the vicinity of the airport,
which represents an important benefit.

     Macro and micro-nutrients are provided to the
 crops by the nutrient-rich waste water. For instance,
 nitrogen content in the waste water approximates
 22 mg/1, phosphate is 4.5 mg/1, and potassium is
 11 mg/1. The nutrients are furnished to the crops
 on a periodic basis with each irrigation of approxi-
 mately 400 m3/ha.
     There is a leaching of salts to the ground-water
 table, particularly because the water applied has a
 TDS of 1,000 mg/1. If the Ministry used fresh water
 (with a salinity of no  more than 600 mg/1) the
 leaching of salts to the ground-water aquifer would
 be substantially less; however, artificial fertilizers
 would have to be applied which would tend to add
 more TDS concentration.

     The Bortnichy State Farm at Kiev is a highly
 successful waste-water irrigation farm, operated  by
 dedicated and skillful personnel of the Ministry of
 Land Reclamation and Water Management of the
 Ukraine Republic of the U.S.S.R. The project was
 initiated in 1962 and construction completed in
 1968. The favorable economics of the irrigation
 system using waste water is evident to U.S.S.R.
 officials and to the observer as one views the green
 fields and busy farmhands going about their work.
 Crop production has doubled  with  the use of the
 waste-water irrigation system. Potatoes for human
 consumption are grown. Results of careful monitor-
 ing of the system and its products show no harmful
 effects of using waste water for irrigation.
     The economic impact in  the Ukraine is
 significant as a result of farm income, food produc-
 tion, local employment, and the improved quality
 of the Dneiper River.

 Melbourne, Australia: Werribee Farm System(9)
     The Werribee Farm of the Melbourne and
Metropolitan Board of Works is a highly productive
agricultural and livestock enterprise as well as an
efficient waste-water treatment project. The Farm
was constructed in the 1890's and is presently only
22 miles from  a metropolitan area with a population
of 2*/2 million people.
    The Farm covers 11,660  ha (28,810 acres),
and represents the most productive agricultural
land in Australia. The gross returns from the
Farm's sale of  livestock produced approximately
$1,500,000 in  gross revenues in 1974.  It also
provides an essential municipal service by treating
waste water. In addition to cleaning the waste
water, the Farm has provided beneficial environ-
mental impacts such as providing a major wildlife
sanctuary. The open space near the metropolitan
area discourages urban sprawl in that direction.
Many foreign and local visitors tour the Farm yearly.

Description of the System
     Melbourne's sewerage system was established
in 1893 and has  been in continuous operation
since 1896. Raw waste water is collected from the
Melbourne metropolitan area and carried to the
Werribee Farm in an open canal. Approximately
20 percent of these wastes are industrial in nature.
The Farm currently receives approximately
two-thirds of the Melbourne area wastes. These
wastes have a BOD5 of 600 mg/1. In recent years,
the Farm has been treating raw wastes at a rate
far in excess of its rated capacity. As  a result, the
Metropolitan Board of Works is currently exploring
pretreatment works for the Werribee  Farm. The
Werribee Farm has been and will continue to be
the pride of the  Board of Works. (Interview with
A. H. Croxford,  Chairman, Melbourne and Metro-
politan Board of Works, September 7, 1976.)
     Waste-water treatment is accomplished at the
Farm by 3 processes. During the irrigation season
(6 to 7 months per year), raw sewage is  applied
to pasture areas  totaling 10,351 acres. The applica-
tions are intermittent, being  approximately 10
centimeters (4 inches) deep.  Between applications,
this provides excellent pasture for grazing cattle.
Usually a drying out period of one week is allowed
prior to grazing.  Approximately one-fifth of the
total waste water at the Farm is used  in this manner.
The  irrigation operations are continuously controlled
by approximately 100 shift workers. The major
statistics of the operations are summarized in
Table B.
     The waste water not required for irrigation  is
treated by sedimentation and oxidation in shallow
  Table B. Melbourne and Metropolitan Board of Works
          Werribee Farm System Parameters

1974 Annual Waste-
Water Supply
Gross Farm Area
Purification Areas
Land Filtration
Grass Filtration
Average Annual Rainfall

207,000,000 m3
11, 660 ha
7,210 ha
4, 190 ha
1,515 ha
1,446 ha
62 ha
49.3 cm

168,000 Ac-Ft
28,810 Acres
17,821 Acres
10,351 Acres
3 ,744 Acres
3,573 Acres
153 Acres
19.4 Inches

lagoons. During the winter period, the entire flow
is treated by primary settling followed by grass
filtration and oxidation ponds. Since permeability
is not the key to this particular process, the areas
used for this purpose are the heavier clay soils.
     Open drains of 1.2 to 1.3 meters (4 to 5 feet)
extend throughout the irrigation area. Their
function is to collect surface flows and ground-
water seepage for discharge into Port Phillip Bay.
Water in the drains is sampled to assure the proper
operation of the waste treatment/irrigation system.

System Costs and Revenues
     The irrigated pastures are grazed by 15,000
head of cattle throughout the year. During the
spring and summer, approximately 40,000 to
50,000 sheep are fattened and sold in the fall.
About 7,000 cattle are sold annually and replaced
with calves born during the year. These operations
produce direct revenues for the Farm which
totalled approximately $1,500,000 in 1973/74.
The capital investment of $16,800,000 in the
Farm was amortized long ago. The operation and
maintenance costs of the Farm are reduced
considerably by the revenues which  it produces. The
costs and revenues are summarized in Table C. The
net annual cost of the system  is  $0.12/m3 of waste
water treated. Equivalent costs for treatment by
conventional systems would be several times as
great. As a result, substantial savings are enjoyed
by the people of Melbourne area because of the
Farm operations. The over-all benefit-cost ratio
does exceed unity.

Environmental Effects
     Since its inception, the Farm has had a
resident population which has varied from 67 to
500. The health of these people has  been similar to
any other population of the area. No epidemics or
disease has occurred. The livestock on the Farm
have thrived. There have been some  complaints
of odor from the Farm. These complaints are
relatively infrequent and the degree  of offense has
  Table C. Melbourne and Metropolitan Board of Works
   Werribee  Farm Summary of Costs (1974 Estimates)

Construction (initial
 costs paid off)
Operation and Maintenance
Farm Revenues (Gross)
Net Annual Cost
Net Annual Cost
$.012/m3($.047/1,000 gal.)
                           been minimal. Odor resulted from overloading of
                           the system as the strength and volume of the
                           raw waste water increased, coupled with
                           occasional management laxness.
                               The vastness of the Farm's operations has
                           provided an open space buffer area for Melbourne.
                           The lagoons at the Farm have also developed into
                           an outstanding year-round bird sanctuary. In the
                           summer months, when inland feed and water
                           sources dry up and birds from the northern
                           hemisphere leave their harsh winters behind, the
                           bird population  at the Farm exceeds 100,000. The
                           Farm staff has developed an intense pride in the
                           bird life and their welfare. The wildlife sanctuary
                           which the Farm provides is an example of how
                           agriculture and waste treatment can work
                           harmoniously with nature.
                               There have been no reports of ground-water
                           contamination. Application of effluent irrigation
                           has helped provide a fresh-water barrier to the saline
                           water of the adjacent Port Phillip Bay.
Muskegon County, Michigan System(9)
     The Muskegon County waste-water system
has brought 2,266 hectares (5,600 acres) of previous
wasteland into productive irrigated agriculture. The
agricultural aspects of the project and the high level
of treatment have resulted in an economically
productive and environmentally sound project. For
each acre-foot of irrigation water applied to the
land, the regional net benefits amount to $62.74
(U.S.). The benefit-cost ratio is currently 1.53:1.00.
The annual benefits include direct revenues of
$706,000 from sales of corn grain. The annual
benefits arising from the basic employment of
farm workers is $1,400,000 per year. A savings of
$5,716,000 per year is also realized since
conventional waste-water treatment facilities which
would otherwise have been necessary have not been
built and are not in  operation.
     Substantial secondary benefits include
improved aquatic habitat, improved industrial
siting potential and  general public awareness. Dollar
values for these benefits have not been included in
this analysis.

Description of the System
     Waste water is  collected from  13 municipalities
and 5 major industrial sources. Approximately 65
percent of the wastes presently treated are from
industrial sources.
     The volume of wastes treated currently
averages 37,267,000 cubic meters (30,200 acre-feet)

            Table D. Muskegon Waste-Water Irrigation System - Summary of Irrigation System Parameters
 1975 Annual Waste-Water Supply
 Capacity Annual Waste-Water Supply
 1975 Usable Waste-Water Supply
 Gross Irrigation Site Area
 Usable Irrigation Site Area
 Average Seasonal Rainfall  (April-October)
 Seasonal Rate of Application
 Size Rotating Irrigation Rigs
 Number of Rotating Rigs
   58,000,000 m3
        3,035 ha
        2,266 ha
          49 cm
        14-57 ha
30,200 A.F.
47,000 A.F.
30,200 A.F.
 7,500 acres
 5,600 acres
  19.3 inches
  4.45 A.F./acre
35-141 acres
per year. As the waste collection system is expanded
and growth occurs, this volume will increase to
approximately 58,000,000 cubic meters (47,000
acre-feet) per year.
     Waste water is pumped approximately 10
miles from the urban center to the irrigation site
through a force main. At the treatment site, the
waste water is first biologically treated. Following
this treatment, the waste water is either applied
immediately to the land or stored for later such
use. All water is chlorinated prior to irrigation as
required by State authorities.
     The major statistics of the irrigation operation
are summarized in Table  D. The annual application
of waste water far exceeds the irrigation requirement
for corn in this area because the project is a
combination waste-water treatment and irrigation
project. The over-all economics of the project have,
at least in the short-term, dictated the high waste-
water application rates. The soil at the  site is sandy
and was considered to be nonproductive prior to
the waste-water irrigation project. In 1975, the
average yield of corn for  the waste-water irrigation
project was 5.2 m3/ha (60 bushels per acre).
Although this nearly matched the average yield of
5.7 mVha (65  bushels per acre), it is felt that
yields of 10.5 m3/ha (120 bushels per acre) may be
obtained as operational experience is gained with
the waste-water system.
     Ground-water levels at the irrigation site prior
to construction varied from less than 1.5  meters
(5 feet) in most places to 7.6 meters (25 feet).
Perforated polyethylene pipe was installed to assure
at least 5 feet of freely draining aerobic soil
throughout the site. The  drainage network discharges
to open channels which carry the clean water to
natural waterways. Monitoring of discharge within
the site is provided by a network of 272 observation
wells scattered throughout the property.
System Costs and Revenues
     The system costs and annual revenues for the
Muskegon system are shown in Table E. The cost of
construction for the treatment system was
$37,700,000. The operation and maintenance costs
for the system are $1,822,000 per year. Labor
costs make up approximately 35 percent of these
annual costs.
     The fertilizer value of the waste water is an
important component of the project. It has been
estimated that 60 percent of the nitrogen, 70
percent of the phosphorus and 100 percent of the
potassium removed from the combined domestic
and industrial wastes actually served as fertilizer
for the 1975 corn crop. At current prices (spring,
1976), these chemicals are worth more than
$190,000 (U.S.) per year.
     The irrigation component of the system is
the prime source of revenues. In 1975, this
amounted to $706,000. In future years, these
revenues are expected to increase to approximately
$1,400,000 when experience is gained in the
operation of the agricultural portions of the system.
The capital construction is amortized at 7 percent
over 20 years. After consideration for amortization,
operation and maintenance, and direct revenues, the
net annual cost of the system is $4,457,000 per
year or $0.12/m3 ($0.45 per 1,000 gallons) of
water treated. When the system is operating at full
capacity, these treatment  costs will be reduced to
approximately $0.09/m3 ($0.33 per 1,000 gallons).
The estimated cost of treating waste water to a
lesser degree by conventional treatment systems
in this area is approximately $0.15/m3 ($0.58
per 1,000 gallons). This represents an initial savings
of $0.13 per 1,000 gallons. When the system is fully
developed,  an annual savings of $0.07/m3 ($0.25
per 1,000 gallons) may be realized.
     The costs of agricultural production are

similar to those of any other public irrigation
project of this magnitude in this area. The only
benefit identified under the agricultural category is
the revenue received from the sale of the corn
grain harvested. The revenues received in 1975 fall
short of the potential revenues expected in future
years. In the future, these revenues are expected to
double, whereas the cost of agricultural production
will increase only approximately 20 percent for the
same period. Secondary benefits normally associated
with agricultural products were not included in this
analysis.  A limited special category, however, has
been included because it has special meaning for
waste-water irrigation projects. This benefit is
known as basic employment, as discussed previously.
    In the Muskegon system, special efforts were
made to  convert workers to agricultural employ-
ment. These workers represent approximately
one-third of those employed by the entire system.
Using the multiplier factor of 8 for identifying
regional national benefits, this results in a net
benefit of $1,400,000 per year.
    The over-all environmental enhancement of the
Muskegon area has been the most visible benefit of
the system. To date, 3 positive environmental
impacts have emerged: a general improvement in
water quality in  Muskegon County, increased
wildlife populations at the irrigation site, and
increased aquatic life in Muskegon Lake. These
benefits manifest themselves in various forms.
Visual  improvements in Muskegon Lake's water
quality have increased the over-all pride of the
local citizenry in their environment, tourist trade,
    Table E. Muskegon Waste-Water Irrigation System
                 Summary of Costs

Construction (including
 land cost)
Operation and Maintenance
Total Annual Cost*
Total Annual 1975
 Direct Revenues**
Net Annual Cost***
Net Annual Cost***

$ 1,822,000
$ 5,380,000

$   923,000
$ 4,457,000
 *    Based upon debt retirement over 20 years at 7%
 **   Revenues include approximately $216,400 in grants,
     laboratory services and other miscellaneous revenues.
 ***  After more operational experience is gained, a corn
     crop yield of 10.5 m3/ha (120 bushels/acre) is
     estimated. Also, when full design flows of 58,000,000
     m3/yr (42 mgd) are realized, net annual costs will
     increase by about $500,000 resulting in a net annual
     unit cost of $0.09 /m3 ($0.33/1,000 gal.).
stocking of more sensitive and desirable fish species
in the lake, fishing activity, and has created an
over-all improvement in the quality of recreational
experiences in the area.
     The waste-water irrigation system is also viewed
by local public officials as an important resource in
the improvement of Muskegon County. The
improved quality of Muskegon Lake has encouraged
the City of Muskegon and private interests to
redevelop the lake's waterfront as the focus for
downtown redevelopment and community revitaliza-
tion. Various programs for attracting industry and
over-all economic development of the area stress
the capabilities of the waste-water irrigation system.
     Monitoring of ground-water quality at the
Muskegon facility show it to  be of high quality with
no measureable salinity increase. Pollutants have
not degraded the ground-water quality.

Sonnenberg-Sterling, Colorado System(9)
     The Sonnenberg-Sterling Irrigation Project
would use 3,947,700 m3 per year (3,200 acre-feet
per year) of waste water to irrigate  530 hectares
(1,310 acres) of present sand hill prairieland for
production of corn grain. This project is small,
but the relative economic impact on the region
would be substantial. The annual benefits include
(1) cash crop, corn grain production of $425,800
per year based on 11.3 m3/ha (130  bushels per
acre) yield; (2) basic local employment for farm
workers of $140,000;  and (3) savings of $479,700
in waste-water treatment which otherwise would
be necessary in the Sterling, Colorado area. (This
project was first conceived in 1970 with detailed
planning commencing  in 1975. The project as
described herein is  a private enterprise system
designed as an agricultural enterprise with costs
based on economic agricultural construction
techniques and actual  bids. The project will
probably not be constructed as described for
institutional reasons. A federally subsidized waste-
water irrigation project is anticipated.)
     This waste-water  irrigation system is unusual
in the  sense that the financing of the system
would be undertaken in a partnership between
private interest and government agencies. In this
case, the desire to irrigate additional lands is the
prime  motivating force in the project development.
The need to irrigate additional lands, when combined
with the waste-water treatment needs in the area,
has resulted in the preferred alternative of irrigation
with waste water and achievement of clean water
     The first step  in the Sterling plan is the

collection and transport of the domestic and
industrial waste-water flows of the area to a site
approximately 4 miles east of the City. At the
site, aerated lagoons are used to pretreat the
waste water to avoid nuisance conditions. The
nutrient-rich stabilized waste water is then stored
for use as an irrigation and fertilizer supply.
Rotating rigs are used to irrigate the crop land.

Description of the System
     Included in the system would be wastes from
3 sources: (1) domestic wastes from the Town of
Sterling, (2) industrial wastes from the Sterling
factory of the Great Western Sugar Company and
(3) industrial wastes from the Sterling, Colorado
Beef Company.  Industrial wastes represent approxi-
mately 60 percent of the total irrigation supply.
     Following biological treatment in the aeration
cell, the effluent would be discharged to a storage
basin. Since the  normal irrigation season lasts only
from mid-April to mid-October, it would be
necessary to store approximately a 6-month volume
of waste water. The storage basin also provides for
additional treatment since the solids remaining in
the waste water  will  settle out. At the time of
withdrawal from the basin, the treated waste
waters are disinfected with chlorine prior to
irrigation. After accounting for evaporation and
minor seepage losses, about 3,580,000 m3 (2,900
acre-feet) would be available for irrigation. The
irrigation land would consist of about 530 hectares
(1,310 acres) in  the area of the treatment and
storage basins. The waste water would be
distributed for irrigation by 10 circular electric-
driven irrigation rigs. Each rig is capable of
irrigating 53 hectares (131 acres) and could be
expanded in the future as needed to include corner
systems capable  of irrigating an additional 10
hectares (25 acres) each.
     The primary crop grown would be corn grain
for cattle feeding purposes. Flexibility remains in
the design for irrigation of alfalfa, if necessary, by
some of the rigs. The soil texture at the irrigation
site is sandy. Sprinklers are the only practical
method of irrigation; pivot sprinklers are ideally
suited for this purpose. The design application
rate is 67.5 centimeters per year (2.22 acre-feet
per acre).
     The use of sewage effluent assures that
nitrogen would be applied frequently and in small
amounts. Allowing for some loss of nutrients, about
280 kg/ha (250 pounds per acre) of nitrogen and
67 kg/ha (60 pounds per acre) of phosphorus would
be applied. Unknown quantities of trace elements
would also provide fertilizer value to the irrigation
water. The expected initial yields of the system are
11.3 m3/ha (130 bushels per acre). As the organic
content of the soil increases through waste-water
application and the plowing in of sludges collected
in the storage basins, the expected yields would
increase to the 13 m3/ha (150 bushels per acre)
     The major parameters of the  irrigation portion
of the Sonnenberg-Sterling system are summarized
in Table F.
     The soils of the area are well  drained with
ground water 25 meters (82 feet) or  more below
the surface. The natural drainage characteristics
of the site would allow ample movement of the
percolated water to the South Platte River
approximately 3 miles to the north.

System  Costs and Revenues
     The estimated total construction cost of the
Sonnenberg-Sterling system is $2,441,000. The
annual operation and maintenance cost of the
system is estimated to be $271,000.
     The projected annual revenue for the waste-
water irrigation system would develop only in the
irrigation component. These revenues develop
from the sale of the corn crop harvested. Based on a
projected initial yield of 11.3 m3/ha (130 bushels per
       Table F. Summary of Irrigation System Parameters — Sonnenberg-Sterling Waste-Water Irrigation System
Annual Waste-Water Supply
Usable Waste-Water Supply
Gross Irrigation Site Area
Usable Irrigation Site Area
Average Seasonal Rainfall (April 15-October 15)
Seasonal Rate of Application
Size Rotating Irrigation Rigs
Number of Rotating Rigs
           688 ha
           5 30 ha
           30.5 cm
           67.5 cm
            53 ha
3,200 A.F.
2,900 A.F.
1,700 acres
1,310 acres
 12.0 inches
 26.6 inches
  131 acres

 Table G. Sterling-Sonnenberg System Summary of Costs

Construction               $2,441,000
Operation and Maintenance   $  271,000
Total Annual Cost           $  501,000
Total Annual Direct Revenues $  425,800
Net Annual Cost            $   75,200
Net Annual Cost            $0.02/m3 ($0.07/1,000 gal.)
acre), these revenues would total $425,800 per year,
but would vary depending upon actual yields of
the system and the prevailing market prices. As
experience is gained in the operation of the system
and the organic content of the soil improves, a
general upward trend in these revenues can be
     The costs and revenues of the Sonnenberg-
Sterling system are summarized in Table G. Capital
construction costs are amortized at an interest
rate of 7 percent over a  20-year pay-back period.
Financing of the capital construction costs is
anticipated to  be through industrial  revenue bonds.
If other methods of financing were available via
municipal bonds or federal funding at lower interest
rates, lower  annual costs could be achieved.
     After consideration is made of the direct
revenues produced by the  sale of corn, the net
annual cost of the system would be  $75,200 per
year. This represents a cost of $0.02/m3
($0.07 per 1,000 gallons) of waste water treated.
For comparison purposes, a conventional system
which would provide similar water quality in this
same area would be approximately $0.12/m3
($0.46 per 1,000 gallons). Thus, an initial savings
of $0.39 per 1,000 gallons of waste  water treated
would be realized immediately.
     The designation of benefits has been divided
into 4 general  categories. The waste-water treatment
costs  are those involved in the  transport to, and
pretreatment of, the wastes at  the irrigation site.
Since the storage basin provides treatment in
addition to storing flows during the winter
nonirrigation season, half of the construction cost
($303,100) was allocated to agricultural production.
The regional benefit of $479,700 assigned to waste-
water treatment is the estimated cost of providing
treatment by a more conventional alternative.
This benefit can vary substantially dependent
upon local stream quality  problems. In the Sterling
area sulphates and nitrogen are emerging problems
in the water supplies. The estimated equivalent
treatment cost includes provision for nitrogen
removal only.
     The cost of conventional treatment is
considered a benefit to the Sonnenberg system
since it represents a regional investment which
would be necessary in the absence of the waste-
water irrigation project.
    Additional benefits for over-all environmental
enhancement such as water recreation and wildlife
habitat have not been quantified.
    The annual cost of agricultural production
includes provision for harvest machinery, supple-
mental fertilizers and herbicides, irrigation equip-
ment, etc. The benefits identified with agricultural
production include only the direct revenues
associated with the sale of the corn crop. They do
not include the secondary regional benefits some-
times associated with the sale of agricultural
products, which typically range on the order of
50 percent of the direct revenues. The benefits
also do not include intangibles such as the
enhancement of local cattle feed supplies for local
feed lots, nor the development of a firm irrigation
water supply.

    Due to the law passed by Congress recently,
the rules and regulations  of the  Environmental
Protection Agency, and the need to optimize
federal funding, it  is necessary to consider land
treatment when planning and designing new
sewage treatment facilities. Items to be weighed
in determining the appropriateness of choosing a
land treatment approach include site characteristics
such as soil conditions, geology, topography,
proximity to water, and climate. If the land
treatment approach is within 15 percent of being
the most cost effective, it will probably be selected.
The decision must be made as to which method to
use, irrigation, overland flow, or rapid infiltration.
An evaluation must also be made of the aquifers
and their properties so that potential problems
can be identified and appropriate preventative
actions taken.
     A monitoring program is essential for land
treatment systems so that awareness is maintained
as to the actual quality of effluent being produced
and the first indications of potential effects on
ground and surface waters, crops, and soils.
     The application of treated waste water to land
can provide an economical and  environmentally
viable alternative to conventional waste-water

1. Pound, C. E., R. W. Crites, and S. C. Reed. 1978. Land
     treatment: present status, future prospects. Civil
     Engineering. June.

2. Proposed Rules — Environmental Protection Agency —
     Federal Water Pollution Control Act. 1978.
     Construction grants for treatment works. Federal
     Register, April 25. v. 43, no. 80.
3. Cleveland-Akron metropolitan three river watershed area
     wastewater management survey. Scope Study,
     Wright-McLaughlin Engineers.
4. Field inspection and interview with A. I. Nasushkin, Head
     of Science Division, Ministry of Land Reclamation
     and Water Management, Ukrainian Republic by
     K. R. Wright on August 14, 1975; Interview in Denver,
     Colorado, with N. A. Garkusha, Minister of Land
     Reclamation and Water Management in the Ukrainian
     Soviet Socialist Republic, September 1975.
5. Wastewater management by disposal on the land. 1972.
     Report prepared by Cold Regions Research and
     Engineering Laboratory, Hanover, New Hampshire,
     February 1972.
6. Personal conversations by author with Thomas K.
     Remple, Manager of Security Water District, Southern
7. Meek, Joseph A. 1978. Report on the Thornton water
     supply. Colorado Department of Health, January.
8. Policy on land treatment of municipal wastewater.
     Adopted July 5,  1978, Colorado Water Quality Control
9. Wright, K. R., J. R. Sheaffer, and F. R. McGregor. 1976.
     Municipal wastewater irrigation economic environ-
     mental analysis. Presented at Seventh Technical
     Conference on Irrigation, Drainage,  and Flood
     Control, Spokane, Washington, October.
10.  Land treatment of municipal wastewater effluents.
     1976. Design Factors — 1, Environmental
     Protection Agency, Technology Transfer Seminar
     Publication EPA-625/4-76-010, January 1976.
11.  Survey of facilities using land application of wastewater.
     1973. Environmental Protection Agency, EPA-
     430/9-73-006, July  1973.
12.  C. W. Thornwaite Associates. An evaluation  of cannery
     waste disposal by overland flow spray irrigation —
     Campbell Soup Co., Paris Plant.
13.  Clean Water Act, P.L.  95-217, 1977 Amendment.
14. Bouwer, et al. Wastewater renovation and reuse:
      virus removal by soil filtration. Paper.
15. Personal conversation by author with Mr. R. H.
      Engelsman, AASA, Secretary, Melbourne Metro-
      politan Board of Works, Melbourne, Australia.
16. Report of the Task Force on the Land Application
      Treatment of Wastewater to the Governor's Science
      and Technology Advisory Committee.
17. The Federal Water Pollution Control Act Amendments
      of 1972. PL 92-500.
18. Guidelines for Sludge Utilization on Land, Techn. Policy
      prepared by State of Colorado Department of Health.
      Kenneth R. Wright is a consulting engineer with offices
in Denver, Colorado. He is president of Wright Water
Engineers, Inc., and a managing partner of Wright-McLaughlin
Engineers. Wright has his B.S. and M.S. degrees in Civil
Engineering from the University of Wisconsin, along with
a B.B.A. in Business Administration. He is registered as a
Professional Engineer in ten States and is Secretary of
the Colorado State Board. His firm has planned and designed
five land treatment systems in Colorado which have been
constructed, and they have planned others which are in the
design stage. Wright-McLaughlin Engineers has designed
around  100 conventional sewage treatment plants in the
Rocky Mountain region.
      Catherine Kraeger Rovey specializes in both ground-
and surface-water resources from the point of view of a
civil engineer and computer modeler. Dr. Rovey heads up
the Special Problems Division of the Ground-Water Branch
of Wright Water Engineers, Inc. She has B.S., M.S., and
Ph.D. degrees in Civil Engineering from Colorado State
University and is registered as a professional engineer in the
States of Colorado and Montana. Rovey has handled
conjunctive use and water right assignments, and most
recently is in charge of complex ground^water modelling
for uranium tailings leachate in Wyoming. She is also
handling the study of urban runoff pollutants for the State
of Montana. She has taught at the college level, and has
been in  consulting engineering since 1974.

Land  Application  of Waste
Important  Alternative"
by John R. Sheaffer
     Land treatment uses a combination of processes to
manage and beneficially use waste water. It represents a
revolution in sewage treatment because it (1) transforms
sewage treatment from a single purpose activity into a
multipurpose activity, (2) changes sewage treatment
construction grants from subsidies into investments in the
production of food and fiber, and (3) requires the
participation of a variety of disciplines to implement
successfully. Because it is revolutionary to the sewage
treatment field, three situations have developed. First, it is
displacing traditional technology at a record-breaking pace.
Second, its logical appeal to thinking decision makers has
created a situation in which the policy makers are ahead of
many technicians. Third, it is attacked with a fervor
heretofore unknown in the sewage treatment field.
     Land treatment has logged an enviable track record
in the United States. Existing systems have produced a
high quality effluent at economically competitive prices.
In addition, in terms of relative risk, the threat to
environmental quality from a land treatment system
compares favorably with advanced waste treatment systems.
      Presented at The Fourth National Ground Water
Quality Symposium, Minneapolis, Minnesota, September
20-22, 1978.
     bPh.D., President, Sheaffer & Roland, Inc., 130 N.
Franklin St., Chicago, Illinois 60606.
     Land treatment of waste water is a contro-
versial issue. A part of the controversy stems from
misunderstanding. As Mark Twain once  said, if two
minds disagree, it's for one of two reasons. Either
they are using the same  words to mean different
things, or they are using different words to mean
the same thing. This characterization describes
many discussions and articles relating to land
treatment. In general, discussants are perceiving
different systems as they debate the performance
level of land treatment.
     To initiate a meaningful discussion of land
treatment, it is necessary to identify first the
elements of a complete  system. This does not
mean that a variety of abbreviated versions of  land
treatment system do not exist. Rather, it suggests
that one  should not expect an abbreviated version
to function like a complete system.
     There may be good reasons to abbreviate land
treatment systems. These are policy decisions.
However, the performance data from an abbreviated
system should not be used to evaluate a complete
system. When this is done it is an  incorrect
technological transfer. Such incorrect transfers have
taken place and have influenced planning decisions.

     A complete land treatment system consists
of a number of processes which manage and use the
waste water. There are six basic components. Each
component is discussed briefly.
     The first component is a network of pipes to
collect the waste water. This collection and trans-
port system conveys the waste water to a selected
location. The location could be contiguous to
the producing area 5 miles away, or conceivably
100 miles away.
     The second component provides pretreatment.
Thus, a land treatment system does not spread raw
sewage on the land. Rather  a proper level of
mechanical and biological treatment is provided
before application to the land. The pretreatment
reduces the BOD level of the sewage to prevent
the creation of nuisance conditions.
     The third component provides storage. This
component provides flexibility with respect to
when waste water will be applied to the land. This
eliminates conflicts with respect to planting,
harvesting, and  irrigation. Also, it avoids the
necessity of irrigating during the nongrowing
season. If the pretreated waste water is to be used
primarily to irrigate and fertilize crops it must be
stored during the nongrowing season. The storage
facility must be designed to manage potential
leakage. This can be done by constructing facilities
to intercept the leakage and return  it to the storage
basin, controlling ground-water movements by
wells and drainage ditches, or lining the storage basin
with an impervious layer. Disinfection of the
treated and stored waste water takes place as it
leaves the storage basin.
     The fourth component is an irrigation site
on which crops can  be grown. When selecting the
site, the hydrogeology and the soil characteristics
should be evaluated. There is a double interest in
these evaluations. First, there are the general
questions regarding the use of the site for irrigation,
e.g., salinity, waterlogging, and the  buildup of
sodium in the soil. Second, there are the questions
regarding the capability of the site to purify the
stored and pretreated waste water.
     Initially, a field description of the site must
be developed. The soil must be evaluated with
regard to texture and be separated into horizons
with depth. This information on soil needs to be
accompanied by observations regarding
infiltration, permeability, depth to zone of
saturation, and direction and rate of flow of
ground water.
     The following group of analyses will help to
establish the potential for prolonged irrigation of
the soil and to evaluate its potential to purify the
waste water: (1) cation exchange capacity (c.e.c.),
(2) pH, (3) calcium carbonate (CaCO3) if exceeding
0.1 percent, (4) particle size distribution, (5) total
organic carbon, (6) total organic nitrogen,
(7) exchangeable Ca, Mg, K, and Na, (8) total
soluble salts, (9) chlorides, and (10) bulk density.
(These parameters are gleaned from the analyses
of land treatment systems provided by G. W. Leeper,
consultant in agricultural chemistry to Sheaffer
& Roland, Inc.) The importance of these parameters
is discussed briefly in the following passages:

     1. Cation exchange capacity. This has a role
in both spheres of irrigation and purification.  In
irrigation, it is helpful in estimating the impact of a
known amount of sodium in the irrigating water. In
purification, it is used in estimating the load of
heavy metal which the soil may safely carry. A
useful figure that is quoted here, and one with
some experimental backing, is that if the pH is 6.5,
then 10 percent of c.e.c. may be held by zinc  and
other heavy metals. (If c.e.c. is 20 m.e. per 100 g,
this means 650 ppm of zinc.)

     2. pH. There is also a dual role for  pH. A pH
exceeding 8 is taken into account in assessing  the
impact of sodium in water; while any information
about pH  is useful in describing a soil's chemistry—a
low pH implies low reserves of nutrients, in
particular. In renovation, one desirable (or essential)
side of a moderately high pH is the increased
ability to hold heavy metals (Leeper, 1978).
Another concern is phosphate. It is held by calcium
at pH above 6 and by iron and aluminum at pH
below 6.

     3. Calcium carbonate.  Information  on CaCO3
is in any soil study. The qualification "above 0.1
percent" is merely to avoid analyzing for trivialities.
Calcareous soils have their own peculiarities in
availability of trace elements. In terms of renovation,
CaCO3 is a powerful buffer against both heavy
metals and phosphate. Against zinc, 1 percent
CaCO3 would certainly hold 6500 ppm zinc.
Against phosphate, 1 percent CaCO3 would hold
1900 ppm phosphorus.
     4. Particle size distribution. This is a numerical
way of recording what the soil survey reports  as
sand, loam, clay loam, clay, etc. The percentage
clay is the most important single value in this
analysis. It can be linked to the conduction of
water through the soil, and to the c.e.c. though

different kinds of clay differ greatly in c.e.c.

     5. Total organic carbon.  This provides an
estimate of total organic matter (given by multiply-
ing by 1.72). While this figure is largely determined
by climate it also depends on management and
generally increases with fertility. Organic matter
contributes to c.e.c. much more than does clay,
and it holds heavy metals, atom for atom, more
strongly than clay. This need not be evaluated
below 2 feet.
     6. Total organic nitrogen. This is easily
determined and gives a little additional information
to organic carbon, in terms of fertility. The carbon
nitrogen ratio (C/N) is usually of the order 10 to 12
to 1. Any reduction in this ratio indicates a
greater likelihood of liberating ammonia. This
need not be evaluated below 2 feet.

     7. Exchangeable Ca, Mg,  K, and A/a. These
exchangeable metals are primarily of interest in
coping with high proportions of sodium. They are
of primary interest to the irrigator.
     8. Total soluble salts.  This is of interest to the

     9. Chloride.  This is of interest to the irrigator.

     10. Bulk density. This information is needed
to make mutual transformations of parts per
million and kilograms, per hectare or pounds per

     The fifth component is a growing crop. This
provides a living filter with the potential to
recycle nutrients. The crops selected must be
compatible with the soil, climate, and the waste-
water characteristics. A soil system  with a growing
crop can recycle nutrients and can extract some
substances that should be confined  and contained
in the environment. Cadmium, an example, is an
element in sewage which is efficiently extracted by
crops. However, the crop keeps the cadmium out
of its seed and deposits it in its stems and foliage.
     The sixth component is an underdrainage
system. This important component can be either
natural (an area of ground-water discharge) or
installed (drain tiles or wells) or a combination
of the two. The purpose of the underdrainage
system is to protect both the living filter and the
aquifer. The living filter is protected from water-
logging and excessive salt buildup by the drainage
network. The aquifer is protected because of the
capability to collect and recycle any pollutants
which may have broken through the living filter.
     Many abbreviated land treatment systems do
not have an underdrainage system. In essence,
they have uncontrolled recharge. The Muskegon
County waste-water management system can be
used to illustrate how an underdrainage system will
function. The United States Geological Survey in
conjunction with the State of Michigan analyzed
the underdrainage system at Muskegon County
(U.S.G.S., 1978). A digital model analysis was
undertaken. This analysis showed that if the
effectiveness of the tile to collect drainage is
reduced by 75 percent—a severe planning
assumption—large areas within the land treatment
site would become waterlogged. However, the
effect outside the waste-water site would be
negligible. With this type of information,
conjecture concerning the potential effects a
complete land treatment system would have on
off-site wells is academic, when a properly designed
underdrainage system is provided.
     It is important to note that many systems
referred to as land  treatment are not designed
properly and do not contain all of the components
of a complete system. In some instances, the treat-
ment plant does not work so the effluent is
conveyed to a nearby field and discharged. This is
not a land treatment system. Similarly an industry
with a seepage bed does not have a land treatment
system. The performance of such a system should
not be used to evaluate the performance of a land
treatment system.
     There is danger in repeating the design of a
successful land treatment system at a new site. In
this respect, land treatment differs significantly from
the more conventional treatment plant technology.
One should not repeat the Muskegon design
throughout the country. A land treatment system
must be designed to fit specific site characteristics.
Even outspoken opponents of land treatment agree
that it is possible to design a land treatment system
that would not result  in the pollution of
underground-water resources.
     To illustrate,  one critic stated, "the impression
should not be left that no waste materials can or
should be placed on, in, or under the ground
surface. Given the  proper hydrogeological
conditions and using appropriately designed
facilities, there are situations when selected wastes
can be disposed of into the ground without
appreciably modifying the quality of the potable
ground water." (Johnson, 1978).

     There are a number of significant technological
changes inherent in a land treatment system.
Essentially land treatment transforms sewage
treatment from a single purpose activity into a
multipurpose activity, changes sewage treatment
construction grants from subsidies into investments
in the production of food and fiber, and requires
the participation of a variety of disciplines to
implement successfully.
     A land treatment system constitutes a change
from a single purpose to a multiple purpose
program. A land treatment system provides agri-
cultural open space near urban areas. It helps to
preserve agriculture—a stated goal of many urban
     Land treatment can be integrated with flood-
plain management. The Department of the Army
observed that the authorities in the Federal Water
Pollution Control Act Amendments of 1972 regard-
ing the acquisition of sites for land treatment of
waste water when combined with the authorities
of Section 73 of the Water Resources Development
Act of 1974 offer an outstanding opportunity for
multiple uses of floodplains while preserving green
space and providing recreational opportunities.
The Army spokesman inquired, "why not use our
floodplains in urban areas for crop production, golf
courses, forests, and other uses which can
capitalize  on the nutrients in our waste water and
provide tertiary waste treatment at the same
time?" (Ford, 1975).
     Land treatment impacts on energy. The
nitrogen in a year's flow of domestic waste water in
the United States requires the equivalent of two
and a quarter billion gallons of crude oil to replace
as fertilizer.
     The implementation of a land  treatment system
allows a community to transfer the cost of sewage
treatment (a social inflationary cost) to the positive
side of the ledger (an investment in the production
of future food and fiber). This is the rationale
behind the 10 percent bonus in Federal construction
grants for  land treatment systems. When the
Federal government supports a land treatment
system over a conventional treatment plant, the
construction grant shifts from a Federal subsidy to
an investment in the production of future food
and fiber.
     To design a land treatment system that is site
specific will involve a number of disciplines. The
design of such systems requires soil scientists,
hydrogeologists, agriculturalists, chemists,
biologists, and engineers. Physicists should play  a
role since land treatment is dealing with the basic
laws of matter and thermodynamics. Land treatment
seeks to use the forces in nature for the benefit of
humanity. To do so successfully requires the involve-
ment of several disciplines.

     Land treatment is replacing traditional
technology at a rapid rate. A decade ago,
land treatment was not considered seriously.
Land treatment was viewed by some as a movement
back to the Dark Ages. It was viewed as a return
to honey buckets.
     However, dramatic changes are now underway
and land  treatment is in the forefront. It  is the
encouraged alternative because it has been successful.
In the light of its success, many policy makers
have become the leaders or advocates of the
     Many persons in the engineering profession
have chosen not to lead. This reluctance was
observed by Eugene T. Jensen in 1971. Mr. Jensen
told an American Society of Civil Engineers
National  Specialty  Conference at Los Angeles:
"I am ashamed to admit that... the old 'pros' in
the field of water pollution control appear to be
lagging. The people and Congress appear to have
swept by us." The reaction to his challenge was
somewhat predictable. Simply remove Mr. Jensen
as Operations Chief of the Water Quality  Control
Office of EPA. The transfer took care of Mr.
Jensen, but fortunately it did not take care of land
treatment. Congress recognized the validity of his
statement and has moved land treatment  along
legislatively as evident by the passage of the Clean
Water Act of 1977  (P.L. 95-217). Having abdicated
the leadership role, some in the engineering
profession have chosen to attack land treatment.
Articles have crept into the trade journals with
titles or headings like "Land Disposal: A Giant
Step Backward;" "Land Disposal: The Paper Tiger;"
and "Land Disposal: The Environmental Blunder
of the 20th Century." This terminology gives
these authors away. They are so engrained with a
disposal philosophy that land treatment is
beyond their comprehension. The management
and use of pollutants as resources out of place is
not understood. Thus, these critics tend to gravitate
to their familiar turf—disposal.
     In the planning process, the attack on land
treatment takes a different course of action. Here,
technical distortions are  introduced into the data to
color the outcome.
    A review of alternative treatment systems in

   Table 1. Key Chemical Raw Materials Advertised as
           Being Available from Michigan
Chlorinated solvents

Air gases
Hydrochloric acid
Magnesium oxide
Phosphoric acid
Sodium carbonate
Sodium hydroxide
Sulphuric acid
Natural gas

a New England State was undertaken. One system
included a traditional treatment plant. The other
system called for land treatment. Both of them
were going to chlorinate their effluent. The study
concluded that the two systems would cost
essentially the same, and suggested that it would
probably be easier to build a traditional treatment
plant since there has been more experience in
building such plants. When the cost breakdown of
these systems is evaluated, a great disparity in
estimating appears. The cost of the chlorination
facility at the treatment plant was listed at $20,000.
On the other hand, the cost of the  chlorination
facility at the land treatment system was listed at
$360,000 (Town of Falmouth). This is simply one
of many blatant examples of technical distortions
which are being used in an effort to stymie the
move toward land treatment.

     Empirical information on the performance of
a land treatment system can be gleaned from the
monitoring of the Muskegon system. The excellent
removal experience of traditional pollution
parameters by the Muskegon County Wastewater
Management System is well documented (U.S. EPA,
1977a). Therefore, emphasis here will be placed on
performance with respect to organics.
     The Muskegon system receives an unusually
large assortment of organic compounds and this is
not typical of a normal municipal system. Some
of the exotic materials which enter the system is
evidenced from the raw materials tabulated in
Table 1. The industries which discharge their
wastes into the system are tabulated in Table 2.
     Another complicating factor is that the ground
water in the nearby area has been contaminated by
discharges from Lakeway Chemical Company's
unsealed lagoons and Thermo-Chem Incorporated's
seepage lagoons. In an effort to correct this
ground-water pollution problem, two 8-inch purge
wells are now in operation at the Lakeway Chemical
site to pump the polluted groundwater to the
Muskegon County Wastewater Management System
for purification (communication with Andy Hogarth,
Michigan Department of Natural Resources, August
10, 1977). The area north of the lagoons has shown
steady improvement. However, the number of purge
wells needed to correct the situation is likely to
increase to six 8-inch wells before the ground-water
pollution will be brought under control. There  are
two interesting observations that can be drawn from
this experience. First, the Muskegon system is
deluged with assorted organic discharges from
industry each day (see Table 2). Second, it is
serving as  a pollution sink for a program that
is seeking  to clean up polluted ground water at a
nearby industrial site. This ground-water cleanup
program is enjoying a measure of success (W. Mich.
Shoreline  Regional Dev. Com., 1977).
     The Robert S. Kerr Environmental Research
Laboratory undertook a preliminary survey of
toxic pollutants at the Muskegon system in
August and September of 1976. The report
emphasized that this was a preliminary survey
conducted within a restricted time  frame which
considerably limited both sampling and analytical
         Table 2. Chemical Process Industries Discharging into the Muskegon Wastewater Management System
Burdick and Jackson Laboratories
East Shore Chemical Co., Inc.
Lakeway Chemicals, Inc.
Story Chemical Corporation
Webb Chemical Service Corporation
Thermo Chemical, Inc.
Thomas Solvent Company
Fisons Limited
Fine organic chemicals
Specialty chemicals
Dichlorobenzidine dihydrochloride,
Specialty fine chemicals
Industrial and laboratory chemicals
Disposal and reprocess chemicals
Agrochemicals and pharmaceuticals

benzidine sulfate slurry
a Not on line when survey was taken.

                           SAMPLE:  EQUIVALENT TO 7.5 ML
                                 OF WASTEWATER.
                           COLUMN:  3% OV-1 ON 100/200 GAS CHROM
                                 Q. 1.8 M x 2 MM.
                                 70-240° 6°/MIN.
                          AERATED LAGOON EFFLUENT
 SOURCE:  Robert S. Kerr, Environmental Research Laboratory, May 1977.
 Fig. 1. Comparison by gas chromatography of neutral
 extracts of waste waters from Muskegon system, August 10,
efforts. Results from the analyses are presented
in Figure 1. It concluded that:
      The Muskegon County Wastewater Treatment System
was receiving for treatment waste waters consistently con-
taining a great many organic pollutants of possible concern,
including at least  11 compounds appearing on the EPA
"List of Dangerous Pollutants." It is further apparent that,
even though  low levels of eight organic pollutants, including
four toxic compounds, were indicated to survive the treat-
ment sequence, the Muskegon System was relatively quite
effective in removing organic pollutants from the waste
water which  it was treating. This is emphasized by the Figure
which presents a comparison by gas chromatography of
neutral extracts prepared from influent, aerated lagoon
effluent, storage lagoon effluent, and final effluent samples.
These chromatograms, which were obtained by chromato-
graphing quantities of extract equivalent to 7.5 ml of each
waste water,  clearly  show the very significant attenuation
of organic pollutants across the system. It is very doubtful
if any other types of treatment systems, with the possible
exception of  those utilizing heroic and very costly measures
for polishing  of final effluents would  have been more
effective than the Muskegon System in removing the organic
pollutants occurring in the waste water being treated,
especially since more than 60 percent of this waste water was
comprised of industrial components. The presence in the final
effluent of atrazine, trimethylisocyanurate, and those eight
 compounds which survived the entire treatment sequence
 is significant primarily because these substances necessarily
 traversed 5-12 ft (1.5-3.66 m) of sandy soil to reach the
 tile carrying the final effluent from the site. This
 comprises further evidence that organic pollutants,
 including chlorinated compounds of suspected toxicity,
 may survive and move significantly in the subsurface under
 proper conditions. Hence, the need is reiterated
 for developing definitive information concerning the
 movement and fate of organic pollutants in the subsurface
 environment in order that waste disposal methods which
 employ the subsurface as a pollutant receptor
 may be utilized to their  full potential with minimum
 impact on ground water (U.S. EPA, 1977b).
      This research did not show any evidence of
 ground-water pollution. Rather it simply showed
 that with heavy applications of waste water on  a
 sandy soil, small quantities of organic compounds
 moved through 5-12  feet of sandy soil into the
 underdrainage  system. It is necessary always to
 distinguish between ground water and a controlled
 underdrainage  system when discussing a land
 treatment system.
      The scientists called for more research. This
 is proper in  light of the myriad of organic com-
 pounds which enter the environment.
      The removal of  chloroform by the Muskegon
 System is presented in Table 3. The influent
 averaged  870 parts per billion. A maximum
 contaminant level of 100 parts per billion for total
 trihalomethanes including chloroform is  suggested
 for drinking water. The concentration which appears
 in the drainage tiles at Muskegon averages 6 parts
 per billion.

      Land treatment systems provide an oppor-
 tunity to view sewage treatment as an investment
 in the production of  food and fiber. They can be
viewed as an investment in the future, rather than
 an increase in social costs. Land treatment provides
 Table 3. Removal of Chloroform by the Muskegon Land
         Treatment System (in parts per billion)
from sample
        Average    870
a Maximum contaminant level (MCL) 100 parts per billion
 for total trihalomethanes including chloroform.

our nation with a positive program to deal with a
negatively perceived material, sewage. In addition,
clean water is achieved. It is very doubtful if any
other type of treatment system could be as
effective as the Muskegon land treatment system
in purifying water. Biases of the past pale when
the merits of land treatment are evaluated
objectively. We need to know more about it.

Ford, Charles R. 1975. Effect of new legislation on
     management of river systems. Transactions of the
     40th North America Wildlife and National Resources
     Conference. Washington, D.C., p. 278.
Johnson, Charles C., Jr. 1978.Drinking water policy
     problems: background of the current situation. Paper
     presented at the National Conference on Drinking
     Water Policy Problems, March 6, 1978.
Leeper, G. W., 1978. Living with heavy metals. Marcel
     Dekker, Inc., New York, p. 88.
Town of Falmouth, Massachusetts. Wastewater facilities
     plan. Preliminary draft, pp. A-8 and A-9.
U.S.  Environmental Protection Agency. 1977a. Process
     design manual for land treatment of municipal
     wastewater. EPA 625/1-77-008, October  1977.
U.S.  Environmental Protection Agency. 1977b. Preliminary
     survey of toxic pollutants at the Muskegon waste-
     water management system. Robert S. Kerr Environ-
     mental Research Laboratory, Ada, Oklahoma.
U.S. Geological Survey. 1978. Model analyses of the impact
     on groundwater conditions of the Muskegon County
     Wastewater Disposal System, Michigan. Open-File
     Report 78-99, January 1978.
West Michigan Shoreline Regional Development Commission.
     1977. Assessment of groundwater quality in region
     14. Preliminary Report, December 1977.
     John R. Sheaffer is President of Sheaffer & Roland,
Inc. He received a B.S. in Physical Science at Millersville
State College, Pennsylvania in 1953; an M.S. in Physical
Science from the University of Chicago in 1958; and a Ph.D.
in Social Science from the University of Chicago in 1964.
He received a Declaration for Exceptional Civilian Service
from the Department of the Army in 1972. His past
experience includes. Presidency of K & A Resource
Planning, Inc.; Bauer, Sheaffer, and Lehr, Inc. (1973-75);
Special Assistant for Environmental Affairs, Department
of the Army (1972-73); Scientific Advisor, Office of the
Secretary of the Army (1970-72); Research Associate and
Consultant, Center for Urban Studies, University of
Chicago (1966-70); and Resource Planning Officer, North-
eastern Illinois Planning Commission (1960-66). He has
published  numerous papers.

Land  Application   of Waste  —  An  Accident
Waiting  to  Happena
by Charles C. Johnson, Jr.
     Half the population depends on ground water for
domestic uses. Use is increasing 25 percent per decade.
Ground water is generally used with little or no treatment.
     Some persons would transfer the discharge of our
waste products from contaminated surface streams to the
land and thus relatively clean ground waters.
     No standards exist that protect ground-water quality.
Research necessary to give assurance that natural interaction
of waste water and soils will remove, to acceptable levels,
potentially harmful contaminants, organic and inorganic,
that permeate today's waste streams and today's health
concerns, has not been done.
     Success reports on land treatment of waste water have
not evaluated deterioration of ground water from organic
contamination. Most waste waters contain synthetic
organics in varying concentrations. EPA recommends their
reduction in drinking water to the lowest possible level.
     Most instances of ground-water contamination have
been discovered after drinking water is contaminated.
Unless the public  is willing to treat ground water as it does
water from surface streams, greater control of land disposal
practices must be exercised. Current practice does not
indicate the necessary controls are contemplated or
recognized. It follows that the widespread use of the land
treatment alternative is, in reality, an accident waiting to

     The title assigned for this session does not
limit one to a discussion of waste-water treatment
practices and their residuals, although I suspect this
was the original intention. Inasmuch as ground-water
protection  is the underlying theme of this National
      Presented at The Fourth National Ground Water
Quality Symposium, Minneapolis, Minnesota, September
20-22, 1978.
     ^Chairman, National Drinking Water Advisory Council,
and Vice President, Malcolm Pirnie, Inc., Consulting
Environmental Engineers, 8757 Georgia Ave., Suite 503,
Silver Spring, Maryland 20910.
Symposium, let's take a brief look at the tremendous
waste produced in this country that helps to place
our nation's vast ground-water resources in
jeopardy. Each year major U.S. industries treat
about 5,000 billion gallons of waste water before
discharging it to the environment (U.S. EPA,
1977a). Of this volume, about 1,700 billion gallons
are pumped to oxidation ponds or lagoons for
treatment or as a step in the treatment process.
Another 5,000 billion gallons per year of municipal
waste water is discharged to the environment, with
an estimated 730 billion gallons of this amount
discharged to the land. In the United States,
municipal sludge production amounts to about
5 million dry tons per year. Industrial sludge
production is believed to be many times this
amount. EPA (1977b) estimated annual solid
waste production at 136.1 million tons in 1975. In
addition we must deal with the millions of tons of
gaseous wastes that are produced annually; the
untold hundreds of million tons of mine  tailings
disposed of each year; and the tremendous volumes
(more than 24 million barrels per day) of oil field
brines produced each  day. The discharge to the
environment of such large volumes of waste with
varying concentrations of toxic and hazardous
substances must have  a detrimental effect on the
quality of our nation's water resources, both surface
and ground-water supplies.
     Because of the proclivity for waste production
in this country, and as a result of the rather
indiscriminant waste disposal practices that prevail,
some basic concepts regarding water-supply protec-
tion  have been destroyed, and some new ones
that  affect established policies in the water-supply
field have surfaced. The paragraphs that follow
will discuss some of these  as they relate to land
application of waste water and protection of
ground-water quality.
     The Public Health Service Drinking Water

Standards (USPHS, 1962) required that water
supplies be obtained from a "protected source."
In the case of ground water, the standard defined
"protected source" as water resulting from the
natural purification by infiltration through soil
and percolation through underlying material and
storage below the ground-water table. If  the source
was not adequately protected by natural means, the
supply is to be adequately protected by treatment.
Ground water for human consumption is seldom
treated except for disinfection. It is generally
agreed that these standards were  designed to
protect against bacteriological contamination and
that this definition of protected source provides
insufficient protection against the massive volumes
of toxic and hazardous wastes that are discharged
to our environment today.
     It must be recognized that the number of
protected underground sources are diminishing.
The remaining acceptable sources are further
threatened by policies being initiated without
supportive studies in terms of today's health
concerns, and promoted under the desire for "zero
discharge" of waste water to surface waters.
    Well meaning, but poorly advised persons
would have us transfer the discharge of our waste
products from our surface streams, which are already
contaminated to the land and thus, subsequently to
the ground water, which in both  instances are
relatively clean. This would be an excellent idea if
complete reliability could be placed upon the natural
action of most soils to remove the potentially
harmful contaminants, organic and inorganic, that
seems to permeate today's waste stream  and
today's health  concerns. The fact is that  we can not.
A search of the literature has failed to reveal one
instance where any qualified expert has agreed that
the natural filtration and percolation of today's
waste-water stream through the soil produces a
water that without question is safe to drink. That is
not unusual. Neither does anyone recommend that
waste water receiving tertiary treatment  followed
by dilution with water of drinking quality
is fit to drink. On the  other hand, the literature
is replete with  examples of ground-water
contamination that results from current
practices—even those projects considered by some
to be successful land treatment operations.
    While some will dismiss these studies as being
representative of archaic practices, others will
recognize that they provide information  that we
need to know. For instance, a preliminary report
discussing the subsurface migration of hazardous
chemicals (Geraghty and Miller, 1977) showed
substantive movement of heavy metals, cyanide,
arsenic, selenium and organics through the soil
and into the ground water.
     A study of the long-term effects of land
application of domestic waste water at Hollister,
California (EPA, 1978a) revealed substantially
higher levels in the total coliform count per 100 ml
over control wells; also it indicated increased
cadmium levels, and lead levels that sometimes
exceeded drinking water standards. Further, the
report stated that "the greatest void of information
remaining with respect to land treatment systems
is that of persistent or refractory organic
compounds. Uncertainties regarding health
effects from transport of these materials through
the soil from land-applied waste water must be
answered before essential design criteria can be
established. Quantification of basic scientific
data on organic substances of known or suspected
toxicity and determination of safe underground
travel distances are major areas where research is
     A report just recently released by EPA
(1978b) discusses environmental changes from
long-term land application of municipal effluents.
In my opinion, what the report says about the
impact of the practice in two communities—
Bakersfield, California, and  Lubbock, Texas—on
ground water is most supportive of my concern
for the paucity of data related to this practice and
its impact on ground-water quality. The report says
that "very little" is known with regard to  ground-
water changes underlying the sewage-effluent-
irrigated farm at Bakersfield. What is known suggests
that high levels of nitrate are in the ground water
under the farm. By comparison it notes that
ground water under farm land several miles to the
east are also high in nitrates. The report states that
only slightly more information is available on
ground-water quality at the Lubbock irrigation farm.
Total dissolved solids of 1692 ppm were one-third
higher than comparison wells, and nitrates of 50
ppm were 6 times higher. From the few data
available, it appears likely that the long-term
effluent irrigation operation (3 farms operated for
38, 19  and 6 years) has caused increased dissolved
solids and nitrate  concentrations in the ground
water underlying the farms.
     It can be pointed out that even the quality of
the ground water  under the country's most
heralded land treatment system—the waste-water
management system serving Muskegon County,
Michigan—must be viewed with a note of caution.
Following a preliminary survey of toxic

pollutants at the site, the report (EPA, 1977c)
stated the presence of low levels of organics in the
final effluent indicates the need for definitive
information concerning the movement and fate of
organic pollutants in the subsurface. I believe we
all know that the State of Michigan does not
allow the ground water at this site to be used for
drinking water.
     Other States also have exhibited concern for
the potential health effects of ingesting over long
periods of time, ground water contaminated with
the waste water following its application to land.
California convened a panel of experts to advise
it on this question (State of California, 1976).
Their report concluded that "areas of uncertainties
regarding health effects can not be resolved because
basic scientific knowledge is lacking." It noted that
"monitoring and surveillance have not been directed
at health aspects."
     The California State Health Department has
completed a draft version of proposed ground-water
recharge regulations for use when reclaimed waste
waters are used to augment underground potable
water supplies through spreading (AWWA Research
Foundation,  1977). Among other things  these
draft regulations require that the waste water
receive carbon absorption treatment (30  minutes
detention time), and percolate through an
unsaturated aerobic zone of undisturbed  soil for at
least 10 feet vertically.
     Almost daily we are reminded of the
perils to our ground water that can result from
land application of wastes. Just recently the
Communicable Disease Center of the Public Health
Service (1978) reported at least 759  cases of
gastroenteritis associated with leakage from a
municipal sewage lagoon in southern Missouri that
affected the aquifer in Arkansas as well. The lagoon
was over a porous limestone formation which
permitted rapid movement of ground water.
Hindsight tells us a  lagoon system probably should
not have been used at this site under these
conditions, but it was. It is a very poignant
reminder that most instances of ground-water
contamination have been discovered  only after
drinking water has been contaminated.
    The EPA recent report to Congress on waste
disposal practices effects on ground water (EPA,
1977a) offers some interesting insight into this
subject. Among other things it notes that:
    • Ground water has been contaminated on a local
basis in all parts of the nation and on a regional  basis in
some heavily industrialized areas, precluding the develop-
ment of water wells.
     • Degree of contamination ranges from a slight
degradation of natural quality to the presence of toxic
concentrations of such substances as heavy metals,
organic compounds, and radioactive materials.
     • Removing the source of contamination does not
clean up the aquifer once contaminated. The contamination
of an aquifer can rule out its usefulness as a drinking water
source for decades and possibly centuries.
     • Existing technology alone cannot guarantee that
soil attenuation alone will be sufficient to prevent
ground-water contamination from a waste disposal source.
     • Land disposal of waste is not environmentally
feasible in many areas.
     • Existing Federal and State programs address many
of the sources of potential contamination, but they do not
provide comprehensive protection of ground water.
     A review of EPA's Land Treatment Manual by
C. Winklehaus was carried in the Journal of the
Water Pollution Control Federation (1978). The
commentary in the review in large measure
summarizes some of my concerns on this treatment
alternative. Mr. Winkelhaus notes that there is a
tendency to overlook the fact that land treatment
systems, unlike "conventional systems," have
relatively open boundaries through which water
and solids can pass quite freely—once applied,
the waste water and pollutants are largely beyond
control. Can anyone assure us that the EPA policy
on land treatment as contained in the Adminis-
trator's memorandum of October 3, 1977 (Costle,
1977), and further amplified by the draft Program
Requirements Memorandum (EPA, 1978c) by
Mr. Cahill dated May 10, 1978, provides the
safeguards required to protect our ground-water
resources? In my opinion,'the answer is no.
     The Assistant Administrator for Water and
Hazardous Materials for EPA seems to have verified
these concerns in a statement (Jorling, 1978)
before the Committee on Environment and Public
Works of the U.S. Senate. In that statement he
said "concern for ground water has emerged
relatively recently as a major environmental issue.
There is a great deal yet to be learned about the fate
and transport of contaminants below the surface;
the practices that represent the greatest threat to
this national resource; and the economics of
alternative ways of disposing of wastes in a manner
more protective of the environment. Another
reason for proceeding carefully is the sheer number
of facilities that seem to have the potential for an
adverse impact on the quality of ground water.
Literally hundreds of thousands of wells, surface
impoundments, ditches  and landfills used by
industry, municipalities, farmers and other private
individuals are involved. Prudence dictates careful

preparation in designing programs to bring these
practices under control and in incurring the probable
social and economic costs involved."
     It is accepted knowledge that contaminants of
known and unknown character and concentrations
reside in all sewage effluents. The examples that
have been cited in this paper  certainly show that
sewage effluents  do percolate through the ground
to the  ground-water table. Contaminants in sewage
without a doubt  have public  health significance.
Little is known about the health significance of
trace levels of synthetic organic contaminants that
have been identified in the ground water under
some of the land treatment systems. The Adminis-
trator of EPA has publicly stated that the presence
of trace levels of synthetic organic chemicals in
drinking water may be hazardous to the health of
persons. Further, the EPA has proposed a treatment
standard for public water supplies so that these
contaminants can be reduced to the lowest
practicable level. If EPA's statements and actions
are to be taken seriously, why should anyone
promote a waste-water treatment practice that adds
even small increments of these contaminants to an
otherwise safe water supply?
     There is no  doubt in my mind that from
strictly a technological viewpoint we can design land
disposal systems  of many types that will dispose
of waste water, allow the production of agricultural
crops,  extend the development and use of pasture
land, provide for certain recreational pursuits and
establish bird sanctuarys, all  at a profit when only
measured by the flow of dollars into the cash
register. The overriding question is, where should
this be done; what quality of waste water should
be applied to the land; and what degree of degrada-
tion should be permitted in the quality of our
ground water? In the absence of more definitive
answers to these questions than those implied by
current EPA policy, I would  prefer the policy  I
understand is used by the British, i.e., only water
of drinking water quality should be  returned to
ground-water aquifers from which drinking water
will be extracted. Otherwise  we must admit that
we proceed in ignorance and we cannot be
surprised  at some future time when  reality tells
us the accident has happened.
American Water Well Association Research Foundation-
     Municipal Wastewater Reuse News. 1977. v. 3, p. 7,
     "Regulations and Legal Aspects." Denver, Colorado.
Costle, Douglas M. 1977. EPA policy on land treatment of
     municipal wastewater. Memorandum of October 3,
     1977 to Assistant Administrators, and Regional
     Administrators. Washington, D.C.
Geraghty and Miller, Inc. 1977. The prevalence of subsurface
     migration of hazardous chemical substances at
     selected industrial waste land disposal sites. Draft
     Final Report Prepared for U.S. EPA. Port Washington,
Jorling, Thomas C. 1978. Testimony before the Subcom-
     mittee on Environmental Pollution Committee on
     Environment and Public Works—United States Senate
     on July 18, 1978. Washington, D.C.
State of California. 1976. Report of the consulting panel
     on health aspects of wastewater reclamation for
     ground-water recharge. Joint Report of the State
     Water Resources Control Board, Department of Water
     Resources and the Department of Health. Berkeley,
U.S. Environmental Protection Agency. 1977a. Waste
     disposal practices and their effects on ground water.
     The Report to Congress. Washington, D.C.
U.S. Environmental Protection Agency. 1977b. Resource
     recovery and waste reduction. Fourth Report to
     Congress, Washington, D.C.
U.S. Environmental Protection Agency. 1977c. Preliminary
     survey of toxic pollutants at the Muskegon wastewater
     management systems. Ada, Oklahoma.
U.S. Environmental Protection Agency. 1978a. Long term
     effects of land application of domestic wastewater:
     Hollister, California, rapid infiltration site.  Washington,
U.S. Environmental Protection Agency. 1978b. Environ-
     mental changes from long-term land application of
     municipal effluents. Washington, D.C.
U.S. Environmental Protection Agency. 1978c. Construc-
     tion grants program requirements memorandum —
     revision of agency guideance for evaluation of land
     treatment alternatives. Washington, D.C.
U.S. Public Health Service Drinking Water Standards. 1962.
     Department of Health, Education and Welfare,
     Washington, D.C.
U.S. Public Health Service, Center for Disease Control-
     Morbidity and Mortality Weekly Report. 1978. v. 27,
     no. 22. Gastroenteritis associated with a sewage leak-
     Missouri, Arkansas. Atlanta, Georgia.
Winklehaus, C. 1978. Land treatment: a paper tiger? Journal
     Water Pollution  Control Federation. January, 1978.
     Washington, D.C.
              *       *       *       *

     Charles C. Johnson, Jr., Vice President of Malcolm
Pirnie,  Inc., and retired Assistant Surgeon General in the
U.S. Public Health Service, graduated from Purdue University
•which has designated him a Distinguished Engineering
Alumnus. He is a Diplomate in the American Academy of
Environmental Engineers, a licensed Professional Engineer,
Chairman of EPA 's National Drinking Water Advisory
Council, associated with EPA 's Management Advisory
Group  for the Construction Grants Program, and
recipient of the National Sanitation Foundation/National
Environmental Health Association 1977 Walter F. Snyder
Award of Achievement m Attaining Environmental Quality.
His 30years' environmental experience includes  positions
in federal and local government and in private industry.

Audience Response  to  Session  III  —  Land  Application  of Waste
Stephen A. Smith, 1423 S. College Ave., Tempe, AZ 85281:
The advantages of using the soil for the application and
treatment of wastes are well-known; however, although we
probably have the technology to design a fail-safe system,
we may not be able to afford it. Accidents can happen due
to improper design, inadequate maintenance, or a lack of a
complete understanding of the soil-water system.
      Ground-water zoning, and the delineation of areas of
possible, potential, or actual ground-water degradation, is a
possible solution to this dilemma. We can, in effect, have
our cake (land treatment) and be able to eat most of it (or
drink the water). By siting land treatment and disposal
facilities in areas designated as zones of potential degrada-
tion, we serve notice that a contamination potential exists,
and special measures are necessary to ensure the safety 6f
water supplies. For example,  development in the area
would have to be accompanied by public or community
water systems  with an outside source, or any wells drilled
in the zone would have to meet rigid requirements, with
sufficient casing and depth to seal off any contaminated
ground water due to the waste disposal facility (zones
could be three-dimensional).
      To a limited extent, the zoning concept is already
being applied.  In Wisconsin, bacteriological contamination
of ground water is a fact in a  few, scattered areas where
creviced dolomite is overlain by thin soils. In these areas,
which are  delineated on maps or described in terms of
section, township, and range, drillers have been notified
that they are required to emplace as much as 200 feet of
casing in order to seal off the upper, contaminated portion
of the aquifer. In other words, zones of actual ground-
water degradation have been defined, and measures have
been taken to ensure bacteriologically safe drinking water.
However, these are not areas where additional land disposal
facilities are encouraged; they would aggravate what is
already a bad situation.
      For planning future land treatment and/or disposal
systems and zones of potential degradation, we obviously
want to keep the zones small. Case histories of contamina-
tion incidents in  the literature document the difference in
the extent of contamination between incidents which have
taken place in recharge areas and those which have occurred
near discharge  areas. I suggest that we site our land treatment
and disposal facilities as near as possible to ground-water
discharge areas. This will accomplish some important
objectives. If an accident does happen (and Murphy's Law
says that it will), the actual zone of degradation is small,
and we won't waste valuable hydrogeologists' time tracking
a plume across a county (let the engineers track it down a
stream). In addition, if the facility is subsequently
modified to  correct the situation, the zone of contaminated
ground water will be renovated in a relatively short time.
      Mr. Sheaffer has suggested that we use floodplains
for the operation of land treatment systems. Provided
that a floodplain site can meet the criteria for soils and
ground water set forth in most State regulations, it would
be an excellent choice if we accept the discharge area
concept of degradation zoning. Obviously, floodplains
would be a poor choice for land disposal facilities such
as solid waste sites, for which adequate protection from
periodic flooding would be difficult and expensive to

David E. Lindorff, Assistant Geologist, Illinois State Geo-
logical Survey, 425A Natural Resources Bldg., Urbana,  IL
61801:  It is perhaps obvious that an important part of any
land application program is proper operation and
maintenance. No matter how well designed a land disposal
project may  be, serious problems can still develop from
lack of or improper maintenance and operation.  I have
visited a number of industrial spray irrigation facilities and
found that, frequently, they  are a low priority in terms of
maintenance. We, therefore, need to be aware of this
problem, not only for  land disposal of waste, but for other
types of waste disposal as well.

Elmer E. Jones, Jr., Agricultural Engineer, USDA, Beltsville
Agricultural  Research Center, Beltsville, MD 20705:
Kenneth Wright implied that on-site subsurface disposal
was not a satisfactory land  application technique. In the
last 10 years, tremendous advances have been made in
on-site disposal technology. Johannes Bouma and others
with Small Scale Waste Management Project at the
University of Wisconsin have made four major contributions
to the science of subsurface disposal, (1) Application of soil

moisture tensiometry to subsurface disposal system
evaluation; (2) Quantification of interface barrier resistance;
(3) Development of effluent purification criteria, and
(4) Development of innovative loading procedures to
improve purification, reduce interface barrier resistance,
and maintain or improve soil porosity.  While the Wisconsin
research has demonstrated that it is possible to design
systems for higher loading rates than recommended in the
Manual of Septic Tank Practice, I would recommend using
lower rates, in effect making the subsurface disposal system
an irrigation system to maximize utilization of water and
nutrients by vegetation. On-site disposal can be the most
economical and desirable land application  technique.
      Dr. Sheaffer placed considerable  emphasis on the use
of underdrain systems. There are sites where underdrainage
is essential to satisfactory performance; however, there are
other situations where increased ground-water recharge
should be a major factor in encouraging greater use of land
application. Some major rivers serving large metropolitan
areas are deficient in surface storage for low flow augmenta-
tion. Every home or building built will increase runoff and
reduce ground-water recharge. As development  proceeds
the rivers tend to become flashy, higher peak  discharges
and lower base flows. Land application of waste water to
increase ground-water storage can have two very beneficial
effects, reduction of waste-water discharge to the river
during critical low flow periods, and increased base flow
from ground water.

Robert D. Sinclair, Western Ground-Water Consultants,
St. Norbert, Manitoba, Canada:  In looking at this problem
as a hydrogeologist and as a sanitary engineer, I see it from
both sides. We are bound to have some sort of pollution.
      If we are looking at any kind of waste, we have the
problem of the sugar in the tea. You put the sugar in, and
we have a problem  trying to get it out again. I think this is
the big problem with a lot of the sewage we're trying to
put on the land. For example, heavy metals, if we look at
the plating industry, it would be much easier  and simpler
in a lot of cases to tackle the problem at the source
instead of trying to handle it after it is  in the  sewage
and diluted down a couple hundred thousand times. It
makes it impossible to get it out. I think we would be  better
spending our money in terms of looking at this  type of
alternative versus trying to figure out how much sludge or
sewage we can put  on the land and how much heavy metals
we can accept in a crop. It may be easier to just get the
problem out right at the start and avoid this whole mess
we've got into.
      In terms of adding stuff on the land we have to look
at what the land can do. What sort of crops are  we taking
off?  We're looking  at crops that pass through  the food
cycle, we're looking at crops that can be biodegraded, so
what kinds of things should we be looking at  putting back
on the ground as these alternatives. We're looking at food
processing waste for one. There are some problems maybe
with caustics in some of them but in general,  if we look at
waste like pulp and paper and food processing or even
human waste, we are looking at some materials that can
be recycled back on the land that don't have  the impact of
such things as heavy metals and plastics that we have in
industries. They can't be handled by the soil structure. It
may take them out but if they are not  biodegrading they
are just accumulating, and this problem with  time is
going to find itself 20 years down the road where we won't
be able to grow the crops. They look okay now but it may
be a problem in a few years.
      If we look at sewage treatment, basically it is one of
removing carbon. When we throw sewage in the river, we
are killing the fish and causing zones of pollution. So
we've gone  to removing carbon which eliminates this
problem. What's happening now is we don't remove too
much of the nutrients in terms of phosphorus and nitrogen,
and in some cases we find that  algae will just take that
nitrogen and phosphorus and put it right back in the stream.
So in  terms of sewage treatment, we haven't
done anything except transfer it down the stream a little
      I'll  give one example of what happened in Winnipeg.
There was a town that was on ground water for quite a
long time and could have continued it but the engineers
decided to go to river water. You can see it, and it's a lot
easier to use so they went to it. Now during low flows, the
water going into that plant was about 50-50 sewage/river
water which a lot of the people in town didn't think  was
too good. Now they are  finding during some tests there
may be problems with viruses.
      If we are looking at adding things into the environ-
ment  which we have to,  we can only add it into the water,
the air or the land and if we look at most of our waste,
they are either on the land or water; we have to be able to
integrate the two and have a managed system that will allow
acceptable use of the environment.

Virginia Jamison, Suntech Group, Marcus Hook, PA:
Sometimes  I feel as if I should have a very big inferiority
complex  because I work for a big, bad villainous oil company.
We have seven refineries in the  U.S. and Canada, and we
produce an awful lot of waste water and an awful lot of
sludge, and we have to get rid of that. We can't dump it  in
the oceans, or in the streams, or in the rivers. The govern-
ment  laws say we can't. We have to pay and it is an
expensive proposition to have it hauled away and then
incinerated. Then we've  got an air pollution problem.
      Dick  Raymond and I have spent the past ten years
trying to convince our company that there is a safe way  to
get rid of this waste and it is land application. I think we've
convinced our company of this and they are doing
something about it. We are what we call "biofarming." We
are applying our waste on the land and getting rid of it. I
think we meet all of Dr. Sheaffer's criteria.
      In the first place we don't have a storage problem
because our crop doesn't cease in the winter. Our
crop is bacteria and they biodegrade in the winter as well
as in the summer. I don't think that, as Dr. Johnson  says,
"we're an accident about to happen," because we have
very strict,  stringent regulations and we monitor these
land applications. If we monitor them correctly and put on
the proper  amounts of material, there is no reason why we
will contaminate ground water. We have been doing this for
five years now and we are not the only company. Most of
the oil companies are using land farming. We feel as if it  is an
economical process; therefore, our company is happy. We
feel that  it's a natural process; therefore, we meet govern-
ment regulations and it is a very safe process.
      I hope that our government doesn't outlaw land
farming.  If it does, the oil companies have spent an awful
lot of time  and money in perfecting this process for nothing.

The  Federal  Ground-Water  Protection
Program  —   A  Reviewa
by Victor J. Kimm
     The Nation's ground-water resources constitute a vast
and often unprotected resource. The Environmental
Protection Agency is about to launch a number of programs
designed to protect what is, in many cases, a virtually non-
renewable resource. Separate regulatory activities mandated
under the Safe Drinking Water Act, the Resource Conserva-
tion and Recovery Act and the Clean Water Act must be
carefully coordinated if they are to be effective.
     The current implementation efforts within the
agency are being framed in view of our major principles
which will be the focus of public comment in the months
ahead. These principles are:
     First, the administration of the related programs will
be a cooperative effort involving Federal, State and local
governments, all of which must participate in formulating
the program if it is to be effective.
     Second, the focus of the programs will be on the
prevention of contamination rather than on its treatment
at the point of withdrawal.
     Third, the applicable standards will be based primarily
on technology rather than ambient ground-water quality
considerations since the effects of discharges upon ambient
quality are complex, difficult to predict, and of long
     Fourth, there is a need to balance environmental
protection, energy development and continued economic
prosperity objectives so that the resulting programs fully
      Presented at The Fourth National Ground Water
Quality Symposium, Minneapolis, Minnesota, September
20-22, 1978.
     t>Deputy Assistant Administrator for Drinking Water,
U.S. Environmental Protection Agency, 401 M St. SW,
Washington, D.C. 20460.
protect public health while being realistically implementable.
     All of us—government, industry and citizens, through
acts of commission or omission—have contributed to the
potential problem. We must work together if we are to get
on with the important task of protecting the quality of
the Nation's ground-water resources.

     The topic I have been asked to address is the
Federal Program for protecting ground water,  and
whether it is a matter for rejoicing or concern. I
suppose in these days of Proposition 13, the easy
answer is that any new or developing  Federal effort
is to be  regarded with some suspicion. I do not
share this view.
     Historically, our society has chosen to approach
environmental problems in the context of a national
partnership. This partnership involves not only the
Federal, State and local governments, but through
the mechanisms of advisory councils and public
participation, interest groups and the general public
as well.  Personally, I think this partnership is crucial
to the success of environmental efforts. In
drinking-water programs we have tried hard to
make it work.
     Our expectations about the future of the
effort to protect ground water must be assessed
in the context of a national partnership. And the
real answer is to be found in Pogo's immortal
observation that: "We have  met the enemy and
he is us." All of us—governments, interest groups
and citizens—have a part to play. The success or
failure of the national program will be a function
of the manner in which all of us meet our

     How then do we in EPA view our part in the
national program at this time?
     Admittedly, EPA's efforts to protect ground
water are still in the developmental stage. One focus
for our efforts has been the development of certain
basic principles which will guide our participation.
The first among these I have already touched upon:
a true partnership between the States and the Feds
and between government  and the public it serves.
     With regard to the former, it is EPA's policy
to consult extensively with States during the
development of any regulations and this will
certainly continue to be the case for ground-water
protection. Furthermore, the Federal legislation
either provides exclusively for State programs
[e.g., the control of open dumps under the Resource
Conservation and Recovery Act (RCRA)]  or for
primary State responsibility in the administration
and enforcement of programs [e.g., the Underground
Injection Control (UIC)]  program under the Safe
Drinking Water Act. Generally, EPA would prefer
the States to retain the lead in managing ground
water. The Agency's role  will be to: (1) establish
minimum quality and program requirements to
insure national consistency; (2) provide technical
and financial assistance to the States; and (3) review
State progress and performance. In establishing
requirements, EPA will strive to minimize any
disruption of programs the States are already
enforcing. We will assume direct responsibility for
administration and enforcement of programs only
in cases where the States fail to meet minimum
national standards.
     With regard to full public participation, the
Agency has recently proposed new regulations on
the subject and we will insist that States observe the
requirements established therein.
     A second principle that will  guide our approach
to ground water is that protection must rely on
the prevention of contamination rather than on its
abatement. Unlike flowing surface water, ground
water does not readily cleanse itself. Once a
contaminant is in the ground, it may be years before
it reaches an aquifer and then  may contaminate
that aquifer for many more years. Remedial action
(e.g., the excavation of the contaminated soil) is
often impractical. Further, due to the slow move-
ment of water in an aquifer, usually measured in
feet per month or even per year, it may take
decades or even centuries for natural processes to
"flush" an aquifer of contaminants.
     Drinking water taken from underground
sources in most instances received little treatment
prior to use. Sophisticated treatment for individual
users or small systems, which constitute the bulk
of ground-water consumers is prohibitively
expensive. As a practical matter, the abandonment
of the contaminated source is often the only
choice. The switch to an alternative source of
water supply is both disruptive and costly, and
will become increasingly so in the future. Such
considerations argue for a strong policy of
     The third principle governing our approach is
a corollary to the concept of prevention. It is a
reliance on technology-based standards or the  use
of sound engineering practices in the siting,
construction, operation, closure and abandonment
of facilities that have the potential for adversely
affecting the quality of ground water. This is not to
say that ambient water quality standards for ground
water are not important because they are. However,
one of the lessons we learned from earlier efforts to
clean up the Nation's navigable waters is that the
business of proving, in a court of law, the linkage
between a specific discharge and a measured
degradation  in ambient quality is very difficult.
This is doubly true for ground water where less is
known about ambient quality, monitoring is
costly and haphazard, and cause and effect may
be separated by years and miles. Furthermore, the
dearth of reliable knowledge about the fate and
transport of contaminants below the ground make
it virtually impossible to express discharge limits
in terms of maximum concentration levels.
     A. fourth principle guiding our efforts is the
need for balance. Ground water is a major resource
that must be protected through the prevention of
     At the  same time, many of the practices that
contribute to the degradation of ground-water
quality are associated with activities that serve other
national objectives. Extractive processes, for
example, oil or uranium recovery, are activities
that are essential to the economic well-being of the
country. Our technological society will, for the
foreseeable future, continue to produce a large
variety and volume of waste products which must
go somewhere.
     Disposal practices need not have unacceptable
environmental consequences. The land application
of sludges low in potentially toxic substances  can
have important benefits for soil conditioning.
Other practices, for example, deep well injection,
may in fact be the most cost-effective and

 environmentally acceptable alternative for the
 disposal of some wastes. The land treatment of
 sewage can be used to maintain quantity and
 quality in the water-table aquifer and can thus
 have an environmentally beneficial impact.
     The point is that the appropriate policy
 is to strike a balance among competing national
 objectives. Many practices serving other objectives
 can be carried on with little adverse impact on the
 environment  if they are located, designed,
 constructed, and operated according to known
 ecological and engineering practices.
     I might add that we have been developing
 Agency-wide  consensus around these principles
 through the mechanism of a policy statement. We
 hope to publish this statement in the Federal
 Register for general comment in the near future.
     Let me now turn to the second area of EPA
priority as we develop our role in the national
effort to protect ground water: coordination among
authorities under our jurisdiction.
     As you all know, there is no single Federal law
nor a single Federal agency that comprehensively
addresses the protection of ground water from every
form of contamination or mismanagement. At the
same time, a number of sections in six Federal
laws [the National  Environmental Policy Act
(NEPA), the Safe Drinking Water Act (SDWA), the
Resource Conservation and Recovery Act (RCRA),
the Clean Water Act (CWA), the Toxic Substances
Control Act (TSCA), and  the Federal Insecticide,
Fungicide, and Rodenticide Act (FIFRA)]  are
related to  or can impact ground water.  These laws
variously mandate  the control of: (1) certain
hazardous or toxic substances; (2) certain actions
such as the manufacture or transport of toxic or
hazardous substances; or (3) certain physical
facilities such as injection wells or open dumps.
The significant requirements in Federal
legislation that bear directly on the protection
of ground water include:

     • The requirement to consider the effects of
Federal action on ground  water as part of the
Environmental Impact Statements mandated by
     • The mandate to promulgate minimum
requirements for State programs to protect existing
and potential underground sources of drinking water
from endangerment from  well injection under Sec.
1421 of SDWA.
     • The authority to designate an aquifer as the
sole or principal source of drinking water for an
area and to deny Federal financial assistance to a
project that may endanger the aquifer so as to
create a significant threat to public health under
Sec. 1424(e)of SDWA.
     • The authority to undertake a national
assessment of surface impoundments (pits, ponds,
and lagoons) and their potential for contaminating
ground water under the SDWA.

     • The authority to support State plans for the
control of solid waste facilities under Sec. 4004 of
     • The requirement to promulgate regulations
for State or Federal programs to control the
surface or subsurface disposal of wastes defined as
hazardous under Sec. 3001 of RCRA.

     • The authorities to regulate the entry into
the market place, use of, and the ultimate disposal
of substances defined as toxic under TSCA.
     • The authority to require and support through
grants the development and implementation of
State  comprehensive water quality management
plans  under Sees. 106 and 208 of CWA.

     In my view, there is no need for more
Federal legislation. Under one section or another,
EPA has more than enough authority to initiate
an effective Federal role in what must be a national
effort to protect ground water. The challenge that
faces  the Agency is to marshal these authorities in
a coherent fashion that reduces confusion and
burdensome overlaps on the one hand, and
minimizes major gaps in coverage on the other.
We are moving to meet this challenge in a number
of ways.
    First,  EPA intends to require the phased
implementation of State/EPA agreements. These
agreements, to be concluded annually between the
State  and the  cognizant Regional Administrator,
are to: (1) identify the State's environmental
problems related to surface waters, ground waters
and solid waste disposal; (2) specify the priority
problems the State intends to address in that year
and the actions it intends to take; and (3) relates
EPA's technical and financial support activities to
the State plan. While the inclusion of program areas
will be phased over FY 1979-81, the eventual
goal is a fully  integrated attack on related
environmental problems.
    Second,  we are reaching agreement on
the definitional framework to be used by all

EPA administrated programs that address ground
water. This framework involves the three
questions that are basic to any effort to protect
ground water.
     The first question is: What is the resource that
is to be protected? I expect that EPA regulations
for the UIC program and the open dumps inventory
will require States to inventory their aquifers and
to designate them for various uses. All current
underground  sources of drinking water and all
aquifers that contain water with less than 10,000
parts per million of total dissolved solids (ppm/TDS)
are to be designated as sources of drinking water.
In the case  of aquifers or portions of aquifers that
do not already serve as drinking-water sources,
exceptions  can be made to this general rule if:

     • The  aquifer or its portion is located  in such
a fashion that the mining of water would be
technically  or economically impractical.
     • The  aquifer is already contaminated so as
to make the treatment of the water for drinking
purposes technically or economically impractical.

     • The  aquifer is oil or mineral producing.
     • The  aquifer or its portion has not been
protected in the past and adequate alternative
supplies of  drinking water are available through
the year 2000.

These exceptions would be subject to public
hearings, EPA review, and a demonstration that
the aquifer  is  sufficiently isolated so that other
surface or ground waters would not be
     In addition, an aquifer or a portion thereof
that  is not designated as a source of drinking
water may be designated by the State for other
uses. Such aquifers would be protected to a level
commensurate with the designated uses.
     The second question is: How is "endangerment"
to be defined? Here the Agency is fashioning a
protective,  yet reasonable approach. Ground-water
regulations under both RCRA and SDWA will
define "endangerment" to occur if the activity in
question has failed to meet technology standards
or may cause:

     • an existing or potential user of the ground
water to violate any drinking-water standard.
     • an existing or potential user of the ground
water to treat the water more than he otherwise
would have had to.

     • other adverse effects on human health.
     The final question is: Where is endangerment
to be measured? We have considered various possible
approaches such as mathematical modeling, fixed
distances, the property boundary and combinations
of some or all of these. Our conclusion is that the
contamination pathways are different for the
various practices of concern and no single
approach is appropriate to all of them. A zone of
endangerment can, for example, be hypothesized
for well injection. Percolation from the surface,
however, behaves differently.
     Consequently, EPA's current policy is to
encourage monitoring at several distances from
the potentially endangering activity. The point
at which endangerment will be considered to
have occurred will be defined in a manner appropri-
ate to the particular type of practice.
     A third area where EPA is attempting to
ensure the coherent use of Federal legislation to
protect ground water is in the coordinated
development of regulations. For example, an
Agency-wide Implementing Task Force is charged
with the responsibility of drafting the regulations
to implement the hazardous waste provisions of
RCRA. A number of policy directions are emerging
from the coordinated  approach to the development
of regulations, including the following:
     • The control of toxic and hazardous industrial
process wastes continues to be one of the Agency's
highest priorities. EPA is attempting to establish
a single set of procedures for granting Federal
permits under RCRA, SDWA, and NPDES.
Eventually, we hope to develop a fully integrated
"one stop" EPA permits program.
     • The open dumps inventory under RCRA
will be phased over several years. The Surface
Impoundments Assessment will, among other uses,
serve as a "screen" to  define priority areas for
future phases of the open dumps inventory.
     A. fourth area of coordination is between
operating and support programs. The Office of
Drinking Water and the Office of Research and
Development are participating in a pilot project
designed to make EPA's research efforts more
directly responsive to  program office needs. A
Steering Committee has been mapping the research
effort for fiscal years  1979 and 1980 and will
continue to supervise  the progress of the crucial

     Much of what I have sketched here is cast in
developmental terms.  It would be easy to  conclude

that all that is really happening is that a bunch of
Washington bureaucrats are appointing task forces,
holding meetings and writing memoranda of
understanding of greater relevance to their own
concerns than to the reality of protecting a vital
national resource.
     Some of that, I suppose, is true. However, I
think we are making real progress and you will see
the results in the accelerating pace of EPA
activities in the months ahead. I say this because
I think we have learned from the past and are
developing an integrated ground-water protection
     The pollution control dimensions of this effort
are underway. The remaining challenge is the
coordination of the various Federal agencies and
authorities with their State counterparts. Efficient
integration and cooperation among the govern-
mental actors at all levels is a prerequisite  to an
effective national program to safeguard our ground-
water resources. This calls for patient, open-minded,
intelligent planning on all sides.
     Most of all, it calls for the active participation
of all involved: the public at large, American
industry, and the engineering and geohydrology
professions, as well as agencies of government.
For the Federal Ground-Water Protection Program—
my topic for today—is not a thing apart; it can
function only in the context of interaction with all
 Appendix I. Status Report on State Primacy for Public
          Water System Supervision Program
Following States Have Assumed Primacy on the Indicated
 6. Alabama
 7. Arkansas
 9.New York
10. Virginia
14.S. Carolina
Following States Are Found to be Qualified for Primacy
Pending Notice in the Federal Register:
 I.Rhode Island
2 I.Maryland
22. North Dakota
23. Florida
2 5. Nevada
26. Kansas
28. Idaho
30. New Mexico
3 I.Delaware
32. West Virginia
3 3. Colorado
34. California
3 5. New Hampshire
3 6. Trust Terr.
37. Guam
39. Arizona


 the other forces of our society that have a bearing
 on how we use our environment, how we manage and
 preserve our natural resources. The issues engage us
 all. I urge you to join the debate, letting your
 voices be heard in the common cause of
 preserving for ourselves and children the vital
 treasure of our Nation's ground water.
      Victor Kimm is responsible for EPA 's program to
 ensure the quality of the Nation's drinking water. He joined
 EPA in 1971, and was Deputy Director of the Office of
 Planning and Evaluation prior to assuming his present
 position in 1975.
      Prior to joining EPA, Kimm worked on economic
 development programs in the United States and Latin
 America. He also spent six years with consulting engineering
 firms engaged in the planning, design and construction of
 water supply and sewage treatment facilities.
      Kimm is a licensed professional engineer in New York
 and Pennsylvania. He holds a Bachelor's and Master's degree
 in Civil Engineering from Manhattan College and NYU. As a
 recipient of a National Institute of Public Affairs Fellow-
 ship, he spent the 1969-1970 academic year at Princeton
 University studying economics and public administration.
      Appendix II. States Designated as Requiring an
         Underground Injection Control Program
      New York
West Virginia
New Mexico
      Appendix III. Listing of Studies Mandated by
             The Safe Drinking Water Act
     • Report to Congress—Preliminary Assessment of
Suspected Carcinogens in Drinking Water in December 1975.
     • Impact on  Underground Sources of Application of
Pesticides and Fertilizers in 1976.
     • Report to Congress—Waste Disposal Practices and
Their Effects on Ground Water in January 1977.
     • Drinking Water and Health, a study of the National
Academy of Sciences, in June 1977.
     • Impact of Abandoned Wells on Ground Water in
August 1977.
     • Underground Injection Methods Which Do Not
Endanger Underground Water Sources in December 1977.
     • Surface Impoundments and Their Effects on Ground-
Water Quality in the United States—A Preliminary Survey
in August 1978.
     • Identification of Potential Contaminants of Under-
ground-Water Sources from Land Spills in August 1978.

The  Federal  Ground-Water  Protection
Program  —  Today's  Hopea
by Charles W. Sever
     The necessary administrative mechanisms for protec-
tion of our underground drinking water sources, and
coordination of natural resource and energy development
and environmental quality programs, should be provided
by a federal ground-water control program, else today's
underground contaminant disposal activities will be
tomorrow's undoing. Federal regulations, however, must
provide flexibility to States and industry to find the least
costly means of meeting national environmental goals.
     A growing body of literature clearly documents cases
of underground drinking water source contamination,
sometimes severe, from a large variety of conditions and
practices. Existing studies also indicate that this problem
is pervasive: aquifers have been adversely  affected in
every region of the country.
     A federal ground-water protection program which
(1) reflects consideration of total long-range natural
resource protection and environmental quality benefits,
(2) regulates in a manner so that the benefits to the
environment generally exceed the regulatory costs and
(3) encourages more efficient ways of meeting
environmental goals in the least costly manner can and  must
be developed by the Environmental Protection Agency.
Without an effective Federal ground-water protection
program, the underground contamination problem will
likely worsen.
      Presented at The Fourth National Ground Water
Quality Symposium, Minneapolis, Minnesota, September
20-22, 1978.
     bchief, Water Supply Branch, U.S. Environmental
Protection Agency, 1201 Elm St., First International Bldg.
Dallas, Texas 75270.
     Before we start a discussion on why federal
regulations are needed, let us first agree that the
problem of unsafe drinking water should be
primarily the concern of State and local govern-
ments but that the federal government also has
the responsibility to insure the safety of the water
that citizens drink.
     Let us further agree that State agencies and
citizens can best determine whether a need exists
to regulate sources of pollution that may
contaminate underground sources of drinking water,
which directions to take in developing regulations,
and which needs are crucial for protecting these
     Therefore, would it not be better to rely upon
the States themselves for the evaluation of need
and the direction of emphasis in the federal
regulatory process? To evaluate the need for a
federal ground-water protection program, we need
to first look to existing State ground-water programs.
     All States have encountered serious problems
because of failure to use available geologic informa-
tion and accepted and proven engineering practices
in design and completion of injection wells, pits,
ponds, lagoons, and the like.
     All of the  50 States have established some
type of State regulatory programs concerning
ground water. Thus, the need for regulation of
underground injection practices is clearly recognized
by the State and local people nationwide.
     A growing body of literature clearly documents
cases of underground drinking water soui ce con-

tamination, sometimes severe, from a large variety
of conditions and practices. Existing studies also
indicate that this problem is pervasive: aquifers have
been adversely affected in every region of the
country. Without appropriate federal ground-water
protection regulations, the ground-water contamina-
tion problem will likely worsen.
     For me, and I am sure for most of you,
personal experience is the authority that I used for
determining whether existing State programs are
adequate or whether federal presence is indeed
needed. During the last ten years or so, I have
either observed or been personally involved with
numerous ground-water contamination situations
in States that thought they had adequate ground-
water protection laws. These included Miami,
Florida, where raw blood from an abattoir was
being injected through an unregulated well
directly into porous limestone of the Biscayne
Aquifer which is the principal source of drinking
water for the entire city of Miami.
     In Camilla, Georgia, creosote,  phenyls, and
other organics were being injected through wells
into the principal artesian limestone aquifer which
supplies drinking water for all of south Georgia and
north Florida including the city of Camilla. An
estimated 20,000 of these unregulated wells are in
use in the Georgia-Florida area today.
     Each of you who have worked in ground water
in the field have yourselves observed similar types
of direct ground-water pollution.
     But pollution is not restricted to injection
into a drinking water aquifer. For example, at
Wilmington, North Carolina, a 1,000-feet deep
industrial injection well failed because fiberglass
casing was fractured during construction and the
acids being injected ate their way through the
cement lining on the outside of the casing.  In
southern New Mexico there is a case of brines
injected for secondary recovery which escaped
through fractures which opened up during high
pressure injection operations and contaminated
ground water at the surface. A similar incident
occurred in southern Oklahoma.
    But, in discussing cases of contamination, we
certainly do not want to leave out pits, ponds and
lagoons. At Pensacola, Florida, nitric acid that was
discharged from a fertilizer plant into a pit on the
southeast part of town percolated downward into a
sand aquifer then moved laterally and contaminated
several of the city's municipal water-supply wells.
    At Miami, organics from a nearby landfill have
ruined their Preston well field. There is inadequate
time to discuss with you today the number of times
I have investigated salt-water contamination and
traced it back to "abandoned" brine disposal pits
associated with oil and gas production.
     My personal experience has convinced me that
numerous independent ground-water contamination
problems have been observed by most of us. Surely
we can all agree that further contamination of our
existing or potential drinking water sources should
not be permitted if there is any reasonable likelihood
that these sources will be needed in the future to
meet the public demand for drinking water and that
these sources may be used for such purposes in the
     The necessary administrative mechanisms for
the protection of our underground drinking water
sources, reduced property damage, coordination of
natural resource and energy development and
environmental quality programs, should be provided
by a federal ground-water control program, else
today's underground injection and contaminant
disposal activities will be tomorrow's undoing. But
these federal regulations must provide flexibility
 o States and industries to find and implement the
least costly means of meeting national environmental
     Congress recognized the need for "federal
presence" in the area of ground-water protection
and indicated that it would be beneficial from the
aspects of enhancing State enforcement authority,
facilitating public acceptance of a State program,
and insuring consistent performance from the
States. Federal presence would also provide technical
assistance to State programs and  emergency response
capabilities, and would broaden the State's jurisdic-
tion to include federal lands and  facilities within
their boundaries.
     In establishing an underground injection
control program, as mandated by Congress in the
Safe Drinking Water Act, EPA has looked to the
States which had a high dependency on ground
water to determine what measures these States
felt they needed to ensure ground-water
protection. Using the programs of the States such
as Texas, Oklahoma and Louisiana as a model,
EPA hopes to develop federal regulations which
closely match the requirements felt to be necessary
in States with a long experience in underground
protection regulations. In other words, EPA has
followed the lead of the States in determining the
need for a standardization of regulations to
alleviate any problems arising from the use of
interstate aquifers and for more effective manage-
ment and control of well systems.
     EPA has been a leader in destroying the

barriers that in prior times prevented the exchange
of knowledge and ideas from all sources available.
We have been fortunate in developing the UIC
regulations to have had such a wealth of knowledge
from such diverse sources. We have come to
understand the viewpoints and the concerns of the
States, of industry and others. And, through
understanding, EPA has, over a period of time,
altered its thinking on the content of its regulations.
     Whether significant pollution of an aquifer
has, or has not, occurred, should not be the point.
Federal programs to  protect aquifers and the
incorporation of ground-water concerns in related
programs are appropriate: for efforts of a regulatory
nature need not necessarily be of a reactionary
nature. The goal should be to prevent contamination
in the first place, rather than to attack problems
that could have been avoided properly with
reasonable controls.  A federal ground-water
protection program which (1) reflects consideration
of total long-range natural resource protection  and
environmental quality benefits, (2) regulates in a
manner so that the benefits to the environment
exceed the regulatory costs, and (3) encourages
more efficient ways of meeting environmental goals
in the least costly manner, can and must be
developed by the Environmental Protection Agency
to protect our ground-water resources. Without an
effective federal ground-water protection program,
the underground contamination problem will
likely worsen.
     But let's also all agree that the federal govern-
ment should propose no regulations for controlling
subsurface implacement of fluids that (1) do not
protect the nation's drinking water resources,
(2) do not protect public health and welfare to the
maximum extent feasible, and (3) unnecessarily
interfere with or impede development or production
of the  nation's mineral and energy resources.
     Charles W. Sever was born in Miami, Florida in January
1931. His undergraduate work was a combination of Physics
at Georgia Institute of Technology and Geology at Emory
University, both in Atlanta, Georgia, He worked as a Geo-
physicist with the Ground Water Branch of the U.S.G.S. for
7 years from 1958 to 1966, worked as a consultant for his
own company on water resource development and sub-
surface disposal for 5 years; then worked as regional expert
on subsurface disposal with the U.S. EPA in Atlanta for
3 years. For the past 3 years he has worked as Chief of the
Water Supply Branch for EPA in Dallas, Texas. He has]
published numerous books and journal articles on subjects
related to ground-water resources protection.

The  Federal  Ground-Water  Protection
Program   —  Tomorrow's  Undoinga
by Dale C. Mosher'
     Past and present guidance in landfilling has been based
on inadequate information. More recent information
indicates past and present recommendations/guidance may
not be accurate. Current trends, as a result of RCRA
(PL 94-580), are generally following the same recom-
mendations. The result can be greater problems from
landfills constructed now and in future years than have
occurred from past landfills, such as the well-known
Llangollen landfill. It is time for Congress, EPA, and others
to recognize what is and is not known about the pollution
potential from landfills and waste disposal, in general.

     The first thing necessary in discussing the
inadequacy of Federal ground-water pollution
protection programs is to put the question in
proper perspective. Today's Federal ground-water
protection program covered by sections  of the
Clean Water Act, Safe Drinking Water Act, etc. are
inappropriate for "solid waste." For example, under
the Safe Drinking Water Act  the Underground
Injection Program covers only deep well injection.
Other acts cover specific toxic substances. Pits,
ponds, landfills, landspreading, etc. are still today,
however, virtually not covered except by a few
State programs in general.
     Presented at The Fourth National Ground Water
Quality Symposium, Minneapolis, Minnesota, September
20-22, 1978.
     ^Director of Research Programs, Wehran Engineering,
666 E. Main St., Middletown, New York 10940.
     It may be presumed that such State programs
are inadequate because Congress passed the Resource
Conservation and Recovery Act (RCRA, PL 94-580).
This act provides for total control of all waste
disposal in or on the land. Essentially, Congress
found that waste disposal "in or on the land ....
can present a danger to human health and the
     The most appropriate question is will the
regulations promulgated by EPA as required by
RCRA be adequate?
     The RCRA requires all wastes to be disposed
of in sanitary landfills which will be defined by
the EPA. The act also requires EPA to develop
guidelines providing a technical and economic
description of the level of performance that can be
attained by various waste management practices.
It is this latter requirement (the level of
performance) which is difficult to meet due to the
inadequacies of regulations developed. A brief
examination of the history of sanitary landfilling is

               PAST HISTORY
     Landfilling of waste material received limited
study until the 1950's. Since that time, significant
changes have occurred in the philosophy and
practices deemed acceptable from the standpoint
of ground-water quality.
     A report published in 1954(1) indicated that
keeping waste materials out of the water table would
alleviate ground-water contamination problems.
This concept apparently prevailed until 1961 when

another California publication (2) indicated that
percolate (leachate) from rainfall or irrigation
water infiltrating the landfill could cause impair-
ment of ground-water quality. This represents a
major change and reversal in concepts concerning
protection of ground-water quality from waste
disposal. A 1969 report(3) indicated that leachate
could be prevented by placing an impermeable cap
over the completed landfill. There is no
question that leachate can be prevented if an
impermeable cap is used if that is the only source
of leachate entry into the landfill.
     The next major publication, Sanitary Landfill
Design and Operation^) addressed the major
potential environmental problems associated with
waste disposal. This report requires further evalua-
     The report states on page 4 that "Some investi-
gators believe that even in a sanitary landfill,
leachate production is inevitable and that some
leachate will eventually enter surface water or
ground water." It even stated further in the same
paragraph that "the present philosophy held by
the Office of Solid Waste Management Programs,
most States .... is that through sound engineering
and design, leachate .... may be prevented or
minimized to the extent that it will not be a
problem. The most obvious means of controlling
leachate production and movement is to prevent
waste from entering the landfill to the greatest
extent practicable " (italics for emphasis by the
     While the latter statement indicates in the
least that some sanitary landfills will produce some
leachate, the prevailing concept was that due to
sound engineering design and operation, leachate
was not a problem at sanitary landfills.
     Those involved with the many discussions
concerning review of a paper published in Waste
Age(5) are well aware of the numerous experts who
felt that sanitary landfills did not generate leachate.
     Since that time, it is now generally recognized
and accepted that sanitary landfills do generate
leachate. The Waste Age paper(5) further states
that where attenuation is ineffective, leachate
collection and treatment should be employed.
There was, however, no guidance as to how to
determine where attenuation would  be effective.
Further, no guidance is available as to whether
minimization to the greatest extent practicable is
adequate. This constitutes one of the major
problems RCRA regulations face.
     Probably the greatest single reason such
predictive capabilities have not been developed
is reflected in the limited budget that solid waste
programs have had. Such research work done on an
excalated scale could easily cost several million
dollars per year. Over the past few years, the EPA
solid waste programs have barely spent one million
per year, and this has been split too far between
many aspects of the problem. The second largest
contributor to inadequate information has been
the length of such programs.
     The EPA's prior research on waste-water
treatment has been of a highly  structured engineer-
ing nature lending themselves to short-term (1 to 3
years) investigation. Waste disposal, however, takes
place in the natural environment where there are
numerous variables and many are interrelated. In
such an environment, research  must have adequate
replication enabling the researchers to factor out
influence of individual parameters. In this manner,
it is then possible to  discern those factors most
responsible for observed variability.
     A third reason for limited development is the
nature of the system. Essentially, Congress required
the EPA in the early  seventies to publish guidelines
relating to safe land disposal practices. The
environmental groups pushed for rapid development
of such guidelines. Based on best available although
limited data, the EPA issued Thermal Processing
and Land Disposal of Solid Waste Guidelines in
     The problem is  solved! At least the problem is
solved in the minds of Congress and high level EPA
management. However, at  the program level EPA
apparently recognized during development of the
Guidelines that the problem was not  solved. From
1973 through  1975,  the Office of Solid Waste
Management Programs has spent man-hours
evaluating the potential for ground-water con-
tamination and studying available data on real
world cases. Many hours were spent in developing
in-house show and tell programs to "sell" the need
for funds for further investigation. Funds for the
first study of existing sites was not available until
1975 and  then only in very limited quantities.
The  first monitoring program covered 10 sites
taking 5 samples over a 7 to 9 months' period of
time at a cost  of about $300,000 including EPA
personnel time. The  second study of  hazardous
waste disposal sites included investigation of
numerous sites with  existing data and 50 sites
actually drilled and sampled. However, only  one
sample was taken from most sites.
     Of these  two studies, the  former of
municipals' solid waste only site provided the most
useful information. All sites evidenced some level

of contamination and demonstrated that even
"sanitary landfills" can contaminate ground water.
The most significant result of that study was that
operation, soils, and design were of no value in
explaining differences in the levels of contamina-
tion found. In short, some of the "best" sites
studied were among those with the highest levels
of contamination found. In most cases, the level
of contaminants found did not suggest that
widespread serious problems exist from municipal
solid waste disposal practices.

     The prevalent current philosophy is that mini-
mizing leachate quantity lessens impact on ground
water. This must assume that less quantity means less
pollutants. It seems, however, that many experrc
subscribe to the theory that minimizing leachate
production maximizes contaminant concentration.
Again, however, by assumption it is assumed that
pollutant loading is minimized. It is quite  possible
that this assumption is false. The amount  of
percolation and ultimate leachate production is a
function over soil conditions and rainfall intensity.
Increasing slope and decreasing permeability will,
in general, decrease the quantity of leachate formed
from any given rain storm event. The key  is event.
The quantity of pollutants leached and, hence,
leachate  quality is a function of the solubilization
rate within the landfill between  events. As a first
cut, it may be safe to assume that the rate of
pollutants' solubilization within the landfill is
constant (after a period of time), since under these
conditions the landfill with less leachate would have
higher pollutant concentrations. Both landfills,
however, are leaching the same quantity of
     At this point it is the responsibility of the
underlying unsaturated soil material to attenuate
the respective leachates. The question is which
leachate  poses the greatest risk to the underlying
ground waters.

    Without going into great elaborate detail or
using a myriad of equations, simply stated water
movement (permeability) in unsaturated soils is
greater than for saturated soils. Further, since
leachate is formed in small quantities and  moves,
as the result of discrete rainfall events, leachate will
generally move as discrete quantities without
respect to actual quantity produced at any given
    If we assume that all attenuating mechanisms
are rate functions (except infiltration), the actual
amount of attenuation will be a function of rate
of water movement, thickness of the unsaturated
zone and rate function of attenuation. Note that
quantity of leachate at any given time is not
included in this evaluation. It is, therefore,
reasonable to assume that the leachate with the
higher concentration will receive less attenuation
and, therefore, will have a greater impact on
ground-water quality. In short, under the above
circumstances, minimizing leachate will have a
greater impact on ground water.

              THE REAL WORLD
     In reality, the situation is somewhat more
complicated. Although significant bodies of data
do not exist to support the previous conclusion,
the writer has not seen any evidence in support of
the opposite  view. The only firm conclusion is
that current technology indeed does not allow
prediction of leachate impact on ground water.
This would strongly suggest that EPA cannot issue
regulations under PL 94-580 which are based on
technology. To do so would result in landfill
practices not acceptable in other locations.
     All, however, is not gloomy. In spite of the
number of impressive cases of ground-water
contamination, that number represents a small
portion of the total number of land disposal sites
in existence. An examination  of ground-water data
from States' files will most likely show some
contamination of water quality at all sites, but
generally to a limited extent.

     If the relationship between leachate quantity
and ground-water pollution potential as described
are correct today, federally recommended
procedures are incorrect. This will result in more
landfills started within the past 10 years to start
showing greater problems than the open burning
dumps of the past within  the next 10 years. We
must keep in  mind that problems which are a long
time in appearing may be with us essentially
     If regulations are based on technology's
practices rather than performance standard, the
result may well be greater contamination problems
in the future.
     A thorough review of existing ground-water
quality problems at disposal sites at this time would
greatly enhance the state-of-the-art. While the task is
monumental, it is feasible and perhaps the only way
to properly determine the basis for and form  of

regulations promulgated under the Resource
Conservation and Recovery Act.
     Several groups are now suing EPA for not
issuing regulations as required by Congress. The
basis of these suits is  that EPA has failed to
promulgate regulations as required by Congress.
It would seem logical to assume that for the most
part such suits would be aimed at getting required
regulations promulgated at the earliest possible
date. In view of the preceding information, that
may well be an error  in that adequate regulations
meeting the full intent of Congress cannot be
promulgated at this time due to insufficient
knowledge or technologies. It would be more in
the interest of the environment and general public
to have EPA issue performance standards and/or
interim acceptable practices in a manner to eliminate
     Regulations of this nature accompanied by
adequately funded investigative and research
problems would provide the best solutions in the
least amount of time. In the field of waste disposal
practices, the use of "best judgement" or "best
engineering" practices which are based on a
limited data base are  no longer adequate.
     Although resource recovery is really the
answer, it will not solve today's problems
everywhere for many years to come. Even in the
distant future it appears that many residuals will
still require land disposal practices.
              LITERATURE CITED
(1) Final report on investigation of leaching of a sanitary
     landfill. 1954. Publication no. 10, Sacramento,
     California. State Water Pollution Control  Board.
(2) Effects of refuse dumps on ground-water quality. 1961.
     Publication no. 24, Sacramento, California, State
     Water Pollution Control Board.
(3) Bulletin No. 147-5. 1969. Sanitary landfill studies,
     Appendix A, Summary of selected preview investiga-
     tions. State of California, The Resources Agency,
     July 1969.
(4) Brunner, D. R. and  D. J. Keller. 1972. Sanitary landfill
     design and operation. Washington, D.C., U.S. Govern-
     ment Printing Office, p. 59.
(5) Garland, G. A. and  D. C. Mosher.  1975. Leachate effects
     of improper land disposal. Waste Age. March.
              *       *       *       *
     Dale C. Mosher is a Soil Scientist with Wehran
Engineering, New York. He has also worked with the U.S.
EPA, Soils Consultants, Inc., Maryland Environmental
Services, and University of Maryland.  He received a B.S. in
Agriculture from the University of Maine in 1970, and
an M.S. in Soils from the University of Maryland in 1972.

Audience Response  to  Session  IV  —  The  Federal
Ground-Water Protection  Program
Boyd N. Possin, Project Manager, Roy F. Weston, Inc.,
Wilmette Office Court, 3330 Old Glenview Road,
Wilmette, IL 60091:  A popular television beer commercial
these days in the Upper Midwest shows a panoramic view
of the rolling hills and valleys in and around La Crosse,
Wisconsin. Referring to this land (with some justification)
as "God's Country," the narrator tells us that the brewer's
water "comes from an underground reservoir which, some
people say, stretches all the way to Canada." The implication
of course is that if the reservoir, or aquifer, extends into
Canada, then the water withdrawn from the wells in
La Crosse might very well come from Canada.  Evidently,
Canadian ground water brews better beer than United
States ground water.
      Unfortunately this example, an aquifer as a closed
pipe, is not as ludicrous as it should be to many people
who should know better. Today we have heard a great deal
of discussion concerning "aquifer protection." All too often
this commendable goal is translated into a policy of aquifer
outcrop protection, a simple-minded approach which makes
no use of the modern hydrogeologic theories of ground-
water movement as set forth by scientists such as M. K.
Hubbert, J. Toth, R. A. Freeze, and  P. A. Witherspoon.
Ground water is not created in situ in an aquifer; neither
does it necessarily enter an aquifer through the aquifer's
outcrop area. Ground water moves along predictable paths
defined topographically by identifiable ground-water flow
systems. Ground-water flow systems have recharge areas
and discharge areas. If the water quality at a particular
location within an aquifer is to be protected, then the
recharge area for the ground-water flow system which
moves through that part of the aquifer must be protected.
This recharge area may or may not  contain parts of the
aquifer outcrop area. It is a complicated set of problems
for which there are seldom any simple answers. Still, the
effort must be made because protecting a ground-water
supply by protecting only the aquifer makes about as
much sense as trying to protect a household water supply
by protecting only the faucet.

Lloyd H.  Woosley, Jr., P.E., Water Quality & Ecology
Branch, Tennessee Valley Authority, Chattanooga, TN
37401: EPA and various other agencies through a multitude
of laws and regulations, have only limited and fragmented
authority for protecting the nation's ground-water quality.
Such laws and regulations include UIC, sole source
aquifers, NEPA, NPDES, 201, 208, State basin plans,
RCRA, Surface Mining and Reclamation Act, USGS, NRC,
FPC, and HUD authority, CZM, COE 404 program, plus
various local, regional, and State air and water pollution
control and planning programs. My concern is that there is
no comprehensive, strategic plan to protect ground-water
quality and to manage the resource conjunctively with
surface-water resources. Mr. Kimm, how does EPA plan to
use existing authority and procure additional authority to
protect the ground-water quality of the nation?

R. G. Shepherd, Willard Owens Associates, lnc.,7391 West
38th Ave., Wheat Ridge, CO:  I'm sure that everyone in
this room would agree that any efforts to protect our
aquifers from contamination and to assure safe drinking
water are commendable. However, as I listened to the
presentations of this session, I could not keep from thinking
of the many, many supplies of drinking water, both municipal
and private, that are already below minimum quality
standards, especially throughout the semiarid West. For
example, in Buffalo, a small town  in northwestern South
Dakota, the municipal supply, although the best water
available, probably would be considered undrinkable by
everyone in this room. Total dissolved solids are  probably
well into the thousands of milligrams per liter, and the water
has a distinctly disagreeable odor.  Remarkable, however,
the local townspeople do not consider their water to  be
especially bad, simply because they have used it  all their
lives. I do not know  the detrimental effects to their health,
but the same situation exists for numerous farms, ranches,
and other small towns all over the West; the total effect of
so many people drinking poor quality water cannot be good.
     I guess my basic point is that if someone from Buffalo
were here, he might say that much money is being spent to
protect aquifers from people, even in remote areas of the
West, while no one seems to be actively working, using
readily available solutions, to  protect people in the same
areas from the naturally unpotable water in the aquifers.
Most of  these small-town people probably would never
understand the direction of effort reported by the  EPA here
today. My question is then, is the EPA interested in efforts
to protect people from aquifers, instead of vice versa?

Elmer E. Jones, Jr., Agricultural Engineer, Beltsville Agri-
cultural  Research Center, USDA, Beltsville, MD 20705:
Mr. Sever referred to maintaining a positive benefit-cost
ratio. It  is important to remember every successful public
health program has a negative benefit-cost ratio.  As a
Fellow—American Public Health Association, the continued
funding  of preventative programs is of special concern to me.

Typhoid, polio and smallpox are not major problems today,
but who wants them back?
      Edgar A. Jeffrey, Acting Chief, Water Supply Branch
(6AWS), U.S. EPA, First International Bldg., 1201 Elm St.,
Dallas, TX: Positive benefit-cost ratios are desirable and
certainly attainable for public health programs. Without
having made a benefit-cost analysis, I have an intuitive
belief that with the advent of chlorination in 1912-13, and
its use in large cities in the U.S., the related cost (only
pennies per person per year) was, and continues to be,
considerably less than the dollar benefits from disease
prevention. The same holds true for poliomyelitis, which
was virtually eradicated from one year to the next by
the mere application of a vaccination procedure.
      Benefit-cost figures for fluoridation programs, on the
other hand, are readily available. It is estimated that if
every community were to fluoridate its water supply to
the optimum  concentration, the annual savings in unneeded
dental treatment would be approximately $700 million,
a return of about $50 for every dollar invested. The cost
again is only pennies per person per year. Detailed cost
studies have been made for several cities.
      Granted, public health programs related to the
therapeutic stage of health care may not have such an
evidently advantageous benefit-cost ratio. However, to be
fair, one must distinguish between preventative and
therapeutic programs. In so doing, the preventative health
programs come to stand on their own as being self
supporting and having a positive benefit-cost ratio.

Don Keech, Section Chief, Ground Water Division,
Michigan Department of Public Health, Lansing, Ml:
I wanted to speak in regard to the Office of Drinking
Water's standards and specifically to a comment made by
Mr. Sever regarding application of these standards to
ground-water quality in the aquifer. The standards really
apply to drinking water as it's furnished to the customer.
However, the fact that you can degrade water in an aquifer
to this level or to a point that exceeds the level, as long
as you can treat it to meet these requirements, is not
sensible. I think that's an erroneous statement because
ground water is usually not treated before passing into
the drinking water system. This is true specifically in
private homes, small establishments, industry and to a
large extent, in small communities.
      You don't degrade something that's good quality to
some predetermined level. You maintain that quality at
what it is. Again, I don't think this is the proper approach.
Now I'd also like to make a comment regarding the
secondary drinking water standards which were referred to.
I understand that there was not going to be any secondary
standards. There were no provisions  in the  law for these,
they are not regulations, they're simply a guideline and
again, you don't degrade water quality to some guideline
but you maintain your water in a natural aquifer to the
best quality that you have there to start with.

Rich DeVries, Oklahoma State University, Stillwater:
I have a question for Mr. Sever. The  fundamental law of
gravity states that the water goes downward. In a recent
report that the EPA published and put out on an oil field
pollution case in Oklahoma, it was stated that the water
flows upward. In this case in point, a salt-water pit was
closed 25 years ago. Last year, a secondary oil recovery well
was drilled across the road from this pit. This year, there
is salt water flowing at the surface. EPA concluded that it
was from the pit that was closed 25 years ago. I wonder if in
fact we really want EPA to come in to arbitrate our salt-
water pollution problems.
      Charles Sever, Chief, Water Supply Branch, U.S. EPA,
Dallas, TX:  I think your facts are a little bit wrong. In fact
the pressure at the injection formation is 1,700 feet on the
land surface so there is no  way the water from that depth
can get to the surface. Second, we flew it and have infrared
photography of it that was presented and it showed that, in
fact, the pit was there, that there are  3 old brine lines
crossing the property that  showed breaks in them. There
was no water at the surface, but there was salt and there
was oil from an old oil spill. The photography showed that
the salt was coming from the breaks in the lines. You could
trace it, it was all there on the photography.
      Rich DeVries:  I agree that was in the report, but there's
also a water  well in the north  side of the road that is
flowing. Since the secondary oil recovery was started, and
the only way you could  start the flow is that it is being
pressured  from below.
      Charles Sever:  The point was we had them shut down
the well and we made pressure measurements in the well,
and the pressure in the well is at 1,700 feet below the
surface. How do you get it from 1,700 feet up?

Paul Plummer, Miami Conservancy District, Dayton, OH:
Many of our local water supplies either are directly induced
from surface supplies or are artificially recharged. So the
connection between our surface supplies and our major
municipal ground-water  supplies is quite close.
      Why are the EPA and the water supply industry so
far apart on the use of activated carbon to control
trihalomethanes in water supplies; has chloroform, etc.
been detected in ground-water supplies, and to what extent
is this a real problem?
      Victor Kimm, Deputy Assistant Administrator for
Drinking Water, U.S. EPA, Washington, D.C.:  I thought
no one would ask. That's been the big battle for the last
6 months. Almost everyone in the industry is up in arms
about our proposed organic standards. As far as trihalo-
methane in ground water,  we have found it in some places.
But generally ground water is better than surface water. As
far as the  legitimate public health concern about trihalo-
methanes and other organics, we have testimony from the
head of the National Cancer Institute and the head of the
National Environmental Health Sciences Institute at our
D.C. hearing, saying they both believe it and they are both
big in the cancer game and not directly responsive to us.
Specifically, how big is the magnitude of the health problem
posed by these contaminants  is the kind of question I
described earlier in which  no one really knows. You can go
through models and come up with some numbers, but
they're not very meaningful. The question is, is it reasonable
to go ahead through standards and force people to reduce
those levels? We think it is, we proposed regulations on that
basis. I think we have a pre.tty good agreement on that with
the industry. It's the other part of the regulation that
requires granular activated carbon unit processing in waters
derived from surface sources highly contaminated with
man-made chemicals where the real controversy lies. That's
going to be a tough  problem for us to deal with in the
months ahead.

State  Ground-Water  Protection  Programs
A  National  Summarya
by Richard E. Barteir
     In order to discuss the adequacy or inadequacy of
State ground-water protection programs, it is helpful to
establish a base line which may be used as a frame of
reference for the discussion. To provide that frame of
reference, the 50 States were contacted and representatives
were questioned as to the nature and extent of their
existing ground-water programs. The survey of States
produced a wealth of information relative to the structure
of various State programs and this information is presented
graphically in the neutral presentation. The subject of
multiple agency involvement is addressed.
     In addition to looking at the structure of State
programs, information was collected regarding the nature
of existing State statutes and regulations. Tabulation and
interpretation of this information is provided to illustrate
how the institutions are providing for the protection of
our ground-water resources. In addition to evaluating the
various types of statutes, existing enforcement mechanisms
were researched and are presented for review. Graphic
presentations of the national data base are used and again
several States' procedures are reviewed in detail. The topic
of ground-water quality standards was specifically
addressed during interviews in order to note the extent of
this developing regulatory  technique.
      Presented at The Fourth National Ground Water
Quality Symposium, Minneapolis, Minnesota, September
20-22, 1978.
     ^Chief, Ground-Water Protection Section, Region V,
U.S. Environmental Protection Agency, 230 S. Dearborn
Street, Chicago, Illinois 60604.
     The presentation will provide a national look at
existing ground-water programs with in-depth analysis
of certain State programs. The variations in State
programs are highlighted and an attempt is made to estimate
resources currently dedicated to ground-water protection
at the State level.
     Everyone is familiar with the old saying,
"People talk about the weather but no one ever
does anything about it." The purpose of this
presentation is to talk about State ground-water
protection programs, NOT to do something about
them. The more active role in addressing this issue
is left to the Pro and Con presenters to follow.
Simply stated, the purpose of this article is to
outline the status of State ground-water
protection programs and to look at predominant
trends or characteristics on a national basis. In
order to simplify the task of depicting State
programs, the concept of managing ground-water
resources—i.e., ground-water use—has not been
pursued. The is not to say that management and
protection of ground water can or should be
separated. It is my personal opinion that they
cannot; however, the topic at hand is State
ground-water protection programs and, accordingly,
the emphasis was placed on protection during
data collection.
     A review of 1975 data compiled by the U.S.
Geological Survey  (Murray and Reeves, 1977) shows
that far more than half of the States rely on ground
water to supply 40% or more of their population

Fig. 1. Percent of population served by ground water.

(see Figure 1). On a national scale approximately
40% of the population depends on ground-water
sources for their water supply. With these figures in
mind  it is impossible to dismiss the importance of
State  ground-water protection programs. The
responsibility for protecting the quality of the
nation's ground-water resources has, in the absence
of a strong national policy, been left principally
to the States. The information to follow was
collected to represent current State activities in
discharging this awesome responsibility.
     In order to more realistically evaluate the data
to be  presented, it is necessary to examine the
method by which the data was collected. Basically
the data was collected through an extensive phone
survey in which all 50 States were contacted.
During the survey, all ten EPA Regions were
contacted and asked to identify their key ground-
water protection contacts at the State level. In
addition, several lists of State ground-water
representatives were consulted to insure that all
States were adequately represented. Once the list
of representatives was complete, the survey itself
was initiated. During the  survey, at least one repre-
sentative of each State was contacted and inter-
viewed regarding the nature, extent, and status of
that State's ground-water protection program. In
numerous incidents, it was  necessary to talk to
several individuals representing more than one
State  agency while,  in other cases, several
individuals, representing a single agency, were
interviewed. All those contacted were  asked
basically the same questions, and almost all
responded openly and proved most helpful. In
many instances, those contacted provided not
only the information requested but also
volunteered more detailed explanations and
insights (not to mention interpretations) into
State programs and problems. The principal informa-
tion solicited from the State representatives
interviewed is as follows:

     1. Laws under which the program is being
     2. Names and functions of the State agency
or agencies involved in ground-water protection

     3. Enforcement mechanisms used to insure
ground-water protection and location  of the
enforcing operational unit.

     4. Status of development of ground-water
quality standards.

     5. Estimate of person years associated with
State ground-water protection programs.
     It should be noted  that the information
presented was collected  solely for the  purpose of
adequately depicting national trends. With limited
resources it was not possible to  contact representa-
tives of all involved State agencies. In  addition,
collecting and categorizing the data collected
required  a certain amount of extrapolation and
drawing some conclusions. It is  hoped that we
have adequately represented the national picture
and in so doing have not grossly misrepresented
any particular State.
     In evaluating the information collected, the
logical starting place is the body of laws under
which the programs are being implemented (see
Figure 2). Our compilation of the data revealed
that the State agencies involved in ground water
operate under various and diverse laws. The most
common is the broad environmental law governing
pollution of what is defined within as  "waters of
Fig. 2. State ground-water laws.

 the State." The term "waters of the State" can be
 typically defined as, "All streams, lakes, ponds,
 marshes, watercourses, waterways, wells, springs,
 reservoirs, aquifers, irrigation systems, drainage
 systems, and all other bodies and accumulations of
 water, surface and underground, natural and
 artificial, public or private, which are  contained
 within, flow through, or border upon, the State or
 any portion thereof." This definition  is  used by
 Minnesota in its Environmental Protection Law,
 Chapter 115. Approximately 60% of the States
 currently rely on general laws as a basis  for ground-
 water protection.
      Eleven, or approximately 20% of the States,
 rely on what we have termed individual  laws for
 their  ground-water protection authorities.
 Individual  laws can be characterized as separate
 pieces of specific legislation which deal with
 particular sources of pollution, usually activities,
 and aspects of ground-water protection. These
 statutes may be used in addition to existing
 environmental laws as in the case of North
 Carolina, or they may be adequate in  themselves
 to provide the requisite ground-water  protection,
 as in Washington and Idaho. Washington, for
 example, relies on the following statutes:
   Pollution Source           Laws & Regulations

 Waste  Injection          SDWA, UIC
 Soluble Sludge Disposal   State Guidelines
 Ground Discharge Treat-
   ment  of Effluents     Clean Water Act NPDES
Non-Point Sources
Federal Water Pollution
  Control Act
Toxic Chemical Storage   Hazardous Waste Law, State
Chemical & Oil Spills     State Water Pollution Control
On-Site Waste Disposal    Clean Water Act
     In seven States, general environmental
protection laws with specific reference to ground
water are used to effect ground-water protection.
Our investigations identified only three States
which had specific ground-water laws. Georgia has
its Ground-Water Use Act of 1972 which provides
protection in conjunction with the Water Quality
Control Act which employs the waters of the State
concept. The Utah Water Code has a specific
section relating to ground water and is used in
conjunction with the State  Water  Pollution Control
Act. Virginia's Ground-Water Act, passed in
1973, has provided for the  implementation of that
State's ground-water management program.
     Looking back at the kinds of laws currently
being used to protect ground water, it is important
to note that, in many cases, States must rely upon
legislation which was not specifically designed to
protect ground water and, as such, is cumbersome
and often difficult to litigate. In other cases, State
laws may be bypassed in favor of federal statutes.
This happens most often in the case of individual
laws, as can be seen in the State of Washington.
Since the federal government has no singular
comprehensive ground-water protection statutes,
the limitations of relying solely on federal laws
are obvious. It should also be pointed out that
the classification of States is not based on accepted
criteria for evaluating State laws,  but, rather,
represents our interpretation of the data collected
during the interviews.
     Having considered the State laws being used
to protect ground-water resources, it is important to
look at the agencies involved in ground-water
protection. Figure 3 depicts the number of agencies
involved in ground-water protection in the various
States. It would be impossible to  address the nature
of the agencies involved as an adequate treatment
would take volumes as opposed to the paragraphs
at hand. Lehr et al.  (1976) have addressed this issue
in a previous EPA publication. Looking at the data
on the number of agencies involved we see that
eleven States involve three agencies, and five States
involve three or more agencies in  their implementa-
tion programs. This leaves only nine States with a
single agency responsible for ground-water
protection. In collecting this data we considered an
agency involved in ground-wafer protection when it
possessed regulatory authority. Other agencies
commonly associated with ground water, such as
                               Fig. 3. Number of State agencies involved in ground-water

State geological surveys, which typically are involved
in data collection and research, are not included in
Figure 3. During the data collection we found
various arrangements and combinations of involved
organizational units. In portraying this data, we
are not attempting to  infer that single agency
involvement is better than multiple agency involve-
ment or vice versa. We are merely trying to depict
what exists in the States.
     With the type of laws and number of
State agencies  involved in ground-water protection
fresh in mind,  it is illuminating to look at the
enforcement mechanisms the States rely on to
implement their ground-water protection programs
(see  Figure 4). Enforcement mechanisms vary
widely among  the States with the most common
method (40%) being through the State's Attorney
General. In this instance, a violation would be
identified and  resolution attempted by the involved
State agency. In the event that resolution fails, a
case  would be  prepared by the technical/professional
staff of the agency and turned over to the Attorney
General for prosecution. (This is an obvious
simplification of a complex administrative
procedure.) Upon completion of a case and
rendering of a  decision against a violator, penalties
may vary from censure to cease and desist orders
to considerable fines.  In eighteen States, agency
attorneys are responsible for enforcement actions.
In two States,  Kansas and Nebraska, a major share
of the responsibility falls to the county/district
attorney.  In at least seven States, no court action
has been taken against ground-water polluters to
date, thus leaving State procedures untested. These
States are Washington, Montana, Wyoming,
Louisiana, Vermont, Massachusetts, and Hawaii.
In a  small number of States we were unable to
        •«.          f      I    /A
        i roA	}      i   .^
Other States define discharge standards which are
relatively independent of the aquifer. New Mexico
has identified the parameter of Total Dissolved
Solids and the limit of less than 10,000 mg/1 as
requiring protection. Maximum contaminant levels
have been established for three separate categories:
(1) human health standards, (2) domestic water-
supply standards, and (3) irrigation use. In addition,
there are  also detailed provisions for discharge
plans, application approval, and reporting and
monitoring of ground water. On the other hand,
Nebraska's proposed ground-water quality
standards are based on a non(anti)-degradation
policy. Maximum contaminant levels are established
in terms of health and aesthetic quality. Non-
degradation is also the focal point of Michigan's
ground-water standards which place emphasis on
regulating discharges, preparing hydrogeologic
reports and monitoring. Alaska and South Carolina
rely on more general ground-water quality standards.
In the case of Virginia, several hydrogeologic regions
have been identified and specific standards are
being applied to each region.
     It is  difficult to assign a major significance  to
the number of persons or person years involved  in
State ground-water protection programs. As Figure
6 shows, the  level of involvement varies among the
States. Variations in organization of the State
programs make  it difficult to relate the outputs of
five person years in Maine to five person years in
Arizona. We do feel that in general the numbers can
serve  as an indicator of the States' awareness and
possibly commitment relative to ground-water
protection. Estimates of the person year involve-
ment of the various States were almost always
identified as very rough. Multiple agency involve-
ment and mixed responsibilities of those involved
Fig. 6. Person years dedicated to ground-water protection.
 in the ground-water programs make it almost
 impossible to derive accurate figures. The data
 presented represents our compilation of these
 guesses and serves to document, at least to a
 limited degree, the resources currently committed
 to ground-water protection at the State  level.
      It is obvious that State staffing and budgeting
 limitations will, for the most part, determine the
 ultimate form and organization of ground-water
 protection efforts.  Based on our discussion with
 the States, it appears that no State has the
 resources or the funding it needs.  A broad
 extrapolation of the data collected regarding
 person years currently involved in State  ground-
 water protection programs, indicates that less
 than 700 person years may be involved nation-
 wide. This figure includes all administrative and
 support functions which typically can be
 estimated as V* of the work force.  Thus,  we can
 crudely say that approximately 525 person years
 of professional/technical effort  are expended by
 the States each year to protect ground water.
      In summary, we have tried to present a brief
 overview  of the state of  State Ground-Water
 Protection Programs. It is difficult to collect and
 present this data without making some assumptions
 and drawing some conclusions; hopefully, these
 liberties have not biased significantly the data
 presented. In conjunction with the subsequent Pro
 and Con presentations, we hope the evaluation of
 legal  authority, State organization, and person
 power will allow the attendees of the Fourth
 National Ground Water Quality Symposium  to
 determine for themselves whether "State Ground-
 Water Protection Programs" are adequate or

 Murray, C. R., and E. B. Reeves. 1977. Estimated use  of
     water in the United States in 1975. Geological Surve)
     Circular 765.
     Richard E. Bartelt graduated in 1970 with a B.S. in
Civil Engineering from Iowa State University. Subsequently
he served 2 years in the Army as a Lieutenant in the Corps
of Engineers. Upon completion of active duty he returned
to Iowa State University where, in 1973, he received a
Master's degree in Sanitary Engineering. For the past 4'/2
years, Rich has worked for the U.S. EPA, Region V, in
Chicago. The past year and a half he has been the Region's
ground-water protection representative and is currently
serving as Chief of the Ground-Water Protection Section,
which represents the Region in most ground-water related
issues. For the past year Mr. Bartelt has participated in the
national work group responsible for drafting and executing
the Surface Impoundment Assessment.

State  Ground-Water  Protection
Programs  —  Adequate"
by Edwin H. Ross
     An assessment of the adequacy of State involvement
should include a historical perspective of resource manage-
ment in the nation. A review of the record indicates that up
until the 70's, Federal policy was virtually nonexistent with
respect to ground-water protection programs.
     Efforts of the ground-water industry and related
scientific community to gain legislative action has, within
the last few years, shown progress within State government.
The Federal EPA, in response to efforts of the only
significant constituency, the NWWA, is now requiring
ground-water protection in their regulations.
     Institutional arrangements, whether national, State or
local, will at least for some years to come by political
necessity require central involvement of the States in
ground-water protection.
     The legislative and executive branch in many States
have shown their willingness to act; however, without an
active political constituency, legislative appropriations are
provided after actual problems arise due to drought or
contamination problems. Rainfall provides extra time to
address quantity problems but there may not be a second
chance to protect ground-water quality. These branches of
government have the monetary and legal authority to act
once the need is demonstrated. The record of the judicial
branch indicates a need for the legislative and executive
      Presented at The Fourth National Ground Water
 Quality Symposium, Minneapolis, Minnesota, September
 20-22, 1978.
      ^Supervisor, Ground Water Quality Control Unit,
 Minnesota Department of Health, 717 Southeast Delaware
 St., Minneapolis, Minnesota 55440.
branch to design and manage programs that will avoid the
necessity of court action. Continued advocacy efforts for
ground-water protection programs yet remains the
responsibility of the water well industry and a small ground-
water technical constituency. The public and the politicians
need to be further informed and educated about the need
for ground-water protection.

     The purpose of this paper is to provide an
analysis of the political perceptions of the adequacy
of State ground-water programs. Whether a program
is adequate in the politician's view appears to be
closely related to the immediacy of a crisis.
     Webster (1970) defines adequate as:

     1. Enough or good enough for what is required
or needed; sufficient, suitable.
     2. Barely satisfactory; acceptable but not

     Adequacy is a relative term and may be judged
differently by various people. In assessing the
adequacy of the State ground-water protection
programs, Bartelt and Dawson (1978) made a
survey of State agency professionals throughout the
nation. Adequacy of State ground-water programs
could be related to:

     1. Needs as addressed by Federal programs.

     2. Needs as addressed by private foundations.

     3. Needs as perceived by the politician.

     4. Actual needs for ground-water protection.

     In an assessment of the adequacy of State
ground-water quality programs, it would be of
interest to make a comparison with Federal
programs and private foundation efforts to protect
ground-water quality.
     Dana (1956), in his survey of Federal natural
resource programs, documents no programs for
ground-water quality protection. Not until  1969
was there any significant Federal program to
protect ground-water quality. The National
Environmental Policy Act of 1969, PL91-190,
provided a mechanism to identify environmental
problems (Hagman, 1974).
     Legislation passed in  the early 1970's,
including the Water Pollution Control Act,
PL92-500, and the  Clean Air Act, PL91-604,
forbids or limits the disposal of waste into surface
waters, the oceans, or the atmosphere, but these
pollution control programs are resulting in ground-
water degradation (Gillies, 1978). Pollutants that
are removed from the air and surface water are now
being dumped on the land surface or into wells
resulting in the contamination of ground water.
     The Safe Drinking Water Act, PL93-523,
limits the protection of ground water to the
designation of certain "sole source aquifers" and to
the control of underground injection of waste fluids.
Studies authorized under the act demonstrated
the urgent need for further ground-water protection
and led to the passage of the Resource and Recovery
Act,  PL94-580, which controls the disposal of solid
and hazardous waste. The act requires the U.S.
Environmental Protection  Agency to develop an
inventory of hazardous substances produced in the
nation. The Toxic Substances Control Act,
PL94-469, seeks to limit or prohibit entry into the
environment of chemicals potentially hazardous to
human health. The  Surface Mining Control and
Reclamation Act, PL95-87, singles out specific
sources of contamination such as injection wells.
This  controls coal mining, both surface and
underground, and requires hydrogeological studies
before disposing of mining waste or filling of a
mine. Most of these Federal acts are administered
and enforced by the States, many of which have
primacy over the acts by virtue of setting up their
own  regulations following  Federal directives.
Enactment of these environmental protection laws
demonstrate that the Federal and State governments
are becoming increasingly more concerned about
the protection of ground-water resources.
     Foundation research on public policy issues
has significantly influenced passage of much
legislation in the United States. There are
approximately 25,000 private foundations in this
country. Even though some of the foundations
have impressive assets, the Ford Foundation being
the largest with over 3.6 billion dollars, the private
foundations have not been found to have much
concern over ground-water  protection (Ford
Foundation, 1974; Nielsen, 1972). The Rockefeller
Foundation has funded research into  the quality
of the environment since 1969, but the program
was phased out in June 1978. The Ford Foundation
is decreasing its funding of projects in environmental
protection. A search of funding done  by  other
private foundations (Council of Foundations,
1975; Conservation Foundation Report,  1958,
1959) revealed almost no foundation-sponsored
research in the areas of water resources, ground-
water quality protection or the related areas of
resource recovery, hazardous waste or toxic
materials handling.
     Bartelt (1978) and Dawson (1978) have made
extensive surveys of the States to solicit the views
of the professionals concerning State ground-
water programs. Dawson reports that the majority
of State agency personnel questioned feel their
ground-water protection programs are inadequate
in providing total resource protection.
     In contrast to the nationwide surveys of
Bartelt (1978) and Dawson (1978), the author
has confined this paper primarily to the question
of adequacy of ground-water programs in
Minnesota over the past 20 years. A description of
water resources and the importance of ground water
to public need is included with a discussion of
funding and personnel provided for ground-water
programs as contrasted to total State expenditures
and political perceptions of the needs of constituents
and pressure groups.
     Minnesota is a head-water State (Figure 1).
Minnesota does not receive surface water in
appreciable amounts from beyond her

boundaries (Ross,  1976). Most surplus water flows
from the Rainy River in northern Minnesota and
the Mississippi River below the Twin Cities
(Figure 1). Although Minnesota is the land of
10,000 lakes, the majority of these lakes lose more
to evaporation than they gain from precipitation
in a year's time (Figure 2). Topography and
land-use priorities  do not provide natural sites
for dams to impound significant amounts of
surface water. Ground water is the water supply
for 93  percent  of  the communities  in Minnesota.
Over 2,500,000 or 66 percent of the  State's
population is served by ground water.

     Between 1956 and 1970, when  the first
ground-water hydrologist was employed by the
Department of Conservation (now Department of
Natural Resources) (Table 1), State personnel
engaged in ground-water programs in Minnesota
increased only slightly. In 1972, public concern
for water quality was reflected in the staff additions
to the Pollution Control Agency. The additions in
1973 and  1975 were primarily for the solid waste
program. The additions in 1977 were primarily for
the requirements of the underground injection
control programs of the Federal Safe Drinking
Water Act.
                                     FROM LAKES
                                   SCALE OF FLOW IN CFS

                                        2  3 I 10,000
Fig. 2. Minnesota's average precipitation minus evaporation
from lakes.
     Other additions to staffing of the Health and
Natural Resources Departments and the Minnesota
Geological Survey resulted from the near public
panic caused by the drought of 1976 and 1977
(Figure 3).
                                                          Table 1. Professional Ground-Water Personnel
                                                                 Minnesota State Government
Fig. 1. Flow of Minnesota streams (width of stream indicates
the relative magnitude of average flow).
— Minnesota
— Minnesota
20 11

of Health


Pollution Control Agency
— Department of Natural
— Minnesota

Geological Survey

Fig. 3. Drought, 1976-77.
     Politicians strive to provide programs to meet
the needs of their constituents. To be successful
the politician should continually assess the
adequacy of governmental programs. Accordingly,
the adequacy or inadequacy of any public program
will be the result of the politicians' perception of
the public's needs and wants.
     As the surveys of Bartelt (1978) and Dawson
(1978) have indicated, State ground-water pro-
fessionals throughout the nation are of the opinion
that ground-water programs are inadequate.
However, Minnesota aspirants to political office in
the Summer of 1978 indicate a contradictory
perception of public wants and needs to that of
most State ground-water professionals.
     In 1978, the Minnesota politician has an
obvious lack of concern  for issues  other than the
high cost of government and the need to cut taxes.
One can only conclude that the public policy
makers at this time are of the opinion that State
ground-water programs are adequate. Because of
the average wage earner's problems in meeting
everyday expenses, the concern for taxes and the
cost of government has accelerated this year. The
consumer price index increased faster than the
real growth in the gross national product (Figure
4). Because of the progressive income tax rates,
the average wage earner's taxes increase dispro-
portionately to his cost-of-living salary adjustments.
The projections of revenue for Federal programs
seemed to be rather dismal a few years back but
                                                    the inflation and progressive tax laws provided a
                                                    solution (Figure 5). State and local budgets are
                                                    now generally in sound condition (Figure 6).
                                                         A sudden change in public attitude erupted
                                                    when California voters sent a loud and clear message
                                                    to their elected officials by passing Proposition  13,
                                                    and reducing property taxes by 57 percent
                                                    (Figure 7).
                                                         In Minnesota, the politician is responding to
                                                    the issue with his concern for the  high cost of
                                                    government (Table 2), but in a way qualified so as
                                                    to not alienate the most influential special interest
                                                    constituency.  Although there are about 900 special
Fig. 4. Soaring prices, slowing growth - percent change in
real from national product, and percent change in consumer
price index.

interest groups represented by about 1300 lobbyists
registered with the Minnesota Ethical Practices
Board, none are as powerful and influential as the
education lobby. In early September 1978,
newspaper headlines announced, repeatedly, the
governor's opposition to increasing taxes as well as
spending. The headlines did not announce the entire
story as revealed in the text of the newspaper
articles: "Two of the biggest budget items are
school and property  tax relief, which includes aid
to local governments (schools*); programs the
     "Inserted by author.
State of the States: Healthy
      nk budgets premise tax rettef, better xrvfau
      In billions of dollars
                                                        -3.99 -3.81
                                                        TIME »»! frv f. Punnun*
                                                  Fig. 6. State and local budgets in billions of dollars.
                                                                                     oy Masnef ano it
Fig. 5. Leaping taxes, billions of dollars.


                     Table 2. Minnesota Summary of Legislative Appropriations by Function

State Agencies
Open Appropriations
Total Federal Funds
Total State Funds
Tax Refund
Federal Funds
Grand Total Appropriation
Federal Funds
$ 216,074,424

State Funds

% of
State Funds

legislature has committed itself to finance at a
substantial level. The governor said he will go along
with a 1978 legislative promise to increase
school aid next year." What the governor said
illustrates a consensus of viewpoints of most
aspirants to public office.
     To fully explain the politicians' sensitivity
to the needs of education in Minnesota would
require a rather detailed and somewhat subjective
analysis; however, it may be sufficient to say that
State funds are provided beyond the strict needs
of the student. Eighty percent of the total number
of State tax-supported employees (Table 3) are
employed in education. Politicians are strangely
silent to the seemingly popular opportunity to
discuss the fact that the most  dramatic and obvious
place to cut spending would be in elementary
     By 1980 the budgetary needs of the school
age population (Minnesota State Planning Agency,
1972, 1975) will only be 80 to 85 percent of the
1970 levels, and by 1985 the needs will only be 70
to 85 percent of the 1970 levels (Figures 8 and 9).
In 1978 dollars this could represent  a saving of
more than $500 million per year and yet the
governor and the legislators are promising to
provide more school aid instead of cutting spending
for education. Considering that this  savings is
almost equal to the total amount provided to all of
the State government agencies and that funds
provided for ground-water programs is less than
$2 million per year, it is obvious that the politicians
are of the opinion that ground-water programs are
adequate and education is inadequate (Minnesota
State Senate, 1977).
     Of the total State biennial budget (Table 2),
only $.25 per capita is allocated to the  professional
staff involved with the ground-water program and
$.025 per capita goes to the professionals working
with the water well program. All the funds spent
by the State averages out to $1,750 per capita and
the funds appropriated for the State agency
Table 3. Analysis of Employee Complements Financed in
            Whole or Part by State Funds

   Department of Education
   Higher Education
   Elementary and Secondary
    School Teachers
   Support Staff
State Departments
Welfare and Correction
Judicial (Including Attorney
   General's Office)

101,467 -
8,427 -
5,023 -
761 -

           529 -   0.4%

Total    128,096 - 100%
(Data from: Minnesota Population Projections, 1970-2000,
Minnesota State Planning Agency, November 1975; Minnesota
Socio-Economic Characteristics (from 1970 Census),
Minnesota State Planning Agency, April 1972; Minnesota
State Senate — A Fiscal Review of the 1977  Legislative
Session, December 1977; and Minnesota Tax Payer's


                               2. I
                                      I .9
                                       I .5
Fig. 8. Projected total school age population of fertility
level, 1970-2000, as a percent of 1970 school age
functions excluding transportation and welfare
averages out to about $160 for each person in the

     Problems with protecting ground-water quality
continue to grow (Figure 10). Recent discoveries
of damage to the drinking-water aquifers reveal a
frightening consequence to the affected communities
in both health and financial costs. Land-use practices
that severely contaminate the land surface may, in
future years, cause severe contamination to
subsurface- (ground-water) water supplies. There
is evidence that the ground water in some areas is
becoming contaminated. Inadvertent and accidental
spills and discharges enter the ground water.
Increased loading of the soil with fertilizers,
insecticides, and herbicides, plus the thousands of
synthetic substances manufactured each year are
contaminating this valuable resource. Landfills,
   1000 -
~   800-
-   600-
                                     Kl ndergarten
      1970      1980      |990      2000
 Fig. 9. Projected total school age population 1970-2000—
                                                                         from affluent U.S.
                                                     Poor site for , chemical wastas
                                                                            ,   „
                                                                           f nr  cnsts
                                                     Waste; Disposal solution is sticky
                                                  "/ ......   . '"'*"""     •-  ,   r,r""'
                                                  Chance seen to recover_arsenite
                                                Proposed Eden Prairie hazardous  •
                                                chemical dump faulted at hearing
                                            Fig. 10. Ground-water contamination.

pipelines, and improperly constructed wells add
to the pollution of the ground water.
     An explanation of this dilemma could be
that in the area of public resource management
and protection, it apparently makes little difference
what the facts are or what the professionals'
observations are if the public or politicians'
perceptions are of a different or indifferent
     If ground-water quality is threatened and if it
is ever to be protected, a concerned public must be
the primary motivating force in providing the
necessary means to assure adequate protection. To
provide a responsible role to the public in this
regard, the scientist, technician, bureaucrat or
academician must inform the public of all
available facts needed to  arrive at a consensus
opinion consistent with the public's responsibility
and welfare (Figure  11). Jefferson (1795) wrote:
"The people of every country are the only safe
              WATER WELL
                   .=»»   GROUND WATER
                   11 •*    NEWSLETTER
Fig. 11. The constituency.
 guardians of their own rights, and are the only
 instruments which can be used for their
 destruction. And certainly they would never
 consent to be so used were they not deceived. To
 avoid this, they should be instructed to a certain
 degree." (Koch and Peden, 1944.)
 Bartelt, Richard E. 1979. State ground-water protection
     programs — a national summary. Ground Water, v. 17,
     no. 1.
 Conservation Foundation Annual Report for the Years
     1958, 1959. 30 E. 40th St., New York, NY 10017.
 Council of Foundations. 1975. Foundation grants index.
     New York.
 Dana, S. T. 1956. Forest and range policy. McGraw-Hill.
 Dawson, James W. 1979. State ground-water protection
     programs — inadequate. Ground Water, v. 17, no. 1.
 Ford Foundation Experiments in Regional Environmental
     Management. 1974. A Symposium of the American
     Association for the Advancement of Science. 320
     East 43rd St., New York, NY 10017.
 Gillies, Nola. 1978. How recent federal legislation has
     moved toward greater protection of ground-water
     resources. Ground Water, v. 16, no. 4, pp. 293-296.
 Hagman, D. G. 1974. Urban and land development cases
     and material. American Casebook Series.
 Jefferson, T. 1944. The life and selected writings of Thomas
     Jefferson. Edited by Adrienne Koch and William
     Peden, Modern  Library, New York.
 Minnesota State Planning Agency. April 1972. Minnesota
     socio-economic characteristics (from the 4th count
     summary tape of the 1970 census).
 Minnesota State Planning Agency. November 1975.
     Minnesota population projections, 1970-2000.
     Office of the State Demographer.
 Minnesota State Senate. 1977. A fiscal review of the 1977
     legislative session. Published by the Minnesota State
 Nielsen, Waldemar. 1972. The big foundations. Columbia
     University Press.
 Ross, E. H. 1976. How about irrigating western Minnesota?
     Soil, Fertilizer and Agricultural Pesticides Short
     Course, Minneapolis Auditorium, December 13-15,
 Wilson, B.  1978. Perpich again says no increase next year.
     Minneapolis Star. September 6, 1978.
     Edwin H. Ross is Supervisor, Ground-Water Quality
Control Unit, Section of Water Supply and General Engineer-
ing, Division of Environmental Health, Minnesota Depart-
ment of Health. He received a B.A. in 1958 in Geology from
the University of Colorado. He has held the following
positions: Geologist, Minnesota Department of Natural
Resources, Division of Waters, 1958-1966; Ground-Water
Geologist, Michigan Department of Health, Ground-Water
Quality Control Section, 1966-1967; Water Resources
Planner, Minnesota State Planning Agency, Water
Resources Planning Program Budgeting Systems, 1967-1972.

State  Ground-Water  Protection
Programs  —  Inadequate"
by James W. Dawson
     The primary reason State ground-water protection
programs are inadequate is that the resource is misunder-
stood, surrounded by misconceptions and, due to its
occurrence, is "out of sight and out of mind." To most
people, ground water is a very elusive and somewhat
magical resource, whose significance in the over-all picture
of water resources has not been realized by those who have
the power and authority to rectify the present state of
affairs. The need for adequate protective legislation and
sufficient financial and manpower resources commitment
is even more difficult to justify because there has not, to
date, been a citizenry outcry for such measures.
     To ascertain the status of current State ground-water
protection programs, a survey of State legislation concerning
ground water was undertaken; additionally, a questionnaire
was sent to the agency in each State responsible for
administration of ground-water protection programs. The
results of this survey indicate that most States have broad
authority over ground-water resources through general
water resources legislation, but the majority do not have
specific ground-water protective legislation. In many cases,
the broad legislative authority is inadequate or, if
legislation is adequate, implementation of legislative
mandates is not sufficient to provide adequate protection.
Lack of ground-water quality and quantity data is severe to
the point that many agencies do not have a realistic
characterization or identification of the ground-water
resources they are to protect.
      Presented at The Fourth National Ground Water
Quality Symposium, Minneapolis, Minnesota, September
20-22, 1978.
     bRegional Geologist, Virginia State Water Control
Board, P.O. Box 7017, Roanoke, Virginia 24019.
     This discussion concerns some deficiencies of
State ground-water protection programs and
emphasizes the fact that the majority of State
agencies contacted feel their programs are inadequate
in providing true resource protection. While
protection immediately implies the prevention of
contamination, management is an integral part of
protection, since the act of protecting is "to shield
from injury, damage or loss; guard; defend"
(Guralnik, 1972). For State ground-water protection
programs to be considered adequate, they must, by
definition, be directed towards the total resource,
i.e., both quality and quantity. Without manage-
ment authority, State programs cannot provide
total resource protection.
     The method of data collection must be
considered when evaluating the data presented
herein. Two survey questionnaires were sent to
the primary State agency concerned with ground-
water resources which requested both subjective
evaluations of some program areas and delineation
of specific program elements; telephone interviews
were conducted to complete data collection.
(Note: Survey questionnaires were not sent to the
Virginia State Water Control  Board, Bureau of
Water Control Management. Program evaluations
utilized in this discussion are those of the author
and do not constitute official Agency response to
the questionnaires.) In most of the States, program
implementation is divided between two or more
agencies and input from sister agencies was provided,
in many cases, through the efforts of the primary

     The survey was not as detailed as would be
required for a comprehensive analysis of State
ground-water protection programs; however, the
effectiveness of such programs can be demonstrated
by considering the following factors:

     1.  Legislative basis for development of
programs and the adequacy of that legislation.
     2.  Ability of the State to collect ground-water
resources data.

     3.  Protection of the resource through proper
     4.  Ground-water quality standards as an
enforcement/regulatory tool.

     5.  Regulation of ground-water users and
management of the resource.
     6.  Implementation of existing programs and
the flexibility to expand those programs, or develop
new ones, to address ground-water problems.

     Adequate legislative authority is a prerequisite
for development of State ground-water protection
programs. All States have general water resources
legislation which declares (in one rhetorical form  or
another), as public policy and  legislative intent,
the protection, enhancement and management of
State waters for the public  health, safety and
welfare; the definition of State waters usually
includes both surface water and ground water. Most
of this legislation is pollution control/abatement-
oriented and is directed primarily towards surface
water, with only broad authority over ground water.
A few States have specific ground-water legislation,
but for  the majority of States, ground-water
protection is provided  through several different
statutes which mandate, to one or more agencies,
the development of sufficient programs to achieve
the intent of the legislation. Figure 1 depicts the
legislative basis for development of State ground-
water protection programs  (Bartelt, 1978) and
the State's evaluation of the adequacy of that
legislation to provide for protection and manage-
ment of ground-water resources is presented in
Figure 2.
     The majority of States (56%) rely on general
laws for development of ground-water protection
programs; seven States utilize general laws which
specifically mention ground water; 12 States have
individual laws which address specific pollution
sources  (usually activities) and their effect on
ground  water; and three States have specific
ground-water legislation. Twelve (12) States felt
                      LEGISLATIVE BASIb

  ''~^-^-i__  •  ',     ',      j	\   i' (  "\y ^,.^ i
     i     1&M-*    'r~'""'"  ^~\- /'C'"l"x^"-'T-"^'''""'  '•/
              ffiSSzSS'""""'   *"""°°" ^  '   ')'-V'-=3^
Fig. 1. Legislative basis.

existing legislation was adequate, 15 States
indicated it to be partially so, and 23 States felt
their legislation was inadequate. In all, 38 States
(76%) felt that their legislative basis was
inadequate or had deficiencies, with lack of
management authority cited as the predominant
factor; fragmented and incomplete legislation
(i.e., specific problem areas not addressed) and
legislative ambiguities were also cited.
     Comparison of legislative basis and evaluations
reveals that seven States felt a general law basis
was adequate, ten States noted deficiencies and 11
indicated that this basis was inadequate. General
laws which specifically mention ground water
were termed  adequate by  one State, deficient by
two  and  inadequate by four. Four States felt
the individual law basis was adequate, while two
indicated deficiencies, and six felt it was
inadequate. Of the States  that have specific
ground-water legislation, one noted deficiencies,
and two felt it was inadequate. These evaluations,
I  contend, emphasize that ground water is a
complex subject which has not received sufficient
Fig. 2. Evaluation of legislation.

                         ISSN .u/Mfef  i
                  W-;—  ip^^-  x~_.
                                                                       PUMPAGE & USE REPORTS REQUIRED
                                                                           /     Q-«,,»-«d
Fig. 3. Water well completion reports required.
Fig. 4. Pumpage and use reports required.
consideration by those who have the legislative
responsibility to mandate adequate protection.
     A fundamental aspect of any protection
program is collection of necessary information
regarding characteristics of the resource because
insufficient data precludes accurate resource
identification or inventory and thus, protection
and realistic management becomes difficult, if
not impossible. Such data collection  usually
includes submission of water well completion
reports (or some similar reporting vehicle),
pumpage and use reports, and background
quality information. Figure 3 reveals that 42
States indicated water well completion reports
were supposed to be filed, although exemptions
(for one reason or another) existed for nine of
those; eight States indicated that no  completion
report or similar form was required. Adequate yield
tests are necessary for determination of many
aquifer parameters, but only six States require pump
tests for all wells and 18 States indicated that pump
tests were required for public supply and/or high
capacity wells. Although not required by the
majority of States, many indicated that the results
of yield tests were frequently filed with water well
completion reports; however, comments indicate
that the tests were usually inaccurate due to the
method of testing (bailing or airlift) and insufficient
test duration. In regard to pumpage and use reports
(Figure 4)—vital data for management purposes—
32 States responded that they were required,
although approximately 80% of those indicated
that exemptions exist (high volume users,  public
supply systems or certain users in designated
areas are usually the only ones required to submit
such reports); five States indicated that they had
the option to require such reports if  they wanted
to. Although background quality data collection
was not specifically addressed in the  survey, such
data collection is dependent upon manpower and
budgetary constraints which can limit sufficient
data accumulation (several comments indicated a
lack of basic ground-water quality data).
     These survey results indicate that a large
number of States are unable to develop a sufficient
data base and the data that is collected is typically
spotty, inaccurate or incomplete, with collection
based primarily on voluntary cooperation.
Enforcement of regulatory provisions for data
submission was indicated to be minimal or non-
existent, due to  either fiscal limitations (manpower,
budget appropriation, etc.) or, in some cases,
because legislative or regulatory ambiguities
preclude enforcement. As a result, many States
do not have a realistic determination of what it
is they are supposed to protect.
     Protection  of the resource through proper
development is basic to preventing contamination,
with water well construction being one of the most
significant vehicles available for ground-water
contamination. Water well drilling codes (Figure 5)
     3   " ' Tiw- -
    .'A  :\"~       ^..-rr •-•».._   £-
    '---                '"'""  ~"
Fig. 5. Drilling codes/construction standards.

  fe^    ;   '->-»s~i-,     ^^  pr ^^7
    ssu   ;    '      f.^—-^.^  ^jfj^^lmjj

                  ""HjA  p" /-""^.^c5*-
  - _ --Ny^SSa          ~~'"\^
  "\ " ;s^^ •—•«..—v- -         &s?
  V, ^&53-\    \          V=z-zfe»... .
  r^^m,       ''^-
Fig. 6. Driller licensing.

which promulgate mandatory construction
standards or provide recommended minimum
standards, have been adopted by 30 States, while
three States are developing such codes (Adams,
1978). The integrity of public water-supply wells
is fairly well established through adequate well
construction standards (40 States have
mandatory requirements). However, for domestic
water wells (which constitute a larger user
population) there are not mandatory standards
in most States (20 States indicate no standards
adoption and of those who have such standards,
many are recommended with only voluntary
compliance and thus, non-enforceable).
     Licensing of water well contractors (Figure 6)
is another means of encouraging adequate well
construction, with 30  States requiring licensing
(one State requires it only for commercial
irrigation wells), 14 States with no licensing (two
States leave this for local control), five States with
licensing procedures in process and one State that
requires driller registration (Adams, 1978).
However, licensing in itself assures the competency
of the contractor, not necessarily that adequate
construction will be employed. Most citizens do not
know what constitutes adequate well construction
and therefore, State-mandated minimum construc-
tion standards for all wells seem to be in order from
a resource, as well as a consumer, protection
     Ground-water quality standards (which refer
specifically to ground-water quality and are not
concerned with discharge standards, drinking water
standards or any other such regulatory standard)
have received considerable interest recently as a
means of facilitating ground-water protection;
in fact, such standards can significantly affect a
State's ability to enforce its programs. In numerous
instances, ground-water pollution or contamination
is difficult or impossible to prove if degradation
from some previous quality standard cannot be
demonstrated; further, regulation of ground-water
dischargers can be difficult if background quality
has not been established. Ground-water quality
standards provide the necessary reference point
for comparison and regulation. Since ground-water
quality is not constant, adoption of a non-degrada-
tion policy,  in addition to specific parameter
concentrations, can prove  beneficial in enforcement
proceedings. Figure 7 indicates which States have
adopted specific ground-water quality standards:
five States have done so; two States have surface-
water quality standards which apply to ground
water; 11 States have standards in the developmental
or proposed stages; and 32 States have no specific
ground-water quality standards (Bartelt, 1978),
although ten of those have adopted standards for
drinking water supplies which utilize ground
water. As mentioned earlier, most States do not
have the reference point (standards) which is
essential in demonstrating water quality degradation
and providing regulatory basis and thus, quality
protection of the resource is diminished.
     Statewide regulation  (Figure  8) of ground-
water users can greatly enhance a State's ability
to inventory and protect the resource. State-issued
permits for ground-water use are required for some
users in all but 17 States; however, exemptions for
certain uses  or volumes exist in 22 of the 3 3 States
that do issue permits for ground-water use; only
11 States require permits for all wells, while three
States  leave  this  issue for local control. The fact
that the majority of States do not permit or
regulate all ground-water users indicates that most
States  do not have an accurate determination of
the level of ground-water development and thus,
realistic management of the resource is impossible.
Fig. 7. Ground-water quality standards.

Fig. 8. Regulation of ground-water users.
Fig. 10. Implementation of programs.
Private domestic wells and small volume users
(between 5,000 and 50,000 gpd) are typically
exempt from regulation and it is recognized that
eliminating these exemptions  could significantly
increase the regulatory workload. But in certain
cases, the total combined effect of these users can
be greater than that of the permitted users. For
adequate resource inventory and management I
contend that regulation of all ground-water users
is a necessity.
     As previously mentioned, management of
ground-water resources is innate to any adequate
protection program. The specific management tool
(e.g., beneficial use, prior appropriation, ground-
water mining, sustained yield, etc.) is not the
topic of discussion, but rather, the State's authority
to implement management alternatives, if warranted.
Declaration of ground-water management areas
(included  in this term are capacity use basins,
adjudicated basins, critical ground-water areas,
etc.) is the most  common means of implementing
management  alternatives. Figure 9 depicts that
24 States can declare management areas (survey
results indicate that exemptions and
"grandfathered" users can significantly reduce the
effectiveness of management plans that are
implemented); one State has legislation in process
that would authorize such areas; two States have
such areas in the State, but cannot delare similar
areas in other portions of the State; and, 23 States
have no such provision. Without this authority,
State ground-water protection programs cannot
provide total resource protection (many comments
identified this  as a major program deficiency).
     Implementation of legislatively mandated
programs is a significant factor in evaluating the
effectiveness of State ground-water protection
programs. As seen in Figure 10, implementation
of existing  programs was termed inadequate by
27 States, with 14 States indicating that the existing
program  implementation was deficient in certain
areas. Comments received generally fell into the
categories of insufficient manpower, budgetary
limitations, ambiguities in underlying legislation
and non-enforcement of regulatory provisions.
Figure 11 depicts the number of State agencies
Fig. 9. Ground-water management areas.

                                                                      '      f—-	1,    \  I,  *
                                                                      r~f^,7,r--"-,""'  ^ -4  '  A- •<**»'
Fig. 11. Number of agencies implementing programs.

Fig. 12. Person-years invested in programs.

involved with implementation of programs
(Bartelt, 1978) and it lends credence to the
adage, "too many cooks spoil the broth." In many
cases, this situation results in jurisdictional
overlaps and ambiguous delineation of agency
responsibilities, spawns inter-agency conflicts,
leads to duplication of efforts in some areas and
fosters the lack of any substantial programs in
other areas. The net result is a hit and miss program,
plagued with inefficient administration, which
does not provide adequate protection and does not
achieve legislative mandates.
     Figure 12 depicts an estimation of the amount
of person-years invested in each State for program
implementation (Bartelt,  1978). Comparison of
person-years invested with implementation adequacy
(Figure 10) emphasizes the variability of ground-
water conditions throughout the country. In many
cases it was difficult to derive even  a "ball park"
estimation; however, it is obvious that increased
staffing is  warranted  (numerous comments
indicated insufficient program staffing).
     A further indication of the effectiveness of
State ground-water protection programs is the
flexibility  of the responsible agency, or agencies,
to expand existing programs, or develop new ones,
to provide for increased protection of the resource.
Most enabling legislation mandates  to a particular
agency the responsibility of developing programs
sufficient to achieve the intent of that legislation,
with promulgation of rules and regulations after
public hearing. The major deficiency with this
procedure is the fact that this regulatory flexibility
is usually restricted to legislative-specific items
and consequently, if a particular item is not
mentioned in the enabling legislation, an agency
can be essentially powerless to address that
problem. This situation dictates that amendments
to existing statutes, or new legislation, be developed
and fed into the legislative grist mill where they
may not be well received or undergo debilitating
changes. The net result is that problem areas are
not addressed in a timely manner and the
program's effectiveness in providing adequate
protection for ground-water resources is reduced.

     A detailed analysis of State ground-water
protection programs must consider other factors
and program elements which have not been
mentioned in this discussion; however, the majority
of State agencies feel their ground-water protection
programs are inadequate in providing total resource
protection. Several States feel that they have done
a pretty good job considering the limitations under
which the programs must operate, although
practically all States indicated that programs could
be more effective if the deficiencies  discussed herein
were alleviated.
     The fact that the majority of the States feel
their current programs are inadequate  is indicative,
I contend, of more fundamental problems concern-
ing ground-water protection:

     1. Ground water is a highly misunderstood
resource and, due to its occurrence,  is  "out of
sight, out  of mind"; its significance in  the total
water resources picture, and its vulnerability, have
not been realized; and,
     2. Mankind's capacity to zealously react to a
problem, rather than to  rationally act to prevent the
problem from occurring in the first place.

These reasons combine to prevent, or impede,
program development because  improper understand-
ing of the  resource and the factors that affect it
makes justification for truly adequate  programs
difficult, if not impossible. Further, significant
ground-water problems have not developed in most
States and many people feel that there are  no real
problems that need action at this time, even though
widespread bacterial contamination  and specific
instances of more serious contamination have been
reported (EPA,  1977). However, remedial programs
for the majority of contamination problems can
require such enormous financial commitment and
extensive time periods that they are prohibitive and
effectively irreparable; additionally, cases of
physical damage to an aquifer are irrevocable.
PREVENTION  is the key to ground-water
protection and this can only be realized if these
fundamental problems are alleviated.
     Improvement of existing programs will require

legislative change, governmental reorganization or
realignment and a substantial financial investment
that will not have an appreciable return at the
present time; although the benefits of such programs
may be realized at some future date—20 years, 50
years, or even later. With reliance on ground water
increasing at 25% per decade (EPA,  1977) and as
land disposal (both surface and subsurface) of waste
materials increases, it behooves the States to develop
adequate protection programs to assure that ground
water remains an economical and high quality
water source. Is comprehensive federal legislation
the answer? The majority of States felt it was not,
although comments indicated that a federal
program—with financial and  technical assistance—
for development  of adequate State ground-water
protection programs would be beneficial.
    The majority of State agencies feel that their
ground-water protection programs are inadequate
and, I contend, these programs will remain so until
the need is recognized to develop adequate
programs. This need may be  recognized through:

     (a) Adequate understanding of the resource by
those who  have the legislative responsibility  to
mandate adequate programs  (be they federal or
State  legislators); or
     (b) When ground-water problems achieve a
level that will force the development of adequate
I only hope that the former, not the latter, situation
results in development of adequate State ground-
water protection programs.

Adams, Gene, Editorial Director. 1978. Ground Water Age.
     v. 12, no. 9. Scott Periodical Corporation, Elmhurst,
     Illinois, May 1978, pp. 16-18.
Bartelt, Richard.  1979. State ground-water protection
     programs — a national summary. Presented at The
     Fourth National Ground Water Quality Symposium,
     Minneapolis, Minnesota, September 20-22, 1978.
     Ground Water, v. 17, no. 1.
Guralnik, David B., Editor in Chief. 1972. Webster's New
     World Dictionary. Second College Edition, The
     World Publishing Company, New York and Cleveland,
     p. 1142.
U.S. Environmental Protection Agency, Office of Water
     Supply and Office of Solid Waste Management
     Programs. 1977. The report to Congress: waste disposal
     practices and their effects on ground water. Washington.
     D.C., January 1977.
     James. W. Dawson is Regional Geologist for the Virginia
State Water Control Board, West Central Regional Office,
Roanoke, Virginia. He received a B.S. degree in Geological
Sciences from Virginia Polytechnic Institute in 1970, and
began his employment with the Board in 1973, concerned
primarily with regulatory responsibilities. He has coauthored
reports on ground-water resources for some Virginia counties.

 Audience  Response  to  Session  V  —  State
 Ground-Water  Protection  Programs
 Ray Kazmann, Louisiana State University, Baton Rouge:
 I've listened to these presentations with a great deal of
 interest. Protecting aquifers and defining aquifer qualities
 is a great idea. Mr. Bartelt, I have a question for you. When
 you have several aquifers, one underneath the other, with
 water of varying quality in each one and differing within
 the aquifer itself, how do you devise an aquifer water
 quality standard? That's the problem in Louisiana.
      Richard Bartelt, U.S. EPA, Region V, Chicago, IL:
 If I knew how to protect those aquifers, I probably
 wouldn't be working for the Environmental Protection
 Agency, I'd be working for one of the States. We are not
 involved in ground-water quality standards right now, and
 I have no idea how you'd handle the situation. When I
 said States did or did not have ground-water quality
 standards, I didn't mean to infer that I was suggesting that
 they go out and develop them, I just wanted to state this
 was my interpretation of the progressive step that is being
 used by approximately 40 percent of the States in the U.S.
 I'm not trying to cast an aspersion on a State that doesn't
 have it.
      Ray Kazmann:  It all depends on the hydrogeology.
 Mr. Dawson, I have a couple of questions for you. Why do
 you feel you have to control the quantity of water being
 taken out of the ground as well as the quality? Why do you
 expand this method of protection? You're protecting the
 ground water from whom?
     James Dawson, Virginia State Water Control Board,
 Roanoke:  That's a good question. I guess in a way it sort
of depends on how you look at the resource in general. I,
for one, hold the philosophy that we ought  to use our
common sense. We ought to approach problems or manage
our resources. First of all, we're in a finite world, and I
think that the problems that we've seen in south central
Arizona with ground-water mining, the problems that
were evident in parts of Texas which have been turned
around a little bit by taking into account management
actions—we have to beneficially utilize our resources, and
there's nothing worse than for us to develop our civilization
or particular urban area and then find out that we're out of
water. What do we do now? We truck it in from 150 miles
away. I think that the State should have the flexibility to
implement management alternatives if it wants to. If it
decides to mine ground water, well it's their business,
but the point of the matter is that a large number of the
States don't have the flexibility to implement management
alternatives if they want to. So I think that as a total
resource, you have to hit both the quality and the
quantity aspects in your protection programs. They go
hand in hand.
      Ray Kazmann:  Who is going to decide whether
water shall be mined or not? In the final analysis, the people
that own the land are  trying to make a living and need the
water, if they mine it, it's better used mined than left
there protected against something else. I don't know what.
It's like saying we don't need the petroleum in the ground
and the coal in  the ground because of the limited stock and
we're  going to run out. What are you protecting when you
protect petroleum in the spaces?
      James Dawson:  Well, I've never fooled around with
petroleum except to put it in my car, but I think the point
is, you seem to be thinking that I'm professing a
preservationist attitude which I'm not. In preservation, a
preservationist implies no use, and I'm saying that we ought
to at least  take  a look at the resource and use it wisely.

The  208  Planning  Approach  to  Ground-Water
Protection  —  A  Program  Overview"
by Merna Hurd
     Ground-water protection is one of the water quality
management priorities that Section 208 planning is
addressing. Examples are derived from the experiences of
selected 208 planning agencies, among them Nassau-
Suffolk Regional Planning Board (NY), Old Colony
Planning Council (MA), and Ventura Regional County
Sanitation District (CA). These agencies have used 208
funds to identify problems such as salt-water intrusion
and contamination from storm runoff. Through ground-
water studies, each assessed the extent of the problems
and used their analysis to produce protection and control
     Section 208 requires that designated State and area-
wide agencies plan for ongoing water quality management
to meet the 1983 goal of restoring and maintaining the
chemical, physical, and biological integrity of the  Nation's
water. The Section, which originated with the Federal
Water Pollution Control Act of 1972, contains the only
extant provision for nonpoint source pollution control.
Opportunities for integration of 208 with other Clean
Water Act programs as well as with programs established
under the Safe Drinking Water Act and the Resource
Conservation and Recovery Act are now being explored
as a means of increasing water quality management
efficiency and quality.
     Presented at The Fourth National Ground Water
Quality Symposium, Minneapolis, Minnesota, September
20-22, 1978.
     bDirector, Water Planning Division, U.S. Environmental
Protection Agency, Office of Water and Waste Management,
WH-554, 401 M St., S.W., Washington, D.C. 20460.
     As Director of the Environmental Protection
Agency's national Water Quality Management
program, I welcome this opportunity to address such
recognized ground-water experts concerning the
208 planning approach to ground-water protection.
While I am relatively new to EPA, having assumed
my current responsibilities in January, I am not new
to water quality management. Prior to my arrival in
Washington, I was on the front lines, so to speak, in
the battle for clean surface and ground waters,
having served as Director of the New Castle County,
Delaware 208 Agency. From those perspectives, I
will tell you  straight out that it is my philosophy
that the achievement of the Clean Water Act
objective "to restore and maintain the chemical,
physical, and biological integrity of the Nation's
waters" requires the conjunctive management of
both surface and ground waters. There exists a
compelling case for the significant involvement of
208 agencies in the planning and management of
ground-water protection;  I intend to make that
case here.

     I feel in somewhat of a paradoxical position,
however, speaking to you as a Federal official on
the subject of ground-water protection. There exists
no Federal statute devoted solely to ground-water
concerns, no Federal program exclusively devoted
to problems unique to the ground waters and no
national ground-water policy (although we at EPA

are, through an intermedia effort, attempting to
develop a ground-water policy statement). Rather,
there exists fragmented authorities whose
implementing responsibilities are divided among
various Environmental Protection Agency water,
and water-related, programs.
     Currently, various sections of six Federal
statutes directly impact ground-water concerns.
These laws are: the Clean Water Act (CWA),
the Safe Drinking Water Act (SDWA), the Resource
Conservation and Recovery Act (RCRA), the
Toxic Substances Control ACT (TSCA), the
National Environmental Protection Act (NEPA)
and the Federal Insecticide, Fungicide and
Rodenticide Act (FIFRA). As my colleague, Vic
Kimm, has already given you an overview of the
relationship between these statutes and ground
water, I won't be repetitive. I will say, however,
that all of the necessary authorities appropriate
to the Federal role in ground-water protection are
probably contained within various sections of
these laws. The challenge  is ours to coordinate
their implementing programs in such a way that
effective ground-water quality management
occurs. That task is complicated somewhat by
State ground-water allocation laws which, in most
cases, allow landowners the right to withdraw
extensive amounts of ground water while imposing
few limitations. State law relating directly to
ground-water quality is virtually nonexistent.
     The primary responsibility of the Water
Quality Management program, under Sections
106 and 208 of the Clean Water Act is to
integrate the water pollution control efforts of
the Federal, State and local governments in order
to achieve the 1983  "goal of water quality which
provides for the protection and propagation
of fish, shellfish and wildlife and recreation in  and
on the water . ..."  It provides a State and local
government with a mechanism to develop and
enforce controls for point and nonpoint source and
ground-water pollution.
     The program is important in other respects. It
is intended to assist State and local governments in
the development of institutional capacities—to
create or strengthen their substantive abilities in
this field. It is also a mechanism whereby
economic, fiscal, social and political factors
affecting water pollution control can be integrated
into State and areawide plans. 208 agencies
may also be the focal point for the education of
local elected officials, operating agency personnel
and the interested public concerning local or
regional problems and recommended solutions.
     I am aware of the arguments, upon the passage
of P.L. 92-500, concerning a usurpation by the
Federal government -of what were historically State
and local prerogatives. Whatever the merit of those
discussions, I believe it worthwhile to note that
the Water Quality Management program is another
example of our Nation's experiment in  Federalism.
This Federally initiated program was conceived to
be State and locally operated. As such, it was
intended to be reflective of the regional nature of
the water pollution problem, the tendency on the
part of most Americans to want to solve their
problems  locally and to provide opportunities for
innovation within the system. Clearly, local
engineers  and planners  have a better understanding
of their own water quality problems and priorities
and the ability of their communities to  address
them than do Federal engineers and planners. As
the initial Environmental Protection Agency role
was to set up the program and  to develop its
guidance and regulations, I can say without
reservation that the Water Quality Management
program exemplified the American Partnership.
     But it does more than bring governments
together in a sharing process. It also brings to one
place key  elements of the Clean Water Act so that
those governments might more efficiently achieve
the Act's goals and requirements. Section 208
provides that water quality management plans
regulate within their jurisdictions, point source
discharges, including publicly owned treatment
facilities. In addition to point source controls, it
is important to note that Section 208 contains
the only Clean Water Act requirement for
nonpoint source control (including agricultural,
silvicultural and mining practices). Section 208
also requires that plans are to include processes to
identify and control saline intrusion, residual wastes
and the  disposal of pollutants on land or in
subsurface excavations  to protect surface and
ground-water quality.
     The structure of the Water Quality Manage-
ment program, then, lends itself well to  the protec-
tion of our ground waters. State and local govern-
ments are primarily responsible for developing
solutions to their water quality problems and all
Clean Water Act and other water, or water-
related programs, can be applied in concert
through this mechanism. All  areawide impacts upon
ground water including nonpoint sources, landfills
and withdrawals can be identified and plans for their
control developed. Likewise, ground-water impacts
upon receiving streams  due to withdrawal or
contamination of the aquifer can be  considered.

Ultimately, a plan will be developed which will
have considered virtually every alternative for
the improvement and protection of water quality
on a comprehensive, intermedia basis.
     I am referring here to the broadest variety of
programs. Because 208 agencies will have developed
areawide water quality expertise, I can envision
a role for them to play in the sole source aquifer
designation and management process and in the
regulation of pits, ponds and lagoons. There is
also a role for them in the siting and regulation of
local landfills, as well as the more traditional role
of siting and regulating the construction of waste
treatment facilities.
     I would like to mention just a few examples of
those 208 agencies which have been addressing
ground-water problems. Among them is my old
agency at New Castle County, Delaware.  Its
planners have examined the state of septic system
usage in the planning area. They have found
deleterious water quality effects caused by
suburban septic systems. Costly relief projects
are necessitated by these failures and their impact
is expected to increase as septic tank popularity
continues to rise because they represent a least cost
alternative to sewering. The New Castle 208 has
recommended that the County take action, which
at a minimum, might include more stringent
regulations or more strict enforcement to control
the problem.
     The Nassau-Suffolk Regional Planning Board
and the Old Colony Planning Council in
Massachusetts have also been concerned about
septics. Both Nassau-Suffolk and Old Colony
planners have emphasized good septic system
management and nonstructural solutions.
Nassau-Suffolk has also addressed the problem of
nitrates which have been leaching into the ground
water from indiscriminate  lawn fertilization. That
agency has also cited storm-water runoff as a
greater threat to ground-water pollution than is
domestic sewage. As solutions to the problem,
Nassau-Suffolk planners have proposed street
sweeping programs, recharge basin modifications
and zoning changes.
     Salt-water intrusion has been addressed by a
number of  208 agencies  including the Ventura
County Regional Sanitation District in California.
The Ventura 208 has recommended that a
moratorium be declared on building wells into the
upper, intruded aquifer. Wells would be permitted
into the lower zone. An  intermediate strategy is
to modify the pumping patterns so that pumpage
from the upper zones will be reduced, and salt-
water intrusion may stabilize and possibly reverse.
208 planning is doing its job; problems are being
identified; alternatives examined and solutions

     There exist four primary sources of ground-
water pollution: saline intrusion associated with
ground-water pumping; the movement into ground
water of bacteria, nutrients, salt, toxics and other
pollutants from agricultural runoff, landfills and
septage fields;  the percolation of bacteriological
and chemical contaminants into and between
aquifers caused by improperly installed wells, or
by abandoned  wells not properly plugged; and the
movement of contaminants between interconnected
ground- and surface-water bodies.
     As you know, due to the extremely slow
movement of ground water within an aquifer and
to subsurface geological discontinuities, pollutants
introduced into an aquifer at one location will
usually constitute a localized or, perhaps, a
regional problem. Since ground waters lack any
significant assimilative capacity such pollutants
will likely remain in the aquifer as we have
discovered no  cost-effective way to remedy the
contamination. Six factors, all local or regional
in nature, determine the extent of ground-water
pollution. Four of them, soil, geology, climate
and hydrology exist in nature and are beyond
man's capacity to control, although they may be
modified. The other two factors, land use and
growth patterns are subject to control by man
through planning and management utilizing
techniques from zoning ordinances to Best
Management Practices (BMP's).
     State ground-water law must also be
understood in  order to define further the ground-
water protection problem and to place the Federal
role in its proper perspective.
     The conclusion to be drawn from any study
of State ground-water law is that water quality
protection is not a significant factor in making
ground-water allocation decisions. With regard to
percolating waters upon which most State ground-
water law is based, there exist five basic categories
of law in use among the various States.
     The absolute ownership rule, reasonable use
rule, and restatement rule fail to address the issue
of depletion of a ground-water reservoir. Under
the absolute ownership rule a landowner may
withdraw ground water without regard to either
the impact on neighboring landowners or the
depletion of the ground-water reservoir. Under the

reasonable use rule a landowner's right to with-
draw ground water will be restricted only if it is
wasteful, is located on distant or nonoverlying
lands, or both. Otherwise, a landowner may
withdraw ground water without regard to ground-
water reservoir depletions. The restatement rule
makes landowners liable for their unreasonable
interference with other ground-water uses, but
deliberately leaves the issue of ground-water
reservoir depletions for legislative resolution.
     The correlative rights doctrine addresses
depletion of ground-water reservoirs in theory  by
prorating the "safe yield" of an aquifer among
ground-water users.
     Approaches for dealing with ground-water
depletions  vary under prior appropriation. The
basic principle that a junior appropriator must stop
using water when his withdrawals conflict with
those of senior appropriators provides one method
for resolving disputes among ground-water users,
but does not prevent the depletion of ground-water
reservoirs.  In some appropriative States the amounts
of ground water  withdrawn may be reduced in
critical ground-water areas. This is essentially a
modification of the correlative rights doctrine
with an administrative determination of the
allowable level of ground-water withdrawals.
     Some sources of ground-water pollution are
directly related to ground-water allocation
policies. Saline intrusion often occurs in coastal
areas where ground-water withdrawals result in
ground-water levels lower than salt-water levels,
allowing the intrusion of salt water into the aquifer.
In the West, use of ground water for irrigation may
also cause ground-water pollution. Excessive
ground-water use may result in the leaching into
the aquifer of agricultural chemicals including
nitrates from fertilizer and organic decomposition,
herbicides and pesticides.
     Ground-water allocation policies also  affect
surface waters. Where excessive withdrawal
occurs, ground-water contributions to stream flow
decline, inducing aquifer recharge from stream flow.
Eventually, stream flow is reduced, reducing the
surface body's assimilative capacity and its ability
to sustain fish and wildlife.  In some situations,
the stream  may dry up.
     To cover adequately the  major causes of
ground-water pollution, I would like to discuss
briefly the  relationship of landfills, septage fields
and wells to ground-water contamination.
     Innumerable waste materials and natural and
man-made products with the potential to pollute our
ground waters are stored or disposed of on or
beneath the land surface. There are over 150,000
land disposal sites in the Nation. Contaminants
found in the ground water beneath these sites
cover the entire range of physical, inorganic and
organic chemical, bacteriological and radioactive
parameters. Waste materials are often stored or
deposited on land surfaces whereby percolation of
rain through the material will carry certain of its
constituents downward modifying the natural
quality of the underlying aquifers.
     Ground-water  contamination is  also caused
by the discharge from on-site disposal systems
(septics)  of water containing dissolved and other
constituents which eventually reach the water table.
The threat of pollution becomes more serious if
the system is not regularly pumped. The most
critical factors influencing ground-water contamina-
tion on a local and regional basis, however, are
the density of on-lot disposal facilities, the
permeability of the  ground and the depth to water.
     Improperly constructed wells are also a cause
of ground-water degradation. If they  do  not
contain a surface seal, or if the seal leaks, poor
quality surface water may enter subsurface waters.
To avoid contamination, proper well  design must
consider  the type of aquifers penetrated, the
quality of waters in each and the relative water or
pressure levels existing. Poor quality aquifers must
be sealed off to prevent interaquifer exchange.

     Ground-water problems are generally local
or regional in nature. State  law historically has
placed few restrictions on withdrawals from
underground reservoirs, and therefore, indirectly
foster ground-water pollution. Ground-water
protection through regulation is best  accomplished
by the States or by regional entities who know
best what community needs are and will be, who
know best  how to balance competing demands
upon capital and operating  budgets and who know
best how to operate within their unique  ground-
water legal systems.
     But what of the Federal role? The appropriate
ground-water protection role for the Environmental
Protection Agency is to develop programs which
will allow the Agency to utilize its resources to
help States and local governments solve their own
problems. The Agency should provide technical
and financial assistance to State governments and
areawide agencies which implement the relevant
programs. Evaluation of State or areawide programs
for progress achieved and substantive quality is

also a necessary Federal function.
     But I do not see, given the facts, a direct,
overarching, Federal role. It is simply not the right
level at which to address the problems of ground-
water protection.
     While there exist several separate and distinct
EPA ground-water protection programs, including
the Underground Injection and Sole Source
Aquifer Programs under the Safe Drinking Water
Act and the RCRA land disposal program, among
others, I believe that the Water Quality Management
program will prove to be the invaluable Federal
mechanism in the prevention of ground-water
     As we have seen, the Water Quality Manage-
ment program brings together  all levels of govern-
ment and all relevant point and nonpoint sources
and ground-water quality programs. Available
resources with which to plan and implement
abatement and prevention programs, whether for
ground or surface waters, can be brought to bear
through the water quality management process.
State and local experts, assisted by Federal funds
and technical know-how, will develop plans to
solve their own ground-water problems. It is likely
that integrated into their recommendations will  be
regional socioeconomic, demographic and
political considerations.
     As the Water Quality Management program has
developed over the years, it has acquired a wealth
of experience concerning water quality control.
From the initial emphasis on getting the program
going and developing guidance, we have had an
opportunity to analyze where  we have been and
where we want to go. We have acquired a better
understanding of water quality problems as they
relate to water quality management. We have
assessed our successes and failures, our strengths
and weaknesses and the proper role of the Federal
government  in water quality management. We have
determined that our process is unique and can
accommodate most every program impacting
water quality. And, as we are on the verge of
receiving the initial round of 208 plans, we have
had to think about their implementation.
     The State/EPA Agreement is the major tool
with which we have decided to reorient our
Program. Next year this mechanism integrates
water quality planning, management, implementa-
tion and evaluation programs.  In the future all
water programs  and other EPA efforts will be
     Its major feature is that it permits the States,
in consultation with the EPA Regional
Administrator, to determine their own needs
and priorities. Programmatic problems, perhaps
institutional, resource deficient or legal in nature
will be identified and prioritized as well. The
States will also consider the broad panoply of
programs and funding sources, both Federal and
State, which might be brought to bear to resolve
their priority problems. They will be limited only
by EPA's own national goals, eligibility require-
ments and most of all, by their own creativity in
determining their approach to getting the job done.
Their focus is upon problem resolution, not upon
     The Agreement will serve as a management
tool for both the States and the Federal govern-
ment. It represents a State commitment to accom-
plish its own identified and prioritized outputs in
the coming year. It includes a detailed, integrated,
intermedia workplan  (which by itself serves to
reduce the paperwork burden). By identifying all
State and Federal sources of funding in advance,
the States and EPA Regions can better determine
whether sufficient  funds are available for obligation,
whether they may  be used for the purpose intended,
or whether alternatives to proposals exist.
     The Agreement, then, sets a baseline for State
and Federal evaluation efforts with which we can
more accurately measure success and pinpoint
     The State/EPA Agreement applies to ground
water as well as it does to any other resource
problem. The separate States each have their
own water quality  problems.  Some have ground-
water problems and others do not. Of those
that do, some are more  severe than others, and
the causes of the contamination may differ.
Each of these categories may be addressed in the
     Each State having a ground-water problem is
free to assign a priority  to that problem in
relation to its other water quality management
needs. We can assume that such problems will be
assigned high, middle or low significance  depending
upon the State's own ranking. The State will also
identify the sources of funding which may be
applied to problem resolution. To solve a ground-
water problem a State may use funds from the
Clean Water Act under the Program Grant (106),
Construction Grants (201) and the Water Quality
Management (208) sections. Relevant sections of
the Resource Conservation and Recovery Act may
also be utilized.
     Programs too, will be State designed. If a land
disposal site, for example, is polluting an underlying

aquifer, a program to remedy the problem can be
fashioned and implemented through the Agreement.
An areawide agency may be identified to complete
planning and a management agency may be
designated, upon appropriate State and local
approvals, to implement the plans. In this case,
sections 106 and 208 of the Clean Water Act,
section 1424, Sole Source Aquifers, of the Safe
Drinking Water Act and the 3000 series, Hazardous
Wastes, of the Resource Conservation and Recovery
Act are, at a minimum, applicable to the
development of a comprehensive solution to the
     The State/EPA Agreement contains benefits
for the States and for EPA. Its major advantage is
that the States will be able to bring maximum
resources together to solve their priority problems
in a systematic manner.
     I would like to thank you for this opportunity
to speak to you today. In closing I will pledge the
efforts of the Water Quality Management Team of
EPA to do our share in solving the ground-water
protection problems of this country. I firmly believe
that with the 208 program and other EPA programs
melded together through the State/EPA Agreement,
States and local governments will have the Federal
tools to solve their existing and potential  ground-
water problems.
     Merna Hard, P.E., is Director, Water Planning Division,
Office of Water Planning and Standards, U.S. EPA. Educa-
tion: University of Nebraska - B.S., 1964; M.S., 1969.
Hurd has worked as Director, Water and Sewer Management
Office, and Director of 208 Program Administration, and
Senior Planner, New Castle County, Delaware; and as a
Consulting Engineer with Harold Hoskins & Associates,
Inc., Lincoln, Nebraska.

The   208  Planning  Approach  to  Ground-Water
Protection  —  A  Foot  in  the  Doora
by Donna Wallace
     The benefits of employing the 208 planning approach
in the protection of surface water or ground water are
twofold—one, involvement of the public early in the planning
process and two, determination of solutions that are
implementable. With increased public awareness precipitated
by the required involvement in Water Quality Management
Planning (WQMP), the ensuing public interest will ultimately
force ground-water issues which have been neglected for
many years. The preparation of a "5-Year Strategy" in
each State coupled with USEPA's new emphasis on aquifer
protection as a priority issue will provide the mechanisms
for funding ground-water planning under 208 programs.
As the cry for ground-water management planning is
adopted by the public as well as technicians, emphasis will
shift and programs will develop. In addition, planning
programs under 208  are usually regional in nature in
contrast with the ground-water studies in recent years
which have been site-specific, directed toward the identi-
fication and alleviation of local problems. Since the
management approach requires that the evaluation of
available alternatives include those mechanisms necessary
to implement the recommendations, viable alternatives
without either management  agencies or financial
considerations will not be acceptable. Therefore, the strength
of the WQMP approach to ground-water protection lies in
those concepts that make planning under 208 a new breed
of governmental program.
      Presented at The Fourth National Ground Water
Quality Symposium, Minneapolis, Minnesota, September
20-22, 1978.
     b208 Program Coordinator, Planning and Standards
Section, Illinois Environmental Protection Agency, 2200
Churchill Rd., Springfield, IL 62706.
     Ground-water management planning becomes
more significant each year as the disposal of wastes
is directed away from rivers and streams and toward
the land. In an effort to provide cleaner streams,
regulations require removal of most pollutants
before discharge to surface water.  These
contaminants are later placed in sanitary landfills
in the form of sludge or liquid wastes. Both
hazardous/toxic and nontoxic residual wastes from
industries find their way to land disposal as well as
those leftover materials from man's activities in
general. As pollutants move toward the land, the
potential for ground-water pollution increases, and
ground-water protection becomes  more significant.
Until recently, ground-water management planning
has been generally overlooked, but a new planning
approach has begun to offer some hope in terms of
ground-water planning issues. The 208 planning
approach is a combination of some old programs
that  produced, or were to produce, water quality
management plans, and the addition of a very new
concept in Federal planning programs designed to
put the plans formulated under the 208 program
into  practice. The general opinion at both the State
and  Federal level is that  the 208 approach has a
better chance of being functional than past planning
programs. If this is found to be true and if ground-
water quality management planning can be drawn
under this umbrella, States may finally find the
mechanism for the long-awaited planning needed
to protect ground-water resources.

     Ground-water protection in Illinois is similar
to that in many States, significantly behind a few
progressive States, and somewhat ahead of a few
seriously lagging States. In general, when ground-
water pollution problems are discovered, detailed
site-specific studies are designed, data collected
and evaluated, causes identified, solutions
determined, and, when necessary, enforcement cases
prepared. This type of activity could be more
accurately termed  "remedial action." The protection
portion of the ground-water activity in Illinois
centers on the Illinois regulation that no source may
cause or contribute to causing a water quality
violation. Since ground water continues to be
considered waters of the State, ground-water
pollution is also covered under this regulation.
The improvement or maintenance of water
quality resulting from regulation  is, however,
dependent upon the degree of enforcement
applied. In ground-water pollution, as in that of
surface-water quality, only the major cases of
pollution justify the time required to prepare
legal action and to provide the data necessary to
prove that pollution can be attributed to a single
source. Therefore,  in reality, water pollution, both
surface and ground, is held to a minimum level
as much as possible within the resources of the
existing programs.  Although this approach
provides a reasonable degree of protection in terms
of control, there is not a high degree of planning
for the management of future ground-water
quality and quantity.
     Illinois can rightfully claim to have a
reasonably  successful statewide 208 Water Quality
Management Planning Program, although it has
not been advanced in terms of ground-water
planning. Due to the levels of Federal funding
available for statewide planning, certain decisions
were made early in the program to limit the
pollution sources to be studied to those most
likely to result in implementation. This
narrowed the scope of the program but aided in
maintaining realistic objectives that allowed
planning to progress beyond the problem assessment
phases in those areas under study. Ground-water
pollution problems were not seen as belonging
in the category likely to yield solutions. In fact,
the history of ground-water management planning
in Illinois suggests a small commitment to address
ground-water planning that managed to get smaller.
More importantly,  in terms of the initiation of
ground-water planning, the lack of commitment
 appeared to be common with both the Illinois
 EPA and the USEPA.
     Two major obstacles stood in the path of
 ground-water planning initiation in Illinois. First,
 the three designated areas in Illinois where specific
 problems had been identified were funded early.
 This left the statewide agency, IEPA, significantly
 underfunded and programs were severely restricted
 as noted earlier. In designated areas where funding
 was more realistic, the areas covered were so small,
 19 of 102 counties, that results of studies com-
 pleted within them were not representative of
 the State as a whole. Therefore, localized studies
 were not likely to result in statewide policy
     Second, Illinois has an extremely compre-
 hensive historical ground-water quality data base
 scattered among half a dozen State agencies.
 However, only one of these agencies has the data
 readily available on a computer. No agency engages
 in ground-water management planning as a major
 portion of its activities. This requires that Illinois
 begin ground-water efforts at the data
 compilation phase. Data evaluation efforts appear
 productive and even data collection efforts seem
 reasonable, but there is little marketable in data
 compilation efforts. Program managers understood
 that neither the public nor USEPA can visualize
 data compilation as providing early outputs.
 Therefore, once the initial 208 program was defined
 with minimal ground-water emphasis, it became
 even more difficult to secure funding.

     Although in most States surface-water quality
 management planning has been addressed for five
 to ten years, Federal and State programs have not
 been totally successful. Past approaches to planning
 for surface-water protection have resulted in data
 collection, evaluation, and the preparation of
 plans that generally were not implemented. This
 is where  the 208 approach differs from past
 planning programs. The 208 concept addresses
 three new requirements for plans prepared with
 Federal funding. (1) Plans must have continual
 public involvement, (2) alternatives must include
 the definition of mechanisms for implementation
 and (3) plans must be updated annually to reflect
 the results of each year's progress. This suggests
 that the public must have a hand in determining
which solutions should be  selected since funding
for implementing alternatives is not provided in
 the 208 program. In addition, the  solutions are
 to be implemented and not simply discussed and

shelved, and changes in solutions may occur as a
result of additional studies. To ascertain that
implementation strategies be carried out, much
of the Federal funding for other State pollution
programs has been tied to the success of 208.
Therefore, there is reasonably strong Federal
support for successful State 208 programs-
addressing surface-water pollution.
     The mechanisms built into the design of
208 planning which aid surface-water planning will
aid in the establishment of direction of 208 studies
for ground-water quality as well. Under the 208
approach, nonpoint sources are addressed in the
following general manner:

     1. Problem assessments are designed and
performed to determine the relative  contribution of
each source and priorities are established.
     2. Alternatives are defined for control of
significant pollution sources and evaluated in terms
of the ability to implement each alternative.

     3. Recommendations of alternatives that best
fit the needs are determined from an examination
of costs versus benefits.
     4. Implementation strategies for the
recommended alternatives are determined and put
into  practice.

     5. Evaluations of the effectiveness of the
alternatives are conducted after implementation has
     6. New recommendations are made based on
new  information or if old recommendations are
shown to be ineffective.

     Although site-specific studies and evaluations
are allowable and in some cases necessary,  the 208
planning approach requires that nonpoint problems
be addressed  on a statewide basis. Therefore, if
208  planning operates properly, controls will not
be placed on  one source of ground-water pollution
(wastes placed in sanitary landfills) while ignoring
others (improper installation of ground-water
monitoring wells). In most cases, these controls
will also be applied in a similar manner on  a
statewide basis.
     But until recently, 208 has been of little value
in producing  any direction for ground-water
planning in other States as well as Illinois.  Initial
208  plans in most States barely address ground
water, if at all. Federal funding for the States'
portion of 208 planning has been at a minimum
due to the late recognition of the necessity of
statewide 208 planning. The bulk of the early
Federal funding for 208 planning was provided
to areas where specific sources of pollution could be
identified and planning was initiated early to address
those identified sources. With funding levels low,
State program administrators were required to
identify those issues most significant and familiar;
and, with implementation a major issue in 208,
priority was given to those sources of pollution
most likely to provide implementable solutions.
Generally ground-water pollution did not qualify
as either significant or familiar. A few token studies
were initiated but, as ground-water technicians
were quick to realize, funding levels were far too
low to provide definitive results.
     Once the initial 208 plans have been completed
nationwide, a more favorable  climate should exist
in terms of ground-water studies. Most States will
have found that the control of point sources has
been defined but that the contribution of these
sources to surface-water quality is relatively low
compared to that of nonpoint sources. In addition,
the most significant nonpoint sources in each State
will have been addressed and the level of contribu-
tion defined. In only a few States, ground water
itself was identified as a major nonpoint source.
Program administrators and planners will begin to
identify the degree of control that will be achieved
as a result of implementing these initial 208 plans
so that the scope of future planning programs can
be redirected. Since 208 has required elaborate
public participation programs from its inception,
this direction for the future planning programs will
have to come, in part, from the people. If planners
are to be successful in determining the relative
contributions of nonpoint sources so that
pollution problems may be controlled, planners
will also influence the direction of the program.

     While future 208 programs are being designed
at the  State level, some significant activities have
occurred at the Federal level which will impact the
States' decisions. Since the 1977 Clean Water Act
called  for  the examination of all State water quality
management programs in terms of overlap or gaps,
USEPA has defined an expanded list of priority
areas for 208 funding. This list includes, among
other point and nonpoint sources, salt-water
intrusion and aquifer protection. The USEPA
rationale is that (1) 208 has proven itself to be a
viable  program for the solution  of water pollution
problems and (2) funding for planning is not
presently available under related Federal programs

 (Safe Drinking Water Act, Resource Conservation
 and Recovery Act, etc.). Thus, USEPA has laid
 the groundwork for including planning for ground-
 water protection in future 208 planning programs.
     It must be understood that recognition of
 ground-water issues by water quality planners is
 only an initial step. Once their attention has
 turned to ground water, the second major issue
 of overlapping authority among State agencies can
 be addressed. Although surface-water quality
 authority is relatively fragmented, responsibility
 for ground-water quality and quantity appears to
 be even more so. Control of the various pollution
 sources rests with one group of State authorities
 while the quality and relative availability of the
 ground water itself rests with a second group.
 With little funding directly tied to ground-water
 management, efforts in most areas have been
 minimal, of necessity, and fragmented. It is
 obvious that a program to address all aspects of
 planning for ground-water protection must be
 established. The importance of such a program will
 not lie in which agency is actually performing the
 data collection, analysis, and description of
 alternatives but instead in the interrelationship of
 the proposed alternatives, in the inclusion of all
 significant sources of ground-water pollution, and
 in the determination of the levels of protection
 that are both technically and economically
     Federal guidelines suggest that USEPA also
 recognizes this need. As mentioned previously,
 ground-water programs have been added to the list
 of sources to receive priority Federal funding; and
 USEPA has determined that preplanning of future
 directions of 208 will occur prior to  the release of
 the remaining 208 funds. The mechanism to
 establish this preplanning,  called annual Water
 Quality Management Planning (WQMP) programs,
 is the requirement that States prepare a "5-Year
 Strategy" delineating the status of planning, the
problems not yet solved, and the programs to be
initiated to solve these problems. In terms of
ground water, one of the most significant require-
ments is that this "Strategy" not be prepared solely
by State program administrators. 208 calls for
public involvement and the strategy follows suit.
Not only do citizens have to be allowed to react to
the proposed programs but other agencies must
describe how their activities will be related to that
which is proposed. As the program progresses, the
strategy must be fine-tuned and updated annually.
But most importantly, this strategy must actually
describe the studies to be performed, who will be
responsible for completing the work, how much it
will cost, and when each study will be initiated.
The first "5-Year Strategy" for each State is to be
submitted to USEPA in September. Once this
document is approved, some form of interagency
coordination will be required. Therefore, develop-
ment of planning for ground-water protection will
require the coordination of all agencies involved in
ground-water studies.

     The outlook for ground-water planning began
to improve late in 1977 when two proposals were
submitted to USEPA in request of supplemental
FY'77 funding. The first would have expanded the
ground-water studies to a minimally acceptable
level. The second was to assess the impact of oil
field brine disposal. Although USEPA rejected
the first proposal, they did fund the second,
concerning oil field brine pollution.
     It appeared that Illinois EPA was beginning to
recognize the need for ground-water planning but
USEPA still seemed hesitant. The turning point
came in early 1978 when USEPA agreed  that if
ground-water proposals were included in the
requests for FY'78 funds, they would be given
careful consideration. True to their word, Illinois
has just received $120,000 in USEPA 208 funding
to begin ground-water management planning on a
statewide basis. And the situation is still improving.
     In September, Illinois submitted to  USEPA
their strategy for the funding of Water Quality
Management Planning studies over the next five
years. The commitment to ground water was ten
percent of total budget or two and a half million
dollars. The initial studies were, of necessity, data
compilation efforts. Once the data compilation and
collection is completed, the following studies
address problems concerning the major sources of
ground-water pollution. Two full years have been
devoted to actual policy preparation and evaluation
for ground-water management. Following are the
five-year objectives for the ground-water program:

     1. To compile the existing data to provide a
comprehensive data base for use in management
     2. To locate and determine the contributions
of significant sources of ground-water pollution.

     3. To determine the ground-water contribu-
tions to surface-water quality in those areas where
background concentrations cannot be explained in

terms of known point and nonpoint sources.
     4. To determine the regional flow systems and
the recharge areas for ground water.

     5. To determine which areas have a high
potential for ground-water contamination.

     6. To examine the problems associated with
existing and abandoned public water supply wells
and nonpublic water supply wells.

     7. To evaluate the impacts of industrialization,
underground injection, artificial recharge, and land
disposal on ground-water quality.
     8. To project future ground-water quality
based on existing and proposed practices.

     9. To develop the necessary State policy,
regulations, and/or legislation to control ground-
water degradation.

     The initial directions that ground-water
management planning will take should be fairly
well defined by late  1978, considering the
schedules established by USEPA. It is the fine-
tuning that will occur after this time that will more
significantly influence the ground-water planning in
the nation. Initial strategies will probably address
ground water in terms of some planning
studies identified, but development of the
alternatives required for protection of ground water
will only come as  a result of the problem assess-
ments once they have been completed. Although
past experience with surface-water planning will
aid in the development of ground-water planning,
control  programs require time for development,
and implementation is slow. A possible scenario
for minimal ground-water planning follows.
     "Point and significant nonpoint sources of
   surface pollution will be identified  and
   reasonable controls determined. The resultant
   water quality will be evaluated, often by
   means of complicated water quality
   modeling. This  water quality to be expected,
   following implementation of previously
   identified controls, will then be evaluated as
   to the relative contributions that can be
   attributed to other nonpoint sources and those
   that can be  claimed as naturally occurring and
   therefore not controllable. That contribution
   claimed as natural background will be described
   as the result of  geologic conditions including
   the ground-water contribution."
     At this point, if ground-water quality manage-
ment has not received sufficient emphasis, the
technical and social outcry will be loud. Efforts to
claim excessive levels of unusual contaminants
(heavy metals, for instance) to be naturally occurring
in ground water will immediately establish the need
for more detailed ground-water evaluation. If
program managers miss this important linkage, the
public, who will be expected to pay the bills for
other controls, will not. Therefore, the evaluation
of initial 208 programs will force ground-water
quality evaluations on a regional basis.
     Obviously, all ground-water problems may not
be addressed if the needs of ground-water quality
studies and planning are not recognized on their
own merit. Quite possibly, the entire ground-water
question could result in the definition of the contri-
bution of ground water to surface-water quality
and little else. Should this occur or appear likely
to occur, the public may well express the opinion
that such conclusions are a  whitewash and more
careful examination is not only warranted but
     Past experience with 208 planning has shown
that the public, especially special interest and
environmental groups,  are remarkably well informed
and certainly vocal. This group, the informed public,
is unlikely to be satisfied with the basic description
of ground-water quality as naturally occurring. So
that, if program managers fail to move into mean-
ingful ground-water management planning programs,
the public will insist on evidence that polluted
ground-water quality should be  claimed as natural.
If ground-water pollution is shown to be caused by
man and his activities, solutions will have to be
forthcoming. Since 208 cannot avoid public input,
it cannot totally ignore public advice  or comment.
Therefore, regardless of early or late recognition,
the results will ultimately be unavoidable and
ground-water planning will be initiated.
     The real question facing the ground-water
planning proponents is how this process can be
insured or better yet, hurried. It seems apparent
that NWWA has recognized the positive aspects of
the 208 planning approach since this topic was
included in a program addressing significant ground-
water issues. It would also seem that those who
attended the Symposium see a need for ground-
water planning. Obviously, there is no cookbook
remedy for lagging ground-water efforts but a
number of opportunities are now available to those
believing in both the need for and value of 208
     First, as a citizen, planner, or technician, insist

on a copy of your State's "5-Year Strategy." Check
carefully for the direction of ground-water planning
as envisioned by program managers. One of the
significant aspects of strategy development is the
requirement for an annual revision; therefore, the
lack of a well defined program for ground-water
planning is not irreparable if recognized.
     Second, get involved in the 208 planning
program. States are required to have elaborate
public participation programs with weight on the
participation of local elected officials. Remember
local mayors and councilmen may not understand
the impacts of ground water in their areas.  Visit
them and explain your concerns.
     Third,  and most important, share your interest
and abilities with those involved in doing the actual
planning. Do not smile knowingly when ground-
water quality is generally claimed as a "given" or
worse—natural. Forget apathy, get involved, be heard!
     Donna Wallace is the 208 Program Coordinator for
Illinois' Water Quality Management Planning Program and is
also responsible for the ground-water portion of the technical
studies being performed under this program.  Donna holds
an M.S. in Geology from Iowa State University at Ames
and has taken post-graduate studies in both environmental
engineering and public administration. During her five years
of employment with Illinois EPA, she has been responsible
for the implementation of the State's ground-water
monitoring program for sanitary landfill sites and
coordinated the preparation of the State's Basin Plans, the
predecessor of 208 planning.

The  208  Planning  Approach  to  Ground-Water
Protection  —  What  Is  Wrong  and
What   Can  Be  Done  About  It?"
by Kenneth D. Schmidt
     Generally, the 208 planning approach is deficient in
a number of ways. Its origin lies in Public Law 92-500,
which focuses on protection of surface water and special
uses of water for fish, wildlife, and recreation. Little
ground water is used for these purposes. Nonpoint sources
have not been defined in terms that have hydrogeologic
significance. Local and State regulatory agencies have
often been unsuccessful in controlling ground-water
pollution, yet the 208 approach tends to disregard the
reasons for this situation. The reasons for ground-water
pollution in an area must be understood before
meaningful control measures can be enacted. These
include both technical and institutional problems.
     Planners are placed in the forefront of many 208
programs at the local level and often their backgrounds
are inadequate in ground water. There is a great lack
of ground-water professionals in regulatory agencies
involved, particularly in the Southwest. This deficiency
is paramount at high levels and in many regional offices
of EPA. There are no provisions in the approach to insure
that qualified ground-water geologists or hydrologists
will be involved. Academic training in ground water is
presently oriented toward ground-water development and
not pollution. Lastly, public participation is greatly
limited by the general lack of knowledge regarding ground
water and its pollution.
      Presented at The Fourth National Ground Water
Quality Symposium, Minneapolis, Minnesota, September
20-22, 1978.
     ^Ground-Water Quality Consultant, 1111 Fulton Mall,
Suite 306, Fresno, CA 93721.
     Successful 208 programs in terms of ground water
have been enacted when ground-water professionals have
had major roles. Changes are necessary in the academic
training of ground-water geologists and hydrologists.
The public must be educated concerning the long-term
consequences of ground-water pollution. Lastly, ground-
water professionals must assume the leadership in
ground-water protection.

     There are numerous deficiencies in the 208
planning approach, particularly with respect to
ground water. Many of these deficiencies are
common to other water pollution control
approaches at the Federal and State level. It is
the author's objective to discuss what is wrong with
the 208 planning approach in terms of ground-water
quality protection. In addition, remedial measures
are proposed  that could correct some of the
deficiencies in the present approach.
     One of the major problems with the 208
approach is obvious in reading Section 101 of
Public Law 92-500. Although the objective of the
act is "to restore and maintain the chemical,
physical, and  biological integrity of the Nation's
waters," a number of specific goals and policies
were stated that effectively ignore ground water.
Navigable water, waters of the contiguous zone,
and the oceans were all given special attention.
Also, special uses of water were to be protected,
namely fish, shellfish, wildlife, and recreation. On
the other hand, the major uses of ground water

in the U.S. are for irrigation, public supply,
domestic, industrial, and mining purposes. It is
my opinion that these are far more important
than the special uses designated for protection in
Public Law 92-500, as only an insignificant
amount of ground water is used for the special
     A careful review of Public Law 92-500 clearly
indicates an overwhelming emphasis on surface-
water quality. This emphasis has hopefully resulted
in some improvement in surface-water quality since
1972; however, much of this improvement has
occurred at the direct expense of ground-water
quality. The number of potential sources of
ground-water pollution was greatly increased
through implementation of portions of Public Law
92-500 and air pollution regulations. Examples
include disposal of sludge and effluent from new
and expanded sewage treatment plants, and on-site
disposal of wastes formerly disposed indiscrim-
inantly to sewers. The present emphasis on land
disposal or treatment will undoubtedly create
numerous new potential sources of ground-
water pollution.
     Despite the fact that the Safe Drinking Water
Act (Public Law 93-523) indicates a strong concern
for the quality of drinking water, there has
apparently been no similar concern at the Federal
level to protect water used for irrigation,
industrial, and  mining purposes. In the western
U.S., much more ground water is used for these
purposes than for drinking water.

     Besides virtually ignoring ground water,
Public Law 92-500 also deals primarily with
humid area problems. An example is emphasis on
treatment of sewage and industrial wastes which
often were formerly dumped untreated or poorly
treated into streams, particularly in the eastern
U.S. While sources such as sewage, industrial
wastes, and storm runoff may comprise the major
sources of surface-water pollution, they may be but
minor sources of ground-water pollution. There are
no perennial streams in much of the Southwest
and wastes are disposed to the land or to  inter-
mittent or ephemeral streams. The major  uses of
such streams are obviously not for  the special uses
to be protected, as specified in Public Law 92-500.
Instead the major use may be for ground-water
recharge. Curiously enough, the use may apply to
the stream bed instead of the water in the stream.
     A common situation in arid lands that may
be unusual in many humid areas is the long time
required for pollutants to travel from the land
surface to the water table. This travel time is
commonly decades or even centuries in arid areas.
Additional time is required for pollutants to travel
from near the water table to the producing zone
of a well and thence to the well. Ground-water
pollution ordinarily cannot be seen even when it
occurs. The combination of these and other
factors renders ground-water pollution a much
different entity than surface-water pollution,
particularly in the western U.S. Public Law
92-500 fails to recognize this difference and its
importance for protection of ground-water quality.

     In terms of surface  water, a point source may
be rather obvious—namely, a waste  discharge from
a pipeline  or other discrete structure. The term
"nonpoint source" has been used for diffuse
sources of pollution. An example is storm runoff
into streams, whereby pollutants can be introduced
over a great distance and not just at one point. The
terms "point and nonpoint sources" as used in
Public  Law 92-500 have  limited significance in
terms of ground water. For example, in some 208
programs, "point source" has been used for sewage,
regardless  of the method of disposal of the effluent
or sludge.  Alternative disposal methods include
ponds, normally dry stream channels, irrigation,
and landfills. All other sources of pollution are
termed nonpoint sources, regardless of the type of
waste or the method of disposal.
     Sources of ground-water  pollution should be
defined in terms that have hydrogeologic signifi-
cance.  Hydrologists have customarily spoken of
recharge from point, line, and diffuse sources.
Schmidt (1976a) proposed a similar use of this
terminology for sources  of ground-water pollution.
Point sources occur over small areas, and include
percolation ponds, landfills, and disposal wells.
Line sources have the length dimension much
greater than the width, and include discharge to a
normally dry stream channel and  leaking sewers.
Diffuse sources occur over large areas, and include
suburban areas on septic tanks and return flow
from crop irrigation. The type of source is important
in designing monitoring programs and formulating
control measures.  Since an evaluation of ground-
water pollution starts at  the source, the importance
of source evaluation should not be overlooked.
Several EPA publications dealing with nonpoint
sources (U.S. Environmental Protection Agency,
1973 and 1976) have little direct relevance to
ground water.

    Much of Public Law 92-500 deals with waste
treatment management. "Waste treatment" is
somewhat of a strange concept to ground-water
geologists and hydrologists. Most specific types
of waste treatment have been directed toward
disposal of wastes to surface water, odor considera-
tions, or some other concern. An example is
reduction of suspended solids content and bio-
chemical oxygen demand for sewage. Few examples
of waste treatment designed specifically for ground-
water disposal can be found in the literature.
Instead, the usual procedure has been to evaluate
the soil and other nonstructural factors. If these
factors cannot be managed to preclude ground-
water contamination, a liner is used to limit
infiltration or seepage loss. This concept is in
diametric opposition to classical structural
solutions. These "solutions" emphasize removing
specific pollutants from a waste stream prior to
    The concept of areawide waste treatment
management discussed in section 208 is but one
approach. An alternative approach begins with an
evaluation of the ground-water quality. The impact
of waste disposal is determined, and then the type
and degree of waste treatment is specified, if any
is necessary. Sewering is  an informative topic
relevant to this concept. It is questionable on a
national scale whether sewering has improved
ground-water quality or not. Certainly new
sources have been created, such as thousands of
miles  of sewers that may leak. Secondly, the
concentration of wastes in small areas due to
regionalization of facilities, which was formerly
widely promoted as the best alternative, tends to
pollute ground water. The latest findings for
disposal of effluent by percolation suggest that
primary treatment is preferable to secondary
treatment for nitrogen removal, which is one of the
major concerns. Also, chlorination of effluent may
not be desirable if disposal is by percolation.
Sewering in itself can adversely affect ground-water
quantity in an area due to export of pumped
ground water to downgradient areas. It is now
becoming widely known that the adverse effects
of septic tanks were greatly exaggerated in many
areas  in order to promote sewering. These and
other factors bring into focus the question of the
meaning of "areawide waste treatment" in terms
of ground water. On a national scale, many of the
wastes that we are attempting to treat are not the
major sources of ground-water pollution.
Secondly, the method of treatment selected often
has nothing to do with ground water. Thirdly,
the method of treatment chosen often has a side
effect of polluting the ground water, due to the
production of sludge and other factors.

     At the local level, 208 planning has often
been attempted by the planning community. In
general, this group is deficient in both academic
training and work experience in geology, water,
soils, water quality, and ground water. All of
these disciplines are integral parts of a 208 program
where ground water is to be properly considered.
The end result in many 208 programs where there
has been insufficient input by ground-water
professionals has frequently been a waste of large
amounts of money and several years of time.
Without qualified ground-water geologists and
hydrologists involved, meaningful plans cannot be
formulated to protect the ground water. In fact,
plans may be  formulated which can seriously
pollute the ground water.

     The 208 approach focuses on formulation of
control  measures for nonpoint  sources of pollution.
As opposed to surface-water pollution, ground-water
pollution takes a much longer time to manifest
itself. Only some of the present sources of ground-
water pollution are susceptible to immediate
control  measures. This is because little or no
monitoring is available in most situations to
determine the nature and extent of the problem.
Thus only the most obvious sources offer potential
for immediate control. Examples include disposal
of brines and hazardous wastes in percolation
ponds or wells, where direct pollution of the aquifer
may occur. In most cases artificial liners may be
necessary to prevent seepage. The majority of
nonpoint source ground-water pollution is caused
by diffuse sources. Such sources will require
decades of monitoring before the impact on ground
water can be determined. The 208 approach
focuses too much attention on formulating control
measures and not enough on problem definition
and monitoring. In most cases, extensive monitor-
ing is necessary prior to development of realistic
control measures. This monitoring includes source
monitoring, assessing infiltration potential, and
evaluating pollutant mobility in the vadose zone
and aquifer.
     A common strategy in many 208 programs is
to rely on existing  data, without accomplishing
site-specific monitoring. Often this entails using

 previous reports which were not prepared for
 the purpose of protecting ground-water quality.
 Numerous recycled mythologies are quoted for
 decades in some areas, based merely on opinion and
 not on actual water quality data. For example, in
 the alluvial valleys of southern Arizona and parts
 of the San Joaquin Valley of California, it has been
 frequently stated that ground-water salinity is
 increasing beneath irrigated areas. Also, it is
 frequently stated that overdrafting increases the
 salinity of ground water. Neither of these
 generalities is supported by actual data. For
 example, extensive chemical analyses of ground
 water in  the Salt River Valley of Arizona since
 the 1920's indicate that the predominant long-
 term trend has been a constant salinity. The
 second most frequent long-term trend has been a
 decreasing salinity. The most infrequent trend has
 been one of increasing salinity, which has occurred
 only in two  specific areas due to altered ground-
 water flow directions. Salt balance calculations have
 been made which contain the assumption that
 there is no dissolution of minerals or precipitation
 of salt in the soil-aquifer system. Substantial
 increases in salinity of ground water with time  are
 projected from such calculations. The results of
 these calculations frequently do not agree with
 historic ground-water quality records. Use of
 recycled  mythologies can lead  to implementation
 of costly control measures for  no reason.
     In many areas, an abundance of records are
 available, but may not be collected or well
 organized. Data collection and organization itself
 may take several months or years, and must be
 done before interpretation is possible. With little
 or no understanding of the present or historical
 situation, there is little likelihood of meaningful
 control measures being formulated. Natural
 factors often exert a predominant influence on
 ground-water quality on a regional scale. The 208
 approach does not focus on distinguishing between
 natural and man-made factors that affect water
 quality. Such a distinction is necessary if man's
 activities are to be evaluated. Although natural
 factors may  not be subject to control, information
 on them  can be extremely useful for future
management of ground-water quality.

     If meaningful protective measures for ground-
water quality are to be formulated, the exact
reasons for ground-water pollution in an area must
 be known. Causative factors include: (1) indifference
or lack of knowledge of polluters, (2) lack of
knowledge and awareness of public, and (3) regula-
tory agencies. In some cases polluters are unaware
of the impact on ground-water quality of
their operation. However, in many cases wastes
are merely swept under the rug and into the
ground water. Limited data now available indicate
that there has been an extreme lack of concern,
particularly for disposal of hazardous wastes.
Protection of ground-water quality requires a
long-range perspective by water users and potential
polluters, often difficult in today's economic
     The public lack of knowledge of ground water
is extensive throughout the nation, as attested to
by the prevalence of water witching.  The meaning
of the word "hydrologist" is not understood by
many people. Presently there is little  concern for
problems that seem decades away. As such, the
public is susceptible to acceptance of the easy or
cheap short-term solution. With the public lack of
knowledge and apathy, it is difficult for the
public interest to be protected in matters of
ground-water quality. The environmentalists and
consumer advocates have yet to enter the field of
ground water in most areas. Politicians have had
little incentive to protect ground-water quality
when there is no pressure to do so. The long-term
solutions are often contradictory to short-term
     An important aspect of ground-water pollution
lies within the regulatory agencies themselves. In
my experience, they are often part of the problem.
The 208 planning approach is to go through the
State and local regulatory agencies. Ground-water
professionals familiar with the national state of
ground-water pollution must ask — "What have these
agencies done in the past, and what are they doing
now to protect ground water?" Often the answer is
little or nothing. This situation is well documented
in the excellent report on ground-water pollution
by hazardous wastes (Geraghty and Miller, Inc.,
1977). In many cases, regulatory agencies have
dealt with polluters behind the scenes, away from
public scrutiny. As such  it is difficult for the public
interest to be protected. Perhaps the biggest problem
is the lack of qualified ground-water professionals
in local, State, and Federal regulatory agencies. This
is particularly true in the Southwest.  Often sanitarians,
sanitary engineers, or civil engineers are at the fore-
front and their knowledge of ground  water is usually
inadequate. As proven in some States, excessive
amounts of money coupled with extensive regulations
do not insure ground-water protection.

     The 208 approach was developed with little
apparent hydrologic input. My opinion is that a
number of politicians and administrators and staff
of EPA throughout the country still lack adequate
knowledge of ground water. This is suggested by
numerous recent publications in which surface
water is still given predominant attention; for
example, the publication on nonpoint source
guidance—hydrologic modification (U.S. Environ-
mental Protection Agency, 1977). On a national
scale, there has been no mechanism developed to
enhance hydrogeologic input to regulatory
agencies. There is no provision in the 208 approach
to insure that ground-water professionals will be
involved. Hydrologists and geologists have taken a
back seat in most 208 programs to engineers,
planners, lawyers, sanitarians, soils scientists, and
others. The same situation is true in many other
EPA programs.
     Land disposal or treatment is another area
where there has been a lack of hydrogeologic
input. Numerous evaluations of the impact of land
disposal of wastes have been reported in the
literature by researchers with little or no training
in ground water (Schmidt, 1978). "Land treat-
ment" has been widely promoted and is given
special consideration under present Federal
policy. In fact, qualified people are not available
to operate the numerous proposed land treatment
systems. Secondly, there are not enough ground-
water professionals to properly monitor such
systems. Thirdly, little data is available from
existing systems due to monitoring deficiencies.
     Probably the only 208 programs in the
country where ground-water quality has been
successfully considered are ones where
experienced ground-water professionals have
assumed paramount roles, such as the Long
Island, New York and Phoenix, Arizona
programs. Ground-water geologists and
hydrologists must be placed in the leadership in
ground-water quality protection if meaningful
results are to be expected. This includes
professionals at high levels in EPA. Registration
or certification in ground water is  urgently

     In many respects, academic training of
ground-water professionals has a similar orientation
to that of a decade or two ago. Prime consideration
is usually given to ground-water development and
aquifer testing, and water quality may receive only
a minor consideration. The recent survey of
university classes in ground water on a national
basis by NWWA indicates only a few classes
devoted specifically to water chemistry or
ground-water quality. Also, ground-water training
has historically focused more on the part of the
soil-aquifer system below the water table than that
above. Investigations  of ground-water pollution
also involve the vadose zone, particularly for
diffuse sources and in arid areas. Pollution sources
and the vadose zone are more important
considerations in some situations than the aquifer
itself. Also, many hydrogeologists tend to be
poorly trained in chemistry. Soils chemistry, water
chemistry, and geochemistry are all important
aspects of ground-water pollution evaluations.
Many new ground-water professionals are being
asked to work extensively on ground-water
quality problems. Obviously, their academic
training is often inadequate for this purpose.
Schmidt (1976b) proposed a new approach for
the academic training of hydrogeologists who
specialize  in ground-water quality. This approach
includes specific training on pollution sources,
including courses in sanitary engineering, mining,
agriculture, and other fields. Ground-water quality
specialists must be well trained in water
chemistry, soils chemistry, and geochemistry.
Newly developed classes on ground-water quality
are necessary. Water and pollutant movement
through the vadose zone must receive greater
attention in academic education.

     The basic deficiencies of the 208 planning
approach relative to ground water stem from the
fact that the goals and policies set forth in Public
Law 92-500 emphasize protection of surface
water. Secondly, special uses are to be protected
which do not coincide with the major uses of
ground water. Many politicians and EPA
administrators and staff in decision making
positions have an inadequate understanding of
ground-water pollution.  This was true when
Public Law 92-500 was formulated and is still
true today. There is a serious lack of ground-
water professionals in local, State, and Federal
regulatory agencies. There are no provisions to
insure that qualified ground-water professionals
are involved in 208 programs. Lastly, ground-
water professionals are often poorly trained in
ground-water quality, partly because of the past
emphasis on ground-water development and the
quantitative aspects.

     Solutions to these problems include placement
of more ground-water professionals in local, State,
and Federal regulatory agencies. Ground-water
geologists and hydrologists must assume leadership
roles in ground-water quality protection. Pro-
visions are needed in the 208 approach to insure
that ground-water professionals are involved. The
public should be educated on a long-term basis
about  ground water and pollution. Academic
training  in ground water needs to be expanded and
ground-water quality elevated to the same level as
ground-water quantity. There is an urgent need for
registration in the field of ground-water hydrology
and additional development of the profession.

Geraghty  & Miller, Inc. 1977. The prevalence of subsurface
     migration of hazardous chemical substances at
     selected industrial waste land disposal sites. U.S.
     Environmental Protection Agency, Solid Waste
     Management Series. Report EPA/530/SW-634.
     166 pp.
Schmidt, K. D. 1976a. Monitoring groundwater pollution.
     Proceedings of the International Conference on
     Environmental Sensing and Assessment, Ground-
     water Section. Sponsored by EPA, WHO, and
     University of Nevada, Las Vegas. September 1975.
     The Institute of Electrical and Electronics Engineers,
     Inc. v. 1, session 9, no. 4, pp. 1-6.
Schmidt, K. D. 1976b. Academic training for groundwater
      quality specialists. In Hydrology and Water Resources
      in Arizona and the Southwest, v. 6. Arizona Section,
      AWRA. pp. 119-123.
Schmidt, K. D. 1978. Impact of land treatment of waste-
      water on groundwater. In Proceedings of National
      Conference on Environmental Engineering, Specialty
      Conference, Environmental Engineering Division,
      ASCE, Kansas City, Missouri, July 10-12. pp. 118-125.
U.S. Environmental Protection Agency. 1973. Methods for
      identifying and evaluating the nature and extent of
      nonpoint sources of pollutants. Office of Air and
      Water Programs. 261 pp.
U.S. Environmental Protection Agency. 1976. Loading
      functions for assessment of water pollution from
      nonpoint sources. Environmental Protection Tech-
      nology Series. Report EPA-600/2-76-151. 445 pp.
U.S. Environmental Protection Agency. 1977. Nonpoint
      source control guidance—hydrologic modifications.
      Office of Water Planning and Standards.
     Kenneth D. Schmidt received a B.S. in Geology from
Fresno State College and an M.S. and Ph.D. in Hydrology
from the University of Arizona. He has over 12 years of
•work experience in ground^water consulting. Since 1972,
he has been the principal of a firm  headquartered in  Fresno
and specializing in ground-water quality. His firm has
conducted numerous investigations of ground-water pollution
in the West. The results of his nitrate study in the Fresno
urban area were presented at the First National Ground
Water Quality Symposium. Schmidt was the General
Chairman of a national symposium on water quality
monitoring in June 1978.

Audience  Response  to  Session  VI  —  The  208  Planning
Approach  to  Ground-Water  Protection
Russ Stein, Chief, Division of Ground Water, Ohio EPA,
361 E. Broad St., Columbus, Ohio 43215: I agree with
both positions on this topic. I think in theory the idea of
208 planning is certainly a foot in the door, but I see some
problems because 1 think the preliminary plans that have
been developed so far are a terrible joke. I think the reason
for this is the fact that the 208 program has been put
together under a very strenuous schedule of completion.
      Our 208 staff consists of a large number of young
men and women who do not have any training; they do not
have any experience and their disciplines do not in fact
coincide with the job they're supposed to  be doing. As it
turns out, they really don't know what they're doing.
Consequently, we're ending up with biologists who are
working on sewage treatment plant plans,  and what
geologists  we do have are not working on ground water.
They are not that experienced in ground water. They're
right out of school, probably interested in other
specialties in geology. This was a job,  a lot of money
available. So consequently, I think there's a great need
to provide at some level, the training of these people.
Maybe it's too late now. I guess it is.
      My greatest problem with 208 planners is the fact
that I work in the same building with  them and I'm not a
208 planner. I would love to be able to sit down with these
people and possibly help train them, but I just simply
don't have time to do this.  Every other day I've got a
young man or a young woman coming down to ask me a lot
of questions that I could handle if I had the time.
      I would like to ask a question of Donna and possibly
Merna and Ken if you'd like to respond. Donna, did  the
State of Illinois have this problem, and if you are progressing
on this program,  how do you approach this within your
time frame?
      Donna Wallace, Illinois EPA, 107  S. Douglas,
Springfield, Illinois 62704: Is your question do we have a
problem with the quality of the people doing the planning?
      Russ Stein: Yes, that, and the training aspect of
getting some experience and expertise in this area  to do the
      Donna Wallace:  You bet. The 208 program builds on
top of the 303-E  base and planning program which builds
on top of  numerous other programs that came before. When
we got 208 planning in Illinois, we had a planning staff doing
303-E planning, which for Illinois was data collection only.
All we did was add more people, and  essentially the  more
people were two  different kinds. One, a group of
technicians which are still inadequate but  we're still
building, and a group of management public participation
type people who knew how to get to  the public because
they had some experience in planning the agencies in
general. We're not there yet either, and our first plan is
going to be pitiful. I think it's magnificent that we've
gotten this far. But  I think it's significant only in that we're
off the ground and moving, and this is a very new field
for almost everyone.
     Jay Lehr, Executive Director, NWWA, 500 W. Wilson
Bridge Rd., Worthington, Ohio 43085: Perhaps some
advice we might offer Merna is that the initial plans
completed anywhere close to the deadline might be taken
with a grain of salt and some mechanism developed where
they could be reviewed and revised, especially with Ken's
point of view that a lot of it was recycled mythology.
     Merna  Hurd, U.S. EPA, 401 M St., S.W., Washington,
D.C. 20460:   I don't disagree that the plans we have coming
are first drafts. We do have to manage our water resources
and somebody's going to have to do it. We've taken the
first step. One of the things we've tried to do in working
is to gain stability for the program. First of all, 208 was
faced with the problem of trying to retain staff all of a
sudden, and  a matter  of a few weeks and months to take
on a project  for a short period of time. I was very
fortunate in  having one of the first agencies. As  more and
more agencies received money, it was very difficult to really
be able to hire people that would come for a short period
of time. We're trying to get stability for a longer period
of time — 5 years to start with so that you can have some
kind of confidence  in hiring. The second step is  to
gradually try to train  these people as they work in the

Gerald Hendricks, President, Seico, Inc., 309 Washington
St., Columbus, Indiana 47201:  The data we've had presented
at these meetings so far indicates the States have not
appropriated enough money to  take care of their problem
on ground water  and ground-water pollution. It's
unfortunate  that we seem to have to keep proving that there
is pollution of ground water. More serious damage is
occurring each year. It bothers me that 25 years ago, I
observed the first loss of a well due to a chromium problem
in an industrial plant  in my home town from the plant
itself. And yet, we keep reinventing the wheel here.  It
bothers me that we keep creating these problems.
      I disagree with the urgency associated with trihalo-
methanes along with the AWWA group. Why not leave that
thing alone for a little while and spend our energy where
it's needed?
      I think the Federal government should control the
development of new chemicals. Why do we allow this
continual addition to the problem? It's going to be very

expensive to build some new water plants that may not be
needed. If we take the same resource and control a product
which is not yet even on the market, which may be a
problem, I think it would be more productive. I can  get
along without new products but I can't get along without
my water supply. So I think we're off on the wrong  track
     My second point is that States be required to
establish pollution standards for ground water and then
control the violations. How on earth  can you  take anything
to court on general,  broad concepts? That's our problem.
I think somebody should have to prove something when
they claim pollution.

Richard Cadwgan, Hydrogeologist, GZD Geotechnical
Consultant, 30 Tower  Road, Newton Upper Falls,
Massachusetts 02164:  I come from a very densely
populated part of eastern Massachusetts and was fortunate
to participate in a very well funded drilling program in
the Boston area.
     I specifically would like to ask  a question of Mrs.
Hurd. It seems to me that an immediate near-term impact
of the 208 planning  process would be  the construction of
a large number of sewage treatment plants. Together with
that, there are ongoing NPDES programs. I think the State
of Massachusetts is trying to write pretreatment standards
for industrial discharges to sewer systems. I gathered that
the pit, pond and lagoon inventory is going to also lead to
the production of both the installation of brine ponds and
the reuse of industrial  waste water. All three things—plants,
pretreatment standards and the inventory of ponds and
lagoons—are going to lead to a tremendous volume of
sludge generated  in my part of the State of Massachusetts.
We don't have any place to put it; we don't know how to
treat it. What thought  is being given to help our State
agencies deal with this problem?
     Merna Hurd:  I don't know if I have  an answer for
that. Unfortunately, this is what happens when you
have individual programs dealing with one  little individual
part. There have been billions of dollars in treatment
facilities, and this is  why this has been such an active
program. What we need to do is look at our waste
products which are going to end up either in the air or the
water or on the land. We've got to decide where best they
should be placed and how best they should be managed.
I  can't tell you right now how you should manage sludge
in Boston or in your State. In a State resource management
program, we have some very difficult political problems,
because we deal with more than  one agency within a State.
We need to put those State agencies together and the
programs together to decide how best to handle those
problems. Of course, sludge is also a political problem
because the city is faced with large volumes of it, and
nobody wants it outside of the municipal boundary. EPA's
role is trying to pressure the agencies in different juris-
dictions to solve their problems together because they are
not going to go away.

Daniel P. Waltz, Hydrogeologist, Layne-Western Company,
Inc., P.O. Box 1322, Mission, Kansas 66222:  My comment
is re a case history involving the Ohio Environmental
Protection Agency. Columbus and Southern Ohio Electric
Company wanted to run an aquifer test on the Hocking River
flood plain near their Poston Run Power Station just south
of Chauncey, Ohio. They were told by a representative of
the Ohio EPA that they would have to obtain a point
discharge permit.  C&SOEC was only planning to pump
ground water from a test well and release it on the surface.
They were not putting it to any use and the water was not
being altered in any  way. Although the Ohio EPA was
aware of this, they continued to insist on a point discharge
permit. It took almost a full 12 months for approval of
the point discharge permit. It seems to me that this is a
gross misuse of the authority granted the Ohio EPA by
the Ohio legislature. If the Ohio EPA were to enforce this
on every well drilled in the State of Ohio, nobody would
even be able to test pump the well which they just finished
without obtaining a point discharge permit. With a similar
12-month delay, all of the well drillers in Ohio would be
put out of business.

W. Bradford Caswell, State of Maine, Department of
Conservation, Augusta, Maine  04333: The impact of
Maine's 208 program on  maintenance of ground-water
quality was not necessarily a terrible joke, but certainly a
disappointment. The basic problem was that funds were
put into the hands of planning  groups with little or no
prior experience in ground-water research and management.
Although honest,  hard-working people,  the 208 program
ran out before many knew what to do. As a result, a large
part of the Round II 208 funds is going directly to the
support of established ground-water programs of the Maine
Geological Survey. The State needs most of all better
continuity of the  208 program, but also Federal oversight
that is both critical of our activities, and sensitive to our
particular needs. The demand to implement 208 ground-
water management schemes that have been designed from a
paucity of basic ground-water data, for example, may not
be in the best interests of Maine people.

Controlled  Degradation  and/or  Protection
Zones  —  The  Way  It  Looks"
by David W. Miller1
     The support for controlled degradation and/or
protection zones arises from the fact that cleaning up
existing bodies of contaminated ground water, almost
without exception, has not been successful because of
technical  difficulties and extremely high costs inherent
to abatement procedures. With regard to potential future
sources of ground-water contamination, controlled
degradation and/or protection zones are attractive because
the state-of-the-art for containment of pollutants has not
advanced to the degree that full ground-water protection
can be guaranteed. Methods used to carry out a program of
controlled degradation and/or establishment of ground-
water protection zones can be applied on both a regional
and site-specific level.

     The concept of controlled degradation and/or
protection zones is based on the assumption that at
least some of man's activities will always contaminate
ground water regardless of technological and
regulatory safeguards. Where extensive degradation
of ground water has already occurred, zoning is
used to protect the present or future water well
user rather than to clean up the aquifer.
     Creation of controlled degradation zones
requires application of  special regulatory alternatives
to areas where contamination of ground water has
already occurred or is expected to occur. The
regulatory mechanism established for controlled
degradation zones may prohibit ground-water
pumpage for potable supply in selected areas, may
concentrate all potential polluting activities within
the zone, and may allow for application of the
most practical, but not necessarily the most rigid,
pollution control practices.
     Protection zones are normally areas that are
still rural and/or where high quality aquifers have
not been adversely affected by land-use and waste
disposal practices. In these zones, very strict
regulatory controls are  instituted. They might rule
out the use of  facilities for storage or disposal of
      Presented at The Fourth National Ground Water
Quality Symposium, Minneapolis, Minnesota, September
20-22, 1978.
     bSenior Vice President, Geraghty & Miller, Inc., Con-
sulting Ground-Water Geologists and Hydrologists,
44 Sintsink Drive East, Port Washington, New York 11050.
industrial waste on the land, require very low
density housing development, and limit the use of
such potential contaminants as highway deicing
salts, lawn fertilizers, and organic chemical
septic tank cleaners. In this paper the major
emphasis is directed toward the use of controlled
degradation zones.
     Any discussion involving strategies for ground-
water quality protection must acknowledge the
existence of two distinct types of contamination
problems. The first involves new sites where wastes
are to be stored or disposed of in the future, in
facilities such as waste-water impoundments and
landfills.  The second involves existing sources of
contamination, including not only old landfills and
lagoons but also areas of heavy industrial activity
and urbanization where many and diverse individual
sources of contamination are concentrated.
     Regulations reflecting recent legislation will
improve design and management at new disposal
sites. However, improvements will be difficult to
implement at existing sites where long-term land
disposal has already contaminated aquifers beneath
the land receiving the wastes. In addition, the
complexity of permit systems, accompanied by
vociferous public opposition to the establishment
of new industrial waste disposal sites, casts serious
doubt upon the ability of localities to  issue permits
for new sites regardless of their apparent hydro-
geologic suitability. Programs of public participa-
tion will not be helpful unless the  participating
public is first educated to awareness that safe sites
are technically possible, and that failure to approve
sites will result in even greater environmental
hazards. The shortage of secure sites for the disposal
of industrial wastes is evolving as a critical national
     If it is assumed that standards for site selection
and engineering of new sites are sufficient to
minimize the possibility of contaminants migrating
to underlying earth materials, the philosophy of
controlled  degradation may be defined as the
provision of safety measures in the event that
engineering design fails or that spills and poor
housekeeping at the facility result in ground-water
contamination. The strategy requires establishment

of adequate buffer zones around the waste disposal
site. The time required for migration of contami-
nants to adjacent critical aquifer areas is then
sufficient to allow for a reasonable planning period
for correction of the engineering design or improve-
ment of management procedures. Proper monitoring,
an essential part of this strategy, will provide
early warning of impending problems. In addition,
the zone must be large enough to accommodate
some attenuation of contaminants. Control of the
buffer zone is assured by either outright ownership
of the land around the facility, purchase of water
rights in the direction of ground-water flow, or
control over ground-water diversion to limit the use
of the aquifer area that might be affected by escape
of contaminants from the facility.
     The use of controlled degradation zones has a
much wider application to cases where ground-water
contamination has already occurred. At older waste
disposal sites in humid parts of the country and in
areas of concentrated industrial and urban activity
throughout the nation, there has been enough time
for chemical contaminants to move uncontrolled
through significant thicknesses of heavily used
aquifers. The contaminants may have moved beyond
the limits of such informal buffer zones as property
boundaries of industrial sites and vacant land
surrounding many municipal landfills. In such cases,
where the water quality of an extensive portion of
an aquifer has been  degraded, rehabilitating
ground-water quality to its natural state is rarely
technically or economically feasible. The cost of
pumping large quantities of ground water in order
to treat relatively small concentrations of
contaminants is normally beyond the means of any
private or public entity. In addition, it is not
always possible  to intercept and remove all of the
contaminated ground water because the interceptor
wells would require  periodic relocation and/or the
quantity pumped would have too great an inter-
ference effect on water levels in unpolluted sections
of the aquifer.
     The most usual practice involves condemnation
of wells used to produce drinking water or, if
possible, treating the ground water at the well head
or mixing it with nondegraded water before
distribution. Pumping and treating contaminated
ground water has been used successfully when the
objective is only containing the  polluted ground-
water body within a certain area or controlling the
rate of migration of contaminants. The quantity
of water removed from the aquifer is much less
than would be required if the  objective of the
pumping and treating is actual purging of con-
taminants from the aquifer system.
     Another major problem associated with
aquifer cleanup has to do with the magnitude of
the task nationally. As monitoring of ground-water
quality is more widely applied, accompanied by
increased ability to analyze for synthetic chemicals
at lower and lower concentration, there is little
doubt that the number of ground-water pollution
cases discovered  and brought to local and national
attention will increase on a logarithmic scale.
     USEPA estimates that 80 percent of the 46
million tons of potentially hazardous industrial
waste produced in this country each year is
disposed of on the waste generator's site in more
than 100,000 waste-water impoundments or
industrial landfills. There are about 20,000 active
and thousands more abandoned sites where
hazardous wastes were stored, treated, and disposed
of on the land overlying important aquifers (The
Bureau of National Affairs, 1978). Facilities were
engineered to prevent ground-water contamination
at only a few of these sites. In most cases, ground
water was used as the discharge mechanism to carry
the pollutants away from the site, with little or no
understanding of the future problems being created.
Unfortunately, each typical significant source of
contamination may require millions of dollars to
clean up. The long-term  economic implications  are
clear. While money may be invested by government
and industry to clean up the first few startling cases
of ground-water  contamination in a region, the  funds
will soon dry up  as the number of instances
     The diversity  of individual sources of contami-
nation in an area which has become heavily
urbanized  and industrialized further complicates
the development of ground-water strategies. The
combination of such diverse sources as landfills,
waste-water impoundments, septic tanks, leaky
sewers, and spills, makes it extremely difficult to
determine the priority that should be given to
correct any particular source of contamination
without a long-term and statistically valid monitor-
ing program. Efforts are typically directed toward
the more obvious sources which may or may not
actually represent the key problems in the region.
Correction of these more obvious sources at great
cost to private organizations or to the public
may not result in significant improvement of
ground-water quality.
     Finally, the size and type of some pollution
sources essentially  prohibits securing them from
the environment or physically removing them for
detoxification or disposal at another location, for

example, hazardous wastes buried in large landfills
and sludges deposited in extensive lagoon systems.
Even if it were feasible to dig up the wastes and
transport them elsewhere, there are few places for
disposal favorable enough to warrant the high
cost and environmental risk. Elimination of other
sources, i.e. septic tanks and leaky  sewers, involves
substantial expenditures of public funds for large-
scale construction projects. In addition, the slow
recovery of an aquifer from widespread contamina-
tion makes it obvious that other alternatives must
be considered for managing ground-water systems
where the water is severely degraded.
     One such alternative is the zoning of aquifers
on the basis of variations in permeability, recharge
and discharge relationships, potential effects on
surface waters, existing ground- and surface-water
quality characteristics, and present and proposed
land use. In this way, priorities for ground-water
protection can be established based on sound
environmental planning and economic principles.
     Controlled degradation and protection zones
as a ground-water management technique have been
used in the development of the  Long Island
Comprehensive Waste Treatment Plan, a 208
project covering Nassau and Suffolk Counties,
New York (Nassau-Suffolk Regional Planning Board,
1978). Ground water beneath Nassau and Suffolk
Counties is the only source of potable water for
almost three  million people. Total  withdrawal from
the three principal aquifers currently approaches
400 mgd. Long Island lies within the Coastal Plain
physiographic province. Major patterns of ground-
water flow are such that the deep ground-water
reservoirs are mainly replenished over a broad area
in the central portion of the region. Recognition
of this flow system and areawide effects of past
land-use and  waste disposal practices, prompted
the definition of critical watersheds or protection
zones for the 208 region. For example, in one zone
of more than 100 square miles, good quality ground
water still exists in the major aquifers.  Moreover,
since the hydraulic conductivities of the aquifers
are high, there is considerable potential for water-
supply development in this zone. Much of the area
is woodland.  The 208 plan recommended that the
zone should be protected by applying land-use
restrictions which would severely limit future urban
and industrial development. Strict control over
potential nonpoint sources of pollution and prohi-
bition of facilities for land disposal of waste were
also recommended. In other words, the entire
zone would be governed by  nondegradation
     In another zone of about 25 square miles,
serious ground-water quality problems have been
experienced over the past few years, primarily due
to the presence of organic chemicals and high
concentrations of nitrate. Land use is  characterized
by mixed commercial/industrial and high density
housing.  Where practical, identified sources of
contamination are being eliminated or their
impacts minimized. Industrial pumpage, presently
about 10 mgd, is being encouraged to prevent
contaminants from  migrating into adjacent zones
containing high quality ground water. The zone
would  not be governed by nondegradation  regula-
tions. In  other zones within the 208 area, depending
on local hydrogeologic factors, recommended
waste-water management alternatives  are designed
to achieve a balance between present land-use and
water quality conditions and  environmental
controls  so that the quality of ground water can
be maintained to assure its continued use as the
regional water supply.
     In summary, a uniform set of environmental
controls  cannot be applied across the  board as a
solution  to all real or potential ground-water
contamination problems. Man's impact  on  ground-
water quality is determined by too  many variables
including land-use and local geologic and hydrologic
conditions. To manage ground-water quality
correctly, we must be able to accept the fact that
it is too late and too costly to undo many of the
past mistakes. However, we must also have sufficient
foresight and creativity to protect high  quality
aquifer areas by means of strict land-use controls
and advanced engineering design.

              REFERENCES CITED
The Bureau of National Affairs, Inc. November 17, 1978.
     Environment Reporter. Washington, D.C. pp. 1301-
Nassau-Suffolk Regional Planning Board. July, 1978. The
     Long Island comprehensive waste treatment manage-
     ment plan. v. 1:  Summary plan. 247 pp.
             *      *       *       *
     David W. Miller is a principal in the firm of Geraghty
& Miller, Inc., consulting ground-water geologists and
hydrologists. He holds degrees in  Geology from Colby
College and Columbia  University.  Mr. Miller has devoted
more than 25 years to  the solution of problems involving
the development, management, and protection of ground-
water resources. He has directed consulting projects for
industry throughout the United States and overseas. Over
the past few years, Mr. Miller has worked on numerous
studies for the U.S. Environmental Protection Agency. These
have included investigations of ground^water pollution
problems  in 26 States; preparation of manuals on  monitor-
ing; and development of the Report to Congress on waste
disposal practices and their effects on ground-water quality.

 Controlled  Degradation   and/or
 Protection  Zones  —   Sensea
 by Ronald A. Landon
     It is herein submitted that the nearly universal
phrase "shall not cause pollution of the ground waters
and surface waters" written into the State regulations for
waste disposal operations not only refutes a sound technical
alternative, but is impractical, uneconomical and often
     It is a fact that all ground watf ~s are not created equal,
as governed by certain irrefutable physical laws including
the water budget equation and Darcy's Law which states
that the quantity of ground water available is subject to
wide variation from location to location. While an aquifer
is a relative term, major, minor and nonaquifers can be
identified within a given geographic area with respect to
cost-effective ground-water resource development. Like-
wise, the natural quality of ground water is also a
significant variable with certain parameters often
exceeding drinking-water standards. The land application
of wastes overlying the ground waters of an area should,
therefore, also be subject to a certain degree of flexibility
for prudent management of both the waste operation and
the ground-water resources.
     Numerous investigations and empirical data can be
cited to substantiate the fact that many wastes and their
associated leachates can be safely assimilated into the
environment with reliance on attenuation and controlled
degradation of ground water by utilization  of a mixing
zone or zone of renovation with a specified distance from
a disposal operation. As increased emphasis is placed on
the land disposal/management of wastes/residuals and as
the cost of these operations continue to mount, it is strongly
recommended that controlled ground-water degradation
be utilized in those areas where a "true" ground-water
resource does not exist. Protection of such  a "true"
ground-water resource is obviously necessary as our
demands for a potable water supply also continue to grow.
      Presented at The Fourth National Ground Water
Quality Symposium, Minneapolis, Minnesota, September
20-22, 1978.
     bp.G., Principal, Environmental Resources Manage-
ment, Inc., One South Church St., West Chester, PA 19380.
     I would like to begin by stating a well-worn
phrase, "What this country needs is ....," and I'd
like to add another to that long list. What this
country needs is a set of regulations governing the
land disposal and land treatment of wastes that are
more realistic with respect to the impact of those
wastes on ground-water and surface-water quality.
     The thesis that I would like to build on is that
we don't have those realistic, flexible regulations
today and in many cases we are painting ourselves
into a corner whereby we  are refuting a sound
technical alternative—that alternative being of
controlled degradation. I've found in working for
both regulatory agencies and consulting firms that
many times the regulations become impractical,
uneconomical and just plain unworkable. I'd like
to clarify my stand on this issue by saying that I
am not in favor of uncontrolled pollution, but I am
definitely in favor of controlled degradation, and  I
think that there is a difference between the two.
     We have just heard an excellent presentation
on a number of case histories that show very
practical applications of controlled degradation. I
would like to build on the concept of controlled
degradation. I think we have only to look at the
quantitative and qualitative aspects of ground water
to realize that this concept does, in fact, make some
sense. All ground waters do not exist with the same
degree of value and all ground waters, therefore, are
not created  "equal." A very definite natural
variation exists for  both geology  and ground-water
flow systems. While that is not news to most,  I
think we often lose sight of that fact.
     There are several very basic irrefutable physical
laws that govern the occurrence, movement and
quality of ground water. The water budget
equation, for example, states that precipitation,
runoff and evapotranspiration will vary in any

given region and, therefore, the net recharge to
ground water will also vary in accord with the
others. Likewise, Darcy's Law states that the
quantity flow is proportional to the permeability,
gradient, cross-sectional area, with permeability
being the most important criteria. Although
ground water will be recharged at a certain rate
at any given locality, its movement and
withdrawal rate will vary according to  the
permeability of the host deposits. Similarly, there
is variation in ground-water quality which is
dependent upon the quality of the recharged water
and the geochemical reactions in the unconsolidated
and consolidated deposits through which that
ground water is moving.
     It would appear to make sense, therefore, that
with the realization that the  natural hydrogeologic
system is variable, there is a need to apply that
realization for more sound waste management
practices. We are in essence between the hard-hat and
the boulder, as they say. We  have both a need to
protect the ground-water resources in the country,
while at the same time we have a growing need to
dispose of wastes we generate. I am a very strong
advocate of that, with more emphasis being placed
on those resources. We have a need, therefore,
to balance the two interests. This is perhaps best
exemplified by a United Kingdom  publication
addressing that very issue entitled, "Balancing the
Interests Between Water Supply and Waste
     The concept of controlled degradation is
based on another concept of a zone of renovation,
assimilation, or a mixing zone. I personally dislike
the phrase "zone of degradation" since degradation
implies a negative. I would rather turn it around in a
positive sense and say a "zone of assimilation" or
"mixing zone." Numerous studies have been
conducted, several of which I have been fortunate
to have been a part of, that have contributed a large
bank of empirical data to the literature which state
that  leachate produced by landfills, sludge sites,
spray irrigation sites, and other land treatment/land
disposal facilities can, in fact, be safely assimilated
into  the environment by attenuation. There are
various forms of attenuation; major among them
are precipitation, adsorption-desorption, and, not
the least important, dilution. I am a strong advocate
of using the natural environment, including
dilution, at a controlled rate to assimilate wastes.
This zone of attenuation or assimilation may be
strictly within the ground-water flow system
depending on the size of the facility and the site
hydrogeology, or it may also  include the surface
water as a receiving stream for the point of
ground-water discharge.
     For controlled degradation to be a viable waste
management approach, several critical factors must
be considered. Obviously, the basic hydrogeology
is a critical factor for any given land disposal site.
I believe, again, that perhaps one of the more
important criteria in the hydrogeologic regime is
that of the permeability. Based on a significant
amount of empirical data and experience, it would
appear that a permeability in a moderate to
moderately low range of 1 X 10"4 to 10~5 cm/sec or
a silty sand deposit has repeatedly proven to be
adequate for renovation or assimilation of waste
leachates emanating from land disposal facilities.
Distances of 200 to 600 feet are commonly cited
in  the literature as being adequate to assimilate
leachates from rather  sizable landfills and other
land disposal areas. A permeability is desired that
will control this diffuse leachate discharge at a rate
that is not so low as to result in a concentrated
buildup of leachate and, at the same time, is so
rapid (i.e. fractured rock or very permeable sand
and gravel) as to result in rapid and far-reaching
migration of leachates and associated adverse
impacts on water quality.
     Another important concept which is being
more frequently discussed with respect to  controlled
degradation is that of waste disposal zoning.
Actually, the concept of waste disposal zoning
has been around a long time. I can think back easily
ten years ago when this concept was discussed. It
is time to realize that we should zone land from a
hydrogeologic standpoint as well as from a
political standpoint. Again, there is a need to
balance the interests between water supply
problems and needs and waste disposal problems and
needs. Waste disposal zoning would entail desig-
nating waste areas in areas of intense land use,
particularly highly industrialized, or areas where
the natural ground-water quality or the man-made
ground-water quality  is already altered. Waste
disposal zoning also implies that the major aquifers
in any given region will be designated. It may be
necessary to look beyond the limits of the
formational boundary to recharge boundaries as
well,  but the point is that for any given area we
can designate major and sole source aquifers as
well as those areas that have minimal value as a
ground-water resource.
     Another critical  factor is the need for waste
segregation, particularly at the disposal site, and if
possible at the source itself. Controlled degradation
or a zone of assimilation does not apply to any or

all wastes. What is needed is a waste segregation
based upon a classification system similar to that
in use in California, or what Texas and Illinois
and others are developing. Toxic and truly
hazardous wastes must be disposed of either in
a secure landfill or by some other method such
as incineration  or encapsulation. But I do believe
that there are many "wastes" that in fact are
nontoxic, decomposable, that can be applied to
the land  in a managed and environmentally
compatible manner.
     Perhaps one of the weakest links in the whole
waste management chain is that of poor operator
training or knowledge. There is a definite need to
have training and certification of land disposal
operators comparable to what exists for water
treatment and waste-water treatment plant
operators. All too often a problem arises because
the person in charge of the daily field operation
frankly does not know what he's doing. While
engineering plans are required, the plans are often
misapplied or in fact never implemented. Certifica-
tion and  training of these people to be present
and accountable for a day-to-day technical
professional input to that operation are needed.
     Finally, I think we need an attitude change
by the regulatory and legal personnel. There is no
doubt that the  socioeconomic, political and legal
aspects of solid waste management all take
precedence over the technical issues. This attitude
change is necessary, therefore, to apply the concept
that waste disposal zoning and controlled
degradation, in fact, make sense—not for all
wastes, but for select wastes.
     In summary, I would hope that what may have
initially appeared to be a radical concept is not so
radical after all. We have only to look at the fact
that there have been numerous waste operations
conducted in the past which have not caused
significant impact prior to enactment of the
increasingly stringent environmental laws existing
today. Granted, we do have the Love Canals and
other similar horror stories which, to my way of
thinking, are largely a case of the wrong waste in the
wrong place and/or poor management practices.
We do have literally thousands of waste operations
which have been conducted over the years that
have not caused significant impact and I would state
again, therefore, that controlled degradation does
make sense. I think that it is a very sound technical
alternative which is workable, practical and
     Ronald A. Landon is employed by Environmental
Resources Management, Inc. He was formerly employed
•with Roy F.  Weston, Inc., Moody and Associates, Inc.,
Pennsylvania Department of Environmental Resources and
Illinois State Geological Survey. He has 15years'
experience in management,  direction and quality assurance
of geologic and ground-water resource projects: ground-
water hydrology and flow system analysis; environmental
impact of existing and proposed sanitary landfills;
delineation, recovery and containmen't of hydrocarbons
and hazardous material spills.

Controlled  Degradation  and/or  Protection
Zones  —  Nonsensea
by Herman Bouwer
     Man's activities are an ever-increasing threat to
ground-water quality. New EPA policies encourage cities to
discharge sewage effluent on land. Irrigated agriculture is
incompatible with high-quality ground water where deep
percolation water is not removed by drainage. Present
drinking-water quality standards cannot be used to
determine the suitability of water for potable use if such
water is waste-water-derived. Where sewage effluent is applied
to land, persistent trace organics occur in underlying
ground water. Some of these organics may be carcinogenic
or otherwise toxic, and much additional research is needed.
Controlled degradation of ground water still is degradation.
High-quality ground-water resources either are to be
protected, or aquifers eventually must be abandoned as
sources of high-quality drinking water. In the long term,
there is no in-between. The choice will be dictated by
economic and environmental considerations. For example,
the most economical use of aquifers below irrigated valleys
ultimately may be to serve as facilities for treatment, storage,
and conveyance of municipal waste water from surrounding
communities, so that this water can be used again for
unrestricted irrigation. While such uses of aquifers may be
far off, they should be anticipated now to allow proper
      Presented at The Fourth National Ground Water
 Quality Symposium, Minneapolis, Minnesota, September
 20-22, 1978.
      ^Director, U.S. Water Conservation Laboratory, Science
 and Education Administration-Agricultural Research, U.S.
 Department of Agriculture, 4331 E. Broadway, Phoenix,
 Arizona 85040.
     The discovery in the early part of this century
that chlorine could be used to make polluted surface
water bacteriologically safe for drinking gave cities
a license to dump sewage effluent into streams and
lakes, which in turn led to widespread pollution of
our surface water. Let's hope the illusion that
controlled degradation of ground water is permissible
will not do the same to  our underground-water
resources. Controlled degradation is still degradation—
the only difference between controlled and uncon-
trolled degradation of ground water is that con-
trolled degradation takes longer; either way, the day
of reckoning will come.
     As an example, let's take an irrigated valley.
Such a valley is essentially a large evaporation pan.
Salt accumulates in the root zone of the crops.
Since salt injures plant growth and eventually makes
agriculture impossible, it has to be leached out of
the root zone by regularly or periodically applying
more irrigation water than is needed for evapo-
transpiration. The salt leachate from the root zone,
often called deep-percolation water, then  moves
down and eventually ends up in the underlying
ground water. Some areas have a high water table
and  are "poorly drained." Although this is
agriculturally undesirable and forces farmers to
install tile drains to control the water table, it is a
blessing from the standpoint of protecting ground
water, because the deep-percolation water is inter-
cepted and disposed of on the surface. In  irrigated
areas, however, ground water is pumped from most
aquifers, and water tables have declined enough that

the overlying land does not need artificial drainage.
This is good for farmers but, unfortunately, all
deep-percolation water ends up in the underlying
ground water. Consequently, the quality of ground
water and well discharges deteriorates, mostly as
total dissolved salts (TDS) and nitrate concentrations
     A number of things can be done to reduce or
delay the ground-water degradation that deep
percolation from irrigated agriculture causes. For
example, farmers can irrigate more efficiently,
applying the water uniformly and in amounts that
do not exceed crop evapotranspiration and the
leaching required to maintain a salt balance in the
root zone. This produces less deep-percolation
water, but this water will have a higher salt
content. The higher salt concentration increases
precipitation of carbonates in the vadose zone,
thus reducing the salt content as the water
percolates downward. The lower deep-
percolation rate also results in less leaching of salt
from weathered minerals or from deeper, saline
formations. Despite these beneficial effects, total
salt loads on underlying ground water are still
severe. Efficient irrigation practices do, however,
slow downward movement of the deep-percolation
water through the vadose zone. This is advantageous
where ground-water tables are declining, because it
reduces the rate at which deep-percolation water
joins the ground water. As a matter of fact, pumping
ground water out so fast that deep-percolation
water does not catch up with the declining ground-
water level is about the only way to protect
ground-water quality in  irrigated areas.
     Another potential threat to ground-water
quality is land application of waste water such
as sewage effluent, wet sewage sludge, and agricul-
tural wastes (manure slurries, processing plant
effluents, etc.). Land application of sewage
effluent will probably increase dramatically in the
near future because secondary  and  tertiary
treatment cost so much  and require so much
energy and because new EPA policies favor land
treatment over conventional, in-plant treatment.
The policies include increased reimbursement for
costs of land treatment systems, higher priority
for the systems on State project lists, free modifica-
tion or replacement of land treatment systems if
they do not do the job properly, and the require-
ment that cities not electing land treatment must
explain why in their application for sewage-plant
construction grants.
     Land application of sewage effluent has a
number of very attractive features.  Where the
effluent is used directly for irrigation, the nitrogen
and phosphorus in the effluent serve as nutrients
for crops, so that land rather than surface water is
being fertilized. If the effluent is applied according
to nitrogen requirements of the crop, the amount of
nitrogen leached to underlying ground water will
probably be about the same as that from
conventional farming.
     Another form  of land treatment of sewage
effluent is the rapid-infiltration system. This is
more like a ground-water recharge system, where
effluent seeps  into the ground  from infiltration
basins. The soils and aquifers are then used as
natural filter systems to remove almost all of
the biological oxygen demand  (BOD), suspended
solids, bacteria, viruses,  and phosphorus and most
of the nitrogen from the effluent water. The
system produces renovated water that can be
pumped from  the aquifer and used for purposes
with a higher economic  or social return than direct
irrigation with sewage-plant effluent (for example,
irrigating vegetables and other  high-value crops,
recreational lakes, etc). The problem with this
system is that, although the renovated water is of
much better quality than the effluent that
entered the soil, it often is not as good as the
native ground water. The problems are associated
not only with nitrogen or metals, but also with
refractory and other trace organics, including
known carcinogens  like  trihalomethanes and other
chlorinated hydrocarbons. More research is needed
on the identity and  toxicity of these organics in
renovated sewage water. Normal drinking-water
standards cannot be used in determining the
safety of renovated  waste water for drinking,
because these standards  apply to relatively
unpolluted surface-water resources. In waste-water
reuse, renovated waste water is guilty until proven
     Encroachment of renovated effluent water
upon native ground water can, theoretically, be
controlled by taking the renovated water out of
the aquifer with wells or drains at a certain distance
from the infiltration basins. The native ground
water beyond these collection  facilities is then
protected against encroachment by the renovated
water. In practice, these systems require careful
management and monitoring of ground-water
levels so that water  from the renovation system
never flows into the native ground water. This
could pose problems in the winter or whenever
the demand for renovated water is less than the
amount that must be collected to protect the
aquifer. Plans and facilities for handling "surplus"

renovated water or sewage effluent thus must be
an integral part of any rapid-infiltration system.
     Another approach toward protecting native
ground-water resources against spread of renovated
waste water is treating the waste water until it is
essentially of drinking-water quality before it is
applied to the land. This is California's philosophy,
where proposed regulations call for treatment of
sewage effluent to reduce the total organic carbon
content (TOG) to less than 3 mg/liter (TOC of
secondary effluent is about 20 to 30 mg/liter)
before it is applied to land from which it can
enter aquifers used for drinking water. Concentra-
tions of arsenic, barium, cadmium, chromium,
lead, mercury, nitrate, and selenium must  also
meet drinking-water standards. While such
treatment is laudable from the standpoint of
ground-water protection, it may lead to costlier
systems than necessary because it does not take
advantage of the organic carbon removal,
denitrification, and other quality-improvement
processes that take place on a  renewable basis in a
soil-aquifer system. More research is needed to
determine the optimum combination of pre-
and post-treatment in rapid-infiltration land
treatment systems.
     Where degradation of ground water by
man's activities is inevitable, and controlled
degradation only means delay  of execution, the
solution may well  be abandonment of aquifers
as sources of high-quality water. The best use of
the aquifers may then be to receive, store, and
renovate waste water. This sounds like heresy,
but it is already done for surface water—for
example  in West Germany, where the Ruhr is
protected but the parallel flowing Emscher is
used as a waste disposal stream. Both streams
are tributaries to the Rhine. This is a good solution
for the Emscher-Ruhr area, but it does nothing
for the downstream users of Rhine water,  who
get the dirty water anyway.
     Abandoning aquifers as sources of high-
quality ground water may be the best ultimate
solution in irrigated areas that are becoming
urbanized. The amount of land that was
originally irrigated in such areas, and the population
that such areas can support, often are limited by
available water supplies. Thus, urbanization can
cause conflicts between municipal and agricultural-
water demands. Assuming that the area has a
certain ensured water supply from a river or other
outside source, agriculture and urban development
can coexist if the municipalities use the water
first and agriculture uses the renovated sewage
effluent for irrigation. A good way to achieve
this would be to concentrate the urban develop-
ments in the higher areas (desert, foothills, etc.)
around the irrigated lands, leaving the agricultural
land intact. Each town around the valley would
then have its own sewage treatment plant, and
the effluent would be applied to rapid-infiltration
basins for ground-water recharge. This would
produce renovated water that would move
downgradient  through the aquifer to the lower,
agricultural areas, where it would be pumped for
irrigation. The aquifer would then serve as a
medium for receiving, renovating, transmitting,
and storing effluent water.
     In summary, we see that controlled degrada-
tion eventually may lead to ground-water  contamina-
tion. There may only be two choices: complete
protection of aquifers and high-quality ground-
water resources, or degradation and eventual
abandonment  of aquifers as sources of high-quality
ground water.  Since restoring contaminated ground
water to drinking-water quality will be more
expensive than conventional drinking-water
treatment, there may be no in-between.
     Herman Bouwer received B.S. and M.S. degrees in
land reclamation, drainage, and irrigation from the National
Agricultural University at Wageningen, The Netherlands,
and a Ph.D. degree in agricultural engineering (water
management) from Cornell University. He was associated
with Auburn University's agricultural engineering depart-
ment in Alabama from 1955 to 1959. He then joined the
U.S. Water Conservation Laboratory, U.S. Department of
Agriculture, in Phoenix, Arizona, where he was appointed
Director in 1972. He is leader of a research group in
subsurface water management and ground-water recharge
with sewage effluent, and teaches ground-water hydrology
at Arizona State University.

Audience  Response to  Session  VII —  Controlled
Degradation  and/or Protection  Zones
Richard Dalton, Principal Geologist, New Jersey Division of
Water Resources, 1474 Prospect St., Trenton, New Jersey
08623:  First, I was quite shocked when I saw the delineation
and writing off of the Raritan outcrop area under Dave
Miller's controlled diagram. What happens when this unit
is also the most heavily utilized ground-water source for
the State of New Jersey?
     Second, many times when we get plans in for a
landfill or a ground-water control system, the consultant
appears to slant his argument toward the client. Do you
think this is fair?
     David Miller, Geraghty & Miller, Inc.,44 Sintsink Dr.
E., Port Washington, New York 11050: I knew you were
going to attack me. That is shocking isn't it. The concept
for eventually writing off an area is what I was trying to
put across; eventually a very large portion of that yellow
section, and some of it very quickly, is already being
written off. Actually, to put down on a slide the entire
area was an exaggeration to put a point across. I don't have
the power to write off anything. New Jersey is actually
doing it, however, whether they know it or  not. They
are zoning the pine barrens. There are certain areas in that
yellow band where people are beginning to talk about
abandoning ground water, and either going to surface
water or going to the next zone and taking ground water.
New Jersey is protecting that area that they can move
into, and that's really zoning.
     As far as clients are concerned, yes, I try  and represent
my client.

Ronald Spong, Environmental Specialist, Bloomington
Health Department, 1772 Ashland Ave., St. Paul, Minnesota
55104: I 'm not persuaded by the argument that controlled
degradation is a good idea. I speak from a public health
point of view that perhaps is not well represented  here
among the hydrogeologists, geologists, consultants, etc.—
not from the standpoint so much as a technical problem
but more from  the standpoint of perspective. Perspective
first of all is garnered from retrospect; in other words, how
well have we been able to control our programs in the
past? We've had quite a bit of discussion on the value, the
performance, and accountability at the State and Federal
levels—whether or not the job is getting done, who is going
to be doing the monitoring and enforcing the rules. Are
the consultants going to be more biased for their
employers? Are the relevant facts going to be brought forward
so that we actually know some of the truisms that exist
in particular ground-water aquifers that are going to be
degraded? Retrospect also from the standpoint that
prevention is a goal in public health and unfortunately,
prevention is very seldom ever achieved.
     In prospect our problems must include the catastrophic
consequences of earthquakes, floods, etc. Perhaps if we
were talking just about aquifers in glacial drift materials,
it might not be a tremendous problem, but aquifers in
granitic rock will be a much  greater problem. Are we
going to continue to perpetuate the myth that our society
continue to waste tremendous amounts of material without
looking towards resource recovery or in fact, lowering our
expectations? Are we, in fact, going to encourage ground
water to be a repository for  waste by voting for "controlled
degradation"? We have it on the land, we had it in the air,
we had it in the surface waters. Out of sight, out of mind,
has been mentioned many times. What are we going to do
about this?

     Ronald  Landon, Roy F. Weston, Inc., Weston Wing,
West Chester, Pennsylvania:  Just a couple of quick points on
that. I happen to feel, with respect to domestic waste, that
land treatment, land disposal of waste, is in fact a resource
recovery operation by the fact that we are recovering some
of the nutrients out of that waste, and  again, I think it's
putting the balance in perspective that we're not
necessarily going to get  locked into preserving all waters to
be of drinking-water quality. There can be use of the land
for waste treatment or a waste disposal facility and use of

the underlying water for such things as irrigation, as Dr.
Bouwer mentioned, or for industrial pumping, which Dave
has mentioned, where drinking-water standards are not
necessary. One other item you mentioned earlier, I think
we all have to share the blame for being a little too late,
but we can begin to close a few loops here. You questioned
the technology; certainly, we have to question the
technology, but we've also heard comments here that
many of the State programs are not adequately staffed or
funded. If they are adquately staffed the proper staff
personnel does not in fact, make the regulations or get
involved with the implementation of those regulations.
These are very real problems as well.

Fred Lahman, Lahman Well Drilling Co., Mines, Minnesota
56647:  What happens to a land disposal system using an
aquifer for the filter that is set up to run for 20 years?
Eventually the water in the aquifer runs into a river or a
lake. If this is set up to operate 20 years, then the system
is abandoned and the water is returned to the natural static
water level. The irrigation pumps are shut off; what
happens to the contamination that's in the system that
moves further down into the ground-water system?
      Herman Bouwer, U.S. Water Conservation Lab.,
4331  E. Broadway, Phoenix, Arizona 85040: Most of the
accumulation of pollutants in a land treatment system
occurs in the top 3 or 4 feet of the soil. And primarily
what you get is really a mineralization of the organic
matter and you get precipitation of phosphates and then
reversion through insoluble pumping of the phosphates,
so it will remain immobilized. I don't think there's much of
a chance really that when abandoned, some of these
materials like phosphates and metals that have accumulated
in the soil will be remobilized and show up in the ground
water. Same as bacteria and viruses that have been removed
by the system, they usually don't survive longer than half
a year or so. So the ground water will not pick up any large
amount of bacteria.
Daniel P. Waltz, Hydrogeologist, Layne-Western Company,
Inc., P.O. Box 1322, Mission, Kansas 66222:  I compare
"controlled degradation" to being only a "little pregnant."
Either the water being affected is polluted or it isn't
polluted. There can be nothing in between. In the past
there has been too much leniency as far as water pollution
is concerned. I feel that there is no good reason for polluting
any water. If the industrial process requires special treatment
of waste water being produced by the company then the
cost of such treatment must be passed on to the  consumer.
The consumers must be aware that the product they are
buying is difficult to produce and that if they intend to use
the product they must be responsible for the  pollution it
produces, at least financially. I repeat; "There is no just
reason for pollution. All water should be returned to its
original state, or at least as close as possible." I enthusi-
astically support recycling of industrial water and
pretreatment of industrial waste water for pollutants which
are not removed in normal municipal waste-water
treatment processes. I do not endorse the idea of controlled
degradation and/or protection zones.

Lloyd H. Woosley, Jr., Water Quality and Ecology Branch,
Tennessee Valley  Authority, Chattanooga, Tennessee
37401:  It is quite evident that many waste disposal
facilities, such as surface impoundments and landfills, are
capable of degrading local ground-water quality. The area
affected may require a management technique such as
zoning for controlled degradation and limited use. But,
Mr. Miller, the investigation you presented dealing with the
implementation of such a management technique failed to
evaluate water quality degradation in  an integrated fashion-
that is, surface and ground waters were not considered as a
total resource. Aren't the investigations by the hydro-
geologic industry deficient in the same way as those of
environmental engineers by neglecting to evaluate ground
water and surface water as a single resource?

 Ground-Water Computer  Models
 State  of  the   Arta

 by Thomas A. Prickettb
     This paper addresses both the pros and cons of ground-
water modeling and is presented from a neutralist's stand-
point. The list of individual modeling pros and cons is
extensive but is condensed into three main points for each
side of the ledger.
     The three main characteristics that put the use of
ground-water models into the class of intellectual toys  are
as follows. First, the wrong model is frequently chosen
for problem solving of which overkill by use of an overly
sophisticated  model is an example. Secondly, the paying
agency or client is often disillusioned with the model results
because of frequent modeler oversell in the early stages of
project planning and budgeting. Thirdly, the problems  are
often solved with a numerical code that is  a mystery to all
except the modeler  himself.
     The three main characteristics that make ground-
water models very practical tools are as follows. First,
there is no doubt that the models of today can solve
extremely complex ground-water flow  problems. Having
methods available for solution of complex problems is  an
advantage that we have not always had. Secondly, the
models of today are available to virtually everyone in the
ground-water business. The days of specialty laboratories
for complex ground-water model solving are over and the
tools are now in the hands of those doing the local work.
And thirdly, having  a computer code and data deck
available is a perfect tool for transferring information to
another person as to how a problem was solved. There  is
no doubt as to the exact assumptions used and the
step-by-step solution of the problem which produces the
results of the entire  analysis.
     This paper also includes a very brief description of
the state-of-the-art of ground-water modeling and a very
comprehensive reference list of useable models.
      Presented at The Fourth National Ground Water
Quality Symposium, Minneapolis, Minnesota, September
20-22, 1978.
     ^Regional Manager, Water Resources Division, Camp
Dresser & McKee, 302 E. John St., Suite 1605,
Champaign, Illinois 61820.
     I was invited to this conference to present
the neutralist's viewpoint on the subject of ground-
water modeling as a practical tool or as an
intellectual toy. I see both pros and cons to the
modeling business and am glad to point these out
in writing. This paper is assembled in four parts.
The first part is a quick state-of-the-art report on
ground-water modeling. The second part includes
the discussion of ground-water models as practical
tools. The third part includes the discussion of
models as intellectual toys. The final part includes
a summary of the main points and some thoughts
about ground-water modeling in the future.

            STATE-OF-THE-ART OF
     Let me begin by stating my definition of what
a ground-water model is. Any system that can
duplicate the response of a ground-water reservoir
can be termed a "model" of the reservoir. The
operation of the model and manipulation of the
results is termed "simulation." Various models for
simulating ground-water flow are used  to the
extent that they simplify solution of ground-water
problems. Presently, there are four broad classes of
ground-water models including (1) analytical
formulas coupled with experience, (2)  numerical-
including finite-difference and finite-element
models, (3) analogs, and  (4) physical. In my
opinion, the order above is by the often used model.
Let me quickly discuss each type of model and
comment on its state-of-the-art. The following
discussion is brief.
    Analytical formulas coupled with experience.
This is the first time that I have written a paper and
included experience as any type of a model for

solving ground-water problems. I am mentioning
this since the "experience" model is always one of
the first to be applied in solving a ground-water
problem and, at the same time, is the model very
few speak about. Again, this particular model can
greatly reduce the time and effort necessary in
assembling a solution to a ground-water problem.
In some cases, you simply don't need any other
model other than experience coupled with use of
available analytical formulas to get a solution to
a problem. The state-of-the-art of the analytical
formulas—experience model is user  dependent
and ranges from completely missing the point on
up to getting one to within 20 percent or so of
the correct answer. The references of this paper list
several textbooks and articles that give analytical
solutions. In combination with recent journal
article reviews, the analytical formulas available in
textbooks are extremely valuable models.
     Numerical models of the finite-difference and
finite-element type are commonly available today
to solve almost any type of ground-water problem.
The numerical techniques only differ from one
another in the way the applicable differential
equations are approximated and solved with a
digital computer.
     Most of the numerical modeling was conceived
in the last 10 years. Computer codes have become
available and are being used by nearly all ground-
water hydrologists. Published articles on the
subject of numerical methods in ground water are
presently coming from nearly all corners of the
world. The references of this paper  give a
collection of published  articles that contain
computer codes that cover solution methods for a
large segment of common ground-water problems.
     There is, however, a problem with finding
computer codes in useable form (listing, operator's
manual, thoroughly debugged programs, comparisons
with theory, and practical applications example).
I believe this situation exists because most authors
find that the solution to a problem  is most
important and there is rarely enough money
alloted for proper documentation. There is, I
believe, also an attitude of unimportance attached
to the rather boring job of documentation.  It
appears that the arguments between finite-
difference versus finite-element techniques for
solving ground-water problems are presently fairly
well settled. Each technique has its  advantages and
disadvantages and neither one is the universal
panacea for solving ground-water problems.
     Analog modeling techniques had their hayday
in the 1950s and 1960s. Today, such models as
the electrical resistor and resistor-capacitor networks,
viscous fluid-parallel plate, and thermal systems are
hard to find. To my knowledge, only a few
universities teach analog design beyond a very
cursory level. The versatility, availability, and
convenience of the digital computer for solution
of ground-water problems were the main reasons
why analogs lost popularity.
     It is interesting to note that recent advances in
electronic miniaturization and printed  circuitry
technology has not caused a resurgence of use of
electrical analogs. One of the greatest advantages
of the analogs is that time does not need to be
discretized. The necessity of using time increments
in numerical modeling is always somewhat of an
aggravation and source of possible error that you
didn't have to be concerned with greatly when using
     The physical models that I am referring to are
of the scaled-down sand tank type. These models
have been around since Darcy's time and will
continue to be used, especially in the area of
ground-water quality and pollution research. A
great deal of work is still needed in the area of
dispersion, diffusion, ion exchange mechanisms,
and heat transport phenomena. The physical sand
tank model will continue to play a part in this
needed work area.
     One development in the sand tank model area
worth special note has been the recent fresh-water
storage in saline-water aquifers study by Kimbler
et al. (1975). Kimbler includes both design of
so-called "mini-aquifers" and finite-difference
models for studying two liquid flows in porous

              PRACTICAL TOOLS
     In assembling ideas for this paper, I made a
list of pros and cons of modeling. That list was
quite lengthy with all of the details. Upon
reflection on these ideas, I realized that most of the
individual items on the list were actually related.
Upon final analysis I reduced the list to three main
points on each side of the practical tool/intellectual
toy ledger.
     In my opinion, there are three main character-
istics that make ground-water models very practical
tools. First, there is no doubt that the models
of today provide a means for solving extremely
complex ground-water problems. Having methods
available for solution of complex problems, without
making a large number of gross approximations, is
an advantage that we have not always had.

 Secondly, the models of today are available to
 virtually everyone in the ground-water business.
 The days of the specialty laboratories are over
 and the tools are now in the hands of those doing
 the local work. And thirdly, having a numerical
 code and data deck available is a perfect record and
 tool for transferring information as to how a
 problem was solved. With this information, there
 is no doubt as to the exact assumptions used and
 the step-by-step solution of a problem. Let me
 expand on these thoughts.
     It is not hard to remember the time when
 analytical formulas and experience formed the
 principal means for ground-water problem solving.
 However, in applying these formulas the number
 of assumptions that had to be made was large
 concerning such items as aquifer heterogeneity,
 boundary geometry, multiple layering effects, and
 other geologic  conditions. Presently, digital com-
 puter modeling techniques can include the variation
 in these parameters and there is no longer a need
 (other than not having sufficient data) to make
 these assumptions. If you know that these
 parameters change in space or  with time, it is a
 relatively straightforward process of entering these
 variations as computer data input. There are existing
 computer models that can accommodate extremely
 complex geologic and hydrologic  conditions. Since
 about  1972, there has been an avalanche in develop-
 ment of numerical modeling techniques. Both water
 quantity and water quality modeling techniques
 are  now available. Simply stated, present ground-
 water models provide a  means for solving complex
 problems. There may be differences in opinion as
 to whether the models are suitable for practical
 application, but it is my thought that a sufficient
 number are to the extent that present ground-
 water models are indeed very practical tools for
 solving complex problems.
    A problem solving technique can be judged
 practical if it is used by a large percentage of all
 ground-water hydrologists. Presently, ground-water
 models are, in fact, being used by the majority
 of ground-water people. Ten years ago you could
 not say that. Today, the ground-water modeling is
 done locally where the problem area exists. There
 is no longer a need to send the data to a distant
 specialized laboratory for a solution as was the
 case 10 years ago when labs such as the Analog
 Model  Unit of the USGS existed. The use of
ground-water models is commonplace now. Thus,
 the  facts that ground-water models are being used
by so many researchers and men in the field and
 that central specialized equipment labs no longer
exist is a good indication that ground-water models
are very practical tools.
     It may seem strange to consider a ground-water
model computer code itself a practical tool other
than as a means of solving a problem. I believe,
however, that the actual code contains information
just as important, if not more important, than the
solution of the problem under study. The computer
code contains the precise method by which the
problem was solved. The code does not contain
assumptions,  differential equations, or the jargon
associated with a written report. You thus have a
perfect means for transferring information. Never
mind the claims made in the accompanying report
as to what the model can do; see exactly what it can
do by looking at the program code.
     Studying a ground-water model computer code
reveals a great deal about the validity of the solution
and the care in which the author solves problems
and documents exactly the model capabilities. The
shape of the model code is not only a very good
means of transferring information, but it  reveals
information as to the degree to which  the model is
a practical tool or an intellectual toy. In summary,
having a precise record of how a problem was
solved makes  computer modeling very practical.

    In my opinion, there are three main  character-
istics that put the use of ground-water models into
the class of intellectual toys. First, the wrong model
is frequently chosen for problem solving of which
overkill by use of an overly sophisticated  model is
an example. Second, the paying agency or client is
often disillusioned with model results because of
frequent modeler oversell in the early stages of the
project planning and budgeting. Finally, the prob-
lems are often solved with a numerical code that
is a mystery to all except the modeler himself. An
amplification  on  these thoughts follows.
    Using a model which is overly sophisticated
for the problem at hand is a common occurrence.
Probably, lack of geohydrologic input data accounts
for the largest number of these occurrences. The
choice of model for the solution  of a problem
should be based upon matching the two together.
As mentioned previously, there are many  problems
that can be solved by experience and application of
formulas. On  occasion a computer model  is chosen
when an application of a formula would do. On the
other hand, I  am aware that public relations and
audience impact are sometimes important and
choosing a computer model is done for these

purposes. In these cases, one has to be cautious.
In any event, choosing an overly sophisticated
model which doesn't fit the problem is a case of
applying the wrong model. The result becomes
more of an intellectual exercise than anything else.
     Excessive modeler claims and oversell of the
power of computers, can lead to client disillusion-
ment with the over-all modeling process. Most of
these panacea-oversell problems come to light soon
after the results of the field-computer calibration
runs become known. Because the data base for
ground-water studies quite often is something else
to be desired, this situation often occurs and
backlash from the paying agency or  client results.
I believe this oversell problem is a serious one at
times and requires restraint on the part of those
in charge of project budgeting and planning.
     Solving a ground-water problem and not
giving an adequate description as to  how it was
done is a situation that commonly occurs in the
modeling business. Documentation of computer
codes is not a popular job. The usual procedure
is to explain the problem in a report, discuss the
differential and approximating equations involved,
explain in words  that a computer  program was
developed and used to solve the equations, and
then give the results. The missing gap is the com-
puter program. From my own experience, that is a
big gap that needs work. There are problems that
need  solving, and if someone has taken the time
to write a program and publish the results, why not
let us benefit by  that work and also  publish the
code? The answers vary around the theme that it
would be easier to develop your own code.
     It is my opinion that undocumented program-
ming, other than providing the immediate solution
sought, is mostly a wasted effort.  In addition, if
the documentation is not done along with the
development of the code, six months afterwards
when your memory has faded, the code is
virtually worthless. Then, it would be easier to
develop your own code. With the  one exception of
immediate necessities that will not need to be
repeated, the undocumented ground-water model is
an intellectual toy of the first magnitude.

     In summary, ground-water models, in my
opinion, are mainly intellectual toys when principal
investigators choose an overly sophisticated model
for the problem at hand, when the paying customer
finally realizes that the model is not a panacea for
his problem, and when the principal investigator
does  not adequately document his work. Models,
as very practical tools, are in evidence today since
most every investigator now has available models to
solve very complex problems. Furthermore, the
existence of the computer code precisely tells the
entire story of how a problem was solved.
     In my opinion, the future looks exciting as
more models will be developed, more  investigators
at the grass-roots level will be effectively using
models, and low-priced computer equipment will
become commonplace for nearly everyone's use.

     The references listed below have been chosen from
published articles that contain the three elements of theory,
documented program codes or model construction features,
and applications. Articles that do not have these three
elements are somewhat limited in scope and have been
purposely avoided.
     The type of model described in the reports is listed
immediately following the citation.
     This reference list would make a small library which
would represent the state-of-the-art in ground-water
modeling from a practical viewpoint.

Afshar, A. and M. A. Marino. 1976. Mathematical model
     for simulating soil moisture flow considering evapo-
     transpiration. Water Science & Engineering Papers
     Number 6002. Department of Water Science and
     Engineering, University of California,  Davis,
     California. (Finite difference)
Amerman, C. R. 1976. Waterflow in soils: A generalized
     steady-state, two-dimensional porous  media flow
     model. Agricultural Research Service, U.S. Department
     of Agriculture Report ARS-NC-30, 62 pp. (Finite
Bear, Jacob. 1972. Dynamics of fluids in porous media.
     American Elsevier, 764 pp. (Textbook)
Brock, R. R. 1976. Hydrodynamics of perched mounds.
     Journal of the Hydraulics Division, Proceedings of
     ASCE. v. 102, HY8, pp. 1083-1100. (Finite
Carslaw, H. S. and J. C. Jaeger. Second Edition, 1959.
     Conduction of heat in solids. Oxford. 510 pp.
Cecen, K. and E. Omay. 1973. Three dimensional viscous
     flow analogy. Proceedings of the Fifteenth Congress
     of the International Association for Hydraulic
     Research, State Hydraulic Works of Turkey, Istanbul.
     v. 3, pp. C10-1 to C10-8. (Viscous fluid)
Coe, J. J. (District Engineer, Southern District, Department
     of Water Resources, State of California). 1974.
     Mathematical modeling of water quality for water
     resources management—v. 1, Development of the
     groundwater quality model. District Report. Depart-
     ment of Water Resources. (Finite difference)
Collins, M. A., L. W. Gelhar, and J. L. Wilson III. 1972.
     Hele-Shaw model of Long Island aquifer system.
     Proceedings of ASCE, Journal of the Hydraulics
     Division, v. 98, HY9, pp.  1701-1714.  (Viscous fluid)
Cooley, Richard and John Peters (Hydrologic Engineering
     Center, Corps of Engineers, U.S. Army, Davis,

      California). 1972. Finite element solution of steady
      state potention flow problems. In Hydrologic
      Engineering Methods for Water Resources Develop-
      ment, v. 10: Principles of Groundwater Hydrology.
      (Finite  element)
Cooley, Richard L. 1974. Finite element solutions for the
      equations of groundwater flow. Technical Report
      Series H-W. Hydrology and Water Resources,
      Publication no. 18. Center for Water Resources
      Research. Desert Research Institute, University of
      Nevada. (Finite element)
Croley, T. E., II. 1977. Hydrologic and hydraulic computa-
      tions on small programmable calculators. Iowa
      Institute of Hydraulic Research. 837 pp. (Textbook)
Davis, S. N. and R.J.M. DeWeist. 1966. Hydrogeology. John
      Wiley & Sons, Inc. 463 pp. (Textbook)
DeMeier, W. V., A. E. Reisenauer and K. L. Kipp (Battelle,
      Pacific Northwest Laboratory, Richland, Washington
      99352). 1974. Variable thickness transient ground-
      water flow model user's manual. BNWL-1704.
      (Finite  difference)
Earlougher, R. C., Jr. 1977. Advances in well test analysis.
      Society of Petroleum Engineers AIME. 264 pp.
      (Oil field textbook)
Evans, D. H.,  B. M. Harley, and R. Bras. 1972. Application
      of linear routing systems to regional groundwater
      problems. Massachusetts Institute of Technology,
      Ralph M. Parson Laboratory Report no. 155, 197
      pp. (Linear routing)
Evenson, D. E. and A. E. Johnson. 1975. Parameter estima-
      tion program. Texas Water Development Board
      Contract with Water Resources Engineers, Inc.,
      Walnut  Creek, California. (Inverse problem)
Payers, F. J. and J. W. Sheldon. 1962. The use of a high-
      speed digital computer in the study of the hydro-
      dynamics of geologic basins. Journal of Geophysical
      Research, v. 67, pp. 2421-2431. (Finite difference)
Freeze, F. A.  1970. Moire pattern techniques in  ground-
      water hydrology. Water Resources Research, v. 6,
      pp. 634-641. (Graphical technique)
Freeze, R. A.  1972. A physics-based approach to hydrologic
      response modeling: Phase L Model development.
      Completion Report, Contract No. 41-31-001-3694,
      Office of Water Resources Research, Washington,
      D.C. (Finite difference)
Gambolati, Giuseepe. 1976. Transient free surface flow to a
      well:  An analysis of theoretical solutions. Water
      Resources Research, v. 12, pp. 27-39. (Formulas)
Gelhar, L. W., P.  Y. Ko, H. H. Kwai and J. L. Wilson. 1974.
      Stochastic modeling of groundwater systems.
      Massachusetts Institute of Technology, Ralph M.
      Parsons Laboratory Report no. 189, 313 pp.
      (Stochastic technique)
Green, D. W.,  H.  Dabin, and J. D. Khare. 1972. Numerical
      modeling of unsaturated groundwater flow including
      effects of evapotranspiration. Completion  Report,
      Contract no. 14-31-0001-3084, Office of Water
      Resources Research, Washington, D.C. (Finite
Gupta, S.D..K. K.Tanji, and J.N. Luthin.  1975. A three-
      dimensional finite element groundwater model.
      California Water Resources Center Contribution no.
      152, 119 pp. (Finite element)
Gureghian, A. B. 1975. A study by the finite-element
      method of the influence of fractures in confined
      aquifers. Society of Petroleum Engineers Journal.
      v. 15, pp. 181-191. (Finite element)
Hansen, V. E. 1952. Complicated well problems solved by
      the membrane analogy. Transactions of the American
      Geophysical Union, v.  36, pp. 912-916. (Rubber
Hantush, M. S. 1964. Hydraulics of wells. Advances in
      Hydroscience, v. 1. V. T. Chow, Editor, pp. 281-
      432.  (Textbook)
Huang, Y. H. and S-J.  Wu. 1974. Analysis of unsteady flow
      toward artesian wells by three-dimensional finite
      elements. University of Kentucky Water Resources
      Research Institute Report no. 75, 164 pp. (Finite
Huntoon, P. W. (Hydrogeologist, Wyoming Water Resources
      Research Institute, University of Wyoming, Laramie,
      Wyoming).  1974. Finite difference methods as
      applied to the solution of groundwater flow problems.
      (Finite difference)
Intercomp  Resource Development and Engineering, Inc.
      (1201 Dairy Ashford, Houston, Texas  77079). 1976.
      A model for calculating effects of liquid waste disposal
      in deep saline aquifer. Part I—Development. Part II—
      Documentation. U.S.G.S. Technical Water Resources
      Investigations 76-61. (Finite difference)
Javendel, K. and P. A. Witherspoon. 1967. Use of thermal
      model to investigate the theory of transient flow to
      a partially penetrating well. Water Resources  Research.
      v. 3, pp. 591-597. (Thermal)
Jorgensen,  D. G. 1975. Analog-model studies of groundwater
      hydrology in the Houston District, Texas. Texas Water
      Development  Board Report 190, 84 pp. (Resistor
Karanjac, J., M. Altunkaynak, and G. Ovul.  1976. Mathe-
      matical model of Elazig-Ulova Plain. Ministry of Power
      and National Resources, Ankara, Turkey. (Finite
Karplus, W. J. 1958. Analog simulation. McGraw-Hill,
Karplus, W. J. 1967. Hybrid computer simulation of
      groundwater basins. American Water Resources
      Association National Symposium on Groundwater
      Hydrology,  San Francisco, pp. 289-299. (Resistor-
Kimbler, O. K., R. G. Kazmann, and W.  R. Whitehead.
      1975. Cyclic storage of fresh water in saline aquifers.
      Louisiana State University, Water Resources Research
      Institute Bulletin 10, 78 pp. (Sand tank-finite
Knowles, T. R., B. J. Claborn and D. M. Wells. 1972. A
      computerized procedure to determine aquifer
      characteristics. Water Resources Center Publication
      WRC-72-5, Texas Tech  University, Lubbock,  Texas.
      (Inverse problem)
Lehr, Jay H. 1963. Ground-water flow models simulating
      subsurface conditions. Journal of Geological Education.
      v. 11, pp. 124-132. (Sand tank)
Mack, L. E. 1957. Evaluation of a conducting-paper analog
      field plotter as an aid in solving groundwater
      problems. State Geological Survey of Kansas  Bulletin
      no. 127, part 2, 47 pp.  (Resistance paper)
Marmion, K. R. 1962.  Hydraulics of artificial recharge in
      non-homogeneous formations. University of

     California, Berkeley Water Resources Center Contribu-
     tion no. 48, 88 pp. (Glass beads sand tank)
Meyer, W., J. P. Reussow, and D. C. Gillies. 1975. Availability
     of ground water in Marion County, Indiana. U.S.G.S.
     Open-File Report 75-312, 87 pp. (Finite difference)
Molz, F. J. 1974. Practical simulation models of the
     subsurface hydrologic system with example applica-
     tions. Water Resources Research Institute Bulletin
     19, Auburn University, Alabama. (Finite difference)
Morel-Seytoux, H. J. and C. J. Daly.  1975. A discrete kernel
     generator for stream-aquifer studies. Water Resources
     Research, v. 11, pp. 253-260. (Finite difference)
Murty, Vadali Venkata Narasimha. 1975. A finite element
     model for miscible displacement in groundwater
     aquifers. Ph.D. Dissertation, University of California,
     Davis, California. (Finite element)
Muskat, M. 1949. Physical principles of oil production.
     McGraw-Hill.  922  pp. (Textbook)
Neuman, S. P. and P. A. Witherspoon. 1970. Variational
     principles for confined and unconfined flow of ground
     water. Water Resources Research, v. 6, pp. 1376-
     1382.(Finite element)
Neuman, S. P. and P. A. Witherspoon. 1971. Analysis of
     nonsteady flow with a free surface using the finite
     element method. Water Resources Research, v. 7,
     pp. 611-623. (Finite element)
Patten, E. P., Jr. 1965. Design, construction, and use of
     electric analog model. In Analog Model Study of
     Groundwater in Houston District, by L. A. Wood
     and R. K. Gabrysch, Texas Water Commission
     Bulletin no. 6508,  103 pp. (Resistor capacitor)
Finder, G. F. 1970. A digital model for aquifer evaluation.
     Techniques of Water-Resources Investigations of the
     U.S.G.S., Book 7, Chapter Cl, 18 pp. (Finite
Pinder, G. F. and W. G. Gray. 1976.  Is there a difference
     in the finite element method? Water Resources
     Research, v. 12, pp. 105-107.
Pinder, G. F. and W. G. Gray. 1977.  Finite element
     simulation in surface and subsurface hydrology.
     Academic Press. 295 pp. (Finite element)
Prickett, T. A. and C. G. Lonnquist.  1971. Selected  digital
     computer techniques for groundwater resource
     evaluation. Illinois State Water Survey Bulletin 55,
     Urbana, IL.62 pp. (Finite  difference)
Prickett, T. A. and C. G. Lonnquist.  1973. Aquifer simula-
     tion model for use on disk supported small computer
     systems. Illinois State Water Survey Circular 114,
     Urbana, IL. (Finite difference)
Prickett, T. A. and C. G. Lonnquist.  1976. Metodos de
     ordenador para evaluacion de recursos hidraulicos
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Remson, I., G. M. Hornberger, and F. J. Molz. 1971.
     Numerical methods in subsurface hydrology. John
     Wiley & Sons, Inc. 389 pp. (Numerical textbook)
Rogers, W. E. 1954. Introduction to electric fields.
     McGraw-Hill. 333 pp. (Viscous fluid)
Rovey, C.E.K. 1975. Numerical model of flow in a stream-
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     Paper no. 74, 73 pp. (Finite difference)
Saleem, Z. A. 1973. Method for numerical simulation of
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Santing, G. 1958. A horizontal scale model based on the
     viscous flow analogy for studying groundwater flow in
     an aquifer having storage. International Association of
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     (Viscous fluid)
Segol, Genevieve, G. F. Pinder and W. G. Gray (Water
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Sherwani, Jabbar K. (Department of Environmental Sciences
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     (Finite difference)
Shibasaki, T. (editor). 1976. Groundwater basin management.
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Stallman, R. W. 1956.  Numerical  analysis of  regional
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Thrailkill, J. 1972.  Digital computer modeling of limestone
     groundwater  systems. University of Kentucky Water
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     (Finite difference)
Todd, D. K. and  J.  Bear. 1959. River seepage investigation.
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Walton, W. C. 1970. Groundwater resource evaluation.
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Wiggert, D. C. 1974. Two-dimensional finite element
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Wilson, John L. and L. W. Gelhar. 1974. Dispersive mixing
      in a partially saturated porous medium. Report no.
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      and Hydrodynamics, Massachusetts  Institute of
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Winslow, J. D.  and C. E. Nuzman. 1966. Electronic  simula-
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Witherspoon, P. A., I. Javandel, and S. P. Neuman.
      1968. Use of finite element method in solving
      transient flow problems in  aquifer systems. Inter-
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Wright, D. E. 1968. Nonlinear flow through granular media.
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      Solutions of anisotropic seepage by finite elements.
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      Thomas A Prickett received his Bachelor 's degree from
the University of Illinois in 1960. He was employed as a
ground^water hydrologist -with the Illinois State Water
Survey for 17 years where his responsibilities were resource
evaluation and developing basic methodologies for solving
problems. He received the National Water Well Association
Science Award in  1977 for his contributions to the science
of ground-water hydrology. In 1977, he became Midwest
Regional Manager of the Water Resources Division of the
environmental consulting firm of Camp Dresser & McKee
located in Champaign, Illinois. In this new position, he has
been involved mainly in projects related to regional systems
analysis for municipalities and in the analysis of impacts of
mining on ground^water resources.

Ground-Water  Computer  Models
Practical  Tools
by Russell E. Darrc
     One of the most valuable and practical tools the
ground-water manager can use is the computer model, be it
wellfield, conjunctive, solute transport, or statistical.
Although these models vary in complexity, the end
product is purely a function of the user's ability to select
the appropriate level of modeling for a particular project.
Any professional working in the field of hydrogeology
should adapt to and use ground-water models to be truly

     There are a number of terms in the title of
this paper which need defining. For example, at one
time a computer was a very sophisticated, expensive,
cumbersome machine. Nowadays, there are hand-
held units capable of performing everything that
the machine called the computer could do a few
years ago. These hand-held machines are also
called computers. Are they computers? Webster
defines a computer as a programmable electronic
device that can store, retrieve and process data. It
is this definition that is used throughout this paper.
      Presented at The Fourth National Ground Water
 Quality Symposium, Minneapolis, Minnesota, September
 20-22, 1978.
     "Vice-President, Groundwater Division, Wright Water
 Engineers, 2420 Alcott, Denver, Colorado 80211.
There is little doubt that the hand-held machine
falls into the computer category.
    We think of a model as a description or
analogy used to help visualize something that
cannot be directly observed, as defined by Webster.
The word practical has been defined as something
being in effect, not theoretical, and capable of being
put to use. A model is a tool, an instrument
necessary for the practice of a profession, and a
means to an end. Therefore, we see a very broad
definition, as used in this paper, of computer models
as practical tools.
     Ground-water management must be practiced
effectively and efficiently if we are to  bring about
the best possible applications for our valuable
ground-water resource. One of the most valuable
tools to the ground-water manager is the computer
model. The model may be a mental conceptualiza-
tion; an empirical relationship; a physical device;
or a collection of mathematical, statistical, and/or
empirical statements. Models can be programmed
on small or large computers and programmable
     Management models fall into four basic
categories: wellfield models, conjunctive use
models, solute transport models, and statistical
models. There are many levels of complexity in
computer modeling as well as a wide variety of
programs available to the user. The state of the art
today is such that any professional working in the
field of hydrogeology should adapt to and use
ground-water models in order to be truly efficient.

     Wellfield models may range from the simple,
 single well model in a homogeneous, isotropic,
 infinite, aquifer to complex models requiring the
 pumping of several points having multiple boundary
 conditions, both barriers and recharge. The purpose
 of the wellfield model can range from simply a
 desire to determine the drawdown at a given point
 due to a given pumping scheme; to maximizing the
 efficiency of a pumping schedule for an entire
 wellfield comprised of several wells. These wellfield
 models  can and, if used effectively, will decrease
 the operating costs both from the standpoint of
 energy consumption  as well as pump maintenance.
     Conjunctive use modeling is a necessity in the
 State of Colorado. A specific example is the South
 Platte Rules and Regulations Case which requires
 the determination of stream depletion due to well
 pumping. Items taken into consideration for
 modeling are the pumping schedule, the application
 of the water (i.e., sprinkler or flood irrigation),
 consumptive use, and the return flows back  to the
 aquifer  and eventually to the river system. The
 input from a conjunctive model is then used to
 develop an augmentation plan. This augmentation
 plan provides for the pumping of the well in the
 alluvial  aquifer without creating injury to senior
 vested surface-water rights. One of the most
 common equations used to model stream  depletion
 is the complimentary error function. Work pub-
 lished on this subject can be found in Transient
 Groundwater Hydraulics by Professor Robert E.
     Another use for conjunctive modeling would be
 models developed for entire basins including
 hundreds or even thousands of square miles. Such
 models have been developed in Colorado to look at
 the effects of well pumping on recharge to and
 discharge from the aquifers. A number of nodal
 points on such a model and the number of layers
 can produce a model which could be cost pro-
 hibitive, because of the amount of input data
 required, number of iterations, and total number  of
     Solute transport models can be used to
 determine the rate and area of flow from discharges
 such as those associated with leaky landfills. In
 addition, such models can also be used to study
 salt-water intrusions into fresh-water aquifers.
A great deal of work  has been done in studying
 the plumes associated with ponds containing rather
 toxic materials. An example is the Colorado
 State University study of pollutant  leakage from a
 waste disposal pond from a chemical plant located
 near Denver. A model utilizing the method
characteristics successfully predicted the areal
extent relative to the concentration of contaminants
traveling from the pond to a nearby stream through
the alluvial aquifer.
     The fourth practical modeling technique to be
discussed in this paper is the statistical models. These
models have been discussed in literature for the last
couple of decades. However, it has been in the last
decade that significant advances have been made
in this field of hydrogeology due to digital
computers and calculators. For example, it is now
quicker, more efficient and accurate to determine
transmissivity using a Jacobs Simplification Method
with a hand-held calculator and statistical methods,
than it is to do the entire solution graphically and
mathematically. Using the method of linear
regression, the time drawdown data can be analyzed
in the form of Y = A + B natural logarithm of X. It
thus works out that A = the intercept at T = 1 minute,
B = the slope of  the line necessary in determining
the transmissivity. Using an additional statistical
method called Coefficient of Determination, a
comparison of the fit of the data to the least
squares line can be made and R2 value of 1 would
indicate a perfect fit. Another beauty of this method
is that the intercept time of the intersection of the
line with the static water level can be mathematical-
ly determined with high accuracy. Therefore, the
transmissivity and Coefficient of Storage are
statistically modeled in order to determine
more accurate values.
     In order to  analyze hydrologic data where the
data are extensive, statistical models have been used
to reduce that data and give it meaning. Some of
the statistical models used include: frequency
analysis, scatter diagram analysis, bivariate correla-
tion, factor analysis, discriminate function, and
trend analysis. All of these methods have been used
in modeling the ground-water conditions within the
Piceance Creek Basin of Colorado.
     In summary, the digital computer, as well as
the analog, and combinations thereof, can and are
being used throughout the United States very
effectively. There are also, however, many
documented cases of what we have all known for a
long time, garbage in and garbage out. There are
two basic fundamentals that must not be violated
when using the wellfield, conjunctive use and solute
transport computer models. These are a mass
balance i.e., that of any given cell or any given
point in a model, the water in must equal the water
out plus the water stored. This continuity require-
ment is essential and often overlooked. The second
fundamental is of course, Darcy's Law. Many people

will argue that if you have enough data to build a
computer model, you already have the answer. But,
on the other hand, computer models are most useful
when there is little data. Computer simulation
models can be used to conduct a sensitivity analysis
quickly and efficiently, thereby allowing the
researcher to determine a range of values for which
an answer should be reasonable.
     Ground-water computer models, which can be
classified as practical tools, vary in complexity
from a Theis Solution of a single well, programmed
on a hand-held calculator to multilevel finite
element or  difference codes programmed in a large
computer such as a CDC  7600. The cost of such
practical tools and their use can be minimal or
extensive, i.e., a few dollars or  a few tens of
thousands of dollars. The practicality of such
models and their results is purely a function of the
intelligence of the user, his ability to select an
appropriate level of modeling for a particular
project, and his ability to communicate the results
to those who  need the information.
     Models do not eliminate the need for data
gathering efforts, practical human experience,
judgement evaluations and common sense. They
are only tools, which are practical when these
criteria are  combined with the  speed and accessi-
bility made available by the use of modern day

Cooper, H. H. and C. E. Jacob. 1946. A generalized graphic
     method for evaluating formation constants and
     summarizing wellfield history. Trans. Amer. Geophys.
     Un. 27, pp. 526-534.
Davis, J. C. 1973. Statistics and data analysis in geology.
     John Wiley and Sons,  Inc., New York, pp. 550.
Hodgson, F. D. 1978. The use of multiple linear regression
     in simulating ground-water level responses. Ground
     Water, v. 16, no. 4, pp. 249-253.
Finder, G. F. and J. D. Bredehoeft. 1968. Application of
     the digital computer for aquifer evaluation. Water
     Resources Research. 4 (5).
Prickett, T. A. and C. G. Lonnquist. 1971. Selected digital
     computer techniques for groundwater resource
     evaluation. Bull. Illinois State Water Survey, Urbana.
     55, pp. 62.
Theis, C. V. 1935. The relation between the lowering of the
     piezometric surface and the rate and duration of
     discharge of a well using ground-water storage. Trans.
     Amer. Geophys. Un. 16, pp. 519-524.
Thiem, G. 1906. Hydrologische metoden. Gebhardt,
     Leipzig, pp. 56.
Walton, W. C. 1970. Groundwater resource evaluation.
     McGraw-Hill Book Co., New York. pp. 664.
Witherspoon, P. A. and S. P. Neuman. 1973. Finite element
     methods in hydrogeology. Bull. B.R.G.M., Paris.
     4, pp. 294.
     Russell E. Darr is the Vice President of Wright Water
Engineers, Inc., where he is the consulting ground-water
hydrologist-geologist. He obtained his B.S. in Geology from
the University of Washington in 1967. He performed
graduate work in Ground-Water Geology at the University
of Colorado in 1973. Mr. Darr has served on various
committees with the National Water Well Association and
is a member of the American Geophysical Union.

 Ground-Water  Computer  Models
 Intellectual Toys
 by Henry A. Baski
     Ground-water computer models are, certainly, toys
which provide intellectual stimulation. They can be useful
tools for advancement of the ground-water profession,
but I believe that they have been blown out of proportion
and that this might cause irreparable damage to our
     It is important to see where computer models fit
into the ground-water problem-solving process. I believe
that ground-water computer programs are simply a
complicated "turn the crank" tool for making projections.
They're one type of tool out of several which requires
aquifer and confining bed characteristics to facilitate
making projections. A second approach for making
projections involves the direct extrapolation or manipulation
of data which does not require transmissivity, storage
coefficient, leakance,  and other interpreted characteristics.
Further, I believe that the collection and evaluation of
data are of greater importance  than the projection methods
and/or tools in arriving at answers.
     Advantages of ground-water computer models
include: speedy analyses once a program is working, ability
to handle many parameters, and utilization of a large data
base. The disadvantages include: use of computer models
as end goals, tendency for misapplications, time-consuming
setup, a waste of time and money in some cases, and
diversion of human talent from useful ground-water work.
      Presented at The Fourth National Ground Water
Quality Symposium, Minneapolis, Minnesota, September
20-22, 1978.
     bGround-Water Consultant, 1586 S. Robb Way,
Denver, Colorado 80226.
     I believe that ground-water computer models
can destroy our ground-water profession!
They are, certainly, intellectual toys that can keep
people entertained for long periods of time.
     There is a disease creeping into this computer
modeling business and I'll call it "computerism."
Some of the symptoms—misapplication, oversell and
mysterious methods—were brought up by Tom
Prickett. Also, there is an important item Tom
didn't mention. I think that there are occasions
when computer models are deliberately used to
keep people busy and to spend  time and money.
This has to stop!
     Models can be practical tools; but when they
are used as toys, it can destroy people's confidence,
both outside and within our profession. In some
parts of this country people have more confidence
in water witches (or dowsers) than they do in
ground-water professionals and  their computer
models. This is because the dowser goes out there
with a stick and these people see something
happening with that stick. Then the dowser says,
"If you drill here, you're going  to get water." Lo
and behold, they drill there and they do get water!
And the water witch gets credit for it! Actually,
he could hardly go wrong. When my brother, Dad,
and I were drilling in northeastern Minnesota, we
encountered only one completely dry hole out
of about 2,000. Anyway, people do not see
something happening with a ground-water computer
model, though it comes up with answers (four or

five significant figures). They seldom have a
reliability attached to them. The reliability of the
answers cannot go beyond the reliability of the
data base. However, there is a tendency to make
projections beyond the data base and this is where
we get into trouble.
    I have to mention an article which was on the
front page of the Denver Post on December 1, 1977.
According to it, a complex computer program
was proposed for the Denver Basin. Study for it
was estimated to take seven years and cost $687,000.
Three years would be for collecting data; then
during the fourth year, the characteristics of the
aquifers would be measured. The model would
be designed to simulate the water levels and
movements in the fifth and sixth years—maybe.
This is absurd! It shouldn't take seven years to
study the Denver Basin. I think that the purpose of
this proposal is to crank out a ground-water
computer model . . . it's a disease!  And it can
adversely affect our profession.
    Where do computer models fit in? We have
our ground-water hydrogeology business which
involves everything from drilling, collecting data,
evaluating data to making projections. Concerning
the latter, there are two classes of projection
methods. The first class of projection methods
which is most familiar uses aquifer and confining
bed characteristics as input to models. It is vital
to have transmissivity and storage coefficient,
boundary conditions, recharge effects, etc. when
using models. Tom had a very good list of models.
However, he had experience as a model by itself;
I beg to differ with him. I think experience is a
vital part of all of the models. You cannot use
models effectively without experience. If a
computer model doesn't work, the hydrologist
who has experience and good judgment can make
it work. Computer models are one type of many
models used in the first class of projection methods.
This is where they fit ... though, the importance
of computer models is sometimes blown out of
     The second class of projection methods which
is not so familiar uses direct extrapolation of data.
I don't know if it is being taught in any of the
college ground-water courses. But I frequently
solve problems (like dewatering of mines) using
field data, and trends of data plus ground-water
flow theory without knowing aquifer and confining
bed characteristics. For example, if you're going to
have a well field with six wells and you want to
know what is going to happen at the end of twenty
years, put in six wells and at the end of twenty years
you will have your answer. Now, that is the
simplest; but it takes too long! Let me work back-
wards to indicate what extrapolation means. Suppose
you pump six wells for ten years, and plot the
data. It is not difficult to extend the plots to
twenty years. Furthermore, you can pump one
well for one year or  less and extrapolate it for
six wells for twenty  years. Eventually, we might see
computer models use this extrapolation method.
     I believe that the collection and interpretation
of data are more important  than any projection
method. Projection methods include flow nets, well
formulas, heat flow formulas, computer programs,
extrapolations, etc. I have found that projections
are usually within plus or minus 20 percent providing
one starts with the same data and assumptions.
However, the data, aquifer and confining bed
characteristics, and assumptions can easily vary by  a
factor of 2 to 10. This emphasizes the absurdity of
many computer printouts which have answers with
four to five significant figures and no reliability
indicated. Does this  mean an accuracy of plus or
minus one part on 10 thousand? No! It doesn't
mean that. But it could be misleading. I cannot
stress enough the importance of the collection and
interpretation of good basic data.
     Short-term and long-term projections are
different. I push things to their extreme to simplify
problems and make  them easier  to solve. Short-term
productions depend on transmissivity values-
forget recharge; forget storage coefficient. What is
the production of the well for the first day,  or for
the first couple of months?  It's a function of
transmissivity! For a well field, it's transmissivity!
Computer programs have their nodes, finite
elements, finite differences, and equations of
water going  in and out, but transmissivity is a key
item. We all feel confident on short-term analysis.
What happens on long term? Transmissivity
becomes much less important. We have to know
recharge and storage. If you fill  a bath tub with
water, it will resemble the kind of ground-water
basins we have in the western United States. We do
not care what the transmissivity is, nor do we care
whether you use two or ten straws, when it is
pumped the water levels drop! Recharge is
negligible. Who needs a computer model for that!
It's mining of the water! There may be some
socioeconomic and legal consideration on how fast
we mine it. Conversely, in areas  like Florida, the
Floridan aquifer's long-term pumping rate is a
function of  storage and recharge; on the longer
term it is dependent on recharge of precipitation
(leakance). With leakance values being more

difficult to obtain than storage coefficient, it is a
problem to arrive at valid projections . . . with or
without computer models.
     The above discussion illustrates that
computer models are only one type of model which
may be applied in one  class of projection methods.
In addition, I believe that the collection and
analysis of data are more important than the two
classes of projection methods for arriving at valid
answers. Therefore, the over-all importance of
computer models is limited and they can be
intellectual toys of the highest order.
     I'd like you to ask yourself the following
questions regarding your projects. They are
related to stopping or, at least, reducing this
disease which we have. (1) What is the purpose of
the ground-water program or study that you are
working on? Is it to go out and collect data? Is it
to come up with an answer? Or is it to keep busy?
(2) How accurate should your answer be? Believe
it or not, there are ground-water problems in which
yes or no is all the client needs to know. Like, is the
water level going to go down or is it going to come
up? Or will mine dewatering be more or less than
5,000 gpm? (3) Does the data base justify the
method of analysis that is used? Or are you
cranking out that program just to keep busy?
(4) Is the cost in line with  the purpose, accuracy
and data base of the ground-water program?
(5) The last question is, "Are any of the symptoms
of computerism present in the jobs which you
are working on?" If so, do something about it!
     Henry A. Baski has 17 years experience ranging
from drilling of wells to completion of technical reports.
He has worked in 12 States and his specialties include:
data collection programs, air lift pumping tests, surface-
water/ground-water interactions, short- and long-term
projections, and mine dewatering analyses. Prior to
becoming an independent ground-water consultant, he was
a senior hydrologist with Dames & Moore, and he had been
an associate of Wright Water Engineers, Inc. Previously,
he had been a partner in a family well drilling business.
Mr.  Baski received a bachelor of Geophysics from the
University of Minnesota, and he is a member of the NWWA,

Audience  Response to   Session  VIII  —
Ground-Water  Computer Models
Raphael Kazmann, Louisiana State University, 231 Duplantier
Blvd., Baton Rouge, Louisiana 70808: One of the big
troubles with computer models of all sorts is that it is
possible that something is going on that you don't under-
stand. I remember an organization made a big analog model
of the Gulf Coast and they didn't take into account that
some of the clays acted as osmotic membranes and are
losing water to the Gulf, although  the water level on the
land is below sea level already. We saw water coming into
the Gulf, the potentiometric surface was measured
regularly and we could tell you exactly where it intersected
at sea level and it kept on going down. Water was moving
and we didn't know where it was going and for 10 years
we were puzzled about that until finally Paul Jones figured
out that there was an osmotic relationship between the
fresh water in the aquifer and the salt water in the Gulf
and the water was moving straight up into the Gulf, with a
driving force of about 600 Ibs psi.  This big model didn't
take this into account, and this phenomenon existed over
150 miles of shore.  So there's one  big deficiency in many
of our models. They don't take all of the natural
phenomenons into account.  My own feeling about these
things is that we don't trust any model, mathematical
or otherwise until we test it out with a physical test of
some sort and make sure that we haven't omitted any of
the major assumptions. Furthermore, many fine
mathematical program results are likely to be very, very
wrong, simply because someone is always coming in
and doing something that was not  assumed in any of the
initial configurations.

Tim Cleath, James M. Montgomery Consulting Engineers,
Inc., 555 E. Walnut, Pasadena, California 91101:  I have
one simple question based on an experience I had recently
with a ground-water model in the south San Francisco
Bay area. There was a ground-water  model made by the
Department of Water Resources with which we really had a
lot of problems. Because of this ground-water model, one
of the local agencies has drawn up ground-water basin water
level contour maps. They've combined both the unconfined
aquifer water levels and the artesian wells all in the same
map. I don't know if you can imagine what that would
look like, but it is definitely a wrong interpretation and
my question is, once you've  got one of these models and
it isn't right, what do you do with it?
      Russ Darr, Wright Water  Engineers, 2420 Alcott,
Denver, Colorado 80211: I've seen the same thing done
by the U.S.G.S. which came out with a composite water
level map. It has value. I think if you know the trans-
missivities of the two aquifers you can separate the various
heads by a formula developed by Dr. Dan Foegle. I
think there's a discussion of  that in Professional Paper
908. What do you do with a model that doesn't work?
My guess is that you throw it away and start all over again.

Francis A. Kohout, U.S.G.S., Water  Resources Division,
Woods Hole, Massachusetts 02543:  The mention of Robert
E. Glover's name by Mr. Darr brought to mind a number
of refreshing incidents associated with some of the early
work in mathematical and computer hydrology. Since I
won't be around much longer, I thought the audience
might enjoy hearing several of these in the form of
     Well the first occurred at an NWWA annual meeting
about 25-odd years ago. Bob Stallman had become very
excited about the finite-difference approach to solving
hydrologic problems.  He recognized  that many of the
practical problems were too complicated to resolve by
rigorous mathematics. Having an engineer's background,
Bob was greatly influenced by Southworth's book on
numerical analysis and he proceeded to wear out numerous
mechanical calculators in the process of "reducing the
residual to zero" at the nodes of a relaxation net. Pretty
soon he got bored with wearing out his fingers on the hand
calculators and began monkeying around with electronics-
first with Teledeltos paper, silver paint,  a razor blade, a
power supply, and a voltmeter. Then he really went into
the electronics business, learned how to build constant-
current and constant-voltage power supplies, etc., and put
together a machine with nodes, as I recall, about 10 by 10—
a total of 100 nodes. This was all built up in a big
6-foot-tall electronics rack with  all kinds of meters and
volume control knobs, etc.—a very impressive piece of
machinery on which boundary conditions could be
simulated and which could be used to measure
simulated heads on the water table, drawdowns at pumping
wells, withdrawal rates, and so on. Well, Bob was
demonstrating this to anyone who would listen as part
of the U.S.G.S. exhibit at the NWWA meeting. And as it
so happened, an interested passerby was a crusty, old,
leather-faced well driller. Bob carried on, explaining and
demonstrating with meter readings and knob turnings,
and lauding the  wonderful things this machine could
accomplish. Well, after about 15 minutes, Bob thought he
had really made a conquest and asked if there were any
questions. The well driller promptly  spoke up: "But how
in hell do you get it down the well?"
     The second anecdote is related to Robert Glover
whose name was mentioned here a couple of times by Mr.
Darr. Hilton Cooper headed up the U.S.G.S. salt-water
diffusion project, and I had been involved with field
studies of salt-water encroachment in Florida. As anyone
who has been involved with hydrology knows, Hilton is
not an insignificant mathematician in his own right-
more or less oriented toward rigorous mathematics. As
part of the studies, Hilton invited Professor Glover to
visit Miami to get familiar with the field test site at Cutler;
and after he returned  home, he wanted me to give
some comments about his approach—so I wrote a long
letter about our discussions and sent it through Hilton.
This was before Xerox, I think,  because Hilton proceeded
to cut up my letter with scissors and passed along the
remainder of it. One of the surviving things was something
to the effect that we needed to hit the mathematics

head-on. Now, rigorous mathematicians confronted with
difficulty rarely ever did hit things head-on. If a technique
was found to work, it was used over and over until a dead
end was reached. Then they would usually find a sneaky
little way of catching up to the problem by making an
assumption, or sliding sideways around the problem. The
report came from Hilton that Professor  Glover's comment
was an emphatic, "Well, I just can't hit this problem
      But things have changed. With modern day computers,
problems can be solved that could not possibly be attempted
before. But one shouldn't overlook some of the questions
of boundary conditions—for  example, those which I
presented earlier in this meeting in regard  to the occurrence
of relatively fresh ground water under the Atlantic
Continental Shelf. We believe this water was recharged into
the offshore aquifers during low stand of sea level in
Pleistocene time and that it is now serving as a buffer for
present-day salt-water encroachment.  We have Atlantic
City pumped down to a hundred feet below sea level:
Savannah, Georgia, pumped down to  100 feet below sea
level; and more—and yet we have not  had extensive
salt-water encroachment in these aquifers. And I say this in
spite of the fact that Henry Barksdale, 40  years ago,
predicted that Atlantic City was in imminent danger of
salt-water encroachment.  It may well  be, but the fact of
the matter is that we are just beginning to find the
whereabouts of the fresh-salt transition  zone in the
offshore  area. Clearly, a very fundamental aspect of any
computer analysis is to have a realistic idea of what your
initial boundary conditions are.
      Now, the last item I wanted to mention is again
related to Professor Glover. You know I have the greatest
respect for him, because we are coauthors on a U.S.G.S.
Water-Supply Paper. Nevertheless, I can't resist passing along
this anecdote.
      This again dates back about 20 years. Hilton Cooper,
at the time, wanted to have a laboratory experiment and
analysis of the dispersion process, so he  got Ivan Johnson,
then head of the U.S.G.S. Hydrologic Lab at Denver, to
set up a hydraulic model in which the fresh-salt interface
was to be modeled—no oils or other substitute fluids-
just plain fresh and salt water, dyed for visibility. The
interface was then going to be oscillated back and forth
to form a zone of diffusion in a permeable medium. Hilton
was at the lab looking over this model with Ivan and
talking about how it was to be operated. Professor Glover
was there also. Hilton said, "Well, I'd  like to have some
little holes drilled in this model so we can  stick some
hypodermic needles through  rubber plugs  and suck out
some water, and make some chemical analyses on the
dispersion zone." Whereupon Glover's response was: "But,
Hilton, you don't have to bother with that. I've already
calculated that distribution."

Gordon Nelson, Hydrologist, U.S.G.S., 1209 Orca St.,
Anchorage, Alaska 99501: I  am not opposed to computer
models. In fact, I use them in my work. However, I think
you should be aware of one danger of computer models
which has not been addressed. That danger is that people
put a tremendous amount of faith in computers. After
building or calibrating a model, you may discover that
you have written a new gospel which some will believe
with fervor equal to belief in the other four, Matthew,
Mark, Luke, and John. Even if you explain the error limits,
you may find them ignored unless you make them
abundantly clear. It is easy to lose sight of the error limits
in a model just as is often the case with radiometric age
dates. How often have you seen a rock dated as, for
example, 20 ± 5 million years and then heard a geologist
describe it as a 20 million-year-old rock?  And don't
criticize planners for misusing models; even hydrologists
or hydrogeologists who build the models may lose sight of
the difference between what the computer tells them and
what they tell the computer. I listened to a speaker on
Wednesday say that the computer model told him
there was no flow from one side of a basin  to the other. It
seems to me that he identified the boundary conditions in
the field and then he told the model that ground water did
not flow from one side of the basin to the other. In another
instance a colleague recently related to me  a case of a
glacier model in which the author said that the model
indicated the glacier would not advance beyond a certain
point. However, the modeler had overlooked the fact that
he had built in that requirement. It was a requirement of
the model, not the glacier. Again he had lost sight of the
difference between what he told the computer and what
the computer told  him. My last example of the pitfalls of
modeling is a basin-runoff model in which the modeler had
such complete faith in the model that he told a field
hydrologist that he had failed to measure a. flood peak.
In this case the hydrologist who had been up
to the top of his hip boots in an icy stream did not take
kindly to the statement that the discharge measurement
was a figment of his imagination. I guess the main point of
this last example is, don't change the data to fit the model,
and don't put more faith  in the model than in real data.
     All of us here today are professional hydrologists,
hydrogeologists, and engineers, and most of you probably
feel that you wouldn't make such mistakes. All I can say
to that is: "GOOD," neither would I, I hope!

Graham E. Fogg, Research Associate, The University of
Texas at Austin, Bureau of Economic Geology, University
Station, Box X, Austin, Texas 78712:  As a hydrologist
who has both studied and used ground-water models, I
have learned that they can be either practical tools or
intellectual toys, depending on the competence of the
     Mr. Prickett pointed out that ground-water models
have existed for years in the forms of mathematical
models and experience. However, the controversy about
the practicality of ground-water models has become
heated only recently, reflecting the increased usage of

numerical models. The numerical models are by far the
most powerful tools ever available for solving ground-water
problems. Naturally, the chief drawback of any powerful
tool is that with only slight misuse it can bring disastrous
results. Such misuse of numerical modelling has resulted
in many models which are no more relevant than intellectual
      A user of numerical ground-water models needs a
firm understanding of the following: (1) ground-water
hydraulics and the complexities of geology that affect
ground-water flow, (2) field data collection, (3) the theory
of well hydraulics, (4) the theory behind numerical
ground-water models, and (5) sound scientific judgment.
In other words, the modeller should understand how
natural ground-water systems work and how accurately
these  systems can be represented by numerical models.
Items 2 and 3 are needed to help assess the worth of model
input data, which are usually sparse and often inadequate.
A mastery of the theory of well hydraulics (item 3) is
requisite for assessing results of aquifer pumping tests.
Most ground-water modellers appear to be weakest in
either 1 or 4.
      Below are listed several basic mistakes and mis-
conceptions which seem to reduce the validity of many
numerical modelling studies.
      (1) As mentioned by Mr. Prickett, the wrong type of
model (i.e., experience, mathematical or numerical) is often
chosen. One needs competence in numerical modelling not
only to use numerical models, but also to know when not to
use them.
      (2) Many hydrologists believe the sole purpose of
constructing a ground-water model is to predict future
conditions. In most cases even numerical ground-water
models are not representative enough of field  conditions to
justify their use for predicting the future. Then what is so
powerful about numerical models? They are the only means
of collectively analyzing a large quantity of ground-water
data as a coherent system. Some ground-water systems
can be adequately understood only by this approach.
Once a system is adequately understood, many of the
crucial problems can often be reduced to  (using Mr.
Baski's terms) yes or no questions.
      (3) Many hydrologists believe numerical models can
be calibrated to accurately predict future ground-water
conditions, regardless of the available data. This is false.
Model calibration, or the adjustment of model input data
(e.g., transmissivity, recharge, storativity) such that model
output (i.e., hydraulic head) matches field measurements,
can improve the predictive capability of a model. However,
the success of a calibration is directly proportional to the
amount of reliable input data and the skill of  the modeller.
Calibrations commonly entail the simultaneous adjustment
of more than one input parameter. These generally yield
unreliable results, since two or more parameters cannot be
adjusted in a unique fashion. In fact, it is usually difficult
to adjust one parameter in a unique fashion. For example,
in a steady-state model with known pumpage  and
prescribed head boundary conditions, there are an infinite
number of different transmissivity distributions which
yield the same model-computed values of head. To
successfully calibrate such a model, the modeller must
have good initial estimates of transmissivity and head in
addition to the earlier mentioned qualifications. Above all,
modellers and water managers should realize that the
ability of a calibrated model to mimic past ground-water
conditions does not necessarily verify its ability to predict
future conditions.
      (4) Numerical models constructed for large regions
are sometimes being used to solve site-specific problems.
This is improper because inherently the regional models are
too general to represent local conditions reliably.
      (5) Recently much work has been devoted  to
developing numerical models for the simulation of solute
transport in ground water. This is very worthwhile research
from which we can learn much about the solute transport
problem. However, there exist several unresolved problems
which limit the usefulness of numerical solute transport
models as practical tools. One such problem involves the
ground-water velocity field, usually the most important
input into a solute transport model. Heterogeneous aquifer
characteristics cause considerable variations in the
direction and magnitude of velocity (in both two and
three dimensions). These velocity variations are generally
critical controls on the movement and dilution of a ground-
water contaminant. Unfortunately, the velocity field is
seldom known in sufficient detail to make a solute trans-
port model reliable. Usually the best method of estimating
the velocity field in any detail is through  ground-water
flow modelling (numerical); and therefore the construction
of a solute transport model should in most cases  be
preceded by construction of a valid flow model.  Other
serious difficulties in solute transport modelling include:
the estimation of representative dispersion coefficients (on
both the regional and local scales), estimation of rates of
solute adsorption onto the solid matrix, and accurate
representation of the solute transport equation through
numerical methods.
      I agree with  Mr. Baski's statement that our
profession  of hydrology may be damaged by numerical
modelling. My fears stem from the following disturbing
observations:  (1) many ground-water models are poorly
constructed and interpreted, (2) in some  cases water
managers are using these models to make broad reaching
decisions regarding their ground-water resources, and
(3) many hydrologists and administrators are now
distinguishing the good ground-water studies from the bad
ones by assuming the former are those in which numerical
models are employed. Surely, these actions can only
produce untenable ground-water studies and management
programs; and the end result may be a loss of confidence
in hydrologists and their models. Such consequences can
be avoided through a rational and deliberate approach to
modelling, careful model calibration  through testing,
and realistic applications of model results.

Waterborne  Disease  —  A  Status Report
Emphasizing  Outbreaks  in  Ground-Water  Systems
by Gunther F. Craun
     A total of 192 outbreaks of waterborne disease
affecting 36,757 persons were reported in the United
States during the period 1971-1977. More outbreaks
occurred in nonmunicipal-water systems (70%) than
municipal-water systems; however, more illness (67%)
resulted from outbreaks in municipal systems. Almost half
of the outbreaks (49%) and illness (42%) were caused by
either the use of untreated or inadequately treated ground
water. An unusually large number of waterborne outbreaks
affected travelers, campers, visitors to recreational areas,
and restaurant patrons during the months of May-August
and involved nonmunicipal-water systems which primarily
depend on ground-water sources. The major causes of
outbreaks in municipal systems were contamination of the
distribution system and treatment deficiencies which
accounted for 68% of the outbreaks and 75% of the
illness that occurred in municipal systems. Use of untreated
ground water was responsible for only 10% of the
municipal system outbreaks and 1% of the illness. The
major cause of outbreaks in nonmunicipal systems was use
of untreated ground water which accounted for 44% of
the outbreaks and 44% of the illness in these systems.
Treatment deficiencies, primarily inadequate and
interrupted chlorination of ground-water sources, were
responsible for 34% of the outbreaks and 50% of the
illness in nonmunicipal-water systems.

     This report deals  exclusively with acute
waterborne disease and summarizes the data
     Presented at The Fourth National Ground Water
Quality Symposium, Minneapolis, Minnesota, September
20-22, 1978.
     bChief, Epidemiology Branch, Field Studies Division,
Health Effects Research Laboratory, U.S. Environmental
Protection Agency, Cincinnati, Ohio 45268.
available on waterborne outbreaks in the United
States during 1971-77 emphasizing outbreaks in
ground-water systems. It is nevertheless important
to remember that chronic diseases, such as cardio-
vascular disease and certain cancers, and human
physiologic changes have been epidemiologically
associated with long-term exposure to various
drinking-water contaminants and types and
treatment of water supplies. It is much more
difficult, however, to present a status report on
these diseases because the data are often incomplete
in regard to specific populations affected or
incomplete in that additional research is required.
For example, although much research has been
conducted to show that populations in hard-water
areas have lower mortality due to cardiovascular
disease than populations in soft-water areas, it is
still unclear whether the high concentrations of
calcium or magnesium in hard waters offer some
protection or whether the higher concentrations
of metals leached from water piping in soft,
corrosive waters are detrimental (Craun and
McCabe, 1975; Craun, Greathouse etal.,  1977).
Recent epidemiologic studies have indicated a
relationship between the type of water source
and treatment, especially chlorination, and cancer
of certain sites; however, these have generally been
hypothesis generating studies of large population
groups and additional studies are required to
account for confounding variables due to individual
life styles and patterns (Cantor, 1975; Cantor and
McCabe, 1978; Cantor, Hoover etal, 1978; Cooper,
          a/., 1978).

     Only outbreaks associated with water used or

intended for drinking or domestic purposes are
included. To be considered an outbreak, at least
two cases of infectious disease must be reported
before a common source can be noted and
investigated. Except in unique circumstances,
such as a case of chemical poisoning in which
the chemical was identified in the water, a single
case cannot be recognized as having been caused
by drinking water. The waterborne outbreaks
reported here are those in which drinking water
has been implicated epidemiologically as the
vehicle of transmission of the illness. In most of
the outbreaks the water was also found to be
bacteriologically or chemically contaminated. In
only a few outbreaks, however, was an etiologic
agent isolated from drinking water.
     For analysis the water systems were classified
as municipal, semipublic, or individual. The
definitions of municipal and semipublic differ
slightly for the periods 1971-75 and 1976-77. The
definitions used for the 1971-75 data are consistent
with reports from previous years (Craun and
McCabe, 1973; Craun, McCabe and Hughes,  1976;
Craun, 1977). Definitions used for classifying water
systems involved in outbreaks during 1976-77
were modified to correspond to those used in the
Safe Drinking Water Act (P.L. 93-523). Municipal
systems are now defined as public or investor-owned
water supplies that serve large or small communities,
subdivisions, and trailer parks of at least 15 service
connections or 25 year-round residents regardless
of the number of service connections. This
corresponds to the Act's definition of community-
water system. Semipublic-water systems are  those
systems that serve transients and include institu-
tions, industries, camps, parks, hotels, and service
stations which have their own water supply available
for use by the general public. This corresponds to
the Act's definition of noncommunity-water system.
The definition of individual system remains
unchanged. Individual-water systems are those used
by single residences in areas without municipal
systems or by persons travelling outside of populated
areas (e.g., backpackers).
     The major effect of this definition change will
be in the analysis of trends because small subdivisions
and trailer parks which had previously been  classified
as semipublic systems are now classified as municipal
systems. This change in definition resulted in the
reclassification of only one system in 1976 (e.g.,
one system classified as municipal in 1976 would
have been classified as semipublic had the  1975
definitions been applied) and two systems in
     A cooperative effort between the Health
Effects Research Laboratory, Environmental
Protection Agency (EPA), in Cincinnati, Ohio,
and the Center for Disease Control (CDC) in
Atlanta, Georgia, to investigate, document, and
report waterborne-disease outbreaks in the
United States has been in existence since 1971.
Local and State health departments investigate
waterborne outbreaks and at times request
assistance from CDC and the EPA. As part of the
reporting system, State epidemiologists and
engineers in State water supply surveillance agencies
cooperate in providing data on waterborne
outbreaks to EPA and CDC annually.
     Although reporting has generally improved
since 1971, it is recognized that more water-
borne disease outbreaks occur than are reported.
Reporting depends upon many factors, including
the type of water system, severity of disease,
number of individuals affected, and interest and
capabilities for recognition and investigation at
the State and local level. For example, 28% of all
waterborne outbreaks since 1975 were reported
by Pennsylvania. It is felt that the primary
reason for this large number of outbreaks in
Pennsylvania is the diligent surveillance and
investigation by State and local public health
officials of  problems in smaller-water systems. It
is difficult to ascertain the number of waterborne
outbreaks that go undetected or unreported. One
estimate, based on data collected from 1945-70,
indicated that about one-half of the waterborne
outbreaks in municipal-water systems and about
one-third of those in nonmunicipal systems are
detected  and reported (Craun and McCabe,
1973). A study of foodborne outbreaks in
Washington State after initiation of an improved
surveillance system and investigation indicated
that only one outbreak in ten had been recognized
and reported (Barker, Sagerser et al., 1974). This
number may be applicable to waterborne
outbreaks as well, since both depend upon the
recognition of acute illness in several individuals
to initiate an investigation.
     Outbreaks in municipal-water systems,
which number about 40,000 and serve about 177
million people, are probably the most likely to be
reported. Outbreaks in semipublic systems, which
number about 200,000 and serve numerous
transients, are the next most likely to be reported.
The least likely to be reported are outbreaks in
individual-water systems, which number  about
ten million.

                         Table 1. Waterbome Disease Outbreaks in the U.S., 1971-1977

Cases of Illness
     During the period 1971-77 a total of 192
 outbreaks of waterborne disease, affecting 36,757
 persons were reported (Table 1). Two deaths
 were associated with these outbreaks.
     Historical data on waterborne disease over the
 past five decades indicate that outbreaks are no
 longer on the decline in the United States (Craun
 and McCabe, 1973; Craun, McCabe and Hughes,
 1976; Craun, 1977). The number of waterborne
 outbreaks decreased steadily from an average
 of 41 per year in 1936-40 to 10 per year in
 1951-55; however, since then, an increase in the
 number of waterborne outbreaks has occurred,
 especially during the 1970's, to an average of  35
 per year in 1976-77. The reason for this apparent
 increase  is difficult to ascertain, but it may be
 primarily the result of increased reporting and
 follow-up by engineers and epidemiologists.

     An etiologic agent was determined in only
 43% of the 192 outbreaks (Table 2). The remaining
 outbreaks were categorized as acute gastrointestinal
 illness. This category included outbreaks character-
 ized by symptoms including abdominal cramps,
 nausea, vomiting, and diarrhea occurring 24 to 48
 hours after comsumption of water and outbreaks
 of "sewage poisoning" which  is presumably caused
 by coliform organisms or enteric viruses that have
 yet to be fully characterized. In many of the
 outbreaks the search for an etiologic agent
 included only stool cultures for Salmonella and
 Shigella; in others the investigation and collection
 of clinical specimens were delayed because of  late
 notification that an outbreak had occurred or
 samples were not collected because the outbreak
 was investigated  after the illness had subsided.
     Twelve percent of the outbreaks were chemical
 poisonings involving arsenic, chlordane, chromate,
 copper, cutting oil, developer  fluid (hydroquinone,
 paramethylamino phenol), ethyl acrylate,
 fluoride, fuel oil, furadan, lead, leaded gasoline, a
mixture of lubricating oil and kerosene, phenol,
polychlorinated biphenyl, selenium, and an
unidentified herbicide.
     The most commonly identified pathogen was
Giardia lamblia. Giardia lamblia is a flagellated
protozoan responsible for giardiasis. Twenty
waterborne outbreaks of giardiasis were documented
during 1971-77; 18 involved surface-water systems.
All but two of the giardiasis outbreaks in surface-
water systems occurred as the result of drinking
untreated surface water or surface water whose only
treatment was simple disinfection. Small municipal
systems or semipublic systems in recreational areas
were primarily affected.
     Outbreaks occurring in ground-water systems
were examined  separately to determine if the
etiologic agents were different. The diseases in
ground-water systems were generally similar to
those in surface-water systems with the exception
of giardiasis. Only two outbreaks of waterborne
giardiasis occurred in ground-water systems: in one,
the well was influenced by water from an adjacent
stream and in the other the well was heavily
contaminated by human  sewage. The percentage
of outbreaks categorized  as acute gastrointestinal
illness was slightly higher in ground-water systems,
no outbreaks of illness caused by toxigenic
E. coli were identified in  ground-water systems, and
the percentage of illness due to shigellosis (30%)
was higher in ground-water systems.
     Many individual wells in some areas of the
United States have high nitrate concentrations.
Infantile methemoglobinemia, a disease related
to the nitrate concentration of drinking water, is
not included in  the tabulation. This disease is not
reportable in the United States and its incidence
is not known. Numerous  cases associated with
individual wells high in nitrate were reported in
the United States in the 1940's and 1950's;

   Table 2. Etiology of Waterborne Disease  Outbreaks
              in the U.S., 1971-1977
Outbreaks. Cases of Illness
(Percent) (Percent)
Acute Gastrointestinal Illness
Chemical Poisoning
Hepatitis A
Enterotoxigenic E. coli


however, only three investigators have been
motivated in the past 17 years to describe cases
that have come to their attention (Comly, 1945;
Waring, 1949; Walton, 1951; Vigil et al, 1965;
Miller, 1971; Jones et al.,(1973). Cases in
European countries continue to be described in
the literature  (Jablonska-Ulbrych and Frelek-Karska,
1974; Faivre,^a/., 1976; Kantecka, 1976;
Bochynski et al., 1977). Our laboratory is currently
conducting a study to determine the incidence of
this disease in areas of the United States with high
nitrate ground water and the influence of health
education and changes in infant feeding practices
on this disease.

     More outbreaks (70%) occurred in the
nonmunicipal-water systems, but most of the
illness (67%) resulted from outbreaks in municipal
systems (Table 3). Outbreaks attributed to municipal
systems affected an average of 425 persons per
outbreak compared to 106 persons in semipublic
systems and 10 persons in individual systems.
     Consistent with previous trends, outbreaks in
semipublic systems peaked during the summer
months (Table 4). There appeared to be little

   Table 3. Waterborne Disease Outbreaks in the U.S.,
           1971-1977, by Type of System

Municipal Systems
Semipublic Systems
Individual Systems
Cases of Illness
   Table 4. Waterborne Disease Outbreaks in the U.S.,
          1971-1977, Seasonal Distribution

           seasonal variation for outbreaks in municipal
           systems during this period or in previous years.
                A large number of waterborne outbreaks each
           year affects the travelling public using semipublic
           water systems which depend primarily upon
           ground-water sources. In 1971-77, 78% of the
           outbreaks in semipublic-water systems affected
           travelers, campers, and visitors to recreational
           areas or restaurant patrons. Seventy-five percent
           (75%) of the outbreaks involving this transient
           population occurred in May-August, the period
           when outdoor activities  such as picnicking, camping,
           and vacationing are  most common.
                Outbreaks in systems using untreated ground
           or surface water were  also examined by month of
           occurrence to determine if contamination is more
           prevalent during certain seasons (Table 5). There
           appeared to be little variation by season for
           outbreaks caused by use of untreated surface water.
           However, a distinct  increase in outbreaks caused
           by the use  of untreated  ground water and springs
           was noted in the summer;  34 (53%) of the 64
           outbreaks occurred  in June-August. This implies
           there is either increased  contamination of these
           water sources during this period or if it is assumed
           that the supplies are always contaminated, use by
           greater numbers of susceptible individuals during
           this period.

                      CAUSE OF OUTBREAKS
                The majority of outbreaks (79%) and illness
           (73%) were caused by the  use of untreated or
           inadequately treated water (Table 6). Use of
           untreated,  contaminated water resulted in 90 (47%)
           outbreaks and 11,534 (31%) illnesses; deficiencies
              Table 5. Seasonal Distribution of Waterborne Disease
            Outbreaks in the U.S., 1971-1977, Use of Untreated Water

Ground Water
& Springs

        Table 6. Causes of Waterborne Disease
               in the U.S., 1971-1977

                          Outbreaks  Cases of Illness
1. Use of Untreated Water:
   Surface Water *
   Ground Water

2. Treatment Deficiencies:
   Surface-Water Systems
   Ground-Water Systems
   Spring-Water Systems

3. Distribution System
4. Miscellaneous and Unknown







   Includes outbreaks of giardiasis in which surface water
   was chlorinated but not filtered.
in treatment, primarily inadequate or interrupted
chlorination, accounted for 61 (32%) outbreaks and
15,607 (42%) illnesses. Distribution system defi-
ciencies such as backsiphonage, cross-connections,
water main breaks, contamination of treated water
storage reservoirs were responsible for 26 (13%)
outbreaks and 9,058 (25%) illnesses. The remaining
outbreaks and illnesses were caused  by miscellaneous
problems such as contaminated ice or containers
and unknown or undetermined causes.
     Almost half of all outbreaks (49%)  and
illness (42%) were caused by either the use
of untreated or inadequately treated ground water.
Fifty-seven (63%) of the 90 outbreaks that were
caused by the use of untreated, contaminated
water occurred in ground-water systems  compared
to 25 (28%) outbreaks in surface-water systems. Of
the 61 outbreaks that were caused by treatment
deficiencies, 38 (62%) outbreaks affecting an
average of 285 persons per outbreak occurred in
systems using ground water compared to 19 (31%)
outbreaks affecting an average of 189 persons in
systems using surface water.
     The 95 outbreaks in ground-water systems
were further examined to determine the specific
causes responsible for the outbreak (Table 7, 8).
Distribution-system related outbreaks  can occur
in any type of water system and were excluded
from this analysis. Also excluded were outbreaks
caused by miscellaneous deficiencies and unknown
causes. Overflow or seepage of sewage, primarily
from septic tanks or  cesspools, was responsible
for 42% of the outbreaks and 71% of the illness
caused by use of untreated ground water. This
includes the four outbreaks where contaminants
travelled through limestone or fissured rock.
Contamination of ground water by various
chemicals (arsenic, ethyl acrylate, leaded gasoline,
phenol, polychlorinated biphenyl, selenium) and
surface runoff or flooding resulted in 12 (21%)
outbreaks and 421 (9%) illnesses. There were
insufficient data to establish a source of contamina-
tion for the remaining 21 (37%) outbreaks in
systems using untreated ground water, emphasizing
the need for better investigation and reporting if
these problems are to be understood and corrective
action  taken.
    The removal of iron and manganese for
aesthetic reasons and disinfection only are the
primary means of treatment for ground water.
Ground-water systems usually depend on a relative-
ly good quality water, and disinfection is sometimes
provided to protect against possible  contamination
of the distribution system. In these situations
unexpected contamination of the source could
completely overwhelm the disinfection provided.
For ground-water systems using a source known
to be frequently or intermittently contaminated
with bacteria, continuous disinfection is necessary
to insure potability of the water. Outbreaks in these
systems are caused by interruption of disinfection
due to  the malfunction of equipment or lack of
maintaining a sufficient supply of disinfectant
and inadequate disinfection because disinfectant
dosages had been reduced below prescribed levels
or no attention was paid to maintaining the
proper residual of disinfectant.
    Interruption of disinfection was responsible
for most of the outbreaks (74%) and illnesses (86%)
caused by treatment deficiencies  in ground-water
systems. Seven (18%) outbreaks resulting in 1,176
(11%) illness occurred because of inadequate
disinfection of the ground-water sources. Most of
the outbreaks were usually the result of improper
chlorination since this is the most widely used

     Table 7. Waterborne Disease in the U.S. Due
        to Source Contamination of Untreated
          Ground-Water Systems, 1971-1977
Contamination through limestone
or fissured rock
Chemical contamination
Contamination by surface runoff
Overflow or seepage of sewage
Data insufficient to classify
Cases of

Table 8. Waterborne Disease in the U.S. Due to Treatment
   Deficiencies in Ground-Water Systems, 1971-1977
                         Outbreaks  Cases of Illness
Problems in chemical addition
Inadequate disinfection:
Interruption of disinfection:





method of disinfection in the United States,
however, four outbreaks resulted from inadequate
or interruption of iodine disinfection. In these
outbreaks, iodination was used by small semipublic
systems serving a primarily transient population.
     There were three outbreaks caused by the
addition of other chemicals to ground water. The
two largest are of interest because they illustrate
the need for increased surveillance and operator
training in fluoridation practices. Both outbreaks
involved semipublic-water systems at elementary
schools. In one, 201 students and 12 adults became
ill minutes after consuming orange juice made from
the school's water supply. Laboratory analysis
of the juice revealed a fluoride concentration of
270 mg/1. Investigation of the water system showed
that fluoride feeder pump at the well site had
malfunctioned, causing fluoride to be fed continu-
ously even while the water pump was not operating.
The second outbreak involved 150 children who
became ill after drinking Kool Aid made with
school water. It was later found that the fluoride
feeder  was purposely run while the water pump
was off because the operator was concerned that
the fluoride level was not high enough in the
system. The third outbreak also involved a
semipublic system serving a school. The pH of the
ground water was 4.9 and pH adjustment was
applied at the well site. Prior to the outbreak,
chemical feed was interrupted and high levels of
copper (12.5 mg/1) were leached from the copper
plumbing. The concentration of copper in the
ground water prior to distribution through the
plumbing was 0.3 mg/1.
     The causes of outbreaks and resulting cases
of illness were also classified by type of water
system. As in previous years, the major cause of
outbreaks in municipal-water systems was con-
tamination of the distribution system; 40% of the
outbreaks in municipal-water systems occurred
because of deficiencies in the distribution of
finished water primarily through cross-connections
and backsiphonage. Most of the resulting outbreaks
were quite contained, affecting relatively few
people. However, two large outbreaks in 1975
accounted for most of the illness in this particular
category: an estimated  5,000 cases of acute gastro-
enteritis in Sewickley, Pennsylvania, felt to be
related to contamination of an uncovered storage
reservoir for treated water and 1,400 cases of a
similar illness in Sellersburg,  Indiana, traced to
sewage contamination of a water main during
     Use of untreated ground water  was responsible
for most illness in municipal-water systems during
previous years; however, during 1971-77,  there were
only 6 (10%) outbreaks and  151 (1%) cases of
illness because of the use of untreated ground water
by municipal systems. In other municipal system
outbreaks in 1971-77, 28% of the  outbreaks and
39% of the cases of illness were related to treatment
deficiencies; 14% of the outbreaks and 23% of the
cases of illness were related to use of untreated
surface water; 8% of the outbreaks and 1% of the
cases of illness were related to miscellaneous
problems such as ice contamination  or unknown
     In nonmunicipal-water  systems, use of
untreated ground water was  responsible for most
of the outbreaks and illness during previous years.
Use of untreated ground water was still an important
problem in 1971-77, but deficiencies in treatment
were also responsible for many outbreaks and illness
in nonmunicipal systems during that period. In
1971-77 use of untreated ground water accounted
for 44% of the outbreaks and 44% of the  cases  of
illness in semipublic systems, and deficiencies in
treatment were responsible for 34%  of the outbreaks
and 50% of the cases of illness. Use of untreated
surface water accounted for  13% of  the outbreaks
and 4% of the illness in nonmunicipal systems.

              CASE  HISTORIES
     The three largest outbreaks involving ground-
water systems occurred in Pico Rivera, California
(3,500 cases), Comerio, Puerto Rico (2,150 cases)
and Richmond Heights, Florida (1,200 cases).
      Between July 20 and August 7, 1971,
approximately 62% of  the people  living within  a
1V*-square-mile area of  Pico Rivera became ill
with gastroenteritis (McCabe and Craun, 1975).
The outbreak was confined to the Pico County
Water District (PCWD) and did not affect any
part of Pico Rivera served by other water
companies. Within the  PCWD, the outbreak was

most severe in the west portion of the water district,
close to a reservoir. A chlorinator provided disinfec-
tion to water entering the reservoir via a gravity
line from a well. It was discovered that the
chlorinator had broken on July 20 and was not
repaired  for approximately one week. Water
samples taken from the reservoir, from a gravity
water line feeding the reservoir, and from a
trailer park within the area revealed  heavy
contamination by fecal coliforms, but no pathogens.
The most likely source of the contamination was
along the gravity line serving the reservoir, since
samples collected from the well supplying
the gravity line yielded no fecal coliforms.
     The second largest outbreak, an estimated
2,105 cases of shigellosis, occurred in Comerio,
Puerto Rico in 1976. Shigella sonnet was isolated
from clinical specimens but could not be isolated
from water samples collected two weeks after
the epidemic peaked. High coliform counts were
found in the water distribution system during
the outbreak, and during the investigation one of
seven wells supplying the system was found to be
contaminated with total coliforms of > 4900/100
ml and fecal coliforms of 230/100 ml. Although
the wells were chlorinated, insufficient chlorine
contact time was  provided prior to distrubution,
and the facilities were not maintained to provide
continuous, effective disinfection. ECHO 8 virus
was also found in the water from the contaminated
well; however, its significance was not evaluated by
epidemiologic studies.
     Between January 17 and March 15, 1974,
approximately 1,200 cases of acute gastrointestinal
illness occurred in Richmond Heights, Florida, a
residential community of 6,500 (Weissman, Craun
et al., 1976). Stool specimens from ten ill
individuals yielded Shigella sonnet, and since
symptoms of other patients correlated closely
with those of culture-positive cases, S. sonnei
was considered as the most likely cause of the
cases reported as gastrointestinal illness. Epidemio-
logic investigation disclosed that consumption of
tap water was significantly associated with illness,
and it was found that one of the two wells providing
water to  the community was continuously con-
taminated with excessive levels of fecal coliforms.
The source of the contamination was traced by
dye studies to  the septic tank of a church and a day-
care center located approximately 150 feet from
the well.  A breakdown in chlorination enabled
approximately 1 million gallons of unchlorinated
or insufficiently chlorinated water from the
contaminated well to be distributed  to the
community 48 hours before the epidemic
began. This outbreak is a good example of why
good disease surveillance is necessary to detect
outbreaks. Initially only ten cases of shigellosis
were recognized by health authorities, but upon
further investigation  1,200 illnesses were found
to have occurred. If local health authorities had
not been conducting shigellosis surveillance, the
initial ten cases might never have been
recognized as an unusual occurrence and a water-
borne outbreak as large as this might not have
been detected.
     On November 16, 1971, a trailer court tenant
in Anchorage, Alaska, telephoned local health
authorities to complain of water that was "dirty"
and had a bad odor (McCabe and Craun, 1975).
That morning a sanitary engineer investigated
the complaint and found what appeared to be gross
sewage contamination of the well-water supply.
Raw sewage was found standing in the well house
to the top of the well casings. Further investigation
revealed 89 of 114 persons exposed were ill.
Symptoms included nausea,  vomiting, abdominal
pain, fever, and diarrhea caused by 5. sonnei.
The water source  was two approximately 242-feet
deep wells, steel cased and enclosed in a well
house. The well house floor was 3 feet below
ground level;  the well casings extended to 1
foot above the well-house floor. Routine
periodic water samples from the trailer court had
consistently been negative. Som'etime prior to
the morning of November 16, a "soft plug" had
obstructed the borough sewer and caused a
backup of sewage in the trailer-court sewage
system. Sewage backed up through the drain in
the well-house floor and spilled over the casings
into  the wells. Subsequently, raw sewage was
pumped into  the trailer-park water system.
     Another outbreak of shigellosis occurred
in November  1972 at a junior high school in
Stockport, Iowa (Baine et al., 1975). Some 208
cases of gastrointestinal illness were reported
among the 289 students and 25 staff members.
A similar illness affected  12 of 26 visiting
basketball players. Rectal swab specimens were
found to be positive for 5. sonnei. Epidemiologic
investigation revealed the vehicle of infection to
be the water supply, a shallow well in the school-
yard. Fluorescein dye introduced into a shower
drain appeared in the well water within 30 minutes.
A sample of tap water at the school showed high
levels of coliforms and yielded S. sonnei.
     A waterborne outbreak of gastrointestinal
illness where Yersinia enterocolitica was isolated

from well water occurred during this period (Eden
etal., 1977). An epidemiologic survey estimated
that some 750 cases of gastroenteritis occurred
among 1,550 guests and  350 employees at a
Montana ski resort during December 6, 1974,
through January 17, 1975. A significant association
was found between drinking water and the illness.
Two 60-foot deep wells developed in sand and
gravel supplied water to the resort. A sewer line
was found to pass near the wells and samples
collected from the wells  after the outbreak
yielded  Y. enterocolitica and coliform organisms
from 1 to more than 16 per 100 ml. Routine
bacteriological surveillance during the previous
three years had not detected coliform contamina-
tion of the  wells. Chlorination of the wells stopped
the outbreak. Although Y. enter ocolitica was
isolated from well-water samples, the significance
of this finding was unclear because rectal swab
cultures from acutely ill  persons were not examined
for this organism.
     An outbreak of 98 cases of viral hepatitis in
Polk County, Arkansas, in 1971 is a good example
of how waterborne outbreaks may occur in areas
where geological formations allow drainage of
septic-tank effluents into ground-water supplies
(McCabe and Craun, 1975). The outbreak was
traced to commercially made pellet ice, either
through patronage of a restaurant that used the
ice or by direct purchase of ice from a general
store. The ice was made from well water at the
general store. Both the ice and well water showed
heavy coliform contamination. Dye studies
revealed that sedimentary rock strata in the area
permitted lateral drainage of a septic tank
effluent from a nearby home occupied by residents
who had infectious hepatitis six weeks previously.
     The largest reported outbreak of typhoid
fever in the United States since 1939 occurred
during this period at the South Dade Migrant
Farm Labor Camp, Florida (Pfeiffer, 1973;
Saslaweta/., 1975). Epidemiologic investigation
of the 210  cases which occurred in February
and March  1973 implicated the camp's water
supply as the vehicle of infection. Two wells,
6.1 meters  deep, supplied water to the camp;
the water was disinfected prior to distribution.
An engineering evaluation revealed that in early
February, chlorination of the water was interrupted
for a period of time, and it was felt that contamina-
tion of the water supply occurred then. The aquifer
was composed of  solution channels, and the wells
had a history of intermittent contamination.  Fecal
coliforms were found as late as March 2. A young
mentally retarded child who developed typhoid
fever in January and who attended a day-care
center located adjacent to the well was felt to be
the index case and source of contamination.
     Between April 4 and May 22, 1972, five cases
of typhoid occurred in a residential area near
Yakima, Washington, that was served by driven
well points and septic tanks (McCabe and Craun,
1975). Upon investigation, a typhoid carrier was
identified in the area, and dye flushed through
the sewage system in his home was traced within
36 hours to numerous wells in the area including
the ill family's well which was 210 feet away. The
water from this well also yielded typhoid bacillus
and coliforms. The soil in the  area is extremely
pervious gravel, and at the time of the outbreak,
the ground-water  level was at or near its seasonal
     The following example illustrates the need
for chemical surveillance of ground-water supplies
(McCabe and Craun, 1975). In May 1972, a
contractor built a warehouse and an office  structure
on the outskirts of a small town in Minnesota. A
well was drilled to supply water. During the next
2V4 months, 11 of the 13 individuals employed by
the contractor became ill; two were hospitalized.
The hospitalization led to the discovery of
elevated urine-arsenic levels in both patients.
Samples obtained from the well on two occasions
yielded arsenic concentrations of 21.0 and 11.8
mg/1. Area residents reported  that grasshoppers
had been a serious problem in the late  1930's and
that a grasshopper bait composed of arsenic, bran,
and sawdust had been prepared  and stored on the
property now occupied by the warehouse and
office. The bait was apparently kept on the ground
and was believed to have been buried in the area.
Soil samples on the property revealed arsenic
concentrations of 3,000 mg/1  at 20 cm-2 m and
12,600 mg/1 at 2 m.
     Chemical spills have also affected ground-water
quality and caused outbreaks. Two that occurred
during this period are described. Accidental spillage
of 10,000 gallons of 100% phenol in 1974 resulted
in the chemical contamination of a number of
wells in a rural area of southern Wisconsin
(Horwitz, Hughes and Craun,  1976). An illness
characterized by diarrhea, mouth sores, burning of
the mouth, and dark urine was reported by 17
persons exposed to the phenol-contaminated water.
Gasoline spilled at a service station in Pennsylvania
affected ten individuals using private wells near
the station;  10 mg/1 leaded gasoline was detected in
the wells.

      Waterborne outbreaks continue to occur in
 the United States. A significant number of outbreaks
 and illnesses occur because of the lack of treatment
 of ground water and because of the interruption of
 disinfection and inadequate disinfection of con-
 taminated ground water. Additional surveillance
 of small ground-water systems is necessary to
 prevent outbreaks from occurring. Emphasis must
 be placed on obtaining water quality data for all
 ground-water sources, insuring through sanitary
 surveys that wells are adequately protected from
 surface water and sources of contamination, such
 as septic  tanks; providing adequate treatment when
 required; and providing for proper operation to
 maintain continuous, effective disinfection when
 ground-water sources are known or suspected to
 be intermittently or continuously contaminated
 with bacteria.

      The assistance and cooperation of epidemiolo-
 gists, engineers,  and public health officials in the
 States and my colleagues at EPA (L. J. McCabe,
 E. W. Akin, W. Jakubowski, E. C. Lippy, D. A.
 White, S. A. Underwood) and CDC (M. H. Merson,
 J. H. Hughes, M. A. Horwitz, R. E. Black, R. A.
 Gunn) during this period are gratefully acknowledged.

 Baine, W, B., et al.  1975. Waterborne shigellosis at a public
     school. Amer. J. Epidemiol. v. 101.
 Barker, W. H., Jr., J. C. Sagerser, et al. 1974.  Foodborne
     disease surveillance. Washington State. Amer. J. Pub.
     Health, v.  64.
 Bochynski, K., et al. 1977. Chemical mass poisoning caused
     by sodium nitrite. Pol. Tyg. Lek. v. 32.
 Cantor, K. P. 1975. The epidemiologic approach to the
     evaluation of waterborne carcinogens. Proceedings
     Conference on Environ. Impact of Water Chlorination.
     Oak  Ridge National Lab. Oct. 22-24.
 Cantor, K. P., R. Hoover, et al. 1978. Associations of
     cancer mortality with halomethanes in drinking water.
     J. Natl. Cancer Inst. v. 61.
 Cantor, K. P. and L. J. McCabe. 1978. Epidemiologic studies
     on the carcinogenicity of organics in drinking water
     supplies. Proceedings Amer. Water Works Assoc.
     98th Annual  Conference. June 25-30.
Comly, H.  H. 1945. Cyanosis in infants caused by nitrates in
     well water. J. Amer. Med. Assoc. v. 129.
Cooper, R. C., M. Kanarek, et al. 1978. Asbestos in domestic
     water supplies in five California counties. Final
     Report R-804366. U.S. Environ. Protect. Agy.
Craun, G. F. and L. J. McCabe. 1973. Review of the causes
     of waterborne-disease outbreaks. J. Amer. Water
     Works Assoc. v. 65.
Craun, G. F. and L. J. McCabe. 1975. Problems associated
     with metals in drinking water. J. Amer. Water Works
     Assoc. v. 67.
 Craun, G. F., L. J. McCabe, and J. H. Hughes. 1976.
      Waterborne disease outbreaks in the U.S.-1971-1974.
      J. Amer. Water Works Assoc. v. 68.
 Craun, G. F. 1977. Impact of the coliform standard on the
      transmission of disease. Symposium on Evaluation
      of the Microbiology Standards for Drinking Water.
      U.S. Environ. Protect. Agy. April 13-14.
 Craun, G. F., D. G. Greathouse, et al. 1977. Preliminary
      report of an epidemiologic investigation of the
      relationships between tap water constituents and
      cardiovascular disease. Proceedings Amer.  Water
      Works Assoc. 97th Annual Conf. May 8-13.
 Eden, K. V., et al. 1977. Waterborne gastrointestinal
      illness at a ski resort. Pub. Health Repts. v. 92.
 Faivre, J., et al. 1976. Methemoglobinemias caused by
      ingestion of nitrates and nitrites. Ann. Nutr.
      Aliment, v. 30.
 Jablonska-Ulbrych, A. and M. Frelek-Karska. 1974.
      Methemoglobinemia in two infants caused by
      nitrates in well water. Pol. Tyg. Lek. v. 29.
 Jones, J. H., et al. 1973. Grandmother's poisoned well:
      report of a  case of methemoglobinemia in  an infant
      in Oklahoma. Okla. Med. Assoc. J. v. 66.
 Horwitz, M. A., J. M. Hughes, and G. F.  Craun. 1976.
      Outbreaks of waterborne disease in the United States,
      1974. J. Inf. Dis. v. 133.
 Kantecka, B. K. 1976. Methemoglobinemia in poisoning
      with nitrogen compounds in a 4-week-old infant.
      Ped. Pol. v. 51.
 Miller, L. W. 1971. Methemoglobinemia  associated with
      well water.  J. Amer. Med. Assoc. v. 216.
 McCabe, L. J. and G. F. Craun. 1975. Status of waterborne
      disease in the U.S. and Canada. J. Amer. Water Works
      Assoc. v. 67.
 Pfeiffer, K. R. 1973. The Homestead typhoid outbreak. J.
      Amer. Water Works Assoc. v. 65.
 Saslaw, M. S., et al. 1975. Typhoid fever public health
      aspects. Amer. J. Pub. Health, v. 65.
 Vigil, J., et al. 1965. Nitrates in municipal water supply
      cause methemoglobinemia in infant. Publ.  Health
      Repts. v. 80.
 Walton, G. 1951. Survey of literature relating to infant
      methemoglobinemia due to nitrate contaminated
      water. Amer. J. Pub. Health, v. 41.
 Waring, F. H. 1949. Significance of nitrates in water
      supplies. J.  Amer. Water Works Assoc. v. 41.
 Weissman, J. B., G. F. Craun, et al. 1976. An epidemic of
      gastroenteritis traced to a contaminated public water
      supply. Amer. J. Epidemiol. v. 103.
              *       *        *       *
      Gunther F.  Craun received the B.S. degree in Civil
 Engineering (1965) and M.S. degree in Sanitary Engineering
 (1971) from Virginia Polytechnic Institute, and has taken
 numerous courses in epidemiology and public health at the
 University of Minnesota, University of Cincinnati, and the
 Center for Disease Control (Atlanta). His Public Health
 Service career has included assignments with the  Indian
 Health Service and Chicago Regional Office, and he is
 currently Chief of the Epidemiology Branch at EPA 's
Health Effects Research Laboratory in Cincinnati. He has
published extensively on the subject of waterborne disease
and initiated a cooperative program with the Center for
Disease Control in 1971 to investigate and report water-
 borne disease in the United States.

Waterborne  Disease  —   Current  Threat
by Robert C. Cooperc
     Control of epidemic waterborne disease of an infectious
nature has been made practical through modern drinking-
water treatment practices. Certainty of such control
depends upon treatment plant reliability. The possibility of
the transmission of newly recognized infectious diseases by
the water route must be considered. The presence of trace
amounts of chemicals in drinking water that are potential
agents of chronic disease, particularly cancer, poses many
questions concerning the safety of our water supplies.
     During the last half of the nineteenth century
through the observation of such men as John Snow
(1854), William Budd (1873) and William Sedgwick
(1900) it became clear that certain infectious
diseases were associated with fecal material and
that drinking water was an important vehicle in the
transmission of these diseases. These observations
gave impetus to the development of the art and
science of water treatment as we know it today.
Because of the long-term interest in the infectious
agents present in contaminated water and because
of extensive experience  in  their control, it  is
reasonable to state that  modern practical water
treatment technology, particularly disinfection,
      Presented at The Fourth National Ground Water
Quality Symposium, Minneapolis, Minnesota, September
20-22, 1978.
     ^Professor of Biomedical and Environmental Health
Sciences, School of Public Health, University of California,
Berkeley, California 94720.
can reduce the number of known pathogens to
levels that presently render the water acceptable
from a public health point of view. This latter
statement assumes treatment plant reliability, an
assumption which may be questioned. For example,
of the 969 water supplies examined in the United
States in 1969, 12 percent were not meeting
bacterial standards (Taylor, et al.,  1972).
     In situations in which drinking water is not
treated there is always the possibility for contamina-
tion and  resultant epidemics such  as occurred in
Riverside, California, in which  18,000 cases of
Salmonellosis was associated with  a nondisinfected
ground-water supply (Ross, et al.,  1966). One
should not overlook the chances of cross connections
in which even a well-treated water supply could be
grossly contaminated. Thus even in this practiced
area of drinking-water management, acute
waterborne disease is always a threat and quality
control must be maintained.
     During the past few years much concern has
been expressed regarding animal viruses in waste
water and in drinking water. This concern  has
been stimulated because of the recognition that
certain enteric viruses are proportionately  more
resistant to chlorination than are the standard
coliform indicators. Thus processed water  that
meets coliform requirements may be contaminated
with viruses. With the exception of the incident in
New Delhi, India, in the 1950's (Viswanathan,
1957), in which thousands of cases of infectious
hepatitis were associated with treated municipal
drinking water, there have been no recorded
incidents in which an epidemic of viral disease has

been associated with properly treated municipal
drinking water. However, it can be hypothesized
that with some frequency a small number of
viruses may be introduced into a distribution
system. There is a probability that a member of the
exposed community will receive this viral dose in a
glass of water and concomitantly that the dose
received will produce disease in some
proportion of those exposed. This results in a
case of viral disease which then may be trans-
mitted horizontally through the family. Because of
the less than explosive nature of such an episode,
it would be unlikely  that an epidemiologist would
associate the incident with the drinking-water
supply. Thus, it may be that water supplies that
meet bacterial standards produce point sources of
disease which are then spread from the primary
contact to other members of the community via
personal contact, food, etc.
     We cannot allow ourselves  to become over-
confident of our knowledge concerning microbial
diseases transmitted by water. Newly recognized
microbial phenomena are continually being
uncovered such as the occurrence of enteropatho-
genic Escherichia coll in waterborne disease
outbreaks (Morbidity and Mortality  Report, 1975),
the apparent increasing incidence of waterborne
giardiasis in the United States (Craun, et al., 1976)
and the recent recognition that the legionnaires'
disease bacterium is associated with cooling tower
water and surface water (Morbidity and Mortality
Report, 1978a, 1978b).
     There are a number of chemical agents in
water which may affect man's health. A number of
inorganic chemicals are known to be toxic at
certain concentrations. These would include such
agents as arsenic, cyanide, lead, mercury, and
nitrates. This latter ion has been recognized to be
associated with methemoglobinemia in young
     Other inorganic substances in water are
suspected of being associated with chronic disease
in man. In 1960, Schroeder (Schroeder, 1960a
and 1960b) examined the 1949-1951 vital statistics
dealing with the annual age-adjusted death rate
from cardiovascular disease in the United States
and compared these data to the weighted average
hardness in water used for human consumption. He
found a negative correlation (higher disease rate
with softer water) between deaths from cardio-
vascular disease and hardness in  the water supply.
Since that time, there have been a number of
studies in various parts of the world that, for the
most part, substantiate this relationship (Morris
etal., 1961; Crawford etal., 1968; and Neri etal,
     A negative correlation between water hardness
and infant mortality has been reported by Morris
etal. (1961) and Crawford etal.  (1968, 1972).
These investigators point out that it has been known
for a long time that social conditions have a
significant impact upon infant mortality;  however,
when these factors are accounted for, there appears
to be a significant negative correlation between
neonatal mortality and water hardness, and with
calcium in particular. One suggestion was  that the
more corrosive soft water might increase the heavy
metal content of drinking water in low calcium
     In  1957 Penrose suggested that anencephalus
(a condition in which major portions of the brain
are missing) might be associated with the  amount
of calcium in water supplies. In 1970, Fredrick
examined the relationship between anencephalus
among children born in certain areas of the United
Kingdom and water hardness and found a negative
correlation. He also pointed out a significantly
higher incidence of death from spina bifida (a
disease related to anencephalus) in soft water areas
of the United States.
     Asbestos is an inorganic substance found in
certain waters, originating from natural sources
or from industrial pollution, which has been
suspected as a possible contributor to the  cancer
incidence in exposed populations (Cooper and
Copper, 1978). Recently in our laboratory, indirect
epidemiological evidence has been developed which
shows a significant positive correlation between
levels of asbestos in domestic drinking water of the
San Francisco Bay Area and  cancer incidence
(Kanarek, 1978). Table 1 is a summary of these
results. As is the case in the water hardness-cardio-
vascular disease relationship, cause and effect is not
proved but the data are very suggestive.
     Since the early 1970's, there has been a growing
concern among Federal, State and local agencies
regarding the health implications of organic chemical
compounds in the country's drinking-water supplies.
A large number of these chemical compounds
have been found and generally their concentrations
have been in the microgram per liter range. The
trihalomethanes, and chloroform in particular, have
been singled out as target compounds since they
seem to  be formed during water disinfection with
chlorine. The public health implications of the
presence of trace amounts of many of these organic
compounds in water is uncertain  at the present time.
This is so because of the chronic nature of diseases

 Table 1. Cancer Sites in White Males and Females That
 Correlate with Asbestos Levels in Drinking Water in the
 San Francisco Bay Area (adapted from Kanarek, 1978)
      Cancer Site
Trachea, bronchus, lung*
All respiratory**
Digestive related organs*
     = correlation exists.
     = no correlation exists.
suspected to be associated with these chemicals
(such as cancer); because health risk data are
usually generated using animals receiving relatively
high doses of suspect compounds; because such
data must be extrapolated to estimate dose response
at much lower concentrations; and because such
extrapolated data must be further extrapolated
from animal to man.
     The evaluation of the impact upon the
morbidity of cancer in populations exposed to
low concentrations of known or suspected carcino-
gens present in drinking water is plagued with the
same difficulties as just noted  for toxic organic
chemicals. Added to the problem is the question as
to whether or not the concept of a threshold dose
is valid. This question arises because of; (1) the
self-replicating nature of the cancer cell, (2) the
probability that the tumor-causing event is
irreversible, and (3) the possible occurrence of
cancer long after the disappearance of the carcino-
gen from the body  (W.H.O., 1974).
     In a recent article, Stokinger (1977) stated
his conviction that  threshold concentrations do
exist for carcinogenic compounds and that
drinking-water standards should be developed from
that point of view.  He draws most of his supporting
data from industrial exposures and animal experi-
mentation. He  strongly feels that toxic response is
frequently much different at low concentration of
toxic chemicals and therefore extrapolation from
"high" dose experiments to estimate "low" dose
response is invalid.
      Others such as Mantel and Bryan (1961) feel
that a no-response dose of carcinogen may not
exist; rather, there  is some risk of contracting the
disease regardless of dose and that risk increases
with increased exposure; i.e., is dose related. Such
risks are determined using a variety  of statistical
methods. Mantel and Bryan suggested that one
extrapolate from high dose response data to an
appropriate risk level using a probit slope of 1 to
1.5 probit per 10-fold increase in dose. This
assumes that response frequency is normally
distributed. Probits are calculated as standard
deviations about the mean of normal distributions
giving zero deviation (the  50 percent response
point) a value of 5. This method is commonly
used and is considered to give conservative values
as it does not include: (1) the probabilities that the
individual involved will be overshadowed by some
competitive health risk; (2) the probability that an
individual will receive a given exposure; and (3) the
age of the individual when the cancer will occur.
     The risk of developing cancer during a lifetime
of exposure to  known or suspected carcinogens
that might be found in water was reported by the
National Academy of Science (1977). These values
were determined using a mathematical risk
model which would allow an estimation of the
increment of risk of disease due to consumption of
suspect compounds in water. Selected values are
shown in Table 2.
     Thus, based upon these calculations, there
would be one excess case of cancer per  37 million
people who drink water containing 1  jug/1 of
chloroform. If  these are accurate estimates, then  as
the level of compound increased to 100 jug/1, it
could mean an increase of more than  600 excess
deaths among this country's 220 million due to
chloroform in drinking water. Tardiff (1977)
estimates the disease risk from the daily
consumption of 0.01  mg of chloroform per
kilogram of body weight using a variety of risk

    Table 2.  Estimated Lifetime Risk of Cancer from
     Consumption of Selected Carcinogens in Water
                              Upper 95% Confidence
   Compound                    Estimate of Risk*
                        Vinyl chloride
                                              5.1 X 10"7
                                              2.6 X 10"4
                                              4.2 X 10"5
                                              1.2X 10"5
                                              9.3 X 10~6
                                              3.7X 10~7
                                              1.3 X 10"7
                        * Risk per microgram per liter of water consumed over a
                        Source: National Academy of Science, Drinking Water
                          and Health, 1977.

models including probit, log linear, and two-step
methods. A dose of 100 jug/1 per day to a 10 Kg
infant would be equivalent to 0.01 /ug/Kg which,
from human data, should not cause any liver
damage. Using such models, it was calculated that
the incidence of cancer should be increased by
1.6 per million population per year, or of
approximately 300,000 cancer deaths annually in
the United States, 252 might be attributed to
chloroform in tap water. Tardiff concludes that
the risk lies somewhere between zero and the above
figure at a chloroform concentration of 100 jug/I.
     At present there are no time proven standards
for acceptable levels of trace organics in water.
Recently, the Environmental Protection Agency has
put forth a target level for trihalomethanes
(including chloroform) in drinking water of
100 Mg/1. The level of THM will be greatly affected
by chlorination procedures in both  the waste-water
and drinking-water treatment plants and by the
amount of precursors of THM present in the raw
     Epidemiological evidence is accumulating
that indicates correlations between  trihalomethane
level in drinking water and cancer morbidity/
mortality at various anatomical sites (Environmental
Protection Agency, 1978). Correlations between
water source (surface and ground) and  cancer have
also been shown (Page et al, 1976). In this latter
case the cancer rates are frequently  higher among
populations that take their drinking water from
surface streams than among those who use ground
water. The difference is  assumed to be  due to the
generally poorer chemical quality of surface water
because of its greater vulnerability to contamination.
     There will always be a threat of waterborne
disease. The magnitude of the threat is our major
concern. Modern water treatment practices have
certainly reduced the threat of infectious disease
and in this regard it is a question of treatment
process reliability and quality control. A quote
from Sir John Simon's report to the London privy
council in 1867 is appropriate:
     The public is hitherto very imperfectly protected
against certain extreme dangers which the malfeasance of a
water company, supplying perhaps half a million customers,
may suddenly bring upon great masses of population. Its
colossal power of life and death is something for which till
recently there has been no precedent in the history of the
world; and such power, in whatever hands it is vested,
ought most sedulously to be guarded against abuse.
     Newly recognized microbial disease agents
arise from time to time and under certain circum-
stances can be associated with water, as for example,
legionnaires' disease with cooling tower water. This
certainly poses a waterborne disease threat to
those exposed.
     Major concern is presently being expressed
about the presence of inorganic and organic
chemicals that may be present in water and their
association with chronic disease, particularly cancer.
At this time there is growing evidence that a health
threat exists but its magnitude is at present poorly
defined. One of the major tasks before those
interested in water quality and health is to define
the risks involved when these compounds are
present in a community water supply.
     Is waterborne disease still a threat? The answer
is, of course, yes. It will always be a threat. We
cannot afford to allow ourselves ever to become
lulled into a complacent attitude towards this

Cooper, R. C. and W. C. Cooper. 1978. Public health aspects
     of asbestos fibers in drinking water. J. Am. Water Works
     Assoc. 70:338.
Craun, G. F., L. S. McCabe, and J. M. Hughes. 1976. Water-
     borne disease outbreaks in the U.S., 1971-1974. J. Am.
     Water Works Assoc. 68:420.
Crawford, M., M. Gardner, and J. Morris. 1968. Mortality
     and hardness of local water supplies. Lancet i. 827.
Crawford, M., D. Gardner, and P. A. Sedgwick. 1972.
     Infant mortality and hardness of local water supplies.
     Lancet i. 988.
Environmental Protection Agency. 1978. Statement of basis
     and purpose for an amendment to the National Interim
     Primary Drinking Water Regulations on Trihalo-
     methanes. Jan. 1978.
Fedrick, J. 1970. Anencephalus and the local water supply.
     Nature. 227:176.
Kanarek, M. 1978. Asbestos in water and cancer incidence.
     Ph.D. Thesis,  University of California, Berkeley, CA.
Mantel, N. and W. R. Bryan. 1961. Safety testing of
     carcinogenic agents. J. Nat. Cancer Inst. 27:455.
Morbidity and Mortality Weekly Report. 1975. Center for
     Disease Control. 24:31.
Morbidity and Mortality Weekly Report. 1978a. Center for
     Disease Control. 27:283.
Morbidity and Mortality Weekly Report. 1978b. Center for
     Disease Control. 27:317.
Morris, J. N., M. Crawford, and J. A. Heady. 1961. Hardness
     of local water supplies and mortality from cardiovascular
     disease. Lancet i. 860.
Neri, L. C., D. Hewitt, and J. S. Mandel. 1971. Risk of
     sudden death in soft water areas. Am. J. of Epidemiol.
Page, T., R. H. Harris, and S. Epstein.  1976. Drinking water
     and cancer mortality in Louisiana. Science. 193:55.
Penrose, L. S. 1957. Genetics of anencephaly. J. Ment.
     Defic. Res. 1:4.
Ross, E. C., K. W. Cambell, and H. J. Ongerth. 1966.
     Salmonella typhimurium contamination of Riverside,
     California water supply. J.A.M.A.  58:165.
Schroeder, H. A. 1960a. Relation between mortality from

     cardiovascular disease and treated water supplies.
     J.A.M.A. 172:1902-1908.
Schroeder, H. A. 1960b. Relations between hardness of
     water and death rates from certain chronic and
     degenerative diseases in the United States. J. Chronic
     Dis. 12:586.
Simon, John. 1867. Ninth report of the medical officer to the
     Privy Council, p. 28, London.
Stokinger, H. E. 1977. Toxicology and drinking water
     contaminants. J. Am. Water Works Assoc. 69:399.
Tardiff, R. G. 1977. Health effects of organics: risk and
     hazard assessment of ingested chloroform. J. Am.
     Water Works Assoc. 69:658.
Taylor, A., G. F. Craun, G. A. Faech, L. J. McCabe,  and
     E. J. Gangarosa. 1972. Outbreaks of waterborne
     disease in the U.S. 1961-1970. J. Infect. Dis. 125-329.
Viswanathan, R. 1957. Infectious hepatitis in Delhi (1955-
     1956): A critical study. Indian J. Med. Res. 45:1
     (Supplement 1).
World Health Organization (W.H.O.). 1974. Assessment of
     the carcinogenicity and mutagenicity of chemicals.
     Report of W.H.O.  Scientific Group, Geneva, W.H.O.
     Technical Report Series 566,  19 pp.
      Robert C. Cooper holds the following degrees: B.S.,
University of California, Berkeley, 1952 (Public Health);
M.S., Michigan State University, East Lansing, 1953
(Microbiology and Public Health); Ph.D., Michigan State
University, East Lansing,  1958 (Microbiology and Public
Health). He is presently Professor, Department of Biomedical
and Environmental Health Sciences, School of Public
Health and Head, Graduate Group in Environmental
Health Sciences,  School of Public Health, University of
California,  Berkeley, He has held teaching positions with
Michigan State University and University of California-
Berkeley since 1953.

Waterborne  Disease   —  Historical  Lesson
by Ira M. Markwood
     While it is true that waterborne diseases are still with
us, and probably always will be, we cannot classify them as
a current threat in the sense that they were 100 years ago.
The discovery that chlorine would disinfect water supplies
removed these diseases from a "current threat" category to
the "historical lesson" category. We are not faced with
unknowns which we are unable to attack. We have only to
look at what others have done to protect themselves and
follow the same or improved practices.
     If the record of waterborne outbreaks in public water
supplies in this country from the end of World War II up
to the present is examined, it will be found that all are
caused by breakdowns in disinfection procedures or
carelessness. The record is replete with statements such
as "improper disinfection after repair," "breakdown or lack
of disinfecting equipment," "back siphonage," and other
similar statements all pointing to failure to follow practices
which the history of water treatment has shown to be
necessary for protection against waterborne disease.
Carelessness allows recurrence of disease outbreaks. If the
lessons of history were followed, the conquest of waterborne
disease transmission by public water systems could be
      Presented at The Fourth National Ground Water
Quality Symposium, Minneapolis, Minnesota, September
20-22, 1978.
     bDivision Manager, Division of Public Water Supplies,
Illinois Environmental Protection Agency, 2200 Churchill
Road, Springfield, Illinois 62706.
     In discussing whether waterborne disease is a
current threat or a historical lesson, it must be borne
in mind that, in this case, the semantics are quite
important. If we define a current threat as one
where great activity must be taken in new areas,
where there is much to learn in order to control
the problem, and where, in many cases, we are
helpless to protect ourselves against the ravages of
the threat, then it immediately becomes obvious
that waterborne disease in the United States does
not fall into this category.
     One hundred years ago there were great
epidemics of typhoid and cholera, to name two of
the most common waterborne diseases, which
ravaged the country and which were completely
beyond the ability of the population to halt or
minimize with the knowledge then available to
them. Since then, particularly in the first quarter
of this century, much has been learned. We now
know that these diseases can be prevented  by
proper precautions, and that these terrible epidemics
need no longer occur. We are not faced with
unknowns which we are unable to attack. We have
only to look at what others have done to protect
themselves and follow the same or improve
     If the record of waterborne outbreaks in public
water supplies in this country from the end of World
War II up to the present is examined, it will be
found that all are caused by breakdowns in
disinfection procedures or carelessness. The record

is replete with statements such as "improper
disinfection after repair," "breakdown or lack of
disinfecting equipment," "back siphonage," and
other similar statements, all pointing to failure to
follow practices which the history of water
treatment has shown to  be necessary for protection
against waterborne disease. Modern technology
presents methods for removing any substance from
water. The only limiting factor is cost. However,
even the most common  methods, such as
flocculation, coagulation and sedimentation,
will remove a high percentage of the microbiological
contaminants. In addition, the pathways by which
contaminants can enter  drinking water are well
known, and, with reasonable precaution, be closed
so that the water will be protected against the
entrance of pathogens. The use of proper disinfection
methods, in addition, allow 100% protection against
the transmission of waterborne disease by this
     Therefore it can be said conclusively that
waterborne disease is now in the class of a historical
lesson. We need only to look back to see what has
been done to prevent transmission of disease by
water, and use these methods as the lesson to
continue such prevention for the protection of
the water consumers.
     Carelessness allows recurrence of disease
outbreaks. If the lessons of history were followed,
the conquest of waterborne disease transmission
by public water systems could be complete.
     Ira M. Mark-wood, Manager of the Public Water
Supplies Division, Illinois EPA, received bis Bachelor's
degree in Chemical Engineering from New York University
and his Master's degree in Chemical Engineering from
Virginia Polytechnic Institute. He is a Registered Professional
Engineer in New York, New Jersey and Illinois. In 1972,
Markwood joined the Illinois EPA and was named Division
Manager two years later. He is a member of a number of
professional societies, and has been active in working with
the U.S. EPA to promote reasonable regulations for public
water systems under the Safe Drinking Water Act.
Audience  Response  to Session IX  — Waterborne  Disease
 Elmer E. Jones, Jr., Agricultural Engineer, USD A, Beltsville
 Agricultural Research Center, Beltsville, Maryland 20705:
 I believe the incidence of waterborne disease in rural areas
 is much higher than generally suspected. Many diseases are
 treated symptomatically without full diagnosis. Normally
 two or more cases must occur to be considered an outbreak.
 One case in a family of four is a 25% incidence. If this
 occurred in a city of 10,000 it would probably make all
 the major papers in the world.
      For some diseases the number of organisms required
 to produce a clinical case is extremely high. I believe
 typhoid requires about 100,000 organisms in a glass of water
 for a 50% incidence among individuals lacking immunity. At
 lower doses most individuals acquire immunity. That herd
 immunity is a factor in control of waterborne disease in
 rural areas is indicated by the high percentage of waterborne
 disease cases in rural areas that involve transients. Herd
 immunity offers no protection to new diseases.
      It is important for regulatory officials to recognize
 that within the well bore is a man-made structure involved
 in the protection of public health. As such it should be
 subject to periodic inspection and maintenance as required.

                                    TECHNICAL REPORT DATA
                             (Please read Instructions on the reverse before completing)
 1. R
                                                            3. RECIPIENT'S ACCESSIOI>NO.
              5. REPORT DATE
                  August 1979  issuing date
                                                            8. PERFORMING ORGANIZATION REPORT NO

   National Water Well  Association
   500 West Wilson  Bridge Road
   Worthington, Ohio   43085
              10. PROGRAM ELEMENT NO.
              11. CONTRACT/GRANT NO.
                Grant No. R-805747
   Robert S. Kerr Environmental Research  Lab.
   Office of Research  &  Development
   U.S.  Environmental  Protection Agency
   Ada,  Oklahoma  74820
 - Ada,  OK
 Final  (02/06/78 - 02/05/79)
             The Fourth National  Ground Water  Quality Symposium  was  held in
        Minneapolis, Minnesota,  September 20-22,  1978, in conjunction with the
        annual  convention  of the National Water Well  Association.

             The Symposium was dedicated to  the late George Burke  Maxey and the
        keynote address was  given by Courtney  Riordan, Associate Deputy Assistant
        Administrator, Office of Air, Land & Water Use, Office of  Research and
        Development, U.S.  Environmental Protection Agency.

             Nine sessions highlighting the  theme "The Issues of Our Time" were
        conducted through  a  debate format featuring national authorities presenting
        neutral, pro, and  con views followed by audience participation.
                                KEY WORDS AND DOCUMENT ANALYSIS
                                               b.lDENTIFIERS/OPEN ENDED TERMS
                           c.  COSATI Field/Group
    Water Quality
    Water Resources
    Water Pollution
    Ground Water
 Ground  Water Movement
 Artificial  Recharge

    Release to public.
19. SECURITY CLASS (ThisReport)
              21. NO. OF PAGES

                                               20. SECURITY CLASS (Thispage)
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EPA Form 2220-1 (9-73)
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