United States
  Environmental Protection
Office of
Public Affairs (A-107)
Washington DC 20460
August 1984
   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
   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
  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
  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

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
  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
  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
  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
  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

• 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

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
  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
  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
  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
  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
  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
                                                                                                            EPA JOURNAL

Coordinating  Protection

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.

     When did the country begin to
realize it has a problem with ground
                                           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.
       What is the nature of the
ground-water problem?
      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
                                              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
                                         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
                                              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.

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
   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.
       Do you believe that we've got a
crisis on our hands with polluted ground

 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
  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

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.
       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.
                                               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

  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
   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

 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
  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.
      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
  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.

  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
       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

 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
  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
       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
  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
    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
                                                                                                           EPA JOURNAL

 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
  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
  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
• design of state ground-water
protection  programs,

• management of ground  water-related

• seminars and  conferences for state
staffs, and

• consultation on issues concerning
interstate aquifers.

  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

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

• 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

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
  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

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
                                                                                                           EPA JOURNAL

 From  the  States'
 Point  of  View
 by Governor Bruce Babbitt
    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
   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
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

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
  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
  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
  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;
                                                                                                             EPA JOURNAL

 •  Elaboration of risk assessment and risk
 management methodologies for ground-
 water contaminants; and
 •  Assistance in aquifer mapping, and
 development of ground-water modeling
   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
   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
   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
   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
   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
  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
  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

2. The authority to set standards by
regulation for the design, installation,

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.
        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

• 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
  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

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
Class G-lll: Nonpotable water use having
a TDS of over 10,000 mg I  in unconfined
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
  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

 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
      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
  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
  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
          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
  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

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
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
        Louis  W. Bercheni

       Bureau of Water Quality
     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
  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
  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

Sources  of
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
  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.


 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
   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

         / Injection Well W?/>//            ^\\\M
         /  or Disposal   /   /' Pumping WelT \  -x
         /                /
Land Spreading    Septic Tank/
                                                                                                         Pumping Well
                                                                                                          \      I
                                                                                           Lagoon, Pit or Basin
                    Cesspool   Sewer
                                                    o£7!Water Table

                                                         *        Water Table Aquifer
                   Discharge  Lea&ge
                                                                 Confining Zone
                                                                 Artesian Aquifer (Fresh)

                                                                 Confining Zone
                                                              Artesian Aquifer (Saline)
          Discharge or Injection
                                                                                                            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

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

Most things that contaminate ground
water may be placed in one of three
broad groups: biological organisms,
inorganic chemicals, and organic

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
  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

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

• 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

Contamination  of Drinking
 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

• 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
                                                                                                        EPA JOURNAL


 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

• 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,

• 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

• 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

• Analytical  techniques will continue to
improve and some areas once thought to
be "clean" will turn out to be

• 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

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
   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
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
  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
                                                                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
  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
  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
  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

 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
  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
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
  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
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                                                   •»                       ••<-.-vj                      .   	
                                                          to deter::
 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

                                        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
  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


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
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
• 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

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

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

 • 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

 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

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
  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
•li i


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

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

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
  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
60 ~


50  §
Total ground-water
            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
  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

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
Lessons From
Nassau  County,

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
  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
  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
  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
                                                                                                  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
   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

The  Ground-Water  Issue:
 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
   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
   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
  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
  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
  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,
                                                                                                       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
  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
  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