United States
            Environmental Protection
            Agency
             Office of
             Ortflking Water
             Washington, DC 20460
November 1980
            Water
&EPA
Proposed Ground Water
Protection Strategy

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PROPOSED GROUND WATER PROTECTION

             STRATEGY
                 U.  3. ENVIRONMENTAL  PROTECTION AGENCY
                       OFFICE OF  DRINKING WATER
                            NOVEMBER  1980

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\         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
 °                     WASHINGTON, D.C. 20460

'
                        November 18,  1980
                                                     OFFICE OF WATER
                                                   AND WASTE MANAGEMENT
    Dear Reader:

         This proposed Ground Water Protection Strategy has
    been formulated over the past months with the active
    participation of a number of State and local government
    officials, business, environmental,  academic and public
    interest groups.  When adopted in its final form,  the
    strategy will serve as EPA's policy framework,  particularly
    in relationships with the States, in the area of ground
    water protection.

         A series of public hearings are now scheduled to seek
    even wider public participation and advice.   At these
    hearings, or  through written responses,  we are soliciting
    comments on all aspects of the proposed strategy which sets
    forth a division of responsibilities at the Federal, State
    and local levels.  We especially seek comment on the following
    questions;

         1.  Is the policy goal based upon "present
             and  projected future uses..." a sound
             and  workable goal?  Conversely, should
             alternative goals be selected,  such as
             non-degradation for some or all ground
             waters?  What would be the practical
             implication of such approaches?

         2.  Are  State strategies a useful vehicle
             for  helping to improve State efforts
             toward ground water protection?  For
             focusing EPA and other federal
             assistance on State and local concerns?

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                        -2-
3.   Is ground water classification an
    effective and useful approach to
    setting priorities on the protection
    of significant ground waters?  To
    identifying appropriate areas for siting
    new hazardous waste disposal facilities
    and other facilities with the potential
    for seriously affecting ground-v/ater
    quality?

4.   What are the technical impediments to
    carrying out a classification system?
    Are there social, economic or political
    impediments?  What steps should be taken
    at the Federal, State or local levels to
    overcome such impediments?

5.   What criteria might be devised to ensure
    appropriate participation of local
    authorities in the formulation of State
    ground water protection strategies and
    in classifying ground waters?

6.  Is the proposed system for developing
    national criteria for ground water
    classification appropriate for State
    implementation?  Are the associated
    Federal, State and local responsibilities
    applicable and useful or should
    alternative approaches be considered?

7.  is there any basis for concern that the
    proposed Ground Water Protection Strategy
     (or any part of it) would preclude or
    hamper EPA or the States from acting
    under their "imminent hazard" statutes
    to protect the public health or to deal
    with significant environmental threats?

8.  Should EPA seek new Federal legislation
    to implement this strategy (or selected
    parts of it) immediately or should we
    await additional experience as outlined
    in the proposed strategy?

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                          -3-
     9.  Are there areas of ground water protection
         into which the Federal government should
         not intrude itself?  What would be the
         impact of leaving these areas exclusively
         to state and local control?

     To submit public comments or obtain further information,
write Ms. Marian Mlay, Associate Deputy Assistant Administrator
for Drinking Water, WH-550, Environmental Protection Agency,
401 M St., S.W., Washington, D.C. 20460.  Expressions of
interest in testifying at one of the hearings may be telephoned
to 800-424-9159.

     Public hearings will be held as follows:
January 12-13, 1981
January 15-16, 1981
January 29-30, 1981
Atlanta Marriott
Courtland at International Blvd.
Atlanta, GA

Denver Hilton
1550 Court Place
Denver,  CO

First International Bldg.
1201 Elm Street
29th Floor Conference Facility
Dallas,  TX

Social Security Auditorium
4th and Spring Garden Streets
Philadelphia, PA

Health and Human Services
  Auditorium (North)
330 Independence Ave.,  S.W.
Washington, D.C.
     All hearings will begin at 8:30 a.m., local time.
     We appreciate your interest etnd concern with ground
water protection and invite viator/participation in this crucial
issue.  The public comment peri'od/w'ill cl6se/on February 18,
                            -L     Eckardt C. Beck
                              Assistant Administrator
                           for Water and Waste Management
                                 November 18, 1980

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                           CONTENTS
EXECUTIVE  SUMMARY


PART ONE:   PREAMBLE

        I.   INTRODUCTION
      II.   INVOLVEMENT OF STATES,  INDUSTRY, PUBLIC  INTEREST
            GROUPS,  AND OTHERS
     III.   BACKGROUND ON GROUND  WATER



PART TWO:   STRATEGY

      IV.   INTRODUCTION TO THE STRATEGY


       V.   ASSUMPTIONS
      VI.   GOAL AND OBJECTIVES
     VII.   MANAGEMENT APPROACH
    VIII.   TECHNICAL REQUIREMENTS
      IX.   NEXT STEPS

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                      EXECUTIVE SUMMARY

               GROUND WATER PROTECTION STRATEGY
     The U.S. Environmental Protection Agency (EPA)  is
proposing this ground water protection strategy in response
to a growing concern over the plight of the Nation's ground
waters.  The public, along with government officials and
experts in the field, is aware that instances of ground-water
contamination have been discovered in most sections of the
country.  They are concerned that ground water is vulnerable
to even more widespread contamination in the future as our
population and industry continue to grow, thus increasing
the already staggering volume of waste to be disposed of.

     The problem is national in scope.  Approximately half
of the country's population relies on ground water for its
drinking water.  And yet protection of those water sources has
been inadequate, in large measure because until recently
conventional wisdom believed that nature protected our
underground water much more than it actually does.
Unfortunately, most of our activities on the land directly
affect the quality of the ground water underneath.

     With growing frequency, newspapers are reporting new
instances of ground-water contamination.  Dramatic problems
such as Love Canal and the Valley of the Drums have attracted
national attention, but numerous local situations of
ground-water contamination are also of concern.   Some
examples are:

     o    South Brunswick, New Jersey, where one-third
          of the local water supply for this community
          of 18,000 is unusable now as a result of
          contamination by a half gallon of solvents
          daily for a five to ten year period.

     o    St. Louis Park, Minnesota, where creosote
          contamination from a manufacturing operation
          built up over many years resulting in some
          drinking water wells being closed due to
          a tar-like taste and the discovery of
          relatively high levels of possible
          carcinogens in the ground water.

     o    Thirty square miles of the shallow aquifer
          table underlying the Rocky Mountain Arsenal
          near Denver, Colorado, are contaminated by
          chemical by-products from the manufacture of
          pesticides and herbicides, resulting in temporary
          abandonment of a number of domestic, stock,
          and irrigation wells, and final abandonment of
          two wells.

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     o    Fifty-one cases have been filed by EPA and
          the Department of Justice to force responsible
          parties to clean up dangerous hazardous waste
          siteso   Of these, 28 involve pollution of
         .ground  water,  about half of which are drinking
          water sources.

     The contaminants in all these cases are synthetic organic
chemicals.   Some  of these compounds are cancer-causing in
laboratory animals.  Some are known human carcinogens.  Many
are highly toxic.  Hundreds of thousands of chemical compounds
are in use; little is known about the health effects of most,
particularly about the impact on human health of various
combinations of compounds.

     The most frequently found industrial solvents are known
to be dangerous to human health.  When they appear in ground
water they are often in concentrations sufficiently high to
present a significant risk to health.  Aquifers do not provide
the natural dilution or flushing that occurs in surface waters.
A contaminant that penetrates ground water tends to form a
"plume" of highly contaminated water, moving slowly through
the aquifer for years, even decades.  Managing instances
where contamination is discovered to avoid future public
health problems is a major task for the future which is
beyond the past experience of most units of state and local
governments.

     EPA is under considerable pressure to assist in the
cleanup of areas  where ground-water problems have been
discovered and to take action to find potential threats and
prevent future instances of contamination.  This is not a
simple task: detecting and cleaning up contamination are
difficult and costly operations.  And ground water underlies
almost the entire country.  The little we have learned in
recent years has  taught us three sobering lessons: the problem
is real and dangerous; our present state of knowledge to deal
with these problems is limited; and present programs,
authorities and resources are inadequate.  It is clear that
while the cost of protecting ground water will be high,
the cost of continuing to ignore the problem is even higher
and clearly unacceptable from a public health perspective.

     As states mount more aggressive efforts to conduct
monitoring and ground-water quality sampling in the future,
and as more ground water monitoring is conducted pursuant
to the hazardous  waste program, more local instances
of ground-water contamination will be discovered.  The more
states look for such problems, doubtlessly, the more they will
find.  Also, normal patterns of increased industrial activity
will expand the problem.  Finally, a significant impact could
be caused by other environmental regulations which are closing
off the air, surface waters, oceans, and other media as
acceptable areas  for waste disposal.

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     The dimensions of the current ground-water problem are
becoming unmanageable.  There is no single Agency at any level
responsible for ground water protection.  Ground water manage-
ment is carried out on a state-by-state basis, with different
approaches and implementation in every state.  With the
growing number of instances of contamination and the addition
of new EPA programs affecting ground water, the states and
localities may soon be overwhelmed.

ADDRESSING GROUND WATER PROTECTION

     Numerous Federal laws and state programs deal in some
way with ground water protection and management.  Some parts of
the Clean Water Act (CWA) -- specifically, Sections 208 and
106 — have strengthened state abilities to protect ground
water.  The Safe Drinking Water Act (SDWA) through its
underground injection control and sole source aquifer
protection provisions and the Resource Conservation and
Recovery Act  (RCRA) provide for control of certain hazardous
practices and some protection for highly vulnerable areas.
Other EPA statutes which regulate toxic substances and
pesticides and the surface mining and uranium mill tailings
programs administered by other Federal agencies also
contribute protection provisions.

     In addition, EPA has now before Congress a Superfund
program which, when enacted, would help resolve problems
caused by abandoned waste disposal sites.  This proposal
provides the Federal government with both the authority and
the resources to clean up abandoned sites; permits speedy
action, prior to long judicial proceedings, to prevent and
abate situations that may threaten public health; and imposes
joint, several, and strict liability on those who caused or
are causing the problem.  This program would serve as both
a deterrent and as a means of recovering cleanup costs.

     EPA is pursuing the imminent hazard provisions of
existing statutes to protect public health and the environment.
It is accelerating its research and development efforts and
taking other steps described in greater detail in this document.
Many states are expanding their ground water protection efforts
by implementing federally delegated programs as well as devising
protection programs for some sources of contamination not
regulated by Federal statute.

     Given the extent of the problem,  with its complexities
and the potential for increasing threats to public health and
sensitive ecological systems, it is clear that significantly
increased attention must be given to this issue to manage
instances where contamination is detected and to initiate
preventive programs to avoid ground-water contamination in
the future.

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     Late last year the Administrator of EPA,  Douglas Costle,
began the formulation of a ground water protection strategy,
calling upon representatives of state and local government,
business and industry, environmental and academic groups and
the public to help.  He felt that we must obtain better
insights into this problem and clarify how,  and in what policy
direction, our nation should proceed.  It is hoped that this
strategy will help to bring focus to uncoordinated efforts,
better enabling us all protect this resource.   This strategy
should help to develop more effective relationships among
Federal, state and local governments in working together on
these problems.

     This strategy is not a detailed implementation plan.
It addresses broad policy issues rather than narrow technical
choices.  It emphasizes a preventive approach rather than
concentrating on the clean-up of known sources of contamination;
not that the latter is not a vital need, but it is already
beginning to occur as a consequence of existing legislation and
the proposed Superfund program.  The strategy is an attempt to
look to the future to assure that the quality of ground water
is protected as a resource for future generations and to
explore new approaches to ground water protection.

     The strategy focuses on key issues that are critical
to ground-water quality in order to have the most impact.
For example, it is not intended to deal with tap water
issues, such as current or proposed drinking water standards
or treatment technologies.  Likewise, the ground-water
depletion issue is not a major focus.  While depletion is a
critical issue in many sections of the country, it relates to
this strategy only as a problem that can contribute to ground
water quality problems, not as an independent issue.

     EPA is not proposing new Federal legislation.  The
immediate challenges seem to be ones of coordination, follow-
through and implementation.  As implementation of the existing
programs is completed and more time and effort are devoted
to the protection of ground water, the need for additional
legislation or significant new programs will be assessed.

     Given the far-reaching aspects of the problem, the
ground water protection strategy is being developed with broad
public debate and participation.  Workshop discussions, which
included some 80 participants from all levels of government
and from industry, public interest groups, and academia, were
instrumental in drafting this strategy.  Public comments based
on public hearings and the publication of this proposal in
the Federal Register will be considered in the final formulation
of the ground water protection strategy.

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GOAL AND OBJECTIVES

     The proposed goal for the ground water protection
strategy is:

     "It shall be the national goal to assess, protect,
     and enhance the quality of ground waters to the
     levels necessary for current and projected future
     uses and for the protection of the public health and
     significant ecological systems."

     This goal recognizes that all ground water is not of
the same value.  The goal is primarily preventive, rather than
curative.  Of course, newly discovered ground-water quality
problems must be remedied to the extent possible to mitigate
against imminent hazards, but the long-term objective of the
strategy is to prevent ground-water contamination before it
occurs, rather than to clean it up after the fact.

     The objectives of this ground water protection strategy
are:
By 1985
          To initiate ground water protection strategies
          in all States, aimed at meeting the goal and
          the long-term objectives and to develop the
          necessary institutional capacities (resources,
          personnel, legal authorities, etc.)  at the
          State and local levels.

          To implement fully the currently enacted
          Federal regulatory programs which affect
          ground water  (e.g., Resource Conservation
          and Recovery Act (RCRA), Underground
          Injection Control Program (UIC), and
          Surface Mining Reclamation Act) and
          Superfund when enacted.

          To launch efforts to evaluate ground-
          water quality, to ameliorate the most
          hazardous conditions discovered, and to
          develop and implement technical and
          administrative methods of managing newly
          discovered plumes of ground-water
          contamination.

          To provide a process whereby State and
          local governments and the public, in
          specific situations, with adequate public
          health and environmental protection, can
          set priorities among competing activities
          which may use or contaminate ground
          water.

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By 1990

     o    To ensure that appropriate levels of protection
          are being provided for the ground water resources
          in each State and that each State has a complete
          program which has been fully implemented to
          manage all ground water.

MANAGEMENT APPROACH

     The management approach proposed in this strategy
includes four key elements:

     First, state ground water protection strategies to be
     developed by the states.   States will be encouraged to
     devise strategies which identify how this goal, as well
     as state and local goals and consistency across state
     boundaries, will be met through specific regulatory and
     other program actions at the state and local levels.
     These will be fostered and may be partially funded as
     part of the State/EPA Agreements (SEAs).

     Second, ground-water classification.  The principal
     premise of a classification system is that different
     levels of protection can be provided to ground water
     according to a number of factors.  The classification
     process should help sort out the high priority ground-
     water areas for high levels of protection and for first
     attention and investment, and assist in identifying
     those areas least environmentally sensitive for siting
     of future waste disposal facilities or other
     potentially polluting activities.

     Classification decisions about the appropriate levels
     of protection for individual ground waters would be
     based on such factors as: present and projected future
     uses; current quality; yield,  or volume of water
     available; availability of alternative water supplies;
     and vulnerability to contamination, that is, the
     degree of natural protection afforded by loc^.1
     hydrology and geology.

     Until a classification system is developed with full
     public participation and adopted, EPA will
     maintain a policy that where ground water is currently
     of drinking water quality or better, it will be
     provided protection to ensure that its utility for
     this use is not impaired.

     Third, minimum national requirements for selected
     high priority problems.  There are some problems which,
     on a national scale, are so severe and complex that
     national standards are appropriate.  Examples include

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     highly toxic chemicals and pesticides where product bans
     or restrictions are appropriate.   The Underground
     Injection Control Program and the Hazardous Waste
     Regulations under RCRA provide national requirements
     for selected problems, including  their imminent hazard
     provisions.  Other ubiquitous problems will be reviewed
     for possible federal action.

     Fourth, EPA administrative action.  This includes EPA
     action to coordinate and bring consistency among
     existing EPA and other federal programs with ground
     water protection authorities.  It will include action
     by EPA to encourage and assist states to expand
     monitoring to detect contamination,  to begin developing
     ground water protection strategies through 3tate/EPA
     Agreements, to increase research  and development and, to
     the extent possible, to provide technical assistance to
     state programs.  In addition, EPA intends to continue its
     involvement of the public and numerous institutions in the
     implementation of this strategy.

TECHNICAL REQUIREMENTS

     A range of technical requirements will be needed under
this ground water protection strategy  due to the variety of
problems affecting ground-water quality.

     There are four types of technical requirements which
are expected to be used extensively under this strategy.
(Other approaches, such as economic incentives, may also
prove effective.)  The four principal  approaches are siting
practices, best management practices,  technology-based or
effluent standards, and performance standards.  These are
described in the text that follows.

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PART ONE:  PREAMBLE

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                 I.  INTRODUCTION
THE SETTING FOR STRATEGY DEVELOPMENT
     The Environmental Protection Agency (EPA)  is concerned
about the growing evidence that ground water, a resource that
has always been considered relatively pollution free, is
widely contaminated.  The nature of that contamination may
pose significant public health problems and threaten critical
ecological systems.  Since ground-water contamination is
usually difficult to contain or control, its prevention, and
where possible its early detection, is a crucial environmental
and public health responsibility.

     Although there are some existing ground water protection
measures authorized by the Clean Water Act (CWA), an Under-
ground Injection Control (UIC)  program recently instituted
under the Safe Drinking Water Act  (SDWA),  and a hazardous
waste program developed under the Resource Conservation and
Recovery Act  (RCRA) and parallel actions among some states
to varying levels, fundamental policies concerning how this
nation should ultimately address the broad issue of ground-
water protection have not yet been determined.   In carrying
out a ground water protection strategy, EPA would like to
build on these new Federal programs and undertake a broad
cooperative effort with state and local governments.  The
EPA also will continue to encourage participation of affected
industries, businesses, and public services; concerned
environmentalists; public interest groups;  and professionals
in related fields.

     Because of the far-reaching effects of the problem, the
ground water protection strategy is being developed with
extensive public debate and participation rather than by issuing
an Agency-drafted strategy for public comment.   This approach
included workshop discussions of the policy choices that appear
critical to the formulation of a ground water protection strategy,
Drawing upon these consultations and other comments, EPA is
proposing this strategy for further public consideration before
final issuance and implementation.

     The problem at hand is immense and represents decades of
neglect or at least ignorance.   Protecting ground water is a
long-term, open-ended imperative.  This strategy represents an
important first step in a lengthy process which must involve
the collaboration of all appropriate institutions.  In addition,
as the country enforces its controls on the disposal of waste

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into our surface waters, oceans, and the air, the land becomes
the last unregulated medium for waste disposal.  Simultaneously,
more environmentally satisfactory disposal schemes for various
wastes, particularly hazardous wastes,  must be identified.

     The ground water protection strategy must have a national
scope.  It is important to note, however, that a national
strategy is not synonymous with a Federal strategy.  Rather,
it implies a general consensus on the part of those concerned—
Federal, State and local governments; business, industry and
the public—as to what problems are to be addressed; what
objectives are to be achieved; and what constitutes the most
effective, efficient, and feasible action program to alleviate
the problem.  Central to the construction of a national strategy
is a specification of the roles to be played by participants,
including governments, industry, and the general public.  The
distribution of these roles depends on many factors—among them
history, current law, capacity to provide needed resources, and
the extent to which the problems are being addressed through
current efforts.

     For ground water protection, EPA has in mind both a
national and a Federal strategy-  A national perspective will
help to limit the Federal role to functions which are appropriate
and supportive of related efforts, most particularly the efforts
of State and local governments.  A national approach also responds
to the mandates of the President's June 6, 1978, Water Policy
Message, which directed Federal agencies to expand Federal-State
dialogue and cooperation on ground water issues.  The strategy
should clearly recognize the larger context in which EPA works--
on the Federal level and with State and local governments—and
provide the framework within which EPA decision-making on
ground water protection should take place.


HISTORY OF THE STRATEGY TO DATE

     The planning process for this proposed strategy began in the
winter of 1979 when the EPA Administrator assigned the Office of
Water and Waste Management (OWWM) responsibility for developing a
ground water protection strategy under the direction of the
Assistant Administrator for Water and Waste Management and the
Deputy Assistant Administrator for Drinking Water.  Administrator
Costle stressed that a ground water strategy should:

        o  Look well into the future to assure that
           the quality of ground water is protected
           as a resource for future generations;

        o  Explore with an open mind alternative
           approaches to ground water protection and
           not be bound by existing policy or law;
                             1-2

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        o  Concentrate on broad policy issues rather
           than narrow regulatory or technical choices;

        o  Fully involve representative state officials
           as well as other concerned groups through
           direct participation;

        o  Stress cooperation and interaction with
           other affected institutions; and

        o  Recognize the relationship between ground water
           and surface waters, including wetlands.

     The strategy was to be focused on key issues that are
critical to ground-water quality.  For example,  it is not
intended to deal directly with tap water issues,  such as
current or proposed drinking water standards or  treatment
technologies.  Likewise, the ground-water depletion issue is
not a major focus.  While depletion is a critical ground water
issue in many sections of the country, it relates to this
strategy only as a problem that can contribute to ground-water
quality problems, not as an independent issue.

     To fulfill the requirements above, EPA outlined a three-
phase approach.

     o  Phase I, which has been completed, involved
        data gathering by four task groups and preliminary
        consultation with representative states  and
        organizations.  A Policy Committee composed of
        all Deputy Assistant Administrators with ground-
        water responsibilities, three Regional officials
        and a USGS representative was established to
        lead this effort, along with work groups to
        provide staff assistance in assembling the
        needed information.

     o  Phase II, which took place in June, consisted
        of a pair of workshops in which eighty
        representative and knowledgeable persons
        developed recommendations leading to this
        document..!/

     o  In Phase III this proposed strategy is
        being published in the Federal Register
        and widely distributed.  Public hearings
        on the subject will be held in five
        locations throughout the nation in
        January, 1981.
V
  Planning Workshops to Develop Recommendations for a Ground
  Water Protection Strategy and Appendices,  EPA,  Office of
  Drinking Water, Washington, D.C.,June 1980.
                           1-3

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     0  The final strategy is expected to be
        published later in the year.
WHAT THE STRATEGY SHOULD PROVIDE

     The ground water protection strategy should provide:

     o  A clear enunciation of the problems and
        issues being addressed and the goals and
        objectives to be achieved;

     o  A greater national recognition and
        understanding of ground-water problems;

     o  A national program with fully defined
        Federal and state roles;

     o  A comprehensive Agency ground water
        protection policy that will apply to
        all programs affecting ground water
        from data collection to management;

     o  A stronger set of relationships among
        Federal, state, and local governments;
        and

     o  A meaningful short-term action plan and a
        strategy for dealing with ground-water
        problems over the long term.

     The strategy is intended to provide a policy basis for
future decisions such as budget allocation, organizational
actions, and regulatory steps.  The strategy should provide a
framework to tie together regulatory efforts under various
legislative authorities.  Any EPA regulations developed in
carrying out this strategy will -be subject to the normal review
process as they are issued under each statute.   Hence the
rule-making process will be carried out for each regulation
but will reflect the policies in the final ground water
protection strategy.
STRUCTURE OF THIS PROPOSED STRATEGY

     This strategy paper is organized in two parts.   The
first -- Preamble -- describes in some detail the process
used in developing the strategy and reviews the Workshops held
in June.  It is followed by a background chapter on ground-water
use and contamination.
                           1-4

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     The proposed strategy is outlined in the second section.
The introduction includes the rationale for the strategy,  the
first chapter presents the basic assumptions which underlie the
strategy, and the following chapter sets forth the goal of the
strategy and reviews the objectives which the strategy aims to
accomplish.  The more detailed elements of the strategy are
covered in the remaining chapters which outline the management
approach and the technical requirements.
                               1-5

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   II.  INVOLVEMENT OF STATES, INDUSTRY, PUBLIC
            INTEREST GROUPS,  AND OTHERS
     From the outset, the ground water strategy development
process has sought to involve as many viewpoints as possible.
Individuals representing government at all levels, members
of industry, public interest groups, academic experts
and others were consulted and their advice was used to construct
the strategy presented below.  The process proceeded in three
phases.  The contribution of each of these phases is discussed
in the sections which follow.

PHASE ONE;  WINTER AND SPRING 1980

     Throughout Phase I of the formulation of the ground
water protection strategy, EPA sought involvement of
groups and individuals outside the Agency.  Over 100 key
organizations interested in ground water protection were
contacted to identify the issues and the range of options
which should be addressed in the strategy.

     In order to gain the perspective of a cross-section of
state governments, EPA made a particular effort to consult with
as many state officials as possible.  Members of state
legislatures, public health and environmental protection
departments, water resources boards, engineering departments,
state geological surveys, and other state offices were included.

     The interests of business and industry were solicited.
Through industry associations and individual companies, those
industries most likely to be affected by the ground water
protection strategy were identified.  In particular, these
include the chemical, oil and gas, mining, water utility,
agriculture, waste disposal, textile, and building industries.

     Many public interest groups including those representing
environmental concerns were also contacted in preparing for
the workshops.

     The National Drinking Water Advisory Council and EPA's
Science Advisory Board were also consulted. Representatives
from the Council assisted in developing issues for consideration
and in selecting workshop participants.

     Local government officials, those who make local decisions
affecting ground-water quality, were involved.  Organizations
representing local officials were consulted, and mayors,
council members, and court officers were contacted directly.

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     To ensure that academic knowledge and technical expertise
were brought into the workshop research,  experts including
university professors, practicing hydrogeologists,  and
engineers were consulted by EPA.

     In addition, a role for other Federal agencies was
provided.  Those federal agencies with a  stake in the ground
water protection strategy or which could  represent  related
Federal interests were consulted, and officials participated
in the strategy process.  These included  the Council on
Environmental Quality, the U. S.  Geological Survey, the
Water Resources Council, and the  Department of Agriculture.

     Throughout early 1980 as these contacts were being made,
EPA officials compiled information on ground water  and wrote
detailed background papers on ground-water use and
contamination, on state and Federal law and on ground water
research and development.  The results were the working papers
and appendices published for use  at the June workshops.  The
conference workbook focused on five key topics and  set the
structure for the workshops.  The topics  listed in  Table II-l
enabled the workshop participants to focus on a logical
sequence of decisions leading to  a comprehensive strategy. The
five topics were goals, management approach, technical
requirements, Federal and state roles, and near-term
implications.  The workbook identified options in each of these
areas to form the basis of discussion during the workshops.  The
options are listed in Table II-l  in abbreviated form.   In
addition to the conference workbook, EPA  has published a set of
appendices which contained the working papers written as
background._!/  These appendices contain ten papers  which analyze
in depth related issues such as ground water use in the U.S.,
synthetic organic contamination in ground water, EPA and other
Federal laws pertaining to ground water,  state and  Federal
programs by pollution source, current state ground  water
management programs and research  and development.


PHASE TWO:  THE JUNE WORKSHOPS

     The two workshops conducted  June 22-28, 1980,  included
representation from groups concerned with ground water
protection—those contacted during Phase  I.  The 80 participants
provided a cross-section of interests, opinion and  knowledge
of ground water protection.

     Those invited to the workshops offered diverse backgrounds
and organizational affiliations.   All areas of the  country were
represented; there was a special  effort,  however, to include the
western states where water resource issues have long been a major
concern for state and local officials.
I/
     Ibid.
                             II -2

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                                                               Table  ll-l

                                SUMMARY OF INITIAL OPTIOHS FOR DEVELOPING A GROUND WATER PflOIECTlOH  STRATEGY
                                                              Mechanisms
      Goa|s
  (select  one)

 •  To protect  all
    ground waters at
    the Ir  present levels
    of qual Ity (I.e.,
    nondcgradal ton)

 »  To assure that  all
    ground water; are
    protected everywhere
    up to some spec I fled
    level  (e.g., a drink Ing
    water standard)

 •  To protect ground
    waters to Hie levels
  •  necessary for pro-
    jected future
    uses

 •  To protect only
    those ground waters
    that ace used as  ,
    dr Ink Iny water
    sources, and to
    rely on  monitoring
    or treatment for
    use of unprotected
    ground waters
Management Approach
(select one or more)*

•  Uniform Require-
   ments Everywhere

•  Classification of
   Ground Waters

•  Class IfIcatIon of
   Contaminants

•  Classification of
   Sources of
   Pollution
Technical Requirements
 (select one or u.ore)*

•  Dost Management
   Practices (UMI's)

•  Technology-Cased
   or Effluent
   Standards

•  Ground Water
   Quality
   Standards

«  Economic Incentives
   and Other
   Approaches.
 Federal/Statc/Local
   (select one or more)*

•  Stales lake primary
   responsibility for Imple-
   ment al Ion of federally
   developed natlonal
   standards

•  States prepare and
   submit program
   plans for federal ap-
   proval In response to
   federal  minimum require-
   ments

•  Slales prepare Indiv-
   idual program plans con-
   sistent  with broad
   .federal  guidelines,
   subject  to federal
   approval prImarIly on
   procedural grounds

•  State and local govern-
   ments set and enforce
   standards consistent  wlllt
   broad federal goals;  the
   federal  government pro-
   vides technical assis-
   tance and support

•  Stales develop plans
   and programs; She federal
   government provides sup-
   porj. and technical assis-
   tance only
'Select or develop one option, or select more for different  categories  of  problems, clc.

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     The participation of Federal officials in the workshop was
limited in several respects.   The only Federal attendees
were those representing the four federal agencies mentioned
above.  EPA staff members served only as resource persons.

     During the closing sessions of the workshops, senior
EPA officials attended to hear the recommendations of the
participants and to ask questions for clarification.   These
final sessions provided senior EPA management with valuable
insights into the preferences of the workshop participants with
respect to each element of the ground water protection strategy,

REVIEW OF WORKSHOPS

     Two identically structured, three-day workshops  were held.
Each workshop included approximately 40 participants  who were
divided into four groups of about 10 members each.  The work
groups were carefully chosen so that each group included
representatives of the principal viewpoints.  Following the
opening session which included all participants,  each of the
work groups was assigned to write a goal statement for the
ground water protection strategy.  The work group chair-
persons then reported back to the whole session.   This
process—work group assignments to develop reports on each
of the sequential elements of the strategy followed by
reports to the assembled session—continued during the
three days and concluded with the final presentations of
each of the four work groups on their recommendations for
the strategy as a whole.  These oral reports from the
eight work groups  (four groups at each of two sessions)
constitute the major results of the workshop.

     The strategy which is proposed in Part II of this
paper reflects in general terms, the recommendations  of the
eight work groups.  The groups presented similiar state-
ments of what should be the strategy's goal and the manage-
ment approach needed to move toward this goal.

Goals

     The principal view expressed concerning the  goal for
the ground water protection strategy was that the third
option shown above in Table Il-l contained most of the
appropriate elements of a goal statement.  There  was
general agreement that the protection of ground water
should be related to existing quality and to present
and projected future uses.
                            II-4

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     The participants expressed views which ranged from
advocacy of total non-degradation to support of little
or no protection of ground-water quality.  The extreme
views were held by few participants, however, for the
majority supported very similar goal statements.

Management Approach

     Virtually all participants stressed the need for
flexibility to accommodate State and local differences.
Those differences include natural ground-water quality,
vulnerability to contamination, degree of natural protection,
availability of alternative sources of water, uses of ground
water, and the relative priority of competing uses.   Most
participants felt that the best vehicle to accommodate
these differences was to base the level of protection on
the water quality levels needed to support the current
and projected future uses of ground water.  EPA has  accepted
this concept and the rationale that in this way ground water
will be protected where protection is needed to the  levels
which are necessary.

     A theme which emerged was that programs or requirements
for protection ought to be based on the uses which will be made
of the ground water.  Accordingly, EPA is proposing  ground-
water classification as a primary element in the strategy.
(In order to avoid the administrative and technical  burden of
classifying all ground waters at one time and to avoid delays
in launching the ground water protection program, a  rebuttable
presumption will be used to focus classification efforts only
on those areas in which either a siting decision needs to be
made or a more stringent level of protection is desired.)

     By linking protection to uses and existing quality, the
proposed goal provides for explicit public decisions on
competing uses of ground water, which could then lead to
differing levels of ground water protection.  While  strict
protectionists generally opposed this concept, most  persons
consulted solidly supported it.  Those from certain  sections of
the country, especially the West, felt that it was essential.
The Agency has agreed that it is important to incorporate this
flexibility into the program, and that such decisions are best
made as explicit public decisions at the State and local levels.
A relatively small number of ground-water trade-off  decisions
are expected to be made, but they should receive the amount of
attention they deserve.

     It should be noted, however, that EPA believes  that no one
has the right to pollute the ground water in such a  way as to
create a significant risk to public health or critical
ecological systems.  For this reason EPA will continue its
efforts to prosecute violations of the imminent hazard
provisions under RCRA and SDWA wherever serious contamination
situations are detected.
                          II-5

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     Another theme which emerged was that there are some ground-
water threats of such high priority that they warrant strong
national action.  Typically these were described in general terms
as situations dealing with highly toxic chemicals or hazardous
wastes.  In some instances Congress has recognized these, too,
and adopted national legislation.  EPA has agreed and included
in the strategy provisions for the identification of further
high priority problems which might warrant national attention
and action and has provided a process for their consideration.

Technical Requirements

     The general view of the workshop participants was that a
variety of technical requirements would need to be a part of
successful ground water protection strategy.  The breadth of
these requirements was due to the diversity of sources of
ground-water pollution and the consequent diversity of technical
approaches needed to limit or eliminate their contaminating
effects.

     The majority of participants favored these three types of
technical requirements:

        o  Best management practices, or operating
           and design requirements for activities
           which may contaminate ground water,
           particularly area-wide sources of con-
           tamination.

        o  Technology-based or effluent standards,
           or specific limits on contaminant
           quantities from industrial or other
           activities.

        o  Economic incentives to reduce ground-water
           contamination.   Few details were offered
           on how economic incentives should be
           structured.

     These three requirements were viewed as collectively
adequate to accomplish the goal of ground water protection.
Few participants suggested that only one of these technical
requirements alone would be adequate.  Many suggested greater
attention be given to the development of performance standards
where practical.

     One technical requirement—the establishment of numerical
ground-water quality standards—was judged by many participants
to be generally beyond the limits of current knowledge.   These
concerns focused primarily on the limited coverage of drinking
water standards and on the ability of models to reliably relate
discharges in ground water to changes in quality at the  point
of withdrawal.  Many participants indicated that ground-water
                            II-6

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quality standards would not be a viable basis for the strategy
for at least five to ten years, although the development of
additional maximum contaminant levels and advisories on safe
drinking water levels should be accelerated.  These will serve
as a major tool in assessing the magnitude of risk posed by the
measurable migration of contaminants from existing facilities.

Federal, State, and Other Roles

     In dealing with this topic, the workshop participants
and others suggested many approaches.  Several participants,
including some from state governments, felt that the states
should be free from specific Federal requirements beyond
existing Federal legislation.  Some states felt that the
appropriate Federal role is to provide research and technical
assistance.  Others felt that a strong Federal role was
necessary to assure program consistency between states and to
encourage reluctant states to adopt adequate ground water
protection programs.  Others expressed views which fell between
these options.

     In response to this diversity of opinion, EPA is
recommending Federal, state, and other roles which leave the
state with the key responsibilities for designing and
implementing programs.  The proposed Federal role will be for
EPA to provide guidance to states to encourage the development
of state strategies, to assure implementation of existing
Federal ground-water related programs, to establish ground-water
classifications as part of the management approach to accelerate
R&D programs where appropriate, and to continue to initiate
Federal "imminent hazard" enforcement actions to clean up
hazardous waste sites and other contamination polluting ground
water.  In addition, some participants suggested that EPA carry
out a ground water program at some time in the future if states
do not establish an adequate program.  If EPA were to take over
a state ground water program beyond the current authorities
of RCRA, CWA, and other laws, new legislation would be needed
to support it.
                             II-7

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            III.  BACKGROUND ON GROUND WATER
     Ground water is the least understood of our major
natural resources.  In both science fiction and courts
of law traditionally it has been erroneously described
and treated as "underground streams."  Despite the general
lack of awareness and understanding surrounding it, ground
water is an important source of the nation's water supply.
Its use has grown sharply over the years but its availability
has decreased because of pollution and, in some areas,
because of depletion.

     This chapter presents a brief description of ground
water as a resource, including past and future use projections,
It also describes damage that has been done to ground water
by various contaminants and pollution sources, discusses
the difficulty of protecting and cleaning up ground
waters, and outlines what Federal and state programs exist
that can address ground-water pollution problems.
GROUND WATER USE

     Ground water has become an increasingly valuable
resource over the past 35 years.  Ground-water withdrawals
in the United States quadrupled from 21 billion gallons
per day in 1945 to 82 billion gallons per day in 1975.
The increase from 68 to 82 billion gallons per day in the
five-year period 1970-1975 was particularly pronounced.

     Most of this increased use can be attributed
to agricultural irrigation.  In 1950, 21 billion gallons
per day of ground water were used for irrigation purposes.
In 1975, 57 billion gallons/day—or approximately 70 percent
of the ground water withdrawn nationwide—were used for
irrigation activities, and ground water constituted 41 percent
of the total amount of water so used.  Since ground water is
withdrawn primarily for irrigation purposes, the total amount
used is bound to be affected by change in agricultural policy
and practices.

     Increased energy costs, as they increase the cost of
pumping ground water for irrigation purposes, will affect
this major sector of ground water use.  Data indicate that
for a 300-foot lift in the Central Valley of California
pumping energy costs increased from $3.30 per acre-foot in
1970 to $12.00 per acre-foot in 1980.  In the short run,
such energy price impacts in the agricultural sector may
manifest themselves as an increase in the amount of dryland
or unirrigated farming and as a shift in the type of crops
grown.   For example, along the Ogallala Aquifer in Texas,
cotton, a water-intensive crop, is being replaced with
sorghum and other crops that are less water intensive.

-------
     For the future, total ground-water withdrawal
projections range from 70 to 100 billion gallons per day
in both 1985 and 2000.V  The range is expected to remain
the same during this 15-year period because the cost of
pumping will serve as a constraint on the demand for
ground water.
SOURCES OF GROUND WATER CONTAMINATION

     Ground water can be contaminated by a variety of
sources.  The degree of threat depends on the nature
(toxicity)  and volume of the contaminant that is generated
by a particular site or activity,  the characteristics of
the material underlying the site,  and the particular
geological and hydrological conditions of the area.  For
instance,  a landfill that is underlain by 200 feet of
impermeable clay would pose little threat to an artesian
aquifer beneath the clay, but a landfill located on a
permeable material with a shallow depth to ground water could
pose a serious threat.
Contamination by Municipal and Industrial Waste Disposal Sites

     Disposal of municipal and industrial waste on the
land is a source of serious concern because of the large
volumes of waste, the large number of sites involved, the
hazardous nature of much of the waste,  and the inadequacy
of the precautions taken to protect ground water at many
of the sites.  While estimates of the magnitude of this
problem vary, the following data are illustrative:

     o  A 1979 study by an EPA contractor indicated
        that 32,000 to 50,000 disposal sites may
        contain hazardous waste, and that of these
        1,200 to 2,000 could pose potential danger to
        public health or to the environment.

     o  EPA estimated that approximately 57 million of
        the 378 million tons of liquid and solid
        industrial waste generated in 1978 were hazardous
        and that this amount will grow by 3.5 percent
        each year.  About 80 percent of these hazardous
        wastes are improperly disposed of in landfills
        or lagoons and pose a threat of ground-water
        contamination.
V
   These projections are based on the Water Resource Council's
   First and Second National Assessments and ground water data
   generated by the United States Geological Survey.
                              III-2

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Very few land disposal sites are lined and few
have leachate collection systems; studies have
estimated that about 75 percent of all active
and inactive sites leach.  Unfortunately, there
are no firm data on the total number of land
disposal sites.  Among existing estimates are
these:

— A 1978 Waste Age survey identified approximately
   15,000 active municipal landfills, of which
   only 35 percent were in compliance with State
   regulations.

— An EPA-funded report estimated the number of
   active industrial landfills to be 75,700 and
   and number of abandoned sites to be possibly
   as high as 100,000.

-- Another EPA-funded report estimated that
   19,400 sites, either landfills or lagoons,
   are needed to handle the current stream of
   hazardous waste and that 50,600 active and
   inactive sites contain potentially dangerous
   amounts of hazardous waste.

  The Surface Impoundment Assessment, funded by
  EPA and conducted by the States, identified
  25,800 industrial sites and 181,000 impoundments.
  Because of the hazardous nature of much waste
  placed in industrial impoundments, states were
  asked to perform detailed assessments of
  industrial sites.  Preliminary analyses of 8,200
  industrial sites indicated the following:

  -- Most--70 percent--are unlined and possibly
     allow contaminants to enter the ground.

  -- Moreover, 10 percent are not only unlined,
     but also overlie usable aquifers and are on
     permeable soil; of these, one-third are
     within one mile of a water supply well.

  -- About 35 percent hold liquid wastes that may
     contain hazardous constituents.

  -- Only 5 percent are known to be monitored.
                     III-3

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Contamination by On-lot Disposal
Systems, Radioactive Disposal Sites
and Buried Storage Tanks

     Domestic on-lot disposal systems also represent
threats to public health when improperly designed,
operated or maintained.  The primary concern in their
case is the large number of sites and the potential for
bacteriological and chemical contamination.  Recent
studies indicate that significant amounts of organic
contaminants have been introduced into ground water
through septic systems.  Buried storage tanks are also
of concern because of the nature of such contaminants
(primarily gasoline) and the significant number of such
sites in areas of high population density.

     Radioactivity waste disposal sites pose a potential
long-term threat to public health.  Some ground-water
contamination has been associated with leakage from the
temporary storage areas in which wastes are held prior
to transfer to permanent sites.  Radioactivity is also
associated with the wastes produced by sources such as
uranium mines and mills and by the mining and milling of
phosphates and metallic ores such as copper.
Other Threats

     Some sources of contamination endanger public health
by introducing into ground water potentially hazardous
materials that would not normally be detected by a user.
Other forms of contamination make ground water more
obviously unusable.  For example, salt water encroachment
(often caused by overpumpage of adjacent fresh water),
brine injection wells, and highway deicing salts may
cause localized problems in the continued use of ground
water both as drinking water and for irrigation.
Abandoned wells can create problems, too, if constructed
so that water in poor-quality aquifers can enter aquifers
of good quality through uncemented well bores.  The use
of pesticides in agriculture is also emerging as a
problem in some areas.  While artificial recharge is
considered a viable technique in some parts of the country
for conserving water that would otherwise be wasted through
evaporation or runoff, there is concern that recharge of
ground water by some types of water (for example, treated
industrial or municipal wastewater)  could preclude its
future use.  Recharging using municipal wastewater must
be carefully controlled to prevent bacteriological problems
that might preclude domestic use.
                            III-4

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     Ground-water contamination implies more than such
threats to public health.  It also involves economic
and environmental costs.  Water quality changes induced
by major ground-water withdrawals for agricultural
activities, for example, can result in reductions in net
economic benefit.  For instance, irrigation can lead to
an increase in the salinity of ground water which in turn
can lower crop yields.  Similarly caused changes in ground-
water quality can also increase.the costs for users who
need to treat the water to enable continued use.

     Activities related to mining waste disposal and acid
mine drainage pose a threat to ecosystems as well as to
certain uses of ground water.  For instance, mine drainage
and waste piles can result in excessive heavy metals in
ground water that would preclude its use as drinking
water without major treatment.
Contamination by Organic Chemicals

     Drinking water drawn from the ground has generally been
viewed as a pristine resource, unspoiled by human activities,
Recent information, however, has revealed that many ground
waters are contaminated by organic chemicals.  The data
are particularly disturbing in that many of these chemicals
are known or suspected carcinogens.  Moreover, they have
frequently been detected at levels that are orders of
magnitude higher than those generally found in surface
waters.

     As a result of these discoveries, Federal and state
agencies have increased their monitoring efforts and new
data are being produced continually.  Most of this
monitoring is concentrated in areas where contamination
is suspected, making it difficult to generalize about
ground waters.  However, it is clear that a widespread
problem exists and that many more cases will come to light
as more monitoring is done.

     As a result of these monitoring efforts, at least
20 communities in Massachusetts have discovered their
public water supplies to be severely contaminated with one
or more synthetic organic compounds: 16 incidents have
occurred in Connecticut, 25 in Pennsylvania, 22 in New York,
and one or more in each of 20 other states.  New Jersey
and California have also detected large-scale contamination
in ground water.
                             III-5

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     For example, a recent testing program conducted by
Connecticut's Department of Health Services at the request
of the State Legislature has detected a large number of wells
contaminated with volatile organic chemicals.  Initial
results were reported on the basis of tests of the wells
used by 78 of the 95 water systems in the state which serve
populations of 1,000 or more.  In that sample some quantity
of volatile organic contaminants were detected in 87 percent
of the wells tested.  Of those, 23 wells serving 17 of these
systems were found to contain chemical levels in excess
of EPA's suggested no adverse response level.

     In another example, the municipal landfill in Jackson
Township, New Jersey, was licensed by the state to receive
wastewater sludge and septic tank wastes, but it now
appears that dumping of chemicals has also occurred at
the site.  As a result, approximately 100 drinking water
wells surrounding the landfill have been closed because
of organic chemical contamination.  Analysis of water
samples has shown the presence of chloroform (33 ug/1),
methylene chloride  (3,000 ug/1), benzene (330 ug/1),
toluene  (6,400 ug/1) trichloroethylene (1,000 ug/1),
ethylbenzene (2,000 ug/1), and acetone (3,000 ug/1).

     As of March 1980 over 8,000 chemical determinations
for volatile organic compounds had been performed on well
water by state agencies.  While a large number of compounds
have been detected in these and other analyses, chlorinated
organic solvents have been found most frequently, sometimes
at very high levels.   Several of these solvents have been
shown to cause cancer in laboratory animals.

     Most frequently found was trichloroethylene, an
industrial solvent and degreaser.  This compound was found
in one third of the samples tested, with concentrations
as high as 35,000 ug/1.  (This should not,  however, be
interpreted to mean that one-third of the nation's
drinking water supplies contain measurable levels of
trichloroethylene; the state monitoring was concentrated
in areas where contamination was expected and a
representative sample would undoubtedly show lower levels
and lesser occurrence.  Such data, however, are not yet
available.)

     Other volatile organics frequently found in ground water
include tetrachloroethylene; 1,1,1-trichloroethane;
1,1-dichloroethane, and dichloroethylenes.

THE DIFFICULTIES OF GROUND WATER PROTECTION

     Strategies to control ground-water contamination
must take account of the major difference between
ground water and surface water.  Compared with surface
water contamination, ground-water contamination is much
                               III-6

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more difficult to detect in a timely manner and to clean
up once discovered.  In ground water, it is also harder
to predict the path and rate of movement of certain
constituents.  Further, it is extremely difficult, if not
impossible at our current state of knowledge,  to
analyze changes in ground-water quality as a result of a
particular land-use activity.  These difficulties are
related to the physical characteristics of ground water,
to the diversity of means by which it can be contaminated,
and the characteristics of the aquifer and overlying
geologic materials.

Slow Movement of Ground Water

     Although some ground waters have very rapid rates
of movement in the feet-per-hour range, such as through
limestone, most have velocities in the feet-per-year
range.  The slow movement of ground water can create
difficulties because large amounts of contaminating
material can enter the ground water without detection.
For instance, if a monitoring well is located at or near
the point of use and the actual source of contamination is
a long distance away, contamination could continue for
many years before detection and take just as many years .to
pass the point of use.

     Ground-water flow characteristics are usually
predictable in that a plume of contamination is fairly
narrow and will not permeate the entire aquifer.  If a
basin-wide monitoring program, however, relies on
randomly selected wells, detecting contamination in a
timely manner will be almost impossible unless a well
happens by chance to be located immediately in the line of
major flow from a contamination source.  This fact has
important consequences for the design of a monitoring
program, as discussed below.  Even more important, new
management techniques will have to be developed to avoid
serious public health risks which may occur as these
plumes enter the area of influence of drinking water
wells.

Monitoring Difficulties

     There is currently no data base from which the
magnitude of the ground-water contamination problem can
be determined.  The large amounts of data gathered by the
states and the U.S. Geological Survey have generally not
focused on the types of problems that have more recently
become the object of concern, particularly hazardous
waste disposal and contamination by synthetic organic
chemicals.  The data available are largely anecdotal in
                             III-7

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nature; that is, based on investigation of particular
instances of contamination.  Therefore, it cannot be
determined with confidence how representative these cases
are.  Increased attention to ground-water contamination
problems is likely to lead to efforts to improve this data
base and, to some extent, to redirection of current
monitoring efforts.

     Ground-water monitoring is much more expensive
than surface water monitoring, since it is necessary to
drill a well in order to monitor each observation or
monitoring point.  In addition, the design of a monitoring
system should be tailored to the kind of contamination
problem that is being studied.

     For example, localized sources of pollution such as
landfills and surface impoundments may produce plumes of
contamination around the site.  Because of the slow
movement of ground water, these plumes will frequently be
limited in size  (although continually growing).  There-
fore, any monitoring plan using wells scattered over a
large area is likely to miss most plumes, thus producing a
misleading result.  This suggests that the appropriate
unit of sampling for such a plan is the potentially
polluting site, rather than the aquifer.  That is,
monitoring wells should be located near the sites and
positioned so that they can detect pollution if it is
occurring.

     Many such potentially polluting sites either
currently have monitoring wells around them or will be
required to drill monitoring wells by regulatory programs
now being established.  This will make it feasible to
select a random sample of such sites and monitor the
quality of ground water in their immediate vicinity.
Such a survey would yield systematic and representative
data which could validly be generalized to conclusions
about the extent of pollution from such sources.

     Area-wide sources like fertilizer use can affect
large ground water areas and are more easily detected by
the conventional aquifer surveys.  Generally, basin-wide
monitoring detects a problem only when contamination
has reached a stage where water quality changes are
regional in nature.  This is especially true if the
monitoring program relies on wells that are designed
for water supply, particularly if they are of limited
depth.  Therefore, building monitoring networks to orovide
an accurate picture of changes in ground-water quality
is expensive and difficult to accomplish.  This is a
fundamentally different problem from monitoring surface
waters where access is seldom difficult.
                             III-S

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Diversity of Sources of Contamination

     Protecting ground water from pollution is further
complicated by the varying nature of the sources of
pollution.  These sources can be classified according to
industry involved, type of waste, volume of waste or
regional distribution.

     Localized sources, though numerous, are subject to
control on a site-by-site basis.  Generally, contamination
from such sources occurs in a localized area around the
site.  Pollution from area-wide sources, such as
agricultural practices and highway deicing, often covers
a wide area and is less subject to site-specific controls.
Controls may involve changes in operation  (for example,
a "best management practice" such as controlled use of
fertilizer)  rather than direct expenditures on control
technology.
Restoration or Cleanup

     If a large area of contamination is found,  it may
be extremely difficult and expensive to institute an
aquifer clean-up program.  While elimination of  the
original pollutant source material is essential  and will
be the purpose of Superfund efforts, cleanup of  the ground
water itself is difficult.  This is because of problems in
defining the area of contamination; because of the large
amounts of water that have to be removed,  treated, and
returned to the aquifer; or because of the difficulty of
changing hydraulic gradients to control the direction in
which the unwanted contaminants are moving.  In  contrast,
surface waters move quite rapidly and can flush  an
area clean in a relatively short time once the discharge
of pollution has stopped.
EXISTING GROUND WATER PROTECTION EFFORTS

     Numerous Federal laws deal in some way with ground-
water management or protection, yet neither these laws nor
existing state programs fully address the range of problems
presented by ground-water pollution.  They are a patchwork
of efforts that fail to cover some of the most serious
problems.

     A brief summary of the major sources of ground-water
contamination and the current approaches to their control
are presented in Table III-l, page 111-10.  In most instances,
for each major source of contamination, there is an
individualized approach to control on the part of state,
local, and federal agencies.
                          III-9

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M
H
H
 I
h--
O
                         MAJOR SOIIHCF.S Of GROUND UATIiR

          Sources of Contamination

Wusle Disposal Sources
     Landfills, Dumps, and Surface Impoundments

     Mining Wastes


     On-lot Waste Water Disposal Systems


     Radioactive Wastes

     nudge Management via I,and Spreading

     Underground Injection Wells


     Land Treatment of Municipal Waste Water

Hun-Disposal Sources
     Abandoned Wells


     Accidental Spills


     Agriculture Practices


     Artificial Recharge-

     Highway De-icing Compounds

     Petroleum Exploration and Development


     Underground Storage Tanks nnd Pipelines

Pep lot Jon
     Increased Salinity
   TAUUC IIl-l

CONTAMINATION AND CURKENT API-ROACHES TO CONTROL

               Primary llnsis uC Current Control Efforts


Vcdernl regulations and state delegation under RCRA.

Previously DKPs for active mines and little for abandoned mines, 1977
Surface Mining Act Initiated permit and reclamation programs.

Ci.'iiCi ally locnl or county control under stnte health regulations, with
evaluation of alternatives under 208 funding,

NKC authority, sometimes delegated to states.

HMPs developed at federal level

New UlC program of federal standards and state enforcement under the
Snfe Drinking Water Act

Step 1 for new 1'OTW construction
I. United state programs, some expansion of program under UIC
and SWDA emergency actions

Federal advice available, sometimes assistance; SDWA; RCRA and Superfund  (If
eiuicted) will extend authorities and funding

Primarily recommended UMPs, with selected regulations under  FIFRA and
CWA

Bill's undr.r development by EPA and selected cities

llMPs at litate levels

State programs In past, now UIC and RCRA add  federal standards for
inject ion wells and lagoons.

Some locnl or state standards for construction, few  inspection programs
                                                                         State nnd locnl efforts

                                                                         State and locnl efforts

                 Source:   Planning  Workshops  to Develop Recommendations for a Ground Water Protection Strotcgy, Table
     Suit Water Encroachment

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Federal Efforts

     EPA has recently turned its attention to ground
water protection.  Despite several specific references
to ground water in the Clean Water Act  CCWA), Congress
did not explicity confer federally enforceable
authority in that Act.  Courts narrowly interpreted the
Act's ground-water provisions, and the Agency itself, for
many reasons—lack of resources and pressures to deal with
surface waters among them—deferred action that would
protect ground waters.  Ironically, in some situations
Agency actions resulted in increases in ground-water
pollution by diverting pollution from surface waters to
the ground.

     In recent years some provisions of the Clean Water
Act have been used to increase ground water protection.
Most notable is the Water Quality Management Program
required by Section 208 of the Clean Water Act.  It served
as the catalyst that enabled many states to develop ground
water management programs and particularly to experiment
with innovative ways of dealing with non-point source
problems.  Grants to the states for pollution control
programs provided under Section 106 of the CWA, and the
creation of coordination mechanisms such as State EPA
Agreements, have also strengthened state abilities in
ground water protection.

     Nonetheless the federally enforceable elements of
the Clean Water Act have not been directed to ground water
protection.  For example, EPA has construed Section 303
(Water Quality Standards) to apply to ground water only
in unique and narrow circumstances.  Accordingly, it has
not developed a program of nationally consistent ground-
water quality standards.  Further, there are conflicting
judicial opinions concerning EPA's authority to issue NPDES
permits related to ground water protection.

     Several provisions of the Safe Drinking Water Act
(SDWA) relate to ground water protection.  One of these
creates the Underground Injection Control program which
establishes minimum standards for injection well design
and operation and state program requirements.   The Act
provides for regulation of injection wells by permit or
by rule.  EPA regulations specify procedural and technical
requirements for the program, including construction,
operating, and monitoring requirements for injection wells.
The Act envisions state assumption of the primary
responsibility for enforcement of the standards.  A
limiting factor with respect to this program is that it
is intended to protect ground waters that are current
or potential sources of drinking water, thus only
restricting pollution in single-use sources and disregarding
other uses and ecological needs.

                              III-ll

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     Another provision of the SDWA is the Sole-Source
Aquifer Protection Program (Section 1424(e))  which provides
a mechanism for state, local, or regional agencies to
petition EPA to protect recharge zones or special aquifers
by designating them sole-source aquifers.   A limiting
factor of this provision is that it protects only recharge
zones from the federally funded projects that might
contaminate them.  Non-federally funded projects are not
regulated.  Despite this and other limitations, it is the
only EPA program that uses recharge zone protection as a
ground water management tool.

     The Resource Conservation and Recovery Act (RCRA)
of 1976 provides for control of the land disposal of
municipal waste and the generation, treatment, storage,
and disposal of hazardous waste and provides authority to
act against imminent hazards.   SPA regulations provide
for a manifest system to track hazardous wastes from the
point of generation to the ultimate disposal sites.  This
Act also provides for Federal standards for disposal of
nonhazardous waste, but these standards are not federally
enforceable.  Again, this Act provides for delegation of
enforcement responsibility to the states.

     The newly launched UIC and RCRA programs provide
significant funds for state grants, which may greatly
improve the ability of the states to fund ground water
protection programs.

     The Surface Mining Control and Reclamation Act of
1977 under the administration of the Department of the
Interior provide authority to control surface mine
pollution; protection of ground waters is explicitly
included.  The Uranium Mill Tailings Radiation Control
Act of 1978 mandates EPA to establish radiation
standards for uranium mill tailings and the Nuclear
Regulatory Commission to implement and enforce the
standards.

     Other EPA laws such as the Toxic Substances Control
Act (TSCA) and the Federal Insecticide, Fungicide,
and Rodenticide Act (FIFPA)  have the clear potential in
certain circumstances to restrict the use of or ban
substances that are of particular danger.   Finally, EPA
has proposed Superfund legislation which is now under
consideration of the Congress.  This authority, if passed,
will support the cleanup of abandoned hazardous waste
sites which may be contaminating ground water.

     Thus, Federal programs provide for explicit, well-
developed regulatory approaches for some threats to
ground-water quality and devote only incidental attention
                         III--12

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to others.  Hazardous waste disposal and underground
injection are well covered by mandatory federal programs
that are now entering the implementing phase.  Federally
funded projects in the recharge zones of designated sole-
source aquifers are regulated, but other projects in those
areas are not.  Potential ground water impacts of surface
mining and the uranium fuel cycle are covered by programs
designated to deal with those activities comprehensively.
EPA has provided Section 208 funds to states to develop
ground-water management programs.

State Efforts

     The state governments have been faced with a
difficult challenge for many years in the area of ground-
water quality management.  The combination of the
technical complexity of the problem, the competition within
state goverments for administrative and financial resources,
and the lack of any central coordinating federal program
have all made significant progress in the area difficult.
Some states have been able to achieve notable progress,
while others have not been able to win adequate support
to make ground water protection a high priority.

     Approximately 60 percent of the states rely on
general laws as the basis for ground water protection.
Laws specific to particular sources of ground-water
pollution or related activities exist only sporadically,
are often not explicitly designed to protect ground-water
quality, and commonly include grandfather clauses that
exempt existing pollution sources.  Laws that do exist
to protect ground water from specific sources of pollution
are not generally applied in a coordinated program aimed
at ground water protection but implemented by diverse
agencies whose primary responsibilities are not directed
at ground water protection.

     State programs to protect ground water are usually
carried out through several state agencies.  Typically, a
public health agency has (or shares) authority over on-lot
wastewater treatment.  An environmental agency will have
authority over most ground-water pollution sources, although
in several states the authority for individual sources of
contamination belongs to more than one agency (that is, oil- and
gas-related issues are under a separate authority from
industrial waste sites).  A third agency may have
responsibility for ground-water quantity issues.  In
addition to the state agencies possessing regulatory
authority, other agencies such as a state geological
survey or the state soil conservationist are 'involved in
data collection or in providing technical assistance.
                            111-13

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     There are attempts in several states to coordinate
efforts through multi-agency advisory committees or
task forces.  However,  many relationships that exist
among the personnel of  various state agencies are informal
and subject to the traditional problems of turf, personalities,
and available resources.

     State staffing and budgetary limitations will, for
the most part, determine the ultimate form and organization
of ground water protection efforts.   It appears that no
state has the resources or funding it needs.  For example,
several states have septic tank regulations or regulations
on oil-well drilling but insufficient staff to enforce them
adequately.  A broad extrapolation from data collected
regarding the number of work-years currently involved in
state ground water protection programs indicates that about
525 work-years of professional/technical effort are expended
each year by all states.

     A state's efforts  in the protection of its ground
water and its commitment in resources is a function of
whether it perceives a  problem.  The level of concern
varies tremendously between states.   In some instances
a state may not, at this time, be a  heavy ground-water
user and may be complacent concerning the issues.  Other
states—New Jersey and  Washington, for example—are
developing fairly large staffs devoted to ground-water
issues and appear to be in the forefront in developing
innovative approaches to ground water protection.

     In order to round  out the general information needed
to give a reasonable picture of existing state ground
water protection programs, ground-water standards were
selected as one barometer of state programs.  Five states
have standards in effect, six are currently reviewing or
processing proposed standards, and another seven are
currently involved in drafting ground-water quality
standards.  Thus, nearly 40 percent  of all states are
either taking or have taken steps to develop specific
standards to protect ground-water quality.  However,
ground-water standards  may be very different from state
to state, with each state emphasizing the parameters and
levels needed to ensure its own protection.

     In addition, major sources of ground-water pollution
vary from state to state.  For example, in Washington and
Vermont, on-lot wastewater treatment is considered the
most severe problem, while in New Jersey, surface
impoundments that are leaking toxic  wastes are the greatest
source of pollution.  Programs also  vary substantially
among states.  In regulating septic  tanks, some states
require permits, some inspect construction and others
regulate system installers.  Attitudes toward land-use
controls also vary.  In Washington,  for example, sensitive
aquifers and recharge areas have been identified, and
                           111-14

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courts have held the right to deny permits for septic tanks
on these aquifers based upon ground-water contamination.

     Information essential to proper management of the
ground-water resources is also lacking in many states.
In a preliminary inventory, six states were identified as
having substantial knowledge of their ground-water resources,
Nine states are in the process of inventorying.  Five states
have a particular inventory and 27 states have no systematic
inventory.

     In addition, there are growing political pressures in
most states-to limit expanding state bureaucracies.   There
is a trend toward establishing limits on budget and
personnel increases, particularly in areas supported by
Federal funds.

Effect of Federal Programs

     A number of Federal programs are being delegated to
the states for management over the next two to five years.
Some of these deal directly with ground-water management--
the UIC and RCRA programs, for example.  Other programs
much more indirectly related include the grants program
for the construction of wastewater treatment plants.  The
delegation of existing environmental programs has tremendous
implications for state governments.  The principal impacts
will be to impose minimum Federal standards as established
in the statutes and to promote significant new levels of
Federal grant assistance.

Conclusion

     Thus it is clear that there is a growing interest in
and concern about ground-water management on the part of the
states.  Many state agencies are involved in ground water
protection.  Existing resources, data bases, and available
expertise are extremely limited.  As a result, there will
be fierce competition for resources in state governments and
a major management challenge facing state officials.
                          111-15

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PART TWO:   STRATEGY

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              IV.  INTRODUCTION TO THE STRATEGY
     EPA is proposing a ground water protection strategy in
recognition of the need to begin a preventive program to
protect the quality of the Nation's ground water in the future
and to manage the growing number of instances of significant
contamination currently being discovered.

     The problem is undeniably huge, considering the extent
and importance of our ground-water resources and the many
widely occurring threats to its safety.  The problem is also
unexpected; it is contrary to past conventional wisdom that
nature protects our underground waters.  Control measures are
few because few were thought to be necessary.  And the problem
is complex; detecting and cleaning up contamination are
difficult and costly operations.

     The prevention of ground-water contamination is a
critical national imperative.  Yet waste disposal and other
industrial and agricultural activities which threaten ground-
water quality cannot be halted altogether.  More instances of
contamination will be found.  The solution must be a realistic
blend of protective measures and practical alternatives to
current practices.

     Citizens expect Federal, state, and local governments to
take prompt action in defense of so great a public interest.
Yet in general, public institutions are not now equipped to
respond efficiently and effectively.  Many agencies have
authority bearing on one or another aspect of the problem but
no agency at any level has overall responsibility.  Nor is
there an existing framework through which various agencies and
levels of government can coordinate their activities.
Therefore, setting priorities, taking consistent appropriate
action, and even assessing the dimensions of the problem are
extremely difficult.  Even making full use of existing
authorities and regulatory tools is often beyond the
capabilities of the agencies concerned.

     What this strategy proposes, then, is to construct a
framework for ground water protection which:

        facilitates the development of institutional
        capabilities at the Federal/state levels;

        enables consistent ground-water policies and
        priorities to be set;

        expedites the gathering of data, technological
        information, and expertise;

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        focuses attention and action on high priority
        problems;  and

     -  promotes longer range planning and identification
        of more comprehensive future actions.

     The proposed  ground water protection strategy can provide
such a framework.   With the development of companion state
ground water protection strategies,  State and local governments
can collaborate with each other and  with EPA,  all using their
existing authorities and resources to full advantage.  Classi-
fication of ground waters can begin, using consistent criteria
to identify high priority ground-water resources and potential
siting locations.   Research and development as well as technical
information and assistance programs  can be intelligently and
expeditiously launched.  Other high  priority problems can be
pin-pointed and we can begin to address them.

     Obviously the key to the strategy's success is a cooperative
relationship among all levels of government in which we agree
to work together,  directing existing authorities and resources
toward a common goal, toward agreed-upon urgent priority problems
and toward the development of a sound and workable long-range
effort to protect  the Nation's ground water.  Out of our initial
experience in implementing current programs will come a better
understanding of the future magnitude of this problem and how
best to limit future contamination as well as how to deal
immediately with problems as they are discovered.   As this
experience is gained and assessed the need for additional
Federal legislation will be considered in the future.
                           IV-2

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                        V.  ASSUMPTIONS
     The proposed ground water protection strategy is based
upon a number of premises or assumptions.  While these are
often unstated, it is important to make them explicit so there
can be a common understanding and meaningful discussion of
the proposed strategy.

     The major working assumptions upon which the proposed
ground water protection strategy is based are:

       o  Ground-water threats will not be controlled
          quickly; the effort to develop a comprehensive
          protection program will be a long-terra one
          spanning many years.  Hence, the planning
          horizons must be long term.

       o  Coordination at all levels of government
          (Federal, State, regional, and local)  is
          essential to the success of the ground water
          protection strategy because the problem is so
          complex and institutions dealing with
          activities affecting ground water are so
          numerous.

       o  The strategy will not be able to identify
          all long-term priorities and policies; it
          provides a framework and a process for
          initiating programs now and for making other
          decisions at the appropriate time in the
          future  (i.e., there will never be a time
          when all the answers are available and the
          ultimate ground water strategy can be
          completely defined).

       o  The quantity and quality of ground water are
          so inextricably linked that any efforts to
          protect or enhance quality will have to be
          coordinated with the activities of the states
          and other Federal agencies in managing
          the quantity of ground water use.  Ground-water
          management efforts must also be coordinated with
          surface water quality management programs.

       o  Pending the adoption of a ground water classification
          system, all ground water currently of drinking water
          quality will be presumed to be a drinking water
          source and provided protection to ensure that its
          utility for this purpose is not impaired.

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o  Setting up a framework of institutional rela-
   tionships and programs for further ground water
   protection will take time and information.  To
   support the process, a priority must be assigned
   to gathering the needed scientific and engineer-
   ing knowledge on ground-water contamination,
   assessment, enhancement, and protection.

o  State and Federal resources available for ground-
   water issues are limited.  It is important to
   phase a strategy over time and to encourage the
   application of resources to the highest priority
   ground-water needs in each state, with respect to
   vulnerable and needed ground waters, toxicity of
   contaminants, severity of risk from polluting
   activities, and susceptibility to management
   action.

o  The strategy should encourage new and innovative
   approaches to ground water protection through,
   for example, process engineering changes to reduce
   pollutant volumes, product substitution, increased
   recycling, and treatment techniques prior to dis-
   posal.  It should also encourage innovative legal
   and institutional approaches to ground-water
   quality management.

o  Consistency among states is desirable in their
   approach to ground water protection, including
   terminology and definitions, use classifications
   categories, and in many technical and administrative
   areas as well.  It is also expected that the
   programs within states will within certain
   circumstances accommodate local conditions and
   priorities.  Nevertheless, it is assumed that this
   approach will facilitate responsible negotiations
   between states to assure consistent and appropriate
   classifications of ground waters crossing state
   boundaries.

o  No major new Federal legislation (with the
   exception of Superfund)  is anticipated at this
   time in the ground water area.  Existing
   authorities appear adequate to initiate the
   strategy and to begin to provide increased
   protection of ground water.  Legislative
   changes may ultimately be necessary, but
   sound and specific proposals can best be
   determined after more data and experience have
   been gained.
                    V-2

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                  VI.  GOAL AND OBJECTIVES


GOAL

    The proposed goal for the ground water protection strategy
is :

     "It shall be the national goal to assess,  protect and
      enhance the quality of ground waters to the levels
      necessary for current and projected future uses and
      for the protection of the public health and significant
      ecological systems."

     The term "goal" is used here in the sense of a mission
or an overall statement of purpose.  It is intended to be
an achievable goal, at least in the long run.

     The goal recognizes that not all ground water is of the
same value.  For example, some ground water is of extremely
high value because it serves a very critical human use or
ecological function; some is of very high quality or extremely
scarce.  Such ground waters should be accorded the most
stringent protection and levels of control.

     The goal for this ground-water strategy must be both
visionary and realistic.  On the one hand, the goal must be a
commitment to protect this basic natural resource for future
generations.  At the same time, it must be sensitive to the
competing interests that will be affected: state, national,
corporate and individual.  There is always some cost,
economic or other, to protecting any natural resource.  There
is also a social cost, perhaps long term, to not protecting
such a basic natural resource as ground water.   This goal
attempts to reasonably take into account these competing
interests.

     This goal is primarily preventive, rather than curative.
The long-term focus of this strategy is to prevent ground-water
contamination before it occurs rather than to focus on
after-the-fact cleanup efforts.  In the short term, however,
ground-water quality problems must be remedied as they continue
to be discovered.

     This goal also provides flexibility ,_e accommodate state
and local conditions affecting ground water.  Incorporating
as it does the assessment of natural geologic and hydrologic
characteristics of areas as well as uses of ground water,
the goal encourages actions which are tailored to state and
local conditions.

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"Assess"

     The goal contains three active verbs.  The first of
these is "to assess" the quality of ground water in order
to be able to protect and enhance it to the appropriate
levels.

     In this context, to assess the ground water does not
mean that full scale inventorying and monitoring is needed
before dealing with known problems.  It does imply taking
stock of existing information and where needed gathering
new data, in order to reach sound judgments on the appropriate
levels of protection for individual ground waters.

"Protect"
    The second action word in the goal is "to protect'1 the
quality of ground waters.

     The proposed goal embodies a protective presumption
that the quality of ground waters ought to be preserved
and protected for ourselves and for future generations.
It also recognizes, however,  that appropriate degrees or
levels of protection in certain circumstances may vary from
place to place depending upon local conditions and the use
for which the water will be needed.

"Enhance"
     The third action word in the goal is "to enhance" the
quality of ground water.  This is expected to be utilized in
cases where some degradation of quality has occurred and
where restoration efforts are warranted and feasible.  This
will occur in three situations:  first, where public health
or the environment is significantly threatened; second,
where the ground waters are of importance for certain uses in
an area; and third, where the contamination can be practically
reversed.

     Enhancement is a supplement to the main focus of the
strategy, which is preventive in nature.  These after-the-
fact corrective actions are important but deal only with
those contamination problems which already exist and those
which occur accidentally in the future.

Current and Projected Future Uses

    This goal is keyed to protecting ground water in
places and to quality levels according to present and future
use.  This is very significant since different uses of
water require varying levels of water quality.
                               VI-2

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     Naturally, current uses of ground water will receive very
high priority.  Forecasting is needed to predict future water
uses; the goal also suggests that ground-water quality be
protected to levels consistent with those anticipated uses.
Projections of future ground-water use will necessarily consider
population projections, land-use patterns, industrial expansion
plans, and agricultural needs, as well as the availability of
alternative water supplies.

     The goal also implies that explicit decisions will have to
be made between ground water protection and other competing
activities.  It acknowledges that certain industrial and other
activities may necessarily be of higher priority than ground
water protection in some areas and, though they may pollute
aquifers, should be continued or cannot reasonably be
discontinued.  Frequently cited activities which may conflict
with ground water protection are fuel extraction and processing,
agricultural practices related to irrigation return flow and
fertilizer use, waste disposal, and highway deicing.  Such
decisions clearly should be made in a public forum with adequate
programs for public participation.  These should assure
consideration of the long-term water needs of an area and require
appropriate controls on those activities which are allowed to
limit and control the spread of unwanted ground-water
contamination into areas where it will cause problems.   Setting
a priority for ground water use other than for drinking,, for
example, does not mean that mitigating measures need not be
instituted to minimize the effect of these competing activities.
Nor does it mean that EPA would take less stringent action when
an imminent hazard threatens.

Protection of the Public Health and
Significant Ecological Systems

    While the strategy focuses on protection for current and
projected future uses, an overriding concern must be the
protection of the public health.   Where limited degradation
will occur of necessity, provisions must be made to assure
protection of the public health.   This principle takes  on
special importance when one considers that ground-waters often
remain underground for hundreds of years; contaminants  deposited
today in a given location may emerge miles away in the  twenty-
third century or beyond.

     Where the migration of contaminants from past activities
threatens ecological systems,  suitable action should also be
taken.   Examples of this would be the discharge of toxic
contaminants in ground water into wetlands which would  pose
major risks to the related sensitive ecological systems.
                               VI-3

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OBJECTIVES

     The goal must be translated into some specific objectives
so that progress toward the goal can be made across a broad
front and measured over time.  These objectives can also serve
as guides to a phased implementation since it will take years
to fully implement the strategy.

     The objectives of the ground water protection strategy
are:

       By 1985

       o  To initiate ground water protection strategies
          in all states,  aimed at meeting the goal and
          and the long-term objectives and to develop
          the basic institutional capacities (resources,
          personnel,  etc.)  at  Federal, State and local
          levels.

       o  To implement fully the currently enacted Federal
          regulatory programs  which affect ground water
          (e.g., Resource Conservation and Recovery Act,
          Underground Injection Control Programs, and Surface
          Mining Reclamation Act).

       o  To launch technical  and administrative efforts to
          evaluate ground-water quality,  to ameliorate the
          most hazardous  conditions discovered,  and to develop
          and implement methods of managing newly discovered
          plumes of ground-water contamination.

       o  To provide a process whereby State and local
          governments and the  public can, in specific
          situations, with adequate public health and
          environmental protection, set priorities among
          competing activities which may use or contaminate
          ground water.

       By 1990

       o  To ensure that  appropriate levels of protection
          are provided for the ground water resources
          in each state and that each state has a complete
          program fully implemented to manage all ground
          water.
                             VI-4

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             VII.  MANAGEMENT APPROACH


INTRODUCTION

     The approach to managing ground water protection which is
envisioned in this strategy is an institution-building and
priority-setting process.  It provides the basis for deciding
which ground waters require the greatest levels of protection,
which sources of contamination to act against first, and what
general roles ought to be taken by Federal and State governments
and others in developing and implementing such programs.  This
management approach has direct implications for the next chapter
on technical requirements.


KEY ELEMENTS IN THE
MANAGEMENT APPROACH

     There are four key elements in the proposed management
approach to ground water quality protection.   These are
summarized briefly below:

     1.   State Ground Water Protection Strategies.  These
          strategies, developed at the state level, should
          identify how the national goal will be met through
          specific regulatory and other program actions at
          the state and local levels, including alternative
          approaches such as economic incentives.

     2.   Ground Water Classification.  The primary basis
          for establishing priorities on ground water
          protection would be the classification of ground
          waters according to the differing degrees of
          protection warranted.  Where ground water is of
          drinking water quality or better, there will be a
          presumption that it will be classified and
          protected as such, unless a lower classification
          is justified by a thorough analysis of the impact
          of such action on ground-water quality in the
          affected areas, the present and projected future
          drinking water needs and availability, and a full
          public consideration of competing uses.

     3.   Minimum National Requirements for Selected
          High Priority Problems.  There are some problems
          which, on a national scale, are so severe and
          complex that they should be assessed on a
          national basis.  Where national action appears
          to be appropriate, EPA in consultation with the
          states and other  affected parties would develop
          regulations or legislative proposals.

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     4.    EPA Administrative Actions.   An important element
          of this approach to ground water protection is the
          coordination of existing EPA and other Federal
          programs providing increased guidance and support
          to the states in carrying out their ground water
          protection strategies and increased research on
          ground water.

     Further elaboration of the elements described above is
presented in the following sections.


STATE GROUND WATER PROTECTION STRATEGIES

     The development of ground water protection strategies by
the states is a central element of the proposed ground water
strategy.  These strategies should establish the framework for
planning, implementation, and enforcement activities at the
state and local levels and should aid immeasurably in
coordinating state efforts with those at the Federal level.
Under this approach the states will continue their historical
role as the primary authority over issues affecting both the
use and quality of ground water within the framework of
existing legislation.

     EPA envisions a three-phase approach to developing state
strategies.  First, EPA will formulate and issue guidance for
development of the strategies with the full participation
of state and other interested groups.   Second,  States would
prepare the strategies with the participation of affected local
governments, the public, business, and special  interest groups.
Third, these strategies would be incorporated into the State/EPA
Agreements  (SEAs), with EPA reviewing the strategies and approving
those portions dealing directly with the implementation of
programs required under Federal legislation. EPA would encourage
States to use these strategies as a vehicle for comprehensive
ground water protection that goes beyond federally mandated
programs to address such problems as highway deicing, under-
ground storage tanks, agricultural practices and other local
practices.

Content of Strategies

     The first step in the state strategy development process
will be the preparation of guidance on the recommended content of
ground water protection strategies.  The following are examples
of what would be expected in most state strategies:

        o  A goal and objectives consistent with
           those stated above and reflecting state
           and local conditions.

        o  A ground-water classification system
           consistent with a national set of criteria
           designations and other definitions.


                           VII-2

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o  Mechanisms for coordinating existing State
   programs as well as Federal programs
   administered by the states related to ground
   water protection, including provisions for
   dealing with instances of ground-water
   contamination as they are discovered,
   especially to protect drinking water
   sources that may be threatened by the
   movement of these plumes of contamination.

o  The state approach to controlling and
   integrating the control of non-federally
   regulated sources of ground-water contami-
   nation.

o  The interrelationship of each state strategy
   to existing state and Federal programs
   affecting ground water (e.g., state programs
   related to ground-water quantity and allo-
   cation issues).

o  How the state would negotiate with neighboring
   states to assure consistent classification
   and management of ground waters crossing state
   boundaries.

o  Identification of the need and plans for enabling
   legislation at the state level to enact and carry
   out the strategy encompassing all state ground-
   water protection efforts.

o  How the state will enforce the program including
   administrative and legal authority.

o  How the state will coordinate state and local
   activities to implement the strategy.

o  A phased implementation plan (including insti-
   tutional, legal, and fiscal components) and
   a schedule, with plans for reassessment.

o  A public participation program which includes
   developing and changing the strategy, making
   ground-water classification decisions, and
   setting technical requirements.
                    VII-3

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Implementing Actions

     The EPA will assist states in preparing these strategies
by, for example, providing guidance, technical assistance on
specific problem areas and facilitating the exchange of
information and experience among the states as they expand
their ground water protection programs.

     In addition, SPA will promote the development of state
ground water protection strategies with interested states
through the existing State/EPA Agreements (SEAs).    Funding
for such activities will, to the extent feasible,  be made
available from existing programs such as Section 208 (Clean
Water Act), RCRA, and UIC,

     EPA will provide additional support by better coordina-
tion and focusing of its own program efforts:  construction
grants, TSCA, FIFRA, RCRA and UIC.
GROUND WATER CLASSIFICATION

     The development and implementation of a ground-water
classification system is a second major element of this
strategy.  Its principal purpose is to provide for different
levels of protection to ground water depending upon a number
of factors.  The classification process should help
differentiate the high priority ground-water areas for high
levels of protection and for first attention and investment,
as well as identify those areas that are least environmentally
sensitive for siting of new waste disposal facilities and
other potential contaminating activity.  This approach
recognizes that not all aquifers have natural yields of the
highest quality water and that all uses do not require the
same level of quality.

     The two sections below elaborate on the classification
approach.  The first describes one way the classification system
may be developed and what factors may be considered in its
establishment.  The second describes how this system might be
developed and implemented.

Classification System Development

     EPA will develop a set of ground-water classes after
substantial participation and consultation with state and local
governments and other interested groups.  The classification
categories will be based on present or projected future uses
and will include consideration of the quality of the ground
water, its yield, its vulnerability and its value relative
to alternative sources of water supply in an area.  If, for
example, a particular ground water is of marginal quality
or good quality but low yield in an area richly endowed with
high quality surface waters, then the ground water may not
                           VII-4

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necessarily be classified as a drinking water source if it is
unlikely to ever be used for that purpose, if contamination can
be limited to avoid threatening adjacent needed ground water
resources and if the need for a competing use can be clearly
established.  On the other hand, that same source might be
classified as a future drinking water source in the arid West
where alternative supplies are not so plentiful.

     The following tentative outline of such a classifi-
cation system illustrates how it could be structured and
how it would provide for three levels of ground water
protection.

Definition of current and projected future use - First, perhaps
as many as seven ground water use categories might be identified.
These could include:

     o  Highly valuable drinking water, (sole source
        or pristine)

     o  Drinking water, with minimal treatment

     o  Drinking water, with extensive treatment

     o  Agriculture uses (irrigation, livestock)

     o  Industrial uses (cooling, process water)

     o  Mining and energy development

     o  Limited waste disposal

     While the dominant factor upon which the classification
system will be based is a judgment regarding the present and
projected future uses of each ground-water supply, the
definition of ground-water uses will also include the yield,
natural quality of the ground water, and the availability of
alternative sources of water.  This will provide flexibility,
for example, to rank a given ground water of marginal or low
quality in a high category if it is the only available drinking
water in an area to protect it to the greatest possible degree.

     Conversely, because it may often be exceedingly difficult
and expensive to clean up ground water once it is contaminated,
a decision to classify ground water now suitable for drinking
for a less protective use can have far-reaching and in some cases
devastating consequences.   Consistent with the strategy's goal
to protect public health,  any decision which may curtail future
supplies of drinking water should be made only after a thorough
analysis of the availability of other drinking water supplies
and full public consideration of the social and economic trade-
offs involved.
                              VII-5

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     The classification process developed as a part of this
strategy would therefore begin with the assumption that all
ground water now suitable for drinking water (whether or not
it is currently being used for drinking)  must be presumed to
have a "projected future use" as a drinking water supply and
should be protected to levels consistent with that use.

     As a state adopts a classification system and proceeds
to identify and classify areas within the state for uses at
levels lower than drinking such as agriculture, industrial
development, energy production or limited waste disposal, the
steps that should be taken prior to that decision should include:

          o  a full assessment of future drinking water
             needs

          o  a full assessment of quantity and quality of
             available drinking water supplies

          o  a demonstration that any loss of potential
             drinking water supply will not be greater
             than that ^needed for future purposes.

          o  adequate protection for significant ecological
             systems and public health

          o  collection and analysis of appropriate related
             data on the ground water and the effect of the
             uses contemplated

          o  development of control requirements for the
             non-federally regulated uses contemplated

          o  full and formal public review

     Such judgments will be especially important with regard
to uses such as energy development or limited waste disposal
which may preclude any future use of the ground water for other
purposes.

Vulnerability - The second major factor determining the level
of control needed is the degree of natural protection afforded
by local hydrological and geological conditions.  For ground
water of given use classification, for example, drinking water,
more control would be required in an area of sandy soil which
affords little natural protection than in an area which
already provides significant protection from contamination.
Also, ground water is vulnerable to contamination from an
overlying or underlying aquifer if the confining stratum
between them is fractured and allows water to flow from one
to the other.  Levels of protection therefore could vary both
as a function of the use classification and the natural
protection in an area.  Each type of contaminating activity
would be controlled differently under one level of protection
versus another.
                             VII-6

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Levels of Control - A three-tiered system is envisioned, the
first generally includes ground water which serves a highly
valuable human use or ecological function warranting the most
stringent levels of control particularly to protect the
recharge areas.  This class could also include waters of lower
quality but extremely high value such as very scarce waters
essential for drinking purposes in arid areas, or ground
waters traditionally used for drinking purposes in densely
populated areas, which were becoming contaminated and for
which extremely high levels of control were deemed appropriate
to assure continued use for drinking purposes.

     The second would provide levels of protection typically
required to ensure a level of ground-water quality associated
with use as a drinking water source.  The assumption is that
the majority of fresh ground water would be found in this
class.

     The third class would cover areas which provide the best
opportunity for mitigating the adverse effects of necessary
waste disposal or for which competing uses such energy
production, agriculture or industrial use are determined to
be necessary and appropriate.  Here limited and defined
contamination would be allowed for some but not all types of
contaminants.  It is expected that the number of areas falling
into the third tier would be relatively small, decided through
an open public process and limited in such a way as to prevent
"pollution havens."

     Classification of ground waters into any of the classes
would in no way preclude or limit the EPA or a state from
bringing an "imminent hazard" action if and when migration
of contaminants poses a significant threat to the public health
or the environment as defined under any of its statutes.

     These three levels of requirements would be specified for
various major polluting activities and for specific high
priority contaminants.  In cases of federally mandated programs
or authorities, the Federal government would specify the
requirements necessary for each of these levels.  Where there
are not Federal programs, the states would set control require-
ments for each level which are appropriate for protecting the
state's ground-water resources.  In such cases, the Federal
role would be one of providing assistance by suggesting
advisory or model control approaches such as best management
practices (BMPs).

     As an illustration, examples of the three levels of
technical requirement which might be set by state and Federal
governments include the following;

     o  Level 1 protection; could include a ban on
        facilities dealing with highly toxic or
        hazardous wastes or establish the highest
        level of control requirements; stringent
        limits for areawide activities such as new

                            VII-7

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        septic systems;  bans or restrictions on
        certain types of industrial development;  a
        prohibition of certain energy development
        or other activities which significantly
        affect the ground water;  and the highest
        priority to enforcement against existing
        sites which are polluting.

     o  Level 2 protection:  could consist of limited
        siting for new facilities dealing with toxic or
        hazardous substances with strict technical and
        monitoring requirements;  strict technical require-
        ments and monitoring for existing sites;  for
        areawide sources of contamination less strict
        siting and design standards such as for septic
        systems; and best management practices (BMPs)  for
        other areawide activities such as agriculture and
        construction.

     o  Level 3 protection;  would allow limited  siting of
        facilities involving toxic or hazardous substances
        with less stringent technical requirements than
        above; it would include less strict BMPs  for
        areawide sources such as agriculture; non-
        hazardous waste disposal and other contaminating
        activities would be subject to BMPs, and  monitoring
        requirements would protect the public health and
        control serious threats to the environment for
        such activities as industrial water use,  waste
        disposal operations and energy development.
        This tier would offer fewer controls on a facility,
        for example, but far greater attention to assuring
        that any resulting pollution is kept from migrating
        from the designated site through more stringent
        monitoring requirements.


Federal and State responsibilities •- This strategy envisions
that the EPA and states would have quite different roles in
developing and implementing a classification system.  Since it
is important to have a reasonable degree of consistency
nationwide in the definition and categories used  for these
classification systems,  EPA would take the lead in working with
the states to develop a common system.  This will facilitate
cooperation in dealing with interstate issues and will provide
a more understandable regulatory environment from state to
state for businesses and individuals.  Furthermore,  a
consistent classification framework is necessary  for federally
mandated programs to enable EPA to define regulatory require-
ments in a structure which each state can readily implement
and in which EPA can ensure that the intent of its laws are
fully carried out in all states.   It would avoid  situations
which could cause major economic dislocations or  promote
"pollution havens" in localities more interested  in development
than in ground water.
                             VII-!

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     If a state adopts the classification system, the state
would make the decision in classifying individual ground
waters into specific use categories and levels of protection.
EPA would over-ride only where it affects program decisions
under existing Federal legislation.  Further, the states,
except where provided for in Federal legislation, would make
the permitting decisions or enforce the rules through which
facilities or activities are kept in compliance with the
related rules and regulations.

Classification System Implementation

     The first step in the implementation of the classification
system will be the development of criteria for classification
categories.  As the system is developed, these categories will
be incorporated into existing ground water protection programs.

     A guidance document would be prepared to describe the
classification criteria and recommended procedures for state
implementation.  The document would also include information on
classification models and other technical data of use to state
officials in the classification process.  Technical experts
on ground water would be identified and made available as
resources to the states.  EPA will give particular emphasis
to assuring that USGS and State Geological Surveys and other
state agencies having responsibility for hydrogeological data
collection are closely tied to this effort and that maximum
use is made of their expertise and information resources.

     Each state would adopt its own tailored application of
the ground water classification system, responsive to the
needs which the state perceives at the state and local levels
yet consistent with Federal requirements for federally
mandated programs.  The classification system would be a key
part of the state's ground water protection strategy and may
require enabling state legislation prior to full implementation.
State decisions of classification for particular ground waters
would be made through a formal public process with participa-
tion of local government, affected business, and industry, and
the public.  Those who propose activities with the potential to
contaminate ground water would be expected to bear the burden
of proof that their activities would not jeopardize ground
water for projected future uses.  Once the classification
system is in place it would be enforced through the usual
permitting or rule-making process of the state or Federal
government where appropriate.  It is expected tha,t state
systems would vary, reflecting different values and situations.

Implementing Actions

     Several EPA actions can be taken to support states in
classifying their ground water.  The first step is to work
with states to develop the system.  Secondly, EPA will make
such classifications a grant-eligible activity under the
State/EPA Agreements.  Thirdly, EPA will work closely with
USGS and other appropriate Federal agencies to ensure their
full participation and contribution to this effort.


                          VII-9

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     State officials will be encouraged to coordinate their
classification efforts with other related programs such as
land use planning, water supply needs assessments, state
geological mapping and similar activities.


MINIMUM NATIONAL REQUIREMENTS
FOR SELECTED HIGH PRIORITY PROBLEMS

     Some problems affecting ground water are so serious,
complex or ubiquitous that national action is warranted.
Cases in which national action may be most effective could
include situations, for example, where chemical substances,
contamination pathways, and treatment processes are extremely
complex and widespread; where special regulatory remedies
such as product bans or use restrictions dictate unified actions;
where interstate issues are significant, as in waste disposal;
and where uniformity among states is clearly needed to avoid
major economic dislocations and the establishment of de facto
pollution havens.

     EPA will also continue to make full use of its emergency
provisions of RCRA (S 3008) and the SDWA  (S 1431)  to protect
ground water.  It is expected that the ground-water
classification process and inventory efforts such as
hazardous waste sites and surface impoundment assessment will
identify even more highly dangerous situations which warrant
action through these laws.                   \

     Another area for major EPA effort is the development of
maximum contaminant levels and suggested no adverse risk
levels for organics and other elements in drinking water.
While these are not ground water standards, they are extremely
useful in defining the health risk posed by contaminants
in ground water likely to serve as sources of drinking water.
They are of particular use to state officials in reacting
quickly and knowledgeably to detected threats to drinking
water sources.  Increased research is being devoted to
the development of risk levels in the area of pesticides
as well.

     National guidelines on how monitoring should be conducted
and how results should be reported, stored and disseminated
could also aid in improving the national data on ground water
and the threats to it.  Additionally, national surveys  (such
as the recently completed Surface Impoundment Assessment) will
add to EPA's and the states' understanding of contaminant sources
or of present ground-water quality-  These data may identify
pervasive contamination where national action could be
effective.  Such data may also aid states in detecting and
dealing with plumes of contamination which may require
state action.  EPA., in conjunction with USGS and others, will
devote substantially increased attention to this area.
                            VII-10

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     Another area to which EPA will give major priority is the
identification of procedures for dealing with instances of
detected contamination.  It will take time for state and EPA
strategies to be fully developed and implemented.  Meanwhile
situations are already being discovered where serious ground-
water contamination has occurred.  There is a need to collect
all that is known about tracking and managing underground
plumes of contamination and to provide assistance and coordina-
tion to the states in that area.  This will be a particularly
difficult task due to the very slow movement of most ground
water and long-term management problem posed by such instances.

     EPA will also identify other high priority sources of
contamination which deserve greater attention.  One such
source might be underground storage tanks.  A fraction of
these leak but they are subject to relatively limited
technical requirements.  EPA could conduct an assessment of
this problem, work with industry to develop recommended design
and installation standards, and work with state governments
to develop better management practices or model state laws.
Such model ground water programs are now being supported
through the 208 program.

New Federal Legislation and Programs

     At this time EPA is not proposing new Federal legislation.
The immediate challenges seem to be ones of coordination,
follow-through, and implementation.

     As implementation of the existing programs is completed
and more time and effort is devoted to new problems,  the need
for additional legislation and new programs for ground water
protection may be considered.

Implementation Action

     There are specific actions which the EPA is taking to
begin implementing this aspect of the ground water protection
effort, RCRA and UIC being of major importance.  The inclusion
of RCRA, for example, in the Consolidated Permits System will
ensure that the effects on ground waters of surface impound-
ments which contain hazardous wastes will be addressed
in a coordinated fashion.

     EPA will also initiate work on recommended approaches
to managing and tracking underground plumes of contamination,
to high priority sources of contamination such as surface
impoundments and gasoline storage tanks, and is increasing
its efforts to provide information guidance and technical
advice in the area of ground water monitoring.
                              VII-11

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     Finally EPA expects to accelerate the development of
additional drinking water standards for additional harmful
contaminants such as synthetic chemicals which are reaching our
drinking water and to provide significantly expanded advice
on health risks posed by currently unregulated contaminants.

EPA ADMINISTRATIVE ACTIONS

     Administrative actions by EPA will be important in
supporting the states in ground water protection.   The
sections above have discussed actions which support the
development of state ground water quality plans,  which
deal with ground water classification and in the  establish-
ment of minimum national requirements for selected high
priority problems.

     In addition to these specific actions described above,
EPA will seek to coordinate its own regulatory and other
programs related to ground water protection.  These include
RCRA, UIC, FIFRA, TSCA,  and many sections of the  CWA
including Section 208 and the construction grants program.
EPA will take specific steps to ensure that the approaches
taken under these authorities are consistent with the ground
water protection strategy.

     EPA will also work  with other Federal agencies such as
the Nuclear Regulatory Commission, the U. S. Geological
Survey, the Water Resources Council,  the Council  on
Environmental Quality, and the Departments of Agriculture,
Interior, Transportation, and Housing and Urban Development
toward achieving the goals of this strategy.  EPA will also
encourage cooperation with the state strategies by all
Federal facilities.

     Steps will be taken at both EPA headquarters and the
regions to assure coordinated implementation, using the SEA
as a principle vehicle.

Research and Development

     The Agency will reflect the choices in this  strategy
in its research and development activities.  These needs will
affect both the priority setting and selection of program
elements for the R&D program.  While specific decisions have
yet to be made, the research areas which will be  given high
priority in support of this strategy include the  following:

     Methods development;  The characterization of this
nation's ground water is a critical element of the strategy,
This will require definition beyond the traditional hydro-
geologic parameters, including improved determination of
acquifer boundaries and  recharge zones and increased
                      VII-12

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capacity to conduct geophysical and hydrogeologic mapping
for land use evaluations.  EPA is now directing its
efforts toward defining the nature of the subsurface
environment in terms of its innate physical, chemical,
and biological characteristics and developing a unified theory
correlating, these findings with contaminant transport.

     A second area requiring considerable research is ground
water modeling to predict the movements of contaminants in
ground water systems.  We need the capability to address economic
and management problems as well as those in mass transport
of organic and biological contaminants.

     Major improvements are required in monitoring techniques
including drilling, completing, and sampling monitoring wells.
Research is needed on methods for monitoring leakage in the
unsaturated zone and in determining the effects of waste
disposal practices on ground water.  In-situ monitoring,
remote sensing, and the proper use of tracers are all areas
needing extensive research.  Finally surface methods must
be developed to detect contamination and delineate the
extent of contamination, thereby eliminating the need for
exploratory drilling to find contamination,  an extremely
expensive practice.

     Health effects research:  Improved information on
the long-term effects of organic contaminants is needed
to support the development of standards for substances
which are frequently found in ground water.   Ultimately,
this strategy contemplates the use of such standards for
enforcement purposes as our knowledge in this area increases.

     In the meantime, increased attention will be given
to producing the science needed to support expanded
drinking water standards and advisory information on
unregulated contaminants of concern.

     Transport and fate:  Research will also be required to
develop classes of contaminants and select an indicator
substance for each of these classes in developing transport
and transformation information. This is particularly
true with respect to organics, bacteria and viruses, and
to a lesser extent, metals.  An important goal of this
area of research is the development of indicators for
monitoring.

     Other areas of high research priority include:

     - effects of water reuse on ground water;

     - contamination potential, design standards, and
       treatment technologies for individual sources of
       contamination such as septic tanks and liners
       in landfills or lagoons; and
                            VII-13

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     - aquifer rehabilitation,  where extensive
       research is required in the physical or
       hydraulic isolation of waste sources and
       the treatment of contaminated ground water
       either in-situ or upon removal.

     Other Research:  Research will be needed in some less
technical areas to support the strategy.   One of these is
in information transfer and data management.  Systems
must be developed for distributing existing and future
technical information in practical and efficient ways.

     Research is also needed on the institutional
arrangements and legal issues which affect the strategy.
Examination of economic incentives and other innovative
approaches to ground water protection will be important.

     Finally, experience in implementing  the strategy will
surely reveal other gaps in our knowledge and technology
that will require research.
                             VII-14

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               VIII.  TECHNICAL REQUIREMENTS
     The proposed strategy provides several types of technical
requirements for use in controlling the many different types
of problems affecting ground-water quality.  Contaminant
sources range from buried storage tanks to agricultural
practices to waste disposal sites, and no one approach to
technical requirements is appropriate for all.

     Because the importance of different problems affecting
ground water varies from state to state, it is expected that
the relative emphasis on different types of technical
requirements will also vary.  Technical requirements will
also vary, at least in degree if not in approach, for each
ground water classification category.  Requirements for the
highest quality ground-water classes would, of course, be
more stringent than those for classes where industrial
development and even waste disposal will be located.

     The mature state program envisioned as a result of this
Strategy will protect ground-water quality to levels dictated
by its value and its use.  All ground water is not of infinite
value.  All uses do not require the same quality levels.
The environmental impacts which can be tolerated in a parti-
cular aquifer, in keeping with its value and its use, will
be limited by imposition of performance controls on facilities
and practices which threaten ground water quality.  Eventually,
under a fully matured system, where water quality limits can
be confidently established, a system to use value-related
water quality standards could be considered.  However,
during the formative period in the near term, the proposed
strategy must rely on technical requirements to achieve the
protection appropriate to the aquifer.

     The exact numerical or other standards which might be
applied to any given activity are not to be defined at this
time, not even in the development of the state ground water
quality plans.  These first steps are to define the approach
to such requirements and to provide a framework and process
for developing the specific requirements later during program
implementation.

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The Major Technical Approaches

     There are four types of technical requirements which are
expected to be used extensively under this strategy.  These
cover the range of problems which are the primary concern of
the states under their ground-water quality plans and also
cover the types of high priority problems which will be
addressed by national actions.

     These four major technical approaches are:

       o  Siting and Design Requirements.  The designation
          of where and how certain facilities should be
          located is one of the most powerful tools for
          control of certain area-wide practices, such as
          septic systems and very toxic or hazardous sources
          of contamination.  Siting standards or guidelines
          would be keyed to the type of ground water involved.

       o  Best Management Practices (BMPs).   These "rules"
          that specify the best operating practices and
          recommended design and construction practices seem
          to provide the best vehicle for managing many
          area-wide activities which affect ground water.
          This approach to technical standards provides
          great flexibility to tailor requirements to
          individual, local situations.

       o  Technology-based or Effluent Standards.  This
          approach typically specifies exact numeric limits
          for allowable levels of "discharge" to ground
          waters separately for each individual technology-
          This is generally best suited to industrial or
          other technological operations where process
          controls or changes can be designed to fit the
          needs of specific equipment, operating rates, and
          chemical constituents.  Since "discharges" to
          ground water can be hard to quantify, this approach
          is sometimes implemented as a basis for design
          requirements rather than directly as an enforcement
          tool.

       o  Performance Standards.  These standards specify
          performance levels which must be attained by
          certain types of activities or facilities and are
          not pegged to specific technologies.  These provide
          the flexibility to encourage innovative technologies
          and other approaches to ground water protection.
                            VIII-2

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Other Technical Approaches

     Numerical ground water standards are appealing because
they specify quality levels which can be measured to ensure
that they have been attained.   However, the technological
bases for them are simply not ready to support specific
standards.  There is more to be done in the areas of monitoring,
ground water modeling, fate and effect research,  and other
areas before ground-water quality standards can broadly
serve as a basis for regulatory requirements at individual
sites.

      Technical approaches other than these four  may be
utilized by states and perhaps on some national programs,
but are expected to be much less widely used than those
above.   In the long run new approaches may prove  to be most
effective, but for the first phases of ground water program
implementation those above will be the mainstays  of the
program.

      Economic incentives are desirable, but are  not yet well
defined.  They are appealing because they provide local
flexibility and lower societal costs.  Consistent with the
general Agency interest in the use of market mechanisms for
environmental protection, EPA and the states should explore
incentives concurrently with the technical approaches outlined
above.
                             VIII-3

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                      IX.   NEXT STEPS
     The strategy for ground water protection that has been
proposed in these pages will be evolving,  not static.
It will be expanded in the future as the new programs  now
underway are more fully developed, as new information  is
gained about ground-water resources and threats,  and as
experience accumulates.

     Once approved as a final strategy, the implementation
of the strategy will begin through the State/EPA Agreements,
EPA's research and development efforts, the Agency's normal
regulatory processes, administrative actions and the budget
process.

     Some questions remain and will be explored during the
course of implementing the strategy.  An evaluation of the
early years of strategy implementation—similar to the
public process used to develop this strategy—will enable
us to identify the changes and additions needed to improve
this ground water protection program.

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                        ACRONYM LIST
BMP

CWA


FIFRA


NPDES


NRC

OWWM

POTW

RCRA


SOW A


SEA

TSCA

UIC

USGS
Best Management Practice  (Water Quality)

Clean Water Act; also known as the Federal Water
Pollution Control Act (FWPCA)

Federal Insecticide, Fungicide, and Rodenticide
Act

National Pollutant Discharge Elimination System
(Water Quality)

Nuclear Regulatory Commission

Office of Water and Waste Management

Publicly-Owned Treatment Works

Resource Conservation and Recovery Act; enacted
as amendment to the Solid Waste Disposal Act

Safe Drinking Water Act; enacted as amendments
to the Public Health Service Act

State/EPA Agreement

Toxic Substances Control Act

Underground Injection Control

United States Geological Survey
                                          U.S. GOVERMENT PRINTING OFFICE 1980-0- 341-085/4616

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