i. •
&EPA
United States           Nitrogen Work Group     40 0/3-90/003
Environmental Protection    PM-221               March 1991
Agency
Nitrogen Action Plan
                            HEADQUARTERS LIBRAfN
                            ENVIRONMENTAL PROTECTION AGENCY
                            WASHINGTON, O.C. 20460
                                     Printed an Recycled Paper

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                        *  DRAFT (3/5/91)  *

                        TABLE OF CONTENTS
EXECUTIVE SUMMARY   	   1

RECOMMENDATIONS 	   9

TECHNICAL APPENDIX  	 	    17

     PROBLEM CHARACTERIZATION 	    18
          Ecological Damages  	 .......    18
               Direct Toxic Effects	    18
               Indirect Effects  	    19
               Estuaries	    21
               Fresh Waters	    23
               US EPA Water Quality Standards 	    23
          Air Quality	    24
               Acid Deposition	    24
               Stratospheric Ozone Depletion  	    25
               Climate Change 	    25
               Ozone	    26
          Human Health Risks	    26
               Methemoglobinemia    	    26
               Reproductive and Developmental Effects ...    28
               Effects of Chronic Exposure  	    28
               Carcinogenic Effects 	    28
          Pathways of Exposure   	    29
               Individual Exposure  	    29
               Drinking Water Exposure  	    31
                    Public Water Systems  	    31
                    Domestic Water Supplies 	    35
               Ground Water   	    36
               Ground and Surface Water Interconnection .  .    38
          Economic Risks to Agriculture 	    38
          Welfare Effects 	    38

     SOURCES OF NITROGENOUS COMPOUNDS 	    40
          Nitrogen Cycle  	    40
          Nitrate Mass Balance	    42
          Natural Background Levels 	    43
          Use of Isotopes to Identify Sources       ....    43
          AGRICULTURAL SOURCES   	    44
               Commercial Fertilizer  ...........    44
                    National Usage  	    45
                    Application Rates 	    45
                    Potential Hotspots for Fertilizer Use .    49
                    Irrigation	    49
                    Chemigation	    51
                    Drainage	    52
                    Timing	    53

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          Livestock Waste  	    53
               Concentrated Livestock Production ...    56
               Animal Waste Storage Ponds  	    57
               Abandoned Feedlots   	    57
               Nonpoint   Source   Surface  Runoff  From
                    Fields	    60
          Legumes and Green Manures  .........    60
          Greenhouses and Nurseries  	    60
          Agri-Chemical Dealers   	    61
     NON-AGRICULTURAL SOURCES  	    62
          Septic Systems  	    62
          Urban Sewage	    64
          Land Application of Sewage Sludge  	    66
          Non-Farm Use of Fertilizer	    67
               Golf Courses	    67
          Airborne Sources 	    68
          Industrial Sources 	    69
               Food Processing Wastes    	    69
               Other Industrial Sources  	    70

POLLUTION PREVENTION 	    72
AGRICULTURE	    72
     Management Practices for Commercial Fertilizer   .    74
          Timing	    74
          Nitrogen Soil Tests	    75
          Economically and Environmentally Optimum Use
               Rates	    76
          Other Nitrogen Management BMPs   	    77
               Soil Conservation	    77
               Irrigation and Drainage Management  .  .    78
               Change in Cropping Patterns 	    79
               Ground Cover  	    79
               Nitrogen Inhibitors  	    80
     Implementation Issues 	    80
          Incentives	    81
               Technology Development and Education   .    81
               Taxes and User Fees	    82
               Reducing  Price  Distortions  from  Farm
                    Programs	    82
          Regulation of Fertilizer Use	    82
               State Programs	    82
               Toxic Substances Control Act	    84
               Agricultural Drainage Wells 	    85
               Nurseries and Greenhouses 	    86
     Livestock Waste Management   	    87
          Concentrated Livestock Facilities  	    87
          Surface Water Runoff from Fields   	    88
          Ground Water 	    89
          Implementation Issues   	    90
               NPDES Program	    90

                           ii


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                   *  DRAFT (3/5/91)  *

               Policies   Regarding  Farm  or  Regional
                    Manure Surpluses 	    90
               Runoff   and   Infiltration    from   Land
                    Application   of  Properly   Stored
                    Livestock Wastes 	    91
               Regulatory Programs  	    91
               Incentive-Based Programs  	    92
     Composting	    92
     Agri-Chemical Dealers 	    93
     European Programs 	    93
          Nitrate Policies in the European Community  .    94
          Programs of Key Individual Member States .  .    95
               The United Kingdom	    95
               West Germany	    96
               France	    97
               The Netherlands	    97
     Septic Systems  	    98
          Regulation	   100
     Urban Sewage	   101
          Regulation and Treatment  	   101
          Land Application of Sewage Sludge  	   101
          Water Conservation	   102
     Industrial sources   	   103
          Food Processing Wastes 	   103
     Non—Farm Use of Fertilizer	   103
          Home and Commercial Site Lawns   	   103
          Golf Courses	   105

REMEDIATION AND TREATMENT      	   106
     Public Water Systems  	   106
          Monitoring	   106
          Public Notification  	   107
          Treatment options  	   107
          New Nitrate Removal Technologies 	   108
          Enforcement	   109
     Domestic Drinking water supplies  	   110
          Private Treatment Options  	   112
          Bottled Water   	   113
          US Department of Agriculture 	   114
     Aquifer Remediation  	   114

INSTITUTIONAL ISSUES 	   116
     Federal Government   	   116
          Environmental Protection Agency  	   116
          U.S. Department of Agriculture 	   119
          U.S. Geological Survey 	   120
          Tennessee Valley Authority 	   122
     State Governments	   122
     Regional or Cross-Jurlsdictional Efforts  ....   124
     Local Governments & Others	   126
                          iii

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     APPENDIX A—Acronyms Used	   128
     APPENDIX B~Glossary	   130
     APPENDIX C—Agency Responsibilities  	   132
     APPENDIX   D—Methodology   for   County-Level   Manure
          Estimates	   133
     APPENDIX  E—Fertilization  Rates  in  Major  Producing
          States	   137
     APPENDIX F—Tons of Nutrient N Sold By State	   137

     BIBLIOGRAPHY 	   138
                              TABLES

TABLE 1A
NUMBER OF ANIMALS IN INVENTORY IN 1987  (1,000'S)	    54

TABLE IB
PRODUCTION  OF  MANURE  AND  NITROGEN  PER  ANIMAL  AND  NATIONAL
PRODUCTION TOTALS (1987): 	    55

TABLE 1C
LARGE-SCALE LIVESTOCK  (PERCENTAGE OF TOTAL PRODUCTION):  1987  56

TABLE 2
Average N use on corn, all farms/split application farms.  .  .  75
                                iv

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Figure 1 -

Figure 2a-

Figure 2b-

Figure 3 -

Figure 4 -


Figure 5 -

Figure 6 -

Figure 7 -

Figure 8 -

Figure 9 —

Figure 10-
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               LIST OF FIGURES


- Estuarine Systems Degraded by Nitrogen Loadings.  .  .22

— Human Exposure to Nitrate	30

— Human Exposure to Nitrite	32

- Public Water Systems:  Violation of Nitrate MCL.  .  . 34

— Distibution  of Nitrate-N Concentrations in Well Water
  Samples	37

- The Nitrogen Cycle	41

- Commercial Nitrogen Fertilizer Sales	46

- Sales of N by Region	46

- Nitrogen  Application Rates, Selected Crops	47

- Estimated Consumption of Nitrogen, Selected Crops.  . 47

— Comercial Fertilizer Nitrogen Purchased per Acre of
  Fertilized Cropland	50
Figure 11— Manure Nitrogen Availability per Acre of Fertilized
            Cropland	58

Figure 12— Total Commercial Fertilizer and Manure Nitrogen
            Availability per Acre of Fertilized Cropland	59

Figure 13— Density of Housing Units Using Septic Systems.  ... 63

Figure 14— Septic System Operation	65

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             NITROGEN ACTION PLAN EXECUTIVE SUMMARY
     Nitrogen is an essential element for all living organisms.  It
is  continually  being transferred  between soil,  water,  air, and
biota  in processes collectively  known  as  the  Nitrogen Cycle.
Nitrogen  compounds  are  ubiquitous.    Although  they  are  found
naturally in the environment,  a wide range of  anthropogenic sources
of these compounds (primarily fertilizers,  manure,  septic  systems,
waste water treatment plants, industry, and  automobiles)  increase
loadings  to  surface and ground  water  to  levels  that  can  be
hazardous to  ecosystems and human health.   This plan is  chiefly
concerned with the risks from nitrate  (N03) , nitrite (NO2),  ammonia
(NH3) ,  and nitrogen oxides (NOX) .

     Nitrate  of natural or anthropogenic  origin  is  found in all
surface waters and ground waters of the United States.   It  has many
important environmental effects,  usually beneficial, but sometimes
adverse.  Monitoring efforts by Federal  and State agencies have
detected elevated  nitrate levels  in the waters of all 50  states.
Since complex factors determine whether or not nitrate will  reach
surface or ground water (i.e., soil composition, geology,  climate,
agricultural  practices,  cover  crops),  it is difficult  to  make
general  predictions that  a  particular agricultural  or  disposal
practice  will   result   in   increased   nitrate  concentrations,
particularly in ground  water.

     Once contaminated,  natural removal of nitrate from aquifers is
usually an extremely long-term expensive process, and remediation
is  generally not  practical  or possible.    Consequently,  EPA's
Nitrogen Action Plan is grounded in the basic tenets of pollution
prevention:   it  is better  to  release  fewer of  these  nitrogen
compounds into  the environment  and  it  is  better to use practices
which minimize the movement of nitrate to  surface and ground  water
than attempt a costly remediation.

     Effectively protecting the environment from excessive  releases
of nitrogen compounds will require the concerted effort of multiple
interests and institutions: private citizens;  environmental groups;
industry; agriculture;  educational institutions; and local, state,
and Federal  agencies.     It  will  require  a  blend  of education,
technology transfer and demonstration,  regulation,  and economic
incentive/disincentive  tools.

                      RISK CHARACTERIZATION

Ecological Effects  Toxic concentrations of ammonia are one of the
leading causes  of  fish kills.   However,  there appears to be  no
direct human health threat from levels of ammonia typically  found
in water.   Fish kills from ammonia are generally transitory,  since
ammonia is readily oxidized to nitrate.

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                       * DRAFT (3/5/91) *

     Nitrate is not directly toxic to aquatic life except at very
high concentrations  [over 90 milligrams per  liter (mg/L)1],  but
excessive  loadings of  nutrients  (nitrogen  and phosphorus)  may
promote eutrophication.  Excessive nitrate, at levels an order of
magnitude below the level set to protect human health, appears to
be the principal cause of eutrophication of  estuaries.  Fresh water
bodies  are more  likely  to be  affected by phosphorus,  although
nitrate is a factor in the degradation of some lakes and streams.

     Nitrogen enrichment in estuaries can stimulate the growth of
algae, and possibly algal species that are less desirable as a food
source.  Overabundance of  algae  can block  sunlight from reaching
submerged aquatic vegetation,  create excessive oxygen demand as it
dies off,  and increase the  incidence  of toxic tides  from algal
blooms.  High nitrogen loadings  can also upset the distribution of
species in an ecosystem by disrupting the food chain.

     Estuaries all along the East Coast (ex: Chesapeake Bay, Upper
Potomac River Basin,  New  York Bight,  Pamlico Sound) have been
adversely affected by nitrogen,  as well as  Puget Sound in the West
and several others on the  Gulf  Coast.   Nitrogen inputs to marine
waters, as well as to many lakes and streams,   including the Great
Lakes, are increasing.

     Nitrogen is often a major contributor  to  acidity in sensitive
surface waters.   These episodes  can be lethal to individual fish
and invertebrates.

Human Exposure      Nitrate is the most common chemical  found by
drinking  water surveys.    Based  on results  from the  National
Pesticide Survey, EPA estimates that more than 50 percent of both
public and private drinking water wells in the United States have
detectable  levels of  nitrate.    1.2 percent  of  public  and  2.4
percent of private drinking  water  wells  are estimated  to have
nitrate at levels that exceed  10 mg/L, the  Maximum Contaminant
Level (MCL).  Some states have found a much greater percentage of
nitrate above 10  mg/L  in private wells,  for example:   Iowa, 18%;
Nebraska,  17.5%;  and Kansas, 28%.

     Approximately 1.7  million people  who use both  surface  and
ground water  public  water systems are  exposed to  nitrate levels
above the MCL during all or part of the year.   In addition, perhaps
two million people who rely on private wells may also be drinking
water contaminated at levels above the MCL.

     Human exposure to nitrate in drinking water  could increase
     1A11 nitrate measurements in this report will be expressed as
nitrate-nitrogen.

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                       * DRAFT (3/5/91) *

substantially over  the  next few decades as  a  result of historic
increases in nitrogen loadings to the soil.   Fertilizer sales have
quadrupled  since the 1950s.   Nitrogen that  is  applied  to  the
surface as  fertilizer may  reach  the ground water  as  nitrate in
months or centuries depending on climate, soil, geology, and many
other factors.

Human Health   Nitrate in drinking water at  levels above the MCL
can cause methemoglobinemia  ("blue baby syndrome")  in infants under
six months.   Even though  doctors are not required to report this
disease, 2,000 cases are cited in the literature in North America
and Western Europe  between 1945 and 1971  with  seven  to eight
percent fatalities.   This  rare,  but potentially  fatal disease,
limits the  oxygen carrying  ability of the  blood.   Older children
and adults  do not show  any  acute effects at  levels several times
higher than the MCL.

     A  few  studies have  investigated the possible reproductive
effects of nitrate with conflicting results.   Developmental effects
have  not  been  investigated with respect  to humans.   Currently
available evidence does  not  support reproductive and developmental
effects at  levels below the MCL.

     A greater number of studies have examined the possibility of
a correlation between nitrate intake and  cancer.   The National
Academy of Sciences  (1981) stated that the association is plausible
because of  the  reduction  of nitrate  to nitrite in the human body
and the ability of nitrite to combine with secondary amines, found
in  many  foods,  to  form N-nitroso  compounds  which are  potent
carcinogens.  However, no association has been proven between human
exposure to nitrate in drinking water and increased cancer risk.

     As a result of the uncertainties associated  with the health
effects of nitrate and nitrite, it is not possible to quantify the
risks from these chemicals on a national basis.

Welfare Effects     High nitrate  levels in ground and surface water
can lead  to adverse effects in areas other  than  human  health or
ecosystems.    Ruminant animals  are susceptible  to  nitrate/nitrite
toxicity  generally  at  levels of 100 mg/1  and above.    Nitrate
contamination is the major  cause of  the closure of public wells.
In California, nitrate contamination  has caused the abandonment of
more drinking water wells than any other chemical.   Increases in
algal growth  and blooms create  conditions highly unfavorable to
recreation  in surface waters.

                             SOURCES

     There are many important sources of nitrogen compounds. It is
difficult to  identify any  single anthropogenic  source  as being

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                       * DRAFT (3/5/91) *

generally responsible  for  the  elevated nitrate concentrations in
ground and surface waters across the United States.  The relative
importance  of individual  sources  varies  greatly  from place to
place, depending on many factors including:   land  use,   geology,
agricultural  systems,  climate, aerial deposition,  intensity of
human activity, and the characteristics of a specific water body.
Ranking of sources of  nitrate contamination is greatly complicated
by the fact that nitrogen in various forms may remain in the soil
system below the root  zone  for  years or decades.  The distribution
of nitrogen in the deep  soil profile in sub-humid  areas often
depends on  historical  practices.   Generalization at the national
level, therefore, can  only  be a point of departure for analysis at
the regional  or local level.   With  this  in mind,  the following
pieces of the picture emerge.

     Nitrate naturally found in ground water is ordinarily three
parts per million or less.   While instances do exist of naturally
occurring nitrate  concentrations  in  ground water  above the HCL,
these are exceptional cases.  Widespread nitrate levels exceeding
the MCL are undoubtedly a result of anthropogenic impacts in humid
regions.   Some areas  have had human  activity for  so  long it is
impossible  to  discern any natural   background  level.    Where
background  levels  do  occur,  control of  anthropogenic sources is
even more critical because  the  system has less ability to deal with
loadings in a benign way.

     The  fertilization of  cropland has  significant potential to
lead  to  nitrate  contamination  in many  areas  of  the country.
Nitrate contamination of ground water  from cropland  is most likely
to occur in areas with coarse-textured soils and a shallow depth to
the water table, sinkholes (karst geology), or fractured bedrock.
Surficial aquifers with high recharge rates are the most vulnerable
to contamination.   However,  deeper aquifers  may be increasingly
affected  in the  future.   Commercial  fertilizer is  the  largest
component  of  introduced nitrogen  on  cereal crops,  followed by
fixation of atmospheric nitrogen by legumes,  decomposition of crop
residues, manure, and atmospheric deposition.

     Commercial fertilizer use is considered to be the major cause
of  nitrate contamination  in  a  number  of  Illinois watersheds.
Rising levels of nitrate in drinking water supplies in some  area of
Iowa  since  1950  have been   attributed   primarily to nitrogen
fertilizers.   Fertilizer  use  in  irrigated  agriculture has been
identified as the chief source of nitrate  contamination of ground
water in the agricultural valleys of California, Central Nebraska,
eastern  Colorado,  and  in the  sand  plain  region of  central
Wisconsin.

     Some   researchers  have   indicated  that  farmers  in   some
circumstances  apply commercial fertilizers at rates in excess of

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                       * DRAFT (3/5/91) *

what  is  cost-effective.   Many  reasons have been  cited for this
apparent   irrational  behavior:     insurance   against  weather
variability;  failure to  adjust application rates  to account for
nitrogen supplied by manure, sludge, or legumes; lack of adequate
soil  and plant  tissue  tests;  and  failure to  follow  the best
available recommendations.   Unrealistic yield goals are another
possible cause of excess application. Manure used as a nutrient
poses particular problems since it has a variable nitrogen content
and can  be  difficult for farmer to get accurately tested and to
handle, making environmentally sound application costly.

     Both large livestock and dairy operations and the cumulative
output of many smaller operations in any given locale can also be
a major  threat to water  quality.   Dairy operations, particularly
when  they  involve  importing  feed grains,  represent significant
nitrogen loadings to the  soil system.  High levels of soil nitrate,
for instance, have been  found beneath animal holding areas in the
dairy regions of southern California.   Poultry manure, which has a
high  nitrogen  content,   has  been  found  to  be  a  source  of
contamination  in  areas  of  Arkansas and the  Delmarva peninsula.
Abandoned  feedlots,  especially,  are  likely  to leach  nitrates.
Livestock manure  has been  cited  as  a major source  of nitrogen
loadings to the Chesapeake Bay.

     Any  livestock  operation,  even  one  with manure management
facilities, can seriously degrade  water  quality,  unless adequate
provisions are made  for  manure  management.   Cattle feedlots with
impermeable manure containment structures can pose a problem when
the structures have inadequate capacity and allow runoff.   Some
farmers spread excess manure on land to dispose of it at rates that
can cause contamination  of ground and surface water.

     Non-agricultural sources of nitrogen compounds  are significant
threats  to  water  quality in many  areas  of the country.   Septic
systems  have  been identified by 41  states as a major  source of
ground water  contamination.   Septic systems are not designed to
remove nitrogen.   They deliver organic nitrogen to soils  at a point
below the root  zone, thereby enhancing the chances that it will
leach as nitrate rather than be  consumed by plants.  Septic system
density is the best available indicator of a problem.  The greatest
concentration of  septic systems  is  found  in the  Northeast  and
Middle  Atlantic  states.   Individual  septic system siting  in
relation  to   drinking  water   wells  is   also   an  important
consideration.

     Wastewater   treatment   plants  and   industrial  facilities
discharge large  quantities of  nitrogen  compounds  directly into
water bodies.  Secondary  treatment at these facilities removes less
than half of the nitrogen from the  effluent.  In wet weather, many
cities  with  combined  sewer overflows are  forced  to  discharge

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                       * DRAFT (3/5/91) *

effluent directly into water bodies with little treatment.

     Industries and  automobiles  also discharge large  amounts of
nitrous oxides  into  the  air.   These have been  implicated in all
major air problems:   acid rain, stratospheric ozone depletion, and
ozone formation in the lower atmosphere. Atmospheric deposition of
nitrate and ammonia are believed  to account for about one-third of
the total input of nitrogen to the Chesapeake Bay.  Estimates show
that the atmosphere is likely to be an important source of nitrogen
in some other estuaries as well as the Great Lakes.

     Urban  and suburban  land  uses  such  as for  lawns and  golf
courses contribute to nitrate loadings  to ground and surface water
in areas where high rates of fertilizer are combined with improper
irrigation.   These  land  uses can be  responsible  for significant
quantities of nutrient runoff during storms.

                      POLLUTION PREVENTION

     Pollution prevention generally is the preferred approach for
addressing  ground and surface  water  pollution  problems.   More
sustainable nitrogen management  practices are necessary  for all
sectors:  agricultural, suburban, and urban.  More costly remedies
should be focused on the largest sources in high risk areas.

     Several nutrient management  practices are available to reduce
farmers reliance  on  adding  fertilizer  nitrogen  in excess  of crop
needs.   Better soil testing and timing of applications  to  meet
plant N requirements  are practices recommended most often, although
insufficient resources for soil test calibration and interpretation
have limited  the  availability  of soil tests capable of reducing
fertilizer use.

     Related practices involve the setting of more realistic crop
yield goals,  plant  tissue testing for nitrogen,  manure testing,
irrigation water testing  for nitrogen,  more efficient water use on
irrigated land, closing drainage  outlets in winter on drained land,
winter  cover crops,  and establishing vegetative filters  along
streams.

     Preventing  pollution  on   farms  with  livestock  or  dairy
operations presents  additional challenges.   The first prevention
measure which a farmer  should undertake is the  construction of
adequate manure  storage  facilities to  limit  unnecessary  runoff.
Second, soil and manure testing,  as well as calibration of manure
spreaders, are recommended to avoid applying manure at rates which
are greater than  needed  by  the crop.   However,  limited financial
and managerial resources,  as well as time constraints can undermine
proper  manure management.   Other major  limitations  to efficient
manure use include:  the  inability to correctly determine nutrient

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                       * DRAFT (3/5/91) *

content; variability in nutrient content of manure; and the lack of
knowledge  about  the  extent  of nutrient  release  during growing
season, local and county-wide imbalances resulting from large-scale
livestock production between the production of manure and its use,
composting or de-watering, and transporting it  to manure deficit
areas has  to be  considered.   Uses may include  land application,
feed supplements, and  energy production.   Testing of the feed is
also recommended to ensure that only appropriate  levels of protein
are supplied.

     Effluent from sewage treatment plants can be treated through
biological denitrification.  While this  process  is expensive,  it
may  be necessary  to  protect  valuable estuaries.   With  proper
management, wastewater and sludge can be applied to land to utilize
the nutrient value.

     Since there currently are no economically practical methods to
limit nitrate concentrations in effluent from septic systems, they
should  be  regulated  through  siting  requirements  and  zoning
densities  to  provide  adequate  area  for  dilution  or  provide
incentives for tie-in  to sewer systems.

     Golf courses and homeowners should adopt sustainable practices
in maintaining their lawns, such as leaving mowed clippings on the
ground and recycling nitrogen from the clippings back into the soil
to reduce the need for commercial fertilizer applications.  Leaving
the  mowed  clippings on the  soil  should also result  in improved
water-use-efficiency.

                    TREATMENT AND REMEDIATION

     Where   pollution  prevention  strategies   have   not   been
implemented or are inadequate to prevent nitrate contamination of
water, nitrate levels  in drinking water can be reduced to protect
public health.   Nitrate removal  from ground water or surface water
occurs naturally through the denitrification process in anaerobic
environments.  No practical  method has yet been found  to reduce
nitrate  levels  in  the  aquifer,   although  researchers are  now
experimenting with processes to augment denitrification,  as well as
determining where denitrification  is  important  in the subsurface
system.

     Although nitrate  can be successfully  removed from drinking
water supplies, water treatment is  an expensive process.  A public
water system might be able to save the  cost of treatment if it can
find a  source  of low nitrate water to blend with or replace its
current  supply.   When that  is not possible,  the water  must  be
treated to meet the federal drinking water standard. EPA currently
lists  three technologies  for  adequate  removal  of  nitrate  from
public  water  systems:    ion  exchange,   reverse  osmosis,  and

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                       * DRAFT (3/5/91) *

electrodialysis.

     EPA estimates  that  public water systems will have  to spend
$192 million annually over the next  20 years  to meet the nitrate
drinking water standard.   Since most  systems  that violate  the
standard serve small populations, most of the national costs will
be born  by small public water systems  which are least  able to
afford the cost of treatment.

     Private well owners with high nitrate levels can choose among
several options, depending on the cost of the options,  the level
and type of contamination, and the amount of water the well owner
wants to  be potable.   They  can  continue  drinking  high nitrate
water, use  bottled  water,  drill new or  deeper  wells,  or install
treatment devices to remove nitrate.  Bottled water has generally
been found to be free of  nitrate,  although testing procedures need
to be strengthened  by the Food and  Drug Administration.   New or
deeper wells  may only  be a  temporary  solution  because nitrate
levels in deeper aquifers many increase with time.

     Very few States have formal  programs for  dealing with private
water  supplies,  although  most will recommend  laboratories  for
testing.   Construction  codes,  licensing of  well drillers,  and
siting requirements for new  wells  have been developed  by some
States.  Banks in several  states  have  begun to  require that well
water is tested for nitrate and bacteria, before loan approval.
                                8

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                       * DRAFT (3/5/91) *

               NITROGEN ACTION PLAN RECOMMENDATIONS

     The  Nitrogen Action  Plan  workgroup's  recommendations  are
organized  into  five  categories.     1)  develop  State  Nutrient
Management Programs,   2)  improve  on-farm  nitrogen management to
protect water  quality,  3)  improve public and  private drinking
water  quality,    4)  increase  control of  point  sources  through
current  regulatory  authority,  and  5)   research  in  areas  of
uncertainty.  These recommendations are not ranked in any order of
importance.  They are all equally part of the plan.

     EPA would ensure implementation of the  recommendations through
three  basic  approaches:   direct  EPA action, nonregulatory  and
regulatory; EPA  encouraging  or requiring State action;   and EPA
working with the  U.S.  Department of Agriculture  (USDA)  and other
Federal agencies.  The Nitrogen Action Plan  would be implemented in
two  phases.     Phase   I   emphasizes  using  current  regulatory
authorities,  pollution  prevention  techniques,   and  research.
Activities under  Phase II would  begin if these voluntary efforts
and current legal authorities were insufficient.

                       Direct Agency Action

     Under Phase  I,  EPA would use portions of the Safe Drinking
Water  Act (SDWA), Clean  Water  Act  (CWA),  and Toxic  Substances
Control Act (TSCA), Coastal Zone Management  Act (CZMA) to implement
the recommendations.   Although the authority  is  present for most
recommendations,  additional  money or reorientation of  current
resources  is  necessary in many  programs.   Direct EPA  action is
required to some  degree  in order to implement recommendations in
each of the five  categories.  Phase II recommendations would all be
implemented under increased EPA authority.

                           State Action

     States  that  rank sources  of nitrogen  compounds as  major
sources  of  ground  or  surface  water  contamination  in  their
assessments would develop programs that  adequately address those
sources both  from a pollution  prevention  and a  drinking  water
remediation perspective.   EPA will work with the states through
guidance, grant agreements, and technical assistance to implement
the Nitrogen Action Plan recommendations.

     Many  of the actions address  surface  water  contamination by
nitrogen compounds would  be  implemented by the States  under the
§319 nonpoint source program  of  the CWA.   EPA guidance under the
Coastal   Zone   Management  Act   will  include  many   of  these
recommendations.  § 319 grant monies for implementing these actions
can  be used  as  incentives   for State  participation by  adding
nitrogen management as a rating factor in grant guidance, although

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                       * DRAFT (3/5/91)  *

this  may  require additional  appropriations.   If  states  have
pesticide  management  plans,  this will be coordinated  with their
nutrient management programs.

     The  recommendations  that  address  ground  water  will  be
implemented under,  or in  coordination  with  Comprehensive state
Ground-Water Protection Programs  (CSGWPPs) and §319 Nonpoint Source
Programs.

                      Other Federal Agencies

     EPA will work in close  cooperation  with the USDA, USGS, and
TVA  (National  Fertilizer  and  Environmental  Research  Center)  to
implement many of the recommendations.  Recommendation  #2 would be
implemented through USDA programs.  Under Phase I, we propose that
EPA  form  a  workgroup with  USDA to develop  and implement and
programs that will improve  fertilizer, manure, and feed management
to protect water quality.  Some of the recommendations could also
be promoted formally through memoranda of understanding, intra and
inter-agency  research  initiatives.     Coordinated  research  is
essential.

     EPA also  has an  interest in working with  USDA  on drinking
water  issues  in  recommendation  #3  since Cooperative Extension
Service agents  work with  private well  owners and Farmer's Home
Administration provides loan guarantees and makes grants to small
community drinking water systems.

Phase I

l.   State Nutrient Management Programs

     EPA  will  include  nitrogen-related  problems  among  those
considered  for  action  under Nonpoint  Source  Programs,  State
Comprehensive Ground-Water  Protection Programs, Wellhead Protection
Programs, Pesticide Management Plans, and Coastal Zone Management
Plans.   To maintain  eligibility for EPA grants, Sates  would be
required to  consider and  identify nitrogen-related  problems for
action under these programs.   States would then implement nutrient
management activities within these  programs to  prevent further
water quality degradation from nitrates and related compounds.  EPA
will   provide  technical   assistance   documents,   guidance  on
development and implementation of nutrient management programs, and
grant guidance documents to the States.

State Program Elements;

   1.1   Identify  high risk  watersheds  through  §319  (including
        locations  where  ground-discharge  significantly  affects
        surface water quality) and vulnerable wellhead areas.

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                       * DRAFT (3/5/91) *

2.   Farm Nitrogen Management

  Through the Presidents' Water Quality Initiative (WQI), the 1990
Farm Bill,  EPA's Agriculture Policy Committee and other forums, EPA
will collaborate  with USDA  to develop and  implement voluntary,
cost-share best management practices (BMPs) that will improve the
efficiency of fertilizer use.

  2.1   Assist USDA in  its accelerated program  to calibrate and
        implement  soil and manure tests.

  2.2   Encourage  and  expand recordkeeping  (realistic yield goals,
        fertilizer application;  yields; ;  manure,  sludge,  food
        processing residue,  N  tests);  include  soil tests  when
        available.

  2.3   Expand  Water  Quality  Initiative  cost-share monies  for
        appropriate manure lagoon liners and storage facilities,
        on-farm biomethanation plants,  composting systems,  manure
        spreaders, etc. where  cost effective.   Assess and revise
        existing  SCS  specifications  to  assure efficient  use  of
        federal resources in  constructing storage facilities.

  2.4   Support financial incentives  for vegetative filters (CRP,
        WQIP,  ACP).

  2.5   Encourage   the Soil  Conservation Service  to modify  its
        national  standard  for  earthen manure  ponds to  require
        liners to  protect ground water in high risk areas.

  2.6   Encourage  USDA to offer easements to retire cropping rights
        within Wellhead Protection Areas by  using the Environmental
        Easement Program in the 1990  Farm Bill.
3.
Remediation and Treatment
     EPA will  work with state, federal,  and  private agencies to
improve  the guality of public and private drinking water supplies.
Some actions can  be taken  by EPA through current authority under
the Safe  Drinking Water Act  (SDWA).   Other recommendations will
require collaboration and cooperation, rather than regulation.

     Public Water Supply

     3.1  Increase  federal  and State enforcement actions against
          public  water systems  with  violations  of  the  nitrate
          standard  set under the SDWA.
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                       * DRAFT (3/5/91) *

     3.2  Require development of enforceable limits on fertilizer
          use  (and other nitrogen  inputs)  in wellhead protection
          areas established under the SDWA and provision of bottled
          water to infants  in  return  for exemptions from the MCL
          for small public water systems with nitrate violations.

     3.3  Encourage States to develop  innovative funding  (tax, fee
          on sources  of nitrogen,  etc.)  to assist  public water
          systems and domestic  well owners to treat water, provide
          an alternate source,  or buy easements.

     3.4  EPA to enter into a Memorandum Of Understanding with the
          Food  and  Drug Administration to require  bottled water
          companies to  monitor  at  the same frequency  as  Public
          Water Supplies and for the same contaminants.

     3.5  Encourage States to develop wellhead protection programs
          to protect public wells from all sources of contamination
          as required under §1428 of the SDWA.

     3.6  Pursue adoption of requirements for wellhead protection
          where  public  wells  are  financed by  Federal  or State
          grants or loans  (e.g.,  FmHA).

     Domestic Water Supply

     3.7  Encourage States to implement specific action to protect
          private wells, i.e. well construction codes, well driller
          certification,  well   testing  requirements,   sanitary
          surveys, financial aid,  alternative water (infants and
          pregnant  women),  septic  system  siting,  and  land  use
          restrictions  to  protect  water quality.    Many  of these
          actions will be  necessary in order for  a  state to meet
          the required elements of a SCGWPP.

     3.8  Encourage States/lending agencies to require well testing
          before real estate transfers and for new wells.

     3.9  Encourage states  to consider adopting the approaches used
          under their Wellhead Protection Programs  for public water
          wells  to  protect  densely-settled  areas  relying  on
          geographically clustered private wells.

4.     Point Source Control/Management

     This recommendation focuses  on using EPA's current regulatory
authority under the Clean Water Act (CWA), the Safe Drinking Water
Act  (CWA),  and the  Toxic  Substances Control  Act  (TSCA)  more
effectively to deal with sources of nitrate contamination.
Some additional authority would also be required.

                               13

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                       * DRAFT (3/5/91)  *

     4.1  Under  the  Class V  well underground  injection  control
          program  of  the SDWA,  require  BMPs on  cropland  and
          greenhouses  that  are drained by  agricultural  drainage
          wells.

     4.2  Require  water  quality  based  permits for  feedlots  and
          greenhouses.  strengthen NPDES  permitting for feedlots
          regulated   under  CWA   authority.    Include   a  land
          application  and manure  storage  component  protective of
          surface and ground water in permits.

     4.3  Require  anti-backsiphoning   devices  on  fertigation
          systems.

     4.4  Revise the  CWA  to eliminate the point source exemption
          for irrigation return flows so that  EPA can target those
          categories of flows  or geographic areas with the greatest
          potential for serious environmental damage.

     4.5  Under  TSCA  authorities  consider  using  the  product
          stewardship  to  require  fertilizer  manufacturers  to
          develop  programs   on   proper  handling   and   use   of
          fertilizers.    Begin  a  regulatory  investigation  on
          requiring  fertilizer dealerships to store  and handle
          fertilizer to better protect water quality.

     4.6  Move  up  the timetable  in  the  Water Quality standards
          Framework to develop nutrient  guidance for water quality
          standards by 1993.

     4.7  Add a requirement  to the  EPA  Operating  Guidance that
          during  a  State's   triennial  review, the State  adopt
          numeric ammonia standards for water where designated uses
          are impaired due to ammonia.   Encourage adoption of
          State-wide standards.

5.     Research

     In order to better understand the risks of nitrogen compounds
and  effective  ways   to  deal with  these  risks,   research  must
continue.   These  recommendations identify key areas  where more
research is needed either by EPA or through  increased coordination
with other Federal agencies.   Adoption    of    particular
recommendations may depend on predictions of  future contamination
of shallow or deep aquifers.

     5.1  Fill  in  data gaps on health  effects using a TSCA test
          rule or EPA/other Federal agency  funds.
                                14

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                  * DRAFT (3/5/91) *

5.2  EPA along with other Federal agencies such as USGS, USDA,
     and NOAA should  work to jointly improve understanding of
     fate and transport, including aerial deposition, nitrogen
     soil  loadings,  and waste  load allocations  in surface
     waters.  Plans should be  developed  on a land use by land
     use basis including intensively managed  crop lands and
     unmanaged forest  ecosystems to identify  the processes
     most   important  in   determining    the   environmental
     processing of nitrogen.    The  plans would  include the
     consideration of:
          in situ denitrification rates  and mechanisms in the
          saturated  zone  and  below the  root  zone in  the
          unsaturated zone.
     -    fate and transport modeling in  the  saturated zone
          and below the root zone.
          estimates  of  the   depth  and  age  of  nitrate
          contamination of the saturated zone and predictions
          of peak contaminant  levels in deep  aquifers  under
          several nitrate management scenarios
          determine the benefits of adding organic matter to
          the soil
          fate and transport modeling in  soil  with emphasis
          on  computing N  mass  balance  and  transformation
          rates

5.3  Develop   new   technologies   and    improve   existing
     technologies for water supply and wastewater treatment.
          Improve efficiency of  drinking  water treatment to
          reduce  costs, especially for  small  systems.
          Improve  wastewater  technology,  including use  of
          constructed wetlands.
     -    Develop/evaluate alternative septic  tank designs.

5.4  Research to improve manure management:
          USDA to  research cost-effectiveness  of innovative
          manure and  septage uses and distribution, for areas
          in  which land area suitable  for application  is
          limited.
          Evaluate the nutrient content  of manure and how it
          changes over time  in relation  to the  ability of the
          plant to take up N.

5.5  Evaluate  the  effectiveness, i.e.,   risk  communication,
     economic  efficiency,   financial  impacts,  health  and
     environmental efficacy  of  implementing  the  Nitrogen
     Action Plan.

5.6  Work with USDA to evaluate effectiveness of nutrient best
     management practices for water quality, including ground-
     water discharge  into surface water.

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                       * DRAFT (3/5/91) *

     5.7  Determine  where  economically efficient  application  of
          fertilizers and manures will still adversely affect water
          quality.

     5.9  Evaluate information on  fertilizer  use by turf growers
          and lawn care companies obtained  under TSCA to determine
          the relative  importance  of non-agricultural fertilizer
          use as a water pollution source.

Phase II

     EPA  would  implement  a  second  set  of  water  protection
activities if Phase I proved insufficient.  For example, additional
measures would be needed if other agencies  fail to adopt voluntary
recommendations,  if  voluntary measure  are inadequate,  if state
enforcement of regulatory  requirements  is  lacking,  or if further
research reveals  that  the health  or  ecological  risks associated
with nitrate contamination is more  severe than current assessments
indicate.

     Examples:

o    Create state revolving loan fund and grant program to assist
     small PWSs  with no other recourse  in providing alternative
     supplies and installing treatment facilities.
     [Will require a Federal infusion of start-up money.]

o    Use TSCA and SDWA to limit fertilizer applications in targeted
     areas.

o    Implement a nationwide tax on sources of nitrate and use the
     proceeds to help contaminated water suppliers, buy easements
     on  highly vulnerable  land,   cost-share  manure  storage  and
     composting facilities, cost-share appropriate use of compost,
     among others.

o    Obtain legislative  authority  to require farmers  to develop
     nutrient management plans in watersheds where nutrients impair
     or threaten water quality.

o    Require farmers to adopt nutrient best management practices in
     order to be eligible for farm subsidy payments.
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                       * DRAFT (3/5/91) *

             NITROGEN ACTION PLAN TECHNICAL APPENDIX

                           INTRODUCTION

       Nitrogen (N) is an ubiquitous substance.  About 98 percent
of the nitrogen on Earth  is  tied up in rocks and minerals of the
lithosphere.   Atmospheric  nitrogen  accounts  for  most of  the
remaining nitrogen. It makes up 78% of the Earth's atmosphere, by
volume.   Living  matter,  soils,  sea bottoms, and  the  oceans all
contribute tiny percentages to the total.  Nitrogen is an essential
element  for life.   It  is continually  being transferred between
soil, water, air, and biota through processes collectively known as
the nitrogen cycle.

     Human activities have altered the natural functioning of the
Nitrogen Cycle by adding large quantities  of  nitrogenous compounds
to  local environments.    In many  places  these  additions  have
overloaded  the ability  of  ecosystems to  compensate for  these
increases,  resulting  in  significant   deterioration of  aquatic
habitats.   Many  estuaries, especially along  the  East  Coast have
become or are becoming eutrophic.  Contamination of ground water is
creating  concerns about  possible  human  health  effects.    Once
contaminated,  natural  removal of nitrate  from ground  water is
usually  an  extremely  long-term  process,  and  remediation  is
generally not practical or possible.

     There are several  primary reasons  for anthropogenic additions
of nitrogen compounds to the environment:  to increase agricultural
production (generally commercial  fertilizers and animal manure) ; to
supplement  lawns,  maintain  golf  courses;   to  dispose  of  human
sewage;  and as a  byproduct  of  industrial  processes,  automobile
operation, and animal production.

     The  Nitrogen Action  Plan  was  developed  in  response  to  a
growing national  concern about the ecological and health impacts of
nitrogenous compounds.   The United States  Environmental Protection
Agency  (EPA)   has  developed  a   national  strategy  to focus  and
coordinate its activities and help states  deal with all sources of
nitrogen effectively and efficiently in order to limit risks posed
by contamination from nitrogen compounds,  especially  nitrate  (NO3-
) , nitrite  (NO2~) ,  and  ammonia  (NH3) , and  nitrogen  oxides (NOX) .

     This background paper is divided into four sections.  First,
Risk Characterization looks at the known and theorized risks from,
and  exposure  to,  nitrogenous  compounds.    The Sources  of  these
compounds are then analyzed, including the relative  importance of
the various sources both  nationally and locally.   Techniques and
regulation available to  limit contamination are evaluated in the
Pollution  Prevention  section.     Finally,   the  Remediation  and
Treatment section looks at technologies and regulation available to

                                17

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                       * DRAFT (3/5/91) *

reduce nitrate contamination in drinking water.

                     PROBLEM CHARACTERIZATION

     Nitrogen compounds  have demonstrated adverse environmental,
health, and welfare effects.  Ground and surface waters throughout
the United States and in many other countries are contaminated by
nitrogenous compounds.   These compounds play a role in all major
air problems.   Some health effects have  never been demonstrated
conclusively in  human populations,  but the  scientific basis for
concern exists.   The Nitrogen Action Plan is,  in part, based on the
assumption that  because of the uncertainties surrounding the health
effects  of  nitrate  in  humans,  it is  reasonable to  limit human
exposure from all sources (NAS,  1981; Forman, 1988).

                        Ecological Damages

     Excessive nutrients in fresh and  saline waters have several
wide-ranging adverse effects on  species and ecosystems  as a whole.
Nitrogen in  the form of ammonia is directly toxic to  fish and
shellfish.   Nitrogen, usually as nitrate,  in addition to phosphorus
can cause eutrophication of  water bodies.   In  addition to ecosystem
effects, eutrophication  can also limit  beneficial uses  such as
recreation,  tourism, or  drinking  water.    The  impact  on  human
populations is especially great in estuaries since approximately 75
percent  of  the  population  of the United States lives within 75
miles of the coast.  Nitrogen oxides contribute to degradation of
the atmosphere and water  bodies in the form of acid deposition, and
the depletion of the stratospheric ozone layer.

Direct Toxic Effects

     Ammonia (NH3)  is the nitrogen compound of greatest concern in
relation to direct  toxic effects in  aquatic  environments.   It is
discharged into  surface water bodies in  relatively large quantities
primarily  from  industrial   processes  and  wastewater treatment
plants.  The level of ammonia that is toxic to aquatic  life varies
considerably with  factors such  as temperature,  pH,  and salinity.
However, ammonia  is generally toxic  in the  range of  one to five
mg/L as nitrogen.   In the respiratory  process, fish excrete ammonia
gas through their  gills.  When there  is  a high concentration of
ammonia gas in the water, ammonia will remain in the bloodstream,
killing the fish.   There appears to  be no human health threat at
levels typically found in water.

     Ammonia is one of the  leading causes of fish kills according
to the  1988  §305(b)  Report. From 1970 to  1978  over reported 200
fish kill incidents were attributed to  ammonia, with approximately
10 million fish  killed (EPA,  Fish Kill File,  1979).  These numbers
probably underestimate the  extent of the  problem since many fish

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                       * DRAFT (3/5/91) *

kills are not be  reported  to state conservation agencies.  Also,
this estimate omits incidents of  reported  fish kills where ammonia
could  not be  specifically  determined  to be  the causal agent.
Ammonia fish-kill data from the 1980s has not been compiled by EPA.
Fish kills  from ammonia are usually transitory  in  nature since
ammonia  is  generally  not  stable  in water  and will  convert to
nitrate or volatilize  into the atmosphere.   However, ammonia may
combine with  chlorine in the effluent  from wastewater treatment
plants, for example, to form chloramine, a  persistent compound that
extends the  effects of  chlorine (highly  toxic  to  aquatic life)
downstream. Nitrate is not directly toxic in aquatic environments
except at very high concentrations (over 90 mg/L).

Indirect Effects

     Excessive loadings of  nutrients (phosphorus and nitrogen) pose
significant ecological risks  by stimulating the  over-enrichment of
estuaries,  lakes,  reservoirs, bays,  and slower streams.   This
process is  known as eutrophication.   Eutrophication occurs when
excess  nutrients stimulate  the  growth  of  algae and  alter  the
biological composition of ecological communities.

     The  availability  of nitrogen   is   generally  the  nutrient
limiting algal growth  in the saline waters of estuaries and bays.
Phosphorus tends to be the limiting  factor  in lakes, reservoirs,
and slower streams.   Although this concept  may be too simplistic
for many  ecosystems where  the limiting nutrient may shift during
the year,  generally either nitrogen or phosphorus  have dominant
effects on algal growth.

     In some cases the ratio  of nitrogen to phosphorus (N:P) may be
more important than the absolute amount of either nutrient.  Most
algae species favor a water  environment containing approximately
ten parts nitrogen to  one part phosphorus.  When the N:P ratio is
below 10:1, nitrogen tends  to be the more important factor limiting
algal growth.   However,  the  optimal N:P  ratio  for  various algae
species ranges  from 4:1  to 38:1.   (When P is high,  N tends to be
limiting in lakes.) Ratios can also  shift dramatically during the
course of a year.  Therefore, it  is necessary to evaluate nutrient
limitations of water bodies during the critical period of the year,
generally the summer,   when the water is impaired by algal growth.

     There are many studies documenting phosphorus limitation for
fresh waters.  However, nitrogen limitation in estuarine waters has
not been rigorously demonstrated  (Hecky, 1988).   With these caveats
in mind however, several  studies show a general trend that nitrogen
tends to  be  the limiting factor in  marine  waters (Hecky, 1988),
waters affected by urban activity (Bartsch,  1981;  Smith, 1982),
eutrophied fresh waters (Suttle,  1988),  and Northwestern waters at
higher elevations (Rhee,  Bachmann,  Larsen, personal communication,

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                       * DRAFT  (3/5/91) *

1990).   Perhaps  ten to  twenty percent  of lakes  worldwide are
nitrogen limited  (Lee, 1990, personal communication).

     Nitrogen  enrichment of estuaries  has six  primary effects,
several of which  follow directly from increases in algal growth.

   1)  Algae attaches directly to submerged aquatic vegetation or
floating  algal  blooms   and blocks  sunlight  from reaching the
vegetation  thereby restricting plant  growth.    The loss  of the
vegetation  has  been  correlated  with  reductions  in  waterfowl
populations  and  elimination  of essential  habitat  for finfish,
shellfish, and other aquatic life.

     2)  Algal  blooms such as red tides,  brown  tides,  and green
tides  have  been linked to  nitrogen  enrichment in  estuaries.   A
toxin  is produced in these blooms which  can be  lethal to fish,
aquatic   invertebrates,   mammals,   and  humans   (Kann,   1987).
Scientists  have  seen  a  world-wide  increase  in the   frequency,
magnitude, and geographic extent of  tides (Gutis, 1988).   In the
United States,  toxic tides have  been  reported off Long Island,
Rhode Island, North Carolina, Florida,  and Washington.

     3)  Algal blooms die off and introduce  ammonia  into the water
body thereby creating increased oxygen demands.  Water below three
parts per million dissolved oxygen limits the  use of habitats by
fish and shellfish.  Mobile fish are  effectively excluded from the
area  of  the available  habitat with low  dissolved oxygen.   The
shellfish or slow moving  species may die out or have  lower survival
rates from the reduction in the available  oxygen.  Oxygen-depleted
water in Raritan Bay, New Jersey,  is responsible  for the death of
approximately one million flounder and fluke which were trapped.

     4)   High  nitrogen  loadings  cause  declines  in   abundance,
biomass, and species diversity, and increase total mortality of the
aquatic community. Opportunistic species,  which can  take advantage
of the nitrogen,  then  increase.   These  species may  be  a  less
desirable food source than the species they are replacing  (Boesch
and Rosenberg, 1981).

     5)    It has been  theorized that  nitrogen  enrichment  in
estuaries results in a shift from green algae or  diatoms to blue-
green  algae.  Unlike green  algae  which can be readily eaten by
minute aquatic herbivores that form the basis of  the aquatic food
chain, blue-green algae are often  filamentous and covered  with
gelatinous sheaths.  Therefore, they are  undesirable as a direct
food source for aquatic herbivores,  and instead accumulate in the
water  (Ryther, 1969).

     6)  Finally,  proliferation of algae has been implicated in the
destruction of  some coral ecosystems.   Algae  can overgrow coral

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                       * DRAFT (3/5/91) *

reefs and kill them.  (need citation)

Estuaries

     Estuaries and  near coastal  waters are the  most productive
habitats on earth.  They serve as  spawning grounds, nursery areas,
and feeding  grounds for fish and  shellfish.   Approximately two-
thirds of  all fish  caught  world-wide are hatched  in estuaries.
Nitrogenous  compounds are  major  contributors  to water quality
degradation in estuaries.
Temporal and Historical Trends     Nitrogen  inputs to  estuaries
vary  greatly  by  the  season and  rainfall.    In years  with high
rainfall, substantially more nitrogen is contributed to the surface
water because of increased runoff  from  the land  and the inadequate
ability of sewage treatment plants  to  handle the increased loads
from the stormwater.   Increased rainfall may somewhat dilute the
nitrate  concentrations.   Resort  areas handle  larger volumes of
waste during  peak vacation periods and  therefore  discharge more
nitrogen into estuaries.

     Historical  trends indicate  that  nitrogen inputs  to marine
waters have increased due to urbanization, centralization of sewage
treatment, greater use  of fertilizer, and increased deposition from
the atmosphere.   For example, the late 1970s  and early  1980s showed
a sharp  decrease in the  diversity  of  aquatic  vegetation  in the
Pamlico  River   Estuary.     The   North  Carolina   Division  of
Environmental  Management  attributed  the  decline  to  nutrient
loadings, 82 percent of the nitrogen coming  from non-point sources
(Harding,  1990) .   Data  from   1974  to  1981  show  the  following
percentage  increases  in  total  nitrogen   loadings:    Northeast
Atlantic Coast,  4.0%;  Long Island  Sound/New York  Blight,  3.3%;
Chesapeake   Bay,   3.6%;   Southeast    Atlantic   Coast   2.6%;
Albermarle/Pamlico  Sound,   3.5%;  Gulf  Coast,   5.4%;  Pacific
Northwest,  .8%;  California, .7%  (Jaworski, ?;  Marchetti,  1989;
Smith, 1987).

     Currently,   the estuarine  systems  of the Atlantic Coast have
been more affected by nitrogen  than  those on the West  Coast.   Low
dissolved  oxygen  concentrations  have  been  identified  in  the
following major estuaries (see  Figure l):  East  Coast—Long Island
Sound, East River, Hudson/Raretan Bay,  New York Bight/Coastal New
Jersey, Chesapeake Bay, Lower Chowan River,  Albemarle  Sound, Neuse
River Estuary, Biscayne Bay; Gulf Coast— Tampa Bay, Perdido Bay,
Mobile Bay, Lake Ponchartrain, Central Gulf of Mexico;  West Coast—
Puget Sound.

     The following estuaries potentially have low dissolved oxygen
concentrations:     East Coast—Indian  River  Bay,   Rehoboth Bay,

                                21

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Cooper/Wando    Estuary,    Savannah    River;    Gulf    Coast—
Escambia/Pensicola  Bay,  Galveston  Bay,  Mississippi  Sound;  West
Coast—Port  Susan,  Hood  Canal, San  Francisco Bay,  Los Angeles
Harbor.

Fresh Waters

     As discussed above,  eutrophication in fresh waters is usually
caused by  excessive phosphorus.  However, there  are examples of
lakes throughout the world that are nitrogen-limited  (Dodds, 1989) .
For example,  Florida has several nitrogen limited  lakes because
there  is  an abundant  supply  of naturally occurring phosphorus.
Algal growth in Lake Tahoe is limited by nitrogen (Jones and Lee,
1990).  There  are also many other  lakes that are limited by both
phosphorus and nitrogen depending on many different factors.

     In  general,  nitrate  levels in  the Great  Lakes have  been
increasing.   Lake  Huron,  for example, has an  annual increase of
.011 mg/L  nitrate per  year and Lake Ontario's annual increase is
.009 mg/L  per  year.  Lake Superior  is the only Lake that shows a
decrease at  .001 mg/L  per year (Great Lakes  Water Quality Board,
1989).   Even  though  no  adverse impacts  from these increasing
nitrate levels have been noted in  the Great  Lakes  to  date,  the
Great Lakes Water Quality Board (1989)  believes that the increases
could have a significant impact on ecosystems within the Lakes.
Since excess  nitrogen  has the  potential  to  change  phytoplankton
(algal)  communities,  as noted above,  the   food  chain may  be
disrupted.

US EPA Water Quality standards

     Through the Clean Water Act, water quality standards [§ 303]
are established to protect the public health and welfare, enhance
water quality  to provide for  the  protection  and propagation of
fish,  shellfish, and wildlife,  and for recreation  in and on the
water. These standards are developed for the  full range of surface
water bodies.  EPA makes  recommendations to the states in the form
of criteria for development of state water quality standards.  Then
US EPA approves the  state-adopted standards for interstate waters,
evaluates adherence to the standards and oversees enforcement.

     EPA criteria  for  ammonia  is based  on a  formula taking the
fluctuations of flow, temperature,  and pH  into  account.  27 states
and territories have adopted numeric standards  for ammonia.  Other
states have been reluctant to  adopt numeric  standards because of
the cost of complying with the standards and  EPA's perceived lack
of confidence in the ammonia freshwater criteria.

     The current water  quality criteria for nitrate is based solely
on the health  endpoint for drinking water supplies,  10  mg/L (US

                                23

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                       * DRAFT (3/5/91) *

EPA, 1976).   A national standard for nitrate based on water quality
impacts is considered inappropriate because the nitrate level which
adversely affects various water bodies depends, to a great extent,
on site-specific conditions:  temperature, turbidity, plant growth,
presence or  absence of nitrogen-fixing bacteria, and other physical
or  chemical  characteristics.    However,  EPA's  Office of  Water
Regulations  and  Standards has  listed  the development of nutrient
criteria  (nitrogen and phosphorus) as a Level I Priority.   US EPA
anticipates  that three  years  will  be  required  to develop  the
nutrient criteria guidance, but current funding levels will delay
publication until 1996.

     States  rarely specify   water quality  standards  for  nitrate
apart from  the  health effects level.   Some states qualitatively
describe  their  nutrient standards, which include nitrate.   For
example,  Arkansas  standards state that  for nutrients "materials
stimulating  algal  growth shall not be  present  in concentrations
sufficient to cause objectionable algal densities or other nuisance
aquatic vegetation"  (US  EPA, 1988) .   Some states  do list nitrate
water quality standards:   Hawaii, 0.008  mg/L in  estuaries, 0.07
mg/L in streams;  North Dakota, 0.375  mg/L in  lakes; New Jersey, 2
mg/L, Nevada, .4-5 mg/L  (depending on the specific water body).

                           Air Quality

     Nitrogenous compounds in the air contribute to adverse effects
in both the  atmosphere and on terrestrial ecosystems and materials.
Emissions are expected to  increase  in the long term.   Nitrogen
oxide gases (NOX)  contribute to  all  major  air problems although
they are  not the primary constituent of any of them:   chemical
formation of acid rain,  stratospheric  ozone  depletion,   climate
change, creation of ozone in the  lower atmosphere, health effects,
and visibility degradation.  Aerial deposition of nitrogen oxides
on  estuaries may be  an  important pathway  for nitrogen loadings
(Jaworski,  1990).   Increased soil nitrogen from  fertilizers and
acid rain may have an effect on global warming.   Atmospheric
deposition has also been  observed to lead to high levels of nitrate
in ground water.   In the San Gabriel Mountains near Los Angeles,
California,   ground-water concentrations  from nearby,  relatively
unpolluted  watershed  were  typically  one to  three  orders  of
magnitude lower.

Acid Deposition

     Acid deposition  is  composed  of  both wet and dry deposition.
Acid rain is the name most  commonly  used for wet deposition, but
nitrogen  can be  also be added  to ecosystems  from fog  and dry
deposition.   NOX is a precursor to  nitric acid which is one of the
primary components of acid deposition along with sulfuric acid and
minor  contributions  from  hydrochloric  acid.    Deposition  is

                               24

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                       * DRAFT  (3/5/91) *

considered acidic if the pH is  5.0 or below.  Nitrogen is often a
major  contributor to  acidity  in  episodes  of  pH  depression in
sensitive  surface  waters.    These  episodes  can  be lethal to
individual fish and invertebrates.2

     Acid rain has been implicated in several ecological effects.
Forests in central and eastern  Europe, Norway, Sweden, the United
States  (especially  northeastern states),  and Canada  are dying.
Needles of  coniferous  trees are turning yellow  and falling  off.
Airborne pollutants including N0x are thought to play a significant
role.  Acid deposition also contributes to  the erosion of stone in
buildings and statues and the corrosion of  metals.   Acid in lakes,
especially in areas with few natural buffers, can suffer depletions
of aquatic life.  For example,  30 percent of Adirondack lakes, 12
percent mid-Atlantic/Coastal plain  lakes, and 23 percent of Florida
lakes  are  acidified (Air/Water Pollution  Report,  9/10/90).   10
percent of the fish populations  in these lakes have been lost.  Few
fish species can sustain viable  populations in water below 5.0 pH.

Stratospheric Ozone Depletion

     Theoretically,  any  increase in the amount  of nitrous oxide
(N20)  reaching the stratosphere  is likely to lead to some depletion
of the ozone layer (NAS, 1978).  Nitrous oxide is  formed from the
process of  denitrification,  conversion of  nitrate to nitrogenous
gases.  As more nitrate is  added by the manufacture of fertilizers
or  the  cultivation  of  legumes  which fix nitrogen  from  the
atmosphere, more  nitrate is available  for denitrification.   The
depletion  of  the stratospheric ozone  layer leads to  increased
ultraviolet radiation on earth  which can cause increased rates of
skin cancer and birth defects.   Nitrous oxide appears to have about
one-tenth  the effect of  chloroflourcarbons  (CFCs) on the ozone
layer.

Climate Change

     Methane  gas  has  been increasing in the atmosphere  by about
1.1%  a year  since  1980.   Steudler,  et  al.  (1989)  found that
increased nitrogen  content in  soils seems  to interfere  with the
     2There  are  important  uncertainties  associated  with  this
statement.     The  quantitative  relationship  between  nitrogen
transport  from watersheds and  nitrogen deposition  is an  area
requiring  more research.   Further, there is  some question about
whether such mortality to  individuals could be compensated for by
populations  in   nature.     If  such  compensation  does  occur,
populations of organisms within a region might not be negatively
impacted.
                                25

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                       * DRAFT (3/5/91) *

ability of  microorganisms  to take up methane from  the  air.   The
bacteria prefer  nitrogen to methane  as  an energy source.   In a
fertilized temperate forest,  this ability was reduced by one-third.
It is not known  what effect  this  phenomenon might have on global
methane levels or  if increases  in methane production rather than
decreases  in methane  uptake may be  responsible for  the rising
methane levels  in  the atmosphere.    If the level  of  methane is
rising it could be   contributing to the "greenhouse" effect.

Ozone

     In the lower atmosphere, complex  photochemical reactions that
involve  NOX,  carbon monoxide,   and  volatile  organic  compounds
produce ozone.  The  rate of  ozone production depends on the ratio
of NOX to volatile  organic  compounds in addition to their absolute
levels.   Ozone contributes to reductions  in the yield of various
agricultural crops:  corn, 1%; cotton, soybeans, 7%; alfalfa, 30%
(NAPAP,  1987).   Two  forests in  California  in  the  San Bernadino
Mountains and the  southern Sierra Nevada  have  been shown to have
experienced declines caused  by increased ozone levels.


                       Human Health Risks

     This section evaluates  the risk to human health from nitrate
in drinking water  on an individual and a  national  basis.  Acute
toxicity results from the  conversion of nitrate to nitrite in the
body.  Infants under six months  appear to be the population most
sensitive  to effects  of  nitrate ingestion.   EPA  has  not yet
evaluated nitrate  and its theorized  role in the  development of
cancer.   Studies are not conclusive.   Exposure to nitrate varies
significantly across the  population  based on diet  and drinking
water source.    Some  estimates  on national exposure  have been
calculated.

Methemoglobinemia

     Depending  upon  a  number  of  factors,  nitrate  (KO3~)  is
generally the stable form  of nitrogen in water.  It is relatively
non-toxic to humans.  However, nitrate can be reduced by bacteria
in water, in saliva, or in the stomach to form  nitrite (NO2-).  In
healthy adults,  about five percent of ingested nitrate is reduced
to nitrite.  However, a large variation exists between individuals
(Packer et al.,  1989).  Up to 50 percent may be reduced in people
with low stomach acidity and a bacterial  infection (NAS, 1981).
Infants reduce more nitrate to nitrite than adults because  of their
naturally  lower gastric  acidity  (Fan,  1987).    Nitrite  is the
specific chemical of concern  because it can bind with hemoglobin in
the blood  to form methemoglobin  (metHb).   MetHb prevents oxygen
from binding to  red blood cells and results in the inability  of the

                                26

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                       * DRAFT  (3/5/91) *

blood to transport oxygen.

     The  average adult  has a  metHb  level  in  the blood  of one
percent or  less.  Less  than  two percent metHb  is average for a
child.   Clinical symptoms  of the disease  methemoglobinemia, or
"blue baby  syndrome" as  it is commonly called,  appear when the
level reaches  10 percent.  The skin  takes  on  a bluish cast and
breathing  may   become   difficult.     Headaches,  weakness,  and
breathlessness occur at 30 to  40 percent. Coma and death can result
when  levels of  metHb in the blood are  60 percent  or greater.
Methemoglobinemia is easily treatable  when it is diagnosed  in  time
(Coroly, 1945).

     Infants under six months  of age are most at  risk of developing
methemoglobinemia from the  ingestion of nitrate  from levels of 10
milligrams per liter (mg/L)  nitrate-nitrogen (N03-N)3 or greater in
drinking water.  There are several factors which  seem to contribute
to  this occurrence:   high  fluid intake  in proportion  to  body
weight, high percentage of fetal hemoglobin in the blood, temporary
deficiency  of  metHb  reductase,  and  lower  gastric acidity (NAS,
1981).  In addition,  infants with diarrhea or respiratory illnesses
may be predisposed to developing methemoglobinemia (Shearer, 1972) .
Shearer studied metHb  levels of 256  infants.   One-third  of  the
infants with respiratory disease had elevated metHb levels,  but the
highest levels were  found in  infants with diarrhea.  The level of
bacteriological contamination in the water source also  seems to be
an  important factor.   Older  children and  most adults  show an
effect,   if   any,   only  at   much  higher   levels  of  nitrate
contamination.  Craun (1981) tested 102 children ages one to eight
years old who drank water with 22 to 111 mg/L nitrate  and did not
find any statistically or biologically significant increases in the
metHb level  in  their blood  based  on the  nitrate level  in  the
drinking water.

     Though the actual incidence of methemoglobinemia in the United
States is unknown since national statistics  are  not maintained, it
appears to be rare.   Walton  (1951) reported  over 278 cases between
1939 and 1950 with 39 deaths.  2,000 cases were documented in North
America and  Europe  between 1945 and  1971  (Shuval and Greuner,
1971).  Fatalities were reported in seven to eight percent of the
cases.  The most recent  death  occurred in South  Dakota.   A two
month old infant who received supplementary feedings  of powdered
     'studies present contaminant levels in two ways, as nitrate-
nitrogen  (NO3-N) or  as nitrate  (NO,) .   All  measurements  in this
report are  presented as nitrate-nitrogen, the  form  used  by EPA.
The word nitrate will  be used  for convenience.  When NO3 was used
in the original study,  appropriate  conversions have been made.  10
mg/L NO3-N equals 44.3  mg/L N03-

                                27

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                       * DRAFT (3/5/91) *

formula mixed with well water with a nitrate concentration of 150
mg/L died in 1986 (Johnson, et al., 1987).

Reproductive and Developmental Effects

     Several recent epidemiological studies have raised a concern
that there is a relationship between congenital malformations and
the nitrate level in the drinking water consumed during pregnancy.
In a study in South  Australia,  Dorsch  (1984) found a statistically
significant three-fold increase in risk of malformations of the
central nervous system (CNS)  and  the musculoskeletal system of the
fetus for women whose drinking water contained 1.1 to 3.4 mg/L
NO3-N.  There was a four-fold risk when the nitrate level was above
3.4 mg/L.  Arbuckle et al.(1986)  conducted a similar study in New
Brunswick, Canada.  He found no significant differences, but risk
of CNS defects increased with increasing nitrate levels  (up to 5.6
mg/L NO3-N)  in well  water.  The same increase was not observed in
spring water or public water supplies.

     Neither   study   is  considered   sufficient  to   discern  a
relationship between nitrate and congenital malformations since the
levels of exposure were  only estimated.  There may be other factors
in the water  source or elsewhere  that explain the malformations
found in the studies.  These studies do,  however,  suggest a focus
for more research.

Effects of Chronic Exposure

     Chronic   effects   of   subclinical    levels   of   acquired
methemoglobinemia from nitrate intake on human growth, development,
and general health have not been studied.  Concern exists because
of the decreased  oxygen carrying capacity of the blood resulting
from increases in methemoglobin.  Studies of  people with hereditary
methemoglobinemia  may  provide  a  model.    Adults  with  chronic
methemoglobin concentrations in the blood of 10 to 25 percent seem
to have no adverse health effects other than a bluish skin color.
 Pregnancy is usually uncomplicated and life
expectancy is not decreased  (Jaffe, 1981).

Carcinogenic Effects

     Nitrates and nitrites themselves  have not yet been classified
as to human carcinogenicity,  but EPA  is  currently evaluating the
classification.  Nitrate alone does not appear to be a carcinogen,
but when nitrate is reduced to nitrite in  the  body or when nitrite
is ingested directly, it can combine with nitrosatable substrates
(secondary amines, amides, carbamates) in the body to form
N-nitroso compounds, such as nitrosamines. N-nitroso compounds are
classified as probable human carcinogens.  Inhalation of nitrogen
oxides have  also been  implicated  in   the formation  of N-nitroso

                                28

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                       * DRAFT  (3/5/91) *

compounds in the body  (US EPA,  1982, Air Quality Criteria).

     Several  substances,  such  as  vitamins  C  and E  and several
phenols, can  inhibit the  formation of N-nitroso compounds in the
body.   Vitamin C acts by reducing  nitrate to  nitrogen or nitric
acid (Mirvish, 1983).   Therefore the absolute amount of nitrate in
vegetables  and other  sources  is not  as  important as  the ratio
between  ingested nitrate  or nitrite  and  the inhibitors  (Forman,
1988) .    The  amount   of  vitamin  C  or  E  needed to block  the
nitrosamine compound formation  is not known.

     Many  studies  have  investigated the  relationship  between
nitrate intake and cancer.  The epidemiological evidence implicates
nitrate  in  stomach and  esophageal  cancer,  but the  studies  are
generally flawed because of the  lack of specific  information on the
history  of  exposure to nitrate, nitrite,  and N-nitroso compounds
for the individuals who developed cancer.   Confounding  factors such
as the  role of  salts  in  the diet and socio-economic status  are
often not controlled for as well.  Although no definite association
has been proven,  the studies do tend to  lend support to the idea
that nitrate  and nitrite  ingestion  is higher  in countries where
gastric  cancer is more prevalent  (NAS,  1981).    Several studies
conducted in Great Britain, however,  showed no association between
nitrate  intake and cancer (Al  Dabbagh, et  al.,  1986, Forman,  et
al., 1985).   The National  Cancer Institute  is currently conducting
an epidemiological study on farmers in Nebraska to investigate the
carcinogenic potential of nitrate.

                       Pathways of  Exposure

Individual Exposure

Nitrate

     Humans are exposed to nitrate from a variety of sources: foods
(including water, fruits,  juices, cured meats,  baked goods, fresh
meats,  milk  products),  water,  and  air.   Figure   2a  presents
estimates of  the average  per capita exposure to  nitrates in  the
United States.   For the average person,  vegetables are  the only
significant source  of  exposure.   For non-vegetarians  however,  if
nitrate in drinking water equals the drinking water standard, water
becomes the major  (54%) source of exposure.

     Since infants under three months generally exclusively ingest
liquids, virtually the only source of exposure to nitrate in this
subpopulation  is  drinking  water.    Water can be  added   to
concentrated or powdered formula or it can  supplement feedings from
breast milk or prepared formula.  Breast milk does not  appear to be
a source of nitrate for infants (Shuval and Gruener,  1977).
                                29

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     Nitrosatable substrates  are  present  in many types of foods;
fish, poultry, meat,  dairy,  and grain.   They are also present in
some agricultural pesticides  like aldicarb, carbofuran, carbaryl;
more than 30 drugs; and many  cosmetics.

     Among vegetables, beets, lettuce, spinach, celery, radishes,
and turnip greens are especially high in nitrate.  Carrots readily
accumulate nitrate.   Many  factors affect  the level of nitrate in
vegetables.   The three most  important variables seem  to  be the
genotype, amount of nitrogen fertilizer applied, and light.  Higher
rates of nitrogen  fertilizer application can  also decrease the
vitamin C content of vegetables (Hornick, 1988).

     Researchers have also suggested that nitrate may be produced
in mammals since some  studies  show that humans excrete more nitrate
than they  ingest (NAS, 1981).   Packer  (1989)  demonstrated that
subjects excrete between 4 and 5 milligrams of nitrate per day or
about 20 percent of average nitrate intake in the United States.

Nitrite

     Nitrite (generally as sodium nitrite) is added to cured meat
products to control pathogens, inhibit spoilage, and contribute to
their flavor and color. FDA  limits  the amount of nitrite added to
all cured meats and prohibits the  addition of  nitrate.  Since 1978
vitamin C,  in the form of sodium ascorbate, has been  added to bacon
to inhibit nitrosamine formation.  Nitrite is  also found naturally
in some  foods.   Figure 2b presents estimates of  the average per
capita nitrite exposure in the United States.  The great majority
of  average nitrite exposure  comes from  reduction of  ingested
nitrate to nitrite.  However,  for  individuals  whose  drinking water
contains 1 mg/L  nitrite  (the  drinking water standard),  the water
would represent the major source of nitrite exposure.
                     Drinking Water Exposure
Public Water Systems
     Through the Safe Drinking Water Act (SDWA),  EPA has regulatory
authority over water systems that have at least 15 connections or
serve 25  or more individuals year  round.   These are  defined as
public water systems since they serve the public, but they can be
publicly  or privately owned.   Under SDWA regulations,  EPA sets
unenforceable maximum contaminant level goals (MCLG) for drinking
water contaminants at "the level at which no known or anticipated
adverse effects on the health of person occur and which allows an
adequate margin of safety" [SDWA § 1412  (b)(4)].  US EPA then sets
an enforceable Maximum Contaminant Level (MCL)  as close to the MCLG
as feasible, taking cost into account [SDWA § 1412  (b)(5)].  Public

                                31

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water  systems  must ensure  that  the water  they supply  does not
violate the MCLs.

     EPA has set the   MCLG  for nitrate at 10 mg/L to protect the
public from the acute effects of methemoglobinemia.   The MCL is set
at the same level since  water treatment can  remove  nitrate and
nitrite to  levels below the MCLG.   The MCLG is based on a public
health survey  that showed no  clinical  cases of methemoglobinemia
(no observable adverse effect level  or NOAEL) when  the nitrate
level  in drinking  water  was at 10  mg/L or  below  (Walton, 1951) .
Although 80 percent  of  the  cases occurred  when  the water was
contaminated with over 50 mg/L nitrate, 2.3 percent of the cases
were  associated with  nitrate  levels  just  above  the  MCL (11-20
mg/L).

     The World Health Organization and  the European Community (EC)
have set a  standard for nitrate similar to the MCL.  However, the
EC standard for nitrite is  set at one-tenth the MCL.   The EC has
set a recommended level or guide level at half the standard.   Two
West  German   surveys  found  that  about  four  percent  of  the
methemoglobinemia cases occurred  when the drinking water was below
10 mg/L (Simon, 1964).  However, the bacteriological contamination
of the water source and nitrate intake from food was  a known factor
in two of those cases.  There  is no uncertainty factor below the
NOAEL.

     An MCLG and MCL has  been  set for  nitrite at  1 mg/L using an
uncertainty factor of ten from the nitrate level, since nitrite is
the toxic agent of concern.  Nitrite  rarely  occurs naturally in
water.   When  it  is  found, it is  usually  because the  water is
already highly contaminated by bacteria. A combined nitrate/nitrite
level has also been set at 10 mg/L.

     All public water systems  (PWSs) must report violations of the
MCLs to the state  or EPA.  These  violations  are compiled in the
Federal Reporting  Data System (FRDS).   According  to  FRDS,  from
October 1987 to April 1990, 280 community water systems  were out of
compliance  with the nitrate MCL.   (See Figure 3.)   Based on this
data,   about 1.1 million  people were exposed  to excess levels of
nitrate in public water systems.  92 percent of these systems serve
very small  populations (under 3,300) and rely on ground water for
their supply.  However, over half of the total population exposed
to  nitrate  contamination  in  public  systems  use   surface water
supplies.   The majority  of  the violations  are  between 11 and 20
mg/L.   Ten  systems had levels  of more  than 25 mg/L.  The highest
concentration recorded was 380 mg/L.

     The FRDS  data probably represent  a minimum number of people
served by public water systems exposed  to nitrate levels above the
MCL.  GAO (1990) , in an investigation of SDWA implementation, found

                               33

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Zthat the number of violations is considerably understated due to
sampling  error  by  water  system  operators,  some  intentional
falsification of data, and  identified  violations not reported to
EPA.   US EPA Regions 2 (NY, NJ, Puerto Rico)  and  (UT, CO, WY, ND,
SD, MT) reported no violations of the nitrate MCL.  A 1985 survey
of states by the American Well Water Association reported a total
of 38 violations in states served by Region 8. USDA estimates that
31  million people  rely on ground  water PWSs  in  regions  with
potential for contamination (Nielsen and Lee, 1987).  In a report
prepared for US  EPA's Office of Drinking Water (Wade, Miller Assc.,
1990), a model  developed based on  previous water supply surveys,
estimated the actual number of people exposed to nitrate above the
MCL through public water supplies at 1.7 million.

     In  order  to  develop  a  statistically  reliable  national
assessment  of  the  frequency  and  concentration  of  agricultural
chemicals in wells, EPA sponsored the National Survey of Pesticides
in Drinking Water  Wells  (US EPA, 1990).   The survey tested 1350
statistically selected  wells  (700  private,  650 public)  for 127
analytes,  including  pesticide degradates, nitrate,  and nitrite.

     As  expected,  since nitrate can  occur  naturally  in ground
water, nitrate  was by far  the contaminant most commonly found in
the  Survey.   52.1 percent  of community water  system  wells were
estimated to contain detectable levels  of  nitrate  (over  .15 mg/L).
1.2 percent or  1,130 systems nationally were estimated to contain
nitrate  levels  above the MCL.   No  information was  available on
wells  containing between 3 mg/L (background level) and  10 mg/L
(MCL), or the actual population exposed. The  maximum concentration
found was 13 mg/L.

Domestic Water  Supplies

     It  is difficult to  estimate the number  of people exposed to
nitrate  contamination  through  the  10.5  million private wells.
There are no federal or state programs which regulate most domestic
wells  or  require  regular  testing.   The   National  Survey  of
Pesticides in Drinking Water Wells (USEPA,  1990)  provided the first
national estimate of nitrate levels in private wells.  The Survey
estimated that 57 percent of the private wells in the United States
contain  nitrate.   2.4 percent or 254,000  wells were estimated to
contain  levels  above the MCL.  Again, population numbers were not
estimated.   It is not yet possible to compare  the nitrate levels in
the  11.7 percent of private  wells located  on  farms  to non-farm
private wells from the survey results.

     Holden  and  Graham   (1990)   provide  another  large-scale
statistical survey  of  rural wells  in  areas  where the pesticide,
alachlor is used (principally the  Mid-West).  Approximately five
percent of shallow rural  wells have nitrate levels that exceed the

                               35

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                       * DRAFT  (3/5/91) *

MCL.   The  percentage doubled  for  wells on  farms.    Another 19
percent have levels that are less than 10 mg/L, but greater than 3
mg/L, probably  showing anthropogenic influence.  The  results of
both  surveys are  a  one  time  picture of  contamination.    USDA
estimates that 19 million people who rely on private wells are in
areas with potential for ground water contamination.  (Nielson and
Lee, 1987)

     A  survey of  readily  available  local,  state,   and regional
nitrate  data  (Hallberg,   1989)  confirmed  the  results  of  the
statistically based survey  of  Holden and Graham.   The monitoring
reports  from these other  areas are  generally  not  statistically
based and  are often biased toward agricultural areas.   They are
often  designed  to  investigate  vulnerable  or  known  areas  of
contamination.     Several   states   have   done  more   thorough
investigations.  Statewide,  Iowa estimates 18 percent of the rural
domestic wells violated the MCL; Nebraska, 17.5%; Kansas, 28% (farm
wells); and  California,  10%.   Probably a minimum of two million
people are exposed to nitrates  over the MCL through domestic water
supplies.

Ground Water

     It is  difficult  to  predict the number of people  who  may be
exposed to high nitrate levels  in the future.  Most studies sample
drinking water wells rather than monitoring wells in fields or from
deep aquifers.   Therefore  no real assessment of ground water in
general  is  available from which to make predictions.   However,
because of the chemical stability of nitrate,  soil  storage, slow
infiltration rates, and complex ground water flow paths that have
the capacity to retard a plume of nitrate, it is likely that future
levels of nitrate in ground water will continue to rise regardless
of  proactive measures taken to limit nitrate  contribution from
various sources  (Keeney,  1986).  Depending on the soil type and
other factors, nitrate can take decades to reach ground water.

     The United States Geological Survey  (USGS) has collected over
87,000 nitrate samples in a data base known as WATSTORE (National
Water-Date Storage  and Retrieval System).   These data have been
collected  from  myriad special  projects  and public  water  system
analyses  over the  past  25 years.   While these  numbers  do not
represent a national sample historically or regionally because of
the variety  of  methods and reasons  for  collection,  they do show
that many  areas of the  country have nitrate levels elevated by
human  activities  (Madison  and Brunett,  1985).     Ground  water
sampling generally show higher  nitrate concentrations from shallow
wells.  The levels tend to  decrease with  increasing depth.  Figure
4 shows the map Madison and Brunett produce based on WATSTORE.
                                36

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                                                37

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                       * DRAFT (3/5/91) *

Ground and Surface Water Interconnection

     Nitrate contamination of ground water is not only a drinking
water concern.  An intimate association exists between ground and
surface waters, such that ecological concerns exist as well.  The
interconnection between ground and surface waters also complicates
nitrate concentration analysis.  Much of the stream flow in humid
regions  (75-90%)   may  be  ground-water  discharge,  rather  than
collected  surface  run-off.    Ground  water  has been  found  to
contribute more than  85  percent  of the nitrogen load to Buzzards
Bay, Massachusetts  (EPA  and MA Executive Office of Environmental
Affairs, 1990).   In arid glacial or karst regions,  surface water
may recharge ground water.  Consequently,  nitrate contamination can
be  recycled  through  the entire  hydrologic  system.   Contaminated
ground water may  contaminate  and be diluted  by surface water or
vice versa.   Thus, ground-surface water interaction  can  be both
beneficial and harmful.   The slow movement of ground water can make
it  a reservoir  for  nitrates  that  can  continue to  contaminate
surface water for years after  other sources  of nutrients have been
controlled.
                  Economic Risks to Agriculture
Animal Production
     Ruminant animals, such as  cows  and  sheep,  along with infant
pigs  and chickens  are susceptible  to  nitrate/nitrite  toxicity
(Keeney, 1986; Hansen et al. , 1987; Shirley,  1975; Young and Mancl,
n.d.).  Generally concentrations of nitrate  in drinking water less
than  100 mg/L  are  safe  for  cattle.    The  symptoms for  acute
nitrate/nitrite  toxicity  include:    asphyxiation  and  labored
breathing, rapid pulse, frothing at  the  mouth,  convulsions,  blue
muzzle and blue eye tint,  and  chocolate brown colored blood.  (SCS
lit search).   in pregnant cows, the oxygen supply to the fetus will
be adversely affected after nitrate intake, especially by the lower
oxygen transfer through the placenta.   When  the oxygen transfer to
the  fetal  blood decreases  too  sharply,   intra-uterine death and
ultimately  abortion  may  result.   Nitrate  toxicity  has  been
associated  with  symptoms  of  poor  growth, fertility  problems,
abortions, and general poor health (SCS,  1989).

     Livestock may  also  develop symptoms of nitrate toxicity by
eating fodder containing high nitrate  levels.   Feed may  be toxic
especially when harvested after a drought.

                         Welfare Effects

     High nitrate levels in ground and surface  water can lead to
adverse  effects  in  areas  other than human  health  or ecosystems.
Nitrate  contamination  can   cost  individuals   and  communities

                                38

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                       * DRAFT (3/5/91) *

significant amounts of money because of the costs of such factors
as  well  relocation  or  deepening,  drinking  water  treatment,
development of  alternative water  supplies,  denial of  loans for
houses  or businesses,  reduced tax  base,  and  the need  for the
development of land use restrictions (Anton, 1988).  Nitrate levels
above the MCL were the major cause of the closure of public wells
identified in a  1985  survey  conducted  by the American Well Water
Association.  In California,  nitrate contamination has caused the
abandonment of more drinking water wells than any other chemical.
In  1986  alone,  the  California  Department  of Health  received
requests from public water systems for $48.7 million dollars (far
in  excess of available funds)  for the  remediation of  nitrate
contamination.  The Department assumed that many other systems were
in need of funds, but did not bother to apply (Anton,  1988).

     It is impossible to estimate how many private drinking water
wells might have been abandoned throughout  the country as a result
of high nitrate  levels.   One  investigation  of  the Columbia aquifer
on the Delmarva  Peninsula in Maryland stated simply  that many wells
in the shallowest and most  productive part  of  the aquifer had been
abandoned because of the nitrate  levels (USGS, 1984) .  The aquifer
is the most heavily used water source in the area.

     Increases  in  algal  growth and blooms  can  create conditions
highly  unfavorable  to  recreation  in surface  waters,  thereby
decreasing tourism.
                                39

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                       * DRAFT (3/5/91) *

                 SOURCES  OF NITROGENOUS COMPOUNDS


     A wide range of sources of nitrogenous compounds circulate in
the environment  as  a result of both natural  processes  and human
activity.  It is difficult to evaluate the relative importance of
the diverse sources of nitrogenous compounds in regard to threats
to human health or  the  health of  ecosystems because  it varies
greatly from place to place according to many complex biological,
chemical, and physical processes or  attributes.  Local land use is
also a key factor in this evaluation.

     On a national scale, mineralization of organic nitrogen in the
soil represents the largest natural source of nitrate to the soil
system.  Commercial  fertilizer is the largest anthropogenic source
(White,  1989) .   However,  sources  that rank high  in terms of the
magnitude of their contribution on a national scale, may cause no
adverse impacts in many areas of the country.  Conversely, sources
that are  considered relatively  minor  nationally,  such  as septic
systems or feedlots, can cause severe local impacts.  In order to
implement effective policies that reduce nitrogen loadings, it is
necessary to evaluate all sources that may be causing area specific
air or water quality problems.

     This section will describe  the sources  of  contamination by
nitrogenous compounds in  the environment, concentrating on sources
that are most subject to policy manipulation.

Nitrogen Cycle

     In order to assess the relative impacts of human activity on
surface  and  ground  water  it is necessary  to first  examine the
natural processes by which nitrogen is converted into its various
molecular  forms and  transported  through  and between  different
media.   This  dynamic,  complex  process  is referred  to  as the
nitrogen  cycle.    Figure  5 shows  a  simplified  version  of the
nitrogen cycle.  It identifies the physical processes involved in
the creation and destruction of the many forms of nitrogen.

     Nitrogenous  compounds are transformed as  they continually
cycle between soil,  water, air, plants, and animals.  Anthropogenic
activity can add nitrogen to each component  of the cycle, however,
these compounds will be formed to some extent irrespective of human
intervention.

     Nitrogen is  naturally found  in soils  in  three major forms:
organic nitrogen, ammonium nitrogen, and soluble inorganic ammonium
and  nitrate  compounds.    Organic   and  ammonium  nitrogen,  which
represent about 98 percent of all soil nitrogen, are bound to the
surfaces of soil minerals and organic matter.  They  can be carried

                               40

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                                     Figure^  s
                              The Nitrogen Cycle
                                    (Ml.... fr.m  I     I NOT  NO.' I
                                    ••«•»* f*n») I     | "*a  ^Z*J
                                            —'    - jf
Not*: Deoths oi soil and atmospheric zones are not rendered to scale    Source:

                                         41

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                       * DRAFT (3/5/91) *

to surface water by erosion of the soil.   Nitrate is soluble and
not absorbed by the soil,  therefore,  it is available for transport
to ground and surface water whenever water moves.

     One to five percent of the organic nitrogen annually converts
to  soluble  forms  (White,  1989).    This  process  is  known  as
mineralization.     During   mineralization  organic   nitrogen  is
converted to ammonium, ammonium to nitrite,  and nitrite finally to
nitrate  (the  soluble stable  form of  nitrogen).   Mineralization
rates can vary  significantly  from region to  region  depending on
climate and carbon content of the soil.

     Once the plant  root  zone  becomes saturated (as may  occur
during storm  events or through  irrigation),  some water  will be
pulled, by gravity, into the unsaturated zone where water and air
share the space between soil particles. Water then moves into the
saturated zone or  ground water table where  all  space between the
particles is  filled with water.   Geology and topology aside, the
rate at which nitrate  moves through the soil  depends on the rate of
ground-water recharge, which is a  function of rainfall, irrigation
rates, and the permeability of the soil.

     Nitrogen  is added to  soils by  human  activity  and  natural
processes which include:  commercial  fertilizers, green and animal
manures,   sewage,  crop  residues, nitrogen fixation by  legume
bacteria, fixation by other  types  of plants and  organisms, and
atmospheric deposition  (wet or dry).   Soils lose  nitrogen via:
plant  uptake,   denitrification  (transformation of  nitrate  to
nitrogen gases), drainage, and erosion  (Buckman and Brady, 1969).
This entire process is dynamic.  Nitrate levels will generally vary
by temperature,  organic content  of  the soil, season,  and  year.
Monitoring  to determine  nitrate  content in  various media will
necessarily artificially freeze the cycle and provide only a "snap-
shot" of nitrate levels at that particular point in time.

Nitrate Mass Balance

     To more accurately assess the amount of nitrate  available to
potentially contaminate ground or  surface water in a specific  area,
mathematical models are used  to predict a  mass  balance.   A mass
balance requires that the  nitrate mass be inventoried to account
for the amount of nitrate that is applied on or near  the surface,
added  through   aerial   deposition,    created  or  destroyed  in
environmental media, and stored in soils and aquifers.

     The predictive capability of mass-balance models is hampered
by three main factors.   First, we do not have adequate monitoring
data to determine  the current concentration of nitrate in ground
water.    The statistically based  monitoring data   on  domestic
drinking water wells comes predominantly from shallow,  rural wells.

                                42

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                       * DRAFT  (3/5/91) *

These data can  not  be  used to give an accurate picture of ground
water contamination in general.  Second, the  rates of creation and
destruction of  nitrate is  not fully understood.  Denitrification
may be very important  to predicting the amount of nitrate that is
likely to  remain in an  aquifer or estuary,  but  little is known
about the quantitative relationships in this process in ground or
surface waters  (Hallberg, 1989; US EPA, 1990).  Finally, estimates
are needed for  the amount of nitrate stored in of different soils
and the rate of  nitrate movement from soil  storage to ground water.
Several studies estimate that 30 to 60 percent of nitrate applied
to the soil  in  the form of fertilizers remains  in  the soil from
year to year depending  on crop uptake and percolation rates (White,
1989; Bundy and Maione, 1988).

Natural Background Levels

     A mass balance model must take into account background levels
in  ground water as  a  result of  natural  processes.    Nitrate
concentrations  less than three parts per million (ppm) are commonly
accepted as being representative  of natural  conditions in ground
water (Madison  and Brunett, 1985).  However,  the range of natural
levels can vary widely, especially for ground water basins in the
western United  States  with internal drainage.  An area in Nevada,
for example,  has ground water with naturally  occurring nitrate
concentrations  in excess of 300 mg/L.   Parts  of some estuaries are
naturally eutrophic. A mass balance would  be  necessary to identify
where this condition was not influenced by human inputs.

     It  is  generally  the  case that widespread  contamination of
ground water at  levels  above the MCL is the result of anthropogenic
influences upon the  environment.  However,  natural soil nitrate was
identified as a major  source of nitrate  in  the  ground waters of
Runnels County,  Texas  (Kreitler and Jones, 1975).

Use of Isotopes to Identify sources

     Several researchers have  attempted to use the  ratio between
the two stable isotopes of  nitrogen to  determine the origin of the
nitrate found in ground  water.   The ratio of UN  to  15N indicates
whether organic sources such as animal wastes or vegetable matter
are present.    Manufactured  fertilizers  produce  an isotope  mix
similar to that  found in the atmosphere. Organic sources alter the
mix of the two  isotopes.

     After  reviewing   the  studies using  this technique,  Keeney
(1986) concluded  that the  isotope ratio  test  can  only  be used
reliably in relatively simple systems where there are only one or
two sources and little denitrification occurs.  Its usefulness is
limited to areas where  the  outcome  is already fairly obvious based
on land use  and agricultural systems, or  where  sources could be

                                43

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                       * DRAFT (3/5/91) *

determined a lot more cheaply by talking to extension agronomists
or fertilizer dealers.

                       AGRICULTURAL SOURCES

     Nitrogen  is  a vital  component  in  the  growth of  plants.
Farmers, therefore, seek to augment available nitrogen in the soil
to increase  crop yields.   When  the prairies  were  plowed under,
large quantities of nitrogen were released which provided nutrients
for the crops.  Commercial  fertilizers primarily, but also animal
manure,  green   manures,   sludge   from   waste  water  treatment
facilities, and food processing wastes are all added to croplands
to increase yields.  Legumes,  such as alfalfa or clover, are grown
for forage and to add nitrogen to the soil because of their ability
to convert atmospheric nitrogen  into ammonia.   Animal production
including  the   increase   in  concentrated   feedlots,   poultry
operations, and  dairy farms  are  all important  sources  in local
areas.

     Although many sources of  agricultural nitrogen nationally are
quantified in this  section,  it does not mean that  all this nitrogen
is available  to contaminate ground  and  surface water.   It does
however indicate which sources could cause problems.   Much of the
applied nitrogen is taken up by plants,  volatilized, immobilized in
the soil,  or denitrified.  Sources of excess nitrogen  in a specific
area must be defined by mass balance.

                      Commercial Fertilizer

     Commercial fertilizer, without other sources of nitrogen and
even when applied  parsimoniously,  can  contribute to ground water
contamination in particularly vulnerable geographic settings (i.e.,
combinations of course textured soils,  with  fractured karst, above
surficial aquifers, with high recharge rates).  In other settings
where  fertilizer   is  the  only   source  of   nitrogen,   nitrate
contamination tends to be  associated  with application  rates in
excess  of agronomically  optimum  rates.    This  occurs   for  the
following  reasons:   research  has  not   identified  the  optimum
application rate,  farmers do  not  give  adequate credits for other
sources  of nitrogen,  or  they  simply do  not  follow the  best
available recommendations (Hallberg, 1987; Keeney, 1986; University
of Nebraska, 1990) .   A survey of nitrogen  use in  the Big Spring
Basin  in  Iowa,  indicated  that  farmers  were  not  correcting
fertilizer application rates  for alfalfa and  animal  manure.   On
average they  were  using  80  Ibs  per  acre  more than was needed
(Keeney, 1986).   Fall application of fertilizer (or animal  manure)
to bare soil  (not accompanying a fall crop), although increasingly
less common,  still  occurs and  is a particular problem for adjacent
surface waters.
                                44

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                       * DRAFT (3/5/91) *

     Fertilizer use  has  been implicated in  the contamination of
ground and  surface waters in many different studies.   Continual
nitrate increases in Iowa surface and ground waters since 1950 is
attributed  primarily  to  nitrogen   fertilizers  (McDonald  and
Splinter, 1982).   High nitrate contamination of ground water on
Long Island are attributed to septage and over-use of fertilizer on
potatoes  (Keeney,   1986,  p.278).    Studies  of  various Illinois
watersheds  cite fertilizer use  as the  major source  of nitrate
contamination (Keeney,  1986).  Cantor (1987) surveyed literature on
nitrate contamination from fertilizer application and reported on
studies from 14 states that identified fertilizer as the source of
nitrate in ground water study area (New York,  California, Nebraska,
Ohio,  Connecticut,  Minnesota,   North  Carolina,  Iowa,  Texas,
Delaware, Arizona, Missouri, Washington, and Wisconsin).

National Usage

       The nitrogen in commercial  fertilizer  (fertilizer nitrogen)
generally takes the form of ammonia,  ammonium  salts  of sulfate,
nitrate,  or urea  (an  organic compound) .   The  most  widely used
formulations  of  nitrogen  fertilizer  are  nitrogen   solutions,
anhydrous ammonia, urea,  and  ammonium nitrate with 8.3, 5.4, 2.7
and 2.2 million tons, respectively, sold annually (Vroomen, 1987).
The nitrogen content of these fertilizers ranges by weight from 82%
for anhydrous ammonia to  16%  for  sodium nitrate.   Regardless of
how it  is  applied,  if the nitrogen is to be usable  by plants it
must eventually exist as ammonium or nitrate.

     Nationally, about 10.5 million tons a year, or 95 percent of
total fertilizer nitrogen,  are used in agriculture.   Sales have
increased dramatically from the three million tons applied in 1960
(see Figure 6) .  The  top 10 states in  quantities  of fertilizer used
are:    Iowa,  Illinois,  Nebraska, Texas,  Missouri,  California,
Kansas,  Indiana,  Ohio,  and  North Dakota, in that order.   They
account for over 58 percent over the nation's fertilizer N usage,
largely because of their extensive acreages of corn,  sorghum, and
wheat (Vroomen, 1989).

Application Rates

     Application rates on various crops are an indicator of where
commercial   fertilizer   might  be   an   important    source   of
contamination.  Corn has the highest application rates  of any field
crop, on  the  order of 140  Ibs/acre  nationally,  almost twice the
rate  used on  the  next  most intensive  field crops,  cotton and
sorghum (Figure 8).  About 38 percent of all fertilizer N sold is
used on corn (Figure 9).  Intensity of use may be correlated with
precipitation—application rates per acre for a  given crop tend to
be higher in regions receiving higher mean levels of rainfall.  For
example, the application rate on corn in Indiana  is 162 Ibs/acre

                                45

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                         Figure 8
  Estimated Consumption of Nitrogen, Selected Crops
    Total 1986 U.S. consumption = 10.4 million tons N
140
                         Figure $ &
      Nitrogen Application Rates, Selected Crops
        67
70
73
76
79
 82     85     88

Source: Vroomen, 1989
                            47

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                       * DRAFT (3/5/91) *

compared to 66 Ibs/acre in South Dakota.  See Appendix E for mean
application rates and percentages  of total N  use in  the major
producing states on several major field crops.

     High value specialty crops,  such as fruits,  vegetables, and
ornamentals, involve only a  fraction  of the acreage of the field
crops, but  they generally employ higher rates of  N  because the
incremental gain in value of the crop offsets the cost  of the extra
fertilizer.  Furthermore, because,  as in the case of vegetables,
they require high levels of nitrogen at the stage of full growth to
achieve satisfactory yield and quality,  excess nitrogen  remains in
the soil at harvest (Schweiger, 1987).  In addition, vegetables can
leave behind high nitrogen-containing plant residues  (AGRA-EUROPE
37/88, 1988).

     Despite their high nitrogen requirement, certain horticultural
crops, such as potatoes, are shallow-rooted and may not efficiently
use  fertilizer once  it  starts  downward in  the  soil profile.
Furthermore, they may require coarse-textured, relatively permeable
soils which permit greater leaching (Saffigna,  1977).

     California and Florida agriculture account for a large share
of the  total  horticultural production  in the  country.  In 1987,
California had 774,553  acres  in vegetable production and 2,152,664
acres  in  orchards.   Florida had  265,331 and 762,068  acres
respectively (U.S.  Census of  Agriculture,  1987).   As much as 600
Ibs  N per  acres  are  applied to ornamental  ferns.    Florida's
Cooperative Extension Service recommends between  200  and 280 Ibs
N/acre for  turfgrass,  depending on  species, 200  Ibs  N/acre for
celery, 160 Ibs N/acre for tomato and pepper,  150 Ibs N/acre for
Irish potato,  and  120  Ibs N/acre  for muskmelon, watermelon, head
cabbage, sweet corn, strawberry and  onion,  etc.  (IFAS, July 1989) .
In California,  potatoes receive  225  Ibs N/acre,  dates 200 Ibs.,
broccoli 238  Ibs., celery 315  Ibs.,  head-lettuce  204  Ibs.,  and
spinach 199 Ibs.  Tomatoes, California's largest specialty crop in
terms of acreage,  receives 128 Ibs N/ac. (Carmen and Heaton, 1977).
These are recommendations per crop season.   Thus,  if several crops
are grown  in  succession,  as   is commonly  the case in Florida and
southern California, total application per acre for the year will
be considerably higher.  High rainfall and specialization in these
horticultural crops cause Florida to have the highest consumption
of N per harvested acre of all states.   California  is sixth highest
state nationally in total nitrogen fertilizer usage.

     Corn appears  to be  much more of a  problem than other field
crops.  In order to get a general  idea of how much of the nitrogen
applied as fertilizer may be  ultimately available  for leaching and
run-off into water, one can subtract the N-content  of the harvested
crop from  the  amount applied.  Nationally fertilizer applied to
corn (5.1 million tons) is 1.7 million tons greater than  the amount

                               48

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                       * DRAFT  (3/5/91) *

of N  contained in grain  corn  (3.4 million  tons)  (White, 1989).
This  figure is  somewhat  of  an overestimate  since it  fails to
account for denitrification and the harvest of corn for silage.

     Much less residual nitrogen appears to come from other field
crops.  For example,  farmers applied 1.5 million tons of fertilizer
N on  wheat and the  harvested grain contained 1.2  million tons.
Thus, the applied tonnage of  fertilizer N to wheat was 25 percent
greater  than the  N  content  of  the  resulting  crop,  while  the
corresponding margin for corn was 50  percent  (White, 1989).  While
these numbers  do not  imply  that  all  the remaining nitrogen is
available  for  leaching,  they give an indication of which crops
could have the greatest potential  for  leaching.

Potential Hotspots for Fertilizer  Use

     Figure 10 differentiates  counties across the country according
to county-wide estimates of the  intensity of commercial fertilizer
applications to cropland.   These data  were generated by dividing
county-level fertilizer nitrogen sales figures for  1987  (US EPA
County-level Fertilizer  Sales  Database,  1990)  by the  number of
acres which farmers reported to  have  fertilized in 1987 (US Census
of Agriculture, 1987).

     The  figure  shows,  in  light  shading,  counties in  which the
estimated average rate of  application  of  fertilizer nitrogen for
all crops was between 70 and 185 pounds per acre.  The lower bound
of  70  pounds  nitrogen  per acre  is the  amount  of  nitrogen
recommended for a relatively low wheat yield goal of  40 bushels per
acre (Livestock Waste Facilities Handbook,  1985).  The upper bound
of  185  pounds of  nitrogen per acre  is  the amount of  nitrogen
recommended for a  relatively high corn yield of  150 bushels per
acre.   As Figure  10 shows, wheat  producing  areas  in the western
U.S. receive a  relatively low  rate of application compared to other
major field crops and non-leguminous crops,  while  corn is be the
most nitrogen-intensive of the major field crops.

     Figure 10 identifies  fertilizer as a very large source of N in
Midwestern and Eastern areas  where analysis identified widespread
N pollution.  Livestock waste represents a much smaller source of
N in these areas.  However, cause and effect cannot be inferred, as
quantity  of  N applied to  the  land  represents  only part  of the
picture.  For example, N from livestock and septic systems may be
more directly available to enter ground and surface water.

irrigation

     Irrigation,  because  it  raises  the  recharge  rate  of ground
water, complicates the nutrient management  problem, particularly in
the West where irrigation water is re-used repeatedly and used to

                                49

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flush salts out of the soils.   The water flushes out the N  in the
soil.   In addition,  higher fertilizer application  rates  may be
correlated with irrigation.  Heavily irrigated cotton in California
uses  118 Ibs/acre  compared to 34  Ibs/acre  for cotton  in less
extensively  irrigated Oklahoma.    Irrigated  corn  in California
receives 192 Ibs/acre  (Carmen and Heaton, 1977).

     Specialty  crops are generally irrigated,  as  they are grown
primarily in the arid west or where rainfall  is often insufficient
for plant growth.  Even in Florida, they are  frequently irrigated.
Because of soil conditions and the unpredictability  of  rainfall in
the more humid areas, a significant amount of  nitrate  leaching is
probable  regardless  of   irrigation  practice  (Pratt,    1984).
According to Keeney, H[t]he high probability  of leaching, combined
with large  nitrogen inputs, makes irrigated agriculture  a major
potential source of nitrate to ground  water."  And,  in  fact, "[i]n
most cases [where high concentrations of nitrates in ground water
were  found  beneath  irrigated  agriculture]   a  close relationship
existed  between  the amount of  nitrate leached and  the amount of
fertilizer nitrogen used."   Fertilizer use in  irrigated  agriculture
has been identified as the chief source of nitrate contamination of
ground water  in the agricultural valleys of California,  central
Nebraska, eastern Colorado,  and in the sand plain region of central
Wisconsin (Keeney, 1986, p.280).

Chemigation

   Chemigation, or  as it is referred to with regard to nitrogen
fertilizer, fertigation, is the process of mixing irrigation water
with chemical  fertilizer.    This process can  cause  ground water
contamination through direct contamination  of wells  and  through
over-fertilization which results in nitrate leaching.

     Wells can be  contaminated through  Chemigation accidents.  If
the backflow  prevention device in  the irrigation  system  fails.
Water mixed with chemicals can flow back down  the well when pumping
stops.   Potentially  the  entire contents  of  fertilizer tank could
siphon back into the well,  losing as much as two tons of nitrogen.
In addition, because nitrogen  is relatively  inexpensive,  farmers
may over apply nitrogen in irrigation  water to  assure a high yield
response.   However,  there  is  a high  risk of over-application if
too much water is applied or if the water is applied after a rain.
A study of Chemigation in the Nebraska Sandhills showed that only
10% of the fertigation nitrogen was consumed by plants (Shearer, 19
).   In  some  instances though,  irrigation  may be  used to time
fertilizer applications more precisely so that fertilizer  to the
plants when it can be used most efficiently.
                                51

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                       * DRAFT (3/5/91) *

Drainage

    100 million acres of wetlands have been converted to cropland
by the installation of artificial drainage.  Subsurface tiles can
be installed  beneath  cropland and either  drain  the  excess water
into  ground water through  an agricultural  drainage well  or to
surface water through  a series of pipes.  Drainage to surface water
is by far  the most  common method.  In  the  Delmarva  Peninsula,
surface drainage is often employed.  Farmers allow excess water to
flow  across their fields  into ditches  that empty  into  surface
water.  Studies conducted in the San Joaguin Valley in California
found that drainage water from tiled lands  averaged 20 mg/1.  Some
areas had levels between 100 and 200 mg/1  (California,  1971).

     The likelihood of  nitrate contamination of ground  water is
lessened in areas where drainage water is diverted to surface water
bodies.  Nitrate and associated problems are not transformed, but
merely transferred.  Major  tile  drained  areas in Ohio, Illinois,
Indiana, and Iowa may show little nitrate  contamination  in analyses
of drinking water wells.  For example,  northwestern Ohio, which has
the most intensive  row crop  agriculture in the state, has the least
amount of  nitrate  contamination in private  drinking water wells
(Baker, 1990).

     Cropland  drained by agricultural  drainage wells  (ADW)  may
present  special  ground  water  quality problems  in areas  of the
country where  they are concentrated.   An ADW is usually a buried
collection  cistern  into  which subsurface  tiles  or  pipe networks
drain  water from  fields to an  aquifer.   The  wells  often have
surface inlets from the surrounding farm  land  or a nearby roadway.
In the west, irrigation return flow is  the principal waste disposed
through  ADWs.   A  report by the  EPA's  Ada,  Oklahoma  laboratory
(1990) states that ADWs facilitate ground water contamination since
they  inject contaminants,  i.e.  agricultural chemicals  and road
salt, directly into aquifers.

     A major study by  the Iowa  Department of Natural Resources and
the Department of  Agriculture and  Land  stewardship  is currently
underway to assess  the impact of ADWs on ground-water  quality.  The
state goal is to prevent  contamination of ground water from ADWs by
1995.   Baker,  et  al.   (1984)    found that  water entering ADWs
exceeded the nitrate MCL in 85% of the cases.  Concentrations were
generally 10-30 mg/L nitrate between runoff events when almost all
drainage to the ADWs was  from subsurface flow.   A ground-water
transport model predicted influence of the ADW within 1 1/4 miles.
The study  states  that there is "strong  evidence that  nitrate in
recharge to ADWs, not surface infiltration, is increasing nitrate
concentration in aquifers."  A large number of drinking  water wells
that have  rising  nitrate levels are  located  in areas  with ADWs.
Surface  infiltration was ruled  out in areas where the overburden

                                52

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                       * DRAFT  (3/5/91) *

was greater than 15 meters.  Since nitrate concentrations appear to
be very dependent on  crop type and fertilizer application rate,  the
current  Iowa  study  may  show  that  these  concentrations   are
overestimates.  The final results will not be available until 1994.

Timing

     While most  fertilizer nitrogen is applied  in the spring, a
significant  amount  is  applied in  the  fall  (28%  of  fertilizer
nitrogen is sold in the fall).   This is not a cause for  concern if
the fall application is  immediately followed by a fall planting,
e.g. winter  wheat.   However,  where there is a  fall  fertilizer
application  not  followed by planting  until spring,  there is an
increased  potential   for  loss  of  N—frozen  soils  and frequent
precipitation  will cause much  of  the  N to  run-off into  surface
water and leach into ground water.  Although the practice  appears
to be declining, as many as 16% of farmers  apply fertilizer in  the
fall, but do not plant until spring (USDA Objective Yield  Survey,
1988).   Table 	 shows total fertilizer sales broken out by spring
and  fall transactions,  by state   (sales  data  tabulated  by   the
Tennessee Valley Authority's National Fertilizer and Environmental
Research Center).

                         Livestock Waste

     In many regions  dominated  by  livestock agriculture, livestock
wastes pose the greatest threat to water quality.   Hallberg (1987)
asserts  that  even  if nationally all livestock  and poultry waste
could be recovered and applied  to  land, it  would represent  only 40
percent of nitrogen fertilizer  application. Because 50  percent of
manure  production is  deposited  diffusely by  cattle  and sheep
grazing on pasture and range (White, 1989), only the remaining 50
percent  that  is deposited  in  confined facilities  (about  20% of
fertilizer  N)  can  be manipulated (CAST,  1975;  White,  1989;
Hallberg, 1990).

       While the total production of manure nitrogen which can be
land applied  may  appear to be minor in  comparison to  fertilizer
nitrogen, the distribution of manure sources, both regionally  and
locally, can play  a  crucial role  in impairing water quality.   As
the following tables  indicate [TABLE 1A], animal production occurs
in all fifty states;  however several key states in the  Southeast,
Corn Belt,  and Southwest account  for  the  largest proportion of
total production, depending on the livestock type.
                                53

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                        * DRAFT (3/5/91)  *

                             TABLE 1A
         NUMBER OF ANIMALS IN INVENTORY IN 1987  (1,000'S)

AL
AK
AZ
AR
CA
CO
CT
DE
FL
6A
HI
ID
IL
IN
IA
KS
KY
LA
ME
MD
MA
MI
MN
MS
MO
MT
NE
NV
NH
NJ
NM
NY
NC
ND
OH
OK
OR
PA
RI
SC
SD
TN
TX
UT
VT
VA
WA
WY
WV
WI
BEEF
COWS
748.0
3.2
334.9
786.2
906.0
830.2
7.1
2.2
995.3
606.8
83.4
558.2
511.2
315.8
1,123.7
1,354.6
967.9
422.6
11.8
48.5
9.7
110.2
360.2
579.3
1,819.0
1,399.9
1,823.6
305.0
4.2
11.4
572.8
71.6
320.6
886.6
284.6
1,630.4
618.9
160.7
1.1
205.3
1,502.9
894.3
5,138.6
346.5
9.8
581.3
335.0
689.2
182.1
180.3
MILK
COWS
46.0
1.7
86.3
70.9
1,070.4
76.3
41.7
9.4
177.0
97.8
11.8
157.7
186.4
163.9
294.9
96.7
224.3
83.4
49.8
110.5
36.9
344.6
709.8
71.8
242.0
26.9
105.2
17.6
25.1
32.1
58.6
814.5
110.1
96.4
347.3
90.5
95.3
673.1
3.0
40.1
137.0
180.4
356.5
76.6
179.0
157.1
220.8
9.3
27.0
1.743.4
HOGS &
PIGS
353.1
0.6
135.4
452.9
150.9
258.7
5.4
49.7
156.1
1,060.4
47.6
76.9
5,643.0
4,372.3
12,983.1
1,516.9
838.5
51.9
9.0
197.2
25.8
1,227.1
4,236.5
179.1
2,582.0
200.7
3,944.2
16.5
5.0
32.0
44.2
99.6
2,547.1
294.4
2,059.2
187.4
86.3
919.8
4.7
352.4
1,750.2
774.5
527.9
33.6
5.1
345.1
59.2
28.4
30.8
1.312.8
SHEEP &
LAMBS
5.3
2.4
301.3
10.9
979.5
708.1
7.3
1.7
8.9
8.7
0.0
316.1
137.9
82.8
451.6
249.3
36.5
11.5
15.6
24.6
14.8
101.3
241.6
5.4
101.8
588.2
195.5
99.8
9.2
12.6
468.3
76.4
15.8
182.0
239.5
120.5
470.3
113.2
1.7
1.6
603.8
15.3
2,055.0
595.6
20.5
161.1
80.2
917.1
75.0
94.4
CHICKENS
3 MONTHS+
15,107.0
2.4
331.5
24,085.4
45,377.6
3,118.8
4,913.0
834.3
12,964.8
26,274.5
1,111.9
1,425.6
4,396.1
26,787.3
9,580.7
2,094.6
2,103.7
1,504.1
6,999.7
4,060.8
1,502.2
8,428.6
12,125.0
7,027.6
8,235.5
978.8
3,621.2
18.2
459.4
2,130.5
0.0
5,455.9
20,070.3
277.6
21,244.9
5,826.7
3,049.6
25,548.5
205.8
7,539.8
1,752.4
3,266.8
19,601.3
2,089.3
405.9
6,605.7
5,928.0
29.2
691.1
5.156.4
BROILERS
SOLD
564,583.5
4.1
NA
719,764.5
209,376.0
43.7
851.0
210,492.1
93,224.8
609,503.0
2,069.3
8.7
435.6
22,306.7
666.0
176.1
2,201.2
96,147.4
13,679.9
257,070.1
NA
702.4
27,356.2
276,652.3
40,991.2
84.7
911.0
0.5
NA
453.8
NA
1,713.6
408,721.1
52.7
8,967.7
89,704.4
14,244.4
106,382.3
58.7
60,295.2
237.8
75,974.5
226,038.1
7.8
5.2
142,971.8
36,068.9
9.5
29,226.9
10.761.7
US  31,652.6 10,084.7   52,271.1  11,037.5   372,245.7 4,361,198.3

                                54

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                       * DRAFT (3/5/91) *

     The type of animal raised is a very important consideration in
nutrient management.   For  example,  even though  nationally,  all
dairy cows produce more tons of  manure than all laying hens, the
number of pounds of nitrogen in one ton of dairy manure which can
be used as a fertilizer is  substantially less than that for laying
hens (see Table IB).   These differences imply that on a farm-level
basis,  substantially more  land  area  is  needed to  efficiently
utilize poultry litter than dairy manure.   Missouri classified
poultry litter and  disposal  as  its  major  ground  water quality
problem.  The number of birds produced in the state  is expected to
quadruple by 1995.

                            TABLE IB
PRODUCTION  OF  MANURE  AND  NITROGEN  PER  ANIMAL  AND  NATIONAL
PRODUCTION TOTALS (1987):
             MANURE  LBS N/
          DRY TONS/  ANIMAL
             ANIMAL
                        TOTAL
                      ANIMALS
ANIMAL
Dairy
Beef
Swine
Sheep
Layers
Broilers
  1.89     123     10,084,697
  0.77     61     31,652,593
  0.21     32     52,271,120
  0.18     16     11,059,397
0.0096    0.94    316,503,065
0.0065    0.78  4,361,975,630
     MANURE
      TOTAL
   DRY TONS

19,060,077
24,372,497
10,976,935
 1,990,691
 3,038,429
28,352,842
  NITROGEN
TOTAL TONS
  620,209
  965,404
  836,338
   88,475
  148,756
1,701,170
SOURCE: Gilbertson (1979) and 1987 Census of Agriculture.
     Farmers often view manure as a waste disposal problem rather
than a source of nutrients.   Their primary concern is disposing of
the manure as economically as possible, with less concern for the
impacts the manure can have  on ground  and surface water.  In these
cases, manure is spread on cropland simply to dispose of it.  As is
the case with fertilizer N, when manure is spread in excess of crop
nutrient  requirements (either  directly or  in  combination  with
fertilizers)  or when  the  ground is  frozen,  excess  nitrogen  is
likely to leach into ground water or runoff into surface water.

     Manure application generally presents more problems for the
farmer than  application  of  commercial fertilizers  for  two  main
reasons.   First,  the nitrogen content  of  manure  is  variable
depending on content  of the  feed, type of animal,  volatilization
and denitrification rates, and management practices employed, i.e.
type of storage,  whether or not manure is incorporated into the
soil.   Second,  it is  more difficult to handle, especially because
of the large volumes (particularly dairy and swine slurries) needed
to obtain the  same nitrogen content  as  fertilizers.   Therefore,
farmers often do  not  spread  their manure evenly across all their
                                55

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                       * DRAFT (3/5/91) *
fields. The  fields closest to the barnyard tend  to receive high
application  rates whereas more  distant  fields  may receive  no
manure.

     When  inadequate provisions  are  made for  manure disposal—
insufficient available land area to assimilate manure nutrients or
inappropriate storage facilities to retain manure during fall and
winter months—ground  and surface water  quality  impairments are
likely to result.

Concentrated Livestock Production

     The  trend  towards  larger  and  more  concentrated  feeding
operations will result in  "increased imbalances between nutrients
imported to feeding sites  and nutrients exported" (White, 1989).
Table 3C  provides some  indication of the extent  of large-scale
livestock production nationally.
                            TABLE 3C
  LARGE-SCALE LIVESTOCK (PERCENTAGE OF TOTAL PRODUCTION):
                                              1987
ANIMAL
  SIZE     NUMBER      PERCENT     PERCENT
CUTOFF     OF FARMS    OF FARMS    OF ANIMALS
            LARGER  THAN  LARGER  THAN LARGER THAN
           SIZE CUTOFF SIZE CUTOFF SIZE CUTOFF
Dairy
Beef
Hogs
Sheep
Layers
Broilers*
500
500
2,000
2,500
100,000
100,000
                          1268
                          4709
                          2809
                           685
                           561
                          1137
                          0.6%
                          0.6%
                          1.2%
                          0.7%
                          0.4%
                          4.1%
11.7%
14.6%
21.0%
34.2%
54.0%
24.3%
* Based on number of farms with sales of over 500,000; assumes
five groups of birds produced per year.

SOURCE: 1987 Census of Agriculture.


     EPA recently estimated that 28 counties across the U.S. have
animal per acre densities which are so great that even if all the
nitrogen needs  of the  most nutrient-demanding crop,  corn, were
supplied  totally  by  manure,  excess  levels  of  nitrogen  and
phosphorous would  be available for  environmental  degradation of
                                56

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                        * DRAFT  (3/5/91) *

water  resources  (see  Figure   II)4.    If  farmers  undertook  the
agronomic  practice of  supplying  half their  nitrogen needs  from
manure and half from commercial  fertilizer (to conserve phosphorous
and potassium), over 100 counties would meet this  criterion,  based
on manure production.   This preliminary analysis suggests that  not
enough land area is available for assimilating manure nutrients in
areas  of high livestock density.   Therefore, off-farm uses  of
manure must be considered.

     In large-scale animal feeding operations, the large amounts of
manure  produced can  lead to high nitrate  concentrations in  the
ground water under some conditions.  Where the feedlots are located
in  areas with  a deep water table,  the risk of contamination  is
minimized in the short term (Scalf et al.  1973 from  Patrick,  Ford,
and Quarles, 1987).

Animal Waste Storage  Ponds

     Currently, a debate exists over whether  animal waste lagoons
constructed to store manure so  it will not be applied in the  fall
or  winter are responsible  for nitrate  contamination  of ground
water.  According to a 1977  EPA study,  "heavy manure accumulations
may produce an impermeable  mat, which in turn produces anaerobic
conditions  that  favor  denitrification.     Thus   nitrate   is
volatilized, and little infiltration takes  place" (Patrick,  Ford
and Quarles,  1987).   However,  research regarding earthen storage
ponds  indicates that  these facilities can  leak under situations
associated with drawdown of manure  and  freeze/thaw cycles  (EPA,
Region 6, 1989).  Channels created by earthworms migrating through
the wetted perimeters  of earthen storage ponds may also be a source
of  leaching.    As  a  result of  these  concerns,  the  Wisconsin
Department of  Natural Resources worked with the Soil Conservation
Service  in  Wisconsin  to   modify   the   national  standard   and
specifications for earthen storage ponds in  the state  (Weinberg,
1990).    Revised  standards  and  specifications  have  also   been
developed in Texas and  Louisiana.

Abandoned Feedlots

     Active feedlots  and barnyards  are  not  a  major  source of
nitrate to regional ground  water  aquifers,  however, abandoned or
seasonally empty  feedlots  are  likely to  leach nitrates  (Keeney,
1986).  Other  researchers state that feedlots pose no danger  of
     4 The amount of total N  available  by acre was calculated by
dividing  the  total number of pounds of  nitrogen  available from
manure  by the  number of  harvested cropland  acres minus  those
cropland acres producing N-fixing crops.   This  figure was compared
to the N uptake per acre for corn.
                                57

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                         59

-------
                       * DRAFT  (3/5/91) *

ground water  contamination  in  the  southeastern states due to the
soil's ability to denitrify the  wastes (Miller, et  al., 1977).
Furhiman  and  Barton (1971)  linked ground  water contamination by
bacteria, viruses, and nitrate to poultry and hog farms in Arizona,
California, Nevada, and Utah (Patrick, Ford, and Quarles, 1987).

Nonpoint Source Surface Runoff From Fields

       Many manure-related impairments of surface and  ground water
originate from nonpoint sources.  For example, manure nutrients may
move  off  cropland  and  pastures  which  have  received  manure
applications   which  are   in   excess  of   crop/grass  nutrient
requirements.      Second,   even in   relatively small  livestock
operations, manure  runoff can  be  significant,  particularly where
livestock are free to trample and defecate in and along streams and
ponds  (Beyerle, 1990).   Third,  runoff from animal  loafing areas,
such as  those associated with dairy  operations, can  be damaging
because daily trampling  eliminates vegetative  cover  which would
otherwise take up manure nutrients or, more importantly, control
movement of runoff to surface waters.  Fourth, to the extent that
relatively  small  pastures  or  areas where  livestock  continually
congregate are unmanaged and overgrazed, manure will more readily
be available  as a water pollutant.

                    Legumes and Green Manures

     Some researchers (see Smith et al.,  1986; Huntington, et al.,
1985)  proposed that legumes, which  have the ability to convert
atmospheric nitrogen  to  a  form usable by  crops,  could minimize
nitrate leaching in comparison  with commercial fertilizers.  Green
manures  (crops grown  for  their nutrient  value and  then plowed
down) , similarly were hypothesized to have less leaching potential.
However,  evidence on the rate of nitrate leaching from legumes is
inconclusive  (Russelle and Hargrove, 1989) .  Legume cover crops can
provide significant fertilizer-N for subsequent crops,  but there is
no definitive data on the fate of legume-N.   Organic sources of
nitrogen such as animal manures or legumes can create significant
problems with nitrate leaching.

                    Greenhouses and Nurseries

     The  intensity of production  on  most  greenhouse  and nursery
land uses makes these operations another likely source of nitrate
in ground or  surface water.    Greenhouse operations employ among
the  highest  rates  of  any  land use,   as  high  as  600 to  800 Ib
N/acre/year  (White,  1990),  and in  1979,   covered  approximately
10,000 acres,  each operation averaging two-thirds of an acre. White
estimates there are probably about 17,000 acres today.  Greenhouses
have been implicated  in  several  areas  as the  cause of nitrate
concentrations that significantly  exceed the MCL.   The Monterey

                                60

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                       * DRAFT  (3/5/91) *

County  Soil and  Water Conservation District  associated nitrate
levels  of  over 20 mg/L and  in  some cases, up to  60 mg/L in the
ground water of two hydrologic subareas with greenhouse operations.
Greenhouse  operations  in Salinas Valley, California  (Snow, 1988).
California has both the highest number of horticultural specialties
establishments  (2,265)  and the greatest  acreage of  floriculture
under greenhouse cover (2,532 acres).  In number of establishments,
California  was followed by Florida, Pennsylvania,  New York, and
Ohio, (White,  1990).

                      Agri-Chemical^Dealers

     There  are  more  than  14,000  individual  retail fertilizer
dealerships in the United States.   While data are not available on
a regional  or  national basis, anecdotal data exist which indicate
that excessively high  nitrate  concentrations  in ground water and
well water  can occur from nitrogen fertilizer spills  at mixing and
loading  areas.   A  recent survey  by the  Illinois  Department of
Health  indicated  that agri-chemical mixing and loading facilities
presented a definite threat to ground water with  levels of nitrate
in proximate ground water far exceeding the federal drinking water
standard.  Random testing of 1500 licensed agri-chemical dealers in
Illinois showed that for 80 sites most of the wells  (more than 60%)
associated with the site had nitrate levels exceeding 10 ppm (Long,
IDPH, 1987).   The reasons cited  for this contamination included
unsuitable  conditions  for  storing  large  amounts  of chemicals,
improper mixing,  loading, and  disposal of chemicals, and running
agrichemical practices on relatively small parcels of land without
taking the  necessary environmental precautions.

      The pollution scenario identified in the Illinois survey is
not unique.  Ten case studies in the Corn  Belt showed a pattern of
high nitrate,  pesticide, and ammonia concentrations associated with
agrichemical dealerships.  Some shallow private wells in the case
study areas had levels of nitrate over 115 ppm.   Hallberg noted
that these sites should be considered "quasi-point sources" because
"even though they are discrete sites, there are literally thousands
of such facilities across  the Corn Belt, so their potential impact
could be widespread" (Mueller, 1989).

     The pattern  of contamination was similar at each dealership:
equipment was rinsed and flushed into drainage ditches and left to
leach into the ground.   This type of problem is equally likely to
occur on farmsteads where farmers load and rinse their equipment in
the  same place  each  year  (Richard  Fawcett  of  the Iowa  State
University  Extension  Service).    Naymik  and  Barcelona  (1981)
describe  how  leaching  from an  uncovered  fertilizer bin at  an
Illinois  plant caused  groundwater  contamination  of 2,100  mg/L
ammonia and 1,800 mg/L nitrate.
                                61

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                       * DRAFT (3/5/91)  *

                     NON-AGRICULTURAL SOURCES

     Non-agricultural sources  of  nitrogenous  compounds represent
small additions  to  the environment,  but locally they  can create
serious  contamination  problems.    They fall  into  four  basic
categories:   a  nutrient added to fertilize grass,  a  human waste
product,  a by-product of  industry,  or  a  result of  fossil  fuel
combustion.   The importance  of  any  of the  sources  depends  on
conditions  in  the   local  area.   Aerial  sources  are  somewhat
different in that they can travel greater distances  in a short time
period.

                         Septic Systems

     Septic  systems are the  most frequently reported  cause  of
ground water contamination in  the  United  States  (Yates, 1985).  41
states  have identified them  as  a major source of ground water
contamination in the state  (Moody, 1990).  For  example,  New Mexico
reported that household septic tanks and cesspools are the single
largest source  of  ground  water  contamination  (New Mexico Water
Quality Control  Commission,  1988).   The California  State Water
Resource Control Board estimates that six percent of nitrate ground
water pollution  comes from septic systems  (Anton,  1988).  Septic
systems represent the largest  source of wastewater discharged into
land by volume,  820 to 1460 million gallons a year (Scalf, 1977).
Over 21 million homes, representing approximately one-third of the
population  of the  United  States,  rely on  septic systems  for
sanitary waste disposal  (Office of Housing, 1987 data).  25 percent
of all new home  construction or an additional 500,000 systems are
installed each year.

     Septic  system  density is a  far more  important indicator of
probability of contamination than  the total number of systems.  The
highest densities of septic  systems occur in high growth areas.
Figure 13 shows the  density of septic systems throughout the United
States.   The Boston to  Washington,  D.C.  urban corridor,  parts of
Florida, and areas around urban centers especially in the east all
have high septic system densities.  EPA considers any area that has
over 40 septic  systems per  square  mile  (1  per 16 acres)  to be
potential areas  of  ground water contamination.  This assumes that
the systems are  spread out evenly.  A greater problem would occur
if the systems were clustered.

     Four counties have over 100,000 housing units served  by septic
systems:  Los Angeles, California; Dade County, Florida; Nassau and
Suffolk Counties, New York, ranging  from  over  25 to 346 per square
mile.  An additional 23 counties have over 50,000 septic systems,
generally ranging from 20 to over  250 per square mile.  15 counties
have at least 100 per square  mile.   These statistics do not take
into account  the area available for each lot.  Nassau county has

                                62

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the highest density in the country with over 350 systems per square
mile  (US EPA, 1977).

     Figure 14 shows a cross section of septic system operation. It
functions  specifically to  discharge waste water  into the ground
water, using the soil as a  filtering mechanism.  Wastewater leaves
the house and flows into the septic tank.  Sludge,  grease, and scum
settle out and the effluent flows into a distribution box where it
is channeled  to  a soil adsorption field.  There  is  virtually no
change in  the total nitrogen content  of  wastewater  as  it passes
through the system.  The anaerobic environment of the tank converts
the organic nitrogen in  the  influent  from the house to primarily
ammonium in the effluent.  Septic tank effluent averages between 40
and 80 mg/L of total nitrogen.  75 percent  in the ammonium form
(NH4)  and 25 percent  as  organic nitrogen  (Reneau, et al., 1989).
The septage, or solids that are pumped out of the  septic tank, has
a much higher nitrogen content up to 700 mg/1 total nitrogen
(55 FR 47241).

     Optimally  operating  septic systems  are  conducive to  the
nitrification of the  ammonium to nitrate in a short distance from
the soil adsorption  field.  Generally very little denitrification
occurs in systems installed in well  drained soils  (Reneau, et al.,
1989).    Therefore much of the  nitrate produced  is  available to
leach into the ground water.   Nitrate is  not filtered out by the
soil: it moves with water.  EPA (1980)  estimates that approximately
18 to  32 mg/L nitrate enters  the ground water.   Walker,  et al.
(1973) estimated that each household  (family of four) results in
approximately 73 pounds of nitrate added to the ground water each
year.  On a national scale, septic systems  contribute about 350,000
tons of nitrogen to  the ground water annually.

     Contamination of ground  or  surface water by septic systems can
be an individual or a local problem.   An individual drinking water
well may be poorly constructed or sited and allow  the infiltration
of nitrate  and other contaminants such as bacteria  and viruses.
The local housing density may overwhelm the ability of the ground
water to dilute the  nitrate to sufficiently low concentrations or
the  local hydrogeology  may  be  inappropriate for septic system
installation.  The  placement  of  septic   systems is  very  site
specific.   Many factors should be  considered:   depth  to ground
water,  permeability  of  the  soil,   slope,   subsurface  geology,
climate, vegetation,  and number of  users.   Some studies estimate
that up to  one half of the United States  is inappropriate due to
one or more of these  factors.

                           Urban Sewage

     On a national  scale, municipal sewage  treatment plant effluent
is not a large part of nitrogen input  to waters.   However, in some

                                64

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                           65

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                       * DRAFT (3/5/91) *

areas, such as the Chesapeake Bay or Santa Ana River in California,
it is a very important source.

     Publicly owned treatment works (POTWs) collect and centrally
treat   sewage   in  areas   where   on-site  septic   systems   are
inappropriate due to restrictive site conditions or higher density
development.  More than  15,500 POTWs are currently in operation.
With the  exception  of some 1,800 non-discharging  ponds  and  land
treatment systems, most POTWs discharge their treated effluent into
surface waters  on a  fairly continuous basis.   About  29 billion
gallons  per  day  (gpd)  of  combined  domestic  and  pretreated
industrial wastewater are currently treated and  discharged by POTWs
nationwide.  These facilities range in size from less than 10,000
gpd to over one billion gpd in treatment  capacity.  Fewer than 500
treat over ten million gpd.  A wide variety of treatment processes
are used by POTWs, although the most common are ponds, activated
sludge, and trickling filters (EPA, 1988, Needs Survey).

     POTWs that discharge their effluent  to surface waters receive
National Pollutant Discharge Elimination  System (NPDES) permits to
meet  state  water  quality standards  which,  with  only  a  few
exceptions, specify  a minimum of secondary treatment.   However,
conventional treatment plants are  not designed to  remove total
nitrogen   (ammonia  and  organic  nitrogen)  from  the  effluent.
Primary-secondary plants  generally  remove no more than  30 to 40
percent of the nitrogen.
     Nitrogen levels in municipal wastewater effluents not required
to remove nitrogen frequently amount to as much as 25 mg/L or more
total nitrogen (which may be mostly ammonia or nitrate, depending
upon the  type of  treatment process used).   Once  discharged to
receiving waters or applied to the land, most of the nitrogen will
convert relatively quickly to nitrate.

                Land Application of Sewage Sludge

     In 1982  there were at least  2,463 publicly  owned treatment
facilities applying liquid and thickened sludge on land surfaces,
and an additional  485 facilities in operation or under construction
using sludge  spray irrigation practices (OTA, 1984).  Of  the 6.8
million dry tons of sludge produced by  municipalities in 1982, 24%
to 29% was spread directly onto crops  (OTA, 1984). The purpose of
land treatments is to biodegrade the organics and to immobilize the
inorganics"  (Patrick  et al.,  1987).   While land  application of
sludge is  considered a pollution  prevention  technique,  examples
exist where farmers have failed to follow best management practices
such as reducing commercial nitrogen fertilizer when sewage sludge
has been  applied to  their fields.  Elevated  groundwater  nitrate
concentrations as high as 35 mg/L have resulted.

                                66

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                       * DRAFT  (3/5/91) *

                    Non-Farm Use of Fertilizer

Home Lawn Care

       Non-farm use of nitrogen fertilizer is estimated to account
for about 4.2% (425,000 tons of  10.2 million tons in 1987) of total
nitrogen fertilizer use (White,  1989).  Regionally, non-farm use is
most significant in New England  (34% of total fertilizer use), Mid-
Atlantic (19%), and Pacific Coast (12%)  (White,  1989).   It is used
on golf courses,  home lawns, and turf on commercial,  industrial,
institutional and multi-family residential facilities.  While these
uses represent a  small percentage of total use, non-farm uses of
fertilizer  have  been  linked to ground water contamination in a
number of areas:   home lawns on Long Island (Flipse, 1984) and golf
courses on  Cape Cod  (Cohen,  1990).

     Privately conducted surveys  indicate that about 425,000 tons
of nitrogen fertilizer (4.0% of the total)  were used on turf and
gardens (Stangel, 1987).   There are about  32  million acres of turf
on residential  and  commercial  sites in  this  country  (Consumers
Union, 1990).  Runoff  of N  applied to turfgrass has been found to
seldom to  occur at  concentrations  above  the MCL,  but there are
instances where water draining from turf to ground water may attain
levels that approach or exceed the MCL, (Petrovic,  1990).

     A survey of Long  Island households indicated  that  homeowners
were applying on  average  122 Ibs/acre to  their lawns  (Koppelman,
1978).  Professional lawn care applicators may apply significantly
more, on the order of 196 Ibs/acre to 261 Ibs/acre (Morton, et al.,
1988).  At least one study found that nitrogen leaching and runoff
from  turfgrass  based  on  rates  typically applied by  commercial
applicators  are not significant (Angle,  1990).   In the  same study,
however,  twice   the  commercial  rate  of  application,   caused
significant  runoff.  Angle suggested that many homeowners managing
their own turf expect  lawns  to look  'twice as good1 for twice the
fertilizer  application (Varner, 1990).

     Further, Morton et al.  (1988)  found that  while  controlled
irrigation  did not  increase nitrate concentrations leaching from
fertilized turfgrass relative to concentrations from unfertilized
plots, irrigation at higher  rates did degrade the  drainage water.
Just as homeowners  are thought to apply  fertilizer in excess of
recommended rates, they may  also over-water their lawns.  Excessive
fertilization compounded by  improper irrigation appears to pose the
most  likely scenario  for nitrate  concentrations  above the  MCL
draining from residential turf.

Golf Courses

   Golf courses typically receive higher annual  rates than home

                                67

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                       * DRAFT (3/5/91) *

lawns, estimated to be between 218  to 260 Ibs/acre (White 1989),
although these  are often applied as  frequent  light applications
that may reduce the  potential loss to ground  water.   Rates vary
widely between areas on a course:  on  Cape Cod, available data for
four golf courses shows average rates  of 100 Ibs/acre on fairways,
118 Ibs/acre on tees, and  187 Ibs/acre on greens (Cohen,  et al.,
1990).   A  1974 Florida turfgrass survey found  that rates  of
application on all areas of golf courses in the state averaged 188
Ibs/acre, but were 747  Ibs/acre for  golf course greens (Snyder,
1982).   There are approximately  12,000  golf  courses  across the
nation (Cohen, et al., 1990).

     Nitrate  leaching from  highly  sandy  golf greens  have been
observed  to  increase  as  the  rate   of  fertilizer  application
increased,  while on fine sandy loam soils, the concentrations did
not increase significantly as the rate of application was increased
(Brown, et  al., 1977).   Considerably less nitrate leaching was
observed to occur from applications  of activated  sewage sludge and
ureaformaldehyde, a slow-release fertilizer.
                                  Sources
     The two major sources of aerial nitrogen oxides are industry,
especially electric utilities, and automobiles and other vehicles
through the burning of fossil fuels and the resulting emissions of
NOX and SO2.  Each sector  contributes about half of the total.
The National Acid Precipitation Program (1987)  estimated that 28%
of NOX emissions came from power plants.   The primary controlling
factor  of  the rate  of NOX emissions from  these sources  is the
combustion temperature of the process.  The 20th century trend for
man-made NOX  is increasing  in almost direct  proportion  to the
amount of fossil fuels burned.  Since the passage of the original
Clean  Air  Act,  NOX has  increased  about  seven percent,  the only
conventional air pollutant to show an increase.

     No clear national picture exists concerning the influence of
atmospheric  deposition of  nitrogen compounds  on estuaries and
coastal waters.   Denitrification  from  these waters is  the most
important process controlling  the  fate of nitrogen,  but it is so
variable that generalizations may not be useful. (For example, on
a single farm, denitrification rates can vary by a factor of 100.)

     In order to discern the role air plays,  it  is  necessary to
calculate a mass balance.  The Environmental Defense Fund (Fisher,
et al., 1988) originally  estimated that one-third of the nitrogen
loadings to Chesapeake Bay were atmospheric in origin.  Atmospheric
deposition enters estuaries through two pathways,  one is deposition
deposited directly to the surface of the water, and the second is
deposition to the upland watersheds which  contributes, to a poorly

                                68

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                       * DRAFT  (3/5/91) *

defined  extent,  to  the runoff from  those  watersheds  and then
through the streams to the estuaries.   The nitrogen  in this runoff
can  contribute to  the eutrophication  of  surface  water without
leading to significant environmental problems in upland  forests.

     EPA then made estimates for four other areas.  The percentages
show extreme  variation:   Narragansett Bay,  10%,  New York Bight,
37%; Upper Potomac River Basin, 68%; and Ochlockonee Bay, Florida
(almost a completely forested watershed), almost 100%  (EPA, 1990).
A more recent study  that  calculated a mass balance for the Upper
Potomac River Basin estimated  that while  atmospheric deposition
represented 42 percent of total nitrogen inputs,  over two-thirds of
the nitrogen  fell on forested land which is able to  assimilate the
additional nitrogen  (Groffman and Jaworski, 1990).  Jones and Lee
(1990) calculated a mass balance for Lake Tahoe (a nitrogen-limited
lake)  and concluded  that   automobile  emissions are  the primary
source, representing over 80 percent of the nitrogen load.  There
are many uncertainties involved in these estimates,  but they point
out the possible impact of  atmospheric sources of nitrogen on the
health of these areas.

     EPA has  developed a  research plan to analyze  the long-term
ecological risk to coastal  waters from atmospheric deposition, in
response to a Congressional  request.  The purpose of the plan is to
provide  information  for pollution  control decision  makers that
considers the ecologic impacts of  nitrogen on estuaries.  The plan
estimates  that  1000 work  years  would  be  necessary to  gather
adequate information.

     The Great Lakes Water  Quality Board (1989)  believes that the
major source of nitrogen loading to Lake Huron and Lake Superior is
atmospheric deposition because both lakes have limited agriculture
on  surrounding lands  and  low population densities.   It may be
impossible to discern the contribution of atmospheric nitrogen to
the loadings  of  the other  Lakes  because  of the number  of  other
possible sources.

     Atmospheric deposition has also been observed to lead to high
levels of nitrate in ground water.   In the San Gabriel Mountains
near Los  Angeles, California,  ground-water concentrations  from
nearby, relatively unpolluted watershed were typically one to three
orders of magnitude lower (Riggan, et al.,  1985).

                       Industrial Sources

Food Processing Wastes

     Some nitrogen is returned to fields in the  form  of  solid
wastes  from   food  processing operations.    While  the amount  of
nitrogen supplied in this manner is small  in aggregate,  estimated

                                69

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                       * DRAFT (3/5/91) *

to be on the  order of 15,000 tons,  excluding brewery,  dairy, and
slaughterhouse wastes  (NFPA,1989), it can be a significant source
in areas surrounding  large  processing  facilities if the nitrogen
content of the waste  is  not considered when applying fertilizer.
This  situation  is  likely  to  be encountered  most  often  in the
western united  states,  due to  the volume  of  processing waste
generated and the types of produce that are processed.

     Cleaning and  washing  at  processing plants  generate liquid
wastes  or high  moisture  sludges.    Liquid  wastes are  usually
discharged to a  POTW  or to water directly.   Sludges are usually
disposed  of  in  landfills  or by field  application.     In  some
operations, substantial quantities of solid waste are culled from
raw  produce  or  screened  from  wastewater  and  used  as  a  soil
amendment.  Generally, solid wastes  from food processing contain
about one percent nitrogen.

Other Industrial sources

     As compared to the estimated 10.5 million tons of fertilizer
nitrogen,  the contribution  of  nitrogen from inorganic industrial
wastes appears to  be  a rather small source to land.   It is more
significant as a source of nitrogen to surface water where 23,800
tons actually reaching surface water is  the equivalent of a much
greater amount  of  fertilizer  nitrogen applied  to  land,  only a
portion of which will be transported to surface water.

     The industrial process which produces the greatest amount of
nitrogenous waste  is  the synthesis of ammonia,  which  is used to
produce other nitrogenous compounds including fertilizers, nitric
acid,  and  paper  products  (Madison,   1984).    Dischargers  of
significant  quantities  of  nitrogen  include  ammonia  dealers,
fertilizer manufacturers, and manufacturers of explosives.  Nitrate
concentrations of  500  mg/L  or  greater  can result from explosives
production  (New  Mexico Water  Quality  Control  Commission, 1988).
Nuclear fuels manufacturers are  also a potential source of high
concentrations of  nitrates.   For one  month in  1988,  a  plant in
Virginia discharged on average, 360 mg/L nitrate to surface water
(Virginia State Water Control  Board, 1988).

     Host  larger  industrial  facilities  are  required under the
Emergency  Planning and  Community Right to  Know Act of  1986 to
report  releases  of  all  toxics  listed on  EPA's Toxics Release
Inventory  (TRI).   The  four  major sources  of nitrogen  in the TRI
database are ammonium nitrate (solution), ammonia, nitric acid, and
ammonium sulfate (solution).   The TRI  lists releases directly to
water, to air, to land, to  POTWs,  by underground  injection, and by
other off-site transfer.
                                70

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                       * DRAFT  (3/5/91) *

     Outlined  below are  releases that  present the  roost likely
impacts to surface and ground water.

Nitric Acid fHNO3l ;  The 1988 figure for releases to water  is 1,622
tons of nitric acid.   Releases of nitric  acid  to air were 5,491
tons, to POTWs 11,661 tons,  and 714 tons were reported released to
land.

Ammonium Nitrate (NH^NCX) ;  82 percent of the 4,411 tons of ammonium
nitrate   releases  directly   to   water   are   facilities  which
manufacture,  import,  or  process  nitrogenous  fertilizers.   Other
industrial  classifications  which released  ammonium nitrate  in
significant  quantities  directly  to  water  include  fertilizer
mixing-only   operations,       paperboard   mills,      explosives
manufacturers, and industrial inorganic chemical vendors.  Releases
to land were 8,373 tons, approximately twice the releases directly
to water.  Total releases to POTWs were 3,798 tons.

Ammonia  fNH3);  The  TRI  database reports  10,244  tons  of ammonia
released directly to water.   This total is believed to be greatly
underestimated,  because  reporting  requirements  have  required
facilities  to  report only the  amount  of  un-ionized  ammonia.
Beginning  1990,  facilities  will  be  required to  report  both the
total  of  ionized  (NH4+)  and un-ionized  ammonia.   The  following
types  of  facilities reported  the largest releases:   industrial
organic  chemicals  vendors,  blast  furnaces  and  steel  mills,
petroleum  refiners,  agrichemical  manufacturers,  primary metals
facilities, and pulp and paper  facilities.

     Releases  to  air were 123,842 tons.   Air releases of ammonia
from industrial facilities  may result  in a significant amount of
air  deposition of nitrogen downwind of  a facility.  A reported
total of  12,169 tons were released  to  POTWs,  and 3,052  tons were
released to land.

Ammonium Sulfate ((NH^KSO^ ;  35,123 tons of ammonium sulfate were
released directly to water  in 1988 from the following industries:
inorganic chemical dealers, pulp  and paper mills, primary metals
facilities, and fertilizer manufacturers .  Total  releases to land
were 7,203 tons, and 95,504 tons were released to POTWs.
                                71

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                       * DRAFT (3/5/91) *                             ^^
                       POLLUTION PREVENTION

     The  goal  of pollution  prevention  is to  avoid  pollution
problems before damage becomes more serious and costly to remedy.
Action is needed now because nitrate contamination represents the
most pervasive problem affecting ground water (Water Quality 2000,
Agriculture Committee, 1990).  Moreover, nitrogen is known to cause
eutrophication of estuarine and marine ecosystems, and some lakes.

     Pollution  prevention  may  offer   fairly  rapid  hope  for
estuaries.   The Chesapeake Bay,  and perhaps  other  estuaries as
well, can  cleanse themselves  of excess  nutrients in  years,  not
decades,  once  the  sources  of  nitrogen  have  been  controlled
(Boynton, 1990).   There  is  no similar  rapid mechanism to cleanse
aquifers once they have  been  contaminated by nitrate.   Pollution
prevention methods, therefore, can prevent the loss of a valuable
ground water resource—used for drinking water and as a source of
recharge to surface water bodies.

     Pollution prevention includes the development of sustainable
technology and education or  low cost, market  incentives,  as well as
more expensive  cost-sharing and regulatory  programs.  Relatively
inexpensive pollution prevention practices can be  implemented while
pollution  problems are  being further assessed.   Prevention is
particularly suited to N problems because  numerous sources often
make it  infeasible to pinpoint the cause  of  a problem.   Since
competition  for resources even  for  low-cost options will  remain
intense, despite recent funding increases, the pollution prevention
strategy considers economics and the likely economic acceptability
of  proposed  technologies.    Innovative  strategies  have  been
developed to deal with excess  nutrients in  the  Tar-Pamlico area
that allow pollution  trading  between point  and non-point sources
(Harding, 1990).

     Pollution  prevention  strategies   are  discussed  for  the
following major sources  of  nitrogen:  agriculture—fertilizer on
cropland and livestock waste;  and non-agriculture—septic systems,
urban sewage, industry, and non-farm use of fertilizer.

                           AGRICULTURE

     Fertilizer, used to encourage crop growth, is a major source
of nitrogen in virtually all areas experiencing  widespread nitrogen
contamination.  The most intensively fertilized cropland is found
in grain production in the Corn Belt (particularly Iowa, Illinois,
Indiana, Nebraska, and Ohio)  and in specialty crop production in
states such as California and Florida.   Throughout the major crop
producing  regions,  virtually  all  farmers need  assistance  in
managing fertilizer.


                                72

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                       * DRAFT  (3/5/91) *

     Livestock problems tend to occur in the localities where the
total amount of manure in a county exceeds the nutrient requirement
of  all  crops  grown in the  county  (Figure    ),  or at  the many
scattered  sites  where livestock  are located on  or near surface
waters.  Prevention efforts need to recognize the  pervasive nature
of fertilizer problems (Canter,  1987),  as  well  as  the concentrated
nature of  many livestock sources.   Prevention efforts  must also
recognize that fertilizer provides a valuable resource to farmers
that leads to abundant and affordable food.

     Both crop residues and livestock waste are used as a source of
nutrients in conjunction with commercial fertilizer. Although crop
residues account for an important,  but variable, part  of  the K
(Meisinger, 1984, p.399), fertilizer application  supplements what
is provided by these residues.   Additions  of commercial fertilizer
compensate  for  discrepancies  between  crop  N  needs  and N from
residues.    Similarly, fertilizer use  is  likely  to supplement N
from livestock waste,  except in areas where livestock densities are
so high  as to provide all of the  N  requirements.  Even on farms
with  considerable livestock, management  must  focus  as  much  on
chemical fertilizer N as on  livestock waste,  since fertilizer is
the  input  most  readily  subject  to   accurate  measurement  and
management.  Proper use of fertilizer requires  accounting for the
fluctuating  nutrient  value  of  crop  residues,  manures,  sewage
sludge,  and mineral  N  in the  soil  in  order to determine  an
agronomically  sound  amount  of  N  to  be  applied  as  commercial
fertilizer.

     In areas where livestock sources of N dominate, improving the
efficiency of fertilizer use often increases farmers'  net returns
(Follett, 1989; Fox, et al., 1989; Blackmere,  1989; Bouldin, 1971),
while improving  storage structures for livestock waste management
more likely represents a net loss to the farmer  (Crowder and Young,
1987).   Important exceptions include such low cost practices  as
manure testing,  manure spreader  calibration,   and more  frequent
hauling to the fields.  Pollution prevention efforts must address
interrelated fertilizer and livestock sources of N.

     Pollution  prevention  needs  may differ  for  surface versus
ground water.    N  is particularly  a  surface  water problem  in
estuaries,  such as the Chesapeake Bay, which are adversely affected
by  livestock  sources  of phosphorus as well  as  nitrogen.   Some
management practices  for  reducing livestock N  from ground water
interflow  to  surface  water  also  reduce  phosphorus losses;   by
preventing pollution from two pollutants at once,  livestock waste
management  may  be  especially  effective  in programs  addressing
surface  water  pollution from N.   Surface water  pollution often
originates far from where the damage occurs, emphasizing again, the
need to target programs to  the geographic area where the livestock
N originates (EPA, Region 3, 1983).

                                73

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                       * DRAFT (3/5/91) *

          Management Practices  for  Commercial  Fertilizer

     Many management  practices have been developed to  limit the
amount of fertilizer  nitrogen  leaching into  ground water  (U.  s.
Congress, 1990).   However, a  fundamental  problem in managing N
fertilizer results from the considerable variation over time in the
amount of N in the soil.   Rainfall events in  spring and  winter
leach N below the  root zone where  plants can  use it  in  ways that
are hard to predict  in advance.   Fertilizer applications need to
coincide with periods  of rapid plant  growth if  plants are  to use
the N.  Accurate N use recommendations are also needed which take
into account N available from the previous year's crop.

     Two best management practices (BMPs)  for avoiding  potential
leaching of nitrogen below  the  root zone are most often emphasized
in the literature:   (1)  timing of fertilizer application through
split preplant and summer side-dress applications (Bouldin, et al.,
1971) and (2) soil testing (Johnson, 1986;  Meisinger,  1984; North
Carolina Extension Service, 1982; Water Quality 2000,  Agriculture
Committee,  1990).    Related practices which  should  be pursued
include:  setting  appropriate yield goals,  testing manure  for N
content,  plant tissue testing  to determine  N  needs,  computer
simulations  using  more complex  models,  and  irrigation  water
sampling for N content.

     Excess nitrogen accounts for much of what leaches through the
root zone, representing an economic loss to the farmer as well as
the  major source  of  pollution  to ground  water  and  potentially
surface water.   Although many BMPs have been designed to address
N problems specific to conditions in certain regions, reducing the
excess application through improved soil testing and through timing
fertilizer  applications  are needed virtually everywhere  that N
pollution from intensive crop production  occurs.  Soil testing
potentially makes the greatest  contribution  in livestock producing
areas where accounting for  N from legume crops and  livestock waste
poses special problems.

Timing

     Fertilization with  chemical fertilizer or manure must occur
when plants can best utilize the nitrogen. A single application of
fertilizer  before  planting   can   increase  the  potential  for
contamination of ground water since plants cannot  immediately use
the  nitrogen and  spring rains  may  leach  the  unused  nitrogen.
"Split" applications improve the timing.  A lower  initial preplant
application in early spring is followed by side-dressing fertilizer
N in  early  summer after the rains.   Side-dress applications are
placed between rows of plants.  This important practice has proven
itself both in research on  experimental plots  and  in actual use by
farmers.  Side-dressing used in combination with soil testing for

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N availability in the soil helps to avoid having substantially more
nitrogen available in the soil at any time than plants can use.

      Timing applications through split, preplant and summer side-
dress applications helps minimize N leaching by reducing the amount
of N fertilizer in the soil  during the  spring months' heavy rains.
These rains  occur  before crops  are  mature enough to  use the N.
Farmers'  use  of  split,   summer  side-dress  application  has  not
reduced fertilizer use as much as the one-third reduction achieved
on experimental plots  (Bouldin,  Reid,  and Lathwell,  1971).   Yet,
farmers who  side-dress do use much less fertilizer per acre each
year than do all  farmers combined (Table 1) . Currently, 25 percent
of U.S. corn farmers  apply  split,  preplant,  and summer sidedress
applications  (Taylor and Vrooroen, 1989).

                             TABLE 2
Average N use on corn, all  farms/split application farms, 1988.
                     All Farms
         Farms Splitting
         Applications
Percent
Difference
Illinois
Indiana
Iowa
Missouri
Ohio
South Dakota
	pounds N/acre,

163             131
146             131
139             131
132             110
158             112
 80              45
   20
   10
    6
   17
   29
   44
Source:  Objective Yield Survey.  1988.  Economic Research Service,
U.S. Department of Agriculture.  Data provided by Harold Taylor.

     While one-quarter  of all farmers side-dress,  16  percent of
farmers apply some fertilizer in the fall  for their spring planted
crops  (Taylor and Vroomen, 1989).  Fall application is especially
likely  to  increase  N  leaching  because  of  the  considerable
precipitation which  occurs in winter  when plants are  often not
available to use the N.

Nitrogen Soil Tests

     In 1984,  researchers successfully employed soil nitrogen tests
in humid  states  in the  late  spring  to  support summer side-dress
applications  of  fertilizer.   These tests  actually  measure the N
availability in the soil for plant growth.  Previously, virtually
all humid states (which  basically exclude the Western states) had
relied on N recommendations based on the farmer's cropping history,
soil type, and yield  goal  (Magdoff,  1984; Meisinger,  1984).   New
technologies for late spring soil testing both support use of the
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side-dressing  BMP  and provide a soil test where  it  has not been
available previously.

     Because of tremendous variability in the amount of N remaining
in the soil from the previous year's  crop and from mineralization,
farmers  tend  to apply much  more fertilizer than  plants  can use
during any but unusual weather.  OVer application of N as insurance
is somewhat costly,  but  supplying  too  little N before a very wet
spring  apparently  reduces many  farmers'  profits  enough,  in the
absence  of  the late spring  soil  test,  to pay  for  the routine,
excess  application.    Similarly, lack  of  information  leads many
farmers to ignore the  fertilizer available from manure and legume
crops even though legumes provide considerable  N by N fixation and
in some instances supply much more  than the following crop can use
(Fox  and Piekielek,  1983; Meisinger,  1984,  p.410; El-Hout and
Blackmer, 1990).

     Soil tests for arid states, particularly Nebraska and Montana,
were developed earlier than in humid  states,  presumably because
spring rains in humid areas introduced considerable uncertainty as
to how much N  leached out of the root zone through the season; this
is not a problem in  arid states.  However,  a survey  of state soil
fertility extension  experts identified lack of calibration of the
tests  as the  major  factor  impeding the  dissemination  of soil
testing technologies to farmers (Meisinger, 1984).   Thus, lack of
resources for  soil test calibration was a problem even before the
breakthrough in late spring soil testing, and it continues to be a
problem.  Calibration involves "tuning" soil tests  for differences
in soils and climate which affect N needs.

     In spite  of the need  for more resources to begin calibration
or improve site specific calibration of soil tests, the land grant
university  system  routinely  provides  soil  test  information  to
farmers.  Reaching farmers with improved  soil test technologies
should  pose relatively  few  institutional  challenges.   Tractor
mounted  soil   testing  technology  (Colburn,   1990),   still  in
experimental stages of development,  may further  streamline delivery
of tests,  and make  these technologies  far  more effective,  as
fertilizer needs vary within fields.  These  tractor  mounted testing
devices have a computer which uses the results of continuous soil
tests to instantaneously adjust fertilizer application to the needs
of each part of the  field.

Economically and Environmentally Optimum Use Rates

     One issue for those developing new soil tests  is whether they
should be calibrated for economic efficiency.  Recommendations to
maximize yields will  lead to greater fertilizer use  than will
recommendations geared to maximizing profits.    (This is because N
costs money and at  yield maximizing  rates,   costs  exceed  added

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returns from more N).
     Plants' use of N depends on how much grain can be produced on
a particular soil.  The higher the expected yield,  or "yield goal,"
the  more N  is  needed  by  plants to  meet that  goal.   Setting
realistic yield goals (which are  in the formula used in making soil
test   recommendations)    is   thus   essential    to   obtaining
environmentally  and  economically efficient N use.    By avoiding
excessive  fertilizer  use,  farmers  will  more  closely  equate
applications to  plant needs.   It is  the  excessive  applications
beyond what  plants  can  use that  are primarily  responsible  for
pollution and for economic waste. However, not providing enough N
to meet plant needs greatly reduces yields,  profits and ultimately,
the availability of  food.

     Keeping records of  yields,  yield goals,  fertilizer use,  and
fertilizer recommendations  is critical to  maintaining realistic
yield goals. These records  also assist those  advising farmers on
fertilizer use, facilitating evaluation of  the performance of each
year's use of N.

     Whether more economically efficient use of fertilizer by U.S.
farmers will eliminate the potential of fertilizers to pollute is
a question that  EPA  and USDA need  to  explore further.   However,
careful  fertilizer   management   can  substantially   reduce  the
pollution without reducing profits  (Ayer,  1989).

other Nitrogen Management BHPs

     Other practices proposed for managing fertilizer  to reduce
nitrogen pollution fall into three major categories:   1) managing
surface  runoff,  usually through soil  conservation practices,  2)
managing water,  itself,  through improved  irrigation  and drainage
practices, and 3) managing  crop  rotations  and crop mix to reduce
the  production  of  crops  requiring  fertilizer.    These  three
categories of practices are important in certain locations but not
recommended as widely to  address N  pollution  as  are  soil testing
and timing practices described above.

Soil Conservation     Managing  surface runoff through practices
like terracing, contour plowing, and ridge tillage on the contour
reduce N runoff  into surface water, but often at the  expense of
increasing infiltration of nitrogen  into the ground water (Kramer,
Hjelmfelt, and Alberts,  1989).   Since ground  water pollution (or
ground water interflow  to  pollute  surface  water)  is  the  more
pervasive N  problem, practices  for managing surface  runoff  are
often not the appropriate  remedy  for N pollution,  in spite of their
importance  in  reducing  sediment and  phosphorus pollution  from
erodible land.   Nitrate  does not attach  to  soil particles like
phosphorus does,  therefore soil  conservation practices have little

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effect on nitrate loadings.

     An exception  is vegetative  filter  strips along  streams  or
marshes.  Filter strips are generally viewed as a BMP to filter out
pollutants in surface runoff using grass, weeds, and tree litter,
but filter strips  also  reduce pollution from  N through nutrient
uptake  and  by aiding denitrification  (Lowrance,  et  al.,  1984).
Thus,  this  practice does not  trade surface water pollution for
ground  water pollution  as  other practices  designed to  reduce
surface runoff.

     A closely  related practice  is a winter cover crop which in
mild climates will  "scavenge" nitrogen left from the previous crop.
                        *  DRAFT  (3/5/91) *

of  humus,  can leach from the  fallow ground between rows  (Sturm,
1987) .   The pollution  prevention technique of  growing a ground
cover,  such as grasses, between rows of trees  or plants serves to
"scavenge" N and other nutrients in the bare soil between the rows.
In  addition,  they contribute  over  time to  replenishment of the
organic matter of  soil  (humus)   (Hempler, 1990).

      For  vegetables,  the period of greatest  potential  nitrate
losses can occur shortly before or after planting when the soil is
largely  bare and  amount of  mineralized  nitrogen  exceeds plant
demand.    A  pollution prevention  technique  is  to  maintain  a
continual grass cover except for the area directly surrounding the
cash  crop.  Where this is not possible or economical,  according to
Hempler,  cover  crops  should  be planted between cash crops to
prevent extended periods  of bare ground.

Nitrogen  Inhibitors     Nitrogen inhibitors, a controversial BMP
candidate,  are  intended to   improve  the  timing  of  fertilizer
availability to plants  without  requiring split applications, once
again, to conserve and  efficiently use the fertilizer  applied.

      Inhibitors  work  by  preventing  bacteria  from  converting
ammonia fertilizer to nitrate that may be leached through the soil.
However,  research  is needed to  verify  that  inhibitors work in a
predictable  enough  way to  actually  influence  farmers'  use of
fertilizer  (Hauck, 1988).   Inhibitors may  have the  undesirable
effect  of encouraging  fall  applications  which  lead to  leaching
(Hoeft,1984).  Slowing the  release  of fertilizer may  also reduce
leaching early in  the season when plants are too small to  use it,
only  to  increase leaching late in the season when it  is too late
for efficient  plant  uptake (Allen,   1984).   Inhibitors are being
regulated as pesticides because they are bactericides.

                      Implementation Issues

      Fertilizer  is quite  amenable to prevention techniques.  The
most  prominent management practices for fertilizer aim to reduce
the need  to apply extra  fertilizer  as "insurance" against risks

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                       * DRAFT  (3/5/91) *

include  improved  irrigation management,  closing  surface drain
outlets during  winter,  winter  cover  crops,  and vegetated filter
strips.  All of these low cost  practices need to receive priority
in U.S. Department of Agriculture, Extension Service, educational
programs.  In addition, State water quality programs, such as those
described  below,  alert  farmers  to  the   seriousness  of these
environmental problems and encourage adoption of the relatively low
cost remedial measures.

Incentives

     Farmers may adopt best management practices more rapidly when
the  government  shares  the  cost.    Although universities often
subsidize soil tests for N (where tests are  available), support for
these practices generally has been limited.  Exceptions include a
$20  million  USDA  pilot  program  in  1989  which  included  some
fertilizer management cost-sharing in selected counties across the
U.S.  Another major exception  is a demonstration program  in Iowa
funded by a state excise tax on fertilizer.

Technology Development and Education     The Iowa program subsidized
adoption of fertilizer BMPs indirectly by contributing hundreds of
thousands of dollars per year to the development  and calibration of
improved soil tests, including a test based on the  late spring soil
test by Magdoff (1984).   Calibration takes  three to five years and
requires an  investment this  large  only in  the  major agricultural
states such  as  Iowa. States with  less extensive  agriculture can
calibrate soil  tests for less.   By  reducing fertilizer use  by a
third,  it is  believed that simply  developing and making  this
technology readily available represents a substantial  financial
incentive for its adoption (Business Publishers, Inc.,  1990).  In
Pennsylvania, introduction and  promotion of carefully calibrated
fertilizer recommendations coincided  with  a gradual rec ction in
fertilizer use, reaching nearly 50 percent reduction over  8 years
(Ogg, 1990) .

     Education  programs,  which in  Iowa and in the Pennsylvania
pilot program included cost sharing for hiring private consultants
as well as demonstrations and other educational services provided
by the USDA Extension Service,   also provide an  incentive to adopt
new  technologies.     The   combined   approaches   of  technology
development, education, and  cost  sharing are mutually supporting
programs  that are  particularly effective where  new  technology
development is a key element in addressing the problem.   Clearly,
new  technologies  and  their   development  must  be  a  critical
ingredient of a successful N management program.

     Farmer interest in these voluntary approaches may be enhanced
by their  own concerns with  providing safe water  for family and
livestock  use.    Farmers must  also  be conscious  with  possible

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liability regarding potential pollution of neighbors1 wells.

Taxes and User Fees    Taxing fertilizer to reduce use represents
another option.  However, a fairly large tax,  or user  fee, would be
required to  substantially  reduce fertilizer use.  Fees are used
also to pay  for  technology development to  better manage N, as in
the Iowa example.  Fees may be used to  internalize (make polluters
share the cost) the damages caused by N pollution. It is doubtful
that these  user fees  would  themselves be sufficiently  large to
greatly affect use, unless fees  as large as  50 or 100 percent of
the price farmers pay are adopted (Dubgaard,  1987).

Reducing Price Distortions from  Farm Programs      Farm programs
have been blamed in the past for encouraging farmers to seek higher
yields in order to  enhance program payments.  Past yields are built
into  the  price  support  payment  formula,   thereby  increasing
fertilizer use in the past contributing to the multi-billion dollar
price support payments received by  farmers   (Hertle,  1990;  Ogg,
1990).

     However, yields used in computing payments have been frozen
since 1985.  By avoiding  raising  program yields to achieved yields
on farms,  program administrators  have sent  the message that higher
input use does not  lead to higher payments.  Continuing this policy
will avoid creating a strong  incentive to apply more N fertilizer,
while  preventing  price  support/supply  control  programs  from
undermining their own price support objectives (Hertle, 1990).

Regulation of Fertilizer Use

     There  are  few  laws currently  regulating  farmers'   use  of
nitrate  fertilizer  in  the  U.S.     In Nebraska  where  nitrate
contamination of ground water is  a serious  problem, the state's 23
Natural Resource Districts  (NRD) have  the authority to regulate
nitrogen fertilizer use to reduce groundwater pollution.  Arizona
is also currently implementing a new permit program that requires
farmers to adopt BMPs.

State Programs

Nebraska     The  Central  Platte NRD has established an aggressive
three-phase  program  to control nitrate concentrations  in ground
water, which is the primary drinking water source for  all residents
within the  District.   The program  is  divided  into  three phases
depending  on nitrate  levels  found  in the  Districts monitoring
wells:  Phase I,  12.5 ppm; Phase  II,  12.6 to 20 ppm; Phase III, 20
ppm.

     Most of the District currently is in Phase I which emphasizes
voluntary deep soil and  irrigation water sampling for nitrate to

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determine the  amount of carry-over available to  the crops.  The
only  regulated  action under  Phase  I is  the  banning  of fall
applications of commercially applied nitrogen fertilizer  on sandy
soils.

     Phases II and  III place more regulatory controls on farming
operations  in  those  areas of  the  District with higher nitrate
levels are  found.   In Phase II areas  (currently 500,000 acres),
farmers are required to have an annual nitrate water analysis for
each  irrigation well,  an  annual deep  soils  analysis,  delayed
applications of commercial fertilizer, and required attendance at
District-approved  educational  programs designed to  explain  the
hazards of nitrogen contamination and provide techniques to  reduce
nitrogen usage.

     Phase  III  controls  have  not  yet  been  triggered  in  the
District.  When nitrogen levels reach the Phase III threshold, both
Phase I and Phase II restrictions continue, and additional controls
on commercial nitrogen fertilizer would be implemented.

     Nebraska's approach to controlling nitrogen use is influenced
by several  factors  generally not found in  other  states:    strong
local regulatory authorities (NRDs),  a  relatively  dry climate with
little risk of wet soil conditions preventing a split application
of  nitrogen,   the   availability  of  a  reliable  soil  test,  and
relatively little legume crop acreage which is a more difficult N
source to measure.

Arizona          The  Regulated  Agricultural  Activities  Program
established under the Environmental  Quality Act of 1986 requires
farmers  to use  N  management BMPs  as a  condition of  a  general
permit.  If farmers violate the  general permit by  failing to adopt
BMPs, they can  face  enforcement actions or be required to apply for
an individual permit which  can contain stringent  stipulations.  The
Program establishes general goals for best management practices for
nitrogen  fertilizer and  animal feeding operations.    The  goals
require farmers that apply fertilizer to use application, timing,
placement, irrigation, and  tillage practices  that minimize nitrogen
loss.  Farmers  choose the specific practices needed on their farms
to achieve these goals from  the Program handbook.   Concentrated
animal feeding operations are required to collect, stockpile,  and
dispose of  manure;  control and dispose  of  nitrogen-contaminated
water associated with large  storms;  and close facilities in ways
that minimize discharge of nitrogen pollutants and  are economically
feasible (Munson and Russell, 1990).

Wisconsin   In Wisconsin,  livestock  operations  too  small  for
permitting programs are nonethelf  3 subject to regulation,  but only
if someone  complains that such   Deration causes  a water quality
problem.  Complaints lead to a visit by an environmental expert and

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an  agricultural  expert.   If an  actual problem  exists,  fanners
become eligible for a 70 percent cost share grant, which according
to  a Wisconsin  Department of Agriculture,  Trade, and  Consumer
Protection "Status Summary" (January 12, 1990), they have elected
to receive in half of the verified complaints.   A  fourth of farmers
address the problem at their own expense. Another 10 percent await
possible judicial action.   (Action was not required for the balance
of the cases).

     Actual regulation  is  difficult under  the Wisconsin program,
because, unlike the programs described for other states, the farm
in question must be the cause  of a problem.  Most programs require
farmers  to follow  certain practices,  rather than  establishing
blame.  However,  the Wisconsin program targets a perceived water
quality offender, offering the  program the advantage  of  a sharp
focus.  Also, even this program's very  modest threat of regulation
has led to remedial  action by  the implicated farmers in 90 percent
of the  complaints.   Complaints generally are  limited  to surface
water problems, which are more visible  than ground water problems.

Toxic Substances  Control  Act      EPA has broad authority under
Section  6  of The Toxic  Substance  Control  Act  (TSCA)  to require
farmers to adopt  specific  best management  practices for nitrogen
fertilizer application.  Section 6 gives EPA the responsibility to
control manufacturing,  processing, distribution in commerce, use or
disposal of a chemical  substance or mixture if it  "presents or will
present  an   unreasonable  risk  of   injury   to   health  or  the
environment."  If EPA finds that there is a  reasonable basis to
conclude that the  use of nitrogen  fertilizer presents  or  will
present an unreasonable risk, it may promulgate rules prohibiting
or otherwise regulating any manner or method of its commercial use
(TSCA §6 (a)(5)).  Such rules  could, for example, condition use of
fertilizers  in compliance with  farm  level  nitrogen  management
plans,  use of  soil tests,  and  adoption  of  a  variety  of  best
management practices,  including  volume and  seasonal  application
restrictions,  fall  cover crop  planting  requirements to  limit
leaching  and  education/certification  requirements  for  farmer-
applicators.  They could also include requirements for fertilizer
dealerships such as handling,  storage  or disposal requirements, to
protect against risk from  spills or dumping.

     Under Section  4 of TSCA, EPA may require industry to test a
chemical substance  or  mixture if  the  Administrator finds that it
"may  present an  unreasonable risk of injury to health  or the
environment."  If EPA decides that it lacks important information
about toxicity or exposure with regard to nitrates, it can specify
what  information the  industry must provide,  through  additional
testing if necessary.

     One of the goals of EPA's chemical control program under TSCA

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is to encourage greater product stewardship.  EPA has been actively
working with  chemical companies,  trade associations,  and other
interested constituencies to encourage safer handling of chemical
substances and mixtures throughout their life cycle.  Fertilizers
containing nitrates clearly fit in this category.  The Agency could
consider  both  regulatory  and  non-regulatory  means  to  promote
greater care  of such  substances  in their manufacture,  use,  and
disposal.

Agricultural Drainage  Wells    Unlike cropland without artificial
drains,  EPA  has  regulatory  authority  over  wells  that  inject
directly into ground water.  Agricultural drainage  wells  (ADWs) are
regulated  by  EPA  under  the  Safe  Drinking  Water Act. They  are
considered  Class   V   underground   injection   wells.     Current
regulations authorize  these wells to operate by rule if  1) their
existence was reported to  the States or EPA within the specified
time  and   2)  they do not  contaminate an underground  source of
drinking  water to  the extent that  it would  violate  an  MCL or
otherwise endanger public health.  Most ADWs were not reported.  An
EPA workgroup has been formed  to develop more specific regulations
and guidance for Class V wells.

     In the 1987 Report  to Congress  on Class V wells,  only 1,338
ADWs were reported nationwide. This  figure grossly underestimates
the number of ADWs.   For example,  one Idaho study reported 2,000
wells on the east Snake River plain alone.   Iowa  initially reported
only 230 wells, but now estimates that about 690 exist.

     Various options have been suggested to control contamination
of ground  water from  ADWs.  The most  drastic  remedy would be to
close  the wells.   The  land  could  continue  as cropland  with  a
concomitant decrease in yields or be converted to wetlands either
through easements  or   eminent domain.   Funds to  buy  significant
amounts of land would be very difficult to obtain.  Land drained by
ADWs  in the Iowa study was valued at $3,000 to  $4,000  an acre.
Alternate  drainage  to  a   surface  water  discharge  is  also  a
possibility.    This  option could  adversely  affect the  surface
waters.  Estimates of the cost of providing the drainage range from
$100 to $440  (1983  dollars) an acre  depending on  the  distance to
drainage facilities and the need  for  pumps.  Use of fertilizer and
leachable  pesticides  on  the drained cropland  could  also  be
proscribed.

     An option under consideration in the current effort to develop
Class V regulations is  mandating the use of BMPs to decrease use of
agricultural chemicals on 1) all land drained by the ADW or 2) just
land  near the  well.   BMPs  are  effective  when employed  on  all
drained land.   When BMPs  are only used on land  adjacent  to  the
well, nitrate contamination is decreased only by the percentage of
the total acreage affected.

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     Other  strategies  exist  for controlling  contamination  by
surface water runoff  into  ADWs,  but  they would not significantly
affect the level of nitrate in the wells (Baker, et al., 1984).

Nurseries and Greenhouses

     The Texas Water Commission has written permits for four large
wholesale nursery operations  in  east Texas  in response to public
complaints.     The operations  need  not be  discharging  from a
discrete conveyance in  order for a permit to be  required.  Host
discharge from these operations occurs during storm events and in
cases where discharge occurs through sheet flow,  the  agency may
require that some conveyance be built which could then be monitored
(Holderread, 1990).

     The permits, in addition to prohibiting detectable pesticide
discharge, contain limits on the  discharge of ammonia and nitrate.
The  limits  are  set  on a  site-specific  basis,  depending  on the
designated uses of the stream receiving discharge.  One operation
for which the Commission wrote a permit  was  a 480-acre tree farm
and other horticultural specialties operation.  On this operation
there were  three distinct  point from which  discharge occurred.
Another operation for which a permit was written was in the process
of developing a slow-release nitrogen management plan.  Monitoring
data is typically required on a quarterly basis.

     Wastewater  from  greenhouse  operations  may reach  surface or
ground water in  a variety  of ways—underground injection, direct
discharge to surface water, discharge to  a POTW, or percolation to
ground water—depending on  the design of the greenhouse.  Injection
into a well can be controlled under SDWA.  In addition, it should
be   possible   to   regulate  some   greenhouses—those   with  a
"discernible,  confined, and discrete conveyance"—under the NPDES
program (though the exemption of  irrigation return flows under CWA
may pose  a  legal question).   EPA may need to  provide technical
assistance to the States in developing permits  for greenhouses.

     Greenhouses discharging to POTWs may in some cases be required
by the POTW to pre-treat, but it is not known to what extent such
requirements are in place.   Pre-treatment requirements are  often a
function  of the size  of  a  POTW—large POTWs tend to   require
pre-treatment more often than small ones.   However, even with large
industrial  discharges  to  POTWs,  nitrate  levels are  rarely a
criterion in pre-treatment.

     Greenhouses allowing percolation to ground water present a bit
of an anomaly in terms of the source/non-point source break out of
pollution sources.    While not  a  point  source in the  sense of
discharging through a  pipe  or  other conveyance, many  of these
operations are very small—greenhouse operations nationwide average

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two-thirds of  an acre (White,  1989).   Best management practices
that are suitable  for greenhouse operations should be developed.
Design  criteria might  also  be developed  and  approved  by EPA,
concerning siting, irrigation systems, and water re-use.


                    Livestock Waste Management

     In  many  regions  of  the  country  dominated  by  livestock
agriculture, livestock wastes pose the greatest  threat to water
quality.        Pollution   prevention  from   livestock   must  be
comprehensive  to prevent  water quality degradation from the most
significant polluters, regardless of whether they are large-scale
feedlots which may be issued permits  as "point"  sources or more
numerous small operations traditionally unregulated  as nonpoint
sources.

Concentrated Livestock Facilities

     In addition to the diffuse source impairments described above,
runoff from manure and wastewater accumulated  in the feeding areas
of  many livestock operations  may  be covered  in the  National
Pollution Discharge Elimination System (NPDES) program. Under this
program, operators of concentrated animal feeding operations must
construct a storage structure for all wastes  and wastewater that
come from the  feeding operation.5

    According to the 1987 Census of Agriculture and the USDA report
Cattle on Feed, there may be as many as 5,000 to 10,000 livestock
operations that meet the 1,000 animal unit criterion.  However, the
number of NPDES permits issued is thought to be substantially less.
To the  extent  that there  are more concentrated feedlots than the
number of NPDES permits already issued, further regulatory efforts
may be needed.

     Given  that a  potentially large  number  of  operations need
permits, the NPDES authorities  need to raise the priority of this
program and  develop a strategic approach.    The  NPDES  authority
might  consider issuing  individual permits to  only the largest
confined operations.   (A  good place to start  might be the highly
concentrated poultry industry because less  than one percent of the
laying hen  producers account for 45 percent  of production and less
     5A concentrated animal feeding operation is defined as having:
1) more than  1000  animal  units (equivalent to 1000 beef cattle);
2) more than 300 animal units and a discharge directly into surface
waters; or  3) operations  with  fewer than 1000 animal units which
are determined through regulatory procedures (40 CFR Part 122.23
(c)) to cause significant water quality impairment.

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than one percent of the broiler producers account for 60 percent of
all broilers.)   The  remaining  universe of  concentrated feeding
operations could be covered by general  permits.  A general permit,
which outlines  certain  manure management  requirements,  could be
issued to all facilities in a certain geographic area.  Compliance
with the permit  would be up to the feedlot owner/operator, however,
if  the  facility  is  found  to be  discharging  outside  of  permit
conditions,  a notice  of violation  would  be issued and  a  remedy
would be sought.

     The NPDES  authority should  also  consider working  with the
nonpoint source authority in the state to identify the watersheds
with  the  most   significant  water quality  problems  caused  by
concentrated feedlots.  According to preliminary Clean Water Act
§319 Assessment data,  approximately 32,706 lake  acres  and 4,827
river miles in 39 states and Puerto Rico were  impaired by feedlots.
(The  other  states grouped  all  categories of  nonpoint  source
impairments  such as  feedlots,  irrigation,  chemicals,  sediments
together in one  category under "agriculture".  Consequently, there
may  be   additional livestock impairments.)      Once  the  NPDES
authority has these watershed-specific data, the authority may then
issue an individual permit,  if  the facility is very  large,  or a
general permit  to cover all  facilities at once  because issuing
individual  permits would  be burdensome.    The  nonpoint  source
authority can also assist in the NPDES program by identifying which
operators are not meeting the terms of their permit.

     Through issuing a permit, the NPDES official requires farmers
to alter their manure management systems to meet the zero discharge
guidelines  in  40  CFR  Part 412,  the  effluent  guideline  for
concentrated feedlots.  The  nonpoint source authority can assist
farmers in seeking available cost-share assistance (either through
the USDA,  Clean Lakes Program,  Chesapeake Bay  Program,  the §319
demonstration programs,  or through various state programs) to limit
pollution potential.

Surface Water Runoff from Fields

     Several options are available to limit these forms of nonpoint
source pollution.  To minimize movement of manure nutrients from
cropland and pastures  into surface and  ground  waters,  farmers
should consider crop nutrient needs, the nutrient value of manure,
as  well  as  other sources  of nutrients  (commercial  fertilizer,
legumes, and sludge)  when  applying manure to cropland.   Proper
storage, testing of manure,  and calibration of spreading equipment
should be encouraged (either through regulation, education, cost-
sharing or a combination of these measures). Where manure supplies
exceed nutrient  requirements of the crops, given the extent of land
area to  be covered, composting  or exporting of  manure  to other
areas should be pursued.

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      To limit: stream and pond disturbance due to direct access of
livestock  to such  waters,  fanners  could install  electric high
tensile wire fences  along streams and provide environmentally sound
stream crossings.  Currently,  the Pennsylvania Game Commission and
the USDA Agricultural Stabilization and Conservation Service  (ASCS)
are working  together to promote  the use of solar-powered tensile
fencing to minimize maintenance,  because traditional barbed wire
fences accumulate a great deal of debris.

     To aid in keeping livestock  out of streams, alternative water
sources such as spring-fed watering troughs could be  installed.  In
Maryland, the EPA Clean Lakes Program provided funds to demonstrate
that installing  these  water  sources will reduce animal trampling
along streams  and  ponds  because the cattle prefer  to  drink from
troughs.  These  troughs are  encircled  with wide concrete pads to
further reduce runoff  of sediments and manure.

     Furthermore, researchers  at  several land  grant universities
are  investigating  the effectiveness  of rotating   cattle  among
several smaller  sized  loafing  areas to allow vegetative cover to
regenerate.   By enhancing vegetative  growth,   farmers  can  limit
runoff of  manure and  sediments to  streams.  Similarly,  the Soil
Conservation   Service   (SCS)   together  with   the  land  grant
universities have developed small-scale intensive grazing systems
to  segment  and more effectively  manage grazed pastures.   These
systems maximize forage  production to  meet livestock  management
needs, while also providing fallow periods which allow pastures to
regenerate.

     To limit  the  concentration  of nitrogen  in manure,  farmers
could reduce the nitrogen content of feed for  livestock and more
closely calibrate the  nutrient content of feed to the nutritional
needs of  the  livestock.   This  approach has been  taken in  the
Netherlands, both regarding nitrogen and phosphorous  as a pollution
prevention technique.

     Another method which can be used in conjunction with each of
the management practices described above is to install gutters and
adequate drain  pipes  around all  barns and  machine  sheds.   This
practice keeps clean water, clean and can be extremely beneficial
during heavy rain storm events.

Ground Water
     Many feedlot  management techniques can also  be  employed to
reduce the  threat of contamination  from manures.  They include
altering the  animal  stocking rate and  density in a  given area,
removing manures  from holding areas and  applying  to  neighboring
fields and pastures at appropriate fertilization rates to account

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for differences  in  soil  types  and crop needs (Patrick,  Ford,  and
Quarles, 1987).  Keeney (1986)  reported that nitrate leaching from
land application of manure can be  controlled  by denitrification
through managing readily degradable organic material.    Farmers
should test manure as well as account for nutrient demands of the
crop and the type of soil receiving the application.   The farmer
should also be aware of  how  specific conduits,  such as sinkholes
and abandoned wells, can affect local manure management.

     Guidelines  on  animal waste storage  ponds  and manure storage
management need to be developed and implemented consistently across
NPDES, the  SCS  programs, and  states,  while taking  into account
variations  in geology,  hydrology,  and soils.   To  minimize  the
threat  of  leaching,  the  staff  recommend  using  a  liner  of
recompacted clay eighteen  inches  thick.   It should  extend up to
cover all  exposed sand  layers.   If the storage  pond  is located
within 100 feet  of a drinking water well, further precautions may
be necessary.   In those instances  where a liner  is not needed,
siting the ponds in areas with low-permeability natural materials
is crucial.  These materials  should "not  allow more than about 300
gallons of  leakage per  day  per  half  acre of  lagoon"  (Chesney,
1990).

Implementation issues

NPDES Program    The NPDES program for feedlots  appears to be a low
priority given  NPDES efforts  to  control other  industrial point
sources.   However,  to  the  extent  that the  NPDES program  for
feedlots is implemented, great care must be  taken to ensure that
storage structures  required  under NPDES do  not encourage ground
water contamination.

     The NPDES program also  should be evaluated to determine the
extent to which  permits  issued under this program cover not just
storage but  also  land  application.    To the  extent  that  land
application controls are not included  in permit,  EPA may need to
revisit the NPDES program and effluent guidelines to identify how
this practice could be included.

Policies Regarding  Farm  or Regional Manure Surpluses  The recent
trend  in   livestock   production   has  been  toward  large-scale
concentrated feeding/production operations.   This trend is driven
in part by  economies  of  scale which states:   as  the size of the
operation increases, the per unit cost of production decreases.

     Options for managing farm and regional imbalances of livestock
waste are limited by economics.  Because manure, particularly dairy
waste, is  very bulky and heavy  due to  a  high moisture content,
affordable  opportunities for its  large-scale  transport to other
farms or even to central  processing facilities  is  limited.  Should

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an economical market be available for using the manure as an energy
source  (either on-farm  or  for regional  use) or  composting the
manure for commercial application,  this problem would be reduced.

     Recent projects show promise, however.  For example, Clevenger
and Kraenzel identified wholesale garden uses,  retail  garden uses,
and  agricultural  uses  for  7,200  tons   of   manure  that  would
accumulate annually  as a byproduct of  utilizing the manure  in a
large-scale  methane  plant  in New Mexico.   Further  research is
needed in the areas of drying or composting the manure on site to
reduce volume and weight.

Runoff and Infiltration  from Land  Application of Properly Stored
Livestock Wastes   While the NPDES program is useful  for shifting
manure from unmanaged piles into controlled storage structures, no
farmer is specifically required to undertake further BMPs to manage
these wastes once they have been taken  out  of storage.  Therefore,
farmers may encourage runoff and leaching of these wastes if they
apply them to cropland at rates that are in excess of crop uptake
or during the most environmentally unsound times of the year (e.g.,
winter).

     Even if  off-farm  export of manure is  not required to adjust
for  farm-level  manure imbalances,  farmers  can undertake several
options to control runoff from their operations. First, the farmer
should test  the soil  (where possible)  and  the manure, as well as
identify the nutrient value  of legumes to determine how much manure
and commercial fertilizer to apply.  When applying the manure, the
farmer should attempt to incorporate it immediately into the soil
in order to  prevent  runoff.  Furthermore,  manure should never be
applied to land if no crops  will be grown.   To  avoid nutrient loss,
other basic  handling guidelines include 1)  never leave stored or
piled  wastes  uncovered,  2)  never pull  spreaders  across  muddy
fields, 3) never  allow manure to  ferment  in warm weather,  and 4)
never spread manure on snow, steep  hillsides, banks along streams,
ponds,  or on farmland  adjacent  to  wells   (Pennsylvania  State
University, n.d.).

Regulatory Programs      A  regulatory program to control  N  from
manure should  focus  on the  total management of animal wastes and
wastewater.   In addition,  storage  of wastes,  land application of
wastes, and management of cattle around streams  and  other waters
must be considered.   The regulatory program  must  also encompass
both ground and surface water protection. To achieve this goal, the
NPDES  program must be  amended  to go  beyond  mere surface water
pollution through a conveyance and  from  large-scale facilities.
Other regulatory  programs beyond the NPDES program could also be
proposed.

     The modelling applied  by EPA's Region 6 ground water program

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should be considered when designing storage structures.  EPA should
ensure  that this  methodology is  consistent  with  other  federal
efforts,  i.e.,  SCS technical assistance.  Furthermore,  given the
large number of facilities which may need to manage their manure,
the regulatory program must  be targeted,  beginning with the most
environmentally unsound facilities.

Incentive-Based Programs       Managing manure presents  a doubly
difficult situation.  Many facilities need to alter their storage
and management practices and most storage and management practices
require a relatively  large-scale capital  investment.   How should
EPA, the states, and USDA proceed?  First,  we need to evaluate what
our previously  spent  resources have achieved, i.e,  Clean Lakes,
Chesapeake Bay, Agricultural Conservation Program (ACP) cost-share.
Then,  we need  to  identify where  further voluntary  cost-share
efforts,  if warranted,  should  be  targeted.   One  criterion for
targeting could be §319 data on livestock related impairments.

     Given the trend toward large-scale animal production, we need
to be identify how best to utilize surplus manure  stocks.   This
concern  could be  addressed through more research, however,  it
appears that opportunities  for composting and energy production may
be  viable   in  certain  regions.    Where  surplus  stocks  are
particularly  problematic,  water quality  managers  should become
aware of  and be prepared to address any institutional, economic,
and cultural impediments to promoting a more even distribution of
animal wastes.

                            Composting

     Composting is a  method  used  to  decompose livestock manure
under controlled conditions  into a stable humus product.   Volume
and weight reduction are achieved through  loss of water and carbon
dioxide during the composting process.  This smaller mass exhibits
an  earthy  odor,   and  can  be more  easily  applied on-site,  or
transported off-site,  compared to raw manure.  The distance which
the compost can be economically transported will  depend on the
relative value of the  compost, the distance to market, and the cost
of transport.

     By  composting manure,  the  likelihood of  rapid  release of
nitrogen from the compost is reduced since the more  available forms
of nitrogen are stabilized or volatilize during composting.  When
compared  to raw manure and  most  fertilizers, composted manure
slowly releases nitrogen since almost  all of  this  nutrient is in
organic forms.  The organic nitrogen must be converted to inorganic
ammonium  and oxidized to  nitrate  to become available  to crops.
This conversion leads to a slower  release of  nitrates.  There is
also a reduced potential leaching of nitrates as crops utilize the
nitrogen as it becomes available.  However, the relative impacts on

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nitrate leaching and crop yields have not yet been fully determined
for annual applications of composted and uncomposted manures.

     Chicken carcasses, in particular,  are  the subject of research
into composting.   The  Delaware Cooperative Extension Service has
developed recipes  involving the use of whole chicken carcasses in
order to generate  a compost product.

                      Agri-Chemical Dealers

     Some  states currently have  or are considering regulations
dealing with fertilizer storage at dealerships,  however there are
no  federal guidelines  or regulations.    California,  Wisconsin,
Kansas,  and  Iowa  all have   bulk  fertilizer  containment  laws
(Simmonds, 1990).

     The  National  Fertilizer  and  Environment  Research  Center
(NFERC) of the  Tennessee Valley Authority  (TVA)  has developed an
information and education program for fertilizer dealers to ensure
improved   environmental   performance.      20   model   facility
demonstration sites are planned nationwide to demonstrate practices
and technologies that  are workable, cost-effective, and  able to
meet  state  regulations.    NFERC  has  also  designed  a  self-
administered environmental checklist.   It  will  also conduct site
assessments of  facilities for a $3,500 fee.

     NFERC has recognized that dealers are reluctant to spend money
to upgrade their facilities especially when this action might put
them  at a  competitive disadvantage with  other dealers  (NFERC,
1990).  Federal regulations of  fertilizer dealers would eliminate
this constraint.

                        European Programs

     High levels of  nitrate in water as a  result of agricultural
activity became a major environmental  issue  in Europe with the
enactment of the European Community (EC) Drinking Water Directive
in 1980.   The directive set regulatory  limits  for contaminants,
including  nitrate, in  drinking water  to   be  achieved by  1985.
Eutrophication  of  the  North  and Adriatic  Seas,  in large  measure
from  nitrate  transported  through  aquifers to  surface  waters,
created a demand for broader  protection than  necessary solely to
protect drinking water  supplies.  60 percent of the nitrate loading
to the  North  Sea has been estimated to have come  through ground
water (Deutscher Bundestag.  1990).   Nearly  every country in the EC
was not in compliance with  the  directive and began  developing
initiatives to protect existing and potential sources of drinking
water from agricultural activities.  European programs offer models
for U.S. policy since  they differ considerably  in  design  and the
degree to which they have been implemented.

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     Unnaturally heavy loadings of  nitrate  and ammonium into the
environment  have  been  a  byproduct  of  European  agricultural
productivity (von Weizsacker, 1989).  In  Denmark, 6 percent of the
population receives  water above the drinking  water  standard and
this  number   is   rapidly  increasing  (Institute   for  European
Environmental  Policy,  1989).  In West Germany, five  percent of
delivered drinking water exceeds the standard  (Merkel, 1985).  Two
percent of population are exposed to levels above the standard in
France (French Ministry of Agriculture, 1988) .   In the Netherlands,
average nitrate concentration of 106 mg/L are found in ground water
at 30 meters below sandy soils.

Nitrate Policies in the European community

     The European Commission recognizes the limitations of member
state programs  and the necessity  of establishing a level playing
field with regard to  agricultural competition within the EC.  Water
suppliers have been reluctant to invest in denitrification plants,
governments have been reluctant to impose controls on farmers, and
control strategies have been politically  sensitive.  Member states
with  strong  environmental advocacy organizations,  such  as West
Germany, the United Kingdom,  and the Netherlands, have taken steps
to  implement  controls  on  agriculture to  protect ground  water
resources, but,  in  so  doing, have  put  domestic producers  at a
competitive disadvantage with producers in other member states with
weak environmental advocacy  groups  and hence  weak enforcement of
environmental protection.

     Drinking water purveyors and environmental organizations have
urged the EC  to promulgate a directive to  control nitrate pollution
to  ensure  fair  competition  among   agricultural  producers  in
different  member states  (Merkel,  1985).   The  draft  directive,
expected to be promulgated in 1991,  proposes to require  Members to
establish nitrate sensitive  zones (both surface and ground water)
and establish  rules  for  good agricultural  practices  within those
zones  (Baldock,  1989).    The  rules  govern   livestock stocking
densities, storage and application of slurry, application rates and
practices  for  fertilizers,  nitrogen emission  limits  from sewage
treatment  works,  and  record-keeping for  the  zones  covering
fertilizer use, manure application,  livestock densities.   All EC
governments will be obliged to designate  vulnerable zones within a
period of two years.   Controls will need to be in place within four
year period.

     EC environmental policy embodies two key  principles.  1)  The
generator of the pollution (including farmers)  is held responsible
for the costs  of preventing and eliminating nuisances, with some
exceptions.  2) Efforts should be made to prevent pollution rather
than expending resources  to  treat the contaminated water (Office
for Official Publication  of  the EC,  1987).

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     In addition, there are attempts change agricultural policy to
bring it into harmony with environmental policy.  A draft directive
allows member states to  pay farmers to be multifunctional and to
de-intensify and to extensify production.  In other words, farmers
would  be  compensated  for  adopting  practices  that  are  less
ecologically harmful.  Finally,  there would be  a  tax on fertilizer
to pay for education and outreach and where possible to dissuade
farmers from certain activities  (Manale, 1991).

     The EC  system implicitly incorporates  an  important watchdog
role   for   non-governmental   organizations   (NGOs),   such   as
environmental  advocacy  groups.     If  a  member  state  fails  to
implement EC directives,  an NGO in the member state may bring suit
against  the  offending government.   As part  of  the  remedy,  the
government may  be forced to  detail how it will  comply  with the
European Community Directive to the satisfaction of the plaintiff
(Office for Official Publications of the EC, 1987).

Programs of Key Individual Member States

     Certain guiding principles underlie the nitrate strategies of
all key member states.  The supply of nutrients during the growing
season must  conform  to crop requirements, with an allowance made
for the  soil nitrogen.   There  must be utilization  of  residual
mineral  nitrogen through crop  rotation and proper  selection of
crops.  The measures for  achieving reductions in  ground or surface
water  loadings  must be  adapted  to specific  localities  (United
Kingdom Ministry of Agriculture,  1990a).  The major differences of
the programs lie in the manner in which these principles have been
incorporated into control strategies and the differing emphases on
voluntary and education measures as opposed to regulation.

The United Kingdom   The government water authorities and private
water companies are  drawing up individual programs for compliance
with the standards.  These plans, which may include changes in land
use  practices,   denitrification plants,  and  blending  of  water
supplies, are submitted  to the  Ministry  of the Environment for
approval  (United Kingdom Ministry  of Agriculture,  1990b).   The
Ministry evaluates the effectiveness of these plans with computer
models capable  of  simulating nitrate  leaching  and movement to
ground water.    The models  estimate  whether  existing  land  use
practices in the catchment will  lead to exceedance of standard and
how much reduction in leaching is necessary through a reduction in
the intensity and area of arable cropping and an extensification of
grassland management fWasserhaushaltsgesetz. 1986).

     Plans  for   fertilizer  control  have  been  proposed only in
"nitrate sensitive areas," where the standard is being exceeded or
is at risk of being  exceeded  (Baden-Wuertteroberg Ministerium fuer
Umwelt.  1989,  1987).   The program is voluntary with  financial

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incentives.  Compensation occurs where restrictions go beyond good
agricultural  practice.     Additional  funds  are  provided  for
converting some or all arable land to unfertilized grass or trees.
As  of August 1990,  62  percent of the farmers in the  NSAs have
applied to join the scheme  (Schnepf,  1989).

     Good agricultural practices relate to the amount and timing of
application of organic and chemical fertilizer, storage of manure,
tillage  practices,  consideration  of  nitrogen  content of  green
manure, maintaining a cover crop, and record-keeping.  Farmers have
to comply with limits on fertilizer application so as to be at or
below the economic optimum  levels.

West Germany     For the area-wide scale protection of ground and
surface waters,  the federal government has developed,  and will soon
issue,  a regulation to  control  the use  of  both organic  and
inorganic fertilizer.  It  will  govern how much can be applied to
what crops when and where,  treatment  of green manure, and breaking
of new land.   It will also  stipulate  best management practices and
record-keeping for both inorganic and organic fertilizers (Manale,
1991).

     Lander (German provinces) are encouraged to develop wellhead
protection areas  (WHPA) to protect drinking water quality.   Each
Land may have a  different  program for controlling the activities
within  a WHPA.   Lander governments have  the  authority to  pay
farmers or to buy filter strips  along key surface  water systems to
reduce  ecological impacts  (Manale,  1991).    In  the Hessen,  for
example, there is a  law  requiring five meter filter strips along
all major waters.

     In Baden-Wurttemberg, which covers an area of karst geology,
farmers  with  operations located within  WHPAs are paid to  adopt
agricultural  practices  that  minimize   the  risk  of  leaching
(Schrifenreihedes	Ministers   fuer  Umwelt.   Raumordnumg,und
Landwirtsch.flft  des  Landes  Nordrhein-Westfalen.  1989).     Best
management practices specify maximum  amounts of nitrogen that can
be applied given the crop and soil  type.   These maximum amounts
incorporate  a  20  percent  reduction in  the  economic  optimum
fertilization rate to account  for uncertainties in weather and soil
that  affect  the  likelihood  of   leaching.     In  return  for
compensation, farmers are required to test their soil twice a year
to prove that the amount of mineral nitrogen  remaining in the soil
falls under limits determined by the Land government.   There are
also limits on  the  number of animals  that can  be kept given the
amount of land to which the manure can be applied.   The state is
involved  in  conducting  over a  hundred thousand soil tests  to
establish a baseline estimate  of nitrogen in the soil.  The cost of
the program is financed by  a Wasserpfenniq—a water penny—that is
born by the water consumers.  Responsibility  for actually carrying

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out: the paying fanners and monitoring their practices is given to
the  municipal  water  authority.    Participation  is  mandatory
(Schriftenreihe  desMinisters   fuer  Umwelt,   Raumordmimg  und
Landwirtschaft de Landes Nordrhein-Westfalen. 1986).

     In North  Rhine Westfalia,  the municipal water authority is
required to negotiate with farmers to  reduce agricultural chemical
use  (Niedersaechsisches  Gesetz  und Verordnungsblatt.  1990).   In
many cases, the municipal  water  authority has bought farmland to
meet  this requirement  and  then leased  it  back  to  the  farmer
stipulating management practices.   The Land  helps facilitate the
agreements and has  also  helped  in the development of markets for
manure  (Hanale,  1990).    In areas  outside  of  WHPAs, the  Land
government has issued regulations  governing the  application of
manure on agricultural land  (Manale, 1991).

     In Lower Saxony, limits on the number of animals or kilograms
of nitrogen  per hectare per year have been  imposed,  along with
restrictions on  timing  and  application of manure  and a  ban on
application after harvest  (French Ministry of Agriculture,  1988).
Authorities also  encourage  nitrogen  soil  testing but it  is not
being used as a tool for assuring compliance (Lida van der Kley and
Graham Bennett, 1988).

France     Until  recently the programs  have  been almost  entirely
educational.  The major exception is a restriction on the size of
livestock operations in water catchment areas. The aim has been to
provide farmers with better  information with regard to the input
needs and the environmental consequences of agricultural practices.
Nitrogen   soil  testing has been  promoted  as  a key  pollution
prevention tool.  Local authorities, for example,  have provided on-
site analyses  of  mineral nitrogen content of soils.   Provincial
governments have established  a program of wellhead protection based
upon pathogen travel time.  Compliance within  these  zones, with the
possible exception  of livestock operations, has been voluntary.

The Netherlands      Three main laws relate to agricultural activity
and  ground and surface  water protection  (Willems,  1987).   The
first, passed  in 1984, restricted the expansion  of the number of
pigs.  The second,  the Soil Protection Act puts limits on how much
manure can be  applied to land,  given  the  soil  type,  establishes
criteria for identifying  areas where the soil has  been contaminated
with excessive  levels of  phosphates  from manure and  upon which
fertilizer can no longer be  applied,  requires regions  to draw up
ground water protection plans, and establishes wellhead protection
areas.  The  third,  the  Fertilizer Act, imposes  a  levy on  animal
waste  above a certain  stocking  ratio—measured  in  terms  of
phosphate per hectare per year.

     A parallel effort  of  the Ministry of Agriculture are pilot

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projects to determine the economic feasibility of treating manure
such that  it  can be eliminated  (Willems, 1987).   There are also
pilot projects in recordkeeping and chemical mass balance, in which
farmers  are taught  to calculate  the chemical  inputs  for  farm
operations and the percentages of these chemicals in the outputs,
to estimate  the  fate  of  what is not  accounted  for, and  how to
minimize these undesirable residuals (Manale, 1991).

     For area-wide protection, the  general  protection plan is to
phase  in reductions in manure  applied  to  soil   (as  measured in
phosphate) will  be phased  in by  the year  2000.    The official
estimate is that there will  be a  three  to five million tons excess
of manure  by 1992, not including  the excess  resulting from the
impending  ban  on  manure  that  can  be  applied  to  phosphate
contaminated soils (European Community, 1989).

     The well head protection program  is much like that of Baden
Wurttemberg, requiring certain agricultural practices in exchange
for compensation.   Protection zones constitute about 4.5 percent
of total area of  Netherlands.    Fanners  in WHPAs are compensated
for the  adoption of manure  regulations  that  exceed the general
protection plan according to  rates  agreed  upon by the Farm Union
and the  Ministry of Agriculture.   Depending  upon the province,
either municipal  water purveyors are responsible for compensating
farmers  and for  increasing consumer  water  rates to  cover the
increased costs or a provincial levy is imposed.  This occurs only
when provincial authorities apply more stringent rules to the use
of nitrogen fertilizers (Manale,  1991).
                          Septic Systems

     Septic  systems do  not function  as a  pollution prevention
practice  for nitrogen  since  they have  traditionally  not  been
designed to remove nitrogen from the effluent.  Appropriate siting
and spacing  of  systems  through land use  planning,  to dilute the
nitrogen  in the  effluent, may be the  only  practical  approach
currently available to protect  drinking water.

     The septic tank converts organic nitrogen to ammonium which is
in turn converted fairly rapidly to nitrate in the soil.  The only
practical  way to  remove  nitrate  from the  soil is  through the
denitrification process.   Denitrification occurs under  anaerobic
conditions when an adequate carbon  source is available to provide
energy for the bacteria.  Because of the  aerobic  conditions in the
unsaturated  zone,  appreciable  amounts of  denitrification  do not
occur in most traditional  septic systems.

     Many  different  researchers  have  been  trying  to develop
engineering  methods to  increase the denitrification potential of

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septic systems by providing both an aerobic  environment for the
nitrification of the ammonium to  nitrate and anaerobic environment
to encourage denitrification of nitrate to nitrogen gas.  A source
of carbon is added in some designs.  Removal of total nitrogen can
reach  between 70 and  95  percent  in these  innovative systems
(Cochet,  1989).    However,  they  are generally not  considered
practical  for widespread  commercial  application because  of the
expense  of installation  or  operation  and maintenance  problems
associated with the system design (Rock,  1990).

     It  is  possible to augment  the natural vegetation and plant
additional trees or nitrogen demanding crops above septic  fields to
take up some ammonium or nitrate  and therefore reduce ground-water
contamination.  Natural vegetation on the  site will have  little or
no impact  on  the amount  of nitrate  taken up.   The  results vary
greatly  depending on  the  plant species and  the  distance from the
field  (Ehrenfield, 1987).

     In  the  absence  of  engineering  or  technical  solutions  to
nitrogen removal  from septic  system  effluent, the only practical
option for local  communities and states to protect water quality,
where sewers are  not economically feasible,  is to set minimum lot
sizes to allow for the dilution of the nitrate  in  the ground water.
10 states  have  set minimum  lot  sizes  ranging from  .23  acres in
Montana to 1.84 acres on lake front property in Minnesota (Yates,
1985).

     Minimum lot sizes are also established by localities, although
it is very difficult to make the determination of appropriate lot
sizes  based  on   water  quality  considerations.   The Cape  Cod,
Massachusetts town of Pembroke has established a minimum lot size
of one acre.  Its goal is to limit the downgradient nitrate level
to 5 mg/L.

     Nelson  (1988)  developed a model to  predict the  minimum lot
size needed to meet the 5  mg/L standard.   He broke sites  into four
basic classifications (soil type, slope, etc.)  and compared them to
the  occupancy rate.   The  lot sizes  needed to meet  the standard
varied from .08 acres with 2 person occupancy and a very  favorable
recharge environment to 5.9 acres for ten person occupancy and an
unfavorable environment.  The biggest variable in determining lot
size  was  the occupancy  rate.  Since local  governments  cannot
realistically limit occupancy of a  residence,  Nelson recommended
that planners be conservative and assume two people  occupy each
bedroom.

     The Waquoit  Bay  Land-Margin Ecosystem  Project,  through EPA,
National Science  Foundation, and National Oceanic and Atmospheric
Administration funding, is developing a  computer-based  tool and
handbook for  local  authorities'  use to predict  impacts  on water

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quality based  on land use decisions.  This  four  year project is
critically  important  for  increasing  local  awareness  of  the
interconnection  between  land use  and  water quality  and  to give
local officials practical tools to make reasoned judgments.

     Historically,  states  and  localities  have  based set  back
distance regulations based on structural engineering considerations
rather than water quality concerns. Of  the 38 states that have set
back requirements, 21 set the minimum at 100 feet  (Kreissl, 1989).
Host of  the other state had  50 foot  requirements.   Ford (1980)
determined  in  a  statistical  analysis of  well water data  in  a
Colorado study that  a distance of 100 feet  had a probability of
nitrate contamination of 21.8 percent and a 200 foot set back had
a probability  of nitrate contamination at  9.4 percent.   At 200
feet, the minimum lot size would be two acres.

     Replacing agriculture  with  unsewered  development will not
markedly reduce  nitrate leaching  to ground water  (Gold,  1990).
According to Gold's  model,  half-acre  zoning with a  three person
occupancy rate will make over 42 pounds of nitrogen available per
acre per year.   That amount is similar to available nitrogen from
chemically fertilized corn with a rye cover crop.

Regulation

Septage   The  septage  that  is  pumped out of septic tanks  is
regulated by EPA under §405(d)  of  the Clean Water  Act.  Septage is
generally pumped by small businesses with several  trucks that have
a capacity of about 2000 gallons.   Each truck can usually service
two septic tanks.  In February 1989, EPA proposed a rule under 40
CFR Part 503 to  regulate septage  in the  same manner as municipal
wastewater  sewage  sludge (54 FR  5796-5807).    The  rule required
septage to be analyzed for  pollutants  covered by  the regulations
and  land  application rates determined by the  maximum pollutant
concentration.   As a result of the comments received, EPA revised
its  proposal  in  November  1990.   The revision proposes  to use
hydraulic  loading rates  of  30,000 gallons  per  acre per  year
(approximately 175 Ibs. N/acre/year) (55 FR 47241).  EPA has also
proposed a requirement that a nitrogen consuming crop must be grown
when septage is applied to agricultural land, to protect ground and
surface water.

Septic Systems   EPA  has  the authority  to regulate septic systems
under the Safe  Drinking Water Act Underground Injection Control
Program (Part 144).  Septic  systems that serve single  family homes
and  those  that  are  used only  for  sanitary  waste and have the
capacity to serve fewer  than 20  people  a  day are  specifically
excluded from regulation  (40  CFR  144.7(2)).   Septic  systems are
currently authorized by rule just like agricultural drainage wells.
However, EPA is currently developing regulations to deal with this

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subclass of wells.
                           Urban  Sewage

     Municipal  treatment  plants have  several options  to reduce
total nitrogen loadings to the environment.  Pollution prevention
for POTWs can be achieved by treating the effluent or utilizing its
nutrient value through land application.

Regulation and Treatment

     conventional secondary treatment does not significantly affect
total  nitrogen in  the  effluent.    Tertiary  treatment  must  be
installed which can remove 90 to 95 percent of the total nitrogen
(Anton,  1988).   Requirements  for  such additional treatment are
imposed on a  plant-by-plant basis  as  needed to comply with State
water  quality  standards.   An  increasing  number of  POTWs  are
required  to   reduce   nutrients   (most  frequently  phosphorus),
especially those discharging into high  quality streams, lakes, and
estuaries.

     Nitrogen in POTW effluent  is generally in the form of ammonia.
About 1,000 of  the  15,500  POTWs  are currently required to reduce
ammonia in their effluents to  very low levels to protect aquatic
life.  Most of these plants reduce ammonia levels simply by using
nitrification processes which convert the ammonia to nitrate.  Only
49  POTWs are required  to reduce total  nitrogen  levels  as  a
condition of their NPDES permit.  Total nitrogen is often reduced
through enhancing the natural biological denitrification process.
90 to 95 percent of the nitrogen  can be removed with this process.

     EPA has not adopted control  policies for ammonia.   27 states
and territories have adopted numeric standards.  Ammonia controls
to meet restrictive water quality standards  can be very expensive,
especially where  denitrification is required.   Costs of ammonia
control depends on many site-specific factors including plant size,
location, receiving water characteristics,  season,  and effluent
discharge.  EPA has  estimated that for the 950 POTWs that discharge
into estuaries, annual construction and operating costs would range
from one to two billion dollars over 20 years.  (These  costs may be
overstated since they do not subtract  for POTWs that already have
denitrification in place.)   Currently  62  POTWS that discharge into
estuaries have denitrification requirements in their permits.

Land Application of Sewage Sludge

     About 2,000 POTWs  land apply  their wastewater effluent as a
part of treatment or  reuse systems.   In some cases these systems
are  designed to  replace   other  irrigation water  and fertilizer
sources, while in other cases these systems are designed to apply
the maximum amount of wastewater effluent to the smallest amount of

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land possible as a part of  effluent treatment or disposal systems.
Many of these  systems  are  designed to recharge ground water with
the treated effluent, while others include underdrains or wells for
recovery  of the  treated  effluent   for  reuse  or surface  water
discharge (EPA, 1984).   When properly sited, designed, constructed
and  operated,   land   application  systems  offer   a  reliable,
cost-effective  means   of  treating and in  many  cases  recycling
wastewater effluents in an environmentally acceptable manner and
problems  that   do  occur generally  are  associated   with  grossly
overloaded or poorly operated systems.

     The  treatment  of municipal  wastewater results  not  only in
renovated effluent, but also the production of  sewage sludge (from
conventional treatment systems) and septage (from  septic systems).
According to the National Sewage Sludge Survey, conducted in 1990,
estimated that approximately one-third of  the 7.7  million dry tons
per year  of sewage sludge  produced by  POTWs is  landfilled or
incinerated, while another third  is applied to  land in one form or
another (55 FR  47214) .  The remaining third was  disposed of through
a combination of surface and ocean disposal and marketing.  In 1984
EPA issued a formal policy promoting the beneficial use of sewage
sludge  for  use as an  organic  soil amendment  and fertilizer
supplement  when proper  treatment and management practices  are
followed  (EPA, 1984, Policy).  A workgroup of federal agencies has
been formed to  implement this policy on federal lands.

     EPA  has proposed revised  regulations for  land application
rates of  sludge.   If pollutant  concentrations  were below  a no
adverse effect  level,  the  only restriction placed on application
rates is  that  the  nitrogen  requirement  of the crop/land  not be
exceeded.  Records would not have to be maintained (55 FR 47261).

     While treated sewage sludge  solids typically  contain only one
to two  percent  (ie,  10,000 - 20,000 ppm) total nitrogen,  some
sewage sludges produced by POTWs that treat wastes from breweries
and certain other food  processors may contain 10% (ie: 100,000 ppm)
or more total nitrogen  depending in part upon the type of treatment
it receives.  For example,  'Milorganite1 is a heat dried activated
sludge product sold by the Milwaukee, Wisconsin, Metro Sanitary
District  with   a  guaranteed  5  percent  nitrogen content,  while
Madison's  digested liquid  'Metrogro1  sludge product  typically
contains about  10.5 percent  (ie,  105,000 mg/L) total  nitrogen.

Water Conservation

     Reduced flows through POTWs  from water conservation appear to
have no  effect on total nitrogen loadings in properly operating
systems.  Evidence from California suggests that overall wastewater
quality  leaving a  POTW may improve  as   a result  of  increased
efficiencies  from  reduced  flows with  the  plant.    But  these

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efficiencies do not affect the nitrogen in the effluent.
                        Industrial Sources

     Effluent  from industrial sources poses  different problems.
The Toxics Release Inventory  indicates that in 1987,  76,944 tons of
ammonium nitrate, ammonium sulfate, ammonia, and nitric acid were
discharged  directly to  water  from industrial  sources.    These
discharges  are  regulated  under  the  NPDES permitting  program.
However, the permits generally are written for ammonia releases or
total Kjeldahl nitrogen  (TKN)  releases.   In Virginia,  this means
that  dischargers  often  nitrify  the  ammonia  in  the  effluent
(Kennedy, 1990).

     For the four chemicals  cited, 19,342 tons were discharged to
land in 1987, and 123,132 tons were discharged to POTWs.

Food Processing Wastes

     Some solid or semi-solid waste from food processing operations
can be  used economically within a limited  radius as  a source of
nitrogen.   As the quantity  of N supplied  by different  types of
waste vary significantly (potato peel waste, for  instance, is quite
high in nitrogen), farmers should be instructed on how to account
for these wastes  in their nutrient planning.

     Wastewater from food processing operations may be discharged
directly to water bodies,  or may be discharged to  a  POTW.   Food
processors  constitute  one industry  that  would be  of  particular
concern in  a control strategy for total nitrogen.

     Research should be done on solid food processing wastes as a
source  of  fertilizer  nitrogen.    (The National  Food  Processors
Association  has  recently completed a study on  feed uses  of food
processing wastes).  Sources  that are not viable  for  feed should be
marketed to  farmers for their nutrient value.
                    Non-Farm Use of Fertilizer
Home and commercial Site Lawns

     There are over 50,000  square miles (or 32,000,000 acres) of
residential and  commercial  lawn in the United States (Consumers
Union,  1990).    In  suburban areas  especially, where  home lawns
account for  a significant  portion  of the land area,  overuse of
fertilizer on turf is  a potential  source of nitrate contamination.

     As with agricultural uses of fertilizer,  in the case of turf
management there is a point of diminishing or  negative returns to

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fertilizer  usage.    The use  of  too much  fertilizer can  cause
excessive build-up of  thatch, which  impedes healthy leaf growth.
It is apparent that homeowners often  apply fertilizer in excess of
recommended  levels,  believing,  as one researcher puts  it,  that
twice as much means grass that looks  twice as good  (Angle, 1990).

     Homeowners should be made aware of the availability of soil
testing.  The Cooperative Extension Service will test soil, usually
for under ten dollars according to Consumers  Union.  However, there
remain many  parts  of  the country for  which an adequate nitrogen
test has not been developed.

     Homeowners should be educated in  BMPs  for home lawns.   They
should be instructed in areas such as proper timing and amount of
fertilization and irrigation,  planting of native species (cool or
warm  season  grasses),   seasonal  nutrient  needs,  proper  mowing
heights, and the nutrient benefits of leaving clippings on a lawn.
Turf clippings are potentially a significant  source of the nitrogen
needed by turf.  Nitrogen from clippings has been observed to be
used by new growth within two weeks of cutting.  After three years,
clippings from previous years contributed 78 pounds of N per acre
(Connecticut Agricultural Experiment Station, 	).

     In   suburban   areas  experiencing   nitrate  contamination,
information  on alternatives to  turf lawns  could be offered to
homeowners.   In an effort  to curtail  peak water  demand,  water
suppliers in Marin County,  California have offered modest rebates
to homeowners converting from turf  to  turfless  or 'xeriscapic1
lawns.  These are landscape designs employing gravel, bonsai, trees
and  wood  chips,   and  require  little  or  no  fertilization  or
irrigation.

     Professional lawn  care companies are  generally  required to
receive  a state permit.   The  permitting  system may provide a
mechanism for requiring  soil  tests to be performed  on  all lawns
treated,  and/or requiring  that  records of  soil  N levels  and
nitrogen applications be maintained.

     Irrigation system installation is restricted in some states to
licensed plumbers and  irrigators.  Many states restrict only the
connection to potable water supply.  Others prohibit any phase of
landscape irrigation without a license.   This  may be a mechanism
through which states  or localities  can  ensure proper irrigation
design for both home and commercial lawns as well as golf courses.

     Municipalities  should  be  encouraged  to consider  nitrogen
impacts  on  ground water   and  surface water when  drawing  up
comprehensive  plans  and zoning ordinances  .   Certain  land uses
might be disallowed in  sensitive  areas.   Such uses might include
golf courses, home and garden dealers, greenhouses and nurseries,

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sod farms and industrial facilities handling nitrogenous compounds.

     Land  development review  at  the local  level  can play  an
important role in protecting both  surface  and ground water.  For
instance,  stormwater  collection  basins,  which  may pool  large
amounts of fertilizer during rain events should perhaps be located
at places where depth to ground water is deepest.

Golf Courses

     Golf courses are heavily fertilized to achieve a  quality turf.
Pollution prevention practices for recommended  for  golf courses
include the use of slow release fertilizers and the competent use
of fertigation  have been  viewed by several  researchers (Snyder,
1979;  Snyder,   1980;   Cohen,   19	).   Fertigation essentially
simulates the controlled-release of  nitrogen  that is provided by
slow release forms, but offers the advantage of allowing cheaper,
conventional  forms  of fertilizer  to  be used   (Snyder,  1979).
Fertigation is best managed as frequent,  light applications, rather
than infrequent,  heavy watering,  and is best  adapted to courses
that have fully automated  irrigation systems, true  of many courses
in the South, Southeast, and arid Southwest.

     Golf   course  superintendents   should   be   provided   with
information  concerning   the  relative  efficiencies   and   cost
effectiveness of slow release fertilizers and fertigation, compared
to conventional fertilization.  The Golf  Course Superintendents'
Association of  America (GCSSA) is  the  professional  organization
which might best provide this information,

     In   areas   where  nitrates   are   a  particular   problem,
municipalities or states might require that land use applications
be accompanied by nutrient  management plans.   Cape Cod, which is
served by  a sole source  aquifer  designated under the  SOWA,  has
established a nitrate-N planning guideline of 5 mg/L within zones
of contribution to public supply wells (CCPEDC, 1978).

     Some golf courses, particularly in California and Florida, and
to some  extent  in Pennsylvania and perhaps other states,  apply
treated wastewater from local sewage treatment plants to the land.
The golf courses benefit from the nutrients in the wastewater.  The
nitrogen value  of such wastewater should  be  quantified and made
known to superintendents.
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                    REMEDIATION AND TREATMENT

     Where pollution  prevention  has not been  implemented  or has
been ineffective, the possibility  of  removing  nitrate from water
must be explored.   As part  of  the  nitrogen  cycle,  nitrate  is
constantly   being   removed   from   water   naturally   through
denitrification.  Nitrogen is also taken up by plants  from the soil
and in the air.   Researchers  are exploring ways that the natural
denitrification process can be enhanced where excess nitrate is a
health or ecological concern.   Technologies are also available to
remove  nitrate physically  from drinking  water.    This  section
discusses treatment approaches for water that has been contaminated
with excess nitrate.
                       Public Water Systems

     In order  to protect human health for  people drinking water
supplied by  public  water systems,  EPA or the  states enforce the
regulations written under the Safe  Drinking  Water  Act  (SDWA).  The
regulations  require public  water  systems  to  monitor  to  assure
compliance with  the MCL,  report the monitoring results to EPA or
the state, and meet all MCLs.  States have primary authority to
enforce the SDWA if they adopt regulations at least as stringent as
EPA.  Otherwise, EPA retains "primacy" over  the enforcement of the
act.   EPA has primacy over drinking water programs in
Wyoming, Washington, D.C., and all Indian lands.

     In order  to protect  the public health  from the acute health
effects of methemoglobinemia, EPA set the nitrate MCL at 10 mg/L.
New monitoring and public notification regulations  were promulgated
December 1990 that reflect the acute nature of this disease.

Monitoring

     The first line of defense EPA employs  to  protect the public
health  from the effects of drinking water contaminants  is to
require all  public water  systems to sample  their water supplies.
Nitrate and nitrite have more frequent monitoring requirements in
the new regulations than any other inorganic or organic chemical.
Ground water systems will be required to monitor annually. If any
result is 50 percent or more of the MCL (5 mg/L, nitrate; .5 mg/L,
nitrite),  monitoring  must  be  conducted   quarterly  until  four
consecutive  quarters  show results  under  50 percent  of the MCL.
Surface water  systems, because the  nitrate/nitrite level varies
more for such  systems, must begin monitoring quarterly until four
consecutive quarters show results that are less than 50 percent of
the MCL. Thereafter, annual monitoring is acceptable unless the 50
percent level  is surpassed.
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Public Notification

     If the nitrate level in any monitoring sample exceeds the MCL,
another sample must be taken within 24  hours or the public must be
notified of  the results.   The  public  water system  then  has two
weeks to resample.   Nitrate violations  require public notification
as  soon as  possible,  but  no   later  than  72  hours  after  the
violation.    The notice  must be given  to radio and  television
stations in  the area.  The  notice must be repeated every three
months by mail  or  hand delivery  as long as the violation exists.
The public must also be notified of any failure to monitor or the
existence of a variance or exemption every three months.
Public  notification regulations  contain mandatory  language  for
nitrate that encourages parents to provide infants under six months
with an alternate source of drinking water.

     This notification requirement is primarily designed to protect
the public  health.   It is  also  a means of informing  the public
about problems with the water supply (Wardlaw and Bruvold, 1989).
Notification may also  be a useful tool gather public support for
increased expenditures to correct problems (USGAO, 1982).

Treatment Options

     The most cost-effective way for a  public water system to meet
the MCL  is  simply  to blend the water  from a  high nitrate source
with low nitrate water.   Drilling  a deeper well or a well  in a
different part  of  the  aquifer may be an option for some  systems.
A  new  well may just be a short term option since the  nitrate
contamination of shallow aquifers may simply be a  function of time
where the contamination has  not  had sufficient time to reach the
deeper aquifer.

     Three technologies are approved by EPA for physically removing
nitrate from water.   If no alternate  water source  is  available,
reverse  osmosis  (RO),  ion exchange   (IE),  or  electrodialysis
reversal (EDR)  must be used.  RO and  EDR both  use  membranes to
remove nitrate. IE uses anion exchange resins.  Removal rates for
the technologies are:  RO,  67 to 95%; EDR, 51  to 92%; and IE, 65-
99%.    Conversion  of  nitrite  to  nitrate  through  breakpoint
chlorination is an  economical method that can be used when nitrite
MCLs are exceeded.

     The costs for all three technologies are considered feasible
for a large public  water  system  (serving  over 100,000 people).  RO
and EDR have comparable costs from $1.50/1,000 gallons for a large
system (about $150  a year per household) to $5.90/1,000 gallons for
a small system.  Ion exchange costs  range from $ .77/1,000 gallons
for a large system to $3.40/1,000 gallons for a small system.


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       A public water system can  apply  for a variance or exemption
from meeting the MCL.  A variance can be granted if the system has
installed an EPA approved technology and it still cannot meet the
HCL and does not pose an unreasonable risk to health.  Public water
systems can apply for an exemption if they are unable to meet the
MCL because of compelling factors (including cost), the system was
in operation at the time the MCL was established,  and it does not
present  an  unreasonable  risk to  health.   States  can  renew  an
exemption  for smaller  public water  systems  with  500  or  fewer
connections for additional two year periods for financial reasons.
15  public water  systems have  variances or  exemptions  for  the
nitrate MCL (Wade Miller Ass., 1990).   The affordability guidance
EPA is proposing suggests that households  should  not have to pay
more than $650 per year for drinking water or over two percent of
the median household income.

     The draft Regulatory Impact  Analysis of the proposed drinking
water regulations (1989) estimates that public water systems will
have to spend $192 million annually over the next 20 years to meet
the nitrate  MCL.    Small public  water systems account  for $129
million  of  those  costs.   The  costs  do not  take  into account
blending  water,  drilling   a new well,   or  using  breakpoint
chlorination instead of using an approved technology.

New Nitrate Removal Technologies

     Currently  approved nitrate  removal  processes  have several
disadvantages that new technologies are trying to avoid.  RO, IE,
and EDR  produce a  significant amount of  effluent that  must  be
disposed  of  and not reintroduced  into the water supply.   These
processes are also very expensive, especially for small systems.

     In order  to  avoid waste disposal costs  associated with ion
exchange  and  reverse osmosis, researchers are  now experimenting
with enhancing the  natural  biological  denitrification process to
treat drinking water.  Although this technology is new to drinking
water treatment, it  has  been used for  nitrogen removal from some
wastewater treatment plants for  years.  As part  of the nitrogen
cycle, bacteria  in  the  soil consume  nitrate  and convert  it  to
nitrogen gases. The rate of natural denitrification often does not
remove enough nitrate from the water to allow its use for drinking
water when anthropogenic additions have been made  to ground and
surface waters.

     Three  pilot  projects   have been  operating  in Belgium  to
experiment with materials to enhance  the  growth  of denitrifying
bacteria  to  remove  nitrate  from  a  surface  water  reservoir
(Liessens, et al.  1990).    The  projects differ  in term  of the
material on which bacteria are grown (sand or polyurethane) and the
bacteria's food  source (methanol or hydrogen). Liessens,  et al.

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concluded that the fluidized bed reactor (sand and methanol) was an
appropriate denitrification technique at low temperatures, but more
evaluation of all techniques was needed.  France also has several
biological denitrification plants operating.  Since this technology
is still considered experimental, EPA has not recognized it  as an
approved removal technology.
Enforcement

     When an MCL is violated, the primacy agency, EPA or the state,
begins an enforcement action against the public  water system.  The
actions range from informal actions such as a notification of the
violation to  the filing of a criminal or  civil case against the
PWS.   An informal  request  for public notification is  the most
frequent action  taken  against  public water systems violating the
nitrate MCL.   According to FRDS  data compiled for this report,
between  October  1987  and  April  1990,  out  of  280 systems  in
violation, 20 administrative/compliance orders  were  issued and no
fines were imposed or criminal/civil cases  filed.   Compliance with
the MCL was achieved in  30  cases.   Since  about 92 percent of the
violations identified  through  FRDS were from small public water
systems, informal actions and technical assistance are considered
more appropriate to bring the systems back into compliance with the
MCL.

     EPA is  currently  developing a plan to increase enforcement
against the worst violators.  Public water systems are considered
in  "significant  noncompliance"  if MCLs are violated in repeated
monitoring periods.  Primacy agencies then  have  six months to take
appropriate action.  Appropriate action is defined as a  bilateral
contract between the  state and the pubic  water systems, a state
Administrative  Order,    a  Federal  Administrative  Order,   or  a
referral  for  a  civil  or  a   criminal  case.    This   increased
enforcement  is  designed to make  violators assure that  water
supplied to customers  meets federal standards either by treating
the water supply, changing raw water sources, or combining with a
public water supply that meets the MCLs.

     The General Accounting  Office's (1990)  assessment of the
implementation  of the Safe Drinking  Water  Act  concluded  that
enforcement actions by the states were  not timely, appropriate, or
effective  in returning  PWSs to  compliance.   Many significant
violations had persisted for years.   GAO  cited costs,  especially
for small  systems,  and  technical  barriers such as  no   available
alternative  water   sources  as  the  principal   hindrances  to
implementation.

     The Office of Drinking Water at EPA has begun a new program,
called Mobilization primarily to aid small public water systems in
meeting  the  requirements  of   the  SDWA  through  institutional,
technical,  and training support. States, public health officials,

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and  the general  public  are also  being  targeted  through  this
program.  Public water systems need support from all these sectors
to  raise  awareness of  the importance and  costs of having  safe
drinking water.  Mobilization activities  such as developing low-
cost treatment  technology might help  small public  water systems
meet the nitrate MCL.

                 Domestic Drinking Water Supplies

     EPA has  no authority over  drinking  water wells  that serve
fewer than 25 people  or  15 connections.   States generally do not
regulate  water  quality  in  private  wells either,  with a  few
exceptions.    Washington  requires  any  well   with  two   or  more
connections to  meet  bacteria and  inorganic  chemical  standards.
Idaho requires any well  with  at  least 10  connections  to meet all
primary drinking water standards.  New Jersey mandates that all new
private wells  must test  for  bacteria,  nitrate and meet all the
primary drinking water standards, except for pesticides.

     Private wells are generally at greater risk of contamination
than public wells  for three  reasons.   First, since the cost of
drilling a well is based  on  a  per foot  charge,  many homeowners
drill  only into the shallow aquifer and  do not  tap  the  more
protected deeper aquifers generally used by public water systems.
Second, private wells are more often  located close to potential
sources of contamination, such as septic systems.  States variously
recommend that private wells be located a minimum of  50  to 100 feet
upgradient from a potential  source of  contamination such  as  a
septic system.  Finally,  the  construction material  and method of
older wells allow  nitrate (and other  contaminants) to enter the
wells more easily.

     Several  monitoring  studies have tried to  correlate  the
characteristics of wells with the extent of  contamination.   The
risk  factors  include  age, depth,  method of  construction  (dug,
drilled, driven), soil  textural  class,  and distance to potential
source of contamination.   One Kansas  study found that wells more
than 70 years  old,  within 100 feet of a  potential  contamination
source, and  21 to 99  feet deep in silty or  clay  soil  are most
likely  to  have nitrate  levels that  exceed  10  mg/L   or  20  mg/L
(Koelliker, et al. 1988).    The Iowa  State-Wide Rural Weil-Water
Survey (1989)  found that 35.1% of the  wells less  than 50  feet deep
were contaminated  with  nitrate compared  to  12.8 percent of the
deeper wells.   Hallberg (1989) believes that this phenomenon may be
just a function of time and nitrate will eventually reach  the lower
aquifers.

     Most states have no formal  program for testing private well
water.  Private wells are usually tested by states only as part of
a special  study or when a specific problem is reported.  Almost

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half the  states  will  test for bacteria either  free  or for a fee
when a request is made.  Nitrate is the second most commonly tested
substance.

     Almost all  states  will provide a well  owner with a list of
labs certified to conduct testing for various contaminants.  Local
and  state  health  departments  often  are  willing   to recommend
specific  tests,  interpret  results,  and offer  advice on  how to
correct problems.  If a doctor or public health official requests
a water sample,  that  state  will  usually conduct the test for the
contaminant(s) indicated. A spill or a leaking underground storage
tank  will  usually  involve  the  state,  especially  if  enough
complaints  are heard  at the  state level or there  is publicity.
Many states concede that they respond more thoroughly the harder
and longer a well owner complains.

     Banks often require a test of the  well water before they will
grant a mortgage.  One sample to test for bacteria is usually the
only requirement, although nitrate test requirements are becoming
more common.   Generally  the information on water quality is only
given to the well owner, although in Nebraska,  the state performs
the tests  for a fee and keeps the  information  to help gauge the
existence or  severity of a  problem.   Other states distrust these
data because of the ease of drawing a potable water sample at some
time of the year.   In one study  in  Ohio,  nitrate  levels in some
wells were shown to fluctuate as  much as 30 mg/L during the course
of a year.  Four states  mandate  testing for bacteria and nitrate
when property changes hands (Baker, 1990).

     Many  states try  to  influence  the water quality  of private
wells by regulating the construction of new wells or the upgrade of
existing wells.  States  require  placement  of new wells outside a
zone of contamination and at some minimum depth (usually 10 to 30
feet).  Construction with certain casing material and grouting mix
specifications are also common requirements.  Some states regulate
well drillers  through licensing or registration procedures.  Eleven
states use  all  or  part of a test developed  by  the  American Well
Water Association.   Many officials believe that the enforcement of
these  regulations  is  virtually   non-existent.   Washington,  for
example, has required well logs since 1971,  but enforcement is just
beginning.  The  extent of the compliance with  the  regulation is
unknown.

     Local  health  officials are  often more involved  than their
state counterparts since they are closest to the well owners, but
most programs  seem  to be extremely limited  because  of a lack of
funds.  States do not often mandate specific programs for private
well testing to the counties.

     Some  states,   like  New  Mexico,  have  developed  innovative

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programs for dealing with private wells.  In addition to responding
to complaints, a water testing laboratory is sent to areas all over
the state  to test anyone's water  free of charge.   These "water
fairs" are often held in conjunction with county fairs or at other
public locations. Many problems have been uncovered including some
that affect public water systems.  65 percent of the samples in one
area violated the nitrate  MCL.   The legislature passed emergency
legislation to fund a public water system for the area.

     Other states, especially in the  Midwest,  have  passed ground
water protection legislation or instituted ground water strategies
in the past few years.  These initiatives usually fund some kind of
monitoring program or special studies  to determine where there are
currently problems or where problems are likely to occur.  The end
result  of these processes  would   probably  be the creation  of
districts  where  certain  best  management  practices  would  be
implemented.

Private Treatment Options

     Private well owners with high  nitrate  levels can choose among
several options, depending on the  cost of  the options, the level
and type of contamination, and the amount of water the well owner
wants  to  be potable.   They can  continue drinking  high  nitrate
water, use bottled  water,  drill  new  or deeper wells,  or  install
treatment devices to remove nitrate.  New or deeper wells may only
be a temporary solution because nitrate levels in deeper aquifers
many increase with time.

     All water supplied by public water systems have to be potable
even though less than 10 percent is used for drinking or cooking.
If water in a private well  is high  in  nitrate,  it cannot simply be
boiled.   Boiling does  not remove  nitrate,  but  concentrates  it
instead thereby making the water more hazardous.

     If high nitrate levels are the result of the location near a
source of  contamination and faulty construction  of  the existing
well,   a  new or  deeper well  can  be  drilled.   Over  400,000 new
domestic wells are drilled annually.  Average  costs for a new well
and a  pump  are $3,500 to  $4,000 (McCray,  1986).  If the  aquifer
itself is high in nitrate from diffuse sources, the nitrate must be
removed.  Nitrate can be removed from drinking water by  some of the
same methods used by public water systems:  reverse osmosis or ion
exchange.  Distillation is also an option  for homeowners.  Costs
range from $500  to $1,000  to  equip a  house (point of entry)  or a
single tap (point of use)  with the treatment equipment.  There is
also an additional annual maintenance charge of approximately $100.
Maintenance is a very important component of the treatment.  When
the membrane is clogged, as much as 60 mg/L can be dumped into the
water.

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     Reverse  osmosis  and  distillation  are  only  suitable  for
drinking and cooking water.  Depending on  the treatment unit 75 to
90 percent  of the water will  go down  the  drain without passing
through the membrane.  It usually takes between three and six hours
to produce  one gallon of  drinking water.   Distillation averages
five hours per gallon  (Consumer Reports, 1990).

Bottled Water

     Bottled  water  is  often  considered  an  option  to  avoid
contamination problems perceived to be associated with public water
supplies  and private  well  contamination.   It is important  to
understand  to  what extent bottled water  should be  considered an
alternative.

     All  bottled water that is sold  interstate or  imported  is
regulated by the Food and Drug Administration (FDA).  Bottled water
must meet all  MCLs.   Bottlers are required  by FDA  to sample and
analyze their water supplies for contaminants at least  once a year.
They must keep maintenance  and testing records for inspection.  FDA
has  a random  testing program,  but generally random tests  are
performed only  if  FDA  has  a reason  to suspect  a violation of the
regulations.

     Most bottled  water is sold interstate.   However,  when it is
exclusively sold intrastate, the  state has regulatory authority.
Often  state regulations  are stricter  than FDA, requiring,  for
example, increased monitoring and quarterly inspection of testing
records.

      Under  the Fair  Packaging and  Labeling  Act,  bottlers  are
required to label  any  water that  does not meet MCLs "substandard
quality".   For nitrate, water  is  substandard if the level is over
the MCL, but less than 40 mg/L.  If the nitrate level is greater,
water  must  be  labeled "adulterated"  and  potential  etiological
effects must be included  on the label.   FDA has no authority to
seize any adulterated water.  It may only require truthful labels
or use negative publicity against bottlers.

     In 1987, Consumer Reports  tested  50  brands of  bottled water
for various contaminants including nitrates.   None  of the brands
violated  the   MCL  for   nitrates  although  arsenic,  fluoride,
trihalomethanes, and tetrachloroethylene  levels were  violated in
some samples.

     It appears from  the  Consumer  Reports testing that bottled
water  is  generally  safe,  at least  from  a  nitrate perspective.
Therefore anyone who has nitrate in their water  supply over 10 mg/L
should feel  fairly comfortable in giving their infant bottled water
in place of the  tap  water.   However,  the  FDA testing program and

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authority over  penalties for violations by bottlers  of  the MCLs
need to be strengthened.

US Department of Agriculture

     Since 1942, the Farmers1 Hone Administration (FmHA)  has been
making loans or giving  grants  to small (population under 10,000)
community drinking water and waste water systems that are unable to
get credit from any other source.  Priority is given to systems
that do not meet SDWA requirements.  Individual  states operate the
program with financing  and guidance from FmHA.   States establish
the priorities based on  factors such as per capita income and size.
The system must meet all requirements under the SDWA and CWA when
completed.  FmHA prefers to give  loans to  systems that do not rely
on  individual  point  of entry/point  of  use  treatment  for each
household.    They  do  not have confidence  that  the  required
maintenance will be performed.

     FmHA has applications for approximately two or three times the
$400 million  available  for  loans and  grants   this fiscal  year.
There is currently about $7 billion in its portfolio.  A guaranteed
loan program has  just  begun  with  $50  million capitalization,
although there does not seem to be a market for these loans yet.

     FmHA also  operates a Circuit  Rider program to  help system
operators with operation and maintenance.   Through a contract, the
National Rural  Water Association provides coverage for  the lower 48
states with an  average of one circuit rider per  state.  The circuit
rider  is  available to  help  anyone who  asks  whether they  are a
borrower or not. The program will also send operators to training.


   Individual housing loans are made in areas with population up to
20,000.   FmHA  requires  that  houses  with domestic wells  and on
public water systems meet  nitrate levels in  order  to qualify for
the loan.  Because of the problem with some communities violating
MCLs, FmHA will make exceptions  and allow POU/POE  treatment (not
for private wells).   They  prefer the  units to  be centrally owned
and operated by the PWS.  In any  case  the  operator has to show the
ability to properly operate  and maintain the  system (including
financial).


                       Aquifer Remediation

   EPA's   laboratory  in  Ada,   Oklahoma   has   begun  laboratory
experiments on the in situ restoration of an aquifer contaminated
with nitrate.   The  emphasis  has been  on injecting  a  source of
carbon into a nitrate plume in a model  sand tank in the laboratory.
In an aquifer the carbon source must be spread naturally.

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        115

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     INSTITUTIONAL ISSUES IN IMPLEMENTING THE NITROGEN ACTION PLAN


     Agencies at the Federal, State,  regional,  and local levels of
government have specific roles and responsibilities for addressing
water quality problems associated with nitrogenous compounds (NCs).
These  agencies  vary greatly  in institutional  capability—in the
legal authority and technical and financial resources available to
them to  protect ground and  surface  waters  from contamination by
nitrogen compounds.

     The following discussion outlines in broad terms three major
institutional issues  for all levels  of government with regard to
the  implementation   of  water  quality  programs  that  address
contamination  from nitrogen compounds:   1)  current roles  and
responsibilities,    2)  existing  authorities  and  examples  of
programs,  and  3)  technical  and  financial  resources  currently
available.

                        Federal Government

     Federal  authorities  often provide  the  basis for  local and
state decision  making by establishing requirements or goals that
must be met by state and local authorities. Land use controls have
not been mandated by federal statute, per se, but federal programs
can  promote the  establishment of  state and  local  controls  by
providing  cooperative  funding  and   by  withholding  or  placing
conditions on federal grants.   In addition, some federal statutes
provide legal authority for the  federal government to preempt state
and local authorities to achieve regulatory standards.  Often the
federal influence on land use is necessary to provide the basis for
balancing competing  economic and environmental  interests  at the
local level.

     The primary federal agencies that would play a major role in
supporting and  implementing the Nitrogen Action Plan are the U.S.
Environmental  Protection  Agency  (EPA),  the  U.S. Department  of
Agriculture  (USDA), and the U.S. Geological Survey (USGS).

                  Environmental Protection Agency

Roles and Responsibilities

     EPA is  the principal  Federal agency charged with protecting
the  nation's  water  resources  from  pollution.    It  has  both
regulatory  and  non-regulatory  responsibilities  that  directly or
indirectly address NC contamination of water.  Under its regulatory
role, EPA limits  discharges  from  point sources of NCs by issuing
permits  and  sets  and  enforces  drinking  water  standards—or
delegates these responsibilities to  states that have demonstrated

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the  capacity  to carry  them  out.    Alternatively,  instead  of
regulating  specific  sources  of  contamination,  the Agency  has
established programs  that  require states to  protect surface and
ground waters from many or all major anthropogenic sources (e.g.,
Nonpoint Source and Wellhead Protection Programs).

     EPA's non-regulatory role is generally directed at building
state and local capacity to  address contamination of water through
public education, technical  and financial  assistance.  At present,
these broad-based efforts have not focused on protecting water from
NC contamination but have the potential to do so.

Authorities and Programs

     EPA derives  most of its authority to  address  water quality
problems associated with NCs from three statutes: the Safe Drinking
Water  Act  (SDWA),  the  Clean Water  Act  (CWA), and the  Toxic
Substances Control Act (TSCA).  The Agency is already taking action
under SDWA and the CWA, and is investigating the potential use of
TSCA and  CZMA to address currently un-regulated sources of NCs,
such as  fertilizers.    Both SDWA  and  the CWA  are  scheduled for
reauthorization by Congress in 1992.

     Four programs under SDWA can deal nitrogen compounds and water
quality.  Nitrate and nitrite drinking water standards for public
water systems are set  and ultimately enforced by  EPA.   In addition,
the  1986  Amendments  to SDWA  require  each State  to develop  a
Wellhead Protection (WHP) Program [§ 1428] to protect ground water
that  supplies  public  drinking  water  wells   from  sources  of
contamination.   Because of the  highly site-specific nature  of
ground water, adequate protection of public wells usually requires
active participation of local governments  in controlling a variety
of potential  contaminants.   Land use controls  are  an  important
local tool for wellhead protection. Sole-source  aquifer program [§
1424]  prohibits  federal  assistance  to  projects that  adversely
impact sole  source aquifers.  Section 1424 may, though,  assist
projects that  eliminate  contamination  over  sole source aquifers.
While no activities  are prohibited under the  federal program, State
and  local government may  use the  Sole Source designation  as
justification  for land  use  controls,  as was done to protect the
Cape Cod  public  water  well fields.    The  Underground  Injection
Control program regulates  injection  of  fluids  into underground
sources of  drinking water.   Agricultural drainage  wells,  large
septic systems, and wastewater disposal into ground water will be
regulated under Class V regulations of this program.

     Under CWA authorities,  EPA  or the state primacy agency issues
permits to point sources of  pollution that limits the contaminants
in  the effluent  discharged into surface  waters.    Industries,
wastewater treatment plants, and feedlots are all permitted to some

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degree under this  program.   For  example,  construction seed money
increases the  availability  of centralized waste water treatment.
Coupled with comprehensive  plans for phased implementation, seed
money advances development along infrastructure emplacement lines
and reduces the number of scattered developments whose reliance on
septic systems contaminating groundwater and surface water.  Also,
the CWA requires States to address surface water pollution through
the nonpoint source  state management programs  [§  319].   Nonpoint
source pollution includes runoff of nitrogen compounds into surface
waters  from such  major sources  as  fertilizer  and manure from
cropland and pastures.   The control  of nonpoint source pollution
invariably includes the establishment of best management practices
(usually voluntary)  or the  establishment  of regulatory controls,
such as permits placing conditions on land use practices.

     The Clean Lakes Program  [§ 314], National Estuary Program [§
320], and the Great Lakes Program [§ 118] all provide money to fund
the development of management programs for specific water bodies.
State  revolving  funds  [§  601]  provide seed  money to  states  to
establish a fund to make loans to waste water treatment plants.

     Recognizing the value  of estuaries,  the  National Estuaries
Program was established  under the  Clean Water  Act  [§  320]  to
coordinate  existing   regulatory,  financial,   and  institutional
resources to deal with problems of specific estuaries of national
concern through the development of Comprehensive Conservation and
Management  Plans.    Originally Puget  Sound,  San  Francisco Bay,
Albemarle-Pamlico Sound, Long Island Sound, Narragansett Bay, and
Buzzards Bay were included in the program.  Now Santa Monica Bay,
Galveston  Bay, Sarasota  Bay, New   York/New  Jersey Harbor,  and
Delaware Bays have been added.

     T8CA has  been used so far  in connection  with one source of
NCs.   The use of  nitrites  was banned as  an additive to certain
metal working solutions because of nitrosamine formation.  EPA is
investigating other options  for using TSCA to control NCs including
regulation  of  fertilizer use and  fertilizer  dealerships  and a
variety of projects based on geographically specific risk reduction
activities.     If   stringent  requirements   were  promulgated,
geographically based targeting could  change  regional production
cost differentials and, ultimately,  affect the  location of certain
economic  activities  and  associated  land uses.   Regulation  of
fertilizer manufacturers may also be considered under the proposed
Product Stewardship Rule.  Health effects can be investigated under
a test rule.

     The CZMA was amended at the end of 1990 to  include significant
new programs  which can be used to control contamination from NCs
by including minimum requirements for NC evaluation and control in
the  guidance.   The  amendments establish a new  Coastal Nonpoint

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Pollution Control  program which require states  with an approved
coastal zone management programs to develop a new program to deal
with  nonpoint  sources.    EPA  and  the  National  Oceanic  and
Atmospheric Administration  (NOAA)  are responsible for developing
guidance  and   approving  state  programs  which  must  include
enforceable  policies and  mechanisms.   These  programs must  be
coordinated with existing water  quality programs, including §319
programs.  If states fail to develop approvable programs, NOAA and
EPA are required to with hold  grant funds beginning in fiscal year
1996 (10%-FY96; 15%-FY97; 20%-FY98? 30%-FY99+).

Technical and Financial Resources

     EPA's nitrates-related technical assistance efforts include
the development  of vulnerability risk  factors  for  nitrates,  the
development of guidance for septic tank management,  and soil-test
technology transfer in  Pennsylvania  and Iowa,  all  underway,  and
research on the economic efficiency of fertilizer application for
its potential to reduce application rates (planned).  Also, EPA's
on-going  study of  ground water/surface  water  interactions  may
enable  States  to   estimate  loadings  of NCs  from  ground-water
discharge to stream segments.

     Financial assistance generally consists of grants to States
for building  their institutional capacity to protect  ground and
surface waters or  to support  projects that  address contamination
from specific sources. The CWA, for instance, authorizes grants to
States for the development of comprehensive ground-water protection
strategies as well  as for projects  that propose to manage nonpoint
sources  [§ 319].   At least  15 state project proposals to EPA for
§319 funding address NCs.


                 U.S. Department of Agriculture

Roles and Responsibilities

     USDA has recently  added water   quality  protection  to  its
traditional responsibilities.   USDA's  new Policy for Water Quality
Protection   (1990)    states  that  the  Department  will  "foster
agricultural and forestry practices that protect and enhance the
Nation's  ground  and  surface  water resources"  through research,
education, technical assistance and technology transfer, cost-share
assistance,   and farm management  guidance.   USDA  has  several
agencies that have  been assigned responsibilities for water quality
protection,   the  Soil Conservation Service  (SCS),  the Extension
Service  (ES), and the Agricultural Research Service (ARS).

Authorities and Programs
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     Under  the  President's Water  Quality  Initiative,  USDA  is
funding demonstration  projects  designed to develop,  improve, and
disseminate best  management practices (BMPs)—some of which will
demonstrate better management of fertilizer and manure use—and to
reduce NC contamination of ground water through more efficient use
of N  fertilizer.   USDA  also has the  authority  to address water
quality protection through  a  national plan  for  soil  and water
conservation required under the Resources Conservation Act of 1977.


     The new Farm Bill or the Food, Agriculture, Conservation, and
Trade Act of  1990 contains  four programs  that may affect USDA's
ability to  deal  with nitrate  contamination.    The  Conservation
Reserve Program (CRP)  directs  an  enrollment  of six  million new
acres of  environmentally sensitive lands.   The  Wetlands Reserve
Program will  enroll  up to one million  acres  of  wetlands into 30
year or permanent  easements out of  the total CRP acreage.   Under
the Water Quality Incentives Program SCS will contract with farmers
to provide incentive payments (up to $3,500 per year, per farm for
up to five years)  for  adoption  of BMPs to protect water quality.
The Environmental Easement Program provides for permanent easements
on lands which pose a significant environmental threat.  The exact
eligibility for these lands has not yet been determined, nor is any
funding available.

Technical and Financial Resources

     USDA is  conducting  research on NC contamination pathways in
the soil and on  farming methods to reduce or prevent contamination.
The SCS and ES,  in particular, will conduct demonstration projects
and provide technical  assistance to show farmers the benefits of
the new practices  and  how  to implement them.   USDA also collects
state level fertilizer use data.

     Financial  assistance  to farmers  is  available through cost-
share payments for the implementation of BMPs—including fertilizer
and  animal   waste  management  practices—through   funding  of
demonstration, hydrologic, and other water  quality projects under
the Water Quality  Initiative.    As  yet,  USDA  has  not  made  a
commitment to conduct or fund off-farm monitoring  for NCs.


                      U.S.  Geological  Survey

Roles and Responsibilities

     USGS is a scientific and technical agency without regulatory
responsibilities.  It monitors ground and surface water, conducts
water quality  assessments, investigates trends in  water quality and
the relation  of  land uses  to  water  quality. It also  provides

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information to agencies at all  levels of government in support of
water  quality  protection   efforts.     In  carrying  out  these
responsibilities,   USGS   provides   support  in   addressing  NC
contamination concerns by  helping to determine  the location and
extent of NC contamination.

Authorities and Programs

     USGS is involved in at least two programs that  are helping to
assess the impacts of fertilizer use on water quality.  First, in
the pilot phase of its National Water Quality Assessment Program,
the USGS is investigating the extent and location of ground-water
pollution by agrichemicals in several regions of the U.S.  Second,
it is conducting research on the impact of growing corn on ground
and  surface water  under the  Midcontinent  Research  Initiative.
Several  other programs,  such  as  the  Federal-State  Cooperative
Program and the State Water Resources Research Institutes Program,
conduct and support research  on  water quality, some of which may be
applicable to NC contamination  problems.

     Since it is not possible with current  data to develop a truly
national picture of the quality of ground and surface waters, the
United  States Geological  Survey  (USGS)  has  initiated a  major
national assessment. The National Water-Quality Assessment (NAWQA)
Program  is  designed to  describe the  status and trends  of U.S.
waters  and  identify  the  factors  that   affect  water  quality.
Beginning in fiscal year 1991,  with a budget of $18 million, USGS
will begin to study  the  first 20 hydrogeologic  units.   The first
cycle of investigations of all 60 units is scheduled for completion
in 2002.  Costs will increase to about  $60  million annually.   The
national and regional synthesis of this  information will emphasize
nutrients beginning in fiscal year 1992 (Leahy,  et al., 1990).


Technical and Financial Resources

     One of the major responsibilities of USGS, as mentioned above,
is to provide technical assistance to government agencies and the
public on water quality-related matters.  This assistance includes
basic  and  applied  research,   mapping  and  transfer  of  mapping
technology, information  collection and management,  and outreach.
USGS is conducting most  of  these activities in  its assessment of
the impact of fertilizer use on water  quality under the National
Water Quality Assessment Program.

     The Federal-State  Cooperative Program  provides  50/50  cost-
sharing between  USGS and  cooperating  State or  local  government
agencies.  Program  activities include  collecting hydrologic data
and  water  quality  investigations.    In  addition, USGS1  Water
Resources  Research  Grants  Program  awards  competitive  matching

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grants  to  qualified  universities,  foundations,  private  firms,
individuals, and  State  or local agencies to  support  research on
water resources problems of national interest.

                    Tennessee Vallev Authority
                        STATE GOVERNMENTS

     Federal programs rely extensively on State technical capacity
and  legal  authorities  to  meet the requirements  of  mandated
environmental programs. States have the primary responsibility and
expertise  for identifying contamination threats,  characterizing
threatened  resources,  establishing  enforcement  and  compliance
programs,  and establishing  sate priorities consistent  with the
requirements of federal Laws.

                           The  States

Roles and Responsibilities

     States and localities play perhaps the largest role in water
quality  protection.    In  addition to  implementing  and enforcing
federal  regulatory  programs,  state  and  local  governments  are
developing  and  implementing EPA's  Nonpoint  Source  (NFS)  and
Wellhead  Protection  (WHP) Programs,  State  Comprehensive Ground-
Water Protection Programs, and  their own water quality programs.
state  agencies  provide  oversight  and   support   (land  grant
universities provide support) to local government by enhancing the
technical and staffing capabilities  of local government when local
planning  agencies  seek compliance  with mandated  environmental
programs.    States  have  primary  responsibility  to  establish
priorities relative to federal mandates, identify and characterize
contamination threats  and establish enforcement programs.
Sometimes states enact legislation  that  delegates specific water
quality program authorities  to  local governments.   All  of these
programs have the potential to address sources of NC contamination.

     states may establish more  stringent  regulations  than those
promulgated by EPA, or place greater emphasis on a non-regulatory
approach through research, monitoring, and technical assistance to
farmers and local officials.   A common objective is to develop an
approach that mixes regulatory and non-regulatory elements in the
most effective manner.

     Many state agencies  have water protection responsibilities.
Three types of agencies that often play major roles in protecting
water  from agrichemical  contamination are state departments of
environmental protection  or  natural  resources,  agriculture, and
public health.  Coordination  of  the  water protection activities of

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different agencies is essential to avoid conflicts between agencies
with different perspectives and duplication of effort.     For this
reason, many  states assign  a  lead  role to  a  single  agency or
establish coordinating committees to facilitate communication among
agencies.

Authorities and Programs

     States derive authority to address sources of NC contamination
from such federal laws as the SDWA and the CWA.  These laws allow
states  with adequate  institutional  capacity to enforce federal
regulations and standards  or  establish programs (e.g.,  WHP,  NFS)
that provide  technical and/or financial assistance  to  states to
develop their own  approaches to protecting their ground and surface
waters.  Some states have passed their own statutes and developed
regulations or programs that support or  go beyond  the Federal
programs.  A few examples of state programs that address sources of
NCs are:

     Iowa's tax on fertilizer purchases funds monitoring and soil
     testing programs.

•    Nebraska  has recently required  the Central  Platte Natural
     Resources District to adopt a ground water quality management
     plan.     The plan   includes  regulatory  requirements  for
     addressing  NCs,  with  possible  bans  on  fall  and  winter
     fertilizer applications, training on use of fertilizers, and
     mandatory recordkeeping.

*    Arizona  has  a  cost-share  program   for implementation  of
     approved BMPs and alternative agricultural practices.

     South Dakota's Centennial Environment Protection Act of 1989
     focuses  on  the  development  of  alternative  agricultural
     practices and management of nonpoint sources.   The State's
     Groundwater Protection Fund should yield $500,000 annually and
     will  support grants  for ground  water   research and public
     education.

     Minnesota's Ground Water Protection Act  of  1989 authorizes a
     new fund to enable the State to respond to agrichemical spills
     and other pesticide and  fertilizer incidents.  Surcharges on
     fertilizer tonnage and agrichemical businesses will feed the
     fund.  Also,  the law authorizes programs to reduce the use of
     fertilizers.

     Wisconsin has  established cost-share programs  to  construct
     manure storage facilities and to implement  approved BMPs and
     alternative  agricultural practices.   The  "Bad  Actors" law
     permits the State to treat individual farmers not co-operating

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                       * DRAFT  (3/5/91) *

     in  a  regional water quality program as  a  "point source" to
     force compliance.

•    Florida  has delineated Water Control  Districts  to regulate
     both water  supply and quantity.

Technical and Financial Resources

     State  agencies  (and  universities)  provide  much  of  the
technical capacity to meet the requirements of Federally-mandated
environmental programs as well as their own  programs.  States also
provide  technical  support  to  local   water  quality  protection
efforts.  Examples of the types of technical  assistance that States
(often  in  collaboration with  Federal  and  local  agencies  and
universities) provide  that currently  or  potentially  address NCs
include:  preparing technical documents on approved BMPs and septic
tank installation  and management,  preparing guidance  on land-use
controls, mapping sources of contamination and aquifers, developing
geographic  information  systems, delineating  wellhead protection
areas, conducting  monitoring and water  quality assessments,  and
improving soil tests.

     States  receive  financial  assistance  from  Federal  programs
(NFS,  POTW  construction grants,  CWA grants  for  ground  water
protection strategies, etc.)  and many  have  established their own
sources of funding.  Some  of the Federal grants must  be used for
specific  purposes,  while   others  are  partially   or  entirely
discretionary.   Up to  20 percent of CWA POTW Construction Grant
funds, for instance, may be used for NFS control.  California has
opted to take advantage  of  this provision to make $13.42 million
available for FY 1990,  and will  use some of  these funds to protect
bays and estuaries from nonpoint sources, including sources of NCs.
State   sources   of   funding   other   than  State   legislative
appropriations  include  fertilizer  sales taxes  (Iowa,  Kansas),
ground water protection funds, water utility user fees, impact fees
(septic tanks,  Florida),  and permit fees  (large feedlots),  real
estate  transfer tax (MA),  License fee (10),  Sales tax  (WA),
Stormwater utility fee  (regional government),  Environmental trusts
(MN).

             Regional or  Cross-Jurisdictional  Efforts

Roles and Responsibilities

     Numerous    regional    entities    across    the    U.S.    have
responsibilities for water quality protection. These  include both
in-State and  supra-State  cooperative programs and administrative
bodies. The  basic  role  of regional entities  is to  address water
quality problems that cannot be dealt  with at any single level of
government because they span more than one local  or State political

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                       * DRAFT (3/5/91) *

or administrative jurisdiction.

Authorities and Programs

     Cross-State   programs  generally   derive   authority   from
agreements   or   charters   signed   by   governors    (or   their
representatives)  of the  participating States.   The  agreements
describe and assign the responsibilities of the participants, and
include at least a commitment to  obtain the resources necessary to
implement the agreements.  Examples of cross-State programs include
the Chesapeake Bay Program and the Spokane-Idaho Panhandle Program.
One of the recent initiatives under the Chesapeake Bay Program is
the Chesapeake Bay Nutrient Reduction Agreement, which calls for a
40 percent reduction in NCCs and phosphorus entering the Bay system
by  the   year  2000,  to   be   accomplished   primarily   through
Federal/State  cost-share  BMPs  and  buffer  zones  or setback  of
sources from critical tributary areas.

     In-State  regional programs  or districts  which  address water
quality concerns include the Puget Sound Water Quality Authority,
the  Cape  Cod  Aquifer   Management  Project,  Nebraska's  Natural
Resources Districts  (NRDs), plus numerous Federal water resources
and  conservation  administrative  districts   across  the  nation.
States establish regional  programs and  give them  authority  to
address  water quality  problems  through  legislation.    Nebraska
enacted  a  law establishing  24  multi-county Natural  Resources
Districts  in 1969.   These districts  have  taxing authority and
professional staffs.

     In response to  detections of nitrate in  ground  water and at
the request  of two NRDs, Nebraska  recently designated its first
Special  Protection  Area.   The  Lower Republican  and Little Blue
districts  have six months  to  draft  a  plan  for  alleviating the
contamination.  The plan must include mandatory measures (such as
imposition of  BMPs or restrictions on fertilizer  use)  as well as
education and monitoring programs.

Technical and Financial Resources

     Regional  bodies contribute  information,  planning,  technical
and  financial assistance  to water quality  protection  efforts.
Contributions vary widely  from body to body.   The Nebraska NRDs,
for example,  have staffs that range from a  few  people  to 40-50
employees and budgets from $300,000 to over $8 million.   Some of
these  regional bodies do  not contribute their own funding but
simply allocate  appropriations  from State legislatures  to local
governments while others  have the authority to  levy taxes or charge
user fees.  Collected funds may support research, monitoring, soil
testing for nitrate levels, and technical assistance for evaluating
onsite septic systems as well as administrative costs.

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                       * DRAFT (3/5/91) *

                    Local Governments  & Others

Roles and Responsibilities

     NC  contamination  results  from  a  variety  of  activities
associated with specific land uses.  Since control of land use has
traditionally  resided at the local  level,  a  federal  plan must
facilitate land use planning efforts.   Local governments typically
implement  zoning  and subdivision  ordinances,  develop land-use
plans,  implement  health requirements,  supply water   and  sewer
services, and enforce police powers.  Together, these powers give
local  governments the  potential to  play an  important role  in
managing or prohibiting activities that may contaminate surface and
ground waters with NCs.  Additionally,  local governments  often have
water quality protection responsibilities under State and Federal
legislation.    For  example,   local   phased  capital  improvement
programs direct  the location, timing  and  rate  of development.
Coupled  with  federal  construction seed money  for waste  water
treatment and State technical assistance, local  government may have
sufficient start-up financing and legal authority to direct growth
away from areas of high groundwater vulnerability.

Authorities and Programs

     Varied limitations  (legal, fiscal, regulatory, economic, and
political)  on  local  governments  have produced   a  variety  of
imaginative programs to mitigate  water contamination.   Generally,
local environmental  programs  mitigate pollution by  (1) reducing
the levels of pollutants in a specific locations and (2) managing
the  type,  location,  and  rate  of community  growth.    Locally
legislated programs  currently include, but are not limited to:
zoning requirements [i.e. wellhead protection overlays and restric-
tions,   special   permitting,  large-lot  zoning,   transfer  of
development   rights,   planned unit  development/cluster  design
criteria, phased capital improvement program, performance zoning,
site plan/subdivision review]; easements [acquisitions of full (fee
simple/eminent domain) and partial (easements/covenants) interests
in land  and development rights]; regulations  [off-site drainage
controls,  septic  system  regulations,  chemical  handling  area
regulations];  acquisition of  land,  watersheds,  and development
rights; programs to  retain farmland; the retention of land within
watersheds; and monitoring activities of businesses (lawncare, golf
courses, etc.).

Technical and Financial Resources

     There  are,  in  part,  two competing  interests at  the  local
level:  environmental  protection and  economic development.  The
complexity, costs and legal authorities of environmental programs
exceeds the capacity of  most local  government  and necessitates a

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                       * DRAFT (3/5/91) *

coalition of multiple levels of government to integrate resources,
an activity atypical at the local level. By contrast, the desire to
develop and  increase the local property tax base  is  business as
usual  at  the  local  level.  Land  use  controls mitigating  con-
tamination must be discussed in the context of a coalition because
the  aggressiveness with which local environmental controls and
their  financing are pursued  reflects,  in  part,  the  political
balance among competing economic and environmental constituencies
for the scarce fiscal and technical resources of local government.
Localities utilize several  methods to raise local funds to pay for
environmental controls:  utility user fees,  property taxes, bonds
to purchase land, and tax deductions.
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ACP
ADW
ASCS

BMPs
BOD5
CAA
CFC
CFR
CNS
CWA
CZHA
DO
EC
EDR
FDA
FmHA
FR
FRDS

gpd
IE
1
MCL
MCLG
metHb
mg
N
NAPAP
NAS
NAWQA
NCI
NH,
N2O
N02
N03
NOx
NOAA
NOAEL
NPDES
NPS
NPS
NSA
ODW
POTW
             * DRAFT (3/5/91)  *

                 APPENDICES

          APPENDIX A—Acronyms Used

Agricultural Conservation Program, USDA
agricultural drainage well
Agricultural  Stabilization and  Conservation  Service,
USDA
best management practices
5-day biochemical oxygen demand
Clean Air Act
chloroflourocarbon
Code of Federal Regulations
central nervous system
Clean Water Act
Coastal Zone Management Act
dissolved oxygen
European Community
electrodialysis removal
Food and Drug Administration
Farmers' Home Administration, USDA
Federal Register
Federal   Reporting   Data   System   (drinking   water
violations)
gallons per day
ion exchange
liter
maximum contaminant level  (SDWA)
maximum contaminant level goal (SDWA)
methemoglobin
milligram
nitrogen
National Acid Precipitation Assessment Program
National Academy of Sciences
National Water Quality Assessment, uses
National Cancer Institute
ammonia
ammonium ion
nitrous oxide
nitrite
nitrate
nitrogen oxides
National Oceanic and Atmospheric Administration
no observed adverse effects level
National Pollutant Discharge Elimination System  (CWA)
non-point source  (pollution)
National Survey of Pesticides in Drinking Water Wells
Nitrogen Sensitive Areas (designated in United Kingdom)
Office of Drinking Water, EPA
publicly owned (sewage) treatment works (CWA)
                               128

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                       * DRAFT  (3/5/91) *

FWS        public water system (SDWA)
RCRA       Resource Conservation and Recovery Act
RIA        regulatory impact analysis
RO         reverse osmosis
SCS        Soil Conservation Service,  USDA
SDWA       Safe Drinking Water Act
SNC        significant non-compliance  (with MCL)
TKN        total Kjeldahl nitrogen
TRI        Toxics Release Inventory
TSCA       Toxic Substances Control Act
UIC        underground injection control (SDWA)
URTH       unreasonable risk to health (SDWA)
USDA       United States Department of Agriculture
US EPA     United states Environmental Protection Agency
USGS       United States Geological Survey
WATSTORE   USGS database of water monitoring results
WHO        World Health Organization,  United Nations
WHPA       Wellhead Protection Area (SDWA)
                               129

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                       * DRAFT  (3/5/91) *

                       APPENDIX B—Glossary

anipp - A negatively charged atom or group of atoms.
aquifer  -  An  underground  geological  formation,  or  group  of
formations,  containing usable  amounts  of ground water  that can
supply wells and springs.
biochemical oxygen demand (BOD)  - A measure of the amount of oxygen
consumed in the biological processes that break down organic matter
in  water.    High  BOD  can  lead  to  oxygen deficiency  in aquatic
environments.
chemiaation  -  Application  of  inorganic  fertilizers  in aqueous
solution through an irrigation  system.
denitrification  -  The   anaerobic   biological  reduction  of
nitrate-nitrogen (NO3)  to nitrogen gas (N2) .
estuary -  A region of interaction between  rivers  and nearshore
ocean waters, where tidal action and river flow create a mixing of
fresh and salt water,  and may include bays, mouths of rivers, salt
marshes, and lagoons.   These brackish water ecosystems shelter and
feed marine life, birds, and other wildlife.
eutrophication  -  The  slow  aging  process during which  a   lake,
estuary  or  bay evolves  into   a  bog  or marsh and  eventually
disappears.  During the  later stages of eutrophication the  water
body is choked  by  abundant  plant life as the result of increased
amounts of  nutritive  compounds  such  as  nitrogen and phosphorus.
Human activities can accelerate  the process.
hypoxic - A state  of oxygen deficiency relative to  the  needs of
living organisms.
lithosphere -  The  earth's crust; the solid  part of  the  earth as
opposed to its  molten core.
mass balance - An accounting of all input,  use, storage, and export
of  a chemical  or  chemical compound  from  a  given  part of  an
ecosystem.
naxinup eqpfc«»inant level (MCL)  - The enforceable level set by EPA
for  maximum permitted concentration  of  a  pollutant in public
drinking water  .
maxim*,™ contaminant level goal	(MCLG) — The  level of pollutant in
a public drinking water system that has been  found not to pose any
health risk.
methemoqlobinemia - A  condition observed  primarily  in infants in
which oxygen  supply in the  blood stream is inhibited,  giving a
bluish hue to the skin.  Also called "blue baby  syndrome."
mineralization - The process by which organic matter is transformed
into inorganic  compounds that are usable by  plants.
N-nitroso compounds -  Substances formed  from the combination of
nitrite  and   nitrosatable  substrates;     e.g.:  nitrosamines,
nitrosamides, nitrosocarbamates.
nitrate - A compound,  NO3, which can  exist  in the atmosphere  or as
a dissolved gas in water and which can be  harmful to the health of
humans and animals.
nitrate-nitrogen -  Nitrogen when  it occurs  in  the form  of the

                                130

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                       * DRAFT (3/5/91) *

compound nitrate (NO3)
nitrification - The process whereby ammonia in water is oxidized to
nitrite and then to nitrate by bacterial or chemical reactions.
nitrite - 1. An intermediate in the process of nitrification.  2.
Nitrous oxide salts used in food preservation.
nitrogen oxides - A byproduct of combustion processes from mobile
and stationary  (industrial) sources.  A major contributor to acid
deposition  and  the  formation  of  ground-level  ozone  in  the
troposphere.
Tiifr-rogmnipes -  A chemical  compound  formed from a secondary amine
and a nitrosatable substrate.
nitrosatabie substrates - Naturally occurring substances found in
many types of food such as  fish, poultry, meat, dairy products and
grains.  Also present  in some  agricultural chemicals,  drugs, and
many cosmetics.
non-point source -  sources of pollution loadings to water which are
diffuse in origin.
percolation - The movement of water downward and radially through
the sub-surface soil layers,  usually continuing downward to ground
water.
pH - A measure  of  the  acidity  or  alkalinity of a liquid or solid
material.
phenols - Organic  compounds  that are by-products  of  a  number of
industrial processes.   Low  concentrations cause  taste and odor
problems in water;  higher concentrations can kill aquatic life and
humans.
point source  - The Code of  Federal Regulations  defines  a point
source to be  "any  discernible,  confined and discrete conveyance,
including but  not  limited  to any pipe,  ditch,  channel, conduit,
well, discrete fissure, container,  rolling  stock,  concentrated
animal  feeding operation,  landfill leachate  collection  system,
vessel or other floating craft, from which pollutants are or may be
discharged.  This term does not include return flows from irrigated
agriculture or agricultural stormwater runoff."   (40 CFR 122.2).
reductase - An enzyme that catalyzes chemical reduction.
side-dressing - A practice by which fertilizer is applied near to
plant roots after emergence of the plant from the soil, in order to
realize use efficiency.
total fclehdahl  nitrogen (TKN)  -  A  method used  to determine the
quantity of nitrogen present  in water, encompassing nitrogen found
in the  form  of ammonia,  ammonium  salts,  nitrates/nitrites and
organic compounds.
wellhead protection area -  An area designated by  a  state under the
Wellhead Protection Area Program,  in which authority is  granted to
regulate certain land uses in the interests of protecting wellheads
and wellfields which provide a source of public drinking water.
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                       * DRAFT  (3/5/91) *





APPENDIX c—Agency Responsibilities
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                       * DRAFT (3/5/91) *

APPENDIX D—Methodology for County-Level Manure Estimates

     I  have calculated  the  ratio  of  the number  of  pounds  of
nitrogen  in animal waste potentially  available to crops  to the
number of acres of harvested cropland, and to the number of acres
of harvested cropland excluding cropland planted in nitrogen-fixing
crops as reported in the 1987 Census of Agriculture for each county
in the U.S.   The  ratio is intended to show where and to what extent
animal wastes  production  may exceed capacity  for  agronomic land
application. We used statistics reflecting the  estimated amount of
"nutrients  which  are  economically  recoverable"  by  region  in
estimating the amount of nitrogen available from animal waste.  The
figures come from Estimating U.S. Livestock and Poultry Manure and
Nutrient  Production  (USDA,   1978).  The animal  types, production
areas,  nitrogen  production estimates,  and nitrogen  after  25%
volatilization are listed below.
Animal type  Production area

Volatilization
Beef cattle

Feeder Cattle

Dairy cattle



Fat hogs

Sheep
Laying hens
Broilers

Production area descriptions
 1
 2
 3
 4
 5
 6
 7
 8
 9
10
                 Lbs N
   3.6
  0.0
 20.0
 20.4
103.8
 55.2
102.2
 98.1
  4.5
  3.4
  3.0
  0.7
  0.1
            Lbs N After 25%
 2.550
 0.000
15.000
15.300
77.850
41.400
76.650
73.575
 3.375
 2.550
 2.250
 0.525
 0.075
1    Northern states  - NV to VA,  all states between  and to the
     north
2    Southern states - all not in area 1
3    ND, SD, NE, KS, AR, LA, and all states eastward
4    Western States - all not in area 3
5    Northeast, Appalachian, Corn Belt,  Lake, Northern  Plains, and
     Northern Mountain States
6    Southeast, Northern CA, OR, and WA
7    Southern Plains
8    Southern CA, AZ, NM
9    Corn Belt, Lake Sates, SD, NE, KS, TX, KY, TN, NC, GA
10   All not in 9
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                       * DRAFT  (3/5/91) *
Recoverable nitrogen varies with management practices

     The 1978 USDA ESCS publication, Estimating U.S. Livestock and
Poultry Manure and Nutrient Production has a table that shows the
amount of "manure and nutrients that are economically recoverable"
by region.   Although  the  authors  do not make  their assumptions
about regional livestock management and manure handling practices
explicit, these factors are accounted for in the table.   (Van Dyne,
p. 4).

Nitrogen production estimate for sows

     The table in Estimating  U.S. Livestock and Poultry Manure and
Nutrient  Production does  not  give a  figure  for sows  used  for
breeding, so we  developed  one  using  information from the Midwest
Plan  Service  Livestock  Waste  Facilities Handbook and  the  USDA
Animaj. Waste Utilization on Cropland and Pastureland.  The MWPS book
gives daily manure  and nutrient  production  figures for gestating
sow and for a sow and  litter.  (MWPS,  pg. 2.1) The USDA book shows
the nitrogen as a percentage of manure in dry weight and contains
implicit storage and handling  loss coefficients.  (Gilbertson, pp.
17, 22)

     We assume that the sow will gestate twice for a total of 305
days and  lactate twice for a  total  of 60 days.  A gestating sow
produces 8.9 Ibs of manure per day, 9.2%  of which is dry weight,
for 305 days a year.  Nitrogen  makes up 2.8% of the dry weight of
this manure. (MWPS,  pg. 2.1) The  implicit storage  loss coefficient
is .714. (Gilbertson,  pp. 17,22)  We further assume that  25% of the
nitrogen will be lost in the  first  few  days after  application as a
result  of  volatilization  (see  below).   (Gilbertson,  pg.   31)
Consequently,   each sow produces  3.76 Ibs  of  nitrogen in  its
gestating periods  each year that  can  be  consumed by  crops  (8.9
Ibs/day x 305 days x 9.2% x 2.8%  x  .714 x  .75 = 3.76.) A lactating
sow and its litter produce 33 Ibs of manure per day, 9.2% of which
is dry weight,  for 60  days a year. The other  variable are the same.
Consequently,  each sow its litters  produce 2.74 Ibs of nitrogen in
the two yearly lactating periods  that can  be consumed by crops (33
Ibs/day x 60 days x  9.2% x  2.8% x .714 x .75  = 2.74.) Thus each sow
reported in the Census and  its  two litters (up to the time they are
weaned 30 days after birth) produce a total of 6.5 Ibs of nitrogen
that can be consumed by crops.

Volatilization losses    The nitrogen  production coefficients we
are using  reflect the  amount  of nitrogen  in  manure immediately
before application. Some of this nitrogen will volatilize in the
first  four  days after application to  cropland  and will not be
available for plant uptake. According to Animal Waste Utilization
on Cropland and Pastureland. it takes  1.33  units of surface-applied

                               134

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                       * DRAFT (3/5/91) *

manure to  make the  amount of  nitrogen present  in one  unit of
nitrogen immediately before application available to crops after
volatilization  loss  following  application.  (Gilbertson,  31)  In
other words, only  75% of the nitrogen present in manure immediately
before   application   will   be  available   for   plant   uptake.
Consequently,  we   have  multiplied  all  our nitrogen  production
numbers by  .75 to account for volatilization after application.

     According to Van Dyne,  the estimates of nitrogen economically
recoverable account for  some  volatilization loss.  Consequently,
the estimated volatilization loss of 25% that we have used may be
too high.  On the other hand, the authors of the publication with
the  25%  loss  figure  clearly  intended  it  to  reflect  losses
immediately after land application,  so  it should include a reduced
propensity  to volatilize due  to previous  volatilization losses
during storage.

Data   We used data from the 1987 Advance Census of Agriculture to
develop  our estimates.  The  Advance Census does not  have data on
cattle fattened on grain and  concentrates   or hogs and pigs in
inventory used for breeding.

     In order to develop our estimates of nitrogen production, we
had to  estimate the populations of the types of animals listed
above. We did this by finding  the ratio of each category of animal
to a similar type of animal  for which we did have data. While this
procedure undoubtedly  introduces errors at the  county  level as
ratios of  animal  type vary,  it does not introduce  a  systematic
bias.

     We used the national ratio in 1982 of "beef cows  in inventory"
to "cattle fattened on grain and concentrates sold," which was  .81,
to estimate the number of cattle on feedlots for 1982.  I keyed in
the 1987  data from the  Final  Census of Agriculture for "cattle
fattened on grain and concentrates sold."  We used  the  national
ratio in 1982 of "hogs and pigs in  inventory" to "hogs and pigs in
inventory used for breeding," which was .13,  to estimate the number
of breeder pigs in inventory for both 1982 and 1987.

     The number of cattle on  range includes half the  number of
cattle  on   feedlots.  This  is  because  feedlot  animals  are  only
fattened on the feedlot  for around  180 days.  They are on pasture
for the remainder of the year.

Problems with methodology

Hissing census data    The Census of Agriculture does not disclose
data  for all items  in  all counties.  Some  counties have  so few
producers of an item that releasing  the census data collected from
individuals would reveal the size of their operations and violate

                               135

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                       * DRAFT  (3/5/91) *

the  confidentiality  promised by census takers. The  counties for
which one  or more data fields was missing  are  indicated with an
asterisk.

Production coefficients for swine may not reflect current situation
The  nitrogen production coefficients  we  used  for hogs  may not
accurately reflect current swine  management practices,  which may
result  in  greater quantities of  recoverable  nitrogen  than the
practices  of the late seventies.   Hog production operations are
becoming increasingly large  and  producers  are moving  away from
feedlots to  complete confinement.

     The effects of large  scale confinement operations are partly
accounted  for in the regional  Van Dyne tables.  The  tables show
production of 3.4 Ibs of nitrogen  per animal per production period
for regions with smaller,  less confined operations and production
of 4.5 Ibs  in regions with  larger, more confined operations. Using
the higher production coefficient (4.5 Ibs)  for the regions that
had smaller,  less confined  operations did not alter the estimate of
total nitrogen per acre substantially. For all counties with 60 Ibs
of nitrogen  per acre or more,  the  total  nitrogen per  acre was
increased by less than 10% when the higher production coefficient
was used.

     We had considered presenting  a range of possible nitrogen per
acre ratios,  but since using the higher production  coefficients for
swine did  not  result in  a  substantially  different figures  in
counties where the nitrogen  per  acre  ratio was  high  enough to
suggest  potential  problems,  we  used  the  figures  originally
recommended by Van Dyne in 1978.

Other production coefficients may also be outdated     Van Dyne
himself  suggested that  the   swine estimates  may  not accurately
reflect current practices in a conversation  in July. Production of
all  types  of animals  has shifted  increasingly  towards large,
concentrated, confined operations  that  make manure recovery easier
and may reduce runoff and  leaching potential. Consequently, it is
also possible  that the  production coefficients  for other animals
understate the amount of recoverable  nitrogen. We  believe  that our
estimates  of the ratio  of Ibs of  nitrogen  available from animal
waste to  acres  of  non-nitrogen  fixing  harvested cropland are
conservative.
                               136

-------
                       * DRAFT  (3/5/91) *



APPENDIX E—Fertilization Rates in Major Producing States



APPENDIX F—Tons of Nutrient N Sold By State
                               137

-------

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                       * DRAFT  (3/5/91) *

                           BIBLIOGRAPHY


	.  1981.  Chlorophyll - phosphorus relations in individual
lakes:  Their importance to lake restoration strategies.  American
Chemical Society. 15(4).

	.  1988.  Testing  needed to tie level of nitrate in water to
cancer, researcher says.  Lincoln Am.  May 25.

	.  1990.  Act's acid rain language:  End of 10-year trek t
hrough Congress.  Air/water Pollution Report.  28(42):330.

	.  1990.  Cover cropping  fights  nitrate  leaching.  Forward.
1(2):4.

	.  1990.  Creating a market:  The selling of water safety.
Consumer Reports.  January:27-43.

           1990.  A  federal sludge policy?   Air/water Pollution
Report.  28(42):334.
          1990.  The green way to a green  lawn.  Consumer Reports.
55(6):399-402.

	.  1990.  Natural lawn care.  Garbage (magazine).  30.


AGRA-EUROPE 37/88, Sonderbeilage 10.  September 12, 1988.

Agricultural   Experiment  Station,   Oregon   State   University,
Corvallis.   1982.   Best management practices  and water quality:
Demonstration and  evaluation  project.   Five-county north central
Oregon area.  Oct. 1977 to April 1981.   Special Report No. 646.

Agricultural Extension Service, University of  Delaware.  1988.
Best Management Practices for disposal of dead chickens in southern
Delaware.  Newark, Delaware.

Agricultural  Extension  Service,   University  of  Wisconsin,  and
Wisconsin Dept.  of Agriculture,  Trade and  Consumer Protection.
1989.    Nutrient  and  pesticide  Best  Management Practices  for
Wisconsin farms.  WDATCP Technical Bulletin ARM-1.  June.

Al-Dabbagh,  D. Fonnan,  D. Bryson,  I. Stratton,  and R. Doll.  1986.
Mortality of nitrate  fertilizer  workers.    British Journal  of
Industrial Medicine.  43:507-515.

Allen, S. E.  1984.  Slow-release nitrogen fertilizers;  Nitrogen
in Crop Production.  Proceedings of a Symposium held at Sheffield,

                               138

-------

-------
                       * DRAFT  (3/5/91) *

Alabama.  May 25-27, 1982.

Anderson, C.E., et al.  1982.  Air quality criteria for oxides of
nitrogen  (final report).    Office of  Health  and Environmental
Assessment,  Office  of   Research  and  Development,   U.S.  EPA.
Washington D.C.  EPA 600/8-82-026F.  795 pp.

Anton E.G.,  J.L.  Barnickol, D.R.  Schnaible.    1988.   Nitrate in
drinking water.   Report  to  the legislature.    Division  of Water
Quality, California State Water Resources Control Board.   Report
No. 88-11WQ.

Arbuckle, T.E., and G. Sherman.   1986.  Letter  to the editor, re:
Congenital  malformations and maternal  drinking water  supply in
rural south Australia:  A case-control  study.  American Journal of
Epidemiology.  124:344.

Arbuckle, T.E., G.  Sherman,  P.  N. Corey,  D.  Walters,  and B. Lo.
1988.  Water, nitrates and CNS birth defects:   A population-based
case-control study. Archives of Environmental Health.  43:162-167.

AWWA Water Quality Division  Committee for Inorganic Contaminants.
1985.  An AWWA survey of inorganic contaminants  in water supplies.
Journal of the American Water Works Association. 77(5):67-72.

Ayer, H.,  P.  Hoyt,  B.  Gardner,  B.  Roth,  and T.  Doerge. 1989.
Cutting nitrogen applications for improved water quality:   Does the
farmer  lose?   Proc.  papers of the 1989  meeting held at Coeur
D'Alen,  Idaho.    July  9-12.     Western  Agricultural  Economics
Association.

Bachmann,  R.W.   1980.   The role of agricultural  sediments and
chemicals in eutrophication.  Journal of the Water Pollution Control
Federation.  52:2425-2431, 2600.

Badger,  D.D.  and  D.  E.  Thomason,  Jr.    1987.    Economic  and
environmental  impacts  of using  municipal  sewage effluent  for
agricultural  production.    D.M.  Fairchild  (ed.), Ground Water
Quality  and  Agricultural Practices.    Lewis  Publishers, Inc.,
Chelsea, Michigan.  111-126.

Baker,  D.B.    1990.     Groundwater  quality  assessment   through
cooperative  private well testing:  An Ohio example.   Journal of
Soil and Water Conservation. 45(2):230-235.

Baker,  J.L. and  T.A.  Austin.    1984.    Impact  of  agricultural
drainage wells on groundwater quality. Completion report 1981-1983.
Iowa State University,  Ames,  Iowa.  U.S. EPA grant no. G-007228010.

Barth, E., et al.  1989.  The state of the Chesapeake Bay:  Third

                                139

-------
                       * DRAFT  (3/5/91) *

biennial  monitoring  report  -  1989.
Monitoring Subcommittee.
Chesapeake  Bay  Program
Berry, J. T.  and  N.  L.  Hargett.   1984,  1988.   Fertilizer summary
data.   National Fertilizer Development  Center,  Tennessee Valley
Authority.  Muscle Shoals, Alabama.

Birch, S.P. Nitrogen and Eutrophication in the U.K.  1990.

Blankenship, K.  1990.  Clean air...dirty bay?  The new Clean Air
Act may clean up the sky but its impact on the Chesapeake will be
mixed.  Chesapeake.  Alliance for the Chesapeake Bay.  Rockville,
Maryland.  November-December.

Boesch,  D.F.  and  R.  Rosenberg.    1981.   G.W.  Barrett and  R.
Rosenberg (eds.),  Stress Effects on Natural Ecosystems.  John Wiley
and Sons, New York.

Bouldin, D., W.  Reid,  and D. Lathwell.  1971.  Fertilizer practices
which minimize nutrient loss.  Agricultural wastes:  Principles and
guidelines  for  practical  solutions.   Proc.  of Cornell University
Conference on Agricultural Waste Management held at Syracuse, New
York.

Business Publishers, Inc.  1990.  Ground Water Monitor.  6:93.

California Department of Water Resources.   1971.   Nutrients from
tile drainage systems.  Report No. 13030 ELY 5/71-3.  Sacremento.

Canter, L.W.  1987.   Nitrates  and pesticides  in groundwater:  An
analysis of  a computer-based literature search.   D.M. Fairchild
(ed.),  Ground Water Quality and  Agricultural Practices.   Lewis
Publishers, Inc.,  Chelsea, Michigan.  153-174.

Cantor, K.P., A.  Blair, and  S.H.  Zahm.   1987.   Health effects of
agrichemicals  in  groundwater:    What do  we know?   Agricultural
Chemicals and Groundwater Protection:   Emerging  Management and
Policy.  Proceedings of a conference held at St. Paul, Minnesota.
Freshwater Foundation.  27-42.

Cape Cod Planning and Economic Development Commission.  1978.
Water  quality  management  plan/EIS  for Cape  Cod.   Barnstable,
Massachusetts.
Central Platte  Natural Resources  District.
3(6):87.
     1990.   Newsletter.
Chenault,  E.A.    1989.   Texans  increase focus  on  gw quality.
Extension Today.  8(3):3.
                               140

-------
                       * DRAFT  (3/5/91) *

Cochet, C., D.  Derangere, and T. Rousselle.  1990.  Soil adsorption
systems  and   nitrogen  removal.     Water  Science  Technology.
22(3/4):109-116.

Cohen, S.Z.,  S.  Nickerson, R.  Maxey,  A.   Dupuy and J.A. Senita.
1990.  A ground water monitoring study for pesticides and nitrates
associated with golf courses on Cape Cod.   Ground water Monitoring
Review.  10(1).

Cohen, S.Z., S. Nickerson, R. Maxey, A. Dupuy and J.A. Senita.  1
990.  A ground water monitoring study for  pesticides and nitrates
associated with golf courses on Cape Cod.   Groundwater Monitoring
Review.  10(1).

Corre, W.J.,   and  T.  Breimer.    1979.    Nitrate  and nitrite in
vegetables.   Literature Survey  No.  39.    Centre  for Agriculture
Publishing and Documentation,  Wageningen,  The Netherlands.  85 pp.

Crowder, B. M., and C.  E. Young. 1987.  Soil conservation practices
and  water  quality:    Is  soil  conservation the  answer?   Water
Resources Bulletin.  22:897-902.

D'ltri,  M. &  L.G.  Wolfson (eds.).   1987.   Rural  Groundwater
Contamination.  Lewis  Publishers, Inc., Chelsea,  Michigan.

Dean,  N.L.   1988.    Danger  on  tap:    The  government's  failure to
enforce the federal Safe Drinking Water  Act.   National Wildlife
Federation, Washington D.C.

Department of the Environment, Central Directorate of
Environmental  Protection.   1986.  Nitrate in water:  A report by
the  Nitrate  Coordination Group.   Pollution Paper  No.   26.   Her
Majesty's Stationery Office, London.  104  pp.

Dodds, W. K.,  K.R.  Johnson, and J.C. Prisco.  1989.  Simultaneous
nitrogen  and  phosphorus  deficiency  in  natural  phytoplankton
assemblages:  Theory/ empirical evidence, and implications for lake
management.  Lake and  Reservoir Management.  5(1):21-26.

Dorsen, M.M.,  R.K.R. Scragg, A.J.  McMichael,  P.A. Baghurst, and K.
F. Dyer.   1984.   Congenital malformations and  maternal drinking
water  supply  in rural South Australia:   A case-control  study.
American Journal of Epidemiology.  119:473-486.

Dubgaard,  A.   1987.   Reconciliation of  agricultural  policy and
environmental  policy in Denmark:  Regarding controls on nitrogen
fertilizer.   Multipurpose  Agriculture and Forestry.   Proc.  llth
Seminar of  the European Association  of Agricultural Economists.
Federal Republic of Germany.


                               141

-------
                       * DRAFT  (3/5/91) *

Dval, H.I., and N. Gruener.  1977.  Health effects of nitrites in
water.  Health Effects Research Laboratory, Office of Research and
Development, U.S. EPAr Cincinnati,  Ohio.   EPA 600/1-77-030.   164
pp.

Eckhardt, D.A.V. and E.T. Oaksford.  1988.  Relation of  land use to
ground water quality in the Upper Glacial Aquifer, Long  Island, New
York.  National Water Summary 1986.  U.S. Geological Survey Water
Supply Paper 2325.  Washington D.C.

Ehrenfield, J.G.  1987.  The role of woody vegetation in preventing
ground  water pollution by nitrogen  from  septic  tank leachate.
Water Research 21(5):605-614.

El-Hout, N., and A.  Blackmer. 1990.  Nitrogen  status of corn after
alfalfa in 29 Iowa fields.  Journal of Soil  and Water Conservation.
45:115-116.

Ervin,  J.L. and  K.M. Kittleson.    1988.    Assessment of  rural
groundwater contamination  by agricultural  chemicals in sensitive
areas of  Michigan.   Institute of Water Research,  Michigan State
University, East Lansing,  Michigan.  Report No. G1429-03.

European Chemical Industry, Ecology & Toxicology Centre.  1988.
Nitrate and drinking  water.  Technical Report No.  27.   Brussels.
January.

Evans, R. O., J. R.  Cummings, and J. W.  Gilliam. 1989.  Controlled
drainage, a Best Management Practice in North Carolina.  Am. Soc. of
Ag. Engineers.  Paper No,  89-2695.

Exner, M.E. and R.  Spaulding.   1985.   Ground water contamination
and  well  construction  in  southeast  Nebraska.    Groundwater.
23(1);26-33.

Exner, M.E. and R.F.  Spaulding.   1990.  Occurrence of pesticides
and nitrate in Nebraska's ground water.  Water Center, Institute of
Agriculture and Natural Resources, University of Nebraska, Lincoln,
Nebraska.

Fairchild,  D.M.  (ed.).     1987.     Ground  Water  Quality  and
Agricultural Practices. Lewis Publishers, Inc., Chelsea, Michigan.
402 pp.

Fan, A.M., C.C.  Willhite,  and S.A.  Book. 1987.  Evaluation of the
nitrate   drinking  water   standard  with   reference   to  infant
methemoglobinemia and potential reproductive toxicity.  Regulatory
Toxicology and Pharmacology.  7:135-148.

Fassett, D. W.  1973.   Nitrates and  nitrites.  Toxicants Occurring
Naturally in Foods.  National Research Council, Washington D.C.  7-
21.

-------
                       * DRAFT  (3/5/91) *

Federal Register.   1985.   Summary of comments and responses from
the October 5, 1983 APRM and the November 13, 1985 MCLG proposals
for  the  synthetic organic  chemicals,  inorganic chemicals  and
microorganisms.  74-84.

Federal Register.   1987.  October 28, 1987.  52(208):41534-41547.

Federal Register.   1989.  May 22, 1989.  54(97): 22062-22160.

Feigin, A.  1987.   Strategies for soil protection under intensive
irrigation in Israel.   Scientific Basis for  Soil Protection  in the
European Community.  Elsevier Science Publishers, London.

Fesler, H.  1990.   Personal communication.  Bureau of the Census,
U.S. Dept. of Commerce, Washington D.C.  July 9.

Feyen, J.  (ed.).   1987.   Field  validation of soil water and crop
models.   Simulation Models  for Cropping Systems  in Relation to
Water  Management.     Com.  European   Communities,   EUR   10869,
Luxembourg.

Firthsen, J.B.  1989.  Marine eutrophication, nutrient loading, n
utrient effects, and the  federal response.   American Association
for  the  Advancement  of  Science/EPA  Environmental   Science  and
Engineering  Fellows Report.    Office  of  Marine and  Estuarine
Protection, Office  of Water, U.S. EPA, Washington D.C.  Mimeo.

Fisher D., J. Ceraso, T. Mathew, and M. Oppenheimer.  1988.
Polluted  coastal waters:   The role of  acid rain.   Environmental
Defence Fund, New York.

Flipse, Jr., W.J.,  B.C. Katz, J.B.  Lindner  and R. Markel.  1984.
Sources  of  nitrate   in   ground  water  in  a  sewered  housing
development,  central  Long  Island,   New York.    Ground  Water.
22(4):418-426.

Follett, R. F.  and D. Kemper.  1990.  Nutrient management and water
guality - An issue  paper  for the workgroup.  Water Quality 2000.
Mimeo.

Ford,  K.L.,  J.  M.  Schott,  and  T.J.  Keefe.    1980.   Mountain
residential development  minimum well  protective  distances: Well
water quality.  Journal of Environmental Health.  43(3):130-133.

Forman, D., S.  Al-Dabbagh,  and R.  Doll.   1983.  Nitrates, nitrites
and gastric cancer  in Great Britain.  Nature.  313:620-625.

Forman, D., S. Al-Dabbagh, T. Knight, and R. Doll.  1988.
Nitrate  exposure  and  the  carcinogenic process.    Living in  a
chemical world:   Occupational and environmental  significance of

                               143

-------
industrial carcinogens.
York.  597-603.
* DRAFT (3/5/91)  *

  The  New York Academy of Sciences.   New
Fox, R.H. and W.  P. Piekielek.  1983.  Response of corn to nitrogen
fertilizer and the prediction  of soil nitrogen availability with
chemical tests in  Pennsylvania.  Agricultural Experiment Station,
Pennsylvania  State University.   Bulletin 843.   University Park,
Pennsylvania.

Fox,  R.  H.  and  W.  P. Piekielek.    1984.    Relationships among
anaerobically mineralized nitrogen,  chemical  indexes, and nitrogen
availability  to  corn. Soil  Science Society  of  America Journal.
48:1087-1090.

Fox, R.H.,  G.w. Roth,  K.V. Iversen and W.P.  Piekielek.  1989.  Soil
and tissue  nitrate tests compared  for predicting  soil nitrogen
availability to corn.  Agronomy Journal  81:971-974.

Gilbertson, C.V.,  F.A.  Norstadt, A.C. Mathers, R.F.  Holt, A.  P.
Barnett, T.M. NcCalla, C.A.  Onstad,  R.A. Young, L.R. Shapler, L.A.
Christiansen and D.L. van Dyne.  1979.  Animal waste utilization on
cropland and  pastureland:   A manual for  evaluation agronomic and
environmental effects.  U.S. Dept. of Agriculture utilization Rep.
6.  Washington D.C.

Gold, A.J., W.R.  DeRagon,  W.M.  Sullivan and J.  L. Lemunyon.  1990.
Nitrate-nitrogen losses to  ground water from rural  and suburban
land uses.  Journal of Soil and Water Conservation.  45(2):305-310.

Goldenman, G.    1988.   Protecting  groundwater from agricultural
chemicals:  How  can  EPA be most effective in getting farmers to
change their  practices?   Report written during  internship study
with U.S. EPA Region VII, Kansas City, Kansas.  Himeo.

Goldman,  C.   R.    1988.    Primary  productivity,  nutrients,  and
transparency  during  the  early onset of  eutrophication  in ultra-
oligotrophic  Lake   Tahoe,   California-Nevada.    Limnology  and
Oceanography, 33(6):1321-1333.

Gollehon, N.   1990.   Chemigation:  A technology for the  future.
Agricultural  Information  Bulletin  No.  608.   Economic Research
Service, U.S. Dept. of Agriculture.  Washington D.C.

Great  Lakes  Water   Quality  Board.     1987.    Report  to  the
International  Joint   Commission:    Report  on Great  Lakes water
quality.

Great  Lakes  Water   Quality  Board.     1989.    Report  to  the
International  Joint   Commission:    Report  on Great  Lakes water
quality.  Presented at Hamilton, Ontario, Canada.

                               144

-------
                       * DRAFT  (3/5/91) *

Gross, C.M.,  J.S.  Angle and M.S.  Welterlen.   1990  (unpublished
draft).  Nutrient  and Sediment Losses  from  Turfgrass.   Dept. of
Agronomy, University of Maryland, College Park, Maryland.

Gunter, G.A.  1987.  Nitrate removal  from contaminated groundwater
supplies.  Vol.  II.   Project summary  for U.S.  EPA.   EPA 600/S2-
87/034.

Guter, G.A.  1987.  Nitrate  removal  from contaminated groundwater
supplies.  Vol. II.  Project summary  for U.S. EPA, Washington D.C.
EPA 600/S2-87/034.

Gutis, P.S.  1988.  Global seas:  Global red tides of algae bring
new fears.  The New York Times, New  York.  May 3:C1.

Hallberg,  G.R.   1989.   Nitrate  in ground  water in the United
States.  R.F.  Follett (ed.), Nitrogen Management and  Ground Water
Protection.  Elsevier Science Publishers, B.V., Amsterdam.  35-74.

Hansen, S.A., J.G. Linn and S.D. Plegge. 1987.  Water quality for
beef  and  dairy cattle.   Understanding Nitrogen  and  Agricultural
Chemicals  in the  Environment.   Agricultural  Extension Service,
University of Minnesota.  AG-BU-3166. pp. 7-17.

Harding,  D.    1990.    Tar-Pamlico  nutrient  sensitive  waters
management strategy.   National Water  Quality  Evaluation Project
(NWQEP) Notes.  Agricultural  Extension Service,  North Carolina
State University.  44:1-2.

Harrington, W., A.J.  Krupnick,  and H.M. Peskin.   1985.  Policies
for nonpoint source water pollution  control.  Journal of Soil and
Water Conservation.  40(l):27-36.

Hartman, P.  1982.  Nitrates  and nitrites.   F.J.  de Serres and A.
Hollaender (eds.), Chemical Mutagens:   Principles and Methods for
Their Detection.   7:211-294.  Plenum Press, New York.

Hauck, R.D.    1988.   Toward an economically  and environmentally
sound agriculture:  Nitrogen research imperatives.  Mimeo.

Hecky,  R.E.   and  P.  Kilham.    1988.    Nutrient  limitation  of
phytoplankton  in freshwater and marine  environments:  A review of
recent  evidence on  the  effects of enrichment.    Limology  and
Oceanography.  33(4):796-822.

Heidman, J.A.  and R.P.G.  Bowker,  1981.   Evaluation of on-site
wastewater treatment  and disposal options. Municipal Environmental
Research  Lab,   Office of  Research  and Development, U.S.  EPA.
Cincinnati, Ohio.  EPA 600/S2-81-178.


                                145

-------
                       * DRAFT  (3/5/91) *

Hempler, N.  1990.  [German].   Stickstoff und unwelt.  Publication
of   the  Industrieverband  Agrar  e.V.   Fachbereich  Duengung,
Frankfurt/Main, Germany.  February.

Henry,  J.    1988.   The nitrate  problem.    Well  Water Journal.
42(8):4-5.

Hertel, T.W., M.E. Tsigas, and P. V. Preckel. 1990.  Unfreezing p
rogram  payment  yields:   Consequences  and  alternatives. Choices.
Second Quarter:32-33.

Hoeft, R. 1984.  Current status of nitrification inhibitor use in
U.S.  agriculture.   Nitrogen  in  Crop  Production.   Proc.  of  a
symposium held at Sheffield, Alabama.  May 25-27,  1982.

Holden, L.R. and J.A.  Graham.   1990.  National alachlor well water
survey:  Data summary.   Monsanto  Agriculture Company, St. Louis,
Missouri.

Holden, L.R. and J.A.  Graham.   1990.  National alachlor well water
survey:  Project summary.  Monsanto Agriculture Company, St. Louis,
Missouri.  Mimeo.

Holderread, J.    1991.   Personal  communication.   Water Quality
Division, Industrial Permits Unit, Texas Water Commission.  Austin,
Texas.  January.

House,  J.    1990.   Abundant  ground  water  N  makes  for tricky
management:   Problem  is  frustrating  affected  growers.   Grape
Grower.  October:4-8.
Hurlburt,  s.    1988.    The problem  with  nitrates.
Journal.  42(8):37-42.
Well  Water
ICAIR/Life  Systems,   Inc.    1987.    Final  draft  drinking water
criteria document on nitrate/nitrite.  Prepared for the Office of
Drinking Water, Office of Water, U.S. EPA, Washington D.C.

ICF/Clement, Inc.  1987.   Toxicity profile of nitrates, nitrites
and  N-nitroso  compounds.   Prepared  for  the Office  of  Policy,
Planning and Evaluation, U.S. EPA, Washington D.C.  552 pp.

ICF/Clement, Inc.  1988.  The regulation of nitrate, nitrate, and
n-nitroso compounds.  Task  2  Report.   Prepared for the Office of
Policy, Planning, and Evaluation, U.S. EPA, Washington D.C.  45 pp.

Iowa  state-wide rural  well  water survey.   1989.    Summary  of
results.  The University of  Iowa and the Iowa Department of  Natural
Resources.
                               146

-------
                       * DRAFT  (3/5/91) *

Iversen,  K.V.,  R.H.  Fox,   and  W.P.  Piekielek.  1985.    The
relationships of nitrate  concentrations in young corn (Zea mays L.)
stalks to soil  nitrogen  availability and grain yields.   Agronomy
Journal.  77:927-932.

Jaffe, E.R.   1981.   Methaemoglobenemia.   Clinics in Haematology.
10(1):99-122.

Jaffe, E.R. and H.  Hsieh.  1971.  DPNH-methemoglobinemia reductase
deficiency   and  hereditary  metheinoglobinemia.     Seminars  in
Haematology. 8(4):417-437.

Jansson, E.  1987.  Medical, environmental and economic information
on nitrates, nitrites, and N-nitroso compounds.  Prepared for the
National Network to Prevent Birth Defects, Washington, D.C. 93 pp.

Jaworski,  N.A.    n.d.   Sources of  nutrients  and the  scale  of
eutrophication  problems  in  estuaries.   Neilson,  B.J.  and  L.E.
Cronin (eds.)/ Estuaries  and Nutrients.  Humana Press, Clifton, New
Jersey.  83-110.

Jaworski, N.A.  1989.  A  watershed  analysis of  nitrogen balance in
the Upper Potomac.  Pre-publication draft.

Johnson, C.J., et al.   1987.  Fatal  outcome of methemoglobinemia in
an infant.   Journal of the American Medical Association.  257:2796-
2797.

Johnson, D.C.   1990.   Floriculture and environmental horticulture
products:   A production and  marketing statistical review,  1960-
1988.    Economic Research  Service,  U.S.  Dept. of  Agriculture,
Washington D.C.  Statistical  Bulletin  817.

Johnson, K.T.  1986.  Fertilizer and water quality.  Association of
American Plant Food Control Officials, Official Publication No. 40.

Jones, R.A.,  and G.F. Lee.   1990.   Evaluation  of the impact of
urbanization  of a  forested  watershed  on eutrophication-related
water quality.  Poster presentation at poster session  of California
Watersheds  at  the Urban  Interface—Third   Biennial Conference.
Organized by the Watershed Management Council and  the  Univ.  of
California Water Resources Center,  Ontario,  California.   October.

Kann, J. and C.M. Falter.  1987.  Development  of toxic blue-green
algae  blooms in Black Lake,  Kootenai  County, Idaho.    Lake and
Reservoir Management Journal.  3:99-108.

Keeney,  D.R.    198_.   Sources of  nitrate to  ground water.   CRC
Critical Reviews in Environmental Control.  16(3):257-304.


                               147

-------
                       * DRAFT  (3/5/91) *

Keeney, D.R.  1983.  Transformations and transport of nitrogen.  F.
Schaller   (ed.),  Proceedings   of  the  National  Conference  on
Agricultural Management and Water Quality held at Ames, Iowa.  May
26-29, 1981.  48-63.

Keeney, D.R.  1986.  Nitrogen management for maximum  efficiency and
minimum pollution.  F.J.  Stevenson (ed.),  Nitrogen in Agricultural
Soils.    Agronomy  22:605-650.    American Society  of  Agronomy,
Madison, Wisconsin.

Kennedy, J.   1990.   Personal Communication.   The Chesapeake Bay
Foundation.  Richmond, VA.  July.

Kittleson, K.M.   1987.   The groundwater problem in Michigan:  An
overview.  F.M.  D'ltri and L.G.  Wolfson.  (eds.), Rural Groundwater
Contamination.  Lewis Publishers, Chelsea, Michigan.

Klaseus, T.G. and J.W. Hines.   1989.  Pesticides  and groundwater:
A survey of selected private wells in Minnesota.

Koelliker,   J.K.,   D.L.   Gosh,  and   J.M.   Steichen.      1988.
Identification  of  factors  related  to  nitrite   and  pesticide
contamination of farmstead wells.  Kansas Agricultural Experiment
Station.  Publication No. 88-578A.

Kramer,  L.A.,  A.T.  Hjelmfelt,  Jr.,   and E.E.  Alberts.     1989.
Watershed runoff and nitrogen loss from ridge-till and conventional
till corn.  American Society of  Agricultural Engineers.  Paper No.
89-2502.

Kramer, R.A., W.T. McSweeney,  W.R. Kerns,  and  R.W. Stavrod.   1984.
An evaluation of alternative policies  for  controlling agricultural
nonpoint source pollution.  Water Resources Bulletin.  20(6):841-
846.

Langeweg,  I.F.   (ed.).     1989.    Eutrophication  of  soil  and
groundwater.  Concern for Tomorrow.  National Institute of Public
Health and Environmental Protection, The Netherlands.  151-168.

Lawrence, C.R.  1983.  Nitrate-rich groundwaters  of Australia.  A
ustralian  Water  Resources Council.    Technical paper  no.  79.
Australian Government Publishing Service, Canberra, Australia.

Leahy,  P.P.,   J.S.  Rosenshein,   and  D.S.    Knopman.      1990.
Implementation  plan for  the National  Water  Quality  Assessment
Program.  U.S. Geological Survey Open-file Report 90-174.

Lee, C.Y., R.S.  Shallenberger,  D.L.  Downing,  G.S. Stoewsand, and
N.H. Peck.  1971.  Nitrate- and nitrite-nitrogen  in fresh, stored
and processed table beets  and  spinach from  different  levels of

                                148

-------
                       * DRAFT  (3/5/91) *

field   nitrogen  fertilization.      Journal   Sci.   Fd.   Agric.
22(February).

Lee, G.F. and R.A. Jones.   1988.  The  North American experience in
eutrophication  control.     Proceedings  of   the  International
Conference on Phosphate, Water  and Quality of Life held at Paris.

Lider, B. and Koch.  1980.  Algae growth potential in the Truckee
River,  Lahontan  Reservoir and Pyramid  Lake,  Nevada.    Desert
Research Inst.  May.

Liessens J., R. Germonpre,  W.  Verstrate.   1990.  Comparative study
of processes for the biological  denitrification of drinking water.
Belgium.

Longstreth, J., and L.  Buc.  1988.  Health effects of nitrates and
nitrites.  Task 1 review  of the ICF Toxicity profile of nitrate,
nitrite,  and  N-nitroso  compounds.    Prepared  by  ICF/Clement
Associates, Inc.  for U.S. EPA,  Washington D.C.  14 pp.

Lowrance,  R.,   R.  Todd,  Fail,  Jr.,   O.  Hendrickson, Jr.,  Ralph
Leonard, L. Asmussen. 1984.  Riparian forests as nutrient filters
in agricultural watersheds.  Bioscience.  34:374-377.

Ludwig, R.D.,  L.D.  Ronald,  and  A.S.  Donald.   1990.  Agricultural
drainage wells: Impact on ground water.  U.S.  EPA, Washington D.C.
RSKERLADA-9037.

Lund, J.W.G.   1974.  Phosphorus  and  the eutrophication problem.
Nature.  249:797.

Madision, R.J. and J.O. Brunett. 1985.  Overview  of the occurrence
of nitrate  in  groundwater of the United  States.   National water
summary 1984 - Hydrologic events, selected water quality trends and
ground water resources.  U.S.  Geological  Survey Water Supply Paper
2275.  U.S. Government Printing Office, Washington D.C.  93-105.

Magdoff, F.R., D. Ross, and J.  Amadon.  1984.  A soil test for ni
trogen availability to corn.  Soil Sci. Soc. Am.  Journal 48:1301-
1304.

Marchetti, R.,  A. Provini  and G.  Gross.   1989.  Marine Pollution
Bulletin.  20,  168.

McCray, K.  1986.   Wellwater industry  survey.  Well Water Journal.
September:58-62.

McCray,  K.     1987.    Tapping  the   water  market.    American
Demographics.  January:42-44.


                                149

-------
McFarland, M.
ater Journal.
        * DRAFT (3/5/91)  *

1988.  Treating water containing nitrates.
42(8):26-27.
Well W
Neisinger,  J.J.   1984.   Evaluating plant-available  nitrogen in
soil-crop systems.   Nitrogen in crop Production.   Madison: ASA-
CSSA-SSSA.

Merkel, W.  1985.  Field actions working paper.   Paper presented at
Workshop on Groundwater  Protection  Against Pollution by Nitrates
held at Varese, Italy.   July 3-5.   European Institute for Water,
Strasbourg.

Minnesota Department of Health.  1989.   Prepared  for Office of
Ground  Water,  Office of  Water,  U.S.   EPA Region V,  Chicago,
Illinois.

Mirvish, S.S.  1972.  Inhibition of the formation of carcinogenic
N-nitroso compounds by ascorbic acid and other compounds.  Eppley
Inst.  for  Research  on  Cancer,  University  of Nebraska Medical
Center, Omaha, Nebraska.

Mirvish, S.S.   1983.  The etiology of gastric cancer:  Intragastric
nitrosamine formation and other theories.  Journal of the National
Cancer Institute.  71:629-647.

Monterey County Flood Control and Water Conservation District.  1
988.  Nitrates in ground water:  Salinas Valley, California.
Moody, D.W.  1990.  Groundwater contamination in the United States.
Journal of Soil and Water Conservation.  45(2):170-179.

Morton, T.G., A.J. Gold and W.M. Sullivan.  1988.  Influence of o
verwatering and fertilization on nitrogen losses from home lawns.
Journal of Environmental Quality.  17(1):124-130.

Mossbarger, Jr., W.A., and R.W.  Yost.  1989.  Effects of  irrigated
agriculture  on groundwater  quality in  the Corn  Belt  and Lake
States.  Journal of Irrigation and Drainage Engineering. 15(5):773-
790.
Mueller, W.   1989.
January:10-12.
       Dealers at the  source.   Agrichemical  Age.
National Network to  Prevent  Birth  Defects.
U.S. EPA re: nitrates.  August 22.
                              1988.   Letter to the
National Academy of  Sciences.   1977.   Drinking water and health.
Safe  Drinking Water Committee, Advisory  Center  on Toxicology,
Assembly of  Life Sciences,  National Research Council, Washington
D.C.  939 pp.
                               150

-------
                       * DRAFT  (3/5/91) *

National Academy of Sciences.   1978.  Nitrates:  An environmental
assessment.  Prepared for the U. S. EPA by the Panel on Nitrates,
Coordinating Committee for Scientific and Technical Assessments of
Environmental Pollutants, Environmental Studies Board, Commission
on Natural Resources, National  Research Council,  Washington D.C.
723 pp.

National  Academy of  Sciences.    1981.   The  health  effects  of
nitrate, nitrite, and N-nitroso  compounds. Part 1 of a 2-part study
by the Committee on Nitrate and  Alternative Curing Agents in Food,
Assembly  of  Life Sciences,  National Research Council,  Washington
D.C.

National Acid Precipitation Assessment Program.  1987.  Interim a
ssessment:   The causes  and effects of acid  deposition.    NAPAP,
Council   on  Environmental   Quality,   Executive  Office  of  the
President, Washington, D.C.

Nelson, M.E., S.w. Horsley, T.C. Cambareri, M.D. Giggey, and J.R.
Pinnette.   1988.   Predicting  nitrogen concentrations in ground
water  - An  analytical  model.   National  Water  Well  Association
Conference, FOCUS on Eastern Ground Water Issues held at Stamford,
Connecticut.  Sept. 27-29.

New Mexico Water Quality Control Commission.  1988.  Water quality
& pollution control in New Mexico.   Prepared  for submission to the
Congress of the U.S. by the State of New Mexico  pursuant to section
305  (b) of the  Federal Clean Water Act (CWA).  April.

Nielsen,  E.  G.,  and L.K.  Lee.   1987.   The magnitude and costs of
groundwater contamination from agricultural  chemicals:  A national
perspective.  Resources and Technology Division, Economic Research
Service, U.S. Dept. of Agriculture, Washington D.C.  Agricultural
Economic Report no. 576.  October.  38 pp.

Nightingale, H.I., and R.L. McCormick.  1985.   Chemical quality of
perched septic  tank effluent for plant use and recharge.  Journal
of the Water Pollution Control  Federation. 57(9):916-920.

Nitrate  and Nitrite  in  Vegetables.   Literature Survey  No.  39.
Center for Agricultural Publishing and Documentation.  Wageningen,
The Netherlands.  85 pp.

Nitrate  Working  Group.     1989.     Nitrate  and  agriculture  in
California.    California  Department  of  Food and  Agriculture.
Sacramento, California.

Nitrogen transformations during subsurface disposal of  septic tank
effluent   in  sands:  II   ground  water  quality.     Journal  of
Environmental Quality.  2(4):521-525.

                                151

-------
                       * DRAFT (3/5/91) *

Nixon,  S.A.    1983.    Estuarine  ecology  - A  comparative  and
experimental analysis using 14 estuaries and the MERL microcosms.
Final report to the U.S. EPA under grant no. X-003259-01.

Nowak, P.J., and P.F. Korsching.  1983.  Social and institutional
factors  affecting  the adoption  and maintenance  of agricultural
BMPs.    F.W.  Schaller  and G.W.   Bailey,   (eds.),  Agricultural
Management and Water Quality.  Iowa State University Press, Ames,
Iowa.  349-384.

North Carolina Agricultural Extension Service.  1982. State of the
art review of Best Management Practices for agricultural nonpoint
source  control,  commercial  fertilizer.    Rural  Nonpoint  Source
Control Water Quality Evaluation and Technical Assistance project.
Novotny, V. and G. Bendoricchio.
and   deterioration.      Water
November:400-407.
1989.   Linking nonpoint pollution
 Environment   and   Technology.
Nowak, P. J.,  and P. F. Korsching.  1983.  Social and institutional
factors  affecting the adoption  and maintenance  of BMPs.   F.W.
Schaller and G.W. Bailey  (eds.),  Agricultural Management and Water
Quality.  Iowa State University Press, Ames, Iowa.  349-384.

Odum, E.P.  1971.  Fundamentals of Ecology.

Ohshima H. and H. Bartsch.  1981.  Quantitative estimation of end
ogenous  nitrosation  in   humans  by  monitoring  N-nitrosoproline
excreted in the urine.  Cancer Research.  41:3658-62.

Oklahoma State Department of Health.  Environmental Health Service.
1987.   Comparison of  expected  ranges for  different  aquifers as
measured by existing monitoring systems.

Olsen,  R.J.,  R.F.  Hensler,  O.F.  Attoe,  S.A.  Witzel,  and L.A.
Peterson.  1970.   Fertilizer nitrogen and crop rotation in relation
to  movement of  nitrate   nitrogen  through  soil  profiles.   Soil
Science Society of America Proceedings.  34:448-452.

Packer,  P.J.,  S.A.  Leach, S.N.  Duncan,  M.H. Thompson,  and M.J.
Hill.  1989.  The effect  of different sources of nitrate exposure
on  urinary  nitrate  recovery in  humans and its relevance to the
methods of estimating nitrate exposure in epidemiological studies.
Carcinogenesis.   10(11):1989-1996.

Paerl, H.  1988.  Limnology and Oceanography.  33, 823.

Patrick,  R.,  E.  Ford  and J.  Quarles.    1987.    Groundwater
Contamination  in the U.S.   2nd  ed.    University  of Pennsylvania
Press.  Philadelphia.  513 pp.

                               152

-------
                       * DRAFT  (3/5/91) *

Pennsylvania State University, College of Agriculture,  n.d.  Use
of Manure.  University Park, Pennsylvania.

Pereira, L.S. and J. Quelhas dos Santos.  1990.  Fertilizing, water
management, and nitrates pollution.   Paper presented at the 1990
NATO Conference on Nitrates in Lincoln, Nebraska.  August.

Petrovic, A.M.  1990.   The  fate  of nitrogenous fertilizers applied
to turfgrass.  Journal of Environmental Quality.  19(1):1-14.

Ponnampalam, R. and N.I. Mondy.  1985.  Effect of  sprout inhibitors
and nitrogen fertilization on nitrate-N content  of potato tubers.
Journal of Food Science.  50(5):1246-1248, 1256.

Porter, K.S., L.B. Baskin and D.H. Zach.  1977.  Use and relative
environmental effects of fertilizers applied to  cropland and turf
in  a  mixed  rural and suburban area.   R.C. Loehr  (ed.),  Food,
Fertilizer   and   Agricultural  Residues.    Ann  Arbor  Science
Publishers, Inc., Ann Arbor, Michigan.  279-297.

Reneau, R.B. Jr.,  C. Hagedorn,  and M.  J.  Degen.   1989.   Fate and
transport  of biological  and  inorganic  contaminants  from on-site
disposal of domestic wastewater. Journal  of  Environmental Quality
18(2):135-144.

Richardson,  T.G.    1977.    Nursery  greenhouse wastewater study.
California   Polytechnic   State  University,  San   Luis  Obispo,
California.  75 pp.

Riggan,  P.,  R. Lockwood,  and E. Lopez.   1985.    Deposition and
processing  of  airborn nitrogen  pollutants  in Mediterranean-type
ecosystems   of  southern  California.     Environmental  Science
Technology.  19(9):781-789.

Ritter, W.F.,  F.J. Humenik and  R.W.  Skaggs.    1989.   Irrigated
agriculture and water quality in the East.  Journal of Irrigation
and Drainage Engineering.  115(5):807-821.

Roberts,  K.D.    1990.   Occurrence of nitrate in  North Dakota's
groundwater.  North Dakota Water Quality Symposium.  Agricultural
Extension Service, North Dakota State University, Grand Forks, ND.

Rock,  C.A.,  S. Irrinki  and S.  Pinkham.   1990.   Elimination of
groundwater contamination by septic tank effluent. Paper presented
at  NATO  Advanced  Research  Workshop—Nitrate  Contamination:
Exposure  Consequences and Control—held  at Lincoln,  Nebraska.
Sept. 9-14.

Rogalla, F., G. de Larminat, J. Coutelle, and H. Godart.  1990
Experience with nitrate removal methods from drinking water.  Paper

                               153

-------
                       * DRAFT  (3/5/91) *

presented    at   NATO   Advanced    Research   Workshop—Nitrate
Contamination,  Exposure,  Consequences  and  Control.    Held  at
Lincoln, Nebraska.  Sept. 9-14.

Ryther, J.H. and C.B.  Officer,  n.d.  Impact of Nutrient Enrichment
on Water Uses.  B.J. Neilson and L.E.  Cronin (eds.), Estuaries and
Nutrients.  Humana  Press, Clifton, New Jersey.  247-261.

Ryther, J.H.   1969.   Science. 166, 166.

Saffigna,  P.G.,  and  D.R. Keeney.   1977.   Nitrogen and chloride
uptake by irrigated russet burbank potatoes.  Agronomy Journal. 69,
258.

Sander J.,  and F.  Seif.   1969.   [German],  Bakterielle Reduktion
von Nitrate im Magen  des Menschen als Ursache einer Nitrosamine-
Bildung.  Arzneimittel-Forsch.  19:1901-1903.

Schepers, J.R. and  D.L.R. Hay.   Impacts of chemigation on ground
water contamination.  Rural Ground Water Contamination.

Schindler,  D.W.    1977.   Evolution  of phosphorus  limitation in
lakes:  Natural mechanism compensates for deficiencies of nitrogen
and carbon  in eutrophic lakes.  Science.  195:260-262.

Schweiger,  P.  1987.  [German].   Beurteilung der Sonderkulturen in
Hinblick auf die Gefahr des Stickstoffaustrages in das Grundwasser.
In  Stichstoffduengung und  Nitrateeintrag  ins Oberflaechen- und
Grundwasser.  Proceedings of the Wuerzburger Conference of April 9-
10,  1987  of  the  Verbandes der  Landwirtschaftskammern and the
Fachverbandes StickstoffIndustrie.

Shapiro, J.  1980.   On the role  of  nitrogen  fixations in lakes and
on the  relative  merits of phosphorus versus nitrogen removal in
controlling algae populations.  Rebuttal to Dr. Joseph Shapiro in
the matter of  National  Pollutant Discharge  Elimination  System
permit  for Blue  Plains  Sewage  Treatment  Plant,  Permit  No.
OC0021199,  Docket NO. DC-AH-102.

Shirley, R.L.   1975.  Nutritional and physiological  effects of
nitrates, nitrites, and nitrosamines.  Bioscience.  25:789-794.

Shirohammadi, A.  and W.G. Knisel.  1989.   Irrigated agriculture and
water quality  in the South.  Journal of  Irrigation and Drainage
Engineering.  15(5):791-806.

Shuval,  H.I.,  and  N.   Gruener.     1972.    Epidemiological  and
toxicological aspects of  nitrates and nitrites in the environment.
American Journal of Public Health.  62:1045-1052.
                               154

-------
                       * DRAFT  (3/5/91) *

Shuval, H.I., and N.  Gruener.  1977.  Health effects of nitrites in
water.  Health Effects Research Laboratory,  Office of  Research and
Development, U.S. EPA, Cincinnati,  Ohio.   EPA 600/1-77-030.  164
pp.

Simmonds,  B.  and D.  Brosten.   1990.   On running  a  tight ship.
Agrichemical Age.  Nov:8-9+.

Smika, D.E., D.F. Heennann,  H.R. Duke, and A.R.  Bathchelder.  1976.
Nitrate-N  percolation  through  irrigated sand soil as affected by
water management.  Agronomy Journal.  69:623-626.

Smith, R.A., R.B. Alexander and M.G. Wolman.  1967.  Science.  235,
1607.

Smith, V.  H.   1982.   The  nitrogen  and phosphorous dependence of
algal biomass  in lakes:   An empirical  and theoretical analysis.
Limnology  and Oceanography. 27(6):1101-1112.

Snyder,  G.H.    1979.    Fertigation for  managing  turf  nitrogen
nutrition.   Golf Course Superintendents'  Association of America
50th International Turfgrass Conference and Show Proceedings.  163-
167.

Snyder, G. H. and E.G. Burt. 1977.   Some agronomic aspects of turf
fertigation.  USGA Green Section Record.  May:10-12.

Snyder,  G.H.,  E.O.  Burt and  J.M.  Davidson.   1980a.   Nitrogen
leaching in bermudagrass turf:   Daily fertigation vs. tri-weekly
conventional fertilization.  J.B. Beard (ed.), Proceedings of the
Third International Turfgrass Research Conference held at Munich,
Federal Republic of Germany. The International Turfgrass Society.
July 11-13.  185-193.

Snyder,  G.H.,  E.O.  Burt and  J.M.  Davidson.   1980b.   Nitrogen
leaching  in  bermudagrass turf:   Effect of  nitrogen  sources and
rates.  R.W. Sheard (ed.),  Proceedings  of the Fourth International
Turf grass Research Conference held at Guelph, Ontario,  Canada.  The
International Turfgrass Society.  July 19-23.  313-323.

Steudler,  P.A., R.D. Bowden, J.M. Melillo, and J.D. Aber.  1989.
Influence of nitrogen fertilization on methane uptake  in temperate
forest soils.  Nature.  341:314-316.

Stumm,  W.   and   J.J.  Morgan.     1981.    Aquatic  chemistry:    An
Introduction Emphasizing Chemical Equilibria  in  Natural Waters.
Wiley Interscience Publishers,  John Wiley and Sons,  New York.  780
pp.

Sturm,   H.       1987.       [German].    Beziehungun   zwischen

                               155

-------
                       * DRAFT (3/5/91)  *

Landbewirtschafttung and Nitratgehalt  im Sickerwasser-Ergebnisse
aus Lysimeter und Tiefenbohrungsversuchen.  In Stichstoffduengung
und Nitrateeintrag ins Oberflaechen- und Grundwasser.  Proceedings
of the Wuerzburger Conference of April 9-10, 1987 of the Verbandes
der    Landwirtschaftskammern    and    the    Fachverbandes
StickstoffIndustrie.

Suttle, C.A.  and P.J. Harrison.   1988.   Ammonium  and phosphate
uptake rates,  N  :  P  supply ratios,  and evidence for  N and  P
limitation in some oligotrophic lakes. Limnology and oceanography.
33(2):186-202.

Szwonek,  E.  1986.  Nitrates concentration in lettuce and spinach
as dependent on nitrate doses.  Acta Horticulture.   176:93-97.

Tannenbaum, S.R., and P. Correa.  Nitrate  and gastric cancer risks.
Nature.  317:675-676.

Taylor,  H.  and  H.  Vroomen.    1989.     Timing  of  fertilizer
applications.    Agricultural  Resources,   Situation  and  Outlook.
Economic  Research   Service,   U.S.  Department  of  Agriculture,
Washington D.C.  Publication AR-15.

Teixeira, J.L.,  and  L.S. Pereira.  1990  (in press).   ISAREG:   An
irrigation scheduling  simulation  model.   Workshop  on Crop Water
Models.  ICID, Rio de Janeiro.

Tennessee Valley Authority.   National Fertilizer and Environmental
Research Center.   1990.  Development  of  an information/education
program for dealers.  Mimeo.

Tobin,  G.A.   and  R.  Rajagopal.    1990.    Expert  opinion  and
groundwater  quality:   The  case  of agricultural drainage wells.
Journal of Soil and Water Conservation.   45(2):336-341.

U.S. Congress.   Office of Technology  Assessment.   1990.   Beneath
the bottom line:   Agricultural approaches to  reduce agrichemical
contamination  of groundwater.   U.S.  Government  Printing Office,
Washington D.C.  OTA-F-417/418.  May.

U.S. Department  of Agriculture.   1988.   Objective  Yield Survey.
Economic Research Service,  Washington D.C.

U.S. Department  of Agriculture. 1989.  The second  RCA appraisal:
Soil, water and related resources  on nonfederal land in the United
States—Analysis  of  conditions and trends.   Government Printing
Office, Washington D.C.

U.S. EPA.  1976.   Quality criteria for water:  Nitrates, nitrites.
National Technical Information Service publication no. PB263-943.

                               156

-------
                       * DRAFT  (3/5/91) *

Springfield, Virginia.  107-110.

U.S. EPA.   1977.   Environmental  effects of septic  tanks.   M.R.
Scalf and W.J. Dunlap.  EPA-600/3-77-096.

U.S. EPA.   1980a.   A strategy for  small  alternative wastewater
systems.   Office of  Water Program Operations,  Office of Water,
Washington D.C.

U.S.  EPA.    1980b.    On-site wastewater treatment  and disposal
systems process design manual.  Office of Water  Program Operations,
Office  of  Water  (Washington  DC)   and  Municipal  Environmental
Research  Lab,  Office of  Research  and  Development  (Cincinnati,
Ohio).

U.S. EPA.  198la.  Clean lakes program guidance  manual.  Washington
D.C.  EPA 440/5/81-003.

U.S. EPA.   1981b.    Restoration  of  inland lakes  and waterways.
Washington D.C.  EPA  440/5-81-010.

U.S. EPA.  1983a.  Land application of municipal sludge process d
esign manual.   EPA/626/1-83-016.  Center for Environmental Research
Information, Office of Research and Development.  Cincinnati, Ohio.

U.S. EPA.  1983b.  Results of the  nationwide urban runoff program:
Volume l, Final Report.  Water Planning Division, Office of Water,
Washington, D.C.  8.3-8.8.

U.S.  EPA,  Region  3.   1983.   Chesapeake  Bay:   A  framework for
action.  Philadelphia.

U.S. EPA.   1984a.   Evaluation  of septic  tank system effects on
ground water quality. L.  Canter  and R.C.  Knox.  Washington D.C.
EPA-600/2-84-107.

U.S. EPA.  I984b.  Evolution of state codes  and  their implications.
J.F. Kreissel, Risk Reduction Engineering  Lab,  Office of Research
and Development, U.S.  EPA, Cincinnati, Ohio.   17 pp.

U.S. EPA.  1984C.  Lake and reservoir management.  Washington D.C.
EPA 440/5-84-003.

U.S. EPA.  1984d.  Policy on municipal sludge management.  July 12,
FR 49(114):24358-24359.

U.S. EPA.   1985.   Ambient water quality  criteria  for ammonia -
1984.     National  Technical  Information  Service,  Springfield
Virginia, publication no.  #PB85-227114.


                                157

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                       * DRAFT  (3/5/91) *

U.S. EPA.   1987a.   Letter to the Administrator.   Prepared by the
Environmental Health Committee, Science Advisory Board, U.S. EPA,
Washington D.c.  May 11.

U.S. EPA.   1987b.   Letter to the Science Advisory Board from the
Administrator, Lee Thomas.  Washington D.C.  July 2.

U.S. EPA.   1987c.   Report to Congress.   Class V injection wells:
Current   inventory,   effects   on   ground   water,   technical
recommendations.    Office  of  Drinking Water,  Office  of  Water,
Washington D.c.

U.S.  EPA.    1988a.    Draft  National  primary  drinking  water
regulations—Synthetic   organic    chemicals,    monitoring   for
unregulated  contaminants.   Office  of Drinking Water,  Office of
Water, Washington D.C.  40 CFR Parts  141 and 142.

U.S. EPA.   1988b.   Is prevention of contamination cheaper than
treatment at the wellhead?  Policy Analysis Exercise,  Final Report.
R. Warden, U.S. EPA Region I, Boston.

U.S. EPA.  1988c.   Letter to  the National Network to  Prevent Birth
Defects,  from  Rebecca Hanmer  (Acting Assistant  Administrator,
Office of Water) and John A. Hoore (Assistant Administrator, Office
of Pesticides and Toxic Substances).  Washington D.C.  July 21.

U.S. EPA. 1988d.  Nitrogen-ammonia/nitrate/nitrite.   Water quality
standards criteria summaries:   A  compilation of   state/federal
criteria.   Office of Water Regulations and Standards,  Office of
Water, Washington D.C.  EPA 440/5-88-029.

U.S. EPA.  1988e.   Regulatory impact  analysis of proposed national
primary  drinking  water  regulations  for  inorganic  chemicals.
Washington D.C.

U.S.  EPA.    1989a.    1988   needs   survey report   to  Congress:
Assessment of needed publicly-owned wastewater treatment facilities
in the U.S.  Office of Municipal Pollution Control, Office of Water,
Washington D.C.  EPA 430/9-89-001.

u.s. EPA.    I989b.   Ambient  water  quality criteria for ammonia
(saltwater)   -  1989.   Office of Water Regulations  and Standards,
Office of Water, Washington D.C.  EPA 440/5-88-004.

U.S. EPA. 1989c.  Report to the Congress:   Activities and programs
implemented under  section  319 of the Clean Water Act  - FY 1988.
Washington D.C.  EPA 5061 9-89/003.

U.S. EPA.   1989d.  Water  quality standards:  Framework.   Draft
background document.   Office  of Water Regulations and standards,

                               158

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                       * DRAFT  (3/5/91) *

Office of Water, Washington DC.  December.

U.S. EPA.  1990a.   Agricultural drainage  wells:  Impact on ground
water.   Ludwig,  R.D.,  R.L.  Drake,  and D.A. Sternitzke, Robert S.
Kerr  Environmental  Research   Lab,   Office  of   Research  and
Deve1opment, Ada, Oklahoma.

U.S.  EPA.    1990b.    Federal   Reporting  Data  System,  nitrate
violations.  Report No. 24 (Community systems). Office of Drinking
Water, Office of Water, Washington D.C.  June 25.

U.S. EPA.  1990C.  National  survey  of  pesticides  in drinking water
wells:  Phase I  report.  Office of Drinking Water, Office of Water,
Washington D.C.  EPA 570/9-90-015.  November.

U.S. EPA.  1990d.  A plan for research on the role of  atmospheric
nitrogen  and toxic pollutants  in coastal waters.   Office of
Research  and Development,  Washington DC.    EPA report no.  600/X-
90/158.

U.S.  EPA/Army  COE/DOI/USDA.    1981,   1984.    Land  treatment of
municipal  wastewater  process   design manual  (A joint  EPA/Army
COE/DOI/USDA  manual).      Center   for   Environmental  Research
Information, Office of Research and Development,  Cincinnati, Ohio.
EPA 625/1-81-031; EPA 625/l-81-031a.

U.S. EPA/FDA/USDA.  1981.  Land application of municipal sewage for
the production  of  fruits  and vegetables:   A statement of federal
policy and guidance. SW-905.

U.S. EPA/State of Massachusetts Executive Office of Environmental
Affairs.  1990.  Buzzards Bay comprehensive conservation management
plan:  Executive summary.  Public draft.  Boston.

U.S. General Accounting Office.   1982. State's compliance lacking
in  meeting  Safe  Drinking  Water  Regulations.    Report  to  the
Administrator, U.S. EPA, Washington D.C.  March.   Report no.  CED-
82-43.

U.S. General Accounting Office.  1990.  Drinking water:  Compliance
problems  undermine  EPA  program  as  new  challenges  emerge.
Washington D.C.  GAO/RCED-90-127.

University of Wisconsin Agricultural Extension and Wisconsin Dept.
of Agriculture,  Trade and Consumer Protection.  1989.  Nutrient and
pesticide Best  Management Practices  for Wisconsin  farms.   WDATCP
Technical Bulletin ARM-1.  Madison, Wisconsin.  June.

van  Eysinga, R.   1984.    Nitrate  and   glasshouse  vegetables.
Fertilizer Research.  5(2):149-156.

                                159

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                       * DRAFT (3/5/91) *

Varner, L.K.  1990.  Growing green, clean:  Studies find fertilizer
safe—if used properly.  The Washington Post,  Washington D.C.  July
26:Md. 1, 3.

Virginia State  Water Control Board.   1990.   Data  printout from
Voluntary Nutrient Monitoring Program.  Richmond, Virginia.
von  Weizsacker,  E.U.    1989.    Erdpolitik.
Buchgesellschaft, Darmstadt.  38.
     Wissenschaftliche
Wade Miller Associates, Inc.   1988.  Regulatory impact analysis of
proposed  drinking  water  regulations   for  inorganic  chemicals.
Prepared for Office of Drinking Water,  Office of Water, U.S. EPA,
Washington D.C.

Wade Miller  Associates.    1989a.   Regulatory impact  analysis of
proposed national primary drinking water regulation for inorganic
chemicals.    Prepared  for Office  of  Drinking Water,  Office of
Water, U.S EPA, Washington DC.

Wade Miller  Associates.  I989b.   Regulatory  impact  analysis of
proposed national primary drinking water regulation for synthetic
organic chemicals. Prepared for Office of Drinking Water, Office of
Water, U.S. EPA, Washington DC.

Wade Miller Associates, Inc.   1990.  Estimated national occurrence
and exposure to nitrate/nitrite in public drinking water supplies.
Prepared for U.S. EPA.  Washington D.C.  July.  30 pp.

Walker,  W.G.  et.  al.   1973.   Nitrogen transformations  during
subsurface disposal of septic  tank effluent in sands:  Ground water
quality.  Journal of Environmental Quality.   2(4):521-525.
Wardlaw, L.A.,  and W.H.  Bruvold.  1989.
notification under  the Safe  Drinking Water Act.
Bulletin.  25(4):837-844.
Evaluation of consumer
       Water Resources
Water  Quality 2000, Agricultural  Work Group.
report. Mimeo.
      1990.
Phase II
White W. C.  1989.  Sources of nitrogen and phosphorus.  Report p
repared  for the  Office of  Policy Analysis,  Office  of Policy,
Planning, and Evaluation,  U.S.  EPA, Washington D.C.   Draft Issue
Paper Regarding Livestock  Impacts on Water Quality.

Whitledge,  T.E.    Nationwide  review  of  oxygen  depletion  and
eutrophication in estuarine and coastal waters:  Executive summary.
Report submitted to the Brookhaven National Lab, National Oceanic
and Atmospheric Administration, Upton, New York.
                               160

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                       * DRAFT (3/5/91) *

Yates,  M.V.     1985.     Septic   tank  density  and  groundwater
contamination.  Ground Water. 23(5):586-591.

Young, K. and K.  Mancl.  n.d.  Nitrate:  Its effect on families and
livestock.  Extension Service, College of Agriculture, Pennsylvania
State University, University Park,  Pennsylvania.  Special circular
308.
                               161

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