United States
Environmental Protection
Agency
Office of
Public Affairs (A-107)
Washington DC 20460
August 1984
xvEPA JOURNAL REPRINT
The Hidden Resource
-------
The Nation's Need
to Protect Ground Water
By William D. Ruckelshaus
Administrator, EPA
I Jpon my return to EPA in June of
'^'1983, it was clear that the nature of
the environmental threat facing our
society had changed markedly in a
decade. From its dominant focus on
conventional air and water pollutants in
the early 1970s, the agency has directed
its attention to toxic and hazardous
contaminants in all media. New
legislation to control these contaminants
has been enacted by Congress in the
form of the Resource Conservation and
Recovery Act, the Superfund law, the
Toxic Substances Control Act, the
pesticides act, and amendments to the
Clean Air Act and the Clean Water Act.
Our experience in implementing these
statutes and evidence drawn from
extensive monitoring and survey data
suggest that the contamination of our
ground-water resources constitutes a
major problem the nation has too long
neglected.
Shortly after I returned to EPA, I set up
a task force of some of our best technical
and professional experts to develop an
agency strategy for ground-water
protection. The dimensions of the
challenge were clear:
• The consumption of ground water is
increasing at twice the rate of surface
sources of fresh water and it won't be
long before most Americans will rely on
ground-water resources for drinking
water. Many regions and communities
simply could not exist without clean and
dependable ground water.
• Ground water is highly vulnerable to
contamination. Abandoned hazardous
waste dumps and thousands of poorly
regulated hazardous waste facilities are
the most prominent sources of
contamination in the public's mind.
• Hundreds of thousands of landfills,
ponds and lagoons used for storing
wastes, and storage tanks containing
gasoline and other liquids may also be
polluting much of the nation's ground
water. There are also literally hundreds
of other major sources that range from
20 million private household septic
systems to various pesticides and
chemicals. A special problem exists in
coastal areas where depleted
ground-water aquifers are threatened by
salt water intrusion. The list of sources of
ground-water contamination keeps
growing as new sources are identified
and verified.
• Specific problems associated with
ground-water contamination are among
the most complex that EPA has ever had
to deal with. Ground-water
contamination is extremely difficult to
detect and monitor, and it is not readily
amenable to conventional cleanup
measures. At present, we simply do not
know how to clean up most
ground-water pollution.
I directed the Ground Water Task Force
to produce four key outputs:
• A program to build and enhance
ground-water management institutions at
the state level;
• A program to begin to deal with
inadequately addressed sources of
ground-water contamination—in
particular, leaking storage tanks, surface
impoundments, and landfills;
• A general framework for making EPA
decisions affecting ground-water
protection and cleanup; and
• A strategy for strengthening EPA's
organization for ground-water
management at the headquarters and
regional levels.
Some of the Task Force
recommendations have already been
implemented and others are being
actively pursued. The recommendations
provide a basis for comprehensive and
effective actions at all levels of
government to protect and enhance our
nation's valuable ground-water
resources.
I have complete confidence in our
nation's ability to provide protection for
its ground-water resources. I have seen
what federal, state, and local
governments have collectively
accomplished in the past when dealing
with other environmental difficulties that
seemed as challenging at the time as this
one is now.
We will pull EPA's resources together
to address the issues involved. We
know that in most instances it is much
easier to prevent ground-water
contamination than to clean it up once it
happens.
EPA is moving forward with vital
research aimed at improving our
capabilities to detect and clean up
ground-water pollution. There's much we
still don't know about these technically
complex issues but we have made
significant advances that were
unimaginable only a short time ago.
We have every reason for optimism.
The skills and dedication of federal, state,
and local governments and the strong
national commitment to environmental
protection have served us well in the
past. They are equal to the challenges of
ground-water protection. D
EPA JOURNAL
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EPA's Ground-Water
Protection Strategy
By Alvin L. Aim
Deputy Administrator
Nlational environmental attention has
'" turned only recently to the problem of
ground-water contamination. During the
1970s, the nation's concern focused
mainly on natural resources and
pollution we could see or smell. Federal
and state programs were developed to
address surface water and air quality,
specific types of contaminants such as
pesticides, and obvious sources of
contamination such as uncontrolled
hazardous waste sites. Few knew or
really understood how seriously our
ground-water resource was being
compromised.
Public awareness of and concern about
the problem grew as reports of
contamination of drinking water wells
and well closings increased. State, local
and federal officials are responding to
public demands for enhanced protection
of ground water. These responses,
however, are hampered by a lack of
coordination between responsible
agencies, limited information about the
health effects of exposure to some
contaminants, and a limited scientific
foundation on which to base policy
decisions.
Recognizing the need to protect
ground-water quality as a national
concern, EPA Administrator William D.
Ruckelshaus asked me to create a
Ground-Water Task Force. Comprised of
senior representatives of EPA program
and regional offices, the group was
charged with developing a strategy for
EPA's ground-water protection efforts.
The Task Force began work in June 1983,
using technical papers and proceedings
from workshops and public hearings held
over a period of several years as a
foundation for their deliberations.
Preliminary conclusions of the Task Force
and a draft strategy were reviewed by
and discussed with Congressional staff,
state officials, and a wide range of
industry and environmental
organizations.
After extensive analysis of EPA
statutory authorities as well as existing
state ground-water programs, the Task
Force concluded that the nature and
variability of ground water makes its
management the primary responsibility
of the states. However, a number of
significant federal authorities exist to
support states in the effort. The group
also found that since these federal laws
were enacted at various times for
separate purposes, some inconsistencies
in regulations and decisions made under
them have hindered a cohesive approach
to ground-water protection. In addition to
EPA's authorities, the Task Force found a
variety of state and local authorities that
can be used to protect ground water.
Many states have already begun
programs in this area, and fostering the
continued development of state
capability to protect ground water was
deemed vital.
The effort to protect ground water will
be enormous, and it will require
sustained attention at all levels of
government for a long period of time.
Given the finite fiscal and human
resources that are available, it is clear
that we must direct our energies to
minimize future contamination, even as
we detect and manage contamination
associated with past activities. If we are
to focus our efforts where ground-water
contamination would cause the greatest
harm, this suggests that we should
assign highest priority to those ground
waters currently used as sources of
drinking water or that feed and replenish
unique ecosystems. In this context, EPA
developed its Ground-Water Protection
Strategy.
The strategy includes four major
components that address critical needs.
They are:
• Building and enhancing institutions at
the state level;
• Addressing problems associated with
inadequately controlled sources of
contamination;
• Issuing guidelines for EPA decisions
affecting ground-water protection and
cleanup; and
• Strengthening EPA's organization for
ground-water management.
With regard to building state programs,
EPA plans to offer several types of
assistance to states. EPA will make
existing grant funds available to help
states develop ground-water protection
programs and strategies. EPA will also
JULY/AUGUST
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provide state agencies with technical
assistance in solving ground-water
problems, and will continue to support a
strong research program in ground water
more directed toward state needs.
The second component of the strategy
is to begin addressing major sources of
ground-water contamination not now
regulated under federal law.
Underground storage tanks, including
those storing gasoline, are becoming
recognized as a possibly serious and
widespread source of ground-water
contamination. EPA's Office of Toxic
Substances has begun studying the
nature, extent, and severity of the
problem, and the agency is considering
possible regulatory approaches to ensure
proper design and operation of these
tanks. In the meantime, the agency will
issue chemical advisories to alert tank
owners about the problem and will work
with states and industry to develop
voluntary steps to reduce contamination.
Direct regulation of tanks storing
hazardous waste is also being
considered.
In addition, the agency is initiating
efforts to determine whether land
disposal facilities, including surface
impoundments and landfills handling
other than hazardous waste, require
further state or federal regulation.
Another recognized source of
ground-water contamination is the use of
pesticides; the agency is also stepping
up efforts to assess the leaching potential
of pesticides and to adopt and implement
appropriate controls.
The strategy's third component
recognizes the need for consistency in
decisions affecting ground water that are
made by EPA's regulatory programs. In
thinking about building consistency in
these requirements, we encountered two
primary questions:
• How should we define the resource to
be protected?
• To what extent should it be protected?
We have proposed guidelines which
divide ground water into three classes,
based on the use of the water and its
vulnerability to contamination. Under the
guidelines, each would receive a different
level of protection.
The highest level of protection is
reserved for "special ground waters."
These special ground waters,
characterized as Class I, are particularly
vulnerable to contamination because of
their hydrogeologic characteristics. To
qualify as Class I, the ground water must
also meet one of two other requirements.
It must either be an irreplaceable source
of drinking water for a substantial
population, or it must provide water for a
sensitive ecological system. To prevent
contamination of Class I ground waters,
EPA will initially discourage by guidance,
and eventually ban by regulation, the
siting of hazardous waste facilities over
them. The agency will also place
additional restrictions on existing land
disposal facilities in those areas. Further,
agency policy will be directed toward
restricting or banning the use of those
pesticides which are known to leach
through soils and are a particular
problem in ground water. EPA's policy
for cleanup of contamination will be
most stringent in these areas, generally
requiring cleanup to background or
drinking water levels.
Class II includes ground waters that are
current or potential sources of drinking
water or have other beneficial uses.
These ground waters, which comprise
the vast majority of ground water in the
nation, will receive levels of protection
consistent with levels now provided for
under EPA's existing regulations. In
addition, where ground waters are
vulnerable to contamination and are used
as a current source of drinking water,
EPA will propose banning the siting of
new hazardous waste facilities. EPA
policy will require contaminating facilities
in Class II areas to clean up to drinking
water quality or background levels, but
exemptions will be available to allow a
less stringent cleanup level or plume
management effort under certain
circumstances when protection of human
health and the environment can be
demonstrated.
Class III — or ground waters that,
because of natural or man made
contamination levels, are not considered
potential sources of drinking water and
which have limited beneficial use — will
receive less protection than the other
classes. However, technology standards
for hazardous waste facilities would
generally be the same. If such a facility
should leak, it could be granted a waiver
to clean up to a less stringent
concentration limit for contaminants
since the ground water would already be
of limited value. However, such waivers
would not be available to facilities which
had caused the contamination that
precluded future use of the ground
water. EPA's Superfund program will not
focus its activities on protecting or
improving ground water that has no
potential impact on human health or the
environment.
To improve the consistency and
effectiveness of EPA's current
ground-water programs, the guidelines
will be translated into specific
requirements in each of the agency's
relevant program areas. Many of these
programs are delegated to the states,
and for most programs states must
demonstrate that their efforts are "no
less stringent" than the federal program.
However, in implementing these
guidelines, EPA will provide as much
flexibility as is possible under existing
statutes.
The final component of the strategy is
strengthening EPA's organization to
focus on ground-water protection. We
have formally established a new
headquarters Office of Ground-Water
Protection within the Office of Water. It
will give the agency the kind of
leadership and coordination it has long
needed to make ground water a genuine
priority. The Office will direct the
development of EPA policies and
guidelines for ground water, and
coordinate the relevant activities of
program offices. In addition, we are '
establishing ground- water staffs in each
of our regional offices, whose function it
will be to assist in ground-water policy
development and implementation, and
coordinate planning and technical
support for states devising ground-water
strategies of their own.
I consider EPA's Ground-Water
Protection Strategy an extremely
important step in enhancing protection of
a vital resource and achieving
consistency in regulatory requirements.
The strategy does not propose simple
solutions to the complex problem of
protecting our nation's ground-water
supplies. Rather, it provides a framework
for a strengthened federal-state
partnership that ensures the most
effective use of our existing and future
resources for protecting ground-water
quality.
EPA's Ground-Water Protection
Strategy gives us the tool for protecting
this important resource and making
sense out of our many programs that
affect ground water. The strategy is now
driving a number of our regulatory
programs toward sensible goals. The
strategy does not propose simple
solutions to the complex problem of
protecting our nation's ground-water
supplies. But it does take us a long way
toward rationalizing our programs,
dealing with unaddressed ground-water
problems, and creating the kind of
state/federal partnership that is necessary
for effective action. D
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Coordinating Protection
Efforts
An Interview with Marian Mlay
In the following interview, Marian Mlay,
director of EPA's Office of Ground-Water
Protection, discusses the ground-water
problem and reviews EPA's efforts to
help deal with it.
Q
When did the country begin to
realize it has a problem with ground
water?
A
The country has been aware for
about the last five years, since some of
the particular incidents of contamination
in New England and New Jersey.
People in the environmental
professions understood earlier that there
were problems. It's just that ground
water did not become a public issue until
some particular instances of
contamination became widely known,
partly because of our new ability to
measure ground-water contamination at
much lower levels.
Traditional contaminants, such as
microbiological contamination from
septic tanks or outhouses, and certain
natural contaminants have been known
for a long time. But it's the new
awareness of manmade chemicals that
are toxic and getting into ground water
that has really heightened public
awareness of the problem.
Q
What is the nature of the
ground-water problem?
A
We're finding ground water
containing relatively high levels of
manmade contaminants. They are
affecting both public and private drinking
water supplies, and drinking water is the
most direct transmitter of pollution and
contamination to people.
People are very concerned about
surface water because they see it and
smell it and have to be around it. By and
large we expect to treat surface water
when we use it for drinking water. But
water from private wells and many
smaller public water systems isn't
treated. Now, with the more
sophisticated methods of measurement,
contaminants are being discovered in
these sources. There is concern about the
public health effects and about the cost
to individuals and to the public water
systems of treatment.
We have also become aware of more
and more kinds of activities that will
cause ground-water contamination. In
addition to large hazardous waste
facilities, there are gasoline storage
tanks, several million of which are
scattered around the country. There are
pesticide and fertilizer applications, and
highway de-salting. Ground water is
being spoiled by many different incidents
of contamination that come from
relatively benign or innocent looking
activities.
Q
What would you say the major
challenge is at this point—protecting
clean ground water, or cleaning up
contaminated ground water?
r\ Both. I don't know that we can
really separate the two.
Clearly in our ground-water strategy
we want to place more emphasis on
protection, but it's easy to say, "Let's
protect everything, let's protect all
ground water, let's make sure that it's all
pristine." We know that's extremely
expensive and very difficult or
impossible.
We can't stop all fertilizer use and we
can't rip up all the gasoline stations in
the country, so protection becomes a
question of assessing the use of that
ground water and protecting it for those
uses while trying to divert potentially
polluting activities where possible to
areas where ground water will not be
affected.
Q
Is cleanup just as difficult?
f\ In ground-water cleanup we have
a major technical challenge. We just
don't know how to do it yet. I'm using
the term cleanup in the context of
turning an aquifer (an underground
stratum containing water) back into its
original, possibly pristine state.
The typical way of trying to restore
ground water is to remove the source of
contamination, even to the point of
digging out contaminated soils. But
you've got to put the spoiled material
somewhere, and it will still have the
potential to contaminate something else.
JULY/AUGUST
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Once the source of the contamination
has been eliminated, usually the water is
pumped out, treated, and pumped back
again. Even in what I'd call some simple
cases involving a contaminant that's
fairly easy to get out of water, like
trichloroethylene (TCE), they've been
pumping and treating for five years and
they've still not gotten it all out. (TCE is a
volatile organic chemical commonly used
as an industrial solvent.)
So the problem of actually restoring
aquifers is not solved technically. The
techniques that exist are extremely
expensive and can take forever.
There are other techniques for
protecting public health from
ground-water pollution: containment
approaches. For example, you can put a
well at the end of a plume of
ground-water contamination spreading
from a particular source and pump it out
so that the plume doesn't move any
farther. You can prevent the pollution
from moving into a well system, for
example.
There are other ways of protecting
drinking water wells from contamination
without cleaning up all the polluted
ground water. Because of the expense of
complete cleanup, we may have to
consider them in many cases.
Some very interesting research is
underway regarding ground-water
cleanup, such as stimulating or injecting
microbes underground to break down
chemicals more rapidly, but we're
probably five or ten years from being
able to use it.
Q
Do you believe that we've got a
crisis on our hands with polluted ground
water?
A No. I think we have a long-term
problem, one that is not going to go
away easily, but it can be dealt with and
we need to do it. It will become a crisis
only if we ignore it.
U How did you get involved in the
ground-water issue?
A Two days after I began work with
the EPA Office of Drinking Water in late
1979 as Deputy Director, my boss, Victor
Kimm, and I were called to the
Administrator's office. The Administrator
was very concerned about ground water.
Those were the days when Superfund
legislation was being considered. Various
legislation had been proposed regarding
aspects of ground-water pollution but no
one was really thinking about the whole
resource.
The Administrator saw the patchwork
which was beginning to develop and
wanted to prevent it. So he charged us
with developing a ground-water strategy
and, I must admit, I walked out of the
office and looked at Victor Kimm and I
said, "What's ground water?" I really had
no background in it at all. So it was an
educational process for me as well. I've
become very much interested and have
seen the issue through since then.
Lz What is the significance of
Administrator Ruckelshaus' action
creating an Office of Ground-Water
Protection?
r\ It's extremely significant. Of all
the comments that we have been getting
on the agency's ground-water strategy
from people that we have asked about it
— environmentalists, industries, state
people — they're unanimous that setting
up this office is extremely important for
EPA. They see it as a focal point within
the agency to heighten awareness of
ground water as an important issue, to
coordinate policy across the agency, to
work with other federal agencies, and to
work with the states.
Many people are interested in this
issue and are grappling with it from their
own perspective. They have been looking
for leadership from EPA on the question,
not so much in the form of regulations or
guidelines, but as a resource to help
them work through their problems. I
think we have a wonderful opportunity to
heighten awareness and work with
experts throughout the country to help
resolve the questions of how to protect
this very complex resource.
Q
What is the purpose of EPA's
strategy for protecting ground water?
A It has several purposes. The basic
one is to say that EPA is truly concerned
about ground-water protection, about the
resource itself. Even though the agency
doesn't have direct authority as it has
with surface water and air, it does
administer statutes that affect ground
water. We want to recognize more
formally that responsibility.
The strategy is designed to clarify the
relationship between EPA and the states
on the issue of ground-water protection.
In ground-water quality the question is,
how can we work together within a
framework that recognizes both the basic
state responsibility for ground-water
protection and the major federal program
efforts to deal with specific kinds of
contaminants like pesticides, hazardous
waste facilities, underground injection
wells, and so on? We're attempting to
clarify these roles.
The strategy is also an attempt to
express our concern about some sources
of contaminants which aren't being
addressed, and to define the extent of
the problem and an appropriate federal
response. Contamination from
underground storage tanks is a good
example. We're getting a lot of
information that they are a major
problem. Some states are doing some
interesting work in that area, but the
question we are addressing is, when
does a problem like leaking tanks
become of national import and require
our action?
I think finally the strategy is an attempt
to get our own act together within EPA.
As we looked at the various EPA
programs to deal with ground water, we
found that they all deal with it differently.
They define ground water differently;
they protect it differently; the kinds and
extent of regulations are different. The
strategy is an attempt to state a general
EPA policy on ground-water protection
and then, over time, to make our own
programs conform to that policy. In that
way, both the regulated community and
states will have a much more consistent
set of requirements to deal with as they
implement our programs.
\J. Drafts of the strategy have been
criticized as relying too heavily on the
states to protect ground water. What is
your reaction to that?
r\ We are dealing within the existing
legal framework. The states have the
major responsibility in ground-water
protection. The federal government has
some major responsibilities as well but it
does not cover every potential source of
contamination, and I'm not sure that it
should. The critics may feel that the
federal government can solve most
problems. But in the case of ground
water, many of the protective actions that
would have to be taken do involve land
use, which traditionally in our country
has been under state and local
prerogatives to control. I think that it's
quite possible for us to forge a
partnership with the states which
respects those prerogatives and yet has
an active and productive federal role.
Q
How will your office coordinate
the various parts of EPA in carrying out
the ground-water strategy?
r\ That's a good question. It doesn't
just involve EPA; other federal agencies
have a major interest in this. The states
are extremely interested and feel that
they have to be a part of the action.
Industry groups are obviously very
interested; the environmentalists are very
interested, and so I'm going to have a
large number of group activities.
We've set up or are in the process of
setting up several coordinating
EPA JOURNAL
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committees. It may sound bureaucratic
but I think it's the only way we can do it.
One is an oversight committee of the
four assistant administrators at EPA with
ground-water programs. Jack Ravan is
the chair and we have Lee Thomas,
hazardous waste and emergency
response; Bernard Goldstein, research
and development; and John Moore,
pesticides and toxic substances. The
committee also includes two regional
administrators, Michael Deland of Region
1 and John Welles of Region 8. This
committee will provide policy direction to
the Office of Ground-Water Protection. It
will also give us an opportunity to deal
directly with the principal operating
assistant administrators in identifying
their major concerns and in directing our
work so that it's beneficial to them. Most
of the things which we are attempting to
do are designed to enhance their efforts
in ground water. The Office of
Ground-Water Protection is not going to
be carrying out direct programs. It is a
policy development and coordination
office and it's going to be very small.
Regional administrators are also
setting up small regional ground-water
coordination offices in each region with a
function comparable to ours.
We're setting up a steering committee
Facts About Ground Water
What is ground water?
Ground water is that part of underground
water that is below the water table.
Ground water is in the zone of saturation
within which all the pore spaces of rock
materials are filled with water.
What is an aquifer?
An aquifer is a body of permeable,
saturated rock material capable of
conducting ground water and yielding
economically significant quantities of
water to wells and springs.
How much ground water
does America have?
The United States has approximately 15
quadrillion gallons of water stored in its
ground-water systems within one half
mile of the surface.
How much ground water
does America use?
Annual ground-water withdrawals in the
United States are on the order of 90
billion gallons per day, which is only a
fraction of the total estimated water in
storage. This represents about a three-fold
increase in American ground-water usage
since I960. Most of this is replenished
through rainfall and offsets the hydraulic
effects of pumpage, except in some
heavily pumped, arid regions of the
Southwest.
American ground-water use is
expected to rise to about 95 billion
gallons a day in 1985.
What are the major uses
of ground water?
Public drinking water accounts for 14
percent of ground-water use in the U.S.
Agricultural uses such as irrigation (67
percent) and water for rural households
and livestock (6 percent) account for 73
percent of American ground-water usage.
Self-supplied industrial water accounts
for the remaining U.S. ground-water use.
What percentage of
American drinking water
comes from ground water?
Approximately 50 percent of all
Americans obtain all or part of their
drinking water from ground-water
sources.
Where is America's ground water
most heavily concentrated?
The richest reserves of American ground
water are in the mid-Atlantic coastal
region, the Gulf Coast states, the Great
Plains, and the Great Valley of California.
What is the largest
American aquifer?
The Ogallala aquifer, which extends from
the southern edge of North Dakota
southwestward to the Texas and New
Mexico border, is the largest single
American aquifer in terms of
geographical area.
What are the most
important American aquifers?
The most important American aquifer in
agricultural terms is the large
unconsolidated aquifer underlying the
Great Valley of California. The most
important ground-water sources of public
drinking water are the aquifers of Long
Island, N.Y, which have the highest per
capita usage concentration in the U.S.
(see story on page 30).
which involves all the office directors at
EPA: Office of Drinking Water,
Superfund, etc.—all of the office directors
who have substantial ground-water
responsibility. They will be our
day-to-day operating contacts, and we
are even now working very closely with a
number of them. We'll be setting up a
group of state officials, a state-EPA
liaison group, so that we can get their
very direct involvement. They will
represent the major state interests in
ground-water protection.
We're setting up an interagency
committee of the various federal
agencies such as the U.S. Geological
Survey and the Nuclear Regulatory
Commission and the Departments of
Interior, Defense and Agriculture. They
see the strategy as having potentially
substantial consequences for their
programs. By and large we have gotten
very enthusiastic support from this
group.
We're also going to be having periodic
briefings and meetings with
environmental groups and industry
people and we hope to coordinate with
them in that way.
By working with these various groups
on selected areas of concentration, we
think we can affect what's happening. It
will be a challenge. Obviously we can't
coordinate with everything that goes on
within the agency on ground water.
\J. What difference do you think the
ground-water strategy will make in the
long run?
A Ground water will be a major
resource for EPA's attention, just like
surface water and air. I think that the
states and others will be able to help us
to use the strategy as a way of focusing
our mutual concerns and giving as much
attention to ground water as we do to
those other resources. I think we can
help build a public awareness and a
foundation for cooperative action.
Q
What kind of help will EPA be
giving the states in ground-water
protection? And how will this differ from
the way it has been?
r\ EPA has done a fair amount in the
past, particularly through the regional
offices. It's a question of more and
better.
Certainly, one of the kinds of help that
we have given is grant support. Our
strategy contemplates enhancing that
through regions working with states on
their ground-water problems and
encouraging them to use our existing
grant resources to focus on the problems
that they see and to develop their own
state plans and strategies.
JULY/AUGUST
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We're also interested in enhancing our
existing research programs so that they
are directed toward the kinds of
problems which states see. We're going
to try to coordinate our research
planning efforts and state interests a lot
more closely than we have in the past.
We're concerned about enhancing
technical assistance to states. The states
certainly are able to hire some expertise;
they're able to buy it through consulting
firms. But EPA has some very unique
people. Some of our regional and
program people have expertise which we
hope to make available to the states
when they have special problems.
I am thinking of one situation in which
Maine was suddenly confronted with
permitting a phosphate mine. They had
never dealt with phosphate mining in
that state. Some people from our Atlanta
regional office who had permitted
phosphate mines and some people from
the state of Florida with similar
experience hopped on a plane to Maine
and spent several days providing
technical assistance on that particular
ground-water issue. That kind of help is
extremely valuable. We will be trying to
identify resource people within the
agency who can provide that kind of
consultation.
Q
Q
How does EPA plan to deal with
sources of ground-water pollution which
are not covered by federal law? One of
the examples is underground storage
tanks.
r\ Our primary emphasis is in
helping the states develop the capacity to
deal with ground-water problems
themselves by encouraging them to do
the necessary planning and providing
useful information. We can also help
insure that cleanup technology is
transferred from state to state through
shared experiences.
The second approach is to consider
whether particular problems may require
further federal activity. Underground
storage tanks are one area we are
looking at. We're trying to get a better fix
on the extent of the problem through a
fairly substantial survey which is now in
the final phase of design by the Office of
Toxic Substances. We're assessing the
extent of current control measures.
Should we conclude that the problem is
big enough for federal action, then we
are going to have to tackle it. We do
have authority under the Toxic
Substances Control Act and several other
acts to take various steps, such as
enforcement under the Safe Drinking
Water Act and the Resource Conservation
and Recovery Act.
What do you expect to
accomplish during the next year?
r\ I would like to get the
ground-water strategy out in public. I
want to have set in place the Office of
Ground-Water Protection and the
regional ground-water offices so that
they are well-functioning institutions.
We're well on our way to that. I would
like to see as a part of that a much closer
working effort between our regions and
states in enhancing state ground-water
activities. We do have some state grant
guidelines, but to help that along I hope
to have ground-water strategy guidance
in place, adopted by our various EPA
programs within the next year. We're
projecting to have draft guidelines within
the next six to nine months.
I hope that within the next year we will
be able to develop a ground-water
monitoring strategy which will provide a
better idea of what we and others, such
as states and the U.S. Geological Survey,
are doing to enhance knowledge of the
extent of contamination and the nature of
the resource.
Certainly, I'd like to see us have a very
good handle on the storage tank
problem. I don't think that all the studies
we're planning will be completed by
then, but we should have them well
underway.
We are planning with the Office of
Research and Development to establish
an outside top level scientific review of
our ground-water research. By the end of
the year we should have a major report
from this group on the directions we
should be taking in ground-water
research.
Q
What process has been followed
in developing the ground-water strategy?
r\ The strategy has been under
development since late 1979. We had a
pair of workshops in June 1980, with
participants from states, industry,
academia, environmental groups, and
local government. That group of 80
people made the fundamental
recommendations that we've been
discussing. We had a public review of the
draft strategy; we've had public hearings
and gathered comments from hundreds
of people that helped us put that early
strategy together.
Since Bill Ruckelshaus came in June of
last year, we've put together an internal
task force to review the results of that
earlier work; to review what's happened
since, including the passage of
Superfund; and to consider a number of
implementing actions. We put together a
report for the Deputy Administrator and
went through several months of internal
debate. We had several meetings with
Deputy Administrator Al Aim and
assistant administrators. Our task force
went through the draft strategy in
considerable detail and finally came up
with a document that we all agreed on.
We briefed industry, environmental
groups, states, Congress and other
federal agencies on our thinking.
We got some comments and ideas
from those discussions, incorporated
them back into the strategy, and came
out with a document in January. We
circulated it among key groups: trade
associations interested in ground water,
organizations representing states, and
environmental groups. We sent copies to
Congress, to other federal agencies. Our
regional administrators sent copies to the
governors and other key state officials
and met with them to gather their
comments.
Aim met with representative state
officials here in Washington to get their
comments. We had another series of
meetings with other federal agencies.
Now we have arrived at a final document
which reflects all this input.
\J. Is there any special comment that
you would like to make? '
r\ One of the questions that comes
up so often is, why hasn't the job already
been done, and why can't we do it fast? I
recall the book, In Search of Excellence,
in which the writer commented that
really good national firms take about ten
years to bring out a new product line. A
ground-water strategy is at least as
complex.
We need to think of ground-water
protection as a long term effort which will
evolve as our understanding of the
resource and related technologies
improves and as public understanding
of the issues crystallizes. D
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EPA JOURNAL
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A State/EPA Partnership
by Jack E. Ravan
Assistant Administrator for Water
Over the past ten years, the states and
EPA have worked together to bring
about a remarkable reduction in pollution
of rivers, streams, and lakes. In working
to clean up surface waters, we forged a
partnership based on mutual respect and
an understanding of each other's
capabilities. I have seen this partnership
from both sides. I have served in a state
office, an EPA regional office, and now at
EPA headquarters, and I can testify to the
importance of coordination. It produces
results.
A new challenge—the protection of
ground water—now confronts many
environmental and other agencies at the
state and federal level. If we are to be
successful in controlling and preventing
ground-water contamination, we must
expand the state/EPA partnership which
serves so well in controlling surface
water pollution and in other program
areas.
EPA's ground-water protection strategy
is an important step toward building a
state/EPA partnership for ground-water
protection. In its early assessments of
ground-water issues and programs, EPA
found that states have the clearest, most
direct authorities to protect ground-water
and that many states are developing
comprehensive ground-water programs.
The EPA strategy recognizes clearly
that states are responsible for
comprehensive management and
protection of ground-water resources. In
developing these programs, states assess
the nature and extent of ground-water
contamination problems, develop
appropriate pollution control programs,
and implement control programs on an
ongoing basis.
EPA's primary responsibility is to
ensure that national environmental laws
are implemented fully. Many of these
laws — including the Safe Drinking Water
Act, the Resource Conservation and
Recovery Act, and the Superfund act —
have substantial ground-water
protection provisions. EPA is committed
to providing states with the methods and
means to carry out these federal
programs and to assist states in
from land cfo.
developing the institutional capability to
design and implement comprehensive
ground-water protection programs,
including protection from pollution
sources which fall exclusively within
state jurisdiction.
Over the next several years, EPA will
provide states with technical and
program development assistance, will
assure that states have maximum
flexibility in the use of grant funds to
develop ground-water protection
programs, and will direct research and
development activities to specifically
address state needs. Each of these
activities is described briefly below.
Technical Assistance
EPA will provide states with assistance in
addressing technical and program design
issues encountered in development of
ground-water protection programs. At
the EPA headquarters level, we plan to
support technology and information
exchange between the regions and
states. EPA regions will play an
important and expanded role in assisting
individual states with particular problems
on a case-by-case basis. EPA regions will
assist states in the following areas:
• analysis of technical or scientific
problems,
• design of state ground-water
protection programs,
• management of ground water-related
data,
• seminars and conferences for state
staffs, and
• consultation on issues concerning
interstate aquifers.
JULY/AUGUST
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EPA is just beginning to explore the
range of mechanisms available to deliver
technical and program development
assistance to states. Ideas being
considered include: exchanges of
personnel under the Intergovernmental
Personnel Act; designation of "national
experts" in various aspects of
ground-water protection; increased
support of scholarships for study in
critical ground-water fields; and regular
state/EPA conferences or seminars on
pressing ground-water issues or technical
problems.
Grant Support
EPA is encouraging states to make full
use of existing grant programs to
develop ground-water protection
strategies and programs. The work EPA
will support is comparable to activities
begun over the past several years by
states that are already developing
ground-water protection programs and
will include:
• development of an overall state action
plan or strategy to set ground-water
protection goals and to coordinate
ground-water programs in various
institutions;
• identification of legal and institutional
barriers to comprehensive ground-water
protection programs;
• development of general ground-water
programs and design of source or
contaminant- specific ground-water
protection programs; and
• creation of a data management system
to increase the accessibility and quality
of information needed to protect ground
water.
Since a number of states have already
completed some of these tasks, the
agency will also support activities to
assess the ground-water resource (e.g.,
mapping, selected monitoring), which are
presented in a broad context indicating
how they fit into an overall state
ground-water strategy.
Funds from a range of existing grant
programs are eligible to support
ground-water program development
activities, including grants under sections
205(j), 205(g), and 106 of the Clean Water
Act, the Underground Injection Control
program grant under section 1443(b) of
the Safe Drinking Water Act, and the
program grant under section 3011 of the
Resource Conservation and Recovery Act,
if RCRA program commitments are
completed.
EPA regional administrators will work
with governors to direct grant support to
the state agency or program with the
most complete authority and capability to
undertake or continue statewide
ground-water strategy and program
development. Regional administrators
will also work with governors in
determining the most appropriate grants
and levels of funding for ground-water
programs in order to assure effective
coordination among various state
agencies involved in ground-water
protection.
Research and Development
EPA conducts a research program to
provide a broad range of data and
information for use by decision-makers
concerned with ground-water protection.
The program is directed toward
improving monitoring technology,
prediction and assessment tools, and
aquifer cleanup methods.
In the near future, EPA will establish a
group of ground-water research experts
under the Science Advisory Board to
advise the agency of ground-water
research needs. The research group will
include state officials and one of the
tasks of the group will be to direct
research and development activities
more specifically toward designing the
tools and methods identified by states as
needed to protect ground water.
Other research programs also
contribute to the scientific bases on
which decisions about ground-water
protection are made. For instance, a
significant portion of the research on the
health effects and removal of drinking
water contaminants is directed toward
chemicals found in ground water.
Research to develop and evaluate
technology for control of sources (such
as surface impoundments) and
improvements in methodology for
analyzing water samples for trace
constitutents also contribute to our
scientific capability. EPA will work to
assure that findings of research efforts
are made available to states in a useful
and timely fashion.
EPA Organization
In addition to assistance directed to
states, EPA is taking steps to improve
coordination of its own programs. The
ground-water protection strategy
provides for developing
guidelines to improve consistency among
EPA programs related to ground water.
Many states have chosen to implement
EPA programs and have found that
inconsistencies in procedural and
substantive requirements have made
coordination of EPA and existing state
programs difficult.
States were also frustrated because
many voices in EPA seemed to speak to
ground-water issues. This problem
should be alleviated by the recently
established Office of Ground-Water
Protection that will speak for the agency
on overall ground-water issues and
policies. The agency will also form a
State Liaison Group to advise senior EPA
officials on ground-water programs and
issues. In addition, each EPA regional
office will establish a point of
coordination for ground-water programs,
information, and activities. By setting a
clear course for our own ground-water
program, EPA is a more reliable partner
for the states.
In my years of public service I have
had the privilege of serving in both state
and federal governments. I have seen
agencies try to tackle a job alone and I
have seen them set out to work
cooperatively in the intergovernmental
system. Almost invariably, a partnership
among agencies brings the best result.
While we may not always agree on a
particular issue, it is important that we
work together, share our views, and
express our differences. The EPA
ground-water protection strategy will offer
states and EPA an opportunity to address
a serious problem of mutual concern. I
will make every effort to assure that
states receive the support and
cooperation they need to protect ground-
water, n
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EPA JOURNAL
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From the States'
Point of View
by Governor Bruce Babbitt
(D-Arizona)
Protecting the quality of our
ground-water resources is one of the
most difficult and complex environmental
and public health issues of this decade.
Since we don't fish or swim in ground
water most traditional approaches to
water pollution control do not apply, and
we've assumed that it will continue to be
available, in a pristine condition, for
drinking and other purposes. Today, we
know that ground-water quality has
deteriorated in many areas, with 40
states already having documented
instances of serious contamination.
The importance of protecting this
resource cannot be overstated. Over 50
percent of us rely upon ground water as
our source of drinking water. Ninety-five
percent of all rural households depend
on ground water. The withdrawal of
ground water has tripled since 1950 and
now accounts for a quarter of all fresh
water used. These uses include irrigation,
drinking water, and industrial
applications.
At the same time, the desirability of
preventing contamination, rather than
relying on corrective measures, is clear.
Arizona, in developing its ground-water
quality program, compared annual
preventative and mitigation costs for
selected industrial impoundments,
surface mining activities, wastewater
treatment plant removal processes, and
landfills. That study showed that in every
case the annual costs of prevention were
from six to ten times less than the cost of
cleaning up the contamination. The
preventative approach is economically
justified, even without considering the
less easily quantifiable and more
insidious public health effects arising
pfrom contamination of ground water.
While the value and vulnerability of
'ground water and the state of technology
make it clear that protection of the
resource and mitigation of existing
contamination are in our best interest, a
number of factors makes protection a
difficult task.
(Governor Babbitt is the Chairman of the
National Governors' Association
Subcommittee on Water Management. The
subcommittee is developing
recommendations for state ground-water
protection.)
The Difficulty
of Protection
Undoubtedly the most important factor
which makes ground-water quality
protection difficult is the variability of the
resource itself. In some states, ground
water is ubiquitous — plentiful supplies
occurring in large shallow aquifers
encouraging development. In other areas,
and not necessarily distant locales,
ground water may occur in small
quantities or at depths which preclude
economic use. Aquifers may be confined,
or may flow into each other in complex
hydrologic systems. Subsurface
conditions may be highly permeable, or
may effectively prevent recharge. The
rate of movement of ground water also
varies from inches to miles per year.
Like any other resource, ground water
changes with use. A vast range of human
activities affects ground-water quality.
While the number of sources of
contamination makes it difficult to
achieve comprehensive controls, each
source will have a potentially different
impact on the ground-water resource,
depending on hydrologic and geologic
conditions at the site, as well as the rate
and nature of the discharge, and the
facility design. Contaminants may move
quickly to ground water, or may take
JULY AUGUST
-------
years to reach the aquifer. Once in
contact with ground water, similar
variations in transport rate occur.
Finally, the art and science of
ground-water management are relatively
young. Historic involvement in the
development and protection of surface
waters has produced relatively plentiful
expertise and considerable data.
Unfortunately, this is not the case when
considering ground water. No common
monitoring system exists, and, while a
number of states have mapped their
aquifers and have sufficient data to
determine the location and quality of
their ground-water resources, most states
do not have a comprehensive
understanding of ground-water
occurrence and conditions.
In spite of these difficulties, states are
progressing in their efforts to address
ground-water quality. Like the resource
itself, protection systems and goals vary.
State Efforts
Whether aggressively pursuing
comprehensive programs or beginning to
examine the need for new regulatory
efforts, states are focusing on
ground-water quality protection. Activities
focus on several broad approaches that
are not mutually exclusive:
• Classification of aquifers by quality,
vulnerability, or use;
• Control of contamination sources on
either a site-specific basis, or by
discharger class;
• Development of numeric or narrative
standards for ground-water quality; and
• Controls on land use, with emphasis
on facility siting or protecting of sensitive
recharge areas.
While these broad approaches form the
basis for protection programs, other
factors bear heavily upon ground-water
program development. Soils and
geology, water yield, and linkages
between surface and ground water all
must be considered in planning for
protection of this resource.
In considering these factors and
combining them into regulatory or
management strategies, states must
make numerous judgments about current
and future users, the relationship
between statutory systems for allocation
and quality protection, the willingness of
an informed publip to assume risks, and
the wisdom of depending upon the
development of new technologies for
mitigation of resource damage.
Population density, levels and types of
industrial activities, and overall
dependence on the resource exert major
influences over the design of protection
systems.
A quick review'of existing systems
reveals that states have addressed these
considerations in formulating protection
strategies. Maine and New Hampshire
have, across-the-board, designated their
aquifers as drinking water sources. The
New Jersey system combines
classification standards and source
controls. Wisconsin has instituted a
non-degradation policy, while
Connecticut, North Carolina, and
Wyoming have intricate classification
systems.
Arizona's ground-water quality
protection system takes a site-specific
approach to protection of current and
future uses of ground water. Broad
narrative standards which focus on use
protection will be applied through a
system of permits on specific sources.
General permits, to guide classes of
activities which are of concern in their
cumulative effects, as well as area
permits which would cover a number of
similar discharges in a specific location,
are also proposed.
The general belief that states possess
the legal authority to control
ground-water quality requires careful
review. While the police powers of states
would presumably suffice in combination
with general water quality statutes,
attempts to implement aggressive
protection strategies have triggered
successful legal challenges. A thorough
examination of the extent of state
jurisdiction and subsequent legislative
action are essential to the pursuit of
comprehensive state protection.
Putting aside the question of legal
authority, it is clear that states have a
basic responsibility for protection of
ground-water resources. Less obvious,
but as important, is the role which local
governments can play in the
development and execution of state
programs. Both the New Jersey Pine
Barrens and Long Island, N.Y., are
models of local land use approaches to
ground-water quality protection. Bills in
the last two sessions of Congress offered
the opportunity to enact, nationwide, a
voluntary state/ local planning and
source control process relying on the use
of zoning and designation of sensitive
areas. Local and regional governments,
depending on their interest, resources
and expertise, cannot be ignored as
potentially valuable components of
protection programs.
The federal government also plays a
significant role in ground-water
protection. Federal activities directly
influence states and the condition of the
ground-water resource.
Federal Efforts
The influence of federal agencies on
ground-water quality arises from a
variety of existing regulatory programs,
the collection and interpretation of data
on specific ground-water resources and
related research and development, as
well as in the operation of federal
facilities.
The federal regulatory picture is a
patchwork of controls on sources and
quality-related uses of the resource. The
Resource Conservation and Recovery Act
is the most important federal statute
which seeks to minimize ground-water
contamination. The Act confers broad
authority to EPA (and through EPA to the
states) for hazardous waste management
and solid waste controls, including a
variety of permit standards as well as
authority to "restrain imminent hazards."
The Clean Water Act offers a regulatory
framework which can protect ground
water as that resource is related to
surface water. The Toxic Substances
Control Act and the Underground
Injection Control portion of the Safe
Drinking Water Act also regulate specific
sources of contamination. Other portions
of the Safe Drinking Water Act, in
regulating quality of water at the tap, can
be used to drive ground-water protection.
And finally, the Superfund program is
already addressing the mitigation of
ground-water resource damage.
EPA, in the preparation of its
ground-water strategy, has already
acknowledged that statutory authority
could be more effective if it were better
focused and less hampered by
inconsistencies in terms and application.
The process for achieving that goal will
be difficult, and the agency should be
commended for embarking on those
efforts. The involvement of states in the
process is crucial if changes in the
operation and scope of programs are to
be accomplished.
Federal research, data gathering, and
technical and financial assistance are all
crucial to the development of effective
state protection programs. Immediate
needs include:
• Expedited EPA development of
drinking water standards for nationally
significant ground-water contaminants
and, in the interim, the provision by EPA
of guidelines to assure consistency
among states in health protection and
enforcement actions;
• Development of additional methods to
assess contamination with emphasis on
both detection at the source and on the
quality of drinking water;
• Development of health and
environmental effects data for various
levels of contaminants in ground water;
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EPA JOURNAL
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• Elaboration of risk assessment and risk
management methodologies for ground-
water contaminants; and
• Assistance in aquifer mapping, and
development of ground-water modeling
capabilities.
Accelerated remedial action at known
sources of contamination will also assist
in driving the development of new
treatment and restoration technologies.
Finally, the federal government, in
operating federal facilities including
military bases, must move aggressively
both to eliminate ground-water
contamination sources and undertake
cleanup activities. This area is ripe for
acceleration.
Left begging at this point is the
question of the need for overarching
federal criteria or goals for ground-water
quality protection. It is on this question
that the most interesting public policy
debate affecting ground-water quality will
turn.
The nature of the ground-water
resource and the large variations in
emphasis and structure among existing
state ground-water programs tend to
argue against the promulgation of a
national ground-water program. States,
with their inherent responsibility for
water allocation and protection activities,
jealously guard the right to control this
resource. But admittedly the pattern of
state activities is uneven. Citizens of two
different locales should not suffer as a
result of different levels of health
protection.
Yet the ability of national guidelines
and criteria to produce accelerated
ground-water protection is also
questionable. Inaction cannot be
attributed only to insensitivity. Limited
resources and the complexity of existing
environmental programs inhibit the
development of new protection
programs.
While the jury is still out on the need
for a federal program, much can be done
to apply existing authorities and
resources throughout government more
effectively. We must work with the tools
which are currently available, and resist
any attempts to retreat from protecting
this most valuable resource, u
Protecting Ground-Water
Five States Report
What particular ground-water problems
do various states face? How do they
handle them? EPA Journal asked these
questions of ground-water officials in five
states. Here are their reports:
Robert E. Moore
Assistant Deputy Commissioner
Connecticut Department
of Environmental Protection
Providing safe drinking water to
Connecticut citizens is the primary goal
of the state's ground-water management
program. Approximately one-third of our
3,100,000 people rely on ground water
for their water supply source. Twenty
percent rely on individual household
wells for drinking water without any
benefit of routine water monitoring to
assure potability.
By March 1, 1984, the Department of
Environmental Protection had
investigated 493 well contamination
problems. Of those, 380 were private
domestic wells; 56, public water supply
wells; and 57, commercial wells. Most
problems were due to contamination by
solvents, followed by pesticides, spills of
gasoline or oil, landfill leachate, and
finally road salt. Most of the problems
have or are being resolved by
development of a new source of supply,
treatment, use of bottled water, and
removal of the contamination source.
Clearly prevention of contamination
must be the main element of any
ground-water management program,as it
is in Connecticut's, but other key
elements must include enforcement and
pollution abatement processes, control of
water withdrawal, monitoring, and
research.
In 1980 the Department adopted
ground-water quality standards along
with its surface water quality standards.
These standards set all goals and policies
for ground-water use and protection.
Four use standards or classes were
adopted; two (GAA & GA) suitable for
drinking water use without treatment
with no sources of pollution allowed; one
(GB) may not be suitable for drinking
without treatment due to past land uses
or disposal practices and no need exists
to restore these waters to potable
quality; and one (GO defining areas
which may be most suitable for certain
waste disposal activities such as landfills
and hazardous waste facilities due to the
hydrogeologic characteristics of the site.
The entire state has been classified and
mapped into these classifications. Over
90 percent of the land area falls into the
GAA or GA class, and less than 0.3
percent into the GC classification.
In the work required to develop this
system, the mapping of hydrogeologic
characteristics, pollution sources, land
uses, etc., it became clear that our
management program lacked several key
tools which were needed to meet the
goals being set. The first was the control
of water withdrawal from the ground. In
1982 the Department prepared and
submitted to the General Assembly a bill
requiring a permit for the diversion of
surface or ground water over 50,000
gallons per day. This bill was adopted as
Connecticut's Water Diversion Policy Act
of 1982 and provides to the Department
the authority to allocate the state's water
resources.
Several other additions to our statutory
authority for enforcement and regulation
beyond the present authorities requiring
permits for wastewater and leachate
discharges were needed and
subsequently pursued and adopted in
1982. They include;
1. The authority to ban by regulation the
use of toxic substances or priority
pollutants in septic system additives and
cleaners. Regulations requiring product
labeling and prohibitions have been
adopted.
2. The authority to set standards by
regulation for the design, installation,
JULY/AUGUST
•
-------
testing and removal of underground fuel
and chemical storage tanks (over 5,000
gallons). Regulations have been through
the administrative process and are
awaiting final adoption.
3. The authority to require persons or
municipalities who have polluted a water
supply well to provide potable water to
the affected persons. This law is a very
important and powerful tool designed to
get safe drinking water to the people as
soon as possible while the months or
years of cleanup activities go on. The Act
provides a municipality a grant to cover
50 percent of the capital costs of
providing potable water from funds
derived from a state hazardous waste
generators tax where there is no obvious
source of contamination or where the
responsible party has no assets.
4. The authority to delegate Department
authority to local municipal agents or
agencies. This allows development of
local ground-water protection programs
with a strong statutory basis. Delegation
of programs to towns will include:
administration of underground fuel
storage regulations, additional review
and permit of large septic systems (only
single residential and small commercial
are now delegated), expanded rights of
investigation and monitoring, and control
over many commercial activities.
Connecticut's ground-water program
direction for the future is towards
prevention through control of land uses
by state ground-water standards and
classifications and by development of
comprehensive local aquifer protection
programs. Our development efforts today
are aimed at providing education,
training, and assistance to towns in
establishing needed land use controls
and establishing locally enforceable
performance standards for small
commercial and industrial establishments
(gas stations, laundromats, dry cleaners,
etc., and home industries such as photo
developing, printing, etc.).
We now feel we have the tools to carry
out an effective, comprehensive
ground-water management program at
the state, and soon, the local level. While
enforcement tools are capable of solving
today's problems, the lack of national
drinking water standards for pesticides
and other toxic, hazardous and
carcinogenic substances hinders and in
some cases halts problem resolution and
stifles anticipation and prevention of
future problems. National standards for
maximum contaminant levels and
understandable risk factors must be
promulgated as soon as possible to
define safe drinking water and to allay
public confusion and fear.
Administrator
Ground-Water Section
Florida Department of
Environmental Regulation
Florida is not known as a highly
industrialized state; yet it has its share of
potential point and nonpoint sources of
pollution. Examples of these are:
• Some 6,000 largely unlined surface
impoundments containing wastewater
that percolates into the ground water;
• Some 7,000 drainage wells directly
discharging water or wastewater of lower
quality than the receiving aquifers;
• Some 40,000 underground storage
tanks that are either leaking or will
potentially leak contaminants into the
ground water within the next two
decades;
• Large agricultural lands that receive
fertilizers and pesticides, some of which
find their way into the ground water;
• Large stretches of coastal aquifers that
have been intruded with salt water;
• Hundreds of potentially uncontrolled
hazardous waste sites and;
• Hundreds of thousands of septic tanks,
some of which are constructed in the
water table aquifers or are periodically
subject to submergence due to water
table fluctuation.
The current large scale contamination of
ground water by the pesticide ethylene
dibromide (EDB) is but one manifestation
of the potential problems facing the
resource.
The Florida Department of
Environmental Regulation (DER) has
developed Ground Water Rules which
classify ground water into four classes
according to water quality as measured
by Total Dissolved Solids (TDS). These
are:
Class G-l: "Single Source Aquifers" for
potable water use and having a TDS of
3000 mg/l (milligrams per liter) or less.
Aquifers in this category receive the
highest protection.
Class G-ll: Potable water use having a
TDS of 10,000 mg/l or less. This class
constitutes the majority of Florida's
aquifers.
Class G-lll: Nonpotable water use having
a TDS of over 10,000 mg I in unconfined
aquifers.
Class G-IV: Nonpotable water use having
a TDS of over 10,000 mg I in confined
aquifers. G-IV aquifers receive the lowest
degree of protection.
The rules define the water quality
standards used in determining ground-
water pollution, monitoring, and cleanup
of polluted aquifers. The standards
include the Primary and Secondary
Drinking Water Standards, as well as the
narrative "Minimum Criteria" standard.
The latter includes any chemical agent
that is judged toxic, carcinogenic,
teratogenic or mutagenic.
Until numerical values are developed
for these standards, the DER will attempt
to prohibit the presence of such
chemicals in the ground water. In April
1984 Maximum Contaminant Levels
(MCL) for eight such chemicals were
added to Florida's drinking and
ground-water standards. Compliance
with the new MCLs will be in effect by
June 1985 for community water systems
which serve 1,000 or more people, and
by January 1987 for those serving fewer
than 1,000 people.
The DER has been delegated Primary
Enforcement Responsibility "Primacy" for
the Underground Injection Control (UIC)
Program. The Department has developed
a UIC rule that is more stringent in
certain aspects than the federal
guidelines.
In 1983 the Florida legislature enacted
the Water Quality Assurance Act,
considered the most important
environmental legislation in decades.
Ground-water protection was addressed
in the act through fifteen steps, including
data collection, a monitoring network,
protection of public water supplies and
establishment of a Pesticide Review
Council. Other steps were a hazardous
waste management program, promotion
of public awareness and inspection of
package sewage treatment plants,
thought to be a potential ground-water
pollution source. Also, state funds were
provided to replace, match or augment
federal funds designated for building
sewage treatment facilities, cleanup of
contaminated sites, emergency cleanup
of spills, and other cases.
The above programs and activities are
directed entirely towards the protection
of ground-water quality. Water quantity
issues such as availability and
consumptive use permits are the
EPA JOURNAL
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responsibility of five agencies known as
the Water Management Districts (WMDs).
Considerable effort is underway to
achieve maximum interaction between
DER and the WMDs so that ground-water
quality issues are better coordinated.
As our population continues to grow
so will our dependence on the
ground-water supply. One major issue
facing Florida in the 1980s is
accommodating the expected population
growth without destroying the
environment that instigated such growth
in the first place. Ground water is a
critical factor in this highly complicated
equation.
Director
Division of Water Resources
New Jersey Department of
Environmental Protection
Ground-water contamination in the State
of New Jersey has of necessity received
rigorous regulatory attention. The
reasons are many. Approximately 50
percent of New Jersey's population and
80 percent of its area is dependent upon
ground water. Population density is high
and the state's geology is complex and
highly variable, ranging from fractured
shale and crystallines to cavernous
limestone and coastal plain sediments.
Compounding these conditions is an
economy heavily dependent upon
chemical and refining industries. The
Department of Environmental Protection
has estimated that between 10,000 and
15,000 firms in New Jersey are engaged
in the production of chemical and
petrochemical products. New Jersey also
generates about eight percent of the
nation's hazardous waste, the highest of
any state. As an inevitable consequence,
aquifer contamination has occurred in
many locations through poor industrial
housekeeping, spills and accidents of all
types, deliberate dumping, illegal
discharges, leaks from subsurface
storage landfills, and so on.
Avenues for the release of
contaminants are all too numerous.
Contamination has had, moreover,
decades of opportunity to reach the
state's unconsolidated and bedrock
aquifers. Contrary to public belief, most
of the pollution sources are at facilities
which had some type of permit to
operate. However, these earlier permits
did not consider ground water an integral
regulatory factor.
Ironically, state and federal laws
passed in the 1970s inadvertently
increased the quantity of pollutants
discharged to the state's aquifers as
federal laws concentrated on "fishable
and swimmable" goals for surface
waters. To quote a predecessor of mine,
"Waste will migrate to the area of least
regulation." This certainly proved to be
true in New Jersey as many surface
discharges were replaced by percolation
and evaporation lagoons, spray
irrigation, and landfills which accepted
chemical wastes. The growth of New
Jersey's ground-water pollution control
program has paralleled a rising public
awareness of ground water and its
possible contamination by toxic
substances.
The first organized effort to investigate
ground-water pollution in New Jersey
began in 1974 with four geologists.
Currently, there are 12 hydrogeologists
and geophysicists dedicated to
ground-water contamination
investigations.
Today as we discuss ground-water
problems and the potential for future
problem sites, I think it is critical to
understand that the State of New Jersey
has the most sophisticated and
comprehensive ground-water permit
program in the United States. Unlike
federal law, New Jersey law requires that
any discharge of waste into the ground,
including non-hazardous waste, must
have a permit and comply with water
quality standards. This requirement
protects the future use of the resource
and controls discharge.
This is illustrative of the type of
commitment New Jersey has made to
implementing an aggressive ground-water
protection program. In this respect, New
Jersey is years ahead of most other
states.
Program Manager
Ground Water Section
New Mexico Environmental
Improvement Division
In New Mexico, much of which is arid,
water has historically been recognized as
a resource which is limited, critical, and
basic. Ground water is particularly
important in this state because: 95
percent of the water supplied by public
systems is from ground-water sources;
three-fourths of the state's population is
supplied drinking water by these
systems; one-half of the total water
annually withdrawn for all uses in New
Mexico is ground water; and the only
source of water in many areas of the
state is ground water.
Potential sources of ground-water
contamination in the state include mining
and milling, oil and gas production,
refinement and distribution, public and
private domestic sewage disposal,
dairies, power plants, and other industrial
discharges.
In the 1970s, concern in New Mexico
about ground-water quality led to the
development of a comprehensive
statewide regulatory program to protect
that quality. The program has two basic
aspects: (1) setting ground water
standards (as of 1984, 35 numerical
standards plus a generic "toxic pollutant"
provision have been adopted); and (2)
requiring by regulation that a discharger
demonstrate he will not cause those
standards to be violated at any place of
present or foreseeable future use.
This combination results in a detailed
enforceable permit. The stated purpose is
to protect all ground water which has an
existing concentration of 10,000 mg/l
(milligrams per liter) or less total
dissolved solids. The regulations apply to
all discharges of effluent or leachate onto
or below the surface of the ground,
including well injection, seepage from
surface impoundments or leach fields,
land application of wastes, and any other
discharges which may impact ground
water, except those specifically
exempted. Oil and gas production
activities, for example, were exempted
from these regulations because they
were covered by other state regulations
already in effect.
Development of the standards and
regulations began in 1974; they were
adopted by the New Mexico Water
Quality Control Commission in 1977 after
JULY/AUGUST
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extensive public hearings and have been
upheld by the New Mexico Supreme
Court. Based on seven years experience
in administering them, the following
general observations can be made:
(1) These regulations have proven
extremely effective in preventing
ground-water pollution from new and
newly modified discharges; improving
pollution controls at facilities already
operating before the 1977
implementation of the regulations is
more difficult and progress has been
slow though steady.
(2) Numerical standards define clearly for
all parties what is allowed, but cannot be
adopted for all possible pollutants;
therefore a generic provision for toxic
pollutants is also necessary.
(3) Having standards that apply in ground
water, rather than detailed design and
operation requirements, allows
consideration of site-specific conditions,
an important advantage in New Mexico
where hydrologic and geologic
conditions vary greatly.
(4) A substantial commitment of expert
staff is required for site-specific
evaluations.
New Mexico's regulatory program for the
protection of ground-water quality is well
established, workable and effective.
However, new industries and other new
facilities continue to enter the state and
new knowledge is being acquired about
existing conditions, resulting in
newly identified problems. It is necessary
that development of the regulatory
program be a continuing process to cope
with these newly identified problems, to
incorporate new knowledge, and to keep
the program at a high level of
effectiveness.
Louis W. Bercheni
Director
Bureau of Water Quality
Management
Pennsylvania Department of
Environmental Resources
The Pennsylvania Department of
Environmental Resources has been
aggressively involved in ground-water
quality protection since the early 1960s.
Our programs rely heavily on the
development and implementation of
regulations and permits to prevent and
abate pollution from all major sources
where disposal, treatment, and storage of
waste materials occur. We are also
committed to the inclusion of
ground-water quality considerations in
environmental planning. Our
ground-water quality staff initially
consisted of a single unit composed of
five hydrogeologists. This has
subsequently grown to more than 50
hydrogeologists, distributed over three
bureaus in the Department.
Much of our recent program growth
has been stimulated by federal expansion
into the areas of solid waste, hazardous
waste and mining regulation as well as
state program development. Rapid
changes in internal Departmental
structure and adjustments to these
regulatory demands have resulted in
extensive diversification in our program
requirements and approaches to problem
solving.
Though all of our programs protect
ground-water quality for water supply
use, no legally specified ground-water
quality standards exist. Only a small
portion of our potential pollution sites
are monitored. Differences in monitoring
design, sampling frequencies, chemical
parameters analyzed, ground-water
isolation characteristics, and data
management make it difficult to conduct
comparative evaluations, hinder program
uniformity, and result in inconsistent
levels of protection. In addition, although
ground water in the Commonwealth is
generally of excellent quality, no effective
mechanism exists to give a true measure
of existing regional water quality, and
subsequently, to evaluate the overall
success of our program efforts.
We are currently developing
recommended program modifications to
solve these problems. Our first step
would be to define ground-water uses
that are to be protected. The statewide
uses "water supply" and "surface water
maintenance" would be protected at the
EPA drinking water standards and
surface water quality standards,
respectively, for all ground water having
a total dissolved solids (TDS)
concentration of 10,000 mg I (milligrams
per liter) or less. Specific siting criteria
would define special waters requiring
nondegradation.
The only ground waters with a natural
TDS concentration of more than 10,000
mg/l are deep, water-bearing formations
containing brines. These are unsuitable
for use and would remain unprotected.
Design and monitoring standards
included in injection permits would
insure containment and protect overlying
ground water. The formal delineation of
mixing and buffer zones would be
required for all major land
treatment'disposal systems.
Microcomputers and ground-water
models are being used to check the
credibility and identify technical
inconsistencies in permit proposals. A
Departmental task force has been
established to review and implement
recommendations designed to improve
program uniformity.
Data management and a viable
assessment mechanism are critical to the
success of our ground-water quality
management efforts. To improve this
program area, 478 ground-water basins
of approximately 100 square miles each
were delineated and prioritized by
evaluating quality, uses, pollution
sources, and pollution dispersion
potential. Basin boundaries were
computerized by EPA's Environmental
Photographic Interpretation Center and
placed in EPA's system for storage of
water quality data (STORET).
A fixed station network consisting of 25
stations in each higher priority basin is
being proposed to supplement ongoing
data gathering efforts and chronological
controls for data evaluation. Surveys will
be relied on to supply additional
information in areas where major data
gaps or significant pollution exist. Data
generated is to be used for quality trend
analyses, program evaluations,
permitting, facility site evaluations, and
to fulfill systematic reporting
requirements such as Section 305(b)
obligations under the federal Clean Water
Act. All monitoring data are being placed
on STORET. Unique data will be stored
on microcomputer discs until such time
as evaluations are required, whereupon
they will be placed on STORET with
other ground-water sources being
systematically monitored.
In anticipating the public presentation
of our recommended program
modifications within the next few
months, the Department held a seminar
for policy level decision makers in
Pennsylvania. It was conducted by
Geraghty and Miller, Inc., a ground-water
consulting firm, for representatives of all
Departmental environmental advisory
groups and upper management level
staff on the fundamentals of ground
water. The intent of the seminar was to
develop a basic understanding and
knowledge about the complex nature of
ground water. This should enhance the
public's participation and input on
recommended program modifications
which are critical to our future success. D
EPA JOURNAL
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Sources of
Ground-Water
Pollution
by David W. Miller
(David Miller is a geologist and a partner in
Geraghty & Miller, Inc., a ground-water
consulting firm in Syosset,New York.)
To the general public, the subject of
ground-water contamination conjures
up pictures of people dressed in space
suits examining abandoned drums of
hazardous wastes. Although there are
hundreds of such sites across the nation
that obviously represent a health threat
to community water supply wells,
hazardous waste sites are only a very
small piece of a very complex picture
when it comes to describing potential
sources of ground-water quality
degradation. In fact, less than one third
of all sources of ground-water
contamination may be caused by
regulated waste discharges such as
landfills and injection wells. Although
existing federal and state regulations
focus on waste discharges and hazardous
waste facilities, a majority of water
supply contamination incidents appear to
be caused by nonpoint sources such as
accidental chemical spills, disposal of
toxic consumer products, leaks from
underground storage tanks, and run-off
from urban and agricultural land.
The sources of ground-water
contamination are essentially the same
as those for any other form of water
contamination. They include practically
every type of facility or structure installed
by man and are present in millions of
places across the face of the land. Some
sources or causes of ground-water
contamination involve discharges of
contaminants that are wastes or
wastewaters. Others involve discharges
of contaminants that are not wastes at all
but are represented by stockpiles of raw
materials or the application of fertilizers
and pesticides. Still others are not even
discharges but can be due to the
infiltration into the ground of polluted
river water or the intrusion of salt water
into a well because of heavy
ground-water pumpage in a coastal area.
Some Major Sources
of Ground-Water Contamination
Surface impoundments: Industrial
wastewater impoundments are a source
of serious ground- water contamination
because of their large number and their
potential for leaking hazardous
substances that are relatively mobile in
the ground-water environment. In some
heavily industrialized sections, for
example, the areal extent and the toxic
nature of the contaminants have ruled
out the use of ground water from
shallow aquifers. The contaminants cover
the full range of inorganic chemicals and
organic chemicals normally contained in
industrial wastewaters. Those
documented as having degraded
ground-water quality include solvents,
phenols, acids, heavy metals, and
cyanide.
Surface impoundments are used by
industry to store wastewater as part of
the treatment process, and they are often
unlined. Pits, ponds, and lagoons are
also used in municipal waste treatment
processes and for storing agricultural and
mining wastes. They can range in size
from a swimming pool to hundreds of
acres. They number in the hundreds of
thousands across the United States.
JULY/AUGUST
-------
Landfills: Land disposal sites for solid
waste can be sources of ground-water
contamination because of the generation
of leachate caused by water percolating
through the refuse and waste materials.
Precipitation falling on a site either runs
off, returns to the atmosphere via
evaporation and transpiration, or
infiltrates the landfill. Contamination
problems are more likely to occur in
humid areas, where the available
moisture exceeds the ability of the waste
pile to absorb water.
Leachate from such sites is a highly
mineralized fluid with such constituents
as chloride, iron, lead, copper, sodium,
nitrate, and a variety of organic
chemicals. Where manufacturing wastes
are included, hazardous constituents are
often present in the leachate (e.g.
cyanide, cadmium, chromium, and
chlorinated hydrocarbons). The particular
makeup of the leachate is dependent
upon the industry using the-landfill or
dump.
There are about 20,000 land disposal
sites that accept municipal wastes. Most
are open dumps or poorly sited and
operated landfills, and most receive
some industrial wastes. There is no
national inventory available on privately
owned industrial land disposal sites.
However, it is estimated that 90 percent
of industrial wastes that are considered
hazardous end up in landfills mainly
because it is the cheapest of all waste-
management options.
Septic tanks and cesspools: Septic tanks
and cesspools rank highest in total
volume of wastewater discharged directly
to ground water and are the most
frequently reported sources of
ground-water contamination. Most of the
reported problems are related to
individual homesites or subdivisions
where recycling of septic fluids through
aquifers has affected private wells used
for drinking water. Except in situations
where the recycling is so quick that
pathogenic organisms can survive, the
overall health hazard from on-site
domestic waste disposal is only
moderate, with relatively high
concentrations of nitrate representing the
principal concern.
Twenty-nine percent of the population,
residing in about 19.5 million
single-housing units, disposes of
domestic waste through individual
on-site systems. Regional ground- water
quality problems have been recognized
only in those areas of the greatest
density of such systems, primarily in the
northeast states and in southern
California. Across the U.S., there are four
counties (Nassau and Suffolk, N.Y.; Dade,
Fla.; and Los Angeles, Calif.), each with
more than 100,000 housing units served
by septic tanks and cesspools, and there
are 23 other counties with more than
50,000 such units. Data on discharge to
industrial septic tanks are not available.
Collection, treatment, and disposal of
municipal wastewater: Municipal
wastewater follows one of three direct
routes to reach ground water: (1) leakage
from collecting sewers, (2) leakage from
a treatment plant during processing, and
(3) land disposal of the treatment plant
effluent. In addition, there are two
indirect routes: (1) effluent disposal to
surface water bodies that recharge
aquifers, and (2) land disposal of sludge
that is subject to leaching. Although the
volume of wastewater entering the
ground-water system from these various
sources may be substantial, there have
been few documented cases of
hazardous levels of constituents of
sewage affecting well-water supplies,
Sources of Ground-Water Contamination
Precipitation
Evapotranspiration
/ Injection Well W?/>// ^\\\M
/ or Disposal / /' Pumping WelT \ -x
/ /
Land Spreading Septic Tank/
Pumping Well
\ I
Lagoon, Pit or Basin
Cesspool Sewer
,Stream
o£7!Water Table
Perception
* Water Table Aquifer
Discharge Lea&ge
n
•
V
Confining Zone
Artesian Aquifer (Fresh)
Confining Zone
Ground-Water
Movement
ntentional
Input
B-B-JUnintentional
Input
Artesian Aquifer (Saline)
Discharge or Injection
18
EPA JOURNAL
-------
largely because the subject has not been
studied in detail.
Mine spoil piles and tailings: All forms of
mining can produce products or
conditions that contribute to
ground-water contamination. Although
every mine is a potential contamination
hazard, few studies of the effects of
mining on ground-water quality have
been carried out.
With both surface and underground
mining, refuse piles and slurry lagoons
are probably the major potential sources
of ground-water contamination. Where
aquifers underlie these sources, water
with a high acidity (except in arid
regions) and an elevated level of total
dissolved solids can percolate to ground
water.
Waste disposal wells: Industrial waste,
sewage effluent, spent cooling water,
storm water and oil field brines are
discharged through wells into fresh- and
saline-water aquifers in many parts of the
U.S. In the literature the greatest
attention has been given to deep
disposal of industrial and municipal
wastes through wells normally drilled
300 metres or more into saline aquifers.
About 300 such wells have been
constructed in 25 states, 20 of which are
presently operating. They pose a
comparatively small contamination threat
compared with the many shallow wells
injecting contaminants into freshwater
aquifers or the tens of thousands of wells
reinjecting oil field brines into deep
geologic units.
Accidental spills: Percolation of liquids
spilled at the land surface can be another
serious threat if the ground is permeable
and allows downward percolation. For
example, many petroleum spills
penetrate into the ground, travel
downward, and come to rest on top of
the water table. Underground storage of
chemicals, chemical wastes, or petroleum
products in steel or concrete tanks
presents a potential hazard because
metal corrosion or concrete deterioration
may ultimately permit seepage of
contaminants into an aquifer.
The leaching of soluble solids stored
on the land surface is another practice
that can be responsible for the
contamination of ground water. These
situations occur, for example, where
rainwater dissolves soluble materials
from piles of highway de-icing salt or
where industrial raw materials have been
allowed to spill at railroad or truck
loading areas.
Types of
Contaminants
Most things that contaminate ground
water may be placed in one of three
broad groups: biological organisms,
inorganic chemicals, and organic
chemicals.
Biological organisms: Biological
contamination of ground water occurs
when human or animal wastes enter an
aquifer. Microorganisms present in the
wastes may be carried by ground water
into nearby wells used for drinking water.
The first time an illness was traced to a
well contaminated with sewage was
during a cholera epidemic in London in
1854.
The travel of bacterial pollutants
through the ground has been studied by
collecting samples from test wells.
Indications are that the bacteria seldom
travel more than 100 feet from a source.
Exceptions are where the aquifer is
fractured or cavernous, allowing bacteria
to travel rapidly for great distances.
Studies also have shown that bacteria
are largely removed by filtration.
Although most microorganisms die out
rapidly in ground water, bacterial
pollution may occur locally:
• In heavily populated suburban areas
where numerous septic tanks discharge
large quantities of waste into an aquifer.
• Near leaking wastewater lines.
• From leaks in storm sewers, storm
sewer overflows, or flows directly from
city streets into the ground.
• Near improperly operating sewage
treatment lagoons and ponds.
• From poorly designed land-spreading
and wastewater recharge operations.
Inorganic chemicals: Inorganic chemicals
are substances of mineral origin. •
Inorganic chemical contamination differs
from biological contamination in a couple
of important ways: the persistence of the
pollutants, and the difficulty of their
removal from water.
EPA has set standards for the
maximum permissible concentrations of
certain substances in drinking water. For
example, the standards require that
concentrations greater than 0.05
milligrams per liter of toxic elements
such as arsenic and chromium will
jeopardize a ground-water source for
drinking purposes. Levels of cadmium
greater than only 0.01 milligrams per liter
will also threaten supply wells. Excessive
concentrations of arsenic, cadmium, and
chromium in ground water are often
found where electroplating wastes have
been discharged into the ground. Lead
can get into the ground water where
gasoline has entered the aquifer through
leaking pipelines and service station
tanks.
Organic chemicals: Organic chemicals
are substances containing predominantly
carbon, hydrogen, and oxygen. There are
many different kinds of organic chemical
contaminants associated with industrial
wastes. They represent a complex group
of byproducts and compounds produced
with major industrial products. Organic
chemical contamination is most often
caused by:
• Solvents used for degreasing septic
tanks.
• Spills and leaks.
• Industrial, municipal, and other wastes
disposed on land.
The Future
Today considerable effort is being
expended toward investigating and
cleaning up some of our past mistakes,
especially those involving hazardous
wastes, that have led to the
contamination of ground-water supplies.
These activities, however, must be
matched in the future by the equally
important effort of preventing
ground-water pollution in the first place.
Because of the diverse nature of sources
of contamination and their widespread
occurrence, much of the responsibility for
protecting ground-water resources must
be left to state and local agencies. This is
especially true because programs to
protect ground-water quality will not be
successful unless they reflect the close
relationship of the land, ground water
and surface water. Long-term
ground-water quality depends on what
we do with the land.
We are still learning more and more
each year about the impact that various
sources of contamination can have on
ground water. In fact, as we have
become more knowledgeable, our
emphasis on which source to concentrate
our regulatory efforts has changed
drastically over the decades. Thus, there
is a critical need to give ground-water
resource protection the high national
priority that it deserves and to encourage
federal, state and local agencies to
develop the required strategies and
programs to carry out this priority. D
JULY/AUGUST
19
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Contamination of Drinking
Water
by John M. Gaston
Prior to 1979 the common theme, at
least in California, was to abandon
marginal drinking water sources obtained
from surface streams (creeks, springs,
lakes, etc.) and develop new ground-water
sources (wells). The public health
philosophy as preached by the state and
local agencies stressed the hazards that
might contaminate surface
sources—waste discharges, livestock,
illegal dumping, etc.—and praised the
pure, pristine ground water.
To be sure, there are many benefits to
be seen by developing a ground-water
source for drinking water. These benefits
include, especially for the small
community or individual, a lesser degree
of maintenance, fewer treatment
chemicals, a relatively trouble-free
operation and, as it was thought at that
time, the ultimate protection afforded by
the depth of the well.
In contrast to this, public health
officials felt that many surface sources
were disasters waiting for a time to
explode. The threat of mine drainage,
livestock waste contamination, illegal
spills and countless other hazards
awaited the hapless water system
operator with the misfortune of having to
deal with a surface water source. Those
hazards in surface sources still exist and
the benefits of most ground-water
systems still exist, but the water supply
"community" or "industry" has learned
quite a lesson since the late 1970s.
• The myth of the protected, pristine
ground-water source has been shattered.
• Public confidence in the water utility
industry and the public health
community has been shaken.
• The professional water supply
community — engineers, scientists, etc.
— has been taken aback by recent
(John Gaston is a senior consultant for
water quality and treatment with CH2M Hill,
an environmental consulting firm, and
former State Sanitary Engineer for the State
of California.)
ground-water problems and, to state the
case politely, is "re-grouping".
• The laboratories and techniques
employed in water analysis are much
more sophisticated than in the recent
past and are able to detect compounds at
very low (part per trillion) levels.
How did we get in this fix and what
have we learned in the process?
The discovery of contaminated drinking
water wells in California in the late 1970s
was not unusual. It was unusual,
however, if the contaminant was
anything other than nitrate or bacteria.
Common knowledge held that improperly
constructed wells could allow surface
water containing either land drainage or
other waste into the well and thereby
contaminate the source.
The nitrate contamination problem
seemed to be prevalent in agricultural
areas and therefore was thought to be
directly related to fertilizer or animal
wastes. Indeed a direct cause and effect
was established in a number of wells
located in feed lot and poultry areas.
Bacteriological problems also occurred in
these areas and seemed to be directly
related to poorly constructed wells.
Other ground-water problems —
arsenic, fluoride, selenium, iron,
manganese — were thought to be
naturally occurring, rather than related to
"outside" contamination. These
problems were relatively scarce and
could either be treated (iron and
manganese) or new sources could be
developed to eliminate the problem.
Most community water system
operators frequently test the water for a
variety of compounds and
constituents—bacteria, inorganic and
organic chemicals. The testing
procedures and compounds are
established by state and federal law and
specific Maximum Contaminant Levels
(MCLs) are set for each constituent. No
wells, at least in California, had shown
any sign of contamination by the
"regulated" organic chemicals contained
in either the state or federal listing.
Honest Disbelief
As a result of this long history of
negative results from ground-water
samples there was some honest disbelief
when "unheard-of" organic compounds
were discovered in the late 1970s. The
reaction by the regulatory agencies was
confused. Many of the contaminated
wells were on or near industrial sites,
and the obvious connection between the
site and the contamination was made.
This happened in specific cases involving
two industrial sites in California. Initially
the fear was that the "protected"
ground-water theory was wrong. This
quickly changed to the position that
these were "special" cases involving
massive contamination and that
ground water as a sacred resource was
still safe.
Advances in analytical techniques in
the laboratory about this time caused
some consternation. When a group of
"clean" ground-water samples was being
analyzed for one of the "special" case
constituents, a low but consistent level of
the contaminant was detected in all of
the samples. This caused the regulatory
people—laboratory and engineers—to
develop and advance the "laboratory
error" theory that was then to be used to
explain the unbelievable. It was as
though one day the sun came up in the
east, proceeded to the north, and then
set in the west. We were all confused
until we discovered that we had moved
to South America.
Eventually a series of events led the
regulatory agencies to conclude that
organic contamination of ground water
was a fact. These events included:
* The installation and operation of new,
sophisticated analytical laboratory
instruments provided by EPA grant
funds;
• The realization that there could only be
a limited number of "laboratory errors";
• The independent confirmation of
contamination by different laboratories;
• The development and verification of
the theory that various organic chemicals
20
EPA JOURNAL
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could move downward through the soil
and into the ground water.
To quote an old bromide, the rest is
history. As more samples were taken,
more contamination was found. Similar
reports from other states confirmed the
phenomenon, and the "pre-1979
syndrome" of pure, pristine ground
water was dead. The regulatory agencies
began to move ahead in several areas
but, to the dismay of the consumer and
public interest groups, more discoveries
and questions were being raised without
any hope for answers or solutions.
It was (and is) a classic regulatory
dilemma. If one problem is found, should
all resources be bent to finding a solution
to that problem, or should other
problems be investigated at the same
time? If resources don't exist (and they
don't) at the state or federal level to fix
all these problems now, should we
provide token support for each problem or
should we concentrate only on the
biggest problems and let the others slide
until we have the resources?
Patterns Emerge
Following a period of chaos, patterns
have emerged to assist the regulatory
agencies and the public:
• It appears that many ground-water
contamination sites can be located by
looking at land use patterns, industrial
grouping and other related factors. This
will save valuable laboratory resources
and allow the states to limit their
sampling to areas where problems are
more likely to be found.
• If contamination is found the levels are
likely to be fairly low—part per billion
range—and the lifetime risk from
ingestion low. Rarely have situations
involving acute hazards been found. This
is not to imply that organic
contamination is good or even
acceptable, but it does buy some time for
the various agencies to fix the problem.
• Intermediate solutions have been
developed to either treat contaminated
sources or to provide alternate drinking
water sources to the impacted
population.
• Advice from toxicologists indicates that
a widespread epidemic is not
forthcoming or even probable. No
incidents of acute poisoning were
demonstrated and most of these
compounds have very long-term, if any,
effects.
• New laws at the state and federal level
have been promulgated to assist in the
discovery and cleanup of many of the
problem sites.
As more sites are found, and everyone
hopes that the frequency decreases soon,
several questions still exist in the mind of
the public and all other parties. For
example, if these problems were first
found in the late 1970s, how long before
that date did the contamination occur? If
ground water is contaminated and a
"responsible party" cannot be found,
who pays for the cleanup and treatment?
The water supply industry has
traditionally been very low key and has
generally kept in the background. Now
the industry has been pushed into the
front row. Both the public and the
industry may feel deceived at some point
because everything was going smoothly
and steadily until the organics and
ground-water problem came along.
Several predictions might be made in
light of what we've seen in the recent
past:
• More contamination will be found and
those states that are not ready with
laboratory facilities and contingency
plans may suffer.
• Water rates will increase to cover the
costs of monitoring and treatment of all
supplies.
• Analytical techniques will continue to
improve and some areas once thought to
be "clean" will turn out to be
contaminated.
• Water utilities will look more closely at
their existing physical facilities and may
choose to improve surface sources rather
than develop new ground-water capacity.
In light of all this the public must be
terribly confused It is faced with a
continuing barrage of bad news about
water supply. The water utility industry
must enlist the support of the public and
regain its confidence. The public, on the
other hand, must take the time to
become informed and be willing to play
a role in the decision making process. If
the average citizen only knows what he
reads in the newspaper, the story may
not be complete and the decision making
may be very one-sided. D
JULY/AUGUST
-------
Potential Health Effects
from Ground-Water Pollution
by Dr. Robert A. Goyer
There is a growing awareness of the
potential toxicologic effects of synthetic
organic chemicals that have
contaminated ground-water sources of
drinking water. This awareness is the
result to some extent of monitoring
chemicals in fresh water supplies, as well
as the realization of the potential for
contamination from human activity.
Particular culprits are the thousands of
improperly located toxic chemical waste
dumps now found throughout the
country.
The problem has received the attention
of a number of government and state
health agencies; the best known reports
are from the Council on Environmental
Quality, New York State Department of
Health, and a four-volume National
Academy of Sciences report on drinking
water and health. The problem is further
highlighted in a recent editorial in
Science magazine.
The topic has immense public health
significance since it is estimated that
roughly 50 percent of Americans receive
their drinking water from wells fed by
ground water. More than 700 specific
synthetic organic chemicals have been
identified in various drinking water
supplies. Nationally, 20 percent of public
water systems contain trace but
measurable amounts of volatile organic
contaminants; 28 percent of public water
systems serving communities with
populations over 10,000 contain volatile
organic contaminants.
Among these chemicals are pesticides,
organic solvents, and a long list of
halogenated compounds. Many are
known carcinogens; many have other
known toxicologic effects. But the
concentration of any one chemical is
likely to be very low. The public health
(Dr. Goyer is Deputy Director of the
National Institute of Environmental Health
Sciences.)
question, therefore, concerns what
possibilities there are, if any, that a
particular chemical contaminant or, in
fact, the mixture of chemicals in drinking
water is likely to cause disease among
people in the general population.
The response to this question is
enormously complex and not completely
answerable at the present time. There are
now a number of studies designed to
investigate associations between the
drinking of chlorinated surface waters
and cancer. These studies do suggest
increased risks of gastrointestinal and
urinary tract cancer, but comparable
studies on populations consuming only
well water are not available. However,
there is only minor overlap between
chemicals found in disinfectant-treated
surface waters and in ground water.
Health problems stemming from
surface drinking water are thought to be
related to byproducts of chlorination,
particularly the four trihalomethanes
(chloroform, bromoform,
bromodichloromethane, and
dibromochloromethane). There are a
number of possible approaches within
the regulatory context for the control of
these substances, such as substitution of
other types of disinfectants, treatment to
reduce precursor concentrations, or even
removal after their formation.
Synthetic organic chemicals in ground
water present a less predictable and less
controllable problem in spite of nature's
filtration and cleansing processes. For
instance, trichloroethylene (TCE),
probably the most commonly occurring
organic chemical contaminant in well
water, has been found in 13 percent of
community water supply wells in Nassau
County, N.Y., with maximum
concentration of 300 ppb (parts per
billion).In 1979, the Pennsylvania
Department of Environmental Resources
found widespread contamination of
drinking water supplies in Montgomery
and Bucks counties, with a maximum
concentration of 1,400 ppb. Human
exposure was confirmed by detection of
metabolites of TCE in urine.
The most direct way of establishing a
link between s^uch exposure and effect on
health is by epidemiologic study,
particularly case control studies which
relate exposures in persons with and
without disease. Although such studies
are useful in appropriate circumstances,
they are retrospective and often depend
on information from death certificates for
diagnoses. Occupational, dietary, and
smoking histories are often incomplete or
unobtainable.
In an effort to assess the influence on
health from TCE in Montgomery and
Bucks counties, physicians from the
Centers for Disease Control (CDC)
reviewed the number of deaths
attributable to liver cancer over the
19-year period, 1960-1978, and found no
difference with the incidence of this
tumor in the rest of Pennsylvania.
Weaknesses of this approach are that the
population studied may not be large
enough to show small increases in
tumors or the period of residency in the
region of investigation and, hence,
exposure to TCE may be too short to
allow a sufficient latency period for the
tumor to develop.
Another problem common to
studies of persons in the
general population is that it is often
difficult to find control cases without
exposures to the chemical(s) in question.
In an effort to establish exposure to
synthetic organic chemicals among
residents of Love Canal, blood samples
were analyzed for synthetic organic
chemicals. A small group of young
volunteers, intended to serve as
unexposed controls, did indeed have
measurable blood levels of many of the
chemicals in question.
Furthermore, corrective action based
on evidence of human disease is not
ideal public health action. Rather,
methods that are predictive and not
dependent on detection of illness seem
22
EPA JOURNAL
-------
more desirable. Such approaches are
dependent on adequate toxicologic data
for the chemicals in question and
appropriate methodology for
extrapolation of the data to man. For
many of the organic chemicals found in
ground water, toxicologic evaluations
have been performed, particularly in
terms of characterization of carcinogenic
potential, but quantitative estimates of
human risk from such data require
additional refinements. A review of
current methodologies suggests that it is
possible to make crude estimates of
carcinogenic risk from animal data for
drinking water that contains synthetic
organic chemicals.
Toxicologic data for prediction of
disease from synthetic chemicals for end
points other than cancer are also
available in terms of characterizing the
effect, but useful quantitative data of this
type are not common. Although there is
some evidence that TCE may be a
carcinogen, there is also evidence that
TCE and other structurally similar
halogenated hydrocarbons are
nephrotoxins (toxic to the kidney).
Experimental studies have shown that
chronic exposure to these compounds
may produce glomerular lesions
sometimes leading to the nephrotoxic
syndrome and renal failure.
Although cancer, as a toxicologic end
point, receives the major focus of
concern, chronic renal failure is also a
major human disease entity. The
incidence for end-stage renal disease
may be as high as 15.6/100,000 people
per year, and the Social Security
Administration indicates that its cost for
the end-stage renal disease program was
$286 million in 1974 and is rising each
year. Costs in 1984 are projected to be
more than $3 billion.
There is also evidence that the
nephrotoxicity of TCE is made more
potent by simultaneous exposure to
polychlorinated biphenyls and
polybrominated biphenyls. This serves
as a reminder that ground water
contaminated with synthetic organic
compounds is always a complex mixture
of chemicals, each with its individual
potential for carcinogenicity and other
toxicities.
Consideration of risk is almost always
calculated on the basis of toxicologic
data on single chemicals. But what about
synergistic or suppressive interactions
that may occur with exposure to
chemically-contaminated ground water?
Without direct experimental study of
each complex mixture in the proportions
present in nature, it seems virtually
impossible to be predictive with the
present state of understanding.
Considerable thought has been given
to this problem. A report of a National
Research Council Committee outlined a
number of basic principles underlying the
behavior and toxicity of mixtures, such
as chemical-chemical interactions,
interactions with macromolecules, and
alterations in cellular responsiveness or
reactivity because of the actions on one
or more members of a mixture. These
principles, however, have not been
assembled into any quantitative measure
of the toxicity of specific complex
mixtures.
In the absence of a more definitive
approach, a World Health Organization
criteria document on methods in toxicity
testing describes an additive model but
restricts the application of the model to
mixtures of chemicals that act at the
same site producing the same type of
acute toxic effect and having similar
dose-effect relationships. Even so, such a
model, when tested experimentally, may
determine an effective dose that is
greater or lesser than the predicted dose.
And finally, factors of individual
susceptibility further complicate the task
of predicting the toxicologic effects of
complex mixtures of even single
chemicals in ground water. Such factors
may subtly or dramatically alter the
predictability of a biologic or toxicologic
reaction. These include stress conditions
of the host, nutrition and dietary factors,
personal habits, and pre-existent disease
states.
It has been shown that animals
exposed to hepatotoxins, such as carbon
tetrachloride, benefit from a diet that is
high in carbohydrates and low in fat,
whereas low caloric diets enhance the
hepatoxicity of carbon tetrachloride.
Protein-deficient diets reduce the activity
of hepatic microsomal enzymes and the
level of cytochrome P450, resulting in
decreased ability to metabolize
xenobiotics, and diseases of the kidney
reduce the ability to excrete chemicals.
From these considerations, it becomes
apparent that the science of predictive
toxicology requires considerable
additional research. The potential
problems posed by synthetic organic
chemicals in ground water add to the
urgency for the further development of
this science and suggest a number of
specific research needs. D
JULY/AUGUST
23
-------
EPA Researchers Seek Answers
to Ground-Water Contamination
by Bob Burke
Many Superfund On-Scene Coordinators
will be able to identify with the scenario
that follows. EPA has directed the
removal of tons of contaminated
materials from a hazardous waste dump
close to a residential area. In a public
meeting, the On-Scene Coordinator
reports that all immediate health threats
have been removed, but notes the
continued presence of ground- water
pollution beneath the site area.
Neighbors begin pressing demands that
the ground water be restored to pristine
conditions as promptly as possible. The
On-Scene Coordinator realizes the
obstacles involved in cleaning up ground
water at this particular site, but it is
difficult to articulate them clearly or to
make on-the-spot commitments. Months
of hard and often dangerous work seem
almost obscured at that moment as a
very wide gap emerges between public
expectations and technical possibilities.
Superfund officials aren't the only ones
who are often confounded by ground
water-related issues. Ground-water
protection is a highly complex and often
frustrating issue that affects a host of
federal and state environmental
responsibilities. This story describes the
major challenges of ground-water
protection and some of the fascinating
and innovative areas of research and
field work that EPA is involved in to solve
these problems.
(Bob Burke is a member of the staff of
EPA's Office of Public Affairs.)
\J round-water pollution poses
challenges to research scientists and
environmental managers that defy
conventional measures for detecting,
monitoring, and cleaning up surface
water pollution. EPA research
laboratories at Ada, Okla., and Las Vegas,
Nev., are working on these problems,
which fall into three broad but
interrelated areas.
Ground-water pollution is elusive.
Ground water is extremely vulnerable to
pollution. Once a pollutant enters ground
water, it follows the flow of the hydraulic
gradient and forms an irregular,
sometimes finger-shaped form of
contaminated water called a plume. A
plume usually occupies a relatively small
part of an aquifer that can range from a
few feet to more than 2,000 feet beneath
the earth's surface. The plumes then
travel to points of ground-water
discharge which can be wells or surface
waters.
Looking for a polluted plume or
locating its pathway into and through an
aquifer without knowing its point of
origin is akin to the proverbial search for
the needle in a haystack. It is often
difficult and expensive to determine
where a plume originated, what
pollutants it contains, its precise location
and configuration, and what private or
public water supply it may ultimately
pollute.
Ground-water pollution is latent. Ground
water generally moves slowly at
velocities that can average from a few
feet per day to a few feet per year. The
contamination of ground water by any
source may go on for months or even
years before it is finally detected when it
reaches a public water supply or an
ecologically vital body of surface water.
Ground-water pollution is difficult to
clean up. Natural transformation or
degradation of pollutants is often a slow
process and may not occur at all because
of the nature of the subsurface
environment and the kinds of pollutants
involved. Restoration of polluted ground
water, even under the most favorable of
conditions, is time consuming, extremely
expensive, and technically challenging.
Ground-Water Prediction:
The Waterloo Field Study
Two major problems with detecting and
monitoring underground pollutants are
accessibility to the ground-water
environment and the heterogeneity of the
subsurface. Subsurface conditions
generally differ significantly over short
distances. Monitoring wells are
expensive and sample only a small
segment of the aquifers but are
practically the only way to access the
ground water. It is extremely difficult to
observe the inception of pollutants from
various manmade sources and activities,
and their penetration of the earth's
surface on their way to a ground-water
supply. This missing picture of the
inception of ground-water pollution may
hold an important key to predicting the
various ways that pollutants will behave
in ground water.
Now researchers are working to
unravel as much of this puzzle as
possible in a unique field investigation
funded by EPA, and carried out by
Stanford University and the University of
Waterloo in Ontario, Canada.
In 1982, a research team from the two
universities injected pollutants into a
shallow, relatively homogeneous,
uncontaminated portion of an aquifer in
Ontario, parts of which had been polluted
by an existing landfill. They used several
synthetic organic compounds (major
sources of ground-water contamination)
at different concentrations, and
monitored the ground water in order to
determine the behavior of each
contaminant.
As expected, the pollutants formed
plumes which are being monitored by
the team using a dense; three-
dimensional network of sampling
wells. By September 1983, over 9,000
samples had been taken using specially
designed devices to ensure sample
24
EPA JOURNAL
-------
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integrity. Most samples were taken in ten
2-3 day sessions distributed over the year
to obtain three-dimensional snapshots of
how the pollutants were being
distributed throughout the aquifer.
There have already been some
important observations in the ongoing
Ontario field investigation. The size,
shape, location, and movement of
polluted plumes vary depending on the
kind, quantity, and concentration of
pollutants they contain. Estimates of
concentration, location of the center of
the plume, and other pertinent
information for each pollutant have also
been observed. The study is leading to a
better understanding of how specific
pollutants may behave and move in the
pathway from the earth's surface to the
aquifer, and how these factors influence
subsequent movement and behavior
within the aquifer.
Various contaminants move through
the subsurface at vastly different rates
once they are in ground water. This may
have special significance for eventually
predicting how long various
contaminants are likely to pose health
hazards and if and how they disperse in
ground water.
For example, at an observation point
downgrade from the injection point, the
study showed that chloride became
highly concentrated very shortly after it
entered into the ground water but was
almost totally undetectable after 50 days
in the aquifer. Dichlorobenzene,
conversely, showed no concentration at
all until it had been in ground water for a
month, but then it showed low levels that
remained relatively constant for at least
several months. The concentration of
several other pollutants also showed
sharp differences. These discoveries are
important, although further verification is
needed under different conditions from
those experienced in this study.
Biodegradation Research:
Working with Ground-Water
Microorganisms
There was a time, not so long ago, when
most experts considered ground water
devoid of life. Now, it appears that
ground water is often teeming with
microbes, some of which may be
potential allies in cleaning up certain
forms of ground-water contamination. In
fact, the total biomass of bacteria in the
subsurface may be greater than the
biomass of bacteria in rivers and surface
soils.
Research into these microbes is being
carried out by EPA's Robert S. Kerr
Environmental Research Laboratory in
Ada, Oklahoma, described in a recent
Smithsonian magazine as the "premier"
facility for ground-water research in the
United States. Using carefully controlled
procedures, researchers from this
laboratory have been learning more
about "ground-water bugs" and their
ability to degrade various pollutants.
The Ada laboratory's field team
examined subsurface organisms in
samples taken from a ground-water
aquifer near Lula, Oklahoma. Their
results clearly showed that certain
subsurface organisms degrade some of
the organic pollutants that may enter
their environment. Positive results have
been obtained for the chemical toluene,
as well as for styrene and bromo-
dichloromethane. But problems
have been observed as well. There is
preliminary evidence, for example, that
trichloroethylene (TCE) occasionally
undergoes biotransformation which
results in an extremely undesirable
product called vinyl chloride.
The precise environmental conditions
required for these various
transformations are, as yet, not
JULY/AUGUST
.
-------
understood and research to characterize
the microorganisms in ground water is
still under way.
The possibility of employing microbes
to degrade wastes and restore aquifers is
fascinating even if the production of
contaminants such as vinyl chloride
demonstrates the possibility of some risks.
Can certain microbes be introduced into
contaminated ground water to degrade
specific pollutants? Can genetic
engineering eventually produce
"superbugs" capable of degrading
ground-water pollutants with which
existing microbes seem unable to deal?
At present, answers to such inquiries
remain in the realm of hopeful
speculation.
Other Research
EPA laboratories in Ada and Las Vegas
are engaged in other areas of research
aimed at meeting the complex challenges
of ground-water protection. Some of
these include:
• Early warning monitoring systems are
being examined intensively by EPA's Las
Vegas laboratory with a view to detecting
the movement of pollutants before they
reach ground water. These systems rely
on tracking pollutant percolation in the
zone above the water table known
technically as the "unsaturated
subsurface." This early warning
monitoring program involves soil testing
methods and the extraction of fluid
samples with suction devices. It is being
developed and tested for practical use in
hazardous waste land treatment
operations.
• The use of fiber optics for detecting
and monitoring the movement of
contaminated plumes in ground water.
Fiber optic technology won't serve to
make detection and monitoring programs
significantly more accurate, but it will
considerably reduce the costs associated
with locating and charting the movement
of small plumes in relatively large
underground aquifers.
• Geophysical methods are aimed at
reducing the number of expensive wells
required for taking samples from
contaminated ground water. The present
system depends on drilling a large
number of wells in a given aquifer.
Improved site selection may be able to
ascertain needed information from a
smaller number of wells which can
provide more representative samples.
Geophysical methods are also being
developed at the Las Vegas lab to map
salt water contamination deep in the
subsurface of oil fields where the salt
water is a major pollution problem to
fresh ground water.
• Under the Underground Injection
Control Program, research is being
carried out to develop methods for
locating abandoned wells and assuring
that injection wells maintain mechanical
integrity so that ground water is isolated
from sources of contamination.
• The development of various simulation
models which allow the prediction of
contaminant behavior according to the
type of ground-water system under
investigation.
Significant progress is being made in
areas of ground-water research such as
locating pollution plumes and monitoring
the ensuing changes in ground-water
quality. There are even some
breakthroughs occurring in the very
difficult area of rehabilitating polluted
aquifers. These achievements are
important first steps in a long and
difficult journey toward the solution of
the nation's ground-water problems. In
other areas, however, we are still in our
infancy in dealing with many of the
problems involved. We must expand our
knowledge of pollutant behavior in the
subsurface environment so that we can
better select sites for waste disposal and
treatment. We must evaluate the extent
of contamination at existing sites, carry
out remedial actions in a cost-effective
way, and deal with new chemicals in an
environmentally acceptable manner.
Ground-water research may not be a
good line of work for those who are
impatient and those who always expect
quick and tangible results from their
technical and professional efforts.
Instead, these efforts require
perseverance, discipline, and the ability
to accept the realization that months and
years of extensive research may yield
incomplete results. The complexity of
ground-water issues makes EPA's
regulatory and research mission both
challenging and frustrating. D
EPA JOURNAL
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The Future of the
Ground-Water Resource
Philip Cohen
Chief Hydrologist
U.S. Geological Survey
The nation's ground-water resource,
1 including both the liquid and the rocks
that house it, is an important share of the
national stock of water. Rising
appreciation of its economic and environ-
mental significance is attracting
unprecedented protective and managerial
attention. A remarkably efficient crystal
ball would be required to forecast the
enlarging role for ground water in our
society, and associated impacts on its
quantity and quality. Until such an
instrument is perfected, estimates of
future demands on ground water, and of
the physical and chemical fate lying
ahead for it, must rely on conventional
predictive methods. Principal among
these are:
• Accumulating knowledge of ground
water, including its geological,
hydrological, and chemical
characteristics;
• Lessons learned from past water and
waste management practices;
• Application of the hydrologist's
growing ability to predict and to estimate
quantitatively the responses of
ground-water systems to imposed
hydraulic, chemical, and structural
stresses; and
• Employment of demographic,
economic, and technologic projections to
anticipate future demands on the
resource.
Based generally on these approaches,
this article is an effort to characterize
factors that shape the future for the
nation's ground water.
Enlarging role
for ground water
It is reasonable to conclude that the
pattern of increasing ground- water
usage defined in past years, as illustrated
graphically in the chart on page 29, will
continue into the near future.
Ground-water withdrawals in 1985
probably will amount to about 95 billion
gallons a day, continuing to be about
one-fifth of the total freshwater usage in
the nation. To meet rising demand, well
fields will be enlarged, new well fields
constructed, and the number of
individual wells increased to supply
single homes and other small uses.
Augmentation of inadequate
surface-water supply systems may be
one principal avenue of growth. Rapid
expansion of metropolitan areas,
particularly in the water-short Southwest,
accounts for a sizable increase in public
supply ground-water pumpage during
the past half-century, and that growing
demand is likely to continue as long as
the Sunbelt attracts new residents.
The nation has also experienced
country-wide and regional droughts with
the ground-water resource being the
focus of attention. Development of water
supplies capable of weathering long
periods of drought is an attractive goal
that increases in appeal with each
passing drought event. Although the
ground-water resource is not immune to
drought, its sheltered environment and
the large volumes of ground water in
storage lend the resource to
supplementary water service during
times when streamflow and surface
storage are deficient.
The "drought resistant" characteristic
of ground water is already utilized on an
unplanned basis over much of the
country. For example, the extensive
drought of 1977 caused failure of surface
water supplies in California's Central
Valley. However, increased pumping
from active irrigation wells, reactivation
of idle wells, and drilling of thousands of
new wells successfully maintained the
flow of irrigation water and minimized
the impact of the drought on food
production. Institution of organized plans
for supplementary irrigation pumpage
during drought throughout the nation
would result in a sizable increase in
ground-water usage.
Irrigation, an established agricultural
practice in the West, is now being
adopted in humid areas of the country as
well. It is the largest usage of ground
water, amounting to slightly more than
60 billion gallons a day in 1980, when
pumpage exceeded one billion gallons a
day in eight western states and two
eastern states.
In Nebraska, irrigation pumpage
amounted to 6.7 billion gallons a day in
1980. The development of center-pivot
equipment, whereby a moving sprinkler
pipe rotates around a central supply well
to irrigate a large circular area, has led to
a manifold increase in irrigated acreage
and enlarged dependence on ground
water as a source of irrigation supply.
With the aid of center-pivot irrigation and
other newly developed equipment,
irrigation usage of ground water in
Georgia rose 1,000 percent between 1975
and 1980.
Large amounts of water will be
required for new energy-producing
industries, particularly for the generation
of power. Wherever surface sources of
water are insufficient or already fully
committed, ground water is likely to be
targeted for additional water supply. The
Madison Aquifer, for example, an
extensive and largely unutilized water
source lying beneath the Great Plains
states, is the subject of intensive
investigation as a potential source of
water for mining operations, coal-slurry
pipelines, and power generation.
Finally, because of the decreasing
availability of surface sites suitable for
large water reservoirs and the
environmental objections they often
precipitate, ground water is becoming a
substitute source of supply for many of
the needs presently fulfilled by surface
reservoirs.
JULY/AUGUST
27
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Consequences of
expanding usage
Continued increases in extracting ground
water have unavoidable impacts. From a
hydraulic point of view, pumpage from
an aquifer or ground-water basin must
result in lowering ground-water levels.
Deepening water levels, though
necessary to progressive development,
impose both a loss of well yield and the
expense and power consumption of
increased pumping lift. The lower water
levels may also reduce flows of
hydraulically connected streams by
decreasing natural discharge of ground
water to them. With continued pumping
and still further declines in water levels,
water from streams may be induced to
flow into ground-water systems.
Inflowing stream water of inferior quality
will degrade the quality of ground water.
Similarly, saline ground water
bordering the edges of the continent may
be induced to flow toward coastal well
fields, threatening freshwater supplies.
Upward movement of saline water
underlying fresh ground water
throughout most inland areas is likewise
stimulated by pumpage of fresh ground
water, and may rise to contaminate fresh
supplies.
Extracted ground water may be
returned to the ground-water system
after use by artifical recharge and
irrigation field seepage. Recycling of
ground water in these ways extends the
supply but progressively reduces the
quality of the water. In a somewhat
similar manner, subsurface disposal of
liquid wastes adds to the volume of
ground water in storage but jeopardizes
its quality.
Land subsidence caused by the
extraction of ground water is less well
known than problems of supply and
quality, but this costly structural
phenomenon is becoming more
prevalent with increasing development of
K-S
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;
*
the nation's ground water. Subsidence is
associated with pumping from artesian
and semi-artesian aquifers containing
fine-grained sediments susceptible to
compaction in response to the lowering
of water levels. Subsidence has been
identified in California, Arizona, Texas,
Louisiana, South Carolina, Virginia, and
several other states.
The most serious cases are in the
Santa Clara and Central Valleys of
California and the Houston-Galveston
area where damaging land-surface
declines ranging from about 3 to 30 feet
have been measured. The textural
structure of the sediments is altered
permanently by compaction, with
consequent permanent loss of water
storage capacity. A long list of other
economically significant harmful effects
include structural damage to buildings,
levees, roads, and bridges; inundated
coastal areas; and changes in grade of
canal systems and irrigated land slope.
Deterioration of ground-water chemical
quality reduces its usefulness. During the
past decade a great deal of information
was published on the actual and
threatened degradation of the nation's
ground-water resource as the result of
intentional and incidental introduction of
waste liquids to the subsurface. Other
articles in this issue of EPA Journal
describe the geographic extent and
severity of contamination of the resource,
and measures being implemented to
cope with the situation.
Although some degradation is
inevitable in our industrial society,
chemical deterioration of ground water to
the point of erasing its utility constitutes
virtually the same loss of resource
incurred by volumetric depletion, and
usually without having put the "lost"
water to a useful purpose. From a purely
hydrologic standpoint, a case can be
made for utilization of subsurface pore
space for controlled storage of waste
liquids in judiciously selected hydrologic
EPA JOURNAL
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settings. However, much of the
ground-water contamination identified at
this time originated under circumstances
devoid of effective control measures and
with limited understanding of, or
indifference to, the receiving hydrologic
system.
The future
The slow rate of movement of ground
water — only a few feet to several
hundred feet a year in most cases —
imparts "slow motion" to the dynamic
changes taking place as the water
migrates from areas of influx to areas of
discharge. These gradual hydraulic and
chemical changes distinguish the
resource from stream systems in which
flow rates and quality changes are
relatively rapid. Accordingly, the
characteristics of hydrologic problems
and of management requirements
commonly differ for the two
environments. A particle of water or
waste might enter and leave a stream
network in a few days. Ground-water
problems are not "flushed away" so
easily.
Thus, ground-water conditions
identified today are a legacy of past
events, natural and man-engineered, and
left to natural hydrologic processes will
change only slowly. Hydraulic, chemical,
and structural ground-water problems
confronted today will remain
problems—hopefully with some gradual
lessening of seriousness—tomorrow. A
ground-water reservoir depleted by
pumpage over a period of decades may
require a similarly long (or longer) period
of rest to recover, unless artificially
replenished. A contaminated
ground-water reservoir will flush out its
degrading chemicals naturally only over
a long period of time. In the time frame
of practical planning, the chemical health
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60 ~
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50 §
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40
30
20
10
Total ground-water
withdrawals
Irrigation
Self-supplied industrii
Public supply
Rural supply
of the reservoir may never be restored
unless effective measures are instituted
to accelerate the process. Unfortunately,
economic and practicable reclamation
technology for ground water is in its
infancy.
Presently, withdrawals of ground water
are on the order of only 10 percent of the
estimated natural flow through the
nation's ground-water systems. From a
national perspective, therefore, the
resource is far from overdeveloped, even
though locally the situation varies widely.
Except for large parts of the Southwest
and certain smaller areas elsewhere,
increased ground-water pumpage
remains a viable option in water
resources management. Contamination,
too, has affected only a relatively small
percentage of the resource, although
local cases of contamination are widely
prevalent. An improved future for the
nation's ground-water resource, then,
would appear to rest on curtailment of
damaging practices; the introduction of
well-informed, judicious management;
and patience while nature acts. With
regard to further development of the
resource and its protection from
deteriorating actions, good management
can make a big difference. Clearly,
effective control of the influx of
contaminants would be a good
beginning. No insurmountable technical
or scientific barriers lie in the path of
improved management practices.
Institutional barriers, however, as always
will present major challenges. C
1950 1955 1960 1965 1970 1975 1980
JULY/AUGUST
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The Ground-Water Issue: Two Viewpoints
How serious is the nation's ground-water
problem? What should be done about it?
EPA Journal asked two experts looking
at the problem from different vantage
points for their views. James T. B. Tripp,
an attorney hand/ing ground-water cases
for the Environmental Defense Fund,
describes the ground-water situation in
Nassau County, New York, and the
lessons he believes it offers nationwide.
Dr. Thomas M. Hellman, Chairman of the
Chemical Manufacturers Association's
Environmental Management Committee,
analyzes the ground-water issue from a
more general perspective. Their articles
follow:
Ground-Water
Lessons From
Nassau County,
N.Y.
by James T. B. Tripp
Oome three million people live in Nassau
and Suffolk Counties, Long Island, New
York. They all depend on the Island's
ground water as the sole source of water
supply. The Island's ground water is also
the predominant source of fresh water
for the area's fresh water wetlands, rivers
and bays. Thus, the quantity and quality
of ground water are critical concerns to
Long Island's residents, economy, and
environment.
In part for these reasons, Long Island's
ground-water hydrology and quality are
perhaps the most studied of any such
system in the country. The U.S.
Geological Survey, the New York State
Legislative Commission on Water
Resources Needs of Long Island, the
Long Island Regional Planning
Commission, the State of New York
Department of Conservation, the County
Health Departments, and Cornell
University have all undertaken extensive
studies of Long Island's aquifers. Nassau
County may rank as the first county in
the United States to have discovered
measurable quantities of toxic organic
compounds in some of its public water
supply wells. Those wells had to be
closed, almost ten years ago. Long Island
therefore often serves as a laboratory for
the nation in its effort to improve
ground-water protection and
management.
Starting with the preparation of the
Long Island Section 208 Water Quality
Management Plan in 1975, Nassau and
Suffolk Counties identified their critical
recharge watershed areas where
precipitation flows deep into the water
table Glacial Aquifer and the deeper
Magothy Aquifer. In Long Island, these
critical watersheds, with sandy soils
underlying them, are generally located in
the middle third of the Island and extend
out the Island's South Fork. Much of their
original vegetation was oak brush and
pine barrens. Of this vegetation, only
remnants remain in central Nassau and
western Suffolk Counties. Eastern Suffolk
is better off in this regard.
About 110,000 acres of largely
undeveloped pine barrens remain in
central eastern Suffolk County and the
South Fork. The Long Island Regional
Planning Commission 208 Plan of 1978
designated most, but not all, of these
eastern Suffolk Pine Barrens as a special
hydrogeological zone which should be
subject to special land use controls.
Halt Development?
Since the ground water recharged
through these pine barrens is of
remarkably high quality, and the sandy
soils would allow for easy percolation of
contaminants, a group from the New
York State Legislative Commission on the
Water Resource Needs of Long Island,
Group for the South Fork, Museum of
Long Island Natural Sciences, Friends of
the Earth, the Sierra Club, and the
Environmental Defense Fund published a
report entitled Watershed Planning for
the Protection of Long Island's
Groundwater (September 1982) in which
we recommended a virtual halt to
development in the remaining Pine
Barrens to retain it as a vast undergraded
watershed, with growth redirected to the
periphery of this vital recharge zone. Two
of the eastern Suffolk County townships,
Southampton and East Hampton, have
undertaken major rezonings of this
watershed within their boundaries.
Due to its size and development status,
Suffolk County can probably retain a
large enough reservoir of high quality
ground water through adoption of
aggressive watershed protection
programs. Nassau County's situation is
much more problematic. Its population is
comparable to that of Suffolk County,
but its land size is only about one-third
as large. Further, much of its central
recharge area has experienced intensive
industrial, transportation, and residential
development. Thus, the major landfills
and industrial waste sites of Nassau
County are situated in this central
recharge zone away from the county's
coastal areas. Organic and other
chemical contaminants from these
sources are moving deep into Nassau
County's two major aquifers. Clearly, this
development pattern occurred in Nassau
County at a time when the critical
recharge zone concept was unknown or
its soils were deemed to be effective
traps for contaminants.
With a population of about 1.68 million,
daily withdrawal of about 180 million
gallons, and total estimated budget area
recharge of some 200 million gallons per
day, Nassau County does not, under the
best of circumstances, have much room
to maneuver to retain water supply self-
sufficiency. Already, on a regional basis
within the county, ground water is being
mined. Further, as organic and nitrate
contaminants extend deeper and
laterally, quality considerations will
impose additional constraints on supply
availability.
Time is therefore running out for
Nassau County. While it may consider
other supply options, such as imports
from New York's system or from Suffolk
County, use of alternative supplemental
sources of supply faces economic and
political obstacles. What, then, should
Nassau County do to maintain
self-sufficiency in water supply in a
cost-effective and environmentally
satisfactory manner?
Some of us active in the preparation of
Watershed Planning for the Protection of
Long Island's Groundwater, joined by
30
EPA JOURNAL
-------
others from New York Community Action
Network and the Natural Resources
Defense Council, have once again joined
forces to address this issue. What is
apparent is that policy debates should
not continue forever; in Nassau County,
the time for action is now.
Six Components
A ground-water action program for
Nassau County must have six major
components to meet this objective.
First, while much of the Nassau County
central watershed is heavily developed,
some 10,000 acres of it, in northern
Nassau straddling and north of the
ground-water divide, are not intensely
developed. Local governments and the
county, with support from the state,
should designate these lands as a special
protection area and use their zoning
powers to limit future development with
a view to preventing degradation of this
ground water. While Nassau County does
not have the extensive undeveloped
watersheds of Suffolk County, it still has
watershed lands which it should protect.
Just because so much of Nassau
County's central recharge area is
intensely developed, designation and
protection through stringent land use
controls of its remaining watershed is
critical.
Second, EPA, the state, the county and
its townships must proceed expeditiously
to implement a program for cleaning up,
containing, and isolating the industrial
waste sites and landfills (some eligible
for Superfund support) in the central
recharge zone. Since the toxic
contaminants from these sources have
penetrated deep into the ground-water
system, remedial action to clean up the
polluted ground water is probably
hopelessly expensive. However, through
removal and treatment of wastes on the
land surface, capping, and other
techniques, it should be possible to abate
introduction of more contaminants from
these sources into the ground water.
Sooner rather than later, the responsible
agencies must move beyond assessment
and monitoring and take action in the
field to contain, remove, and/or treat
these wastes.
Third, private and public open spaces
used for golf courses and parks are
located throughout both the intensely
developed and less developed parts of
the central watershed. Fertilizers and
pesticides used on these lands are a
major source of contamination. The state,
county and towns should adopt limits on
uses of these chemicals to avoid further
contamination. They must recognize the
watershed, as well as recreational,
function of these lands.
Fourth, because of the extent of the
penetration of the ground-water system
by organic contaminants, some of the
county's water suppliers will have to
install appropriate treatment technologies
to remove toxic pollutants, at least on an
interim basis. Use of such technologies
should not serve as an excuse for failing
to take other urgent action. It is far better
to have programs in place which prevent
contaminants from entering the ground
water in the first place. But Nassau
County does not have the luxury of
relying solely on preventive strategies.
Ideally, over time, supply treatment will
become less necessary as preventive and
control actions protect and restore the
ground water.
Fifth, the county should pursue
vigorously wastewater reclamation and
recharge. Presently, much of the county
is sewered, and treated wastewaters are
discharged in'o coastal waters. Both in
terms of maintaining water supplies and
ground water-dependent ecosystems,
scientifically controlled reclamation and
recharge makes sense. The county, with
state and EPA support, has sponsored a
5 million-gallon-a-day reclamation
recharge demonstration project. It should
pursue and expand this project, not
discontinue it, as has happened.
Sixth, water supply conservation is a
necessity. Both carrots and sticks should
be used. The state has water well
regulations which in theory could limit
withdrawals to achieve a conservation
management objective, although they
have not been so used. Water pricing
strategies tied to watershed protection
and cleanup programs could also serve
to dampen demand. In addition, required
use of water recycling systems and
water-conserving devices would further
conservation. Compared to other
alternatives, we expect that an
aggressive conservation program,
designed to reduce per capita demand by
15 to 20 percent, would be cost-effective.
What is needed are the institutional
reforms to implement such a program.
Crises create opportunities. Nassau
County should face the reality of its
ground-water quantity and quality crises
and act aggressively. If it does so, it will
have established an action program from
which the many communities in the
country that face ground-water quantity
and related quality problems could
benefit.
JULY/AUGUST
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The Ground-Water Issue:
(continued)
Ground Water:
A Major Concern
by Dr. Thomas M. Hellman
/Tound water has become a major
^national issue that will continue to be
debated throughout the 1980s. The
ground-water issue is complex and the
political and economic stakes are
enormous.
Ground water is an important resource
that contributes significantly to the
economic well-being of the nation. As a
society we have historically used ground
water for a wide variety of purposes and
we will continue to do so in the future.
Increasing use of ground water and
rapidly improving monitoring and
analytical capabilities increase national
attention to the issues of quality and
quantity.
There has been an approximate 200
percent increase in this nation's
population in the past 80 years, but the
consumption of water on a per capita
basis has increased 500-800 percent. This
is about 2,000 gallons of water used per
day for each man, women and child in
the U.S., and three times the per capita
water use by the Japanese. There is
growing concern that the supply of our
nation's ground water is being used at a
rate greater than the resource is being
replenished. Many experts compare
today's water problems to the energy
crisis of the 70s. Water, they predict, will
be the resource crisis of the 80s.
Many states are facing the growing
reality that the crisis over water will not
abate in the near future. Southern
California and Arizona have battled one
another for the right to water from the
Colorado River. Arizona won that legal
fight.
Southern California is also trying to
gain access to the abundant water supply
of northern California. New Mexico,
Texas, and Colorado are locked in a
dispute over rights to both surface and
ground water. The eastern half of
Colorado wants more water from west of
the Continental Divide. Native Americans
in the West have filed lawsuits claiming
rights to enormous amounts of water
based on terms of peace treaties signed
during the 1800s. The list goes on, and
includes the eastern half of the country
as well as the western.
The concern about this resource is
genuine for several reasons. First, the
supply is unevenly distributed. Most of it
is concentrated in the eastern half of the
United States and in the Pacific
Northwest, while in the more arid
western regions of the country farmers
are competing with urban residents and
industry for the available ground water.
Another concern is the management of
this resource. Historically, we have had
an abundant supply of ground water for
all uses. But today we are becoming
more aware of the limitations of this
valuable resource. In order for everyone
to have the continued access that we
have enjoyed in the past, we must begin
to protect and manage the nation's
ground water in a sound and rational
fashion. Safeguarding water quality and
quantity requires comprehensive
ground-water management on a federal,
state, and local level.
In looking at modern man's
achievements in ground-water
management, we see extraordinary
knowledge and skill in hydrology. On the
other hand we have ground-water
shortages caused by overpumping,
scattered chemical and biological
contamination, saline and contaminated
river water intrusion into fresh water
aquifers, and serious subsidence
problems.
We are fortunate that the supplies of
ground water in this country are vast. If
we act now to apply our knowledge and
skills in protecting this resource, we can
assure the development of a sound
ground-water management system
resulting in a supply of water for all uses.
Comprehensive ground- water
management is necessary to protect
public health and the environment while
responsibly maintaining multiple uses of
the resource. This type of an approach is
needed to insure that we do not misuse
our ground-water resource.
Ground water is one of the nation's
most valuable, but least understood,
natural resources. Out of sight, ground
water is all too often out of mind.
However, new awareness and knowledge
of the effects of human activity on the
subsurface environment force us to
recognize that this resource — once
thought to be protected from pollution by
layers of soil and rock— is indeed
vulnerable.
One viable method of protecting
ground water is through the
development of a comprehensive
use-based classification system. The
concept of ground-water classification is
practical and technically feasible. A
ground water use-based classification
system provides a basis for planning and
action. Such a system combines a goal, a
management approach, a technical
approach and a state/federal relationship.
A use-based classification system
maintains multiple uses of the resource
while protecting human health and the
environment. This is done by: a)
recognizing existing ground-water uses,
b) protecting future ground-water uses,
32
EPA JOURNAL
-------
.
c) accounting for the occurrence,
availability and chemical and biological
quality of ground water, and d) ensuring
that different uses of the same ground
water are compatible.
The flexibility of this type of water
management system allows it to be
successfully applied on a micro- and a
macro-geographic basis. The concept of
classification is not a solution in itself but
a useful tool in a comprehensive
ground-water management plan.
Congress has already taken several
important steps toward protecting our
ground-water resources. Major
environmental legislation has been
enacted to control potential discharges to
aquifers. The requirements of existing
statutes such as the Clean Water Act and
the Comprehensive Environmental
Response, Compensation and Liability
Act (Superfund) are reducing and
controlling industrial, commercial, and
municipal facility discharges that
contribute to ground-water
contamination.
Several states presently have water
pollution control statutes that extend to
ground water. Many states have specific
statutory authority to develop
ground-water management systems.
Most of the western states have
implemented general permit systems for
allocating the quantity of ground water.
A few eastern states have followed suit,
although quantity is generally not a
priority because of an abundant water
supply.
The question of who has the ultimate
authority over the management of
ground water is an important one. We
believe the states should have the
primary responsibility for developing
their own ground-water management
plan and implementing ground-water
policy. The federal role should be one of
adviser, funder, and supplier of technical
assistance and scientific information.
Congress and EPA both have
determined that ground water protection
will be one of their primary activities
during the next few years. Congress is
currently addressing the reauthorization
of the Safe Drinking Water Act with
proposed bills in the House and Senate,
and EPA has recently completed a
ground-water protection strategy. It is
important that we manage our ground
water so we can maintain multiple uses
and assure that there is a safe and
sufficient supply of water for all uses in
the years ahead. D
JULY/AUGUST
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