EPA 910/948-248
              United States
              Environmental Protection
              Agency
Region 10
1200 Sixth Avenue
Seattle WA 98101
              Ground Water
              Program Profile
              1991
Alaska
Idaho
Oregon
Washington

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           PROFILE OP GROUND WATER PROTECTION IN IDAHO
INTRODUCTION                                                   1

     A.  State History of Ground-Water Protection              1
     B.  Legislative Authorities                               2

I.  SETTING GOALS AND DOCUMENTING PROGRESS                     4

     IA.  Ground-Water Protection Goal                         4
     IB.  Evaluation Mechanism                                 6
     1C.  Public Participation                                 7
             Public Involvement                                7
             Public Outreach and Education                     7

II.  CHARACTERIZING THE RESOURCE AND PRIORITIZING ACTIONS      9

     IIA.  Resource Assessment                                 9
             Aquifer Mapping
             Aquifer Vulnerability Mapping
             Ground-Water Standards and Aquifer Classification
             Wellhead Protection Area Delineation
             Sole Source Aquifer Designation
             Ground-Water Quality Assessments
             State Programs and the USGS

     IIB.  Contamination Source Identification                 20
             Underground Storage Tanks
             Solid Waste Landfills
             Hazardous Waste Facilities
             Underground Injection Control Wells
             Land Spreading Operations

     IIC.  Setting Priorities                                  23

     I ID.  Data Management, Monitoring, and Research           26
             Data Management
             Monitoring
             Quality Assurance
             Research

III.  DEVELOPING AND IMPLEMENTING PREVENTION AND CONTROL       31
      PROGRAMS

     IIIA.   Source Elimination                                 31
              Idaho Waste Reduction Assistance Program
              Agricultural Pollution Abatement Plan
              Grassy Swales

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     IIIB.  Locational Criteria                               38
              Hazardous Waste Facility Siting
              Source Specific Locational Criteria
                 Septic Systems
                 Underground Injection Wells
                 Public Water Supply Regulations
                 Land Application of Wastewater

     IIIC.  Permitting, Compliance Monitoring and             39
            Enforcement Systems
              Permitting
                 Land Applied Wastewater
                 Underground Injection Wells
                 Well Construction Standards
                 Solid Waste Disposal Sites
                 Hazardous Waste Sites
                 Septic Tanks
              Other Control Programs
                 Underground Storage Tanks
                 Idaho National Engineering Laboratory
                 Drinking Water Program
                 Agricultural Chemicals/Chemigation
                 Feedlots and Dairies
                 Mining
                 Rathdrum Prairie Aquifer Protection Program
                 Indian Lands
              Compliance Monitoring
                 IDHW
                 IDWR
                 DOA
                 Health Districts
              Enforcement
                 IDHW
                 IDWR
                 DOA
              Remediation
                 Superfund Type Activities
                 RCRA Corrective Action
                 Leaking Underground Storage Tanks
                 Contamination Log
                 INEL

IV.  DEFINING ROLES WITHIN THE STATE AND THE RELATIONSHIP      54
     TO FEDERAL AGENCIES

     IVA.   State Roles                                         54
              IDHW
              IDWR
              DOA
              State Fire Marshal
              State Insurance Commissioner
              INEL Oversight Program
              Idaho Geological Survey
              Coordination Mechanisms

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     IVB.  Local Roles                                         57



     IVC.  Relationship with Federal Agencies                  58



V.  RESOURCES                                                  60



     VA.  Financial                                            60



     VB.  Personnel                                            61



Appendix A                                                     62




Appendix B                                                     64



Appendix C                                                     65

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                        LIST OF ACRONYMNS





APAP   -  Agricultural Pollution Abatement Plan



BLM    -  Bureau of Land Management



BMP    -  Best Management Practices



DOA    -  Department of Agriculture



GWQPA  -  Ground Water Quality Protection Act



I DEW   -  Idaho Department of Health and Welfare



IDWR   -  Idaho Department of Water Resources



IGIAC  -  Idaho Geographic Information Advisory Committee



IGS    -  Idaho Geologic Survey



PWS    -  Public Water Supply Program



RCRA   -  Resource Conservation and Recovery Act



SCO    -  Soil Conservation Commission



SCS    -  Soil Conservation Service



SDWA   -  Safe Drinking Water Act



UIC    -  Underground Injection Control Program



DSFS   -  United States Forest Service



USGS   -  United States Geological Survey

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                           INTRODUCTION
A.  STATE HISTORY OF GROUND-WATER PROTECTION

Prior  to 1983  ground-water protection  in  Idaho was  limited to
existing  statutory  and regulatory  authorities administered by
various  media  programs and  state  agencies.   None  of  these were
dedicated to a  distinct focus on protection  of ground water as a
resource, but  this  was either a secondary goal or  an incidental
benefit of the regulation.   Such program regulations  were also very
limited  since,  for  example: the solid waste  regulations were ten
years old and  out of date; state hazardous waste legislation did
not  exist;  the underground  injection  control  program was  not
delegated from  EPA, etc.

Recognizing the need for a more comprehensive approach to ground-
water protection the Ground-Water Quality Management  Plan for Idaho
was administratively adopted by the Idaho Department of Health and
Welfare  (IDHW)  in 1983. A ground-water unit  was formed in IDHW's
Water  Quality  Bureau  in  1984 when EPA's new  ground-water grant
program  was initiated.   After beginning to implement some of the
recommendations,  the  plan was subsequently updated  in  1985 to
provide  additional direction  for ground-water quality protection.
While the plan provided the framework for a good beginning, it was
largely  an IDHW plan and was  not formally adopted by the Governor
and/or the legislature.  The need for a more multi-agency approach
was recognized with  the advent of increased scrutiny  on such issues
as agricultural chemicals  in  ground water, etc. and the state was
beginning to address the need for a more comprehensive plan
when other developments arose.

After the 1985  plan update IDHW began working  on one  of  the key
recommendations which  was  the development and adoption of ground-
water standards which  included an aquifer classification system.
IDHW researched the  various approaches taken in other states and
developed several draft proposals during 1985-1987.   In late  1987
formal hearings were  held throughout  the  state.    The  proposed
ground-water standards proved controversial and were  brought to the
attention  of  the  state  legislature.   A  special  legislative
committee  was   formed  to   provide   guidance  on   ground-water
protection.  Public meetings were held around  the  state  to  seek
additional input  and  IDHW was requested to delay  the standards
adoption process.

After seeking public input the legislature decided there was great
interest  in  protecting   the  ground-water   resource  but   that
legislation was needed to  guide the process. Legislation was
drafted  in 1988 and the proposal was introduced during the  1989
session.

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The Ground-Water  Quality  Protection Act was enacted  by the 1989
legislature and was signed by the Governor.  The Act amends Idaho
Code, Section 39-102 and adds new sections of Idaho Code Sections
39-120 through 39-127.  Also  included  in  the Act is an amendment
to  Idaho Code, Section  67-6537  requiring local  governments  to
consider the  impacts to  ground water in  comprehensive planning
decisions.

The Act calls for creation of a Ground-Water Quality Council that
is responsible for  developing a Ground-Water Quality  Plan.   The
plan is to present a strategy to protect and maintain the ground-
water quality in the State by requiring components that:

1.  "Describe the state's  overall approach to protecting its
     ground water.

2.  Take into account existing  and  future beneficial  uses and
    existing ground-water quality.

3.  Identify existing authorities and programs to protect ground-
    water qua1ity.

4.  Propose legislative, administrative and economic mechanisms to
    protect ground-water quality.

5.  Review and make  recommendations on plans for development and
    administration of a  comprehensive ground water monitoring
    network, including point  of use, point  of  contamination and
    problem assessment monitoring sites  across  the state  and
    assessment of ambient  ground-water quality  utilizing, to the
    greatest extent  possible,  collection  and coordination of
    existing data sources, and

6.  Include programs to promote and assure public awareness of
    ground-water protection" (Idaho Code 39-120)

The plan was completed  by June  30,  1991.   A  series  of public
meetings and hearings were held during  the summer  and fall of 1991
to seek input in  finalizing the plan document.   The Council will
formally adopt the  plan and  submit it to  the  1992 legislature.
The legislature  will adopt,  amend, or  reject  the plan through
passage of  a statute.  After  action by the legislature, the plan
shall have  the force and effect of law.
B.  LEGISLATIVE AUTHORITIES

The Ground-Water  Quality Protection Act  of 1989  is  the primary
legislation for ground-water quality in Idaho.  In addition the

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Statutes  listed  below were  enacted  for other purposes  but  have
ground-water protection implications as well.

  Idaho Environmental Health and Protection Act

  Hazardous Waste Management Act of 1983

  Hazardous Waste Siting Act

  Public Records Act

  Injection Wells- Protection of Ground Water as a Public Resource

  Chemigation Law of 1989

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            I.   SETTING GOALS  AND  DOCUMENTING  PROGRESS


IA.  Ground-Water Protection Goal

The Ground-Water Quality Protection Act of 1989  (Senate Bill 1269)
will be  the foundation  for  the future of  Idaho's comprehensive
ground-water  protection  program.    Older  waste  disposal  and
injection well  statutes (Title 42, Chapter 39,  Idaho  Code)  also
declare the ground waters of  Idaho to be  a  public resource which
must   be  protected   against   unreasonable    contamination   or
deterioration of quality to preserve such waters for diversion to
beneficial uses. Much  rides on the reception the legislature gives
the proposed The Ground-Water Quality Plan next session.

The Idaho Ground-Water Quality  Protection Act of 1989  (GWQP)  has
it's general ground water goals and policies worded as follows:

     "The goal  of the  legislature  in  enacting the Ground-Water
  Quality Protection Act of 1989 shall  be to  maintain  the
  existing high quality of the  state's  ground water  and  to
  satisfy existing and projected future beneficial uses
  including drinking water, agricultural, industrial and
  aquacultural water supplies.  All ground  water shall be
  protected as  a  valuable public  resource  against unreasonable
  contamination or deterioration.   The quality of degraded
  ground water  shall  be restored  where feasible  and appropriate
  to support identified beneficial uses."

The purpose of the Ground-Water Quality Plan is to protect ground-
water quality  for use by the  public.   The  plan  also  provides
guidance and direction to state agencies,  local  governments  and
citizens in preventing ground water contamination.   This purpose
is to be accomplished  by fulfilling goals of the statute which are
listed in Table 1.

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          TABLE 1; GOALS AND REQUIREMENTS OF THE
             IDAHO GROUND-WATER PROTECTION ACT


Prevent contamination of ground water from point and non-point
sources to the maximum extent possible.


The discovery of  any contamination that poses  a threat to
existing or projected  future  beneficial uses  of ground water
shall require appropriate  actions  to prevent further
contamination.  These actions may  consist of investigation and
evaluation of enforcement actions,  if necessary, to stop further
contamination or  clean up existing contamination  as  required
under the Environmental Protection and Health Act.
All persons in the state should conduct their activities so as
to prevent the non-regulated release of contaminants into ground
water.
Education of the citizens of the state  is necessary to preserve
and restore ground-water quality.


Make public  the results of investigations concerning ground-
water quality subject to the restrictions contained in Section
39-120, Idaho Code  (Idaho Code  39-120)


Develop a  ground-water  monitoring plan concurrently with the
development of  a  ground-water  quality plan.   The ground-water
monitoring network will be  a dynamic ongoing program.


Establish a system or systems within state departments and
political subdivisions of the state for collecting, evaluating,
and disseminating ground-water  quality data and information.


Develop and maintain a natural  resource geographic information
system.  The system shall be accessible to the public.

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IB. Evaluation Mechanism

The membership of  the  Ground-Water Council,  currently developing
the Ground-Water Quality Protection Plan, is made up of 17 voting
members  and 5 ex-officio  nonvoting  members.    The Ground-Water
Quality Protection Act (GWQPA) specifies the various interests to
be represented on  the Council  including:  industry, agriculture,
mining, state government,  local government and the general public.
The Council is  to  exist  for up  to two years  after legislative
approval of the plan and will then be disbanded if not reauthorized
by the legislature.  During the two years after plan adoption, and
thereafter  if reauthorized, the Council is to oversee progress in
implementing the plan.

Current drafts of the plan present a wide variety of proposed state
policies   on  ground   water   protection   issues   along   with
recommendations  for  implementation that  are  based on  Council
consensus .  Once the legislature approves the plan by adopting it
as statute, the Council will likely prioritize the recommendations
and develop an implementation schedule.  During the  life of the
Council an annual report  is also required detailing the number and
concentration of contaminants   discovered  in  the ground-water
monitoring program mandated by the GWQPA.

The policies being  addressed in the latest draft  of the plan which
each have implementation recommendations include the following:

   The broad general ground-water policy
-  Existing and future beneficial uses
   Categorization of ground water
   Prevention of ground water contamination
   Public education on ground-water quality
   Ground-Water quality research
   Public participation in ground-water activities
   Local/State government interaction
   Local/State consistency
   Federal consistency
   Interstate/Interprovincial/Tribal agreements
   Artificial recharge of ground-water aquifers
   Statewide ground-water quality monitoring network
   Regional and local ground-water monitoring
   Publicly funded  ground-water data standards
   Idaho ground-water data information system
   Agricultural  chemical and nutrient management
   Mining
   Remediation
   Ground-water  quality standards
   Agency roles
   Liability for  remediation costs

It  is   likely   that  some   of  these  policies   will  include
recommendations  for new state legislation.

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1C.  Public Participation

Public Involvement

In  addition to  specifying the makeup  of the membership  of the
Ground-Water Council to  insure  representation by a broad range of
interests  in  development of the  plan,  the GWQPA mandates public
participation in plan development.  It states that the Departments
of Health and Welfare, Water Resources, and Agriculture should take
actions  necessary to  promote  and  assure public  confidence and
public awareness of ground-water  quality  protection.  In addition
the statute specifies that the plan include programs to promote and
assure public awareness  of  ground-water protection.

Upon  completion of the  plan,   the  GWQPA also requires  that the
Council publish notice after giving 20 days  notice as provided in
Section  60-109,  Idaho Code, in one or  more  newspapers  and shall
issue statewide  news  releases  announcing the availability of the
plan for inspection by interested persons. The announcement shall
indicate where  and  how the plan  may  be obtained or reviewed and
shall indicate that not  less than three public hearings shall be
conducted at various locations in  the state before formal adoption.
The  first  public hearing  shall  not  be  held until 45  days  have
elapsed from the date of the notice  announcing the availability of
the  plan.    After public  hearings  the  Council  shall  prepare  a
written summary of the comments received, provide comments on major
concerns raised, make amendments to the plan  as necessary and then
formally adopt the plan.

When state agencies develop or  revise any regulation their Legal
Services Divisions will publish public notice of proposed rules or
rule changes.  The location of  copies for review is specified and
a  copy  will be  mailed  for a  small  fee.    Written  comments  are
invited and the deadline for submitting comments is specified.


Public Outreach and Education

Idaho currently has  several ongoing outreach activities.  The Idaho
Department  of  Health  and  Welfare  (IDHW) publishes a  quarterly
newsletter entitled "Idaho Clean Water" which is widely distributed
and covers both ground and surface water issues and programs.  The
Idaho Department of Water Resources (IDWR)  publishes a quarterly
newsletter entitled "Injection  Well Quarterly"  which is aimed at
the user,  designer,  and planner  of underground  injection wells.
They  also  produce  a  document  entitled  "Idaho Currents"  which
provides information on energy and water news.  IDWR also received
demonstration  grant  funds under  a  national  competition for  a
program called Operation Outreach and they are developing public
information brochures on various  types  of injection wells.   IDWR
is pursuing  education of  the  water  well drilling  community by
organizing annual workshops and publishing a bi-annual newsletter
for licenced drillers.

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Idaho has initiated the  Idaho  Waste Reduction Assistance Program
(IWRAP)  under  federal  funding.   A waste  reduction  and recycling
clearing house has been established and a toll-free hot line made
available. IWRAP  has  also linked the public  with  regional waste
exchanges and  is networking with national  information exchange
services.  IDHW  has  also promoted waste  reduction  and recycling
with a Solid Waste Awareness Week and a three year public service
awareness campaign  called  "Let's  Talk  Trash".   The  three-R's
(reduce, reuse and recycle) have  also  been promoted within Idaho
schools.

During May 1990 IDHW's Hazardous Materials Bureau assisted Boise,
Ada County and Latah County in Household Hazardous Waste Collection
Day events in Boise and Moscow.   People  were polled on future years
with 46%  favoring annual  events and  42% supporting  them semi-
annual ly.

The GWQPA stresses public participation and awareness and current
drafts of the Ground-Water Quality Protection Plan contain policy
recommendations that  call for  expanded  efforts  in  a  number  of
areas.   While the  plan has not been adopted, these recommendations
will,  in all  likelihood,  be  retained   since  they  are  widely
supported.   One  key  recommendation is   for  establishment of  a
ground-water quality information clearing house.

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     II.  CHARACTERIZING THE RESOURCE AND PRIORITIZING ACTIONS

IIA. Resource Assessment

Aquifer Mapping

A  1981 report  entitled  "Ground-Water  Resources  of  Idaho" was
developed by  IDWR to identify and describe the major aquifers of
the state.  Because of the complex geologic makeup of the state,
it was not practical or possible to identify and describe each and
every  aquifer.    Seventy  major  ground-water  flow  systems  were
identified with  many comprising  more  than  one aquifer.   Several
major plates were developed at  scale of  1:1,000,000 depicting the
seventy  major   flow  systems,   the   general   lithologies  ,the
potentiometric contours and the  direction of ground-water movement.

Although seventy aquifers were identified, many  are  limited  in
extent and yield.   There are three major aquifer types in Idaho,
each depicted by their geology  as shown  in  Figure  1.

Unconsolidated  sedimentary aquifers  yield sufficient water for
domestic and  farming activities and are located in valley filled
regions of  the state.   Such aquifers in  northern  Idaho  are  of
glacial outwash  and recent alluvium with the principal one being
the  Spokane  Valley-Rathdrum Prairie  Aquifer.   This system  is
extremely productive with very  high transmissivities resulting in
low draw down in high-yielding wells.  Much  attention  is being
focused  on  protecting   this   aquifer   because   its   extreme
vulnerability to contamination.

The Snake  River Plain Aquifer  in southern Idaho  is composed  of
primarily  of  basalt  with sedimentary  interbeds.    It  is  the
principal  aquifer  in  the  state  and  one of  the  largest  in the
country- It discharges 6.5 million acre-feet annually to the Snake
River.  Smaller basalt aquifers in the Weiser  River Basin and the
Lewiston-Moscow area have much smaller yields,  but  provide most of
the domestic  water and significant agricultural water for their
regions.

Sedimentary and volcanic aquifers are found in the Boise Valley,
Mountain Home, Buhl and  Twin Falls.   They are composed of clay  ,
silt,  sand  and  gravel and interbedded volcanics  and are located
primarily in  the western  Snake Plain.  Such  aquifers may yield
significant geothermal water.

with the advent  of the new   computerized geographic  information
systems (CIS), environmental and natural resource agencies as well
local governments and others are  moving  into a new era in mapping
capability and coordination.   The Idaho Geographic Information
Advisory Committee  (IGIAC) was  created by Executive Order No. 88-
16  dated  June   26,  1988.    The  order  established  the  voting
membership of the committee as  members of state agencies with the
non-voting membership open to federal  agencies, industrial and

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FIGURE I. Principal Aquifers of Idaho
                   LEGEMQ
                     Valley-rilled Aquifer


                     BeMlt Aquifer


                     Sedimentary and Volcanic
                     Aquifer
              After USGS 1984. Graham and Camp-
              Dell 1901

              NOTE: All aquifer systems are
              comolex. containing a-variety of
              rock types.

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professional  organizations and academic institutions.  The  IGIAC
was created to:

     1.   Review new geographic information mapping and remote
          sensing technology applications which can be directed to
          the  states  interests;

     2.   Make recommendations to state and federal agencies
          regarding geographic information  systems,  mapping
          programs, and remote  sensing  specifications;

     3.  Assist in the preparation of requests to pertinent federal
          agencies as a  part of the diversified national mapping
          program;

     4.   Meet on at  least an annual basis to review geographic
          information programs carried on by  federal  and  state
          agencies and private industry, develop a  list  of
          priorities  with  regard  thereto, and  make
          recommendation with regard to possibilities  for
          cooperation and  resource sharing; and

     5.  Submit an annual  report  to the Governor of the committee's
          activities  subsequent to the  annual meeting.

The voting  members  of  the committee  include  the  Departments of
Transportation,  Water  Resources,   Fish   and  Game,   Parks  and
Recreation, Lands,  Health and Welfare, the State Tax Commission and
the Division  of  Financial Management.

The  IGIAC  established a  geographic  information  policy  and  a
standard  for  a geographic data base  in  1988.  These are contained
in Appendices A and B.    They emphasized that the increasingly
powerful  GIS  technology  has the  potential  to greatly increase
efficiency and reduce costs and is in a period of dynamic evolution
and growth.  Also GIS technology  is but one of  related technologies
(e.g.  remote  sensing and  digital cartography)  that can assist in
carrying out responsibilities more efficiently.  IGIAC established
that  it  is   imperative   that  strong  emphasis   be  placed  on
coordination   among  organizations   using  or   planning   these
technologies.

The 7.5-minute,  1:24,000  scale quadrangle map series has recently
been completed by USGS.  The IGIAC feels that  USGS needs to pursue
maintenance of  its  7.5-minute mapping  via  acquisition  of update
information  from appropriate agencies,  i.e., secure  hydrology
feature  update  from IDWR,  transportation  feature  update  from
transportation departments, etc.  They also have a number of other
recommendations  for  USGS  on  this  mapping   program which  are
highlighted in 1989  annual  report of IGIAC.

The small scale  1:1,000,000  maps are produced by the USGS and the
USFS and are used by nearly every agency in Idaho.  Typically they
are derived maps compiled from reduced  7.5-minute, 1:24,000  scale
                                11

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maps  and  the agencies reprinting them usually  perform an update
and add a theme such as ownership, recreation sites, etc.

Orthophoto quadrangles (OQ's) are primarily 1:24,000 scale photo-
image maps  formatted  to  cover the same area  as the standard 7.5
minute quadrangle  maps.   Other scales are used by some agencies
with some using a township format.

While OQ's were originally  conceived as  a temporary stand-in for
standard maps, they have  found  a  niche as a  replacement for high
altitude photo maps.   They have  been  adopted and are maintained as
a  base  by the   U.S.  Bureau  of Land Management  (BLM) ,  the U.S.
Forest Service  (USFS),  the  Idaho Department  of Lands,  IDWR, and
several large  corporations.  The USGS, BLM and the USFS have OQ
production equipment.  USGS  produces OQ's for other agencies and
maintains a  master to make  copies  for users while BLM and USFS
produce OQ's for  internal  use only.  IGIAC recommends that USGS and
USFS  formalize  and publicize  their  cooperative  arrangement for
production of OQ's and establish an aerial photography contract to
produce 1:80,000-scale photos where OQ's are needed.   They also
feel that USGS  needs  to  provide coordination for OQ  cooperative
projects on a local basis.

Many agencies  in  Idaho are performing digital  mapping and IGIAC
recommends that they continue to work closely together to develop
nonduplicative, multiuse  digital  data sets,   including  a graphic
coordinate database.   Agencies can use the digital map information
to make and recreate maps and perform GIS analysis for management
purposes.  One  example will be  discussed  in  the  next  section on
ground-water vulnerability mapping.   The users of GIS (the ARC/INFO
system  is  used by all)   are listed  in  Appendix  C and  this is
expected to expand rapidly.

With the  increased emphasis on mapping in Idaho and  the rapidly
expanding  GIS  capabilities,  aquifer mapping  for  ground-water
quality protection purposes can be refined and  enhanced.

Aquifer Vulnerability Mapping

Idaho has been the leader in EPA Region  10  for the past several
years in ground-water  vulnerability  mapping.   IDHW initiated the
project but it was a multi-agency effort  building on the combined
expertise of IDWR, USGS, IDHW and  the  U.S.  Soil Conservation
Service (SCS).  The purpose was to develop  and  demonstrate a method
to rate areas  within  the state for  their ground-water  pollution
potential. The project was  initiated on  a pilot project basis by
mapping the Lake Walcott  quadrangle  on a  1:100,000 scale.  After
this was successfully completed in 1988,  the mapping was extended
across the entire  Snake  River Plain  and  tributary valleys.  The
project is ongoing with the  intention of mapping the entire  state.

The results  of  the work  on  the Snake River  Plain were recently
summarized  in  a   report  entitled   "Ground   Water  Vulnerability
Assessment,  Snake River Plain Southern Idaho" dated April  1991.
The following four pages provide the  excerpted  Executive Summary.

                                12

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                         EXECUTIVE SUMMARY

 The Idaho Ground Water Vulnerability project was initiated by the
 Idaho Department of Health  and Welfare to rate areas  within the
 state for their  relative  ground water pollution potential.   The
 Idaho Department of  Health and  Welfare  (IDHW)  combined  their
 efforts  and  expertise  with the  Idaho Department of Water Resources
 (IDWR),  the U.S. Geological  Survey (USGS)  and the U.S.D.A.  Soil
 Conservation Service (SCS)  to develop the vulnerability maps.

 The project utilized  a  modified form of DRASTIC  (Aller et.  al.,
 1985)  which  was developed by the National Water Well Association
 under contract to the U.S. Environmental Protection Agency.   The
 DRASTIC  model evaluates the ground water pollution potential of  a
 given  hydrogeologic   setting  based   on   a   set  of   defined
 characteristics,  along with ratings or "weights" assigned to those
 characteristics.  This project utilized three layers which resemble
 those used by DRASTIC  (depth-to-water, soils, and  recharge),  but
 differ greatly from DRASTIC in that they used different  sources of
 information,  a finer scale, and a different point  rating  scheme.
 The project used a Geographic Information System (GIS), which gives
 the ability for enhanced data analysis and integration capabilities
 over  the standard cartographic techniques used by  DRASTIC.

 1)    Description  of  Data Layers

      a)    Depth-to-water Layer

      The depth-to-water  layer was developed by the  U.S.  Geological
      Survey  (Maupin,  in press-a; Maupin, in press-b).  Depth-to-
      water is important for susceptibility assessment because areas
      where the ground water is close to the surface typically have
      a higher probability  of ground water  pollution  than  areas
      where ground  water  is  quite deep.    A  computer   program
      (Universal   Kriging)   was  used  to   generate   a   surface
      representing first-encountered ground water below land  surface
      from measured  water levels.  The  depth-to-water  values  were
      generated by  subtracting  land-surface  altitudes  from  the
      KRIGED  water-level surface using  a  simple FORTRAN program.
      The  depth-to-water map  was then contoured and  broken  into
      categories,  with  each category rated on a  scale  of 1 to 50
      points  to reflect its relative significance to ground  water
      vulnerability.  The following  ratings were used:

           Depth-to-water Ranges        Rating  (points)

           1 to 25 feet                       50
           26 to 50 feet                      35
           51 to 100 feet                    20
           101  to  250 feet                    10
           > 250 feet                         1

Note:ThisExecutive  Summary  was excerpted from a report entitled
"Ground Water Vulnerability Assessment Snake River Plain, Southern
Idaho
                                13

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b)   Recharge Layer

The  "recharge"  component of the  Ground  Water Vulnerability
Model  was  developed  by  the  Idaho  Department  of  Water
Resources.  This  layer  represents water  that penetrates the
ground surface and percolates to the water table, potentially
carrying contaminants with it.

The  "recharge"  map combined three data  sets  or layers that
indicate  types  of  land cover.    The  first  layer outlines
irrigated and dry  cropland.  The second layer differentiates
between  sprinkler-   and  gravity-fed   irrigation  delivery
systems.  The  third layer subdivides  land  cover types into
five categories representing rangelands,  agricultural lands,
forests,  lava  flows, and  riparian areas.    Each resulting
recharge class was given the following point rating to be used
in determining relative vulnerability:

     Recharge Classes                   Rating  (points)

     Gravity-fed irrigated land              50
     Riparian areas                          50
     Sprinkler-fed irrigated land            40
     Forests                                 30
     Dryland agriculture                     20
     Rangeland                               20
     Bare rock  (lava flows)                  10
     Urban areas                             No rating
     Surface water                           No rating

c)   Soils Layer

The  soils  layer  incorporated the  State  Soil  Geographic
Database (STATSGO)  and SOILS-5 databases developed by the SCS.
Four soil-landscape characteristics were chosen to be included
in   the    soils    layer.    These  characteristics are:  1)
permeability of the most restrictive layer; 2) depth-to-water
table within the  soil horizon; 3) depth to  bedrock;  and 4)
flooding frequency.  Each characteristic  was rated to reflect
its relative significance to ground water  susceptibility.  The
ranges of possible scores for the soils layer are as follows:

     Soil Characteristics          Rating (points)

     1)  permeability                    2 to 20
     2)  depth to bedrock                1 to 10
     3)  depth to water-table            0 or 8
     4)  flooding frequency              0 to 5

          Total                         2 to 43
                           14

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     The score for each soil unit was then multiplied by three to
     determine the final soils vulnerability rating.  This was done
     because the  soils  layer  incorporates more than one criteria
     relevant to ground water vulnerability assessment, and hence
     deserves more weighing than the other two layers.

2)   Vulnerability Map

     The Ground Water Vulnerability map (Figure 2) was generated
     by  merging   the  three   characteristics  (depth-to-water,
     recharge, and soils)  into one map using  computer  mapping
     (Geographic Information System) techniques.  The point ratings
     from each layer  were added to  create  a  total vulnerability
     rating.

     The final vulnerability map was broken into four categories
     of relative vulnerability;  low, moderate,  high, and very high.
     The division points  for  these categories  were  derived  by
     graphing  the  relationship  of  total  acres  versus  total
     vulnerability factor.   The resulting distribution is 30% =
     low,  30% =  moderate,  30% =  high,  and  10%  = very  high
     vulnerability (Figure 8).   These  divisions will be refined
     in the near  future by comparing the vulnerability maps with
     ground water monitoring data, and then adjusting the divisions
     to  correlate  with the monitoring  data in  a  statistically-
     valid fashion.

3)   Uses of Vulnerability Maps

     The vulnerability maps are designed to serve  as  a tool for
     prioritizing ground  water  management activities.  Areas  of
     higher vulnerability can  be given higher priority for prudent
     ground water protection measures and study in  order to assure
     that  limited resources  are  effectively  used  in areas  of
     greatest concern.  Because of  the  scale  of mapping that was
     incorporated in the development of  these maps, they should be
     used for regional program planning purposes only, and should
     not be  used for making  site  specific  decisions.  This  is
     because  there   could  be  smaller  areas   of   very  high
     vulnerability within generalized areas of low vulnerability,
     and vice versa.  Programs which can  utilize vulnerability maps
     include leaking  underground  storage tanks  (LUST),  wellhead
     protection,  ground water monitoring,  public water supplies,
     agricultural  chemicals,   waste   water  management,   best
     management practice   (BMP)  implementation  and development,
     hazardous and solid waste management,   state  and  federal
     superfund programs,  land use planning, State underground tank
     insurance agencies, and public information.  The maps may also
     be useful in establishing "Areas of Drilling Concern" within
     the regulatory programs of IDWR.
                                15

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Ground-Water Standards and Aquifer Classification

As discussed in the introduction, proposed ground-water standards
that  included  an  aquifer classification  system went  to public
hearing in late 1987.  Legislators became interested and  asked IDHW
to put them on  hold while they drafted and introduced the Ground
Water Quality Protection  Act  of  1989.   With passage  of the bill,
the Ground  Water Council was  directed to focus on  the need for
ground-water standards  and the Board  of  Health  was  empowered to
adopt such standards for contaminants  for which EPA had developed
maximum contaminant levels.  The current draft of the Ground Water
Quality  Plan  recommends  that standards  be adopted  including  a
system of categories of aquifers.  The categorization is proposed
to be based on  vulnerability,  existing  and future beneficial uses,
existing quality  and  social and economic considerations.   Three
categories have been suggested.

As proposed  IDHW, IDWR and  the Idaho  Department  of Agriculture
(IDA) would propose initial categories  for the major use aquifers.
Initial categories would be adopted by  rule by the Board of Health
after opportunity for public comment. Regulations are proposed for
changing the category of an aquifer or for proposing a category for
an uncategorized  aquifer.   The  burden of proof would  be on the
petitioner and  any changes would require full public participation.
Different  management  strategies  would  be necessary  for  each
category of aquifer.

The ground-water  standards would consist  of a  two part approach
with a preventative portion based on increasing trends rather than
fixed percentages as was proposed in 1987.  The enforcement portion
would  automatically kick in  when  an MCL  was exceeded.    The
standards would establish aquifer  protection permits to manage a
localized source  when  voluntary  efforts  prove  inappropriate or
ineffective.

Wellhead Protection Area Delineation

Idaho is currently in the process of developing the framework for
their wellhead  protection program.   A technical advisory committee
has been formed which will address the state's approach to wellhead
area delineation.   A policy advisory committee has also been formed
to provide direction in development of the overall program.   The
Idaho wellhead  protection program will likely embrace a voluntary
approach for local programs so delineation techniques  will probably
provide a list  of  options.  A draft wellhead protection plan is due
to EPA in the spring of 1992.


Sole Source Aquifer Designation

Two sole source aquifer designations have been made  by EPA  in Idaho
and a third  is  expected  during the  fall of 1991.  Those  designated
include  the Spokane  Valley-Rathdrum   Prairie   Aquifer  and  the
Lewiston Basin  Aquifer.    Both are interstate  aquifers with the
designations extending across  the Washington border. The former was

                                16

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                                                 FIGURE  2
                            Relative  Qrounawater  Vulnerability  :  Idaho  Snake River'Plain
                                   Vulnerability  Ratings
                                        I   I Unclassified
                                            Low
                                            Moderate
                                            High
                                            Very  High
                                 A cooperative  project between:
                                 Idaho Dept. of Health & Welfare
                                 Idaho Dept. of Water  Resources
                                 USDA Soil  Conservation Service
                                 United States Geological Survey
                                                                                                                           :1,500,000

                                                                                                                          0   20KM   20UI
                                                                                                                            Edilian
                                                                                                                            Uoich 1991
igur«a  Rilatiu Groundtatir Vulntrabllll|r mop, Snoki Ri»er Plain, Idaho
his mop confalm g.nwolU.d data - tor more d.loll rtfir to thi 1:500,000 scoli mop.

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the  second designation  in the  country  and  was  made  in  1978.
Protection of this aquifer has received a great deal of attention
and the  special  funding   provided by Congress  will  be discussed
later.  The latter was designated in 1988 and includes Tribal lands
administered by the Nez Pierce Tribe.

Designation of the Snake  River Plain  Aquifer in southern Idaho has
been pending for a number  of  years with the  boundaries extending
into Wyoming, Utah and Nevada as well.   This is  one  of  the most
productive aquifers in the world and designation  should  occur in
the fall of 1991.  Over 9000 square miles will be included in the
designation.

Sole  source designation  has   been  used creatively  in  Idaho  in
protecting the ground  water resource especially  for  the Spokane
Valley-Rathdrum Prairie  Aquifer.  Projects proposed  for Federal
financial  assistance have frequently  been   modified to  better
address  ground-water protection concerns because the  required
review by EPA. The cooperation and assistance  of State and local
agencies  in the  review  process has also been  instrumental  in
factoring in ground-water protection concerns.

Ground-Water Quality Assessments

In  1979  the USGS identified  the need for a  dedicated statewide
ground-water monitoring program involving that agency and IDHW and
IDWR to address trends and identify contamination.  This continuing
need was also recognized  in the original  1983 ground-water quality
management  plan  and the  1985  update  and   was   included  as  a
recommendation  for  implementation.     Lack   of   funding  was  an
impediment and most monitoring was small scale and mostly done in
areas of known or suspected contamination.

With the passage of the 1989 GWQPA the legislature recognized the
need  for  long  term monitoring  by  mandating  development  of  a
comprehensive ground-water monitoring network.  This is to include
point of use monitoring, point of contamination monitoring, problem
assessment monitoring and  assessment of the  ambient ground-water
quality.  The ambient monitoring  network is managed by  IDWR and the
initial wells were selected and sampled in 1990.  This was expanded
to a 400 well network in  1991.  The final network may include as
many as 1500 - 2000 wells.  The regional  and local  monitoring is to
be administered by IDHW but to date has  gone unfunded.  A specific
monitoring plan is being developed by a sub-committee of the Ground
Water Council and will  constitute part of the  overall Ground Water
Quality Plan called  for  in the  GWQPA.   The monitoring plan will
address ambient monitoring, regional problem  monitoring  and site
specific problem monitoring.   An annual monitoring plan  is to be
prepared along with  an  annual report  on  results which  will be
available to the public.

The small scale localized sampling programs have detected  a variety
of contaminants including nitrates, bacteria,  petroleum products,
pesticides, etc.   Groups  other than State and  Federal  agencies are
also becoming interested  in monitoring.   In 1990 and again in  1991

                                18

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The  Farm  Bureau  worked  with  farmers  and   State  agencies  in
conducting a  fairly extensive sampling program where well owners
provided  samples for  analysis.   Although  the results  were not
alarming, pesticides  were detected  and high nitrates reconfirmed
as a problem  in  some wells.

State Programs and  the OSGS

The State programs and USGS have a long history of working together
on cooperative projects  on a variety of ground-water issues.  As
discussed  previously, the IGIAC group  relies  heavily  on  USGS
products and  USGS  serves as a nonvoting member.   In recent years
USGS  has also  served as  an active member  on the  ground water
vulnerability task  force and was a  key participant in developing
one of the GIS data layers for the maps.

The USGS started the Regional Aquifer-System Analysis program in
1978  prompted by the  1977 drought.   The purpose was  to define
regional  hydrology and  geology to  establish  a  framework  of
background information on geology,  hydrology and geochemistry of
the  important aquifer  systems  in  the U.S..   Several  of these
detailed studies were carried out within Idaho's borders with major
effort being  the Snake River  Plain Aquifer.  This work provided a
great deal of new data on ground water in these areas of the state.

The National  Water-Quality Assessment  (NAWQA)  Program is a manor
new USGS effort  designed to describe the  status and trends in the
quality of the Nation's  ground and  surface water resources.   The
Administration decided that USGS should begin with implementation
in  1991 after   an  earlier pilot  project and followed  up  with
substantial funding.  Sixty study units throughout the country will
be extensively analyzed over a period extending to 2002.  The Upper
Snake  River  Plain  in Idaho  will be one of  the  first 20 to be
initiated and intensively studied.   This program  should aid the
state  considerably  in implementing  their ground-water protection
program.
                                19

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IIB.  CONTAMINATION SOURCE IDENTIFICATION

The current draft  of  the Ground Water Quality Plan  recognizes a
variety of both point and  non-point  sources  of  contamination and
references the list in the Office of Technology Assessment's 1984
report.  Table 2 provides this  listing.  Idaho has done a priority
ranking  of  major  sources  which will  be discussed  in the  next
section on priority setting.

A  number of  ground water contamination  sources are  currently
regulated by state and  federal  agencies.   The following provides
a brief  summary of information on each source type.   Additional
discussion  on  the  status and  direction of  these programs  are
provided in Chapter III.

Underground Storage Tanks

Idaho feels they need enabling legislation to receive delegation
from  EPA for  the  underground storage  tank program.    Current
information shows that approximately 3200 nonexempt tank sites have
been registered in Idaho.   The state estimates  approximately 30%
of the nonexempt population are unregistered which would bring the
total to about  4600.  Furthermore, they estimate that between 1900-
2400 contaminated  sites exist  and that between  300-600  of these
sites have ground water contamination.

Solid Waste Landfills

There are an estimated  140 landfills in Idaho that  are  not well
regulated from a  ground-water  protection standpoint  because the
regulations date back to 1973.

Hazardous Waste Facilities

There are currently 976 Idaho  businesses and government agencies
that are known to generate, treat, store, transport or dispose of
hazardous waste.   Five  hazardous waste  facilities are permitted
including three post  closure permits, one storage and treatment
permit,  and one  storage,treatment  and  disposal permit.    The
disposal permit is for  a major state- of-the- art facility where
the vast majority of the wastes come from out of state.

Underground Injection Control Wells

IDWR has received primacy  from EPA  to administer the Underground
Injection Control (UIC)  Program.  Class V wells are the only type
allowed in Idaho and an estimated 4500-5000 exist.  Shallow wells
(under 18 feet) pose a threat to ground-water quality in Idaho as
their number and uses  are not well understood.  There  is reason to
believe that numerous  automobile service  stations are utilizing
this practice.

Improperly constructed wells drilled near areas high  risk or known
contamination provide the opportunity for increased vertical


                                20

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Taole
                   Potential  Sources  of  Ground Water  Contamination
CATEGORY I - Sources designed to discharge
       substances:

Subsurface percolation (e.g., septic tanks and
       cesspoo/sJ
Injection  Wells
       Hazardous  waste
       Non-hazardous  waste   (e.g.,   brine
       disposal and drainage)
Non-waste (e.g., enhanced recovery, artificial
       recovery, solution mining and in-situ
       mining)
Land Application
       Waste Water (e.g., spray irrigation)
       Wastewater byproducts (e.g., sludge)
       Hazardous  waste
       Non-hazardous waste

CATEGORY II - Sources designed  to  store,
       treat, and/or dispose of substances;
       discharge through unplanned release:

Landfills
       Industrial hazardous waste
       Industrial non-hazardous waste
       Municipal Sanitary
Open dumps, including illegal dumping (waste)
Residential (or local) disposal (waste)
Surface Impoundments
       Hazardous  waste
       Non-hazardous waste
Waste tailings
Waste piles
       Hazardous  waste
       Non-hazardous waste
Materials stockpiles (non-waste)
Graveyards
An/mat burial
Aboveground storage tanks
       Hazardous  waste
       Non-hazardous waste
       Non-waste
Underground storage  tanks
       Hazardous  waste
       Non-hazardous waste
       Non-waste
Containers
       Hazardous  waste
       Non-hazardous waste
       Non-waste
Open burning sites
Detonation sites
Radioactive disposal sites
                                          CATEGORY  III - Sources designed  to  retain
                                                 substances   during    transport   or
                                                 transmission:

                                          Pipelines
                                                 Hazardous waste
                                                 Non-hazardous waste
                                                 Non-waste
                                          Materials transport and transfer operations
                                                 Hazardous waste
                                                 Non-hazardous waste
                                                 Non-waste
                                          CATEGORY  IV   •   Sources  discharging
                                                 substances as a consequence of other
                                                 planned activities:

                                          Irrigation practices (e.g., return flow)
                                          Pesticide applications
                                          Fertilizer applications
                                          Animal feeding  operations
                                          De-icing salts applications
                                          Urban runoff
                                          Percolation of atmospheric pollutants
                                          Mining and mine drainage
                                                 Surface related mining
                                                 Underground mine-related
                                           CATEGORY V - Sources providing conduit or
                                                  inducing discharge through altered flow
                                                  patterns:

                                           Production wells
                                                  Oil (and gas) wells
                                                  Geothermal and heat recovery wells
                                                  Water supply wells
                                           Other wells (non-waste)
                                                  Monitoring wells
                                                  Exploration wells
                                           Construction excavation
                                           CATEGORY  VI -  Naturally  occurring sources
                                                  whose discharge is created  and or
                                                  exacerbated by human  activity:

                                           Ground water - surface water interactions
                                           Natural leaching
                                           Salt-water intrusion/brackish water upconing
                                                   (or  intrusion  of  other- poor-quality
                                                   natural water)
                         (from Office of Technology Assessment,  1984)
                                         21

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movement and  spread of contaminants to  otherwise uncontaminated
aquifers.  IDWR is exercising its authorities to establish "Areas
of Drilling Concern."

Land Spreading operations

Approximately 100  land  application  permits  have been issued over
the past several years under a new land application permit program
that was initiated in 1988.   These permits regulate the conditions
for  land  application  of  municipal and industrial  wastewater.
Dairies and confined animal feeding operations are exempt from land
application permit requirements.
                                22

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     lie.  SETTING PRIORITIES

In  1979 the  USGS prioritized  Idaho's  aquifers based  upon the
sources of potential pollution, population, and  ground water use.
This assessment  was  based on hydrologic  units  which are surface
features that  describe general recharge  areas  for  aquifers.   By
applying such  a  rating system directly  to major aquifers,  their
potential  for pollution  can be  determined.     The  eleven  major
aquifers  were ranked  in priority  order  in  terms  of  pollution
potential  in  Figure  3.    The  areas  of  highest   priority  for
protection such as the  Boise, Snake Plain and Rathdrum Prairie have
begun  to  receive the  most  attention  for vulnerability mapping,
aquifer protection plans and other protection activities.

Most known and potential sources of ground-water  contamination have
been  ranked  in  Idaho.     IDHW   ranked   potential   contamination
utilizing two  factors.  The first related to  the adequacy of the
present regulatory program  for a  particular land use practice or
contamination  source with unregulated or unmonitored activities
placed highest.  The second factor was the relative  public health
or  environmental  risk  posed by the potential  contamination.
Activities which  can produce  contaminants of  high toxicity which
are typically found in  areas of high population density were ranked
highest.   The two  factors,  regulatory   program development and
relative risk, were ranked on a scale of 1-3 and  combined using the
formula in Table 3.   Idaho considers Table 3 to present the ranking
of potential sources  of ground-water contamination in the state and
plans to place most  emphasis accordingly-

Combined with  the above  list  of  ranked sources, the ground-water
vulnerability maps described previously  will  serve  as a valuable
tool  for  prioritizing ground  water  management and  protection
activities.  Areas of  higher  vulnerability can be given priority
for  the limited  resources  available  for protection activities,
special studies,  and monitoring  programs.  Because  of  the scale
used in development  of the maps,  they  should be  used for regional
program planning  purposes only and not  for making  site specific
decisions.  There  can  be  areas of very high vulnerability within
generalized areas  of low  vulnerability and vice versa.   Programs
which  should  find the maps  useful  include  underground storage
tanks,  management  of agricultural chemicals,  hazardous and solid
waste  management, wellhead protection,   wastewater management,
ground-water monitoring, public water  supply management, nonpoint
source  best  management  practices  (BMP)  application,  remedial
action, underground  storage tank  insurance considerations,  etc.


The  Ground  Water Quality Plan mandated  by the legislature will
include a series  of  ground  water  policy  statements  for the  state
each  having a list  of recommendations for implementation.  Once
the  legislature  adopts the plan,  the Ground Water  Council will
likely prioritize the recommendations and develop a implementation
schedule.
                                23

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Pollution Pottntlal Rating of SOOM Major Aojitftri

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                                    Table:3'
      Priority Ranking and Rating of Potential Sources of Groundwater
                                 Contamination
                                                	Factor	
Priority    Potential Source of Contamination       Regulatory       Risk     Score2
1
2


3
4
5
6
6
6
6
7
8
9
10
11
Petroleum handling and storage
Feedlots and dairies

landfills and hazardous waste sites
Land application of wastewater
Hazardous material handling
Pesticide handling and use
Land spreading of septage and sludge
Surface runoff
Pits, ponds and lagoons
Radioactive substances
Fertilizer application
Septic tank systems
Mining. Including oil & gas drilling
Wells: injection, geothermal , domestic
Silvicultural activities
2.9
2.8
A /%
2.0
ZS
1.5
2.3
2.3
2.0
2.3
Z3
1.5
1.8
1.5
1.7
1.5
3.0
2.0
*> a
£.0
2.3
3.0
2.3
2.0
Z3
ZO
ZO
2.3
ZO
ZO
1.8
1.8
295
243
O^T
^4.5
240
237
225
215
215
215
215
194
191
177
175
150
'Modified from  Tedwiicil Report for the Snak« Plain Aquifer (IOHW 1985) and Environmental and
Energy Study Institute (1995)

2Total Score is determined by the formula:
                     ToUl Score «   / Regulatory2 + Risk2   x 100
                                        2

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IID.  DATA MANAGEMENT, MONITORING, AND RESEARCH

Legislative  mandates  in  the  GWQPA  of  1989  require  that  a
comprehensive ground water monitoring network be developed, a CIS
data  management system  be  developed and  maintained and  that a
ground-water quality data management program be established.

Data Management

The GWQPA clearly recognizes the need for a comprehensive ground-
water quality data management system to meet the needs and handle
the information  for  multiple state and local  agencies.   IDWR is
currently coordinating  this  project and receives  much  input and
assistance from IDHW and IDA as well as others.  These agencies had
previously developed data systems to meet some of their own needs
and this new initiative will  build upon past work while developing
new  capabilities to meet  more  of the  identified  needs.    In
developing the system, the state intends to have it encompass the
scope of ground water minimum data set developed nationally by EPA
in coordination  with others  and meet other broader state needs.
The GWQPA establishes that  the data system be accessible to the
public and they intend to meet this requirement by allowing others
to access and read the information but not have the capability to
manipulate it.

To date IDWR has been working on the development of  user and system
requirements.  This will be completed so that any computer hardware
or  software  acquired  will  be  adequate  to  meet  everybody's
objectives.   Data processing staff have been hired.  A consultant
is to be responsible for developing,  installing, and modifying the
computer software necessary to satisfy all user needs.  It  is hoped
that a prototype information system will be available by late 1991.
Initial input data from primary sources has been requested.

The  draft  Ground  Water  Quality  Plan  now  undergoing  public
participation  contains  two proposed  policies related  to ground
water monitoring data issues.    The first states that all publicly
funded  ground-water  quality  monitoring  and   data  gathering
activities will be consistent with the ground-water  monitoring plan
which is part of  the overall  Ground Water  Quality Plan.   This is
to encourage that all public  entities submit data in an electronic
format to be easily  incorporated  into  the data  system  and that
appropriate  quality  assurance  and  quality  control   (QA/QC)
guidelines be followed.   The  second policy  relates  to the  need  for
the data management  system to include data  from past, present,  and
future  ground-water  quality  monitoring  and  that  it  all  be
accessible to the general public.

In  implementing  this policy,   state  agencies will  maintain an
effort to  coordinate with  all  public  and private ground-water
quality  data  collection programs.   A   technical  data review
committee will be established to classify all  data  as to its level
of confidence,  utility,  and limitations it may have. The committee
will make use of the data management system's  capability  to


                                26

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evaluate data confidence and record results of the review process.
A  data  certification  procedure  is  also  proposed whereby  the
supplying organization would certify that the data is free of data
entry errors.

Well Drillers  Reports have historically been maintained by IDWR.
These reports are prepared and  submitted by the driller as required
by Idaho statute.   The drillers report is an important and often
sole source of subsurface  information on aquifer lithology, water
levels, and well design. Currently these reports are on microfiche
and are  extensively utilized  by government  and  the public.   The
microfiche  is  organized by  legal  survey description and  has  no
search, sort, and retrieval mechanism thereby reducing this systems
usefulness  for subsurface  research.    The  IDWR is studying  the
implementation  of a  digital  imaging system where  these reports
would be stored in an optical  disk and would be available as  an
indexed image to government and the public via computer link.  IDWR
has secured partial funding and is reviewing equipment and software
options.   The  new system  could make  the current 60,000 drillers
report archive more useful  and  help IDWR process approximately 2500
new reports received  annually.

The GWQPA  also  required that a natural resource CIS be developed
and maintained  which will be  accessible to  the  public.   For  the
past several  years IDWR has been  the lead  for  GIS and has been
instrumental in development of  the ground-water vulnerability maps.
This will continue and other agencies such as IDHW and will obtain
GIS workstations and  have  access to the database.

Monitoring

The  GWQPA  mandated  that  a  comprehensive  ground-water  quality
network be  established and that ambient, point  of  use, point  of
contamination and problem  assessment monitoring be addressed.   As
part   of the  Ground Water Quality  Plan being  developed  by  the
Ground Water Council  a proposed overall monitoring  plan has been
developed specifying roles, responsibilities, etc. It is envisioned
that each year an annual monitoring plan for that particular year
covering   items   such  as   sampling  objectives,  probable  site
locations,  QA/QC, sampling constituents and  estimated costs.

IDWR is to have responsibility for  ambient monitoring and IDHW for
local and regional monitoring.   Funding for the ambient program has
been provided  but to date the local  and regional monitoring has
gone unfunded.   Table  4 provides a  comparison of the types  of
monitoring that  are to be  done by each agency.  IDWR  worked  in
cooperation with  USGS in sampling 97 wells  during  the  summer_of
1990.   Selection of the well sites was  coordinated with  existing
monitoring  programs  to  reflect as  many different locations  as
possible throughout  the  state.   An analysis  for  more  than  70
potential   contaminants  was   performed  for    all   the  wells.
Preliminary results show positive detection for at least  one of the
potential  contaminants at  approximately 20 percent  of  all  the
sampled sites.   The network and sampling have been significantly
expanded in 1991 to a minimum  of 400 sites.  A proposed  minimum

                                27

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                    Area of
                   Monitoring
                      Monitoring
                       Duration
                     Types of Questions
                     Monitoring Will Answer
                                    Lead
                                   Agency
Ambient
Monitoring
   Statewide
     Long  term,
     ongoing
What is general statewide ground
water quality?  What are the
trends over time?  Are there
problem areas that need more
detailed monitoring?  What are
background levels?  Is ground
water generally suitable for
drinking, agricultural, and
industrial purposes?
                                                                                        IDWR
Problem
Monitoring

 A. Regional
    Monitoring
Areas of  high
vulnerability,
10-250 square
miles
Typically 1-5
years per area
What is ground water quality in
areas of highest vulnerability?
How much variability is there in
ground water quality in these
areas?  How widespread are the
problems?  What needs to be
addressed by applying BMP's?  How
effective are the BMP's?
                                                       IDHW

                                                           I
 B.  fiite-
    flpecific
    Monitoring
Areas of
contamination
incidents, less
than 10 square
miles
Typically 1-5
years per site
(except where
duration specified
by state or
federal statute)
Are there point-source impacts
such as leaking underground
tanks, chemical spill, or
landfill?  Once the area is
identified and problem isolated
is the management plan working to
rectify the problem?  Are addi-
tional studies needed?
IDHW
 Table ^.  Comparison .of the three parts of the Ground Water Quality Monitoring Program

-------
monitoring of 375 wells annually was proposed and approved by the
Ground Water Council.   Hopefully annual funding will be provided
so  that  the  monitoring  can  begin to provide  data  for  trend
analysis.

Over  past  years many ground-water  quality  studies  have  been
conducted  by  various  state and  federal  agencies mostly  in the
vicinity of known or suspected sites of contamination.  Also public
water supply wells  are required by law  to be routinely monitored.
In spite of these previous efforts the ability to describe existing
statewide  ground-water quality is still extremely  limited.   The
limitations on existing ground-water quality information are:

     - Data from all monitoring efforts  are not stored in a central
       database  so  that much information is not readily useable
       in making assessments of ambient quality.

     - There are variations in  sampling and analytical methods
       between collecting agencies making data  potentially
       incomparable.

     - The period of record is generally short  (the same wells are
       not revisited)  and the frequency of analysis is inadequate
       to  identify  trends over time.

     - Interpretation of long term trends is very difficult because
       cyclic seasonal variations in ground water quality are
       poorly understood.

     - Evaluation of potential  ground-water impacts from point
       sources is sometimes difficult because existing monitoring
       and/or water supply wells are not always  optimally cited or
       constructed.

     - Non-point source monitoring is  rarely done because of the
       costs involved  for large well networks.

     - Interpretation  of variations in ground-water quality with
       depth are difficult because wells are often open  to several
       aquifers.

     - Improperly designed  monitoring  systems  often do not allow
       determination of the specific source of  contamination that
       is detected.

     - Sampling  programs do not always  provide  for analysis of  all
       the potential contaminants of concern.

Although  the mandates in the GWQPA  for statewide monitoring  and
data  management systems   will   help   alleviate  some  of   these
shortcomings, some  will  continue  to remain  issues to  deal with.
                                29

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Quality Assurance

The draft  monitoring plan proposed for the  statewide monitoring
plan clearly recognizes the need  for  QA/QC.   The plan contains a
section on  sample  collection  and  laboratory  practices indicating
specific QA/QC  plans will  be prepared for  each  sampling event
modeled after procedures established by EPA.   A QA/QC coordinator
has recently been  hired  by  Bureau  of  Laboratories to  develop
laboratory  wide  procedures.   The  laboratory will be  asking for
sampling plans in  advance of  sampling events.   The annual review
planned for the monitoring program will focus the status of issues
including QA/QC.

The IDA will soon be completing a new two million dollar laboratory
which will greatly enhance the capability for sampling analysis.

Research

Much ground-water research is done at the University of Idaho and
the Idaho Geological Survey  (IGS) maintains close affiliation with
the school.   Publications  and  maps  are  available from  the IGS
office  in  Moscow,  Idaho.   The draft Ground Water  Quality Plan
contains a  research  policy  proposing  ongoing research to protect
ground-water quality.  The recommendations for implementation are
that the Universities have the lead, that research be of an applied
nature  designed  to  allow  a better understanding  of  factors
affecting  quality,  that  the  research involve  local, state and
federal agencies as well as interested private entities,  and that
the Universities consult with  the  above to determine high priority
ground-water research needs.
                                30

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III.  DEVELOPING AND IMPLEMENTING PREVENTION AND CONTROL PROGRAMS

IIIA.  SOURCE ELIMINATION

Idaho Waste Reduction Assistance
Idaho has  initiated  the  Idaho Waste Reduction Assistance Program
(IWRAP) under  federal funding.  A  waste  reduction and recycling
clearinghouse has  been established  and a  toll-free hot line made
available.  IWRAP  has also linked the  public  with regional waste
exchanges  and  is  networking with  national  information exchange
services.   IDHW has also promoted  waste  reduction and recycling
with a Solid Waste Awareness Week and  a three year public service
awareness  campaign  called  "Let's  Talk Trash".    The three-R's
(reduce, reuse  and recycle)  have also been promoted within Idaho
schools.

Agricultural Pollution Abatement Plan

Idaho  has  long been  recognized  as  a  leader  in non-point source
agricultural pollution  abatement activities.    While  most of the
emphasis has  been placed on surface water issues, the need for
coordinated surface water /ground-water approach is beginning to be
recognized.  The program began in 1976 when the Soil Conservation
Commission  (SCC)   initiated  development  of  the  Agricultural
Pollution  Abatement Plan  (APAP) .   The APAP  development process
spanned three years and involved extensive public interaction.  The
APAP basically  calls  for replacing  management practices impacting
water quality with best management practices (BMP's) that minimize
such  impacts.   Funding  from  the  state's  Water Pollution Control
Account  has been  made  available annually  to  fund demonstration
projects  for BMP's.  Table 5 provides  a list of some of these
projects that  relate to  ground water that have been funded under
this program as well as other ground-water projects that have been
funded  from other sources such  as  CWA 319, the President's USDA
Clean Water Initiative Program,  etc.

The BMP development process in Idaho is a multi-agency effort that
involves a systematic approach.   To evaluate  BMP's and the degree
they  are implemented the APAP established the Idaho  State Water
Quality  Feed Back Loop Process.   The process  was  contained  in the
APAP  when  it   was certified  by the  Governor in 1979  and was
officially  incorporated  into  the  Idaho  State  Water   Quality
Standards  in 1987.   An integrated system  of BMP's are approved  by
the  state, implemented  on  a  site   specific  basis and  evaluated
through monitoring and modified as  needed to achieve water quality
standards.   The  SCC  and its  Districts are recognized to be the
principal  local agency for  implementing and coordinating soil and
water  quality  programs  in  their respective districts  and as so
assume  a  leadership  role in  BMP  implementation.   Each  District
?ollSws  the Field Office Technical  Guide in each SCS Field Office
which  contains  the standards  and specifications for soil and water
conservation practices.
                                 31

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  SUMMAMY Of IDAHO AQracULI/TRAL PROGRAMS AND PBOJECTS

  OCTOBER 1991
  rnOJECT TITLE
                                                                                                                    LEAD AGENCIES
                                                                                                                                                                 OOOPERATORS
  SNAKE RIVER
  DEMONSTRATION
  PROJECT

  USDA PRESIDENTIAL
  INITITIVE PROJECT
DEMONSTRATE GROUND WATER BEST
MANAGEMENT PRACTICES TO GAIN
ON FARM ACCEPTANCE AND ADOPTION
6 YEAR PROJECT
BEGINS 1/91
DESIGN, DEVELOP. AND IMPLEMENT A
GROUND WATER MONITORING PROGRAM
AND ASSIST IN THE EVALUATION PROCESS
US DEPARTMENT OF AGRICULTURE AGENCIES
(SOIL CONSERVATION SERVICE. COOPERATIVE
EXTENSION SERVICE. AGRICULTURAL STABILIZATION
AND CONSERVATION SERVICE)
IDAHO SOIL CONSERVATION COMMISSION
IDAHO DEPARTMENT Of AGRICULTURE
IDAHO DEPARTMENT Of WATER RESOURCES
IDAHO DIVISION OF ENVIRONMENTAL QUALITY
EAST CASSIA SOIL CONSERVATION DISTRICT
WEST CASSIA SOIL CONSERVATION DISTRICT
MINIOOKA SOIL CONSERVATION DISTRICT
MONITORING FUNDS PROVIDED BY
EPA lit NATIONAL MONITORING PROGRAM
                                                                                                                                                                                     1 OF t USDA PRESIDENTIAL INrTITIVE
                                                                                                                                                                                     PROJECTS IN IDAHO,
                                                                                                                                                                                                         1 OF t USDA DEMONSTRATION PROJECTS
                                                                                                                                                                                                         IN U.S.
  IDAHO SNAKE -
  PAYETTE RIVERS
  HVDROLOOIC UNIT

  U5DA PRESIDENTIAL
  INITITIVE PROJECT
IDENTIFY THE NATURE AND EXTENT OF
NONPOINT SOURCE POLLUTION FROM
PESTICIDES AND NUTRIENTS,
DEVELOP AND IMPLEMENT GROUND WATER
BEST MANAGEMENT PRACTICES TO
REDUCE ADVERSE GROUND WATER QUALITY
IMPACTS FROM CONTRIBUTING SOURCES
5 YEAR PROJECT      DESIGN. DEVELOP, AND IMPLEMENT A
BEGINS 1^1          GROUND WATER MONITORING PROGRAM
                   TO IDENTIFY GROUND WATER IMPACTED
                   BY AGRICULTURAL NONPOINT SOURCES
                                     US DEPARTMENT Of AGRICULTURE AGENCIES
                                     (SOIL CONSERVATION SERVICE, COOPERATIVE
                                     EXTENSION SERVICE, AGRICULTURAL STABILIZATION
                                     AND CONSERVATION SERVICE)
                                             IDAHO (OC CONSERVATION COMMISSION
                                             IDAHO DEPARTMENT Of AGRICULTURE
                                             IDAHO DEPARTMENT OF WATER RESOURCES
                                             IDAHO DIVISION OF ENVIRONMENTAL QUALITY
                                             CANYON SOIL CONSERVATION DISTRICT
                                             GEM CONSERVATION DISTRICT
                                             PAYETTE SOIL CONSERVATION DISTRICT
                                             WEISER RIVER SOIL CONSERVATION DISTRICT
                                             ADAMS SOIL CONSERVATION DISTRICT
                                                                                                                                                                                                        MONITORING FUND SOURCE IS UNKOWN.
                                        1 OF 1 USDA PRESIDENTIAL INITITIVE
                                        PROJECTS IN IDAHO,
                                                                                                                                                                                                        1 OF »7 USOA HYDROLOGIC UNIT
                                                                                                                                                                                                        PROJECTS IN U.S.,
                                                                                                                                                                                                        RELATED TO OREGON'S HYDROLOGIC UNIT
                                                                                                                                                                                                        PROJECT IN MALHEUR COUNTY.
 LOWER PAVETTE      IDENTIFY THE NATURE AND EXTENT OF
                    NONPOINT SOURCE POLLUTION FROM
 STATE AORICULTURAL  PESTICIDES AND NUTRIENTS. DESIGN
 WATER QUALITY       AND DEVELOP A PLAN OF ACTION TO
 rnoORAM PROJECT    REDUCE ADVERSE GROUND WATER QUALITY
                    IMPACTS FROM CONTRIBUTING SOURCES
                                        S» YEAR PROJECT
                                        BEGAN Hit
                   ASSIST IN THE DEVELOPMENT OF A
                   GROUND WATER MONITORING PROGRAM
                   TO IDENTIFY GROUND WATER IMPACTED
                   BY AGRICULTURAL NONPOINT SOURCES
                                                                                                                   PAYETTE SOU CONSERVATION DISTRICT
                                                                                 IDAHO SOU CONSERVATION COMMISSION
                                                                                 USDA SOIL CONSERVATION SERVICE
                                                                                 IDAHO DIVISION OF ENVIRONMENTAL QUALITY
                                                                                                                                                                                    INITIAL MONITORING FUNDS HAVE BEEN
                                                                                                                                                                                    GIVEN TO DEO BY THE SOIL CONSERVATION
                                                                                                                                                                                    COMMISSION.  THESE ARE LIMITED FUNDS
                                                                                                                                                                                    AND ARE NOT ADEQUATE TO COMPLETE
                                                                                                                                                                                    THE PROJECT. INTENTION IS TO INCLUDE A
                                                                                                                                                                                    REQUEST FOR MONITORING FUNDS IN WITH
                                                                                                                                                                                    THE OVER ALL PROJECT BUDGET.
SCOTT'S POND       IDENTIFY THE NATURE AND EXTENT OF
                   NONPOINT SOURCE WATER POLLUTION
STATE AORICULTURAL FROM AGRICULTURAL ACTIVITIES WITH
WATER QUALITY      AN EMPHASIS ON GROUND WATER QUALITY
PROGRAM PROJECT   IMPACTS RESULTING FROM IRRIGATED
                   CHOP LANDS. DAIRIES. AND FEEDLOTS
                                       !. YEAR PROJECT
                                       BEGAN 9/90
                   ASSIST IN THE DEVELOPMENT OF A
                   GROUND WATER MONITORING PROGRAM
                   TO IDENTIFY AND ASSESS NONPOINT
                   SOURCE IMPACTS RESULTING FROM
                   IRRIGATED CROP LANDS, DAIRIES.
                   AND FEEDLOTS
                                                                                                                   NORTH SIDE SOIL CONSERVATION DISTRICT
                                                                                 US SOIL CONSERVATION SERVICE
                                                                                 IDAHO DIVISION OF ENVIRONMENTAL QUALITY
                                                                                 SOIL CONSERVATION COMMISSION
                                                                                 NORTH SIDE CANAL COMPANY
                                                                                 JEROME COUNTY HEALTH DEPARTMENT
                                                                                 BUREAU OF LAND MANAGEMENT
                                                                                 IDAHO DAIRYMAN'S ASSOCIATION
                                                                                 JEROME COUNTY COMMISSIONERS
                                                                                 AGRICULTURAL RESEARCH SERVICE
                                                                                 IDAHO DEPARTMENT OF FISH » GAME
                                                                                                                                                                                    GROUND WATER QUALITY MONITORING HAS
                                                                                                                                                                                    BEEN FUNDED THROUGH THE IDAHO POLLUTION
                                                                                                                                                                                    ACCOUNT FUND. THIS IS THE FIRST
                                                                                                                                                                                    OHOUNO WATER PROJECT FUNDED THROUGH
                                                                                                                                                                                    THIS ACCOUNT.
                                                                                                               32

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 SUMUAI1VOI  IIMMOA.-.IIICUIUTRALPROC.nAMS AND PROJECTS

 OCTOBER 1991
 PROJECT TITLE
                    OUTPUT
                                                                                                                    LEAD AGENCIES
                                                                                                                                                                 COOPERATORS
 DEEP CREEK         DETERMINE THE STATUS OF BENEFICIAL
                    USES OF SURFACE WATERS AND QROUND
 STATE AGRICULTURAL WATER WITHIN THE PROJECT AREA.
 WAT EH QUALITY      IDENTIFY THE NATURE AND EXTENT OF
 PROGRAM PROJECT   ANY ADVERSE IMPACTS ON WATER QUALITY
                    RESULTING FROM NONPOINT SOURCE
                    AGRICULTURAL ACTIVTTIES.
                                         2 YEAR PROJECT
                                         BEGINNING 4(81
 ASSIST IN THE DESIGN AND
 IMPLEMENTATION OF A WATER QUALITY
 MONITORING PROGRAM TO CHARACTERIZE
 CURRENT WATER QUALITY CONDITIONS.
 ASSIST IN THE DEVELOPMENT OF A WORK
 PLAN TO ADDRESS ANY ADVERSE WATER
 QUALITY IMPACTS IDENTIFIED.
                                                                                                                    BALANCED ROCK SOIL CONSERVATION DISTRICT
U3DA SOIL CONSERVATION SERVICE
IDAHO SOIL CONSERVATION COMMISSION
IDAHO DIVISION OF ENVIRONMENTAL QUALITY
                                                                                                                                                                                      GROUND WATER QUALITY MONITORING HAS
                                                                                                                                                                                      NOT BEEN FUNDED. INTENTION IS TO INCLUDE
                                                                                                                                                                                      A REQUEST FOR MONITORING FUNDS IN WITH
                                                                                                                                                                                      THE OVERALL PROJECT BUDGET REQUEST.
 JUMP CREEK         DETERMINE THE STATUS OF BENEFICIAL
                    USES OF SURFACE WATERS AND GROUND
 STATE AGRICULTURAL WATER WITHIN THE PROJECT AREA.
 WATER QUALITY      IDENTIFY THE NATURE AND EXTENT OF
 PROGRAM PRCurr.T   ANY ADVERSE IMPACTS ON WATER QUALITY
                    RESULTING FROM NONPOINT SOURCE
                    AGRICULTURAL ACTIVTTIES.
                                         2 YEAH PROJECT
                                         BEGINNING 4/81
ASSIST IN THE DESIGN AND
IMPLEMENTATION OF A WATER QUALITY
MONITORING PROGRAM TO CHARACTERIZE
CURRENT WATER QUALITY CONDITIONS.
ASSIST IN THE DEVELOPMENT OF A WORK
PLAN TO ADDRESS ANY ADVERSE WATER
QUALITY IMPACTS IDENTIFIED.
                                                                                                                    OWHYEE SOIL CONSERVATION DISTRICT
USDA 8OH. CONSERVATION SERVICE
IDAHO 8OtL CONSERVATION COMMISSION
IDAHO DIVISION OF ENVIRONMENTAL QUALITY
                                                                                                                                                                                       GROUND WATER QUALITY MONITORING HAS
                                                                                                                                                                                       NOT BEEN FUNDED. INTENTION IS TO INCLUDE
                                                                                                                                                                                       A REQUEST FOR MONITORING FUNDS IN WITH
                                                                                                                                                                                       THE OVERALL PROJECT BUDGET REQUEST.
 BEAR RIVER          DETERMINE THE STATUS OF BENEFICIAL
                    USES OF SURFACE WATERS AND GROUND
 STATE AGRICULTURAL WATER WITHIN THE PROJECT AREA.
 WATER QUALITY      IDENTIFY THE NATURE AND EXTENT OF
 PROGRAM PROJECT   ANY ADVERSE IMPACTS ON WATER QUALITY
                    RESULTING FROM NONPOINT SOURCE
                    AGRICULTURAL ACTIVTTIES.
                                         2 YEAR PROJECT
                                         BEGAN 10/90
ASSIST IN THE DESIGN AND
IMPLEMENTATION OF A WATER QUALITY
MONITORING PROGRAM TO CHARACTERIZE
CURRENT WATER QUALITY CONDITIONS.
ASSIST IN THE DEVELOPMENT OF A WORK
PLAN TO ADDRESS ANY ADVERSE WATER
QUALITY IMPACTS IDENTIFIED.
                                                                                                                    FRANKLIN BOIL CONSERVATION DISTRICT
USDA SOn. CONSERVATION SERVICE
US DEPARTMENT OF FISH AND QAME
US FOREST SERVICE
IDAHO SOIL CONSERVATION COMMISSION
IDAHO DIVISION OF ENVIRONMENTAL QUALITY
                                                                                                                                                                                       GROUND WATER QUALITY MONITORING HAS
                                                                                                                                                                                       NOT BEEN FUNDED. INTENTION IS TO INCLUDE
                                                                                                                                                                                       A REQUEST FOR MONITORING FUNDS IN WITH
                                                                                                                                                                                       THE OVERALL PROJECT BUDGET REQUEST.

                                                                                                                                                                                       INITIAL GROUND WATER QUALITY SAMPLES
                                                                                                                                                                                       WERE COLLECTED AND ANALYZED
                                                                                                                                                                                       APPROXIMATELY 10NO.
ADMINISTRATION
OF THE GROUND
WATER PORTION
OF THE STATE
AGRICULTURAL
WATER QUALITY
PROGRAM
INCORPORATION OF GROUND WATER
QUALITY PROTECTION IN THE ESTABLISHED
STATE AGRICULTURAL WATER QUALITY
PROGRAM.
DEGREE OF GROUND WATER QUALITY
INVOLVEMENT WILL VARY DEPENDING
ON INITIAL PROJECT EVALUATION.
                                                                                                                    IDAHO DIVISION OF ENVIRONMENTAL QUALITY
USOA SOIL CONSERVATION SERVICE
IDAHO SOn. CONSERVATION COMMISSION
INDIVIDUAL CONSERVATION DISTRICTS
THE STATE AGRICULTURAL WATER QUALITY
PROGRAM HAS REQUESTED QROUND WATER
OUAUTY CONCERNS BE REPRESENTED IN
THE PROGRAM. PAST REPRESENTATION
HAS BEEN INADEQUATE DUE TO LIMITED
PROGRAM INVOLVEMENT.

ADEQUATE ADMINISTRATIVE INVOLVEMENT
HAS BEEN ESTIMATED TO REQUIRE APPROX.
M HOURS PER PROJECT. APPROX. 5-7
PROJECTS ARE INITIATED EACH YEAR
                                                                                                                  33

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SUMMARY Of IDAHO AGFOCULUTRAL PROGRAMS AND PROJECTS

OCTOBER 1991
PROJECT TITLE
                   OUTPUT
                                                                                                                   LEAD AGENCIES
                                                                                                                                                                COOPERATOHS
rmnuNo wATrn
OUALITY COUNCIL'S
AGRICULTURAL
CHEMICALS
SUBCOMMITTEE
ASSIST IN THE DEVELOPMENT OF A
GROUND WATER QUALITY MANAGEMENT
PLAN FOR AGRICULTURAL CHEMICALS
IN GROUND WATER.
 1 YEAR PROJECT      POOV1OE TECHNICAL ASSISTANCE TO
 BEGAN 7/W           THE QROUND WATER QUALITY COUNCIL'S
                    AGRICULTURAL CHEMICALS SUBCOMMITTEE
                    DURING THE DEVELOPMENT OF A STATE
                    WIDE GROUND WATER MANAGEMENT PLAN
                    FOR AGRICULTURAL CHEMICALS.
                                                                                                                   IDAHO DEPARTMENT OF AGRICULTURE
                                                                                  IDAHO DIVISION OF ENVIRONMENTAL QUALITY
                                                                                  ASSOC. OF tO»- CONSERVATION DISTRICTS
                                                                                  U.S. ENVIRONMENTAL PROTECTION AGENCY
                                                                                  IDAHO WATER RESOURCE RESEARCH INSTITUTE
                                                                                  SNAKE RIVER CHEMICAL, INC.
                                                                                  IDAHO FARM BUREAU FEDERATION
                                         THE AGRICULTURAL CHEMICALS
                                         SUBCOMMITTEE IS ASSISTING THE GROUND
                                         WATER QUALITY COUNCIL IN DEVELOPING
                                         A AGRICULTURAL CHEMICAL MANAGEMENT
                                         PLAN FOR THE STATE.
EPA 319
SPECIAL
BONUS
PROJECT
PROVIDE GROUND WATER OUALITY DATA
TO SUPPORT INFTIAL GROUND WATER
QUALITY CHARACTERIZATION FOR
USE IN AGRICULTURAL NONPOINT SOURCE
PROJECTS IN CENTRAL SNAKE PJVER PLAIN
1 YEAR PROJECT      PROVIDE INITIAL CHARACTERIZATION
BEGAN »«0           OF GROUND WATER QUALITY CONDITIONS
                    WITH RESPECT TO ADVERSE IMPACTS
                    RESULTING FROM AGRICULTURAL ACTTVTTY
                                                                                                                   IDAHO DIVISION OF ENVIRONMENTAL OUALfTY
                                                                                                                                                                US ENVIRONMENTAL PROTECTION AGENCY
                                                                                                                          PROJECT FUNDING HAS BEEN PROVIDED BY
                                                                                                                          EPA THROUGH A SECTION 319 GRANT.

                                                                                                                          THIS PROJECT IS INTENDED TO PROVIDE
                                                                                                                          INITIAL GROUND WATER OUALITY MONITORING
                                                                                                                          SUPPORT FOR THE SNAKE PLAIN DEMON-
                                                                                                                          STRATION PROJECT AND VERIFICATION
                                                                                                                          MONTTOH1NQ TO SUPPORT THE SNAKE PLAIN
                                                                                                                          GROUND WATER VULNERABILITY MAPPING
                                                                                                                          PROJECT.
EPA 319
CONFINED ANIMAL
FEEDING OPERATION
(CAFO)
DESIGN. DEVELOP, PFOMOTE INNOVATIVE
CONFINED ANIMAL FEEDING OPERATION
FACILITIES AND BEST MANAGEMENT
PRACTICES TO REDUCE POTENTIAL ADVERSE
IMPACTS ON GROUND WATER QUALrTY.
1 YEAR PROJECT      PROVIDE PROJECT ADMINISTRATION,
BEGAN 1*1           OVERSIGHT. FACnjTIES, AND TECHNICAL
                    SUPPORT FOR A SOIL CONSERVATION
                    SERVICE ENGINEER IN THE TWIN FALLS
                    FIELD OFFICE.
                                                                                                                   IDAHO DIVISION OF ENVIRONMENTAL OUALITY
                                                                                  US ENVIRONMENTAL PROTECTION AOENCY
                                                                                  US SOIL CONSERVATION SERVICE
                                        PROJECT FUNDmo HAS BEEN PROVIDED BY
                                        EPA THROUGH A SECTION 318 GRANT. THIS
                                        PROJECT IS INTENDED TO BE EXTENDED
                                        BEYOND THE CURRENT TERMINATION DATE.

                                        THIS PROJECT IS INTENDED TO PROVIDE
                                        SUPPORT FOR THE SNAKE PLAIN DEMON-
                                        STRATION PROJECT AND THE SCOTT'S POND
                                        PROJECT WITH RESPECT TO CONFINED ANIMAL
                                        FEEDING OPERATIONS WITHIN THE AREA.
STATE PESTICIDE
MANAGEMENT PLAN
DEVELOP AND ESTABLISH A PREVENTITIVE
AND RESPONSIVE APPROACH TO ADDRESSING
GROUND WATER CONTAMINATION RESULTING
FROM AGRICULTURAL CHEMICALS.
Z.YEARPFIOJECT
BEGAN B/BO
ASSIST IN PROGRAM DEVELOPMENT BY
PROVIDING TECHNICAL ASSISTANCE
RELATIVE TO QROUND WATER QUALITY
PROTECTION.
                                                                                                                   IDAHO DEPARTMENT OF AGRICULTURE
US ENVIRONMENTAL PROTECTION AGENCY
IDAHO DIVISION OF ENVIRONMENTAL OUALfTY
THE STATE PESTICIDE MANAGEMENT PLAN
IS BEING COORDINATED THROUGH THE EPA
FEDERAL INSECTICIDE, FUNGICIDE. AND
ROOENTICIDEACT.  PLAN DEVELOPMENT
IS SCHEDULED TO BEGIN 7WI.
                                                                                                            34

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  si iMUAnv or IDAHO Ar.nicuLlrrnAL PROGRAMS AND PROJECTS
  ociourn 1901
  PROJECT TITLE
                                                                                                                      LEAD AQENCIE9
                                                                                                                                                                   COOPERATORS
  nFTVISION OF THE     REVISE THE STATE AGRICULTURAL
  STATE AoniCUlTUFW POLLUTION ABATEMENT PLAN TO INCLUDE
  POI LUTION
  ARATEMENT PLAN
  THOSE ITEMS IDENTIFIED AS
  INADEQUATELY ADDRESSED IN THE
  FEDERAL CLEAN WATER ACT SECTION 31»
  NONPOINT SOURCE WATER QUALITY
  ASSESSMENT.
1 YEAH PROJECT      ASSIST IN THE AGRICULTURAL POLLUTION
BEGAN «WO          ABATEMENT PLAN REVISION BY PROVIDING
                   TECHNICAL ASSISTANCE WITH RESPECT
                   TO GROUND WATER QUALITY PROTECTION.
                   SOURCES OF GROUND WATER CONCERN
                   INCLUDE CONFINED ANIMAL FEEDING
                   OPERATIONS AND IRRIGATED CROPLANDS.
                                                                                                                      IDAHO SOIL CONSERVATION COMMISSION
IDAHO ASSOC. OF SOIL CONSER DISTRICTS
IDAHO FARM BUREAU
IDAHO WATER USERS ASSOCIATION
IDAHO CATTLE ASSOCIATION
IDAHO AGRICULTURAL CHEMICAL ASSOCIATION
IDAHO DAIRYMEN'S ASSOCIATION
US SOIL CONSERVATION SERVICE
U OF I EXTENSION SERVICE
FARMERS HOME ADMINISTRATION
US BUREAU OF RECLAMATION
US BUREAU OF LAND MANAGEMENT
IDAHO DEPARTMENT Of LANDS
IDAHO DIVISION OF ENVIRONMENTAL QUALITY
US FOREST SERVICE:
AGRICULTURAL RESEARCH SERVICE
AGRI. 8TABIL 1CONSERV. 8ERV.
IDAHO DEPARTMENT OF WATER RESOURCES
US ENVIRONMENTAL PROTECTION AGENCY
THE IDAHO SOIL CONSERVATION COMMISSION
HAS ESTABLISHED AN INDUSTRY REPRESENTED
COMMITTEE TO LEAD THE REVISION PROCESS
STATE AND FEDERAL AGENCIES PARTICIPATE
IN THE COMMITTEE PROCESS BY PROVIDING
TECHNICAL ASSISTANCE.
 SOIL CONSEOVATION  TO ADDRESS CURRENT ISSUES AND
 SERVICE WATER
 QUALITY
 MANAGEMENT
 COMMITTEE
 PLOT OUT OUR FUTURE OURECTION IN
 POLICY TYPE ISSUES AND DIRECTION.
                   TO PARTICIPATE IN COMMITTEE
                   DISCUSSIONS CONCERNING CURRENT
                   AND FUTURE POLICY TYPE ISSUES
                   AND DIRECTION.
                                                                                                                     USDA SOIL CONSERVATION SERVICE
                                                                                                                                                                   IDAHO SOIL CONSERVATION COMMISSION
                                                                                                                                                                   IDAHO DIVISION OF ENVIRONMENTAL OUALFTY
                                         THE SOIL CONSERVATION SERVICE WATER
                                         QUALITY MANAGEMENT COMMITTEE REPORTS
                                         TO THE SOS STATE CONSERVATIONIST
                                         (PAULCALVERLEY).
 SOIL CONSERVATION
 SERVICE WATER
 OUALITY TECHNICAL
 COMMITTEE
 TO ADDRESS CURRENT ISSUES AND
 PLOT OUT OUR FUTURE DIRECTION IN
 TECHNICAL ISSUES.
                  TO PARTICIPATE IN COMMITTEE
                  DISCUSSIONS CONCERNING CURRENT
                  AND FUTURE TECHNICAL TYPE ISSUES
                  AND DIRECTION.
                                                                                                                     USDA SOIL CONSERVATION SERVICE
IDAHO SOIL CONSERVATION COMMISSION
IDAHO DIVISION OF ENVIRONMENTAL OUALITY
THE SOIL CONSERVATION SERVICE WATER
QUALITY TECHNICAL COMMITTEE REPORTS
TO THE WATER QUALITY MANAGEMENT
COMMITTEE.
IN-HOUSE AG
CHEMICAL GROUND
WATER OUALITY
MONITORING
TO OBTAIN GROUND WATER OUALFTY
DATA TO CHARACTERIZE AND EVALUATE
IMPACTS RESULTING FROM AGRICULTURAL
ACTIVITIES.
                  DESIGN. DEVELOP, IMPLEMENT. AND
                  EVALUATE GROUND WATER OUALITY
                  PROJECTS.
                                                                                                                     DIVISION OF ENVIRONMENTAL QUALITY
                                                                                                                                                                   SPECIFIC TO PROJECT
                                         IN-HOUSE PROJECTS DEVELOPED TO ADDRESS
                                         SPECIFIC PROGRAM CONCERNS OR TO ASSIST
                                         OR SUPPORT RELATED IN-HOUSE PROJECTS.
COOPERATIVE AO     TO OBTAIN GROUND WATER QUALITY
CHEMICAL GROUND   DATA TO CHARACTERIZE AND EVALUATE
WATER OUALITY      IMPACTS RESULTING FROM AGRICULTURAL
MONITORING         ACTIVITIES.
                                                            DESIGN, DEVELOP. IMPLEMENT, AND
                                                            EVALUATE GROUND WATER OUALITY
                                                            PROJECTS.
                                                                                                                     DIVISION OF ENVIRONMENTAL QUALITY
                                                                                                                                                                   SPECIFIC TO PROJECT
                                                                                                                                               COOPERATIVE PROJECTS TO ADDRESS
                                                                                                                                               SPECIFIC CONCERNS OR AREAS. THESE
                                                                                                                                               PROJECTS SHOULD BE CONSIDERED AN
                                                                                                                                               ASSET TO THE DIVISION'S PUBLIC RELATIONS.
                                                                                                              35

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SUMMARY Of IDAHO AOmCULUTRAL PROGRAMS AND PROJECTS '

OCTOBER 1991                                        1
PROJECT TITLE
                    OUTPUT
                                                                                                                    LEAD AGENCIES
                                                                                                                                                                 COOPERATOHS
USOA FARM BILL       STATE ENVIRONMENTAL AGENCIES WILL
                    HAVE A MAJOR ROLE IN DETERMINING
                    LANDS AND PRACTICES ELIGIBLE FOR
                    PROGRAM ASSISTANCE.
                                                            PARTICIPATION THROUGH SECTION 319
                                                            AND WELL HEAD PROTECTION PROGRAMS.
                                                                                                                    USOA AGENCIES
                                                                                                                                                                 TO BE DEVELOPED
                                                                                                                          THE 1W1 FARM BILL HAS INCORPORATED
                                                                                                                          VARIOUS GROUND WATER QUALITY PROTECTION
                                                                                                                          ISSUES. ACTIONS IN RESPONSE TO THESE
                                                                                                                          ISSUES NEED TO BE ADDRESSED THROUGH
                                                                                                                          STATE WATER QUALITY PROGRAMS
RATHDRUM PAIRIE
PROJECT
DETERMINE THE STATUS OF BENEFICIAL
USES OF SURFACE WATERS AND GROUND
WATER WITHIN THE PROJECT AREA.
IDENTIFY THE NATURE AND EXTENT OF
ANY ADVERSE IMPACTS ON WATER QUALITY
RESULTING FROM NONPOINT SOURCE
AGRICULTURAL ACTIVITIES.
DESIGN. DEVELOP. AND IMPLEMENT A
GROUND WATER QUALITY PROTECTION
PROGRAM TO PROTECT WATER OUAUTY
FROM AGRICULTURAL NONPOINT SOURCES.
                                                                                                                   DIVISION OF ENVIRONMENTAL QUALITY
                                                                                                                                                                 SPECIFIC TO PROJECT ACTIVITY
THE RATHORUM PAIRIE PROJECT IS A
COMPONENT OF THE SOLE SOURCE
AQUIFER MANAGEMENT PROGRAM.
DEPARTMENT OF
AGRICULTURE
PESTICIDE
APPLICATORS
CERTIFICATION
AND TRAINING
PROGRAM
SERIES OF EDUCATIONAL WORKSHOPS
TARGETED FOR PESTICIDE APPLICATORS
ATTENDANCE IS REQUIRED TO OBTAIN
APPLICATORS CERTIFICATION
                                                                              CURRENTLY NOT PARTICIPATING
                                                                                                                   IDAHO DEPARTMENT OF AGRICULTURE
                                                                                  UNIVERSITY OF IDAHO  •
                                                                                  COOPERATIVE EXTENSION SYSTEM
ATTENDANCE IS REQUIRED TO OBTAIN
NEEDED CERTIFICATION FOR
APPLICATION OF SELECT PESTICIDES
                                                                                                                36

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Revisions to the APAP are under consideration and many will relate
to better incorporation of ground water concerns so  a more balanced
approach to  surface water and ground-water quality protection is
maintained.   The state feels that passage of  the  1990 USDA Farm
Bill provides new  tools  for the development  of  individual farm
plans for protection of both.   In addition, the President's Water
Quality  Initiative  provides  many  new  resources  to  address
agricultural pollution issues and inter-agency committees have been
established to address current  issues and plot future direction.

USDA  Water  Quality  Demonstration  Project  and Hvdrologic  Unit
Project

Two USDA water quality projects have recently been implemented to
address   ground  water   impacts  resulting   from  agricultural
activities.
The  Snake River Plain  Demonstration  Project  was one  of  eight
nationwide  water quality projects  and  the  Snake-Payette Rivers
Hydrologic Unit  Planning Project was one  of  37 nationwide water
quality  projects which  were selected and  funded  by  USDA.   The
demonstration project is located in south  central Idaho and the
hydrologic unit  project is located in southwestern Idaho.  These
projects  are designed to show farmers  and ranchers  new ways to
minimize the  effects of agricultural nonpoint  sources of pollution
on ground-water  quality.  The USDA's Soil Conservation  Service and
the University of Idaho Cooperative Extention Service provide joint
leadership  for  these five  year  projects.   Cost share  will be
provided by the Agricultural Stabilization and Conservation Service
to eligible  farmers  and ranchers who install approved management
practices.   Ground-water monitoring  is being performed by IDHW to
document  the effects of  these  installed practices on the area's
ground-water  quality through funding awarded by EPA's  Clean Water
Act Section  319  nonpoint source program.

Grassy swales

Injection wells  are numerous  in Idaho and provide a direct conduit
for  contaminants to reach ground  water.   The  concept of using
grassy  swales as an alternative is beginning to be  implemented
primarily  in North  Idaho where  they  are following  the lead  of
Spokane  County.   The idea is to use the grassed area  as  a  filter
for contaminant  removal before infiltration.
                                 37

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IIIB.  LOCATIONAL CRITERIA

Hazardous Waste Facility Siting

In 1985 the legislature passed the Hazardous Waste Facility Siting
Act encouraging alternatives to land disposal of hazardous waste,
requiring  the  development  of  a  state hazardous  waste  siting
management plan, a  site licencing  program,  and mandating a great
deal of public involvement in siting decisions.   A Siting Board was
also established.  The licencing program was not to be duplicative
of the  RCRA  permitting program and to  date only one  licence has
been issued under the siting law program.

Source Specific Locations! Criteria

Septic  Systems:   The minimum setback from  domestic water supply
wells under the existing rules is 100 feet.

Underground Injection Wells:  For  certain types of  Class V wells
minimum setback  distances from  water  wells  have been established
by regulation  based on  the  discharge  rate to the injection well.
For example for a discharge rate of 1-2 cubic feet per second the
minimum setback is  2500 feet while for a discharge rate 4-5 cubic
feet per second it  is 4000 feet.

Public  Water  Supply Regulations:   Minimum  setback  distances for
public water supply wells include the following:

          50 feet from  a sewer line
          100  feet  from a home septic tank
          50 feet from  livestock operations

These setback  requirements will be looked at when regulations are
updated as it is felt that they do not  provide adequate protection.
Setback  requirements  will  also  be  addressed  in  the  wellhead
protection program.

Land Application of Wastewater:  Each land spreading operation gets
a site  specific permit  which may specify a setback distance.  The
applicants are required to supply maps showing all  wells in the
area.

Land Applications  of Sewage  Sludge:    Under  current  Idaho  water
quality regulations, sewage treatment plants are to have  a sludge
disposal plan  which is  approved  by  IDHW.   The plan  is to  cover
application rates when  used as  fertilizer and  include  setbacks  to
streams and  wells.   The requirement  to have such plans has been
adhered to in  a very limited  sense, however.
                                38

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       PERMITTING, COMPLIANCE MONITORING AND ENFORCEMENT SYSTEMS
Permitting

While  Idaho  has general  enabling  legislation  under  Title  39,
Chapters  1  and  36 to  protect the environment and  health  of  the
state, they have not  developed a permit program allowing assumption
of the National Pollution Discharge Elimination System (NPDES) from
EPA and the federal system  operates in the state.  The NPDES system
is a surface water protection program and does not cover potential
ground-water  impacts unless the  ground water discharge has  the
potential to impact a surface water body. Recent changes, however,
now make the NPDES program available  to regulate the use of sewage
sludge and  septate as  fertilizer  and  to regulate  sludge/septate
landfills, disposal  pits,  and lagoons.  Future rules may allow EPA
to delegate this authority separately from other NPDES permitting
authority.

Unlike some of the other states in Region 10, Idaho does not have
general  waste discharge regulations to  deal with any type  of
potential ground water  impact that  may arise. Rather,  they have
used the  above mentioned general enabling legislation along with
other media specific statutes to write permitting regulations that
control some activities with potential  ground water  impacts.

Land Applied Wastewater:   Concern about past and future potential
ground water  impacts of municipal and  industrial wastewater land
spreading operations lead to the establishment of a  new permitting
program in 1988.  IDHW  administers the  program and  worked closely
with the  regulated  community  in developing the program.   Since
inception  of the  program 84  of  the   97 applicants   have been
permitted with a number of additional applications expected  in the
next year.    A  semi-automated  annual  report  submittal tracking
mechanism has been set  up  and there  are plans to incorporate land
application  site and monitoring  information into  a CIS ground-
water vulnerability  data layer.  Now that the bulk  of the initial
permitting has been  processed IDHW wants to begin  evaluating the
effectiveness of the program.  This program  could also be expanded
to cover sewage  sludge  and septage thus controlling these ground-
water threats in another way than the NPDES option mentioned  above.

Underground Injection Wells:   Injection wells are defined  as any
bored,  drilled,  or  dug hole  deeper  than  it  is   wide  used  for
subsurface placement of fluids. Only Class V wells  are  authorized
in Idaho and the regulatory program  is  administered by  IDWR which
received primacy from EPA in  1984.  Prior to  receiving primacy IDWR
operated a UIC program of their  own.   Shallow wells  are  those less
than 18  feet deep and  they are  authorized by rule but must be
reported for inventory purposes. Wells  deeper than 18 feet require
a permit  and  abandonment  requires  IDWR notification and  proper
plugging.  The quality  of  the injectate is also to be  regulated.
Many have expressed  the opinion that this program  is underfunded
and  not  effective because of  large number of shallow wells of
unknown location.


                                39

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Well construction  standards:  The owner of  any well constructed,
drilled,  deepened  or  enlarged  after July 1,  1987  requires  a
drilling  permit  from  IDWR.   Wells  are  to  be constructed  in
accordance with  the well construction standards  adopted in 1988
which state  all  wells  shall be constructed  in a manner that will
guard  against waste  and contamination  of  ground  water.   Many
people,  however,  have  expressed  the  opinion  that  the  well
construction standards are outdated and inadequate.

Solid Waste Disposal Sites:  The regulations covering solid waste
were written in 1973 and are not  up to date  especially  in terms to
ground-water   protection.     They  require   landfills  to  have
conditional use permits, but this authority has been exercised in
a  limited manner.   Much  effort went  into seeking new legislation
in  1990 but  it was  not successful  leaving  a major  source  of
potential ground-water contamination unregulated by IDHW.

During  1991,  IDHW together with the  Health Districts,  have been
actively looking  into  the  future of  Idaho's solid waste program.
A new and considerably upgraded program may  emerge within the next
several years with some funding made available to support it.  An
interim measure  taken  by one  of the  counties  on  its own,  was to
follow  the  State  of  Washington regulations  as  the  basis  for
developing a new landfill.

EPA's RCRA Subtitle D landfill criteria has  finally been finalized
and will  become effective  in October 1993.    Under  Subtitle D,
States have the lead role for permitting and enforcement, and are
expected to  have,  or  adopt,  regulations which are at  least as
stringent as the new federal criteria. Secondly, citizens may file
suit  in federal  district court to  achieve  enforcement  of  the
Subtitle D criteria.

Hazardous Waste Sites:  Idaho has final authorization from EPA to
operate nearly all aspects of the RCRA hazardous waste program so
IDHW has permitting authority for storage, treatment and disposal
facilities.  As discussed earlier, there are few permits in Idaho
as it  is  complex process with stringent requirements  (including
ground-water protection)  which  motivates generators  to have the
waste handled off site.

Septic Tanks:  The Idaho regulations for subsurface sewage disposal
require  that  installation  permits  be  acquired  from  IDHW  for
subsurface systems.  The permit  applicant must  supply a specified
list of information with the  permit  request.   The permit will be
issued or denied based  on completeness and on meeting the technical
standards contained in the regulations.   Installers  must also have
a registration permit.  Recent court decisions have determined that
the State  Legislature, through  concurrent  resolutions,  has the
authority to  change Idaho Rules  and  Regulations.   Consequently,
regulations have been altered  to  allow less  stringent requirements
in one area of the state.
There is currently a discrepancy between Idaho  statutes  and EPA
                                40

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regulations regarding  the inclusion of septic systems serving at
least 20 persons as a Class V injection well.  EPA is working with
Idaho to change state  statutes to make this inclusion.

Other Control Programs

In  addition to source control programs requiring  permits other
control  programs  for  ground-water  protecting or monitoring  are
underway or evolving.

Underground Storage Tanks:   Idaho currently has 11 people working
in  the  Underground  Storage Tank Program  (UST)  and  the Leaking
Underground Storage Tank Program (LUST) at  IDHW all who are funded
by  EPA  grants.    In  1990  the  legislature  passed a  concurrent
resolution authorizing IDHW to submit a UST regulatory proposal to
the legislature for  approval.   IDHW submitted a proposal in 1990
which included draft regulations as  well as necessary staffing and
funding  levels.    No  further  action  has   been  taken  by  the
legislature.   IDHW,  however, feels  they need further legislative
direction to  actually implement a  program and apply to EPA  for
primacy-  The legislature has also established  a  Petroleum Tank
Insurance Fund to  provide low cost  insurance to tank owners with
tanks  in compliance  with  federal   standards,  a Certified  Tank
Technician  Program  for  tank  testing,  installation  and removal
(administered by the Fire Marshall) and a  UST Upgrade Assistance
Program  to  assist  small retailers to qualify  for conventional
loans.

EPA currently has responsibility  for enforcing the  federal  UST
regulations   for   notification,   tank  testing  and  financial
responsibility.   IDHW is provided  both UST  and LUST funding to
support  staff working  on these programs.   To qualify for the UST
grant the state must be actively seeking primacy.  Currently state
action  on  this  issue  is   uncertain  since  IDHW   feels  further
legislative direction  is  necessary.

Sewage Sludge:  -Under the  state water quality standards, sewage
treatment  plants  are required  to have  sludge disposal  plans
approved  by  IDHW.    In some  cases  IDHW  visits  and  approves
individual sites,  but in  general  the requirement to have such plans
is not closely followed.

Idaho  National  Engineering Laboratory:     The  Idaho  National
Engineering Laboratory (INEL) is  an  890 square mile U.S. Department
of Energy (DOE) facility in Eastern Idaho.   It lies  over  the Snake
River Plain Aquifer and  has nine  major facilities with nuclear
reactor  research,   fuel   reprocessing  and  waste  management,
constituting it's major operations.   In 1989, at the  recommendation
of the Governor, the  Idaho legislature established the state's  INEL
Oversight Program.   The purpose of this major  new program is to
ensure that Idaho monitors INEL activities to protect public health
and the  environment,  to  ensure  that the  people  of Idaho have  a
vigilant and independent  overseer with full  access  to INEL and to
provide  Idahoans  with an  independent factual  analysis of  INEL
activities.

                                41

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Over  30  state personnel paid  by both federal and  state funding
sources make up the oversight team.  The team represents a variety
of state agencies with coordination provided by the Deputy Director
of IDHW.  The staff conducts independent health and environmental
studies, analyzes historic and current environmental monitoring and
health   data,   ensures  compliance   with  state   environmental
regulations, oversees environmental restoration activities, makes
recommendations to DOE and  reports findings to the legislature and
the public.  To improve the state's effectiveness, a state project
office  has been  established  near INEL in  Idaho Falls  where  11
technical  staff  are  responsible for  ground-water  monitoring,
hazardous waste  and  water  quality inspections,  corrective action
and engineering  review  of  drinking water  and  wastewater systems.

This  program  is  to take a  comprehensive environmental and public
health  view   of  the  facility  on a scientific basis.   There are
still problems related  to  issues of  sovereign immunity regarding
federal government compliance with state regulatory requirements.
A  notice  of violation was  recently  issued by the  state to INEL
covering a number of environmental regulations.

There is also a  group of eight people (with an  additional 12 FTE
approved) in the  Hazardous Materials Bureau who are funded by DOE
and responsible  for  overseeing the superfund  mandated cleanup of
past practices contamination.  These staff members are independent
of, but work in close coordination with, the Oversight Program.

Drinking Water Program:  Idaho has received primacy from EPA for
the Public Water  Supply  (PWS)  program in  1978 but that status is
tentative as IDHW has been unable to secure adequate resources to
adequately implement  the new requirements  of  the 1986 amendments
to the Safe Drinking Water Act  (SDWA) .  The program is currently 70%
federally funded and 30% state  funded.  They would like to keep the
program  if adequate state  resources  can  be  secured  from the
legislature.

With  the exception  of the  developing  Wellhead Protection Program
that is separately authorized  in the SDWA, the PWS program is not
set up to protect ground-water but the monitoring data from  it is
used  to assist  in the  state's overall ground-water protection
efforts.  Both the PWS and  the  ground-water program are located in
the same section  at  IDHW somewhat simplifying coordination.  The
majority of drinking water in the state  comes  from ground-water
sources.  Private wells have no monitoring requirements  but  their
construction is minimally regulated by  IDWR.

Monitoring of public wells is done as  required  by  the SDWA with
analysis required at the  state  laboratory or a state  certified
laboratory.   The sampling  is  done by the purveyor  so there are
questions about QA/QC.   Monitoring results have resulted in some
wells  being  taken   off  line  but   that   has   not  solved  the
contamination problem.   The vulnerability  criteria used in  Idaho
for justifying the need for waiving VOC monitoring is testing once,
and if no hits are detected the source is considered  not
                                42

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vulnerable.  They feel this approach has saved $200,000 in unneeded
monitoring costs.

Agricultural Chemicals/Chemigation:  In addition to the discussion
of this  in  the above section on source reduction, the Department
of Agriculture chairs the Agricultural Chemicals Subcommittee of
the  Ground  Water  Council. The  Ground Water Quality  Plan being
developed  will  contain  a Agricultural  Chemicals  Ground Water
Management Plan as an appendix.   This appendix will not meet all
the  requirements for a State  Pesticide Management  Plan (PMP) as
required  by  EPA's  draft  National  Pesticides  in  Ground Water
Strategy.   The PMP  is  expected to  be  developed as  a separate
document  by the  Department of Agriculture with assistance from
IDHW.    The ongoing  vulnerability mapping  program  will  assist
greatly in implementing the PMP.   The  PMP will outline  the  state's
approach to dealing with use of  pesticides in the state that are
deemed  by EPA to be  of  concern  because  potential ground-water
contamination.

In  1989  the  Idaho  legislature  passed  a  chemigation law  for
regulation of  chemicals added  to irrigation water which is spread
on the land.  The Department of Agriculture administers the  program
and promulgated the required regulations in 1990. All  those using
chemigation  must  be  licenced and must  follow the  general  and
technical  requirements of the  regulations.    One  of  the major
requirements of the regulations is for the  use of backflow  devices
to prevent chemicals  from flowing back into the well.

Under  the Federal Insecticide,   Fungicide,  and  Rodenticide  Act
(FIFRA), the State of Idaho has enforcement primacy for the  use and
misuse of pesticides.   The Department of Agriculture  administers
this  enforcement  program  based  on   State  regulations   and  on
requirements  listed  on  pesticide labeling.   The  Department of
Agriculture  also  administers the   State  pesticide  applicator
certification  program which requires  training of certain types of
pesticide applicators.

Agricultural  chemicals  container  rinsate  regulations are also
pending finalization.

Feedlots and  Dairies:   Dairy  operations  in  Idaho  are regulated
through  a  general waste  discharge permit (NPDES)  issued  by the
Environmental  Protection  Agency   (EPA) as authorized  under  the
Federal  Clean Water Act.   Through a contractual agreement,  the
Water Quality Bureau of  the Department of  Health  and Welfare^s
Division of Environmental Quality assists  EPA in implementing this
program by conducting periodic field inspections and responding to
complaints.     If  violations   are  identified,  the  operation is
referred to EPA for enforcement.   The  State of  Idaho does not have
enforcement authority under this permit program.

The  Water  Quality Bureau published  the  "Idaho Waste Management
Guidelines  for Concentrated Animal Feeding  Operations" in 1987.
These guidelines  are  intended  to provide technical assistance to
dairy operators for properly  operating  and  maintaining dairies.

                                43

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The guidelines address water quality problems, current regulations,
runoff  control,  land  application  of  animal  wastes,  and  odor
control.  These are merely guidelines, and the State of Idaho does
not have the authority  to enforce these guidelines as regulations.

There are no state drinking water regulations directly applicable
to  dairy  operations,   particularly  on  how  a  dairy  operates.
However,  there   are   Federal   and   State   Safe   Drinking  Water
Regulations that  have  limitations  on the amount  of  nitrates and
bacteria  that  may be  present in  public  water  supply  systems
providing water  to 10  or  more households  or 25  or  more  people.
Nitrates  and bacteria  can be the result  of  dairy  operations,
although other sources such as septic tanks can also create these
contaminants.   These regulations only limit the  allowable amount
of  these  contaminants  in  the  drinking  water supplied  in public
drinking water, and have no direct application on how a particular
dairy operates.  There  are no state water quality regulations that
apply to private water systems such as an individual house with a
domestic water well, so it is  that well owner's responsibility to
assure that his well is providing water safe for consumption.

Without adequate personnel either at the state or federal level to
perform compliance  inspections of CAFOs, the NPDES  permit system
is unlikely to meet EPA's intended goal of approximately 400 CAFOs
in the Twin Falls area, only 29 have obtained a NPDES permit.  The
percentage of CAFO operators who have voluntarily applied for their
NPDES permit is very small. An inordinate amount of time is spent
on responding to illegal discharge complaints and working with the
operator to control the discharge.

It is not practical to view EPA's  CAFO  permit  program as  a final
solution  to addressing  surface water  and groundwater  concerns
associated with dairies and feedlots.  The issuance of permits is
the  first  step  in a process  that will  take  the  input  and
cooperation and coordination form a  number of government agencies.
Development  of  specific  design  criteria  for  waste  management
facilities, operation  and maintenance considerations,  and update
of Idaho Waste Management Guidelines for CAFOs need to be addressed
along with a viable ongoing compliance inspection and enforcement
program in order to adequately control the problem.

Sludge and Septage: Idaho is not decided where  to  go with  a sludge
management program. EPA  has developed the criteria for what a good
state  program would  be  but   the  Agency's  technical  regulatory
requirements won't be  out until January  1992 and  the state wants
to see the  final  version before making  any decisions.  Generally
this program is not viewed as  a high priority.

Currently the state water quality standards call for municipalities
to have sludge management plans but this  is  not evenly implemented.
There  are  liner  requirements  for  municipal  lagoons  which are
usually natural liners  but sometimes plastic  liners  have been
required.   The  requirement was that they have  either an  approved
disposal  site  or  such  a  plan, one or the other.    Sludge land
application guidelines were developed by  the  state  a  number of

                                44

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years  ago.    The land  application  of wastewater  permit program
discussed  earlier does  not cover sludge.   Some  sludge is also
disposed of in monofills and there are municipal composting plants
in Couer d' Alene and Lewiston.   The state is also  concerned about
septage  disposal and  has  regulations governing the  cleaning of
septic tanks. Federal  sludge regulations for municipal wastewater
treatment plants may include septate land application requirements.
State septage regulations may need to be updated.

The  NPDES  program  is  run  by EPA in Idaho  and  municipal permit
applicants are  being asked  to submit a sludge management plan as
part  of their  application.   Many  of  the applicants  have  been
advised of this  several  times with limited success.

Mining:   On January 1,  1988 the Rules and  Regulations for Ore
Processing  by  Cyanidation  went  into effect.   The  regulations
established the procedures  and requirements  for the issuance and
maintenance  of  a permit to  construct,  operate  and  close  that
portion  of  an ore processing facility which utilized cyanidation
and  is intended  to contain,  treat  or  dispose process  water or
process-contaminated water  containing cyanide.   The regulations
specify  procedures   for obtaining  a  permit  and  set  minimum
performance standards  for:  1) the design and construction of the
cyanidation facility;  2) water quality monitoring and reporting;
3) process water  containment and  control during operation; and 4)
seasonal and  permanent  closure  of  the facility-   Site-specific
design and operating flexibility  are built into the program.  The
burden  of  proof is upon the permit  applicant to demonstrate how
water quality will be protected.  Permit requirements may also vary
depending  on  local  factors.   A form of  financial assurance for
detoxification  of heaps and solutions at permanent  closure is
required before operation may begin.   The  regulations also provide
procedures  for  public  involvement,   appeals  modification  or
expansion of a  facility  and permit revocation.

"Registration"  in lieu  of  a  permit was  required  for facilities
existing on January 1, 1988.  Registration provides the Department
with   information  needed  to  evaluate   future  expansions  or
modifications  and provides a  basis  for  compliance inspections.
Prior  to the  March  31, 1988  deadline for  registration,  eight
cyanide  facilities  registered as existing facilities.   Of those
eight facilities, only three are  currently operating.

The fact sheet and draft  permit are prepared in the  appropriate DEQ
field office with coordination by the central office.  Engineering
plan and specification reviews are done in the field offices.  The
permit is finalized in the central office and sent to the applicant
under the Director's signature.   Since January 1, 1988,  fourteen
applications have been received,  two were returned as  incomplete
with  no resubmittal,   one  is  on  hold  at  the  request  of  the
applicant,  one  is currently being processed,  and ten permits have
been issued.

!t  is  difficult to estimate  the   number  of  future  CN permit
applications  as so  much depends on  the  current  price of gold.

                                45

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There will  probably be at  least one new application  next year.
This will  be an  expansion  of a currently  operating,  registered
facility.  Tracking of permit "conditions", compliance inspections
of operating facilities, and monitoring the construction of newly
permitted facilities should receive the most attention next year.

Rathdrum  Prairie  Aquifer  Protection  Program:    As  mentioned
previously there  is a major effort in Northern  Idaho  to protect
this highly vulnerable and productive aquifer under special funding
provided by  Congress for the past  four  years.   This  program is
modeled after  Wellhead Protection Program concepts and  is being
undertaken by  IDHW and the  Panhandle Health District.   Several
staff work at both agencies and are developing programs to better
characterize the  resource and  develop programs for  controlling
nearly all potential  sources of  contamination.   They  are dealing
with septic tanks, solid waste, agricultural chemicals, wood waste,
pipelines, drain wells, etc.  One special new program for dealing
with hazardous materials was developed and is being implemented.
Critical Materials Regulations have been developed under a recently
adopted  ordinance  that  require all those  handling  specified
hazardous  materials  to  report  them to  the  Panhandle  Health
District.  Secondary containment may then be required depending on
the  nature of the operation to prevent  leaks  and spills  from
reaching the aquifer.  A major national conference is planned for
the  Spring of 1993  to showcase  accomplishments of the aquifer
protection  program  both  in North  Idaho  and  Spokane  County,
Washington which  shares in the funding.

Indian Lands:  There is limited interaction between the state and
Indian Tribes on  ground-water protection  but  IDHW  has been asked
to enforce  in  spill situations  on occasion.  Some  of  the Tribes
have  been  active  in  pursuing  ground-water  protection  issues
especially the Shoshone-Bannock  Tribe. There  is a proposed policy
in the draft Ground Water Quality  Plan  that  states State/Tribal
Agreements should be pursued when aquifers span Tribal boundaries.

Idaho Tribes are generally willing to respond to  state requests for
PWS  monitoring  and  report  results  to  the  state  but  state
enforcement does not apply.

The Shoshone-Bannock Tribe is the most aggressive of Idaho tribes
in protecting ground water.   Under  CWA 106 and Pesticides grants
they have developed  a  ground-water  protection plan and adopted  a
ground-water Protection Act.   Both the and the Nez Pierce Tribe
have expressed  interest in the Wellhead Protection Program and have
made proposals for EPA demonstration  grant funds.

Compliance Monitoring

Compliance monitoring is carried  out by agencies in  Idaho that have
regulations  covering  activities with ground-water contamination
potential.   The major environmental regulator is IDHW and they have
the primary role  in inspections, etc.
                                46

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IDHW:  IDHW conducts compliance monitoring  for the above mentioned
programs they administer with inspections carried out primarily by
the staff in their field offices.  Each program has it's own scheme
for setting priorities which are not necessarily tied to the value
or vulnerability  of the ground-water resource.  With the ongoing
ground-water  vulnerability  mapping program,  this  can begin to
change since many programs can use this information for planning
as was discussed  earlier.

There is sufficient legislation to  provide the basis for adequate
compliance monitoring  but for nearly  all programs  resources are
limited.  The state also  does  not want to overemphasize it at the
expense of  other  activities.  Generally enough monitoring cannot
be  accommodated  within  existing  staff resources  and there is
insufficient oversight over  regulated facilities  responsible for
self monitoring and reporting.  Also better tracking systems for
monitoring  inspections and  results is felt  as  a  need by  IDHW.
Permit fees  are  generally not imposed to help cover  the  cost of
compliance monitoring.  Through the ongoing efforts of the Ground
Water  Council it is  envisioned  that  interagency  MOA's can be
developed  to allow  better coordination and  cooperation  between
agencies involved in monitoring.

IDWR:   The  primary ground-water  protection  aspects of  IDWR's
activities relate to driller  licencing, well construction standards
and the regulations for construction and use of  injection wells.
The permits for injection wells are  usually issued for  10 years and
they try to inspect at least once over that span preferably within
two years of renewal. Owners and operators of  injection wells are
not normally subject to monitoring, record  keeping  and reporting
requirements but these requirement can be imposed for ground-water
protection purposes.
The construction  of  water wells requires a permit and fee.   With
the  large  number  of  wells  that  are  constructed  annually  the
monitoring and regulation of construction regulations is limited.
IDWR can  take action  if  owner or  drillers are in  violation of
standards or if drillers  have  not submitted drillers reports.

Department  of  Agriculture:   The  1989 chemigation  law  gives the
Director right of entry to determine compliance with  the law or the
regulations promulgated  thereto.   The Director may  also enter in
an agreement  with  IDWR  allowing  any employee of that  agency to
determine compliance.  The Director  or his designee is also charged
with  making  at  least  250  annual  audits  of  chemigation
installations.  Retail  sellers and suppliers that  have reason to
know that  agricultural chemicals will  be applied  by chemigation
must insure that  the sales recipient has a chemigation licence.

US Environmental  Protection Agency:   Since  EPA  administers the
NPDES  Program  they are just  getting  started  in  compliance
monitoring of sludge land spreading as newly required under  this
program.

Health Districts:  The seven Health Districts provide oversight of
the  septic tank  regulations  and  site  inspections are  made on

                                47

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installations.    The  Panhandle  Health  District  also  oversees
implementation  of the  Critical Materials  Regulations discussed
previously for protection of the Rathdrum Prairie Aquifer.

The Panhandle Health District also performs project reviews for EPA
for possible  ground-water  impacts of proposed projects receiving
federal  financial assistance.   This is  done  in accordance with
Section  1424(e) of the SDWA outlining EPA's responsibilities once
the agency designates  a  sole source  aquifer (as was  done for the
Rathdrum Prairie Aquifer).

The Panhandle Health District also has a Cooperative Agreement with
IDWR  for the UIC  program.    The Health  District   receives  and
processes  permit  applications and  does  inspections,  but  IDWR
retains permitting authority for injection wells.

Enforcement

The agencies in Idaho with ground-water protection regulations have
enforcement authority to take action when requirements are not met.
Enforcement tools generally include notices  of violation (NOV),
consent orders (CO) and civil and  criminal penalties.  Both formal
and  informal  actions  can be taken.    Each  agency's  penalty
provisions are contained in the statutes and regulations for the
programs they administer.

IDHW:   Enforcement actions by IDHW  that are  related to ground-
water  stem  from  regulatory programs  administered  by the  Water
Quality Bureau and the Hazardous Materials Bureau (primarily RCRA) .
The RCRA program has  been delegated to  Idaho by EPA under the
stringent equivalency  requirements of that program.   While IDHW
lacks the authority to issue "orders", their NOV and CO processes
have  been  deemed  adequate for   equivalency  to  the  EPA  RCRA
enforcement regulations.   With the exception of the  PWS program,
EPA  has not  delegated  water  quality authorities  to the  Water
Quality Bureau and the enforcement procedures  are largely the same
as RCRA.  Figures  4  and  5  provide a  depiction of the options and
administrative procedures that  are available.  Enforcement actions
are initiated  in  the field offices  and then  sent to Boise where
they are centrally handled. Ground water remediation is presently
conducted under  the  authority of the Water  Quality Standards.
Legislation is needed to provide more authorities.

In general there is adequate legislation to provide  the basis for
regulatory enforcement but regulations are  lacking  as in the UST
program.    There  is  lack of adequate  staff for enforcement
activities  and  IDHW  feels   that   enforcement  procedures  need
improvement and they are working on improvement. The authority to
issue "orders" would also help  streamline the  enforcement process.
One of IDHW's  priorities  is to develop a better tracking system for
keeping up to date on the status of  enforcement actions.

IDWR:  Title 42, Chapter  39 related to UIC wells provides IDWR the
authority to  seek  injunctive  relief,  levy  civil   and  criminal
penalties and issue cease and desist  orders.   The penalties  can be

                                48

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                 ADMINISTRATIVE ENFORCEMENT ACTION PROCESS
                            Violation of the Environmental
                            Protection and Health Act or
                            Rules. Regulations, Permlta, or
                            Ordara Promulgated Thereunder
Action
                    | Unresponsive
delation
iesolved
                                               (Formal Action
                                 Case Referral
                                 Prepared by
                                 Reid Office
{Civil Enforcement
                                 Draft NOV/CO
                                 Prepared
                                                NOV signed by
                                                Director
                                                Compliance
                                                Conference
                                                Requested
                                                       NO
                                                     Yes
                                                Compliance
                                                Conference held
                                                Consent Order
                                                Negotiated	
                                                               No —'
                                                     Ye«
                                                Consent Order
                                                Signed by Director
                                  Penalty Paid and/or
                                  Performance
                                                     Penalty not Paid
                                                     and/or Performance
                                                     Requirements not mat_
                                     Violation
                                     Resolved

-------
                            ENFORCEMENT ACTION ALTERNATIVES
                                  WATER QUALITY BUREAU
VloMton at ttw Environmental
Protection and Hcafth Act or
RutM, Regulations. P*n*t, or
Orders Pronulgated Thereunder


                   Enforcement PiocwJuras
              I   EfHorcement
1 Internal AcOons  |
                Noooompfano
Conference
                ErrfocccfTWK
                Case Referral
                                                    Acttora \
                                              ;AdmlnictraUM
                                                  Actions
                                                                  Vtotatton
                                              [Consent Order |
                                           50

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applied  to  those who construct, operate, maintain, convert, plug
or  abandon  wells in  a  manner that may  result  in  injection of a
hazardous or radioactive waste  in  violation of  Idaho Code.

Under the well construction standards owners or  operators allowing
waste contamination  of  ground water or causing  a well not to meet
construction standards  are subject to civil  penalties.   Drillers
who  violate construction  standards are subject  to  the  penalty
provisions  of Title  42.

Department  of  Agriculture:   Under  the  chemigation  law,  anyone
conducting  chemigation  without  a licence will be  liable to civil
penalties fines over and above under the general  penalty provisions
of Idaho Code.

Fines  are  to  go to  the  water  pollution  control  account.   The
Department  can  also issue  stop work orders for violations  of
chemigation rules.   Penalties  escalate with  the  frequency  of
violation.   A first violation  within a five year period  is  to
result in warning letter from  the  Director.   A second violation
within a five  year period  is to result in a  misdemeanor.   Upon a
third  or subsequent  violation, within  a  five year  period,  the
violator will be subject to a misdemeanor and  be fined $10,000 for
each separate violation or  $1,000 per day for continuing violations
whichever is greater.   These penalties are in addition to others
provided by law  for  pollution of waters  of the  state.

Remediation

The draft Ground Water  Quality  Plan developed by the Ground Water
Council  contains a proposed  remediation policy. It  states that:
"The policy of the state of Idaho is where contamination resulting
from human  activities  produces a significant  potential  for the
impairment  of  an existing or projected  future  beneficial use of
ground water,  remediation  should  be  conducted  when  feasible and
appropriate.   Decisions  for when  to initiate remediation,  the
extent of remediation needed and the appropriate remedy should take
into  consideration   site   specific  risks  to  health  and  the
environment, the cost of remediation, the  technological limitations
and the need to maintain or recover beneficial uses  of ground water
and interconnected  surface water."  The proposed policy includes
recommendations  to  develop remediation regulations and what they
should include,  concepts  for what  the definition  of responsible
party should be  and  the need  for public  participation.

A summary of  current ongoing remediation  activities is provided
below.
Superfund Type Activities:   Idaho does not have  any superfund type
legislation  similar to  the  federal  Comprehensive Environmental
Response,  Compensation  and  Liability  Act  (CERCLA)  enacted  by
Congress in 1980 and reauthorized in 1986.   All CERCLA type work
in Idaho is federally funded and  EPA, INEL,  DOD  and BLM provide
funding  to  the Hazardous Materials  Bureau to  assist in overseeing
and management of the National Priority List  (NPL)  sites in  Idaho.
There are nine NPL sites in  Idaho  four of which have ground-water

                                51

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problems.    Responsible  parties  are  encouraged  to  undertake
voluntary cleanup actions, but enforcement options and/or federal
superfund monies are  used,  when necessary,  to  facilitate  site
cleanup.   Federal and state  criteria or standards  (e.g.  MCL's,
ACL's,  water  quality criteria,  etc.)  are  typically  used  to
establish  ground-water  cleanup goals.    Specific  ground-water
remediation techniques are selected on a site specific basis after
consideration of possible options.  All contractors or responsible
parties conducting superfund work for EPA  or  under EPA oversight
are required to submit ground-water monitoring data to the Agency
according to  the formats specified in the  regional ground-water
order.

RCRA Corrective Action Sites:  Idaho has RCRA interim authorization
for  corrective  action at  old waste management  facilities where
contamination problems exist.   They are in the early stages of the
program and are  doing facility assessments to determine what is out
there.

Leaking Underground  storage Tanks  (LUST):   Idaho receives a LUST
Trust Fund grant  from EPA to  fund  staff  to enforce Idaho's Water
Quality Standards and oversee state-led and responsible party-led
investigation and cleanup activities.  There are a large number of
LUST sites in the state as discussed previously and field staff are
fully committed.  It is  expected that many additional LUST sites
will  be  discovered  when  Insurance  Fund  audits  are  made  of
applicants for  the  low  cost  insurance.   Only those  meeting the
federal standards are eligible for the insurance.

Contamination  Log:    In  1985  a  contamination  log project was
initiated to  help track  contamination incidents  and  maintain an
ongoing record.   After initial records  of historical information
were obtained it  was intended that  field staff  update the log on
a periodic basis as new  contamination  information was revealed.
These updates did not materialize on a  reliable or consistent basis
and the log was  largely put on hold.  In  1990 the contamination log
activity  was resumed as  it  was  seen  as  a  potential  tool  in
answering the increasing  number of environmental audit requests on
specific areas and as a possible database for tracking enforcement
proceedings  allowing sites to  be  prioritized and  tracked.   The
computer group plans to begin developing a new database system in
late summer 1991.  The groundwater unit is also trying to improve
more  consistent  reporting  on  contamination  incidents  by  field
staff.

INEL:  There are  350 identified waste units at INEL containing  a
wide variety of potential contamination sources.  Three locations
at INEL  have releases of  hazardous waste beyond  the waste site
boundaries.  The state has worked with  DOE to develop workplans for
sampling soil and regular meetings are held to  hold DOE accountable
for completing  scheduled activities.   Hazardous Materials Bureau
staff have reviewed summary assessments characterizing contaminants
at numerous waste units  and UST's.  Ten waste unit closure  plans
that were submitted  in FY90 were found  inadequate and an additional
18 are expected  to  be submitted in  FY91.  EPA created a technical

                                52

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review committee to help solve hydrogeological problems related to
environmental restoration at  INEL.   This  committee is made up of
specialists  from  DOE,  DOE contractors EPA,  and  EPA contractors,
USGS  and  the  state.    DOE  is  also preparing  a  Programmatic
Environmental Impact Statement to serve as a planning document for
future environmental restoration at DOE facilities nationwide.
                                 53

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            IV.  DEFINING ROLES WITHIN THE STATE AND
               THE  RELATIONSHIP  TO  FEDERAL AGENCIES


IVA.  State Roles

As  discussed  previously several  state agencies have  regulatory
authority over activities that  affect  ground-water  quality.   The
responsibilities and roles of each are discussed briefly below:

Idaho Department of Health and Welfare

The  Idaho  Department of Health and Welfare (IDHW), Division of
Environmental  Quality  administers  most  of  the  environmental
protection programs in Idaho and is charged by the legislature as
being the primary agency for ground-water quality protection.   The
draft Ground Water  Quality Plan being developed  by the Ground Water
Quality Council also contains a policy assigning IDHW with lead for
regional and local ground-water monitoring.   IDHW administers the
programs  for  drinking water,  ground-water protection,  wellhead
protection,  solid   waste,  hazardous  waste,  sewage  construction
grants, agricultural pollution abatement grants, non-point source
pollution,  septic  tanks,  sludge  land  spreading  plans,  land
application  of   wastewater,    and  currently   assists  EPA  in
implementing the underground  storage  tank, leaking  underground
storage  tank,  and  Superfund  programs.   In  this  capacity  they
develop  regulations,  write   permits,   and  provide  compliance
monitoring  and  enforcement.    They also have a  major role in
environmental oversight at INEL along with other agencies.

Idaho Department of Water Resources

The  Idaho  Department  of  Water  Resources  administers  programs
dealing  with  water  quantity  issues  and  is  charged  by  the
legislature with being the  agency  responsible for the  natural
resources GIS  system and  for  collection of baseline data  on the
state's  water  resources.    The draft  Ground Water  Quality  Plan
developed by  the  Ground  Water Quality  Council also  contains a
policy   assigning   IDWR   with  lead   for   ambient  ground-water
monitoring.  IDWR is also responsible for protecting ground-water
quality through it's permitting program for underground injection
wells  and  the water  well  construction standards and  driller
licencing.

Idaho Department of Agriculture

The Idaho Department of Agriculture is charged  by the  legislature
with  being  responsible for  regulating  the use  of agricultural
chemicals as related to ground-water protection. The draft Ground
Water Quality  Plan  developed  by the Ground  Water Quality Council
contains a  policy  stating that agrichemicals  will  be  managed  so
that  potential contaminants  will  not impair  beneficial  uses  of
ground water below the crop  root  zone.   The  Department has  lead
responsibility for  developing the state's Pesticide Management Plan


                                54

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as called  for in EPA's  draft  national  Pesticide  in Ground-Water
Strategy.  The Department also has responsibility for administering
and enforcing  the 1989 Chemigation Law.
State Fire Marshal

The State  Fire Marshal's Office has responsibility for Certified
Tank Technician Program  established by the legislature in 1990 to
help assure that persons that install,  remove, and leak test tanks
meet established requirements.
State Insurance commissioner

The 1990 legislature established the Petroleum Tank Insurance Fund
that  provides low  cost  insurance  to  tank  owners  that  can
demonstrate that their tanks  are not  leaking and  are in complete
compliance with federal  technical requirements.

INEL Oversight Program

This special  program enacted by the legislature has  the program
administrator  reporting to  the Deputy  Director  of  IDHW.    The
program  is guided by an internal  steering committee made  up of
these two  individuals plus the Administrators of the Divisions of
Health  and  Environmental  Quality at  IDHW.    Programs  submit
proposals  for  resources  tied  to specific program  objectives with
the steering committee setting priorities and approving workplans
for allocation of funds.  This mechanism has been formalized with
IDWR through  a Memorandum  of  Understanding.   Affected bureaus at
IDHW must submit a workplan with measurable objectives to maintain
there Oversight funding and  must  participate in the  INEL  QA/QC
program.

Idaho Geological Survey

The Idaho Geological is  closely  associated with the University of
Idaho and studies and reports on geology,  surface and ground water
resources, and the  energy  resources in the state.   They maintain
an extensive  list of publications,  etc. that are  available for
distribution.

Coordination Mechanisms

The Ground-Water Quality Protection Act of 1989 clearly recognized
the need for inter-agency coordination  and public participation in
protection of the ground-water resource.   It  mandated the creation
of a Ground Water  Quality  Council  representing  a  wide variety of
interests to guide the development of the Ground Water Quality Plan
required by the law.  The Council is to exist for up to two  years
after approval of  the  plan  and will then  be  disbanded  if not
reauthorized by the legislature.  During the two years after  plan
adoption, and thereafter if reauthorized, the Council is to oversee
progress in implementing the plan.

Once the plan  is  approved it  is  envisioned that  more detailed
memorandums of agreement will be developed among the various


                                55

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agencies to better outline specific roles and responsibilities in
implementing the plan.

As discussed earlier many new agricultural initiatives related to
ground water  such as the  Clean Water Act Section  319 non-point
source program, the  President's Water Quality Initiative and the
1990 Farm Bill provide a great deal of opportunity if coordinated
right.  IDHW has committed FTE to maintain a broad perspective on
the overall picture to insure opportunities aren't missed and that
duplication  of   effort   doesn't  occur.     The   Department  of
Agriculture's FTE will also be increased in July 1991 allowing more
resources to be available for coordinating on these new programs.
The Farm  Bureau has also  taken an active role in  water quality
issues and  has been working with  state  agencies  on ground-water
monitoring programs.
                                56

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IVB.  Local Roles

The Ground Water Quality Protection Act of 1989 contains a specific
section  on  the  duties  of   local  government  in  ground-water
protection.  Local units of government  are directed to incorporate
provisions of the  adopted statewide  Ground  Water Quality Plan in
their programs and are encouraged to implement ground-water quality
protection policies within their jurisdictions.   Implementation of
such local policies,  however, must be  consistent with  the state
plan and not preempted  by the  laws or regulations of the state.

All units of state and  local government are directed to cooperate
with the Ground  Water Council and are  to assist state regulatory
agencies  in  disseminating  public information  on protection  of
ground-water quality.  They are also to cooperate in the collection
of ground-water  quality data and in  research on technologies for
preventing or remedying ground-water contamination.   Any unit of
government which  issues  a  permit  or  licence  dealing with  the
environment is to take  into  account the effect of the activity on
ground-water quality  and may attach  conditions to the licence or
permit  to mitigate  potential adverse  effects.  They may  not,
however,  require  permits  or licenses  that  are  not  otherwise
authorized by  law.    Also,  if a state agency issues  a  permit or
licence dealing with the environment, and that agency considers the
impact of that activity on ground-water quality, no  other unit of
government may  impose additional prohibitions or conditions that
impact the rights of  the  permittee.

The ground-water quality law also directs  local governing boards
amending, repealing,  or adopting comprehensive plans to consider
what such action would  have on the quality  of ground water.   The
draft Ground  Water  Quality Plan developed  by the  Ground Water
Council also contains two proposed policies on state/local issues.
The first states that all  units of local government shall integrate
the state plan into their  existing programs and planning activities
and are  authorized and encouraged to implement ground-water quality
protection policies  within their respective  jurisdictions.   The
second states that local  governments shall not adopt ground-water
quality  ordinances,   regulations,  standards,  etc.  that are  not
consistent with  state plan or impose duplicative requirements on
the public.

Local  unit  of  government   can  adopt  ground-water  protection
ordinances, etc.  which cover  protection measures not covered by
state programs.    Such is  the  case  in North  Idaho  where  the
Panhandle Health District used the ordinance approach to develop
Critical  Materials Regulations  requiring  secondary containment
measures for  those handling  specified  hazardous materials.   The
ground-water protection authorities of  local  government, however,
have become controversial during development of the Ground Water
Quality Plan because of the wording in  the ground water protection
act that was discussed  above.
                                57

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IVC.  Relationship with Federal Agencies

State ground-water protection  regulatory  agencies generally have
their primary interaction with EPA  at  the federal level although
other agencies  are involved as discussed  below.  The relationship
with EPA varies  depending on the nature and status  of the pollution
control program  involved.   On overall protection of  the ground-
water resource the state works  with  EPA on a voluntary cooperative
basis to  work towards  building a  comprehensive  program through
federal  financial  and technical  assistance.    Other  programs
originate from a  national statutory mandate  and allow delegation
from EPA to the state if requirements are met.  In Idaho the IDWR
has been delegated the UIC program and  IDHW has been delegated the
RCRA and  PWS programs.   EPA  provides financial  assistance  and
maintains oversight of the state programs.

For other programs where the state has not sought delegation they
receive funding to assist in implementation  such  as  in the NPDES
and UST programs.  For some programs EPA has no authority such as
for septic tank regulation and  land  applied wastewater permitting.
Other programs  such  as Clean Water Act Section 319  for nonpoint
source pollution  control  require that the state develop  an  EPA
approved plan to be eligible to receive  funding for implementation.

The Idaho Department  of Agriculture will  be  working  closely with
EPA over the next several years in developing  and implementing the
state's Pesticide Management Plan as  called  for  in  the proposed
national Pesticides in  Ground-Water Strategy.  This  will require
close coordination between the pesticides and ground-water programs
at both EPA and the state.

The state's relationship with  INEL  is a special oversight program
with DOE and it's purpose and  scope were discussed previously.

With  the increased  focus  on  agricultural  practices  and water
quality the state needs expanded coordination  and  interaction with
USDA  and  its  various  outreach   and  financial  and  technical
assistance programs.  The  state has  been a leader  in this area and
the 319  non-point source  program,  the President's Water Quality
Initiative and the 1990 Farm Bill provide many new opportunities
to reduce surface and ground-water quality impacts by the adoption
of new and improved BMP's.

The state has worked  closely with USGS on a number of monitoring
and  resource characterization projects  over the  years  as  was
discussed previously.  The USGS has also  been a key player  in the
vulnerability mapping program  currently underway.  The new NAWQA
program being  implemented  by  USGS  is  a  major  long  term  program
which includes parts  of Idaho as initial study  areas and  should
benefit state ground-water  protection efforts greatly.   USGS  is
also involved in the INEL Oversight Program.

The BLM and the USFS  have been  heavily  involved in nonpoint source
issues and work closely with both EPA  and the state in  addressing
these issues.  The BLM also has a cooperative agreement with  IDHW

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to fund a position in the Hazardous Materials Bureau for assessing
pollution   from  BLM's   extensive   land   holdings   in   Idaho.
Approximately 40% of the permitted landfills  are on lands leased
to counties by BLM.

The draft  Ground Water  Quality Plan contains  a proposed policy
related to  federal  consistency.   It states that it is the policy
of the state  of  Idaho that ground water underlying all federally
owned lands be
provided with the same level of protection as other ground waters
of the state.  For  implementation  it  states that federal agencies
should comply with the plan and any ground-water standards that may
come about as well as incorporating all  applicable  state and local
ground-water protection  provisions.
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                          V.  RESOURCES

VA.  Financial

The state of Idaho is heavily dependent on federal funding for many
of its environmental programs.  For example, Superfund activities
in Idaho  are entirely  funded  with federal dollars  from various
agencies.   Getting adequate state funding to  administer  the PWS
program has been a problem and with the many new responsibilities
added by the 1986  amendments  to  the  SDWA it is uncertain whether
the state can maintain primacy.  Currently EPA provides about 70%
of the  funding.   The  Department of  Agriculture  has gotten  an
increase for staff support in dealing with water  quality issues
with EPA now funding about 1/3 of the program.   The IDWR receives
EPA funding to administer the UIC program which  requires  a 25%
match.

The ground-water protection unit  at IDHW  has utilized funding from
several sources  to support its activities.  These include Clean
Water Act 106,  319 and 205(j) funding, some state funds and funding
from DOE for the  INEL Oversight  Program.   Also for the past four
years Congress has provided substantial special appropriations to
be used for  programs  to protect  the  Rathdrum/Spokane  Prairie
Aquifer  in  both  Washington  and  Northern Idaho.    Substantial
progress is being made.

For a number of years  the state has  supported the Agricultural
Pollution Abatement Plan  with funds  from Water Pollution Control
Account.   Funds  for  this account  are generated  from specially
generated tax  revenues.   Potential sources of  funding for these
type of activities have considerably expanded with funding of the
319 non-point source program, introduction of the President's Clean
Water Initiative and passage of the 1990 Farm Bill.

The Ground  Water  Quality  Protection  Act  of 1989 mandated both an
ambient  monitoring program and  regional  and  local ground-water
monitoring programs. To date funding has been provided to IDWR for
ambient monitoring  but  IDHW hasn't been  provided  funding for the
local and regional program for which they are responsible.

The draft plan  will make recommendations  for how the provisions of
the plan should be funded.  When the final proposed plan goes to
the legislature next January,  many  issues on the  adequacy  of
financial resources will be decided depending on the action taken.
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VB.  Personnel

The organizational  structure  in the Water Quality Bureau at IDHW
has made coordination on ground-water protection somewhat simpler
than in other  states.   The ground-water protection, PWS, UST and
LUST  programs  have  been  in  units  supervised  by  the  ground
water/drinking program manager.  A current reoriganization effort
may undo  this however.   The ground-water protection unit  has a
supervisor and 10 staff members  working on the Ground Water Quality
Plan, the land applied wastewater permit program, the vulnerability
mapping project,  the agricultural water quality program, ground-
water monitoring efforts, the wellhead protection program and soil
science and hydrogeologic  technical support. Each of  the  field
offices also have staff that deal  with ground-water  issues.  The
following  provides  staffing levels  for other programs  impacting
ground water (including field staff)  and the  percentage of funding
support derived  from federal sources.

Program                     # of Staff         % Federally Funded

PWS                           14                     70

UST/LUST                      11                     90

RCRA                          17                     49

CERCLA                        20                     99

Solid Waste/Sludge              1                       0

Nonpoint Source               24                     75

Laboratory                    56                     16

Data Management                 6                     40


The Department of Agriculture has two FTE working  on water quality
issues and  IDWR  has 3  staff working on the UIC program.
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                            APPENDIX A

                          STATE OF  IDAHO

                       POLICY STATEMENT FOR
                  GEOGRAPHIC INFORMATION  SYSTEMS
Background
In the past decade, governmental agencies and private industry have
developed  increasingly  powerful  computer  systems  designed  to
process  and  analyze   map  information.     Collectively  called
geographic  information  systems   (GIS),  these  systems  have  the
potential to significantly increase efficiency and reduce costs to
the  State for  conducting  land,  water,  demographic,  and  other
resource management activities.

GIS technology, much like  the  computer  field  in general,  is in a
period of dynamic evolution and growth.  Moreover,  GIS technology
is  but  one  of  a  number of related  technologies   (e.g.,  remote
sensing, and digital cartography)  that could assist state agencies
in carrying out their mandated responsibilities more efficiently.
Indeed,  these technologies are becoming ever more closely linked,
and are part of the information  management activities  of Idaho.
Within this framework,  it is imperative  that emphasis be placed on
coordination between the departmental organizations currently using
or planning  to use these  technologies.  This  coordination will
facilitate exchange of data between agencies.

Objectives

A.   Encourage and assist in the development,  implementation, and
     use  of  geographic  information systems  to meet  current and
     future statewide and departmental missions and objectives.

B.   Establish an  effective  management  and  support framework for
     the orderly growth of geographic information system technology
     within the State.

C.   Achieve and maintain  levels  of hardware, software,  and data
     compatibility in accordance with State standards and promote
     the sharing of technology,  research,  applications,  and data
     resources throughout the State of  Idaho.

D.   Encourage cooperative work among state agencies, universities,
     federal   agencies  and  private   associations  to  test,
     demonstrate,  and  complete cooperative  projects within their
     mandated responsibilities.

E.   Coordinate development  of statewide  information predicated
     upon agencies  implementing  their own geographic information
     systems.

F.   Develop  a central catalog  of  geographic information  for
     current and future agency and statewide  applications.

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Policing

It is the policy of the State of Idaho to encourage the utilization
of  geographic  information systems  when such  use  enhances  the
overall cost effectiveness of administrative  functions or improves
productivity.    It  is also  the State's  policy to  acquire,  and
support  geographic   information  systems  through  well  planned
implementation strategies.  These strategies include:

     a.   Develop and maintain data standards  for  base category
data, statewide  exchange data  and, as needed, project data.

     b.   Develop  and maintain contracts for  state agency  use
covering the  purchase of geographic information systems software
and hardware.

Management and Organizational  Responsibilities

A.   The Idaho Geographic Information Advisory Committee (formerly
     the Idaho Mapping Advisory Committee) will  be responsible for
     developing data standards for geographic information systems.

B.   The  IGIAC  will be  responsible  for  the  development  of
     specifications  for  the  contract  purchasing  of  geographic
     information systems hardware and software in conjunction with
     the  state  purchasing agent and  the state  data  processing
     coordinator.

C.   The  acquisition and  application of geographic information
     systems  hardware  and  software  will  be  accomplished  in
     accordance  with each   agency's  approved  automated  data
     processing plan.

D.   The  IGIAC  will establish  a  standing  CIS  subcommittee  to
     accomplish  the  following:

          1.  Hold quarterly meetings for information exchange and
          work status review.  Identify opportunities for exchange
          of data,  joint production  of data  or  the contracting of
          work between state agencies.

          2.  Review needs for  geographic information and determine
          data  categories necessary  for statewide  applications.
          Establish  and  maintain an inventory of each  category's
          collection  status.

          3.      Provide  GIS  informational   and  educational
          opportunities as needed.

          4.   Work with agencies to implement  the objectives of
          this policy.
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                           APPENDIX B

                 IDAHO MAPPING  ADVISORY COMMITTEE

       RECOMMENDED STANDARDS FOR DIGITAL CARTOGRAPHIC DATA
                         January  29, 1988

GEOGRAPHIC BASE DATA - This includes digital cartographic data and
information that are captured and stored as a part of a statewide
geographic data base.  These data  elements must be at a level of
accuracy which make them suitable for interchange with federal and
local government entities.  Digital Line Graph (DLG) - as defined
by the U.S. Geological Survey  (USGS), National Mapping Division is
the recommended standard for these  data.  This implies an accuracy
of plus or minus  40 feet.  This standard is used  by the USGS in
the production of their 7.5 minute quad (1:24000)  maps.  Any data
which are digitized from a 7.5  Quad map should conform to this DLG
standard.

IDAHO GIS  DATA -  Unique  state  data and  information developed for
use in Idaho Geographic Information Systems (GIS) are intended for
interchange among  Idaho  State  Agencies.   These data re "system"
specific.  Vendors represent geographic information and digitized
data in different ways. They may or may not include facilities for
the interchange  of geographic  data with other  vendor's systems.
When  the  state,  through  the  Idaho  Mapping Advisory Committee
(IMAC), establishes  a  recommended  GIS standard,  this category of
data  can  be captured  and remain in the standard  system format.
This  category  includes map data captured from  scales other than
1:24,000,  including the  1:100,000 scale.    As  DGL standard are
adopted and published  by  USGS for other map scales, they can also
be adopted by IMAC.  Until that time,  state agencies can continue
to collect data with available systems and software.

PROJECT SPECIFIC  DATA -  This  includes the collection of data to
generate a report or meet the needs of a single agency.  The data
and information  collected are  not intended  for interchange with
other agencies or government entities.  No standard is  appropriate
to the specific project or problem which is being  addressed.
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                            APPENDIX C
                       IDAHO ARC/INFO USERS
  COMPANY/AGENCY
Geographic General, Inc.
Power Engineers, Inc.
Morrison-Knudsen Co.
Potlatch Corporation
Boise Cascade Corporation
U.S. Forest Service
     Pest Management
     Boise National Forest
U.S. Soil Conservation Svc
U.S. Geological Survey
     Water Resources
University of Idaho
     Forestry
     Landscape Architecture
     Geography
ID Dept of Health & Welfare
ID Dept of Water Resources
ID Dept of Lands
Nez Perce Tribe
LICENSE
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                     CONTACT
            Andy Little
            Mary Ann Mix
            Kim Johnson
            Steve Smith
            Brad Holt
               343-1181
               788-3456
               386-5000
               799-1288
               384-7632
Joy Roberts    364-4224
Rich Jeffs     364-4211
Doug Harrison  334-1525

Molly Maupin   334-9012

Michael Scott  885-6960
Toru Otawa     885-7729
Karl Chang     885-6240
Mike Cook      334-5907
Hal Anderson   334-7888
Dave Gruenhagen334-3864
Jack Bell      843-5416
1-PC ARC/INFO License
2-Workstation ARC/INFO License
                                65

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