United States
           Environmental Protection
           Office of
           Drinking Water
           Washington DC 20460
                                 June 1980
Planning Workshops
to Develop
Recommendations for
A Ground Water
Protection Strategy




                     DEVELOPING AN EPA
                   GROUND WATER STRATEGY

     These Appendices supplement the papers on "Developing
an EPA Ground Water Protection Strategy" that were assembled
for the Environmental Protection Agency workshops to be held
in late June.  They include papers on ground-water use and
pollution, descriptions and analyses of current laws and
activities at the Federal and State levels, and a discussion
of research categories for ground water.

     The ten papers serve various purposes and may appeal to
readers of different professional interests and perspectives.
The content ranges from a general overview of ground water
(Appendix I) to technical discussions of various State and
Federal laws affecting ground water (Appendices VI and VII)
to possible future research in this area (Appendix X).
Through this wide range of topics, these papers bring
together current information on the subject of ground water.

     This document will be made available to Workshop
participants and others who wish further reading on the
issues facing the EPA in developing a ground water protection

                    TABLE OF CONTENTS
   I     Ground Water Fundamentals 	   1-1

  II     Ground Water Use in the United States	II-l

 III     Summary of Ground Water Damage in the
         United States 	 III-l

  IV     Synthetic Organic Contamination in Ground
         Water	IV-1

   V     Analysis of State and Federal Programs by
         Pollutant Source  	   V-l

  VI     Analysis of EPA Laws and Potential Application
         to Ground Water	VI-1

 VII     A Synopsis of Federal Laws Relating to
         Ground Water  	 VII-1

VIII     Current State Ground Water Management Programs. .VIII-1

  IX     Other Federal Programs with Ground Water-
         Related Responsibilities  	    IX-1

  X      Ground Water Research Strategy  	     X-l

  XI     Acronym List	    XI-1


     This document represents the completion of Phase I
of a three-phase approach to the development of a Ground
Water Strategy.  Phase I involved the assembling of current
information on ground-water use and pollution,  Federal and
State laws and programs, and the state-of-the-art in ground-
water protection.  (Phase II will be the June workshops.
Phase III will be the publication of a strategy that reflects
the views of the workshops in the Federal Register and public
meetings to be scheduled in the Fall.)

     This set of papers and appendices evolved from the
working papers submitted by four EPA Work Groups composed
of principal representatives of several Deputy Assistant
Administrators and the Regions.  "Using information currently
available, the Work Groups were asked to define the nature
and extent of the ground-water problem, identify the major
policy choices, estimate related resource implications, and
make recommendations for action in selected areas.

     A project of this proportion requires the collaborative
efforts of many individuals working within various EPA
programs and professional areas.  The members of the Policy
Committee and the Work Groups and their Task Force chairpersons
are listed below.  In addition, many persons from EPA
Headquarters and Regional Offices participated as members.
We thank them for their intensive work over several months
that made this document possible.

                     Policy Committee

Victor Kimm, Deputy Assistant Administrator for Drinking Water
Mike Conlon, Associate Deputy Assistant Administrator for
 Pesticide Programs
Swep Davis, Associate Assistant Administrator, Office of
 Water and Waste Management
Al Erickson, Associate Deputy Assistant Administrator, Water
 Planning and Standards
Roy Garose, Deputy Assistant Administrator for Planning and
Alan Hirsch, Deputy Assistant Administrator for Env. Processes
 and Effects Research
Henry Longest, Deputy Assistant Administrator for Water
 Program Operations
R. Sarah Compton, Deputy Assistant Administrator for Water

Steffen Plehn, Deputy Assistant Administrator for Solid  Waste
Jim Rogers, Associate General Counsel
Jack Schramm, Regional Administrator, Region III
David Standley, Director,  Water Division,  Region. VIII
Charles Sutfin, Director,  Water Division,  Region V
Leonard Wood, Hydrologist, U.S. Geological Survey
Marian Mlay, Associate Deputy Assistant Administrator
 for Drinking Water, (Executive Secretary to Policy Committee)

         Work Groups and Task Group Chairpersons

Arnold Kuzmack, Director,  Office of Program Development
 and Evaluation (Task Group Chairperson)
Alan Levin, Director, State Programs Division (Task Group
Merna Kurd, Director, Water Planning Division (Task Group
Jack Keeley, Chief, Ground Water Research Branch, Robert S. Kerr
 Environmental Research Lab  (Task Group Chairperson)
Alan Abramson, Director, Water Division, Region VII
Ronald Brand, Acting Director, Program Evaluation Division
Hal Cahill, Director, Municipal Construction Division
Mark Gordon, Attorney, Office of General Counsel
Clint Hall, Associate Deputy Assistant Administrator for
 Env. Proc. and Effects Branch
Martin Halper, Director, Survey and Analysis Division





     The nature and extent of the ground-water problem
will be best comprehended with a basic understanding of
the natural occurrence of ground water.  This paper
provides basic geology and hydrology information to
workshop participants who do not have a technical background,
While many experts attending the workshop will find this
elementary, we hope it will be useful to participants who
feel the need for a "refresher."

     Ground water is defined as water that exists beneath
the surface of the ground and occurs in aquifers which
are geologic formations that contain enough saturated,
permeable material to yield usable amounts of water to
wells and springs.

     Aquifers underlie most of the United States, although
some of these aquifers are not widely used because of
their depth, the quality of the water, or the yield of
the aquifer.  In general, the degree to which an aquifer
is used is a function of the availability of good quality
surface water and the relative cost of delivering the
ground water to individual users.

     Aquifers are categorized as unconfined  (water table)
and confined (artesian).  Water table aquifers are over-
lain by material which is reasonably permeable so that
water can percolate from the surface through the natural
pore spaces or through open fractures.  The upper surface
of the saturated zone in the aquifer will be at atmos-
pheric pressure and is referred to as  the water table.
In most cases, water table aquifers are fairly shallow
and are interconnected to local rivers and creeks which
will either receive water from the aquifer, recharge  the
aquifer or both.

     Artesian aquifers are confined by a layer or layers
of material such as clay or shale which are relatively
impermeable so that water in a well tapping  the aquifer
will rise above the top of the aquifer.  The amount of
water level rise depends on the hydrostatic pressure  at
that point.

     The recharge of confined aquifers has historically
been considered to be in the upgradient portion of the
aquifer where the confining beds are absent, allowing
precipitation or infiltration from streams to directly
enter the aquifer.  In these zones the aquifer is under
water table conditions.  An example of this recharge zone
would be found for the Atlantic Coastal Plain confined
aquifers along with the western edge of the coastal plain
near the Piedmont Province (the Fall Line).  The amount
of recharge would be controlled by the thickness of the
unit, its areal e'xpanse, surface conditions and the perme-
ability of the unit, and amount of water available for
recharge.  A significant amount of recharge to confined
aquifers occurs through the confining beds.  Even though
the confining beds are considered "impermeable," their
low permeability still transmits considerable volumes of
water over large areas.  The term "aquiclude," referring
to "impermeable" confining beds, is being replaced in
hydrogeologic thought by "aquitard," referring to beds
which retard the flow of water.  The replacement of
aquiclude by aquitard has occurred as a result of the
recognition that confining beds do actually transmit
large quantities of water over large areas.

     The component material and structure of aquifers
allows their further classification of aquifer into unconsoli-
dated or consolidated rock, and primary or secondary
permeability.  Unconsolidated rocks such as alluvial and
glacial sands and gravels consist of loose particles
which transmit water through primary permeability.
Primary permeability is due to open, interconnected pores
occurring between particle grains which are created when
the rock is formed.  Consolidated sedimentary, igneous
and metamorphic rocks are characterized by interlocking
or cemented grains or minerals which make up the rock.

     Consolidated rock may have both primary and secondary
permeability.  Secondary permeability is due to voids
created in the rock sometime after its formation and
solidification or consolidation.  The secondary permeability
features are joints, fractures, faults and solution
channels.  In consolidated rocks, the primary permeability
is generally insignificant and the aquifer transmits
water through the secondary permeability of fractures or
solution channels.  The exception generally is sandstone
where, depending on degree of cementation, the primary
permeability may be significant.


     The unconsolidated aquifers (i.e.,  sand and gravel)
are generally the most prolific ground-water producers
because of their relatively high porosity and perme-
ability.  Consolidated rocks are variable in yield depending
on degree of cementation or fracturing.   Limestone and
dolostone (carbonate rocks) "yields are dependent upon
the degree of fracturing and the enlargement of these
fractures by solution of the carbonate mineral by acidic
ground water.  The igneous and metamorphic rocks are
also dependent on fractures for permeability, except
basalt.  Whereas granite (the major igneous rock) and
schist and gneiss (metamorphic rocks) owe their permeability
entirely to fractures, basalt also may contain considerable
primary permeability from lava tubes (open tunnels formed
by entrapped gasses in the molten lava)  and interbedded
alluvial and weathered material which provides consider-
able yields in the basalt flows of the Columbia plateau
of the Northwest.

     The importance of aquifer types to ground-water
contamination is that the relative ease with which
contaminants migrate into the ground water is con-
trolled by the permeability and component material of the
aquifer and overlying earth material.

     Confined aquifers are relatively safe from con-
tamination by surface sources as compared to unconfined,
water table aquifers.  Confining beds (aquitards) tend to
slow and inhibit the movement of contaminants and the
upward-directed hydrostatic pressure in many confined
aquifers prohibits flow into the confined aquifer.  If
overpumping of the confined aquifer is allowed,  it may
lower the hydrostatic head enough to allow movement of
overlying contaminants into the confined aquifer.  The
historic conception that recharge occurs only in the up
dip outcrops (as mentioned previously) leads to an erroneous
conclusion that confined aquifers are completely immune
from contamination outside of that outcrop area — they
are not completely immune.

     Unconfined aquifers may be very vulnerable to con-
tamination depending on the component material and thickness
of the overlying unsaturated zone.  Aquifers already
designated as Sole Source Aquifers pursuant to Section
1424e of the SDWA .such as the Edwards Limestone in Texas
and the .Spokane-Rathdrum Aquifer (alluvial sands and
gravels) in western Washington illustrate the dangerous
vulnerability of shallow aquifers which have little or
no overlying earth material.


     Unconsolidated aquifers consisting of sands or
finer grained material act to slow down the advance of
contaminant plumes in the aquifer.  These finer grained
materials along with clays and organic material in the
unsaturated zone and in the aquifer provide attenuative
capacity by sorption, ion exchange and filtration, all
of which act to reduce concentrations of contaminants.
This attenuative capacity is highly variable because
of the interactions between different waste components
and the earth material.  Some contaminants are not
attenuated at all, while others are attenuated under
certain Eh/pH conditions, but not under other, conditions.

     Aquifers having secondary permeability transmit
water through fractures or solution channels.  Once con-
taminated, the plume may move very quickly, as in
cavernous limestone with velocities of miles per day.
In addition, consolidated aquifers having secondary
permeability have much reduced capacities for attenuation.

     Monitoring for ground-water contamination is de-
pendent to a large degree type of aquifer.  Aquifers
of fractured or solution channeled rock have unpredictable
flow paths which may change directions drastically as
the ground water flows through the interconnecting fractures
and channels.  Unconsolidated alluvial and glacial deposits
frequently consist of interbedded and interfingering lenses
of clay, silt, sand and gravel.  Flow paths through such
complex geology are very difficult to deduce with the
limited data generally available.  Attempting to monitor
ground water with wells in such conditions is often
difficult and expensive, requiring considerable expertise
in hydrogeology.



                    GROUND WATER USE IN
                     THE UNITED STATES

     This paper presents information on ground-water use
and overdraft in the United States for the past,  present
and future as background to the development of  a  national
ground-water protection strategy.  It includes  a  presenta-
tion of a range of ground-water withdrawal projections
for the years 1985 through 2000.  Projecting the  use of
any product or service far into the future is difficult
because the factors that affect its demand or use also
change over time — this is particularly the case with
ground water.  This paper will address the specific
factors that affect demand and the magnitude of these
factors over time.

     There are several methods available for making pro-
jections.  Some are as simple as applying the compound
growth rate of past years to future years.  Others involve
the construction of complex mathematical models using
techniques such as regression and correlation analysis.
Additional methods involve the application of major
indicators of change in a subjective manner to the forecasts.
The latter approach is appropriate when major policy
shifts in the future are expected to affect the underlying

     When using those techniques, care must be taken in
determining the key independent variables and the sensitivity
of the final forecasted results to changes in the values
of the independent variables.  If the sensitivity of the
final forecasted results to the independent variables is
not recognized and pointed out, the end user of the
projections may be misled in conclusions reached using
the projections.  Such misuse of projections, particularly
at the policy-making level, can lead to suboptimal decisions
and misallocation of national resources.

     The methods applied to the process of projecting
ground-water use in 1985 and 2000 combine some elements
from each of the above methods.  Extrapolations of past
trends, based on the Water Resources Council's (WRC)
First National Water Assessment, are used for high range
projections while historical ground-water use rates are
applied to total national withdrawal projections published
by the Water Resources Council in the Second National
Water Assessment to generate medium range projections.

A lower range was projected to account for a number of
causative factors such as energy costs which will influence
future ground-water use.  Each of these projections and
the principle variables that may determine the future use
levels are discussed in detail below.  No mathematical
models are presented in this document but the key variables
are described.  It is important to recognize the relation-
ships between these variables which could be expressed
The Past

     The ground-water resource has become increasingly
valuable during the past 35 years.  An indicator of
economic value is the withdrawal rate.  Ground-water
withdrawals in the United States have quadrupled since
1945, increasing from 21 billion gallons per day to 82
billion gallons per day in 1975.  Withdrawals increased
from 68 to 82 billion gallons per day during the five
year period from 1970 to 1975.  In 1975, total withdrawals
from both surface and ground were approximately 340
billion gallons per day.

     The largest share of the increase was attributable
to withdrawals for agricultural purposes.  Agricultural
withdrawals were applied primarily to the irrigation of
cropland.  Irrigation withdrawal amounted to 21 billion
gallons per day in 1950.  By 1975, the rate was 57 billion
gallons per day, an increase of more than 170 percent.
That year, nearly 70 percent of the Nation's ground-water
use was for agricultural irrigation.  Other uses of
ground water were also significant between 1950 and 1975.
These include public water supplies, rural water supplies
and industry.

     The following table presents total fresh water with-
drawals of ground water between 1950 and 1975 and a per-
centage breakdown by category of use.

                          TABLE I

            A PERCENT OF WITHDRAWALS:  1950-1975
Total Fresh Ground-
Water Withdrawals
Public Supplies (%)  12

Rural Supplies (%)    8

Irrigation (%)       62

Industry (%)         18















Note:  May not total 100% due to rounding.
Source:  Murray and Reeves (1972, 1977) and MacKichen and
         Krammer (1961) based on USGS data.

     At the present time, a number of factors are affecting
the amount of ground water used.  Agricultural irrigation,
energy prices, manufacturing and mineral development, and
ground-water overdraft are but a few of the influences on
the demand for this resource.  Ground-water withdrawal
and overdraft vary regionally.  This variation is reflected
in Table 2 from the Second National Water Assessment by
the WRC.  The Tennessee Region has withdrawals of 271
million gallons per day while the California Region
reaches 19,160 million gallons per day.  A number of the
regions have no overdrafting while in others overdrafts
exceed 50 percent of total withdrawals.

                                 TABLE  2
      Water resources
       region and No.
              OF OVERDRAFT ~ "19751
Range in
New England (1)	     635        00         60
Mid-Atlantic (2)	   2,661        32      1.2         6        3
South Atlantic-Gulf (3)	   5,449       339      6.2         9        8
Great Lakes (4)	   1,215        27      2.2         8        1
Ohio (5)	   1,843        0070
Tennessee (6)	     271        0020
Upper Mississippi (7)	   2,366        0050
Lower Mississippi (8)	   4,838       412      8.5         3        3
Souris-Red-Rainy (9)	     86        00         10
Missouri (10)	   10,407      2,557      24.6        11       10
Arkansas-White-Red (11)	   8,846      5,457      61.7         7        7
Texas-Gulf (12)	   7,222      5,578      77.2         5        5
Rio Grande (13) 	   2,335       657      28.1         5        4
Upper Colorado (14)	     126        00         30
Lower Colorado (15)	   5,008      2,415      48.2         3        3
Groat Basin (16)     	_   1,424       591      41.5         4        4
Pacific Norlliwost (17).		   7,348       627      8.5         7        6
California (18)	   19.160      2,197      11.5       	7        5
  Regions 1-18               81,240     20,889      25.7        99       59
Alaska (19)	     44        00         10
Hawaii (20)	     790        0040
Caribbean (21)	     254     	13      5.1       	2        1
  Regions 1-21	   82,328     20,902      25.4       106       60
    Source:   U.S.  Water  Resources Council.   Second National
              Water Assessment.  Volume 1:  Summary.
              December 1978.

    For the category of  largest use,  agricultural irrigation,
    a  few statistics are applicable  to the development of
    projections for future demand.   First, approximately 58
    million acres,  or about  14 percent of the cropland in the
    United  States,  are irrigated.  The value of crops  produced
    on irrigated  land is estimated to be 25  percent  of the
    total value of  the Nation's crops.  Ninety percent of the
    irrigated land  is located in  the 17 States farthest west
    (excluding Alaska and  Hawaii).   Approximately 47 percent
    of  the  fresh  water withdrawn  from ground or surface
    sources is used for  irrigation.   About 81 percent  of
    consumption,  i.e., water withdrawn from  and not  returned
    to ground or  surface sources, occurs from irrigation.

          The value of irrigation  to  the farmer is higher per
    acre  for fruits and  vegetables than for  most field crops.
    Fruits  and vegetables  have high  investment and production
    costs per acre.  This  increases  the economic risk  if the
    crops fail or yields are reduced because of drought.
    Irrigation reduces the risk of inadequate rainfall,
    allowing farmers to produce a plentiful  supply of  a high
    quality product at lower cost.
                                                1- 9


     The total economic or social value of irrigation is
more than just the increase in agricultural production.
Additional economic growth is also generated in the
agricultural processing and marketing industries.   As
production increases, the demand for fertilizer,  machinery,
pesticides, labor, and other commodities increases.  This
generates economic growth which is estimated to be approxi-
mately equal to the increase in the value of agricultural

     The manufacturing and minerals industry also contribute
significantly to the demand and use of ground water.
This set of industries represent 17.2 percent of total
fresh-water withdrawals from surface and ground sources
in 1975.  In 1975, manufacturing fresh-water demand was
51 billion gallons per day.  Total withdrawals for mineral
production amounted to 7 bgd in 1975, constituting 36
percent of the industry total.  Fuels mining which includes
coal, oil shale, petroleum, natural gas, and natural gas
liquids was responsible for 62 percent of the industry's
total consumption.

     Based upon the increasing demand for fuel and hence
water use, the problems of water shortages in the fuels
mining industries will appear first in the Missouri,  Ohio
and upper Colorado water resources basins (Figure 1).
For example, in the Missouri Basin, 84.5 percent of all
ground water pumped is used for manufacturing and minerals
production.  The percentage is 34.8 in the Upper Colorado
Basin and 12.6 in the Ohio Basin.  As these resources are
developed, and, assuming production technology remains
basically the same, the availability of ground water
could be a constraint.  This is particularly true in the
Missouri Basin where 10 of the 11 subregions overdraft
their ground water.

     The manufacturing and minerals industries and irriga-
tion make up approximately 83 percent of the total demand
for ground water.  The remaining 17 percent is used by
public and rural water supplies. In 1975, 21 billion
gallons per day (bgd) were withdrawn for use by central
municipal systems which was 13 percent of the total
demand for ground water.  Rural noncentral systems used 2 bgd
or 5 percent of the total demand.



     The factors that affect the past and present will
continue to be predominant consideration for ground water
demand in the future.  The two key variables which account
for over 80 percent of the ground-water demand on a
national basis are agricultural irrigation and manufactur-
ing and minerals development.  Ground-water use for
public domestic supplies is a particular concern in
quality terms but comparatively small in quantity terms.

     The demand for ground water as a source for domestic
use and manufacturing and minerals development is likely
to continue to be relatively stable as a percentage of
the total demand.  This is particularly true for minerals
development and domestic uses.  Manufacturing demand for
ground water will probably continue to decline through
1985 as the Clean Water Act's pollution abatement program
increasingly affects water uses by manufacturing.  Recycling
and reuse is being introduced not only for manufacturing,
but also for the recharge of aquifers.

     There are several parameters that will affect the
demand for ground water as a source of irrigation water,
the largest of the uses.  The first of these is overdrafting
— the withdrawal of water on a long-term basis at a rate
which is greater than the aquifer's recharge.  Approximately
25 percent of all ground-water withdrawals nationally
were overdrafts in 1975 and much of the water was applied
to agricultural irrigation.

     A second factor that continues to have an influence
on irrigation is the cost of energy for pumping.  With
overdrafting situations, supply wells have to be drilled
deeper (or abandoned), thus increasing the amount of
energy used for pumping.  An associated concern is that
energy prices are rising faster than prices for other
productions.  If the energy prices faced by farmers
increase by a factor of 5 or 10 from their relatively low
1970 levels, pumpage for agriculture could become uneconomical
for many low value or water intensive crops or locations
of cropland.  Energy prices for pumping increased fourfold
between 1970 and 1980.

     The projections of ground-water use are reflected in
Table 3 and Figure 2.

                          TABLE 3
                FOR THE YEARS 1985 and 2000
                 (Billion Gallons Per Day)

                                    2             3
                              Medium           Low

1970                            68
1980            82                              86
1985                            69              77
1990            95                              70
2000           100              90              73
I/   U. S. EPA Report to Congress.  Waste Disposal Practices
     and Their Effects on Ground Water/ January 1977.

2/   INTASA, March 1980.  Ground Water Use and Overdraft in
     the United States.  Prepared for U.S. EPA.Based on
     WRC Second National Water Assessment and USGS Report
     Estimated Water Use in the United States in 1975
     (Murray and Reeves).

3/   INTASA, Preliminary and approximate.  Decreases
     attributable to increased energy costs, etc.

                                         FIGURE 2
  100  - -
   80  --
  60  --
  40  --
  20  --
                                TOTAL FRESH GROUND WATER
                                                   USGS Data

                                                   Projections 1985 - 2000


            APPENDIX III


     The development of a ground-water protection strategy
requires an understanding of the significance of the
ground-water contamination problem:

        How extensive is ground-water contamination
         at the present time?

        Is the amount of contamination increasing?

        To what extent can ground-water contamination
         be reduced once it occurs?

     Numerous reports and studies have demonstrated con-
vincingly that ground-water contamination is a widespread
problem that affects every region of the country.  For
example, the EPA Region II office has reported that at 13
locations in New York during 197378, 28 public wells, serving
two million people, and 380 private wells were contaminated.
In eleven separate incidents in New Jersey during 197879, at
least 115 wells were closed and one major aquifer was damaged.
The existing reports and studies have been helpful in that
they have:

        Documented a large number of contamination

        Identified the most important sources of

        Determined the mechanisms by which contamination

        Studied the contamination caused by some
         incidents in depth, and

        Surveyed the number of some types of potential
         sources of contamination in the nation.

     However, none of these reports and studies have tried
to assess the extent of the groundwater contamination problem
in quantitative terms.  In short, a large data base has been
gathered, but no conclusions about the significance of the
problem have been developed.

     This report provides a preliminary assessment of
the extent of the ground-water contamination problem at
the present time.  In doing so, it provides a base from
which further evaluation of the extent of existing
contamination and the magnitude of the potential future
problem can be performed.

     There are two possible approaches which can be used
to estimate the extent of the ground-water contamination
problem.  One approach is to sample and test the ground
water at randomly selected locations and use the results
to generate a national estimate of ground-water con-
tamination.  If a sufficiently large statistical sample
is drawn, this approach can provide a good estimate of
the extent and the nature of the contamination problem.
The limitation of this approach from a strategy stand-
point is that it does not provide much information on
the cause of the contamination and implicitly on what
needs to be done to control it.  Although a complete
survey of ground water would be useful, the time, cost,
and technical demands of this approach preclude its use
at this time.

     An alternative method of assessing the ground-water
contamination problem is to focus on the sources of con-
tamination.  Using estimates of the number of sources of
contamination and the amount of contamination per source
as its basic components, this approach can be used to
develop an order of magnitude estimate of the size of the
ground-water contamination problem.  This second approach
is less precise, but it can make use of the existing
quantitative and qualitative information on ground-water
contamination, and because it begins with an estimate of
the number of sources, it provides a useful starting
point for the development of a ground-water protection

     The remainder of the report presents a preliminary
assessment of the significance of the ground-water
contamination problem using this second approach.  Our
analysis will proceed as follows:

        Identify the sources of contamination.

        Determine which sources are the most
         important from a national perspective.

        Estimate the area of ground water con-
         taminated by the most important sources
         of contamination:

            Estimate the number of contaminating
             sites in each source category;

            Estimate the area contaminated by
             each site;

            Calculate the total area contaminated
             in each source category;

            Aggregate the estimated contamination
             from all source categories.

        Discuss the probable extent of contamination
         from sources that could not be quantitatively

        Compare the area contaminated to the total
         area of usable surface aquifers.

Identification of the Causes of Contamination

     A survey of the many reported incidents of contamination
indicates that there are a wide variety of sources of con-
tamination.  Despite their differences, the sources can be
divided into two subsets:  waste disposal-related sources
and non-disposal sources.  These sources are:
Disposal Sources

Animal Feedlots
Industrial Impoundments
Industrial Landfills
Injection and Disposal Wells
Landspreading of Wastes
Municipal Wastewater Disposal
Petroleum Exploration
Subsurface Disposal Systems
Non-Disposal Sources

Accidental Spills
Buried Storage Tanks
Irrigation Return Flows
Natural Leaching
Salt Water Encroachment
Use of Fertilizer and
Use of Road Deicing
     In recent years attention has centered on the potential
contamination from land disposal of wastes because these
wastes often contain a large amount of toxic materials, are
primarily deposited in specific sites, and can be dealt with
through specific regulatory controls.  These sources of

ground-water contamination should become relatively more
important in the future as air and surface water pollution
controls become more restrictive and waste generation

     Although non-disposal sources are perhaps responsible
for a large portion of the current contamination problem,
their impacts are not easily measured or projected and
they are difficult to control through regulation.  There
appear to be three types of non-disposal contamination
sources:  (1) natural events, which cannot be prevented
but whose effects can sometimes be reduced through proper
management;   (2) accidental events, which can be prevented
by better individual transportation and storage practices;
and (3) unwanted by-products of useful activities which
can only be reduced through alteration of the manner
in which the activities are carried out.  Available
reports and anecdotes indicate that the extent and impacts
of contamination from non-disposal sources are highly area
and incident specific.  Therefore, because no estimates
exist of the current extent of non-disposal contamination
problems and the contamination cannot reasonably be
estimated using simple modeling techniques, our preliminary
analysis will concentrate on disposal-related sources of
Determination of the Importance of the Sources of

     The diverse nature of the activities and contaminants
causing groundwater pollution makes it difficult to rank the
importance of different contamination sources. Among the
factors that could be included in the ranking of sources are
the number of potential outlets for contamination, the type
of contaminants, the toxicity of the waste stream, the size
of the area affected by a typical contamination incident,
and the number of persons affected by a typical contamination

     There are two more simplistic approaches which can be
used to determine which sources may be the most important.
One approach is to examine the volume of wastes deposited
on the land by different sources.  A second approach is to
review past reports of groundwater contamination to see
which sources are mentioned most frequently.  Although
these approaches can only indicate the relative importance
of the problem, they are used here for this preliminary

     Table 1 presents estimates of the amount of waste
deposited on the land through different disposal operations.
The amounts are measured in both tons and gallons, but since
both measures are available for industrial impoundments,
the overall volumes can be compared.  The tonnage figure for
liquid wastes refers to the solid portion of the waste
present.  The volume estimates in the table suggest that
industrial landfills and impoundments are the most important
sources of ground-water contamination.  Municipal landfill
and wastewater sludges are substantial in volume, but
generally much less toxic.  Mining and petroleum exploration
wastes are significant, but often are located in less popu-
lated areas.

     A review of the existing reports on contamination
incidents also provides insights about which sources are
the most important:

        The study "Major Sources of Ground-Water
         Contamination in Connecticut" reported:
         Leachate from 25 out of 185 active landfills
         has degraded ground-water quality and leachate
         migration at the other 160 landfills is
         suspected.  At least 100 of these sites are in
         public water supply watershed areas or are
         located on permeable soil.

        Leachate from 30 of 335 known industrial
         landfills or impoundments has caused documented
         ground-water contamination.  There may be as
         many as 1,000 industrial waste disposal sites
         in the state.  In the 30 reported cases, 53
         private and municipal wells and six local
         ground-water supplies were contaminated.
         Subsurface disposal systems, the use of road
         salts, and accidental leaks and spill have caused
         numerous site-specific ground-water contamination

        A Massachusetts government report on chemical con-
         tamination identified 22 communities affected by
         chemical contamination of their water supplies.
         In 11 of the cases, a total of 15 private wells
         and 16 municipal wells were contaminated.  The
         report also discussed 22 other cases in which
         chemical contamination of ground water is sus*-
         pected but has not yet affected drinking water

                             TABLE 1

                         Industrial/Commercial   Waste Liquids
Type of Waste and Site    (million tons/year)     (billion gallons/year)

Solid Waste                          375
  industrial Landfill       240
  Municipal Landfill        135

Semi-Solid Waste/Sludge               15
  industrial Landt'ili         5
  industrial impoundment      5
  Municipal Landfill          5

Liquid Waste                         110
  industrial impoundment    110                             1,700
  Mining Sites                                                950
  Septic Tanks and Cess-
    pools                                                     800
  Municipal Waste Treatment                                   300
  Petroleum Exploration                                       300
         injection/Disposal Wells                   ^ou

Total                                50°          "'05°
Total Hazardous  (15%)

Source:  EPA  reports and  staff estimates

         supplies.  The majority of the cases involved
         improper or illegal land disposal of industrial
         wastes or accidental leaks and spills.

        In 1979, the Michigan Department of Natural
         Resources undertook an assessment of ground-
         water contamination problems in the state.
         They identified 260 sites where the ground
         water is known to be contaminated and 375 sites
         where the ground water is suspected to be con-
         taminated.  Of the 260 confirmed contamination
         cases, the majority involved accidental leaks
         and spills, 20 percent involved impoundments,
         and 15 percent involved landfills.  In addition,
         Michigan officials estimate that 50,000 other
         sites in the state have the potential to cause
         ground-water contamination.  An examination of the
         781 cases in the Office of Solid Waste files
         revealed that 32 percent of the cases involved
         landfills or dumps, 12 percent involved surface
         surface impoundments, and 18 percent involved
         other disposal incidents.  The remaining cases
         included spills and accidents at storage or manufac-
         turing sites.

        In 1966, the Texas Water Commission began an
         investigation of 23,000 cases of ground and
         surface water contamination caused by petroleum
         exploration.  (1, p. 314)

     These reports indicate that while there are regional
variations in the importance of different contamination
sources, a significant proportion of reported contamination
problems are caused by the disposal of industrial wastes.
These findings are consistent with the conclusions reached
in the 1977 Report to Congress on Waste Disposal Practices
and Their Effects on Ground Water.(1)~~

     The 1977 Report identified the disposal of industrial
wastes at industrial impoundment and solid waste disposal
sites as the most important source of ground-water contam-
ination.  The majority of the current landfill and impoundment
sites are unlined, but the extent of contamination is usually
not recognized because operators do not monitor for ground-
water contamination.  Nevertheless, because these sites are
often located in or near highly populated residential or
industrial areas, ground-water problems have been discovered
in many communities.  In addition, the highly toxic nature
 (1) Referred to as the 1977 Report,


 Of  the  contaminants  further  increases the importance of
 landfills  and  impoundments as  sources of contamination.
 Consequently,  this preliminary assessment of the extent of
 ground-water contamination will  focus on landfills and

     The 1977  Report identified  four other sources as
 having  secondary  importance  nationally.  The concentration
 of  toxic materials and the total volumes of waste materials
 deposited  on the  land are lower  for these sources than for
 industrial waste  disposal operations.  Nevertheless, these
 four sources,  subsurface disposal systems, municipal waste-
 water,  mining  activity, and  petroleum exploration, can have
 significant regional impacts in areas where they are highly
Regional Distribution of Contamination Problems

     Although landfills, impoundments, and the other important
sources of ground-water contamination are found in all areas
of the country, the type and size of the ground-water contam-
ination problem in any region depends on the land use in
that region.  Although the purpose of this analysis is to
estimate the total areal extent of ground-water contamination,
the second phase of any assessment of contamination must
examine how contamination problems are distributed around
the nation.

     Evaluations of the ground-water resource and case
studies of the causes of contamination have been published
for five areas.  The remaining two regional assessments
covering the Midwest and North Central states are not yet
complete.  A summary of the regional rankings of contamination
problems by source is presented in Table 2.  In the Northeast,
Southeast, and Northwest, where there are areas with sub-
stantial manufacturing activity and high population densities,
industrial waste and domestic sewage disposal have the
largest impacts on ground water.  In areas where petroleum
exploration and mining activity are concentrated, those
activities cause the most commonly reported contamination

     Regional differences in contamination problems are in
part determined by regional weather differences.  In very
dry areas of the country, the South Central,  Southwest, and
parts of the Northwest region,  irrigation return and natural


                                                             TABLE 2

South Central
   Industrial impoundments       I
   Land disposal sites           I
   Septic tanks & cesspools      I
   Municipal waste water         II
   Petroleum exploration         II
   Mining                        II
   Other important contami-
     nation sources, including
     non-disposal sources
       Spills; leaks;
       road salt;
       storage tanks.
Spills, leaks;
storage tanks;
 Natural leach-
 ing; irrigation
 return; aban-
 doned wells.
sea water
   NOTE:    Relative importance is based on the typical health hazard of the contaminants, the typical size of the area
            affected, and the distribution of the waste disposal practice across the U.S.  A waste disposal practice may be
            a serious problem in certain areas, but if the number of such areas is relatively small, then the practice
            would not be given a high national rating.  A very widespread practice which does not create serious problems
            even where sources of contamination are concentrated would also be given a low rating with regard to national
            importance.  The ratings in the table are defined as follows:

                                     I - high,
                                    II - moderate,
                                   III - low.
   SOURCES: National significance:
            1977, p. 8.
EPA, Report to Congress on Waste Disposal Activities and Their Effects on Groundwater,
            Regional significance derived from:  Fuhrman, D. and J. Barton Groundwater Pollution in Arizona, California,
            Nevada and Utah, 1971, p. 87; Miller, P., F. De^uca and T. Tesser, Groundwater Contamination in the Northeast
            States, 1974, p. 150; Scalf, M.R., J.W. Keeley and C.J. LaFevers, Groundwater Pollution in the South Central
            States, 1973, p. 78; Vander Leeden, F., L. Cerrillo, and D. Miller, Groundwater Pollution Problems in the
            Northwest United States, 1975, p. 229; Miller, D., P. Hackenberry, and F. DeLuca Groundwater Pollution Problems
            in the Southeastern United States, 1977, p. 143.

 leaching  are  substantial problems and land disposal of
 industrial wastes is not.  In these areas, evaporation
 usually exceeds precipitation.  Although this often prevents
 land disposed materials from achieving field capacity and
 creating  leachate, it causes water drawn and used on the
 surface to have high concentrations of salts and solids.
 Thus, the ground-water problem in these areas is generally
 the increasing concentration of total dissolved solids.  In
 the "wet" eastern regions of the U.S., landfill leaching is an
 important problem; accidents and the buildup of contaminants
 as a byproduct of useful activities create the additional
 significant contamination problems. Contamination problems
 in these  regions are likely to be caused by the dumping of
 wastes and other materials on the land.  The regional reports
 contain many  anecdotal reports of ground-water contamination
 and should be consulted if more specific information on
 regional  contamination problems is desired.

 Evaluation of the Contamination Caused by the Important

     Although the national ranking of the impacts of waste
 disposal practices is a composite measure of contamination
 problems, it provides a workable structure for our estimate
 of the extent of groundwater contamination in the United
 States.   For the two categories rated high in national
 importance, impoundments and landfills, specific estimates
will be made of the areal extent of contamination.  This
 analysis will be followed by an evaluation of the regional
 impacts of three of the sources ranked moderate in importance;
 subsurface disposal systems,  petroleum exploration, and
mining activity.  The extent of the contamination caused by
 leaking sewer lines (municipal wastewater activities)  is not
evaluated due to limited time and information.

     A simple model is used in this analysis.  First,  the
number of sites that potentially could cause contamination
is estimated.  Characteristics that affect the contamination
potential of sites include: permeability of the soil;
existence of a surface aquifer beneath the site;  type,
concentration and amount of waste at the site;  and site
design and operating procedures.   Second, the surface  of the
plume beneath the site is estimated.   These estimates  are
rough and are related to judgments about the behavior  of
contaminants entering the ground water.  Although the  timing
and mechanisms of contamination from landfills and lagoons
are somewhat different,  the analysis assumes the behavior of
leakage  from impoundment sites and leachate from landfill
sites is the same once the contaminated stream enters  the

ground. Finally, the area of contamination per site is
multiplied by the number of contaminating sites to get the
total area of contamination per source.

Extent of Contamination from Industrial  Impoundment

     For the impoundment analysis, only  active impoundments
are considered; it is assumed that on inactive sites the
liquid in the impoundment has drained away or evaporated and
that the site has the contamination potential of an inactive
landfill.  The Surface Impoundment Assessment (SIA), funded
by EPA and conducted by the states, has  identified 25,000
active industrial impoundments at 11,000 locations across
the U.S.  An analysis of the results of  the survey indicates
that about two-thirds of the active impoundments are unlined
and can be considered potential sources  of contamination.
The analysis also indicates that,half of the impoundments
are located over usable aquifers—  and on highly permeable
soil; ground water in these areas is highly susceptible to
contamination.  Using this information,  it is estimated that
approximately 8,400 industrial impoundments may leak into
usable aquifers.-'

     The area of contamination caused by a leaking impound-
ment is determined by the amount and type of waste, the
length of time leakage has taken place,  and the geology and
the hydrology of the area where the impoundment is located.
EPA's analysis indicates that the typical industrial impound-
ment is about 10 acres in size and has operated for about 10
years.  Assuming that the impoundment is located on permeable
soil, the surface area contaminated would total about 60 acres.
Thus, if 8,400 impoundments each produce a contaminated area
of 60 acres and none of the plumes overlap or are intercepted
by surface water, the total area of contamination caused by
industrial impoundments would be 504,000 acres or 790 square
miles.  However, since the survey results indicate that many
sites include several impoundments, the plumes may overlap
and the total surface area contaminated may be lower.
Consequently, for the preliminary assessment a range of 400
to 800 square miles for industrial potential impoundment
contamination will be used.
I/ In this analysis, a usable aquifer is defined as a surfacial
~~  aquifer capable of yielding water containing not more than
   1,000 ppm of dissolved solids.

2/ 25,000 x .67 x .5 = 8,400 impoundment.


Extent of Contamination from Landfills

     An estimate of the contamination from land disposal
sites other than impoundments is more difficult to make than
was the estimate for impoundments.  First, there is no
inventory of active landfills comparable to the SIA. Second,
because landfills maintain the capacity to leach for extended
lengths of time, both active and inactive sites must be
considered.  Third, since landfills generally contain solid
or semi-solid waste, leaching depends on rainfall and may be
intermittent.  Fourth, no ones knows how much waste has been
illegally dumped at unauthorized locations through the years.

     Finally, although only a portion of the waste stream
disposed of on land contains hazardous materials, hazardous
and non-hazardous wastes are not always disposed of separately,
All these factors must be taken into account in the estimate
of the number of contaminating land disposal sites.

     The total number of active landfills has not been
rigorously surveyed; a 1977 Waste Age survey identified
15,000 municipal landfills, and Fred C. Hart Associates has
estimated that there are 75,700 industrial landfills.-'  Fred
C. Hart Associates has also estimated the number of active
and inactive (now closed)  sites which must exist in the
nation to have handled the amount of hazardous industrial
waste which has been generated in the U.S. They estimate
that there must be 19,400 active sites and 31,300 inactive
sites for a total of 50,700 sites.%-' Since there are 10,400
active landfills, this would leave 40,300 active and inactive
landfills.  According to these calculations, the total
number of sites is 2.6 times the number of active sites.
Since the disposal of hazardous waste is not separate from
the disposal of non-hazardous waste, however, the number of
sites where hazardous waste is located is certain to be
I/ Discussion of both estimates can be found in U.S.  EPA,
   Environmental Impact Statement:   Criteria for the
   Classification of Solid Waste Disposal Facilities  and
   Practices, Appendices D and G,December 1979. For
   Derivation of the estimated number of industrial landfills,
   see Fred C. Hart Associates, Analysis of the Technology,
   Prevalence, and Economics of Landfill Disposal of  5011?
   Waste in the United States, February 19, 1979, p.  48.

2/ Fred C.  Hart Associates, Preliminary Assessment of Clean-
   up Costs for National Hazardous  Waste Problems, 1979, p.  22

     An estimate of the total active hazardous and non-
hazardous industrial and municipal waste sites is 101,000
sites.-   An estimate of total active and inactive sites
would be 2.6 times this number, or 263,000 sites, of which
253,000 are landfill sites.   Consequently, the number of
landfill sites-where there is hazardous waste is 40,000-
253,000 sites.-7

     Of these 40,000-253,000 sites, however,  not all will
leach into usable aquifers.   Assuming that industrial
impoundments and landfills accepting industrial (i.e.,
hazardous) waste are generally sited in the same geographic
area, then, like impoundments, about 50 percent of the
landfills are located on permeable soils over usable aquifers.
Unlike surface impoundments, the absence of a lining at
landfills cannot be used alone to predict the probability  of
leakage. Although most landfills are unlined, only about  71
percent are located in areas having sufficient rainfall to
cause leaching.—   This analysis indicates that, at the
present time, 14,000 to 90,000 land disposal sites are
currently contaminating surface aquifers.-'
i'75,700 industrial landfills, 15,000 municipal landfills,
  and 10,400 surface impoundments.

—'The upper end of this range (253,000) may greatly exceed
  the number of sites where hazardous waste has been
  deposited.  The Chemical and Allied Products Industry
  generates about one-fifth of the total industrial
  wastewater and one-fourth of the total industrial solid
  waste produced in the U.S.  The Eckhardt subcommittee
  report on disposal practices by the 53 largest chemical
  company identified 3,363 sites used by the companies since
  1950 to dispose of hazardous and non-hazardous waste;
  sixteen percent of the sites were municipal sites, 31
  percent were company-owned facilities, and a larger
  number appear to be improper disposal sites.

—'EPA, 1977 Report to Congress on Waste Disposal Activities
  and Their Effect on Groundwater, p^152,

-' For simplicity, this analysis will not discuss the implica-
  tions of the seasonal variations in rainfall and leaching.

          40,000 x .5 x .71 = 41,200 landfills
         253,000 x .5 x .71 = 89,815 landfills

      Test  results confirm that a high proportion of land-
 fills do contaminate ground water.  A 1977 study, "The
 Prevalence of  Subsurface Migration of Hazardous Chemical
 Substances of  Selected  Industrial Waste Land Disposal Sites,"
 presented  the  results of ground-water testing at 50 disposal
 sites.  Of the 50 sites, thirtyfour were landfills, eight
 were  surface impoundments, and eight were a combination of
 the two.   Although none of the fifty sites had previously
 reported any contamination problem, organic contaminants
 were  detected  in the ground water at 40 sites and the
 migration  of one or more hazardous substances was confirmed
 at 43  sites.   At 26 sites, hazardous inorganic constituents
 in the ground  water exceeded EPA drinking water standards.

      In the absence of better estimates, we assume in this
 preliminary analysis that a landfill leaching into a surface
 aquifer has a  contaminant plume that is the same size as an
 impoundmentrelated plume (60 acres).  Therefore, the total
 area of contamination produced by 14,000 to 90,000 active
 and inactive landfills would be 1,300 to 8,400 square miles.

      If none of the plumes overlap or intersect surface
 water, the total area of contamination from industrial
 impoundments and landfills would be 1,700 to 9,200 square
 miles.  Since  the total area of United States is 3.5 million
 square miles,  of which 60 percent is underlain with usable
 aquifers, about 0.1-0.4 percent of the country's usable
 (surface) aquifer area is contaminated with toxic materials
 from industrial impoundments and landfill sites.

     Although  the estimated contaminated area may seem
 relatively small in comparison to the total area, two other
 aspects must be considered.   First, the impoundment and
 landfills are  generally located in areas of significant
 domestic and industrial water use.   Therefore, depending on
 the demand for ground water, the area contaminated could be
 a substantial  portion of the area where ground water is
 heavily used.  Moreover, significant withdrawals of ground
water will pull a nearby plume toward the point of withdrawal,
 so that the area whose ground water is no longer usable will
be larger than the plumes themselves.  Second,  landfills and
 impoundments are only two of the many sources of contamination.
A discussion of three other  sources of contamination,  all of
which have the potential to  contaminate large areas, follows
 in the next section.

Evaluation of Secondary Sources of Ground-Water Contamination

     Three activities that can affect large regions are the
use of subsurface disposal systems, petroleum exploration,
and mining.  The ground-water contamination problems associated
with each activity are well-documented; but no quantification
of the extent of contamination caused by these sources is
available. Unfortunately, the simple modeling approach used
to estimate the contamination caused by landfills and impound-
ments cannot be used to estimate the contamination caused by
subsurface disposal systems, petroleum exploration and mining
activities.  Because many of the contaminants involved (e.g.,
salt, nitrates) are a problem only when highly concentrated
in the ground water, the extent of contamination is a function
of the density of the sites rather than just the number of
sites and the leachate from each kind of site.  Petroleum
exploration and mining activity can cause contamination in
several unrelated ways; a variety of types of contamination
sources, ranging from pits and slag piles to general operations
such as drilling or digging, can be found at any one site.
Although a precise quantification of the total contamination
caused by each of these three sources is not attempted here,
a rough estimate of the magnitude of the contamination
caused by these sources is presented.

Contamination from Subsurface Disposal Systems

     Regional ground-water quality problems have been
identified and documented in these communities having high
densities of subsurface disposal systems.  Ground water in
these regions, primarily located in Southern California and
on the East Coast between Boston and Washington, D. C., has
been degraded by high concentrations of nitrates, bacteria,
and other contaminants.  The problem is magnified by the
fact that in many areas, especially rural communities, a
substantial reliance on subsurface disposal systems is
paralleled by a reliance on private wells for drinking water
supplies. EPA's 1977 Report estimates that counties where
there are more than 50,000 subsurface disposal systems are
susceptible to ground-water problems.  Using 1970 statistics,
twenty-seven counties in the U.S., covering about 50,000
square miles (about-]! percent of total U.S. land area), fit
into that category.-'  In addition, numerous other small
communities across the U.S. have high densities of subsurface
disposal systems.  Although only a small fraction of this
area may be affected, it is certain that the use of subsurface
disposal systems by 20 million housing units in the U.S.
does pose a potential threat to regional ground-water quality.
-' 1977 Report to Congress, p. 194; U.S. Department of Commerce,
   Bureau or the Census.County and City Data Book 1977.

Contamination from Petroleum Exploration and Mining

     Several different activities related to petroleum
exploration have caused substantial contamination problems
in states in the south central and southwest United States.
Although no full account of the problem is available,
seventeen states have located and documented ground-water
contamination problems.  In Texas alone, 23,000 cases of
ground and surface water contamination have been reported.
One of the major causes of contamination, the use of brine
pits to dispose of saline by-products of drilling, is now
almost universally banned in producing states.  Nevertheless,
the contamination caused by the use of brine pits for more
than eighty years has limited the use of ground water in
many areas and surface impoundments continue to be used for
temporary storage and other activities.  The Surface Improve-
ment Assessment identified nearly 70,000 active petroleum
production impoundments, more than twice the number of
industrial impoundments.  In addition, abandoned and poorly
maintained producing wells and injection wells are other
potential contamination sources.

     As was the case with petroleum exploration, the mere
presence of mining activity in a region significantly
increases the possibility of ground-water contamination.
There are more than 17,000 active coal, metal, and non-metal
mines in the United States.  Every mine poses a contamination
threat but little research has been done on mine-related
contamination;  in many mining areas,  ground-water contamination
is an accepted fact of life.   Contamination problems are
caused not only by waste disposal sources, such as slurry
lagoons, tailings ponds, and slag piles, but also by activities
such as mine dewatering and failure to undertake land
reclamation.  The SIA identified approximately 25,000 mining
impoundments;  like petroleum impoundments, these can be
expected to add to the total area of estimated ground-water
contamination in the nation.

     Table 3 presents data on the number of active surface
impoundments and surface impoundment sites in the U.S.  The
data indicate that there are three times as many oil, gas,
and mining impoundment sites as there are industrial impound-
ment sites.  If these impoundments contaminate usable
aquifers to the same degree industrial impoundments do, then
about 0.1 percent of nation's usable (surface) aquifers are
contaminated by these sources.

                      TABLE 3


                    Number of Impoundments    Number  of  Sites*

Industrial                    24,483              10,495
Municipal                     32,669              17,233
Agricultural                  18,570              14,147
Mining                        23,976               6,902*
Oil & Gas Brine Pits          66,655              25,120*
Other                          6,645               1,781

                             172,998              75,678

     *SIA estimates for the mining and oil  and gas brine
      pit sites are not necessarily related to actual
      ownership and should not be referred  to as the
      actual number of legal sites.

   SOURCE:  1980 SIA survey
Preliminary Conclusions on the Extent of Ground-Water

     This analysis has developed some preliminary estimates
of the amount of contamination caused by the most important
sources of ground-water contamination.  Industrial impound-
ments and landfills appear to have contaminated 0.1 to 0.4
percent of the Nation's usable (surface) aquifer area.
Subsurface disposal systems appear to have contaminated
significantly less than 1 percent of usable aquifer area,
and oil, gas, and mining impoundments may have contaminated
0.1 percent of the nation's usable aquifer area.  Other
waste disposal activities (e.g.,  injection wells) have also
contributed to aquifer contamination.  Consequently, this
preliminary assessment of ground-water contamination sug-
gests that up to 1 percent of the area of usable surface
aquifers in the United States may be contaminated at the
present time as a result of industrial and other waste
disposal activities.  The area of these
 plumes of contamination will, of course, increase with

     Additional analysis is required to improve this estimate
and to examine the amount of contamination caused by non-
disposal related activities.  Additional analysis is also
required to determine to what degree the areas where ground
water is contaminated overlap the areas where ground water
is currently used or will be needed for water supplies in
the future.


          APPENDIX IV

     Drinking water drawn from the ground has generally
been viewed as a pristine resource, unspoiled by human
activities.  Typically, major treatment is not con-
sidered necessary and treatment is generally not
utilized by the over 100 million people using ground
water as their source of drinking water.  Traditionally,
the focus has been on the contamination of surface
waters by wastewater discharges, industrial discharges,
and diffuse source run-off.  Health regulatory agencies
have been most concerned that treatment systems and
careful monitoring were employed by public water systems
using surface water for protection of human health against
the bacterial contamination and, more recently, organic
chemicals contamination.

     Recent information, however, has shown that many
grour.d waters are also contaminated with organic
chemicals.   The contamination of ground water is now
recognized as a serious problem and a potential health
hazard to millions cf consumers.  Contamination has
been most commonly found in urbanized or industrial
areas and is the result of improper disposal of
hazardous waste, industrial activities and possibly
subsurface disposal system discharges.  Unlike surface
waters, ground waters do not have a natural cleansing
mechanism,  and once contaminated, ground waters will generally
remain contaminated.


     To date a relatively small but rapidly growing
effort has been expended to obtain a clear view of the
level to which synthetic organic chemicals have become
contaminants of potable water drawn from the Nation's
ground waters.  We now know that ground waters can be
contaminated with significant levels of both natural and
synthetic chemicals that are toxic. Toxic chemicals such as
arsenic, barium and radionuclides are often related to the
natural chemicals in the soil, whereas contamination with
synthetic organic chemicals is generally associated with
places where those chemicals are made, spilled, used or
disposed.  Pesticides such as DBCP, Aldicarb and Carbonfuran
have been found in farm veils.  Trichloroethane, trichloro-
ethylene, freon, acetane, xylene, dimethyl sulfoxide,
trimethyl silanol, chomium, arsenic, lead, zinc, chloroform,

methylene chloride, benzene, toluene, ethyl benzene, fuel
oil, vinyl chloride, 1,2-dichloroethane, tetrachloroethylene
and many other organic compounds have been found in
highly contaminated wells.   (Table 1)

     To date 44 communities  in Massachusetts have had
their public water supply severely contaminated with one
or more synthetic organic compounds:  16 incidents have
occurred in Connecticut, 25  in Pennsylvania, 12 in
New York, and 1 or more in each of 20 other states.

     For example:

Wells Closed as a Result of Chemical
  Contamination in Gray, Maine

     In September of 1977, the McKin Company was ordered
to close by town officials of Gray, Maine, due to
drinking water well contamination associated with the
site.  The facility was built in 1972 to handle waste
oil from the "Tamano" oil spill in Casco Bay.  From
1972 until 1977, its primary operation was as a transfer
station for fuel still bottoms.  Materials stored in
existing tanks were mixed together for final shipment
to refiners.  Approximately 100,000 to 200,000 gallons
were annually processed by McKin at the Gray site.

     There was evidence that wastes were spilled at the
processing facility and leached into the aquifer.  An
unpleasant taste and offensive odors in the drinking water
were reported in 1974. Samples of drinking water were
submitted to the state laboratory for testing, but the
contaminants were not identified.  When the well water
discolored laundry, residents started turning to alternate
sources for their water supply.

     In 1977, trichloroethane, trichloroethylene, freon,
acetone, xylene, dimethyl sulfide, trimethylsilanol, and
alcohols were identified.  Toxic organics were detected
in eight domestic wells within 2,000 feet of the McKin
Company.  As a result, the town health officer ordered
sixteen contaminated wells in the area capped.  Traces
of these same chemicals were also discovered in the town's
public water supply where contaminants are thought to have
leached into the water table from the town dump where
the company disposed of its  chemical wastes.

                                       TABLE  1


methyl Phthalate
Dibutyl Phthalate
Phthalic Acid
Carbon Tetrachloride
Trichloroe thylene
Di chloromethane
Phenyl Acetic Acid
Frequency %

Phthalic Acid
Tri chloroethylene
bis (2-Chloroethyl)Ether
Ethyl Chloride
Methyl Parathion
Carbon Tetrachloride
Frequency %


Jackson Township, New Jersey

     The municipal landfill was licensed by NJDEP in
1972 to accept sewage sludge and septic tank wastes.
However, chemical dumping allegations have been confirmed
by chemical analysis of underlying ground water.  The
landfill was recently closed to all wastes.

     The landfill abuts the Ridgeway Branch of Toms
River, and overlies the Cohansey Aquifer, the sole source
of drinking water for the surrounding residential com-
munity.  The soil is composed of porous sands and no
natural or manmade liners exist.  Over 100 residences
used private water wells within 1.5 'miles of the site.
Water is now trucked to the community.

     Approximately 100 drinking water wells surrounding
the landfill have been closed because of organic
chemical contamination.  Analysis of water samples has
shown the presence of chloroform (33 ug/1) methylene
chloride (3,000 ug/1), benzene (330 ug/1), toluene
(6,400 ug/1), trichloroethylene (1,000 ug/l)» ethyl-
benzene (2,000 ug/1) and acetone (3,000 ug/1).  Residents
claim that premature deaths, kidney malfunctions, kidney
removals,  recurrent rashes,  infections and other health-
related problems are due to the contamination of their
water supplies by the landfill.  Although use of the water
wells has been banned, residents are still using well
water because no other dependable source of water

Ground-Water Contamination Beneath
  the Rocky Mountain Arsenal

     Rocky Mountain Arsenal, jointly operated by the
U.S. Army Chemical Corps and Shell Chemical Company, is
located between Denver and Brighton, Colorado.  Over
the years the facility has disposed of a complex mixture
of chemical by-products from the manufacture of pesticides
and herbicides, along with other wastes during the
years 1943-1957.  Originally, wastes were disposed of in
unlined holding ponds, a practice which led to infiltration
into the shallow water table aquifer and the consequent
migration of contaminants through the ground water.
Although this practice was discontinued in 1957, extensive
ground-water contamination is still very much in evidence.

     To date, thirty square miles of the shallow water
table aquifer are contaminated, resulting in the
temporary abandonment of a number of domestic, stock, and
irrigation wells, and final abandonment of two wells.


Soil in the vicinity of one pond is contaminated by the
pesticides aldrin and dieldrin. Classified as cyclodienes,
these compounds are derivatives of fcexachlorocyclopentadiene,
They bioaccumulate in the fatty tissues of terrestrial and
aquatic organisms and tend to persist in the environment
over long periods. These pesticides are quite toxic.

Long-Term Pollution Problems Associated with Creosote:
  Production in St. Louis Park, Minnesota

     For 50 years, Reilly Tar and Chemical Company and
Republic Creosoting Company operated on an 80-acre site
in St. Louis Park, a western suburb cf Minneapolis.
Reilly Tar and Chemical refined coal tars to produce
creosote, and Republic Creosoting then used the material
to treat wood products.  While the operation supposedly
included discharge of waste products into a ponding
area on the property, there were apparently numerous
cases of spills, leaks, pipeline breaks, and burial of
wastes over the; years.

     The site has a long history cf pollution problems.
As early as the 1930s, some drinking water wells in the
area were closed due to a tarlike taste.  In 1969,
low levels of possible carcinogens were found in a ground
water investigation for the city.  The Minnesota Pollution
Control Agency ultimately brought suit against  the
generators in 1970, and in 1971 the operations  were
clo sed.

     Several years of study have revealed the extensive
contamination that the St. Louis Park plant has caused.
Analyses have documented the presence of phenols and
three polynuclear organics—phenanthrene, chrysene,
and pyrene.  Low phenol concentrations have also been
found in wells further than one mile off the site.
Certain drinking water supplies have already been closed.
This incident illustrates the capability of pollutants
to migrate with the ground-water flow.

     Thirty-nine cities using ground water  have  been
tested in Federal surveys to determine  how  frequently
volatile chlorinated solvents contaminate finished
drinking water.  As of March 1980,  over  8000  chemical
determinations for volatile organics had been performed
on well water by some State Agencies.   Most of the  state
data focuses on "hot spots" of pollution and  provides  a
"worst case" of ground-water contamination  nationwide.


Systematic data based on representative samples is
not available.  The findings of both State and Federal
monitoring efforts are summarized below.


     Trichloroethylene (TCE) is a high volume industrial
chemical which is used extensively as a solvent for
degreasing metal.  In 1973 over 451 million pounds of this
chemical were produced in the United States.  Based on
high dose animal studies performed by the National Cancer
Institute, TCE was found to be carcinogenic in mice.

     Trichloroethylene has been detected in ground water
from 16 states across the United States.  Data obtained
from Federal monitoring programs indicate that over 30
percent of the 25 public drinking water supplies sampled
contained levels of this contaminant.  These data show
that contaminated supplies contained from 0.11 to 53 ug cf
trichloroethylene per liter of finished water.  The rate
of discovering contamination in wells varies from state to
state.  Seventy-nine percent of the wells (19) tested in
Delaware have been found to be contaminated whereas only 2
percent of the 1200 wells tested in Connecticut contained
traces of the chemical.   A national summary of 2,984
samples of well water from 8 states reveals that nearly 1
out of every 3 drinking water supplies contain measurable
amounts of trichloroethylene.  The highest level of trichloro-
ethylene reported in well water was 35,000 ug/1.
Carbon Tetrachloride

     Carbon tetrachloride is one of the volatile organic
compounds that has been fcund more frequently In finished
water than in raw, untreated water.  Over 1 billion
pounds of this compound were produced in the United
States in 1973.  It is used as a cleaning solvent, pesticide
and intermediate in the production of chlorofluoro-

     Carbon tetrachloride is rapidly absorbed through
the: gastrointestinal tract and the lungs.  Exposure to
high levels of this chemical can cause damage to the
kidneys and liver.  In an NCI test, mice exposed to
high levels cf carbon tetrachloride for their lifetime
developed an increased incidence cf liver cancer.


     Twenty-eight percent of the 39 finished ground
waters tested in Federal surveys were found to be
contaminated with carbon tetrachloride.   The levels
of contamination ranged from 0.2 to 13.0 ug/1 with a
national average of 3.8 ug/1.  This chemical has been
found in chlorinated ground waters serving as public
drinking water in many states.  It is believed that
the presence of carbon tetrachloride in finished water
is largely due to impurities in the chlorine used as a
disinfectant.  This theory is substantiated by the knowledge
that only 7 percent of the raw water drawn from underground
sources has shown the presence of carbon tetrachloride.


     Tetrachloroethylene is a solvent that is widely
used in dry cleaning and degreasing operations.  In 1973
over 700 million pounds of this industrial chemical were
produced in the United States.  Animal tests show that
mice exposed to this compound for a lifetime have an
increased incidence of liver cancer.

     Data from Federal studies indicate that 18 percent
of raw water being used by the 27 community systems tested
in the United States contained tetrachloroethylene.  While
the treatment processes used by most contaminated public
systems do reduce the level of contamination slightly,
most of this chemical does reach the consumer.   The  level of
contamination found in finished drinking water ranged  from
0.2 to 3.1 ug/1 in that survey.

     Tetrachloroethylene has been  shown to be  an accidental
additive to  drinking water coming  in contact with resin-
lined asbestos cement pipe.   Concentrations  as high  as
3,500 ug/1 have been reported  in drinking  water supplies
using this type of pipe in their distribution  system.
Twelve states have reported  efforts  to  determine if  tetra-
chloroethylene contamination has occurred  in their aquifers.
Positive samples were taken  from over 60%  of the wells.
 1,1,1  Trichloroethane

      1,1,1 Trichloroethane is also known as methyl
 chloroform.  It is widely used as an industrial cleaner
 and degreaser of metals,  resin adhesive, and vapor


pressure depressant.  In 1978 over 600 million pounds of
methyl chloroform were produced in the United States.
Methyl chloroform is not considered to be a carcinogen.

     State authorities in New York, New Jersey, Alabama,
Florida, Idaho, Maine, Massachusetts, North Carolina,
Tennessee and Washington have reported finding from
1 percent to 69 percent of their wells positive.  Con-
centrations as high as 2,250 ug/1 have been detected in
highly contaminated wells.  Federal surveys indicate
that 21 percent of the 23 public water supplies tested
using ground water are contaminated with 1,1,1-trichloro-
ethane.  Consumers of this water would, on the average,
be ingesting 2 ug of 1,1,1-trichloroethane per liter of

1,2 Dichloroethane

     In 1977 over 4 million metric tons of 1,2-dichloroethane
were produced in the United States.  The major use of 1,2-
dichloroethane (EDC) is as a raw material for the pro-
duction of vinyl chloride.  However, every gallon of leaded
gasoline produced in the United States contains EDC as a
lead scavenger.  This chemical is also used as a solvent
for paints, cleaning solvent and grain fumigant.  NCI
reports continuous exposure to high levels of EDC causes
cancer in animals.

     EDC has been reported as a contaminant in well water
analyzed from eight states.  The preponderance of these
positive samples was collected from states along the
eastern seaboard of the United States.  The analysis of
1,200 water samples by State agencies has shown this chemical
to be a contaminant of finished drinking water in 7 percent
of the sample.  A maximum concentration of 400 ug/1 has been
recorded.  Data from Federal surveys show that 4 percent
of the 25 ground-water supplies sampled contained this
pollutant.   The average concentration in contaminated
wells is approximately 0.2 ug/1.


     1,1-Dichloroethane is not reported to be produced
commercially in the United States but is imported for
use as a solvent and cleaning agent in specialized
processes.   Very little information is available on
the toxicity of 1,1-dichlorethane.

     1,1-dichloroethane has been detected in 23 percent
of the samples of the 13 ground waters examined during
Federal monitoring programs.   The contaminant has been


reported to be present in well water from Alabama,
Colorado, Florida, Massachusetts,  North Carolina,
Pennsylvania and Tennessee.  The highest level of  1,1-
dichloroethane reported to be in drinking water was
11,330 ug/1.  An average concentration of 0.3 ug/1
1,1-dichloroethane has been computed for contaminated


     Dlchloroethylenes are a group of 3 isomers.  Cis
1,2-dichloroethylene and Trans 1,2-dichloroethylenes
have rot had wide industrial usage; 1,1-dichloroethylene
has found a place in the market.  In 1976 it was
estimated that 120,000 metric tons of 1,1-DCE were
produced in the United States.  1,1-dichloroethylene is
used as a chemical intermediate for the production of
methyl chloroform.

     Very little information is available on the
toxicity of Cis and Trans 1,2-dichloroethylene.  1,1-
dichloroethylene has been more widely studied.  Exposure
to high levels of the 1,1 isomer can have adverse
effects on the kidney and liver.  Although tests on the
carcinogenicity cf this compound are not yet complete,
preliminary data from Maltoni indicates that test
animals are experiencing an increased incidence of
kidney and mammary cancer.

     Cis 1,2-dichloroethylene has been detected In 30
percent of the 39 finished ground waters sampled in
Federal surveys.  The trans and 1,1 isomers have been
detected in 15 percent and 7 percent of the wells tested.
State Agencies report that as much as 860 ug/1 of
"dichloroethylenes" have teen found in highly contaminated
water supplies.

Methylene Chloride

     Methylene chloride is used in the manufacture of
paint and varnish removers, insecticides, solvents,
pressurized spray products and Christmas tree bubble
lights.  In 1973 over 1/2 billion pounds of methylene
chloride were produced in the United States.  Exposure
to methylene chloride produces an elevation of the blood
carboxyhemoglobin in humans.  Exposure to high levels
results in the formation of large amounts of carbon
monoxide in the body and central nervous systen impairment


     Two percent of the 1,180 wells examined by State
agencies have revealed the presence of methylene
chloride.  Concentrations as high as 3,600 ug/1 have
been recorded.  Federal studies indicate that, on
the average, consumers of water from contaminated wells
would be exposed to a concentration of 7 ug/1 of water

Vinyl Chloride

     Vinyl chloride has been used for over 40 years in
producing polyvinyl chloride, which is the most widely
used material for the production of plastics.  In 1975
nearly 5 billion pounds of vinyl chloride were produced
in the United States.  Continuous exposure to vinyl
chloride has been shown to produce cancer in humans.  Vinyl
chloride has been detected in nearly 16 percent of the
13 raw waters tested in Federal surveys.  However, it
appears that because of its volatility much of this
contamination never reaches the consumer.  Seven
percent of the 1,033 wells tested by State agencies have
been positive for vinyl chloride.  Concentrations as
high as 380 ug/1 have been reported.

     The ability to look for a specific pollutant or
classes of pollutants is excellent, but it is impossible
to detect the presence of all contaminants in a water
sample.  The specific list of compounds that are
detectable in drinking water is severely limited by the
methods of isolation and detection that are available. Many
compounds have been detected in finished well water. The
list presented in Table 1 is a partial representation of the
chemicals found thus far.  Intensive surveys conducted by
State agencies have added to our perception of the magnitude
of the ground-water contamination problem.  Phthalates,
toluene, ethylbenzene, benzene, and other compounds have
frequently been found in well water from New York (Table 2).
Dichlorobenzene, trichlorobenzene and iodomethane have been
reported from New Jersey (Table 3).  The national scope of
contamination by these chemicals is unknown.  However,
polluting ground water with a single pure chemical is
unlikely.  It is far more probable that contaminated
wells will be affected by multiple pollutants simultaneously,
Information on the volatile organic compounds substantiates
this hypothesis.  Sixty percent of the 39 ground-water


supplies tested in Federal monitoring programs contained
either trichloroethylene, tetrachloroethylene, 1,1,1-
trichloroethane, 1,1-dichloroethylene, 1,2-dichloroethylene,
carbon tetrachloride, 1,2-dichloroethane, 1,1-dichloroethane,
methylene chloride or vinyl chloride.  Slightly over one
half of contaminated water supplies contained one of these
industrial solvents.  Ten percent of the potable waters
tested contained two of these compounds.  Another ten
percent contained three of these chemicals and twenty-
three percent were found to contain four of these
toxicants simultaneously.

     The toxicity associated with simultaneous exposure
to more than one of these compounds is unknown.

                       TABLE 2



Bis (2-Ethylhexyl) Phtha.late
Di-N-Butyl Phthalate
Diethyl Phthalate
Butyl Benzyl Phthalate
Maximum Level
Detected (ug/L)

                                        TABLE 3

                                 WATER SURVEY—PARTIAL
# of
Trihalome thanes
% Positive
Frequency Distribution (ug/L)
<1.0 1-10 10-100 >100
5 3
1 0

Carbon Tetrachloride
3.,),, 3,-Trich loroethane
1,1,2,2-Tetra.Qhloroethy lene


The following  chemicals were  not found:   Me thy 3, Chloride, WethyJ, Bromide, vinyl Chloride,
Methoxychlor,  Methylene Chloride,, Toxaphene,

          APPENDIX V



     This paper discusses the major sources of pollution
to ground water, describes the current Federal and State
programs for controlling these pollutants and the related
institutional relationships, and poses key policy questions
for consideration.


     Over 16,000 landfills in the United States receive
approximately 230 million tons of wastes per year.
Leakage of contaminants to ground water is estimated at
90 billion gallons per year.  Toxicity of wastes stored
varies widely.  It is estimated that 638 landfill/dumps
may contribute substantial quantities of hazardous wastes
which could cause significant, imminent hazard to public
health and the environment.

     The States have initiated the open dump inventory
required under RCRA which is projected to be completed in
five years.  More recently, EPA has initiated the hazardous
uncontrolled and abandoned waste site program.  EPA will
rank uncontrolled waste sites, investigate sites which
pose the greatest threat and initiate emergency assistance
and containment actions at most critical sites.

     Under the Surface Impoundment Assessment (SIA) under
SDWA, the EPA gave grants to States to locate all surface
impoundments and assess at least a random sample of
impoundments, using a standardized system to determine
their potential for causing ground-water pollution.  Over
180,000 impoundments have been located and in excess of
30,000 impoundment sites have been assessed as of April,
1980.  it was observed that 97 percent of the respondants
did not know if there were significant changes in ground
water.  For the 25,000 industrial impoundments, 94 percent
have no monitoring wells, 66 percent have no liner, 58
percent are sited over sand/gravel or fractured rock
aquifers and 52 percent have a relatively high waste hazard

     This inventory will serve as a first round approxima-
tion to help the RCRA inventory of open dumps and the
hazardous and abandoned site program set priorities and to
provide a basis for the States to develop regulatory programs
under RCRA, and for EPA to implement the Superfund


     Currently RCRA regulations are being completed.  The
 regulations will establish standards for the listing of
 hazardous wastes, and standards for generators, transporters
 and for operators of treatment and disposal facilities.
 The program requires monitoring, a manifest system and a
 facility permit system.

     EPA may delegate the administration/enforcement of
 the hazardous waste programs to the States.  A State may
 seek interim authorization of up to two years if the
 State has a hazardous waste program in effect with sufficient
 legislative authority, regulations in effect and adequate
 resources to administer and enforce the program which are
 substantially equivalent to the Federal program.

     Guidelines for solid waste management plans under
 RCRA have been published addressing the implementation of
 the management of solid waste (non-hazardous) through
 resource recovery or environmentally sound disposal,
 including the closing and/or upgrading of open dumps.

     At this time, the Superfund legislation is proposed in
 Congress which will address releases to the environment of
 oil and hazardous substances, and hazardous wastes from
 spills and from inactive and abandoned disposal sites.  It
 establishes a comprehensive and uniform system of notifica-
 tion, emergency government response, enforcement, liability
 and compensation.  The proposed legislation establishes a
 fund to assure monies to carry out the authorities.  The
 fund would be raised from Federal appropriations and an
 industry-based fee.   The fund would raise approximately 1.3
 billion dollars over a four year period.  The proposal would
 authorize EPA to make grants to States, or enter into contracts
 or cooperative agreements to respond to spills.

     In many States, there has been a lack of clear and
 specific authority to regulate on-site industrial disposal
 sites.   Several States also have difficulty in enforcement
 because of local government jurisdiction.  The Superfund
 legislation should assist in resolving these issues by
 clarifying the responsibility for waste handling and dis-
posal.   Superfund will also provide a source of funding
 to contain major ground-water contamination problems.

          How will proposed policies on delegation and
          interim authorization for State's management of
          the hazardous waste program affect timing and
          resource requirements?  What are options if
          several States refuse or fail to participate in
          the program?

          What should be the Federal role in disposing of
          wastes if adequate sites cannot be found or are
          not politically acceptable?  What should be
          EPA's policy on closing dumps or lagoons, require-
          ments for new sites prior to closing facilities
          and upgrading bad dumps.

          What is our ability to rehabilitate or control
          hazardous waste sites?  Impact on criteria for
          allocation of Superfund monies?

     Over one-fourth of the United States households use on-
lot disposal systems which discharge over a trillion gallons
of wastes per year to the subsurface.  There are many exist-
ing and potential problems with malfunctions of these systems,
which has resulted in the belief that on-lot systems are
inadequate treatment facilities.  On-lot systems can be
effective treatment systems if properly designed, constructed,
operated and maintained, and if drainage fields are located
in appropriate soils.

     Density of on-lot systems, especially those in the
urban fringe areas, can also affect ground-water quality.
Pew State or local regulatory programs include density
controls for protection of ground water.

     New York, Connecticut and Pennsylvania have attributed
chlorinated hydrocarbon ground-water contamination to the
use of solvents to clean plumbing and septic tanks.
These degreasing products and drain-opening products are
potentially a large non-industrial source of contaminating
solvents.  In most occurrences of chlorinated solvent
contamination, industrial activities have been implicated
as a source of the chemicals.  The full extent of the
role of consumer products and other chemicals disposed of
or used in septic tanks has not yet been fully determined.

     Control of on-lot  systems is usually contained in
 some basic  authority of a State agency.  Local or county
 governments administer  the program under State regulations
 and supervision.  Regulations generally control the
 siting, design and  construction of the systems but do not
 specifically require maintenance.  Many communities also
 lack proper control of  septage disposal.  In addition,
 regulations are not directed to the control of industrial
 wastes disposal or density controls to protect ground

     The Clean Water Act of 1977 established funding
 eligibility for the construction, rehabilitation and/or
 upgrading of on-lot wastewater disposal systems for
 individual  homes and small businesses as a part of the
 Construction Grants program.  This change to the law
 resulted from the realization of the high cost of construc-
 tion of conventional wastewater collection and treatment
 works in low-population density areas.  The CWA regulations
 require detailed economic and environmental studies as
 part of the justification for funding of any construction

     The 208 grant program has provided funding for
 evaluation  and revision of on-lot system regulations, for
 establishing agreements between jurisdictions on administra-
 tion of on-lot regulations and disposal of septage wastes,
 as well as  site-specific impact assessments and control
 options of  on-lot systems, and determining financing
 alternatives for replacing malfunctioning systems.
 Several ongoing projects are evaluating alternatives for
 controlling densities (i.e., Spokane-Rathdrum Prairie
Aquifer in  Washington and Idaho,  designated as a sole
 sources aquifer,  is utilizing 208 funds to examine densities
of on-lot systems).

     EPA has developed  technical evaluations of controls
and currently is evaluating management alternatives.  EPA
has held a  number of technical seminars to provide assistance
and currently is preparing an on-lot strategy dealing
with issues such as 201/208 funding criteria, technical
assistance  and research needs.
          What should EPA's role be in requiring minimum
          on-lot disposal design or performance standards?
          Should EPA/States restrict the use of septic
          tank degreasers?


          What methods can State and local governments use
          to provide adequate levels of manpower to administer
          existing programs?  What are options for Federal
          incentives?  Should EPA require minimal level of
          on-lot disposal State management?  Should SMSA's
          manage on-lot systems as well as operations of
          POTW through user charge system?

          Should policy directives through 201 program and
          user charge system requirements be used to
          minimize use of on-lot systems in urban fringe

          What are the options for developing density
          limitations and design critera?

     Spills and leaks from pipelines and underground
storage tanks are frequent sources of ground-water contamina-
tion; leaks, however, are exceedingly difficult to detect
and locate.

     Storage tanks and transmission lines which store and
transmit hazardous materials will be under the control of
RCRA.  This control, however, will be limited because
most materials involved are not classified as hazardous
by RCRA, e.g., petroleum.  For pipelines constructed with
201 grant dollars, there are existing standards for
location, design and construction as well as inflow and
infiltration analyses requirements.

     Several States have assessed problems and operational
programs dealing with storage tanks, e.g.. New York is
developing a program that will require periodic inspection
including pressure testing and careful monitoring of
fluid levels.  While some jurisdictions have standards
for storage tank construction, many do not have inspection
programs for existing facilities and may have access
problems for inspections.
          What options exist for Federal and State programs
          to control problems resulting from underground
          storage tanks and pipelines?


     The National Oil and Hazardous Substances Pollution
Contingency Plan provides for Federal interagency response/
including EPA and other Federal agencies.  Spill response
in inland waterways is provided by EPA Regional Offices.
The U.S. Coast Guard is responsible for spills into
coastal waters.

     The Chemical Transportation Emergency Center
(CHEMTREC) provides twenty-four hour advice on chemicals
involved in spills.  The National Agricultural Chemical
Association provides personnel, equipment and expertise
for cleanup of Class B poison pesticides.

     RCRA and Superfund will provide authorities and
funding to deal with hazardous waste spills.  States will
be required to develop adequate legislation and management
capability prior to program delegation.
          How can procedures and techniques for controlling
          spills be applied to ground water?

          What should be the Federal role, if States
          refuse or fail to develop adequate spill response

     The Nuclear Regulatory Commission (NRC) has the
responsibility for control of radioactive pollutants from
milling facilities and from disposal practices.  Mills
processing radioactive materials produce highly acidic
liquid slurries which are contaminated with chemical and
radioactive pollutants, e.g., ammonia, nitrates, heavy
metals, uranium.  Mills generally have large tailing
piles containing these wastes, but often do not have
adequate monitoring programs.

     The Uranium Mill Tailings Radiation Control Act of
1978 establishes authorities for control of milling
operations.  NRC has established a regulatory program
which requires licenses for new mills and the relicensing
of existing mills.  Standards and BMPs (e.g., lined
ponds, dewatering tailings to minimize seepage/runoff)
are established by EPA.


     NRG can delegate the regulatory program to States if
they demonstrate a. satisfactory health and safety program
consistent with the NRC regulations and EPA standards.
Currently, Colorado and New Mexico operate this program;
Wyoming does not.

     NRC requires an EIS on any new or revised license
applications and will provide technical assistance in the
preparation of the EIS.  EPA prepares EIS's for the
mills. The EIS's must address specific BMPs and the
impact on ground water.  NRC is currently producing a
draft generic EIS on uranium milling.  EPA gathers data
on uranium milling and establishes standards.

     In cooperation with the States, DOE will provide 90%
funding for cleanup of inactive milling sites.  Standards
for this cleanup were promulgated April 22, 1980 by EPA
(45 FR 27370).

     High level radioactive wastes are not disposed of
but are being stored in containment vessels by DOE.
Approximately 75 million gallons of high-level nuclear
wastes are in temporary storage.  EPA is developing
standards for disposal of these wastes; NRC will license
disposal by DOE.

     NRC has no authority over mining.  However, problems
result from the discharge of mine water and from the
leachate created from tailings.  Metal mines other than
uranium are also causing problems.  Little is known about
the radiation problems occurring from titanium and zirconium
mines.  There is also radiation associated with copper
ores and beryllium ores which recover uranium.

     EPA/State has in some instances issued NPDES permits
for mine discharge (e.g., New Mexico).  The Mine Safety
and Health Administration has authority to control mining
hazards and to regulate wastes/products during the ^transport
to the mill, but currently not much is being done regarding
the impacts of mine wastes or the impacts of mining
operations on ground water.

     Mining wastes are being addressed by the continuing
208 program (see section on mining wastes).' Generally,
there are limited operational control programs over the

     An additional source of radioactive waste materials
results from the mining and milling of radioactive phosphate
ores.  Fertilizer plants produce uranium wastes from
phosphate host rocks.  NRC only regulates these facilities
if they are producing uranium commercially or if uranium
is a fairly high percentage of material.
          Do EPA standards and EIS procedures sufficiently
          address ground-water impacts?  How should other
          ores that are causing radioactive problems,
          e.g., titanium, be dealt with?

     Agricultural runoff is a problem in 68 percent of
all hydrologic basins in the United States.  Ground-water
pollution resulting from agricultural activities is less
documented.  However, agriculture has a special dependency
on ground water.  Almost all of the Nation's rur-al house-
holds are supplied by wells, and most of these are single-
family wells subject to few, if any, water quality safeguards.

     Agricultural practices responsible for contamination
of ground water are:  irrigation return flow; application
of chemical fertilizers or animal wastes; changes in
vegetation; and use of pesticides.  In the West especially,
irrigated agriculture is both a victim and a cause of
saline pollution; crop yields are reduced on one-quarter
of the irrigated land in that region.  The process of
irrigation, which concentrates salts by evapotrans-
piration and adds others by leaching from soils, can
introduce chloride and other substances into a ground-
water reservoir.  Increased salinity in irrigation water
may also decrease crop production by affecting crops
sensitive to salinity and by changing the productive
characteristics of soils.

     Ground-water pollution by pesticides has not been
detected as frequently as surface water pollution because
of the transit time through the soil.  The problem is
more prevalent in areas of high water tables, in fracture
zones, or in immediate vicinity of wells.  The increase
of concentration of contaminants in ground water from use
of fertilizers is a more frequent problem.

     EPA regulates pesticides under the Federal Insecticide,
Fungicide and Rodenticide Act (FIFRA).   EPA's registration
and labeling programs are preventive in nature.  The cert-
ification of pesticide applicators and  the pesticide use
enforcement program are generally delegated to the States
or the state department of agriculture.

     High nitrate content is reported in ground water in
many agricultural areas.  As an example, Nebraska is
examining ways to control the increasing nitrate levels
in its ground water resulting from agricultural activities.
BMPs include optimizing fertilizer application, timing
nitrogen application, using crop rotation, using animal
wastes for fertilizer, and plowing-under green legume

     The generation and disposal of large quantities of
animal waste at locations of feeding operations can pose
ground-water problems if improperly contained.  There are
several potential contaminants in manure, but nitrate is
the one most frequently encountered in ground water.
Pathogens from the animal wastes can also contaminate
ground water.

     Concentrated animal feeding operations are regulated
under the CWA and can be required to have a NPDES permit.
Additional regulations are imposed by some States.  Typically
they are based on ratio of animals to land area.  Larger
installations generally have treatment facilities or
lagoons, and in recent years there has been a  trend to
increase the use of manure as fertilizer.
     EPA has developed an agriculture nonpoint source
strategy to focus the 208 efforts toward solving the most
significant problems in areas where water quality is
affected most adversely.  While implementation programs
move ahead, EPA/States will undertake a limited, but
comprehensive evaluation of the impacts of agricultural
pollutants on water quality and the effectiveness of
BMPs.  The focus of the agriculture strategy is the
ranking of critical areas based on surface water quality.

     An important part of the strategy is an analysis of
policy issues dealing, with the Federal role in long-term
agricultural pollution control.  Issues include the
comparative effectiveness of regulatory versus non-regulatory
NFS control programs for agriculture, use of CWA Section
313 to accelerate implementation on public lands, additional
incentive programs to promote BMP implementation and
Federal policies which impact agriculture land use  detrimental
to water quality, e.g., farming marginal lands.


          What  should be  the Federal and State role in
          ensuring that BMPs will be implemented?  Should
          some  form of a  regulatory program be used if
          non-regulatory  programs are  ineffective?

          What  are the alternatives and incentives for
          increasing use  of manures and sludges in lieu of
          use of chemicals for  fertilizers?

     Salt water intrusion into fresh water aquifers has
become a major problem.  The saline water may come from
the sea or from inland saline aquifers.  Overdraft of a
fresh water aquifer can cause reversal or reduction of the
density gradient which keeps the saline water in place.
Salt water can then move into the remaining fresh water

     Contamination of wells with sea water is a major
problem in the Gulf Coast area, California and New England.
California has established programs to reverse the movement
of saline water through the use of barriers created by
injection of non-saline water.  Two communities, Ventura
and Monterey are currently evaluating measures for control-
ling ground-water withdrawal to prevent additional salt
water intrusion.

     More than two-thirds of the United States is underlain
by water containing more than 1,000 mg/1 of dissolved
solids and many inland fresh water aquifers are hydraulic-
ally connected with saline ground water.  In most cases,
the heavier,  mineralized water underlies the fresh water.
Where wells are too deep or where excessive pumping
modifies the hydraulic gradient,  saline water may be
drawn into zones formerly containing fresh water.

     Examples of saline intrusion in inland States include
various locations in New Mexico and the Red River Valley
of North Dakota, where vertical intrusion of deeper
saline waters into the producing aquifer occurs as a
result of heavy pumping.  Similar problems exist in
northwest Minnesota,  various locations in Michigan, and
the Mount Vernon-West Franklin area of Indiana.


          What should be the Federal and State/local roles
          in developing data and management programs for
          salt water intrusion?

     Petroleum exploration and development have caused
ground-water contamination.  There are several potential
sources of contamination — accidental spills, release of
drilling fluids, corrosion inhibitors or gas and oil
through well casings by poor well construction, and disposal
of fluids brought to the surface in connection with oil
and gas production.  A major threat to ground-water quality
is the disposal of brine.

     In the past, brine was discharged to streams or
unlined evaporation pits.  There have been a large number
of instances of ground-water contamination from these
pits.  It is impossible to estimate the total volume of
brine discharged to these pits, particularly since many
have been abandoned over the past decade.

     Today, brine is disposed of by underground injection
or by discharge into lined lagoons.  Underground injection
through new wells will be controlled by the UIC program.
There are proposed EPA regulations which address BPT
requirements for the "Oil and Gas extraction point source
category."  Protection of the ground water is not addressed
directly as the regulations control oil and grease discharges,

     RCRA contains the authority to regulate and prevent
ground-water contamination from lagoons containing hazardous
materials.  Proposed Superfund legislation would provide
authority for government response and enforcement on
abandoned disposal sites.

     Most of the 30 oil-producing States have adequate
regulations, particularly with respect to casing require-
ments for well construction.  Most regulatory agencies
require steel casings grouted to the surface.  An unregu-
lated situation exists with improperly plugged exploration

     The problem of limited enforcement generally results
from the limited funding and manpower availability to the
regulatory agency.



          Do the proposed BPCT regulations contain sufficient
          controls or evaluations to protect ground
          water?  How can EPA work with the States to
          enable effective delegation of Hazardous Waste
          Management Programs under RCRA?  What are the
          impacts if a State doesn't take the program?


     Injection wells are used for the subsurface disposal
 of  industrial, municipal, nuclear and hazardous wastes
 and wastes, associated with oil and gas production.
 Contamination is not only caused by direct injection into
 an  aquifer but also by leakage of pollutants from the
 well head, through the casing or well bore or through
 fractures in confining beds.

     An estimated 500,000 injection wells are in operation
 nationwide.  These wells involve a broad variety of practices
 and have been categorized into five classes.  (Table I)

                         TABLE I

                FUNCTION                 NUMBER OF WELLS*
                    Industrial, municipal
                    waste disposal, beneath
                    deepest stratum containing
                    drinking water source.
           Disposal of fluids brought
           to the surface in connec-
           tion with oil and gas pro-
           duction, or to increase
           recovery of oil or gas.

           Injection of fluids for solu-
           tion mining of minerals, to
           recover geothermal energy.
^Estimates of well inventory.


IV                  Hazardous waste disposal         5,000-10,000
                    into or above strata that
                    contain drinking water

V                   All other wells, i.e.,        250,000-500,000
                    air condition-return flow

     The Safe Drinking Water Act (1974) established the
Underground Injection Control (UIC) program to prevent
underground injection of wastes which endanger drinking
water sources.  States may assume primary enforcement
responsibility for operating effective programs.  EPA
responsibilities include establishing national requirements,
providing grants to States for developing and implementing
the UIC program, and reviewing and approving State programs.
EPA will administer a program only if a State chooses not
to participate or fails to administer the program effectively.
          How can EPA work with the States to enable
          effective delegation of the UIC program?  What
          are the impacts and options if several States
          don't take over the program?

     It has been estimated that 1.2 million abandoned
wells are located near the review areas for underground
injection wells.  The total number of abandoned wells is
so vast that all will never be located.

     A number of abandoned wells have caused ground-water
contamination.  Often, wells serving houses or buildings
which are being demolished for redevelopment or construction
of a highway are simply bulldozed over, often breaking
surface casings and seals.  The old wells become a direct
route for pollutants such as highway deicing chemicals or
wastewater from leaky pipelines to enter the underlying
aquifer.  Abandoned oil and gas wells also present problems,
to ground-water quality.  For example, abandoned oil
wells can discharge brine continuously, contaminating
shallow fresh water aquifers.  Abandoned gas wells can
discharge brine when the gas reserve has been depleted
and salt water has migrated to the wells.


     There is a growing effort on the part of the States
to have abandoned wells properly plugged.  As examples,
New York, Minnesota, California and New Jersey have
developed regulations concerning the drilling and plugging
of wells.  In addition, it is difficult to locate abandoned
wells if an owner connects to a municipal system in lieu
of developing a new well.  Permits are required for construc-
tion of new wells but there is no enforcement of correct
closure.  The most successful BMP, which is very expensive,
is to grout the well to prevent entrance of surface water
and inter-aquifer exchange.

     Abandoned wells may also be convenient illegal
disposal sites for wastes, particularly hazardous wastes.
The manifest system being developed under RCRA will
control the problem related to hazardous waste disposal.
Although abandoned wells are a problem, improperly constructed
wells are also sources of ground-water pollution.  Many
States established minimum standards for well construction
and/or licensed well drillers.
          What should be the Federal role in encouraging
          or mandating States to develop regulatory programs
          to properly plug abandoned wells?  In locating
          abandoned wells in key or sole source aquifers
          and undertaking appropriate remedial action?  In
          establishing minimum standards for new well

     The use of large amounts of soluble salts for road
clearing during winter months has led to a significant
number of cases of ground and surface water contamination.

     Salt-laden runoff from roads can percolate into
soils adjacent to highways and reach ground water.  Rain
falling on uncovered storage piles at highway maintenance
garages can dissolve the salt and facilitate infiltration
into shallow aquifers.  The latter generally is considered
to be a more serious problem because of the high concentration
of chloride entering the ground-water system.

     Because of the large amounts of salt spread and
stored in the Northeast, water in many aquifers, especially
sand and gravel deposits in the glaciated region, has
shown a disturbing rise in chloride and sodium concentra-
tion.  Complaints of salt contamination of water from
individual wells are so common in New England that several
States have established annual budgets to allow for
replacement of affected wells.

     There appears to be no practical substitute for
highway deicing salts.  Several States have addressed
BMPs for controlling deicing salts, e.g., reducing quantities
used and substituting sands when possible and enclosing
salt storage piles.  The Commonwealth of Massachusetts
has developed a very active program.  The program includes
an education program for spreaders, a health program to
detect high blood pressure, a program requiring BMPs for
storage piles and a salt-spreading program which reduces
the spreading rates of salt and the partial use of sand.
          What should be the Federal role in encouraging
          States to develop programs in the use of highway
          deicing salts?  How can key aquifer recharge
          areas be protected by limiting the spread or
          storage of deicing salts?

     Artifical recharge includes a variety of techniques
used to increase the amount of water infiltrating to an
aquifer.  Recharge by spreading stormwater runoff or
treated wastewater effluent over the land is the major
concern.  Underground injection wells, particularly Class
V wells, indirectly recharge ground water and are discussed
in another section.

     In the case of an artificial recharge, site-specific
impacts that need to be considered include controlling
the quality of the recharge water and controlling the
water pressure so that adverse effects do not occur.  In
many communities, the construction of this type of structure
has close scrutiny.

      Land spreading of  wastewater can pose a threat  to
 ground water unless properly controlled.   The Construction
 Grants program encourages spray irrigation of wastewater
 as an alternative treatment technique by  providing
 economic incentives pursuant to the  mandate of the Clean
 Water Act.  Projects funded by the 201 program are required
 to evaluate impacts on  ground water  and to ensure protection
 of ground water as a source of drinking water.

      Stormwater runoff  can become polluted,  particularly
 from  urban debris and areas containing industrial stock
 piles.   Protection from stock piles  runoff  can be provided
 by covering or by enclosing the materials.   EPA is developing
 BMPs  and requirements for industrial stock  piles.

      Urban  runoff is being addressed by the Water Quality
 Management  Program.   Thirty cities are currently implement-
 ing BMPs and over the next three  years will  evaluate the
 impact  on water quality and effectiveness  of  BMPs.  The
 water quality  assessments are being  made on  surface waters
 because  most runoff  in  developed  areas is  discharged into
 surface  bodies of water.   However, a few areas (Long
 Island)  are assessing various  BMPs (vegetation,  retention
 basins)  which  recharge  ground-water  supplies.
          How can policies and procedures for assessing
          wastewater disposal on land ensure ground-water
          quality impacts are taken into consideration?

     Ground-water contamination associated with mining
operations is prevalent in the Northeast, and to some
extent, in the Southwest regions.  Most mining operations
encounter ground water.  Drainage of high mineralized
water from mine workings can cause ground-water contami-

     Dewatering of mines to allow work to proceed below
the static water level causes water levels to fall.
Exposing these materials to the air can cause oxidation
of the minerals.

     Percolating surface water or rainfall entering a
mine or surface waste pile leaches the minerals and may
transport them downward to the water table.  After a mine
is abandoned and dewatering operations are suspended, the
local water table rises through the oxidized minerals,
accelerating the leaching.  This causes abandoned mines,
including strip mines, to be a greater source of ground-
water contamination than operating mines.

     In a study of ground-water quality in Appalachia,
high iron and sulfate concentrations and low pH in ground
water were traced to coal mining operations.  In northwestern
Pennsylvania, acid mine drainage moved downward from
strip mines into underlying aquifers through abandoned
oil and gas wells and rock fractures, increasing the iron
and sulfate content of the ground water.  Thousands of
active and abandoned metal mines in the western United
States contribute to acid drainage problems and other
pollution impacts from metals.

     Measures to correct drainage of poor quality water
from abandoned mines are typically prohibitive in cost.
They may include sealing of mine openings to prevent
drainage and precipitation from entering, flooding with
water to eliminate air contact with acid-forming minerals
or chemical treatment of drainage water.

     With both surface and underground mining, waste dis-
posal from mining operations — tailing piles and slurry
lagoons are a potential source of ground-water contamina-
tion.  Where aquifers underlie these sources, contaminated
water can percolate to the ground water.

     BMPs for active mines can be highly effective.  BMPs
include special handling of pollutants, e.g., isolation
of problem materials, rapid stabilization of exposed
soils, water management through diversion, terracing,
drainway, etc., bore hole grouting and shaft sealing,
preplanned flooding and avoiding post-mining gravity

     The Surface Mining Control and Reclamation Act of
1977 administered by DOI requires the implementation of a
strong water pollution control program of coal raining in
all coal States (26 States).  The program provides Federal
monies for developing a State regulatory program, partial
funding to control implementation and enforcement of the

 State regulations,  and  an  Abandoned Mine  Reclamation  Land
 (AML)  Program/  the  latter  from a  fee  on coal  production.
 The projected need  for  coal  mining pollution  control  is
 greater than 30  billion dollars.  OSM is  currently under-
 taking a three-year inventory  of  abandoned  sites.  The
 SCS under the USDA  administers the RAMP program which is
 a  rural abandoned mine  program with cost-sharing funds

      Agreements  are being  developed between EPA and the
 Office of  Surface Mining to  eliminate duplication of  NPDES
 and OSM permits.  EPA must concur on  each DOI approved
 State  Coal Mining Regulatory Program.

      Several state  programs  are currently being developed
 with mining and  ground-water protection.  Arizona is
 developing a program to manage both surface and ground-
 water  impacts from  mining, and New Mexico is  developing a
 ground-water strategy to implement regulations in Albuquerque
 - Metro, Carlsbad and Grants Mineral  Belt areas.  Particular
 emphasis  is directed to controlling the impacts of uranium
 mining  on  ground water.

     The OSW recently initiated a $3  million program  for
 monitoring ground-water  pollution resulting from mining
 pollution.  Two of  the  sites are  located in New Mexico
 and  Arizona.  The purpose of the program is to develop
 data for the hazardous waste program  under RCRA and to
 work with  the industries to develop BMPs.
          What should be the_Federal role and the State
          role in ensuring that BMPs and a regulatory
          program will be implemented for non-coal mining

     In the United States municipal sludge production
amounts to about 5 million dry tons per year and volume
of industrial sludge is much greater.  This area was not
delineated into a separate category because hazardous
materials included in sludge, which has the greater
impact on ground water quality, are addressed under RCRA
and the pretreatment program.  Stronger and more comprehensive
source controls will encourage development of recycling/
reuse and degradation technology.


     One of the waste disposal problems which could have
an effect on ground-water quality but was not specifically
addressed in the previous sections is sludge management
using land spreading.  Ground-water degradation could be
caused from the leaching and percolation of organisms and
chemical ions and compounds.


     The purpose of this analysis is to summarize EPA's
legal authorities and programs which affect or may affect
ground-water protection.  It is not intended as a set
of recommendations by EPA, but rather a tool to provide
information and stimulate ideas.  At the time this
document was prepared RCRA and UIC regulations had not
been promulgated, and, therefore, were not included
in this analysis.

     This analysis identifies each EPA law according
to section or some other appropriate designation.  These
laws and sections are classified into six categories:
policy, program development, regulatory, control tech-
nologies and standards, information development and
transfer and emergency powers.  Statutory language in
each of the six categories has been analyzed for im-
plementation of a proposed strategy.  The status of
implementation of authorities within each category
is briefly set forth.  This includes an identification
of difficiencies or potential areas where improvement
is needed.

     The major acts administered by EPA, along with
NEPA, the President's Water Resources Policy Reform
Message, and its July 12, 1978 memoranda of implementation
contain policy statements that vary in their specificity
and the extent to which they have been carried out in
the area of ground-water protection.

     RCRA, TSCA and FIFRA contain rather general state-
ments of policy to protect health and environment.  Use
of these general policies to develop a ground-water
protection strategy has been been minimal to date.  Cur-
rently OPTS and the Office of Drinking Water have made
arrangements to review the effect of new chemicals on
ground water, and are developing regulations on solvents.
Further efforts to incorporate ground-water emphasis in
EPA Toxic Substances Priority Committee are anticipated.

     A major SDWA policy is to protect underground sources
of drinking water.  This policy is being implemented by

 the development of the UIC  regulations  (see  regulatory
 category summary).

      The President has issued  a  memorandum to  implement
 his Water Resources Policy  Reform Message which directs
 Federal  Agencies to take  specific ground-water actions
 when planning water resources  projects  and gathering

      Potentially the most valuable policy foundations
 for developing  a broad, ground-water  strategy  are NEPA,
 Section  309  of  the Clean  Air Act,  and Sections 101(a)
 and 102(a) of the  Clean Water  Act.  The environmental
 impact statement requirements  of NEPA emerge as a
 unique tool  to  be  utilized  by  all Federal Agencies in
 the planning process as it  relates to the ground-water
 resources.   NEPA provides EPA, as well  as other Federal
 Agencies, with  the opportunity to review, comment on,
 and,  if  necessary,  recommend modification of Federal
 Agency actions  that affect  ground water.  However, NEPA
 is  advisory  in  nature,  not  enforceable.  Currently,
 the degree of analysis  of ground-water  considerations
 varies in environmental assessments and EIS's  on a
 case-by-case basis.

      In  addition to EPA's EIS  review  mandate under
 NEPA, Section 309  of the  Clean Air Act  directs the
 Administrator of EPA to review and comment in  writing
 on  the environmental impact of any matter relating to
 EPA statutory authority contained in  (1) legislation
 proposed by  any  Federal department or Agency (2) Federal
 construction projects and major Agency  actions which
 significantly affect the  environment  and (3) proposed
 regulations  published by  a Federal department  or agency.
 If  the Administrator determines  that  any such  legislation,
 action, or regulation is  unsatisfactory from the stand-
 point of public  health or welfare  or  environmental quality,
 he  is directed to publish his  determination and refer the
 matter to the Council on  Environmental  Quality.  The 309
 authority puts EPA  in the unique  position of "watchdogging"
 other Federal agencies activities, as well as  its own,
 concerning how they  may affect the ground water resource.

     Sections 101(a) and  102(a) of the  Clean Water Act
promote the  objective of  restoring and  maintaining the
 integrity of the Nation's waters  and  call for  the devel-
opment of comprehensive programs  for preventing,  reducing,
or  eliminating the pollution of the navigable  waters and
ground waters.    This congressional policy objective could
be  the impetus behind strengthening or  revision of existing
programs, or the pursuit  of new legislative initiatives.

     These existing policies, if expanded of redirected,
represent a opportunity for developing and carrying out
a ground-water strategy.

     Table 1 summarizes this discussion.

     Program development opportunities for ground-water
protection are available within the current EPA statutes
and authorities, although in many cases they are not
fully utilized.  Properly structured, these opportunities
could provide additional options in implementing a ground-
water protection program.  Programs included in the category
of program development are those relating to planning,
management, and implementation, including construction,
which generally are grant-related.

     Sections 104, 106, 208 and 304 of the Clean Water
Act offer specific program potential which could provide the
foundation for statewide ground-water protection programs.
In two of these programs, 104 and 106, little attention
has been given to ground water because of the low priority
of this issue.  There is, however, a clear opportunity
to expand the interpretations and functions within them
given sufficient resources.  Section 104 funds have not
been used for ground water.

     Section 304 has been used to make ground-water
protection a priority requirement for municipal waste-
water projects receiving construction grant funds from
EPA.  The criteria for best practicable waste treatment
(PR 41, No. 29, p. 2160) require that projects are
evaluated to protect the ground water for use as a
drinking water supply or other appropriate uses.

     Section 208 has had a limited ground water focus
because of resource and time constraints.  It has recently
been redirected to encourage States to develop ground-
water protection programs.  Eight million dollars is
being spent on development of ground-water protection
controls nationwide.  There appears to be an increasing
emphasis on "conjunctive" management of surface and ground
waters.  This program affords one of the key initiatives for
ground-water protection.


      Sections  4002,  4003,  and  4008  of  RCRA (non-hazardous
 waste management)  also provide a  mechanism to  control
 contamination  of  the ground  water.   There  is,  however,  no
 direct Federal enforcement associated  with this  program.
 Refinements  can be made in this program, but the language
 does  not  appear to provide a basis  for an  expanded  program.

      The  potential role of Section  1424 (e), sole source
 aquifer designation,  is limited according  to Federal
 jurisdiction.   It  is,  by definition, a Federal program
 designed  to  provide  for protection  of  the  sole or
 principal sources  of  drinking  water.   It is implemented
 by review of Federal  financially  assisted  projects  for
 potential contamination of underlying  ground water  resulting
 in a  public  health hazard.   Procedural regulations  for  this
 program are  under  development.  There  could still be
 provisions made in the final regulation to influence other
 Federal agencies,  States and localities with respect to
 ground water protection through the incorporation of or
 reference of the EPA  ground-water protection strategy currently
 being  developed.

      Table 2 summarizes this discussion, identifies
 relevant  grant programs, and identifies in greater
 detail  preliminary potential actions.

     This section includes only those portions of
major EPA legislation which are directly enforceable
by EPA.  Such parts of the Clean Water Act as effluent
guidelines and BMP's are included in the Control Tech-
nologies and Standards.  Emphasis was placed on those
regulatory mandates which are implemented by permits.

     The strongest EPA regulatory authorities to control
pollution of ground water are those regulating underground
injection under SDWA; those regulating hazardous waste
landfills or other disposal sites under RCRA; and the
broad regulatory authority under TSCA Section 6 to regulate
chemicals at any step from production to disposal.

     Potential regulatory authorities to control pollution
of ground water are the discharge permitting authority
under Section 402 and the dredge and fill permitting
authority under Section 404 of the CWA.  The use of FIFRA
to control contamination by pesticides and containers is
also possible.  Use of any specific act may depend on the
avenue of contamination to be controlled.

     Table 3 summarizes this discussion and provides
greater detail on potential actions.

     Control technologies include requirements for use
of specific types or levels of technology.   Standards
include uses, criteria (numerical limitations mass con-
centration), and performance standards.  Generally,
the technologies and standards identified in the CWA
currently are applied to surface water only.  An im-
portant exception is use of Section 304 criteria for
protection of ground water, but only for 201 funded
projects.  They provide a control concept which may be
transferrable to a ground-water management program.

     The control technologies identified in the CWA
include, for effluent limitations, best practicable
control technology (BPT), best conventional technology
(BCT), best available technology (BAT), and best manage-
ment practices (BMP) for nonpoint sources,  new source
performance standards (NSPS), and innovative and
alternative treatment technologies for publicly owned
treatment works.  In SDWA, the primary ground-water
control technology can be found in Section 1421 which
relates to the UIC program.  RCRA Section 1008 has
resulted in guidelines which provide a technical
and economic description of the level of performance
which can be attained by various solid waste management
practices.  Both the SDWA and RCRA control technology
requirements can provide an initial basis for a ground-
water management program.

     Historically, standards requirements in the CWA
have been applied to surface water.  However, several
States have existing ground-water standards programs
and others are considering using the standards approach.
Thus, it is useful to examine the surface water quality
standards requirement to determine its potential relevance
to any ground-water quality standards program which the
EPA Ground Water Protection Strategy might address.

     Section 1412 of the SDWA requires the promulgation
of primary drinking water standards which establish
maximum contaminant levels or treatment technology
requirements.  These standards apply to water at the
tap rather than at the source.  RCRA, Section 3004,
requires performance standards for owners and operators


 of  hazardous waste management  facilities  and Section
 4004 provides  for criteria  for classifying  sanitary
 landfills  and  open dumps.   These  two  sections provide
 a mechanism for  ground-water protection,

     Table 4 summarizes  this discussion and provides
 greater  detail on potential actions.

     Relevant  statutory authorities for information
 development  and transfer are divided into three
 groupings:   technical assistance, monitoring/ and
 research and development.

     Technical assistance requirements, including
 collection and dissemination of information, educational
 programs, and training can be found in all of these

     Each of the statutes also contains monitoring
 and surveillance requirements.  Potential actions
 identified in regard to monitoring emphasize the need
 for increased ground-water monitoring, consistency of
 parameters used by the various programs, and a con-
 solidated monitoring program.

     The section on research and development identifies
 ongoing programs and their related budget, but does
 not detail a research strategy which is contained
 in another section.

     See Table 5 for a more detailed analysis of
 information  development and transfer requirements.

     The type of authority and the normal kind of
response for emergencies varies by program area.  Authority
ranges from that under the proposed Superfund legis-
lation and the existing CWA Section 311 clean-up of
spills to the technical advice and assistance offered
by RCRA.  Most likely the legislation to establish a
Superfund would tie together all the disparate pieces
now implemented separately by each program office.

                                               TABLE 1

                                 RELATING TO GROUND WATER PROTECTION
                                   Status of  Implementation
 Potential Actions
       Maintain integrity of Nation's
       waters.  Develop comprehensive
       programs for water pollution
       control re: navigable waters
       and ground waters

                                    Status of Implementation
Potential Actions
         Water Resources  Policy Reform
         Protect health and
Prevent unreasonable risk to
health and environment.
         Prevent unreasonable risk to
         health and environment.
         To protect underground sources
         of drinking water.
                                    Executive Policy

                                    July 12, 1978, implementing

                                    DOI report issued.

                                    Resource Conservation and
                                    Recovery Act - Section 1003
                                             Toxic Substancos Control
                                             Act - Section 1
                                    Federal Insecticide. Fungicide,
                                    and RodentIcids Act — Section 3
                                    and 6

                                    Guidelines requiring data on
                                    environmental fate of pesti-
                                    cides proposed; final rule-
                                    making expected Summer 1980.

                                    §afe Drinking Water Act -
                                    Section 1421

                                    Under development.
Ensure consistency.

                                                 TABLE  2

                                             PROGRAM DEVELOPMENT
Status of Implementation^
Potential Action
                                              Clean Water Act - Section
                                              104(a) (5)
        EPA  in cooperation with  States
        equips and maintains a water
        quality  surveillance system
        for  the  purpose of monitoring
        the  quality of navigable waters
        and  ground waters.
        Grants  to  States to prevent,
        reduce  or  eliminate pollution.
Only surface water monitoring
has been implemented.  Most
of ground water has been done
by USGS except R&D/monitoring
by Ada Laboratory, at MERL, and
at Office of Drinking Water.


FY 80 - $3 million
FY 81 - $2.5 million

Section 106

Surface Waters: Funds used
at State level for permits,
monitorincr, trainina, public
participation, proaram
operation, etc.

Ground Waters:  Little
emphasis to date.  Program
funds traditionally used for
surface water proarams.


FY 80 - .$100 million
FY 81 - $48.7 million
Resume development of
ground-water monitoring
strategy for Federal/
State activities.
Authority exists for
use of 106 funds in
around water (e.g. NY
State NPDES proaram
covers underground
discharges), but they
have been decreasing
over the years.

Needs Assessment Advisory
Group (NAAG) Should add
ground-water functions
into their anaylsis as
an Agency priority.

                                            TABLE 2
                                      PROGRAM DEVELOPMENT
Status of Implementation
     Potential Action
Authorizes Administrator to
make grants for construction
of publicly owned treatment
works.  Requires consideration
of innovative and alternative
technologies and 15% cost
preference under cost
effectiveness guidelines.

Grants are available for
privately owned treatment
works under certain conditions.
 Requires Agency  to  issue
 information  and  guidelines  to
 restore and  maintain  the
 chemical,  physical, and
 biological integrity  of all
 navigable  waters, ground  waters,
     Clean Water Act
        202(a) (2)

Step 1 planning must consider
availability of supply, including
ground water, for determining
size of facility and future
growth resulting from the


FY 80 - $3.4 million
FY 81 - $3.7 million (requests)
     Clean Water Act
         304(a) (2)

Section  201  projects must protect
ground water as a  source of
drinking water or  other appro-
priate use.
Ensure in development
of Step 1 plans that
ground water and surface
water impacts are given
equal consideration.
Ensures the above for 201
funded projects.

                                       TABLE 2  (cont'd)

                                      PROGRAM DEVELOPMENT

                                   Status of Implementation
     Potential Action

    TABLE 2 (cont'd)


Status of Implementation
     Potential Action
       State program developed for
       closing open dumps.

       State may develop permit
       programs to implement this
Resource Conservation and
      Recovery Act

Regs, promulgated Sept. 79

Implementation has  commenced.

Limited actual monitoring will
take place.

No Federal back-up program.

Limited Federal dollars.

Potential ground-water
contamination through "small
generators" and non-hazardous
industrial wastes.

No financial responsibility on
owner/operator for closure or
post closure.


FY 80 - $10 million
FY 81 - $ 8 million   (requested)
Amend statute to assure
Federal back-up in the
event States fail to
complete inventories of
non-hazardous wastes.
                                                                             Reevaluate open dump
                                                                             criteria (for improved
                                                                             ground-water quality)
                                                                             for harmful pollutants
                                                                             not covered.

                                             TABLE  2  (cont'd)

                                            PROGRAM DEVELOPMENT

      Language	Status of  Implementation	Potential Action


      Assistance  to rural communities
      for solid waste management
                                            State/EPA Agreement
      Mechanism to ensure integrated,    All FY 80 agreements signed.       Continue high agency
      cost-effective, and coordinated    FY 81 agreements being             priority for SEA.
      implementation of EPA programs.    negotiated.  Increased
                                         emphasis on addressing environ-    Encourage increased
                                         mental problems.                   emphasis on ground
<                                                                           water.

                                            TABLE 3
Status of Implementation
     Potential Action
Control of discharges to
navigable waters by HPDES.
     Clean Water Act

Ongoing, but does not reflect
interface of surface and ground
water.  State program must
control underground injection
from point sources discharge to
surface waters.
Rank permit renewal so
discharges upstream from
drinking water intakes
and recharge areas are
high priority.
                                                                      Explore extent to which
                                                                      this program can be
                                                                      applied to ground-water
                                                                      contamination from
                                                                      Look for new ways to use
                                                                      the 208 "consistency"
                                                                      clause to protect ground
Protection of U.S. waters
from impacts of dredged and/or
fill materials via permit
issued by Corps of Engineers,
reviewed by EPA.

Applies  to  protection of
ground-water quality especially
recharge areas  and  salt water
intrusion.  Little  or no
compliance  monitoring due  to
lack of  resources.
Expand CWA definition of
"waters of the U.S," to
include subsurface waters.
Train staff and research
regarding ground water/
surface water interaction.

Develop permitting strategy
that addresses ground
water concerns.

    TABLE 3 (cont'd)


Status of Implementation
                                                                                 Potential Action
                                              Clean Water Act
      The Administrator may prevent
      disposal at sites specified
      by Secretary of Army upon
      determination that discharge
      will have an unacceptable
      adverse effect on municipal
      water supplies.
      Regulation of sludge disposal
                                   Utilize this authority to
                                   prohibit disposal to
                                   navigable waters that
                                   recharge aquifers.
      Control of hazardous waste
      disposal sites by permit.
     Hazardous Waste Control Grants
     for  States

Proposed regulations not yet
issued.  Section appeared in
1972 Act, and was strengthened
in 1977.

Resource Conservation and
      Recovery Act

To be issued as part of
consolidated permits regulatory


FY 80 - $18.6 million
FY 81 - $30 million
Promulgate regulations
consistent with ground~
water strategy.
Rank permitting of sites
to minimize ground-water
contamination from
uncontrolled disposal of
hazardous waste.

         TABLE 3 (cont'd)


     Status of Implementation
     Potential Action
      Protection by permit for
      ground water from sub-
      surface discharges.
      Protection of  sole or
      principal drinking water
      source aquifer.
        Safe Drinking Water
            Act (SDWAT
            1421 (UIC)

Regulation promulgation in process
Fifty-seven States and territories
eligible for grants.


Proposed regulations published Sept.
                                    Final regulations being developed.
Final regulations should
contain key elements of
"EPA Ground Water Protection

     Status of Implementation
                    Potential Action
Control of all  pesticides
by means of registration
or other authorization  for
sale  and use only  in
accordance with practices
which do not cause no
reasonable adverse
environmental effects.
Control of pesticides
packages or containers
and disposal or storage
of excess amounts of
                                                                      Develop regulatory controls
                                                                      for septic system solvents
                                                                      and other chemicals which
                                                                      pose ground-water problems.
  Federal  Insecticide Fungicide and
      Rodenticide Act  (FIFRA)
            3,5,18,  & 24

Environmental chemistry data is
required  prior  to registration on
which soil  transformation, transport
and retabolism  can  be  assessed from
which to  predict ground water effects
which may occur through use. Final
guidelines  expected summer 1980.

Production  and  (limited) use data
available from  which to assess location
and magnitude of ground water "exposure.
                              As re-registration occurs, labels are
                              being changed to read "Bury in safe place
                              away from water supplies."
               40,000 products registered.
               19 (a)

Guidelines May 1, 1974.
since then.
Not updated
Recommendation: Disposal in accordance
with Federal, State, and local pollution
control regulations.  Well injection only
with guidelines from RA.

Well injection only if all reasonable
alternatives have been explored and
found unsatisfactory.  Storage where
underground water won't be affected.

                                                 TABLE 4
                                   CONTROL TECHNOLOGIES AND STANDARDS
                                 Status of Implementation
                                             Potential Action
Grants for construction of
treatment works shall not
be made unless it has been
demonstrated that
"innovative and alternative
wastewater treatment
processes and techniques
which provide for the
reclaiming and reuse of
water...and utilize
recycling techniques, land
treatment...and the confined
disposal of pollutants...
have been fully studied...."
       Clean Water Act
      Section 304 (a)(2)

See comments on Table 2 for use of
these sections to protect ground
water for projects funded under 201.

        Clean Water Act
       Section 201(g)(5)

Potential for ground-water pollution
from land treatment, but also
potential for increased recharge.
Federal Register, February 11, 1976
defines criteria for evaluating
treatment technologies, including
land treatment.  Primary drinking
water standards provide technological
basis for protection of drinking
water supplies.
Develop criteria for
protecting ground water
uses other than drinking

Improve coordination
within EPA to ensure
criteria are met and
program recommendations
(e.g. 208, 201, Step 1,
Sole Source) are uniform.
                                                                             Review applications for
                                                                             innovative and alternative
                                                                             technologies to ensure
                                                                             ground-water protection.,
                                                                             with  particular emphasis
                                                                             on Federal Sole Source

                                             TABLE 4 (cont'd)

 	Status of Implementation	
     Potential Action
     Grants for construction of
     waste treatment works are
     conditioned on a determina-
     tion by the Administrator
     that the size and capacity
     of such works directly
     relate to needs.  Reserved
     capacity shall be determined
     after considering efforts to
     reduce total flow of sewage
     and unnecessary water
           Clean Water Act
          Section 204(a)(5)

Potential vehicle to protect ground-
water quantity and indirectly quality.
This is now a part of all Step 1
analysis for design of waste treat-
ment facilities.
Give equal consideration
to ground and surface
water conservation.
                                        Disseminate information
                                        regarding ground-water
                                        quantity/quality relation-
     Regulations require
     development of Best
     Management Practices (BMP)
     to address identified
     nonpoint source pollution
     problems including ground
     water  quality-related
           Clean Water Act
             Section 208

Initial planning cycle is complete.
BMP's that have been developed are
supposed to be implemented, tested,
revised by 208 management agencies.
208 Funding Policy favors prototype
projects to develop managment
programs for ground water, including
BMP's, which are transferrable to
other States.
Develop guidance which
addresses BMP's for
ground water.
Expand and improve
existing information
exchange programs to
transfer state-of-the-
ar.t technology in
ground-water management.

                                        TABLE 4 (cont'd)

                               CONTROL TECHNOLOGIES AND STANDARDS

                              	  Status of Implementation	
                                             Potential Action
     No permit under Section 402
     shall be issued for any
     point source which is in
     conflict with a 208 plan.
                                              Section 208(e)
                                                                      Where point sources
                                                                     'discharge to surface
                                                                      water impacts ground
                                                                      water and 208 plan
                                                                      identifies ground-water
                                                                      problem, condition permit
                                                                      to protect ground water.
(1) (A)
Requires establishment by
July 1, 1977 of effluent
limitations for point
sources other than publicly
owned treatment works which
shall require application
of the best practicable
control technology currently
available (BPT).

For publicly owned treatment
works in existence on
July 1, 1977 effluent
limitations based on
secondary treatment.
                                              Clean Water Act
                                              Section 30Kb)
Applied only to discharges to
                                   Applied only to discharges to surface
Develop similar program for
ground water.(Substantial
legal problems).
                                        Develop similar program for
                                        ground water.  (Substantial
                                        legal problems.)

                                              TABLE 4  (cont'd)

                                     CONTROL TECHNOLOGIES AND STANDARDS

      Language	Status of Implementation	Potential Action	

       (1) (C)
      By July 1,  1977 any more      Applied only  to discharges to surface   Extend concept to ground
      stringent  limitation          water.                                  water.  (Substantial legal
      including  those necessary                                             problems.)
      to meet water quality
      standards,  treatment
      standards  or schedule
      of compliance established
      pursuant to an State law
      or regulation or required
      to implement any water
      quality standard established
      pursuant to the Clean Water
 V                                             Section 301(b)

      (2) (A)
      Establishes requirement for   Applied only  to discharges to surface   Develop similar program
      best available technology     water.                                  for ground water.
      economically feasible by                                              (Substantial legal problems.)
      July If 1984 for toxic and

                                        TABLE 4 (cont'd)

                               CONTROL TECHNOLOGIES AND STANDARDS

                              	Status of Implementation	
                                        Potential Action
      (a) (3) (A) and  (C) (2)
      Requires States  to  adopt water
      quality standards applicable to
      intrastate waters and  submit
      them  to the Administrator  for
(a) (3), (c) and (d)
For States which do not adopt
standards within the prescribed
timeframe the Administrator
shall promulgate standards for
those States.

Revised and new standards shall
consist of designated uses of
the navigable waters involved
and the water quality criteria
for such waters based upon such
                                              Clean Water Act
                                                Section 303
                                   Has only been applied to surface
                                   waters.  New policy planned which
                                   will make certain pollutants
Done selectively.  It may only be
part of a State's revised standard
that is promulgated by EPA.  40 CPR
120 includes standards EPA has
                                         EPA emphasizing attainability of in
                                         place standards, (e.g.  for
                                         intermittent streams)  Emphasizing
                                         site specific designations of uses
                                         and appropriate criteria to protect

                                                 Section 303
                                        Require encourage States
                                        to adopt  ground-water
                                        quality standards.  Seek
                                        authorizing legislation
                                        if needed. (Substantial
                                        legal problems.)
                                                                                 Employ similar approach
                                                                                 to ground-water quality
                                                                                 standards.  (Substantial
                                                                                 legal problems.)
                                        Employ similar approach
                                        to ground-water quality
                                        standards.  (Substantial
                                        legal problems.)
      Requires States to establish
      total daily maximum load (TDML)
      for pollutants for waters for
      which effluent limitations are
      not stringent enough to implement
      water quality standards, (see 303
      (d) (1) (A) and (B) .
                                   Based on  standards.
                                         Apply TDML  concept to
                                         ground-water  aquifers.
                                         substantial legal

                                             TABLE  4  (cont'd)
                                     CONTROL TECHNOLOGIES AND STANDARDS
                                   Status of Implementation
                                             Potential Action
      Requires identification of
      the degree of effluent
      reduction attainable through
      application of the best
      conventional pollution
      control technology (BCT).
      BCT is largely treatment
      cost based.
Publish regulations for any
specific pollutant which EPA
is charged with a duty to
regulate as a toxic or
hazardous pollutant under
Section 307(a)(1) or 311 to
control plant site runoff,
spillage or leaks, sludge
or waste disposal and
drainage from raw material
storage...ancillary to
industrial manufacturing
or treatment process...
and contribute significant
amounts of such pollutants
to navigable waters.
                                         Clean Water Act
                                        Section 304(b)(4)

                              Consideration given to impacts on ground
                              water in determining BCT.  Emphasis on good
                              engineering practices such as lining
                              lagoons.  RCRA 3004 covers similar
           Section 304(e)

This is a technology based requirement
rather than a performance standard.  Same
as requirement in RCRA regarding hazardous
                                             Make consideration of
                                             ground-water impacts
Amend or interpret 304(e)
to include impacts on
ground water during
transport to navigable
                                                                                 Amend 304(e)  to address
                                                                                 introduction  of these
                                                                                 pollutants into ground

          TABLE  4  (cont'd)


	Status  of implementation	
Potential Action
     Authorizes EPA to promulgate
     effluent  standards for
     toxic pollutants.  Certain
     toxic pollutants shall be subject
     to effluent limitation from
     application of the best
     available technology economically
     achievable for the applicable
     category or class of point
     source established in accordance
     with Sections 30Kb) (2) (A) and
     304(b)(2) of the Art.
             Section  307

     Effluent standard  applies  to  a pollutant
     nation-wide.   See  Federal  Register,
     January 13,  1977 for  list  (e.g. Aidrin,
     DDT,  PCB's etc.).
     Propose and promulgate
     regulations for State under-
     ground injection controls.
         Safe Drinking Water
            Section 1421

     The proposal and promulgation of
     regulations for the Underground
     Injection Control program will include
     detailed control technologies for
     ensuring mechnical integrity related
     to injection well construction. Not yet
Amend or interpret
authority to extend
effluent standard
concept to ground
                                                  Apply  effluent
                                                  standard concept  to
                                                  pollutants  tied to
                                                  non-point source
                                                  activities  which  may
                                                  pollute ground water.
Ensure adequate
publicity and
and understanding
of the regulations.
                                                                                     EPA provide technical
                                                                                     assistance to States
                                                                                     to ensure full
                                                                                     implementation of

                                              TABLE 4 (cont'd)
                                     CONTROL TECHNOLOGIES AND STANDARDS
Status of Implementation
      Publish suggested guidelines
      providing technical and economic
      description of level of
      performance that can be attained
      by various solid waste management
      practices including methods and
      degrees of control to protect
      public health, protect ground
      and surface water quality from
      leachates, etc.
 Resource Conservation And
       Recovery Act
       Section 1008

Guidelines have been published.
      Promulgate regulations establish-
      ing performance standards for
      owners and operators of
      hazardous waste management
      facilities to include location,
      design and storage.
      Promulgate regulations
      containing criteria for
      classifying sanitary landfills
      and open dumps.
       Section 3004

Regulations proposed.  Except to
be promulgated in two phases in
April and October 1980.
       Section 4004

Potential Action
Ensure coordinated and
consistent application
at State and local level
of solid waste management
practices and nonpoint
source BMP's.
                                        Investigate alternative
                                        methods of implementation
                                        including mandatory
Expand criteria to include
additional pollutants
giving first emphasis to
priority pollutants
identified in 1977
Amendments to the CWA.

                                                    TABLE  5

                                    INFORMATION DEVELOPMENT AND  TRANSFER

                                               Clean Water  Act
Technical assistance  to
States  in developing  and
implementing a program
for dredged and  fill
Technical assistance and
cost sharing for the
Rural Clean Water
Program  (RCWP).
Public  information and
education program on
recycling and  reuse of
wastewater  (including
sludge), the use of land
treatment,  and methods
for  the reduction of
wastewater  volume.
                                            Section  208(i)(l)
               Section 208(j)(l)

    Agriculture Rural Development & Related
    Agencies Appropriations Act, FY 80
    P.L. 96-108.

Appropriation to USDA of $50 million for FY
80, $30 million spent to date.  Experimental
RCWP Program.  13 projects to date none speci-
fically addressed ground water.  EPA approves
technological practices.  When there may be a
ground water problem, practices are required
to address it.  Request of $20 million in
Presidents budget for FY 81.

                  Section 214
New projects should focus
on ground-water problems.


                                              TECHNICAL ASSISTANCE

                                                 Clean Water Act
                                          STATUS OF IMPLEMENTATION
   Criteria  for water qual-
   ity  including  kind and
   extent of effects on
   health and welfare,
   including ground water.
   Information on factors
   necessary to restore and
   maintain chemical/
<  physical and biological
 i  integrity of ground
   Publish information
   including guidelines and
   proceses, procedures and
   methods to control
   pollution from non-point
   sources.  This includes
   agriculture, raining,
   constuction, disposal in
   wells or subsurface
   excavations, salt water
   intrusion and changes in
   flow of surface and
   ground waters.
                                               Section 304(a)

                               Has been published and periodically revised.
Increased emphasis on
                                                Section  304(a)
                                               Section 304(f)
                               Has been published.
                                                                                Publish additional informa-
                                                                                tion reflecting State-of-
                                                                                the-Art in ground-water
                                                                                management/ including find-
                                                                                ings and summaries from 208
                                                                                ground-water prototype

                                                TABLE 5 (Continued)

                                       INFORMATION DEVELOPMENT AND TRANSFER

                                              Safe Drinking Water Act
                                           STATUS OF IMPLEMENTATION
                                                                                       POTENTIAL ACTION
    Technical assistance to
    States and municipali-
    ties for development of
    public water supply
    system (PWS) supervision
    program and underground
    injection control (UIC).
Technical assistance to
States and publicly
owned water systems to
assist in responding to
and alleviating
emergency situations
affecting public water
systems including
sources of water for
such systems.
                                         Section 1442(A)(2)(a)

                                         Section 1442(A)(2)(b)
                                Irapleraentat ion
                                                                                 Continued ground-water
                                                                                 emphasis is necessary.

    TABLE 5 (continued)


Toxic Substances Control Act

    Collection and dissemin-
    ation of data submitted
    to other Federal
    departments under TSCA.
                                                  Section 10

                                                     TABLE 5

                                      INFORMATION DEVELOPMENT AND TRANSFER

                                            TECHNICAL ASSISTANCE
                                     Resource Conservation and Recovery Act
                                          STATUS OF IMPLEMENTATION
                                                       POTENTIAL ACTION
   Technical assistance
   through Resource Conser-
   vation and Recovery
   Panels for Solid Waste
   Management, Resource
   Recovery and
•<  Provide technical
   assistance to State and
   local governments for
   purposes of developing
   and implementing State

   Evaluate commercial
   feasibility of resource
   recovery facilities and
   develop data base for
   purposes of assisting
   persons in choosing such
   a system.
   EPA funds training for
   all aspects of solid
   waste management.
                 Section 2003

Experts are assembled in each EPA regional
office to provide technical assistance to
communities on all aspects of solid waste.
Ground water received perhaps 20% of the
effort.  Use vehicle for other programs—e.g.,
OWP contributed to the Region IX panel to
perform aquifer rnapping at an Indian

                Section 4008(d)

State Guidance provided by Regional Office.
                                                Section 5004

                               No activity to date.  Positions established,
                               but office not yet performed.
                                                                                Develop technology transfer
                                                                                process to assure findings
                                                                                are available for other
                                                 Accelerate program develop-
                                                 Section  7007

                                Implemented  in part  through  grants  to  public
                                interest  groups.   80 meetings  have  been held;
                                about  25% of the  overall  content  was devoted
                                to  ground water.   Also implemented  through
                                Peer Match by wnich  the agency pays travel
                                and expenses for  experienced officials to
                                consult with other communities facing  similar
                                                 Develop  technology transfer
                                                 to  assure  information
                                                 developed  is available to

                                               TABLE  5  (continued)

                                              TECHNICAL ASSISTANCE

                                     Resource Conservation and Recovery Act


                                                Section 8003

   Provides for                No concerted, programmatic implementation
   coordination, collection    Occurs as normal office function of report
   and dissemination of        writing and publication.

                                            TABLE 5 (CONTINUED)

                                   INFORMATION DEVELOPMENT AND TRANSFER


                                              Clean Water Act

                                       STATUS OF IMPLEMENTATION
                                                                                       POTENTIAL ACTION
    Shall establish national
    programs which equip and
    maintain a surface and
    surveillance system.
                                           Section 104(a)(1)

                            Established and on going.  Major focus on
                            surface water.  Primarily oriented toward
                            ambient water quality monitoring and trends
                            rather than compliance.  Collected in the
                            Storet data system.  Interagency agreement
                            with USGS to do ground-water monitoring.
Increased emphasis on
ground-water monitoring.
Grants to States  are
contingent on
establishing and
maintaining a  (surface
and) ground-water
monitoring system
capable to supporting
the Sec. 305 report.
               Section 106(e)(l)

Coordinated with 104 above.   Also entirely
devoted to surface water.
Include ground-water
monitoring in next grant
application round.

                                             TABLE 5  (continued)


                                           Safe Drinking Water Act


                                           Section 1421(b)(l)(C)

 UIC regulations require     Regulations have been proposed which require     Develop system to integrate
 that monitoring be part     both mechanical integrity monitoring and water   monitoring data with data
 of the permit process.      quality monitoring.                              from other programs.

                                                TABLE 5 (continued)


                                      Resource Conservation and Recovery Act
    EPA can require
    storage,treatment and
    disposal sites to
    No explicit Federal
    monitoring authority.
                 Section 3004

Regulations have been proposed which specify
number and location of minimally acceptable
monitoring systems.  Monitoring objective is
regulatory control of individual facilities.

                 Section 4004

State programs are required to have capability
of monitoring facilities.
Data generated from 3004
monitoring should be
integrated into EPA data
collection system.
Data generated under 4004
should be integrated into
EPA data collection system.

                                                TABLE 5 (continued)


                                          Toxic Substances Control Act


                                                 Section 10
    Shall conduct such          Only  very few incidents have been monitored.     Develop coordination
    monitoring as necessary     even  fewer in ground water.  Only a  few          mechanism to more fully
    to carry out the Act.        substances, such  as septic  tank degreasers,      utilize TSCA monitoring
                                will  be subject to  TSCA ground-water            capability.

                                                 TABLE 5 (continued)


                                 Federal Insecticide, Fungicide and Rodenticide Act
     Shall undertake
     monitoring activities as
     may be necessary to
     implement FIFRA and the
     National Monitoring
     Pesticide Plan.  Shall
     establish procedures for
     monitoring environmental
     and incidental exposure.
                  Section 20

Well developed data base on fate and effects
of pesticides in air, food, soil,  human
tissue, etc.  Little emphasis on ground water
monitoring.  Procedures manuals and protocols
have been disseminated.
Efforts should be made to
include monitoring for
presence and potential
effects of all pesticides
on ground water.

Ensure consistency with
other programs.

                                                  TABLE 5

                                   INFORMATION DEVELOPMENT AND TRANSFER

                                         RESEARCH AND DEVELOPMENT

                                  Resource Conservation and Recovery Act

        LANGUAGE                       STATUS OF IMPLEMENTATION                    POTENTIAL ACTION
                                             Section 8001
Conduct research            See R&D Strategy.
relating to any adverse
health and welfare
effects of release of
waste constituents;
development of new
disposal methods, and
improvements reducing
the adverse effects of
disposal.  May use pilot
plant facilities.

                                             Section 8002

Conduct detailed study      Sludge study complete, sent to Congress.
of effects of raining on     Mining waste study commenced.  Completion
waste water, including      during FY 80.
the effects of leachate;
study the effects of
sludge on water.

                                                TABLE 5 (continued)

                                             RESEARCH AND DEVELOPMENT

                                                Safe Drinking Water
                                       STATUS OF IMPLEMENTATION
                                                                                       POTENTIAL ACTION
May conduct research
related to the provision
of safe water supply,
including measurement of
contaminants and methods
of protection from
                                                 Section 1442

                                Studies on waste disposal practices,  methods
                                of preventing-detecting-dealing with  surface
                                spills with underground impacts,  impacts of
                                abandoned injection/extraction wells, and
                                impacts of intensive application of
                                pesticides, etc. in recharge areas have been
                                completed.  National assessment of impact of
                                surface impoundment on underground sources is
                                near ing completion.  Research  being conducted
                                on subsurface transport and fate of
                                contaminants .

                                               TABLE 5  (continued)

                                              RESEARCH AND DEVELOPMENT

                                            Toxic Substances Control Act


                                                   Section 10

      Conduct research as         Principally directed at the assessment and the
      necessary for purposes      methodologies for determining fate and effects
      of  the Act.  Shall          for classes of chemicals.  Ground water may be
      establish research          a small portion of work to date.
      programs  to develop
      monitoring techniques.

                                                TABLE 5 (Continued)

                                              RESEARCH AND DEVELOPMENT

                                           Toxic Substances Control Act
                                           STATUS OF IMPLEMENTATION
   Shall  promulgate rules
   for  chemical manufac-
   turers and processors to
   keep records and submit
   such reports as may be
    Shall compile,  maintain
    and publish an inventory
    of  chemicals manufac-
    tured or processed in
<   Manufacturers, proces-
 i   sors, distributors shall
    maintain records of all
    significant adverse
    reactions to health or
    the environment from
    chemical substance or
    mixture.  Shall allow
    inspection of records by
    Shall rule require manu-
    facturers, processors,
    or distributors of a
    chemical to submit un-
    published health and
    safety studies for
    listed chemicals.
                                              TSCA Section 8  (a)
                                Proposed rule.
Mechanism available to
other programs for data
gathering needs.
                                               TSCA Section 8(b)

                                Inventory on computer file.  Non-confidential
                                data available for information needs.  Confi-
                                dential data available with proper clearance.
                                               TSCA Section 8(c)
Each office needing data
should have at least one
person cleared for confi-
dential business informa-
                                               TSCA Section 8(d)
                                Proposed rule.

                                           TABLE  5  (continued)

                                         RESEARCH AND DEVELOPMENT

                            Federal Insecticide, Fungicide and Rodenticide Act
                                           STATUS OF IMPLEMENTATION
Ground-water Research
Center for long term
ground water research.
Energy transport and
fate for ground-water
and energy monitoring
for ground water
(development of methods
and evaluating systems),
                                         Anticipatory Research Program
                                               (Interd isc iplinary)

                                Established this year.  See R&D Strategy,
                                        Energy Research Program

             TABLE 6


              Clean Water Act

                                                                                          POTENTIAL ACTION
(2) (a)  Promulgate... regulations
designating as hazardous substances...
elements and compounds which, when
discharged in any quantity into or upon
the navigable waters...present an
imminent and substantial danger to
public health or welfare...

(2)(B)(ii)  Owner or  operator of...a
vessel...or a facility discharging a
hazardous substance determined not
removable...shall be  liable...for a
civil  penalty per discharge...based on
toxicity, degradability and  dispersal

(2)(B)(v)   In addition to a  penalty—
the Administrator may act to mitigate
the damage  to the public health or
welfare  caused by such discharge.   The
cost	shall be  deemed a cost incurred
under  subsection (c)...for the removal
of such  substance by  the U.S. Government.

 (c)(2)...the President shall prepare  and
publish  a National  Contingency Plan for
removal  of  oil and  hazardous substances...
Plan...shall provide  for efficient
coordinated, effective action to  minimize
damage from oil  and hazardous substance
            Section 311

National Contingency Plan published 2/10/75.
Emergency Response Teams set up in all regions.
Oil spills responsibilities shared with Coast
Guard.  List of 271 substances published, but
court ordered injunction in 1978.  Therefore
reporting not required, and costs not recovered
for clean-up of these until 8/29/79 when new
regulations were published.

                                                       TABLE 6 (cont'd)

                                                       EMERGENCY POWERS

                                                       Clean Water Act
 (f)(2)  Owner or operator of discharging
 facility is liable to the U.S. for actual
 costs  incurred for removal of oil or
 hazardous substances, nte $50,000,000,
 except where willful negligence or
 misconduct is shown.  Then...full cost...
Provide assistance in emergencies caused
by release of any pollutant including but
not limited to, those which present, or
may reasonably be anticipated to present
imminent and substantial danger to the
public health or welfare.  There is
established a contingency fund...
Emergency assistance
prevent, limit or mitigate the emergency,
which assistance would not otherwise be
provided on a timely basis, and there is
an immediate significant risk to health or
welfare and the environment.  (note:  Not
limited to water}
            Section 504

Mo funds have been appropriated.   No
mechanism for cost recovery.
Superfund will

                                              TABLE 6  (cont'd)

                                             EMERGENCY POWERS

                                            Safe Drinking Water Act


                                                     Section 1442 (a) (2) (B)

Provide technical assistance and make        Not funded.  No cost recovery provisions.
grants to States or publicly-owned
water systems to assist in responding
to and alleviating any emergency
situation affecting public water
systems, which Administrator determines
to present substantial danger to the
public health.  Grants are limited to:
actions necessary for preventing,
limiting or mitigating danger to public
health in emergency, and would not be
taken without emergency assistance...

                                                            Section  1431

Upon receipt of information that a           No funding.   (Used only one time)
contaminant in, or likely to enter, a
public water supply may present an
imminent and substantial endangerment
to health, and that State/local
authorities have not acted to protect
health, the Administrator may take
such actions as he deems necessary to
protect health.  Action he may take,
but is not limited to, includes
issuing orders and commencing civil
action, including restraining order or


                                                 TABLE 6  tcont'd)

                                                  EMERGENCY POWERS

                                          Resource Conservation and Recovery Act


                                                            Section 7003

Upon receipt of evidence that handling,      No cost recovery clause.  Program does not
storage, treatment,  transportation or        take direct, clean-up action, but provides
disposal of any...waste presents an          information and technical assistance.
immediate and substantial endangerment
to health or the environment, the
Administrator may bring
restrain any person,,,or take such
other action as may  be necessary.
Administrator shall  provide notice to
the affected State.

                                                            Section 3003

Requirement in regulations for reports       Not yet promulgated.
and clean-up of spills during


                                                TABLE 6 (cont'd)

                                               EMERGENCY POWERS

                                     Federal Insecticide,  Fungicide and Rodenticide Act
Any pesticide previously approved which
appears to cause unreasonable adverse
effects may have approval revoked
through processes of suspension and/or
cancellation, with administrative appeal
opportunities through adjudicatory

Suspension is an interim remedy invoked
in cases where continued use during such
hearings would pose an imminent hazard.
It is valid only until the cancellation
decision is made.  The Administrator
may also use Section 6 mechanism to
restrict the use of a pesticide to
certain trained and certified operators.
               Section 6(c)

Several major pesticides found ubiquitously
in the environment have had most uses
cancelled because of risks posed to health
or environment which Administrator deemed
to exceed their benefits.

Recently a manufacturer voluntarily modified
terms of registration to cancel use of aldicarb
on potatoes in Long Island after serious
ground water contamination was detected.
Suspension of DBCP was predicated in part on
its presence in well water.

                                                   TABLE  6  (cont'd)

                                                    EMERGENCY POWERS

                                                Toxic Substances Control Act
The Administrator may commence a civil
action in an appropriate district
court... for seizure of an imminently
hazardous chemical substance...and/or
for relief...against any person who
manufactures, processes, distributes
in commerce, or uses, or disposes of,
an imminent hazardous chemical
                                                            Section 7
Never used.  No cost recovery provisions.

                                                 TABLE 6 (cont'd)

                                                EMERGENCY POWERS

                                                  Clean Air Act


                                                       Section 303

...the Administrator upon receipt of evidence     Used several times in emergency
that a pollution source or combination of         episodes.  No cost recovery pro-
sources... is presenting an imminent and           visions.
substantial endangerment to the health of
persons, and that appropriate State or
local authorities have not acted to abate
such sources...may bring suit in the
appropriate U.S. district
immediately restrain any person causing
or contributing to the alleged pollution...
or take such other action as may be
necessary.  If not practicable to...
commence civil action, the Administrator
may issue such orders as may be necessary
to protect health...

                                                 TABLE 6 (cont'd)

                                                EMERGENCY POWERS



                                                  Several different bills, one
                                                  freestanding, one amending
                                                  only  Section 504 of Clean
                                                        Water Act, several amending
                                                  RCRA, or RCRA and CWA

Different with different bills.  Objective     Currently under consideration by one
of all is to protect air, surface water        Congress.
and ground water as a resource, in addition
to the usual protection of human health
and the environment.  The fund would pay
for abatement of pollution from the source,
whether active or abandoned.  Several bills
would allow remedial action, such as cleanup
of ground water.  The cost recovery provisions
are mostly the suits brought against
responsible parties.


     This section contains a brief synopsis of those Federal
laws which impact ground waters and an analysis of how those
laws might be used to implement a ground-water protection
strategy.  These analyses do not reflect a current policy
choice by EPA or a legal interpretation of the law, but are
intended only to provide Workshop participants with a picture
of those laws which are currently in effect and how they
could be used to give further protections to ground waters,
if the strategy called for such action.  Currently ground-
water protection functions are assigned to Federal agencies
other than EPA.  We have, therefore, included all Federal
legislation in this analysis.

                                                    U.  S.  Department  of  Agriculture (USDA)
                                               Coverage  of  the  Act
                                                  Potential Future Role in Ground
                                                 	Water Strategy	
 Federal Assistance, Resources
 Conservation and Development
 Projects 7 U.S.C.   1010-1013
§1010.  Land conservation and land utili-
zation—a program of land conservation and
land utilization to correct maladjustments
in land use, and assist in controlling
soil erosion, reforestation, preserving
natural resources, protecting fish and
wildlife, developing and protecting
recreational facilities, mitigating
floods, preventing impairment of dams
and reservoirs, conserving surface
and subsurface moisture, protecting
the watersheds of navigable streams,
and protecting the public lands,
health, safety, and welfare, but not to
build industrial parks or establish
private industrial or commercial enter-
prises .

SlOlOa.  Secretary of Agriculture is
directed to carry out a land inventory
and monitoring program to include,
but not be related to, studies and
surveys of erosion and sediment damages,
flood plain identification and
utilization, land use changes and
trends, and degradation of the
environment resulting from improper
use of soil, water, and related
resources and issue a land inventory
every 20 years.
Secretary authorized and directed to
develop land utilization program—
to assist in conserving surface and
subsurface moisture, protect water-
sheds; health.
                                                                                            Includes study of degradation of
                                                                                            environment resulting from improper
                                                                                            use of soil, water,  and related

                                                     U.  S. Department of Agriculture  (USDA)
                                           Agricultural  Stabilization and Conservation Service  (ASCS)
     Coverage of  the Act
 Potential Future Role  in Ground
	Water  Strategy	
   Water Bank Act 16 U.S.C. 1301-1311
   Fish 6 Wildlife Conservation
   at Small Watershed Projects
   16 U.S.C.  1001-1009
Secretary of Agriculture is authorized
and directed to formulate and carry out
a continuous program to prevent the
serious loss of wetlands, and to pre-
serve, restore, and improve such lands.
Secretary has authority to enter into
agreements with landowners and operators
in important migratory waterfowl
nesting and breeding areas for the
conservation of water on specified farm,
ranch, or other wetlands identified in
a conservation plan developed in coopera-
tion with Soil and Water Conservation

          U. S. Department of Agriculture  (USDA)
             Soil Conservation Service  (SCS)

Erosion, floodwater, and sediment damages  in
the watersheds of the rivers and streams of
the United States, causing loss of life and
damage to property, constitute a menace to
the national welfare.  Cooperate with States
and their political subdivisions, soil or
water conservation districts, flood pre-
vention or control districts, and other local
public agencies to prevent damage and to further
conservation, developing utilization and
disposal of water, and the conservation and
utilization of land.
 Preserve,  restore,  improve and
 prevent loss of wetlands and  thereby
 conserve surface waters  .  .  . con-
 tribute to improved water quality
 .  .  .  contribute to improved
 subsurface moisture .  .  . promote
 comprehensive and total water
 management planning.

 Agreements with land owners and
 operators  for conservation of
 water  on specified  farm, ranch,
 or other wetlands identified  in
 a conservation plan could affect
 ground water.
 Further conservation development,
 utilization and disposal of water.

                                                     V, S. Department of Agriculture 'USPA)
                                                        Soil, Conservation Service (SCS)
     Coverage of the Act
                                                                                             Potential Future Role in Ground
                                                                                             	Hater Strategy	
   Resource Conservation & Development
   Program  7 U.S.C. 1010 et seq.
   Soil £ Water Resources
   Conservation Act of 1917
   16 U.S.C. 2001 et seq.
   Watershed Protection (.
   Flood Prevention Act
   16 U.S.C. 1001 et seq.
The Resource Conservation and Development
Program was initiated in 1964 to encourage
conservation and wise utilization of natural
resources in rural areas.
The Act directs the Secretary of
Agriculture to conduct periodic appraisals
of soil and water conservation programs
to ensure that they are responsive to
the long-term needs of the Nation.

Section 6(a)(5) of the Act directs that an
analysis be done of the feasibility and
desirability of recycling agricultural,
municipal and industrial organic waste
materials for use as fertilizer.

The Act provides for the prevention of
erosion, floodwater, and sediment damages
in the watersheds of the rivers and streams
of the United States.  The Soil Conservation
Service (SCS) administers the Act by
providing technical and financial assistance
to local organizations for planning and
installing measures to prevent damage to
Encourage conservation and wise
utilization of natural resources
in rural areas.

Land treatment—impacts subsurface-
but positively in terms of quality
and conservation.

Assess overall effects of SCS
programs on ... vater quality,
water conservation.
Technical and financial assistance
to local organizations for planning
and installing measures to prevent
damage to watershed.

                                                   U.  S.  Department of Agriculture (USDA)
                                              Coverage of the Act
                                                   Potential  Future  Role  in Ground
                                                  	Water  Strategy	
 Agricultural Credit for Pollution
 Control 7 U.S.C. 1921-1926,  1932
 Loans  may be made  or  insured  under
 this subchapter for  (1)  acquiring,  or
 enlarging, or improving  farms,  including
 land and water development, use and
 conservation,  (2)  recreational  uses and

 51924.   Soil and water conservation,
 recreational facilities  and uses, and rural
 enterprise loans to farmers for the purposes
 of land  and  water  development use and

 §1926. Water and waste facility loans
 and grants.
Criteria;  definitions, limitation on
allowable  users of Federal funds; inclusion
of interest or other income in  gross income
on sale of insured loan.
 Loans made or  insured for land and
 water development, use, and conser-
                                                                                           Water and  waste  facility  loans and
National Forest Management Act
16 O.S.C. 1604(g)(3)(E)(iii)
Provides loans for private business enter-
prises and pollution abatement and control
projects; loan guarantees.

         U.S. Department of Agriculture  (USDA)
          United States Forest Service (USFS)

This section provides for the protection of
water resources in the development of forest
management plants.
Strong potential role—but limited to
areas within jurisdiction of U.S.
Forest Service.  In being responsible
for the entire management of Forest
Service lands under the NFMA, the
Forest Service has great latitude
in protecting ground water.

           U.S. Department of Commerce (DOC)

     Coverage of the Act
 Potential  Future  Role  in  Ground
	Water Strategy	
  Public Works & Development Act
  42 U.S.C. 3131-3133; 3135-3136
M Coastal  Zone Management  Act  of  1972
7 16 U.S.C.  1451  et  seq.
Direct and supplementary grants for
acquisition or development of facilities;
required findings precedent to making of
direct grants; supplementary grants to
provide matching share funds; sewer and
other waste disposal facilities;
certification by Administrator of the
Environmental Protection Agency regarding
adequate treatment prior to discharge into

           U. S. Department of Commerce  (DOC)
      Office of Coastal Zone Management  (OCZM)

This provides for financial and technical
assistance and Federal guidance to the States
and territories to conserve and manage
coastal resources.  The Office of Coastal
Zone Management (OCZM) was created in 1973 to
implement the provisions of this Act.
 The Congress  is  presently  con-
 sidering expanded  economic
 development and  public  assistance
 (result and impacts of  population
 growth and  public  works and
 development facilities  on  water
 quality, uses, development and
 Approved State Coastal Zone
 Management programs are a strong
 mechanism for controlling Federal
 actions within an affected State
 coast zone.  This would include
 ground-water quantity or quality
 if it were included within an
 approved Coastal Zone Management
 plan.  The specific procedure is a
 "Federal consistency determination"
 required by S307.

 Potential for ground water to be
 included specifically in tho scope
 of the Act.  Title I of MPRSA has
 some limited potential impact on
 ground-water quality which may result
 in the pollution of the marine

                                                       0.  S.  Department of  Commerce (DOC)
                                                     Office of Coastal Zone Management (QC2M)
                                                Coveraae of the Act
                                                  Potential Future Role in Ground
                                                        Hater Strateov
   Marine Protection,  Research,  6
   Sanctuaries Act
   33  U.S.C.  1401  et seq.
  Appalachian  Regional  Development
  Act Amendments  of  1975
  40 App.  U.S.C.  1-2, 203,
  205-206,  2.12
The Ocean Dumping Act establishes a permit
system for the regulation of ocean dumping
of materials that could degrade the marine
environment.  The Corps of Engineers
has responsibility under Title I for the
regulation of the dumping of dredged spoil,
through the issuance of permits in
accordance with criteria and test pro-
cedures developed cooperatively with EPA.

Title II of the Act deals with research
into the effects of pollution in the
marine environment.

        U.S. Department of Defense (DOD)
        Army Corps of Engineers (ACOE)

The Secretary of the Army is to prepare
a comprehensive plan for the development
and efficient use of the water and
related resources of the Appalachian
region and to recommend measures for
the control of floods, the
regulation of rivers to enhance their
value as sources of water supply for
industrial and municipal development,
the generation of hydroelectric power,
the prevention of water pollution by drainage
from mines, the development and enhancement
of the recreational potentials of the region,
the improvement of rivers for navigation
where this would further industrial
development at less cost than would the
improvement of other modes of
transportation, the conservation, and
efficient utilization of the land resource,
and such other measures as may be found
necessary to achieve the objectives of this
Could have major potential.   Might
    for example, help to identify
sole source or principle aquifers.
Also a potential vehicle to  inform
public of importance of ground
water in "water rich" .Northeast.

                                                       U,  S, Department of  Defense  (DQD)
                                                       Army Corps of  Engineers  (ACOE)
     Coverage of the Act
                                                                                            Potential Future Role in Ground
                                                                                            	Water Strategy	
  Marine Protection, Research  and
  Sanctuaries Act
  33 U.S.C.  1401 et seq.
  Clean Water Act
  33 U.S.C.  1344
  River  & Harbor Act of  1899
< 33  U.S.C.  401, 403
The Corps of Engineers has responsibility
under Title I for the regulation of the
dumping of dredged spoil, through the
issuance of permits in accordance with,
criteria and test procedures developed
cooperatively with EPA.

Section 404 authorizes the Secretary of
the Army to issue permits for the discharge
of dredge or fill material into the
waters of the United States at specified
disposal sites.

Section 9 of the River and Harbor Act prohibits
the construction of any dam or dike without
Congressional consent and approval of the
plans by the Chief of Engineers and the
Secretary of the Army.  VThere the
navigable portions of the waterbody lie
wholly within the limits of a single State,
the structure may be built under authority
Of the legislation of that State, if the
location and plans are approved by the
Chief of Engineers and the Secretary of
the Army,  The instrument of authorization
is a permit.

A Department of the Army permit is required for
the discharge of dredged or fill material into
waters of the United States associated with
bridges and causeways pursuant to Section 404
of the Clean Water Act.  Section 10 prohibits
the unauthorized obstruction or alteration of
any navigable water of the United States.
The construction of. any structure in or over
a.ny navigable water of the United States, the
excavation form or depositing.
404 potential very significant.
Wetlands effects as recharge areas.
Impacts usually deal with recharge
areas and reservoir and loss of
natural recharge areas.

                                                       U.  S.  Department of Energy (DOE)
                                                Coverage of the Act
                                                   Potential  Future Role in Ground
                                                  	Hater Strategy	
   Nonnuclear Energy Research and
   Development Act
   42 U.S.C.   5901 et seq.
  Geothermal  loan Guaranty Program
  under Title II of the Geothermal
  Enerqy R&D Act of 1974
 A report by the Department  of  Energy  on
 compliance  with Section  13  of  the
 Nonnuclear  Energy  Research  and  Development
 Act  of  1974 indicates  that  this section
 provides for a  cooperative  program between
 the  Department  of  Energy {DOE)  and the Water
 Resources Council  (WRC)  to  examine the impacts
 on water resources of  emerging  energy

 Implementation  has concentrated primarily on
 the  preparation of basinwide assessments
 of water, resources availability and the
 impacts  of  energy  development on the
 environmental,  social, and  economic
 resources of  the region.

 There is a  growing need  for implementation
of the provisions  for  site-specific studies
of 'the impacts  of  demonstration and com-
mercialization  projects.  The»DOE is
required to request site-specific assess-
ments for demonstrating  plants  having
 "significant effects,' and  for  com-
mercialization  projects.

The program provides Federal loan
guarantees for  the acquisition  of
geothermal resources and development,
construction, and  operation of  geo--
thermal  facilities
Portion of the R&D funding pro-
vided under this act would be
devoted to assessing- the ground
water impacts of managing energy
technologies.  Some work is
already going on in this area.
Geothermal energy has the potential
for causing major ground water

                                             U. S.  Department of  the  Interior  (DOT-)
                                               Bureau of land Management  (BLM)
                                             Coverage of  the Act
                                                  Potential Future Role in Ground
                                                 	Hater Strategy	
Federal Land Policy and
Management Act of 1976
P.L. 94-579  (90 Stat.
Outer Continental Shelf Lands
Act  43 U.S.C. 1334 and 1346
Establish public land policies and
establish guidelines for their
administration; to provide for the manage-
ment, protection, development, and enhance-
ment of the lands and its resources.
Selected sections of the Federal Land Policy
and Management Act (FLPMA) provide for
the designation and protection of areas of
critical environmental concern (ACECs) in
the preparation of land-use plans for
public lands, and for compliance with
applicable State and Federal pollution
control laws.

Provides for conservation of marine life,
recreational potential, aesthetic values,
as well as reserves of' gas and oil on the
This land use planning could be
directed to include protection of
ground water; i.e., those recharge
areas could have restricted activi-
OCS oil/gas and sulpher operations
result in development of coastal
infrastructure, and almost invariably,
secondary economic development.  This
development changes land configura-
tions, which may decrease the rate
of ground water recharging, owing to
increased runoff.  Increased growth
may at the same time put increased
demand on ground water.  The
diminished water in the aquifer can
result in salt water intrusion of
ground water along the coastal zone.

Disposal of toxic drilling and well-
treatment fluids on land without
proper containment may result in
contamination of ground water by
leaching of organic chemicals, heavy
metals and hydrocarbons.

                                                    U. S, Department of the Interior (DOT)
                                                   Water and Power Resource Service (WPRS)
                                               Coverage of the Act
                                                  Potential Future Role in Ground
                                                  	Hater Strategy	
  Flood Control Act of 1960
  74 Stat.  472 (not codified)

  The Reclamation Act 32  Stat.
  388;  43 U.S.C.  91
 Colorado River Basin Salinitv
 43 U.S.C. 1571-1599
Study means  of  recharging and replenishing
Edwards Underground Reservoir.

This Act provides authority for the Water and
Power Resource  Administration for the
examination  and survey for construction and
maintenance  of  irrigation works for the
storage, diversion, and development of
waters for the  reclamation of arid and semi-
arid lands in the Western states.

Subsequent authorizations, under individual
pieces of legislation, have been made for
specific projects or groups of, projects.
These include,  for example, poulder
Canyon Project  Act, Colorado River Storage
Project of 1956, Spokane Valley Project,
and Colorado River Basin Project^ Central
Arizona Project,

         0. S.  Department of the Interior (DOI)
            Bureau of Reclamation (BuRec)

Provides for various water quality improve-
ments, canal or canal lining and salinity
control programs, research and other
programs downstream and upstream from the
Imperial Dam,
Water service contracts of WPRS
can be used to ensure irrigators
follow best management practices
designed to protect ground-water
quality.  WPRS requires conservancy
district to use BMP as condition
to receipt of project water.

There have been many court cases to
determine the "rights of the United
States."  Generally, the U.S. as
the owner of an irrigation project
may retain control over and re-use
seepage waters from the project.

                                              U. S, department of the Interior  (DOI)
                                                     Fish and Wildlife Service
     Coverage of the Act
 Potential Future Role  in  Ground
	Water Strategy	
Endangered Species Act
16 O.S.C. 1251 et seq.
Fish s Wildlife Coordination
Act  16 U.S.C. 661-667c
Wild  6 Scenic  Rivers Act
16 O.S.C.  1271 et  seq.
The Act established a Federal-State effort
to identify, protect, and recover animals
and plants which are in danger of extinction.
A significant proportion of the ecosystems
which the Act seeks to conserve includes
or is affected by aquatic, wetland, or
marine areas.

The FWCA ensures that the conservation and
enhancement of fish and wildlife resources'
are considered equally with all other aspects
of water resources development projects.

The FWCA requires Federal agencies which
propose or are authorized to undertake
water resource development project's to
consult with State and Federal wildlife
agencies for the purpose of mitigating
and compensating for project-occasioned
losses to wildlife resources.

     U. S. Department of the Interior  (DOI)
   Heritage Conservation and Recreation Service

The Act established the policy that certain
rivers which, with their immediate environ-
ments, possess outstanding scenic,
recreational, geologic, fish and wildlife,
historic, cultural, or other similar values,
will be preserved and protected.
 Limited to specific  geographic
 areas of habitat—but  strong  pro-
 tection against Federal  actions which
 could impact ground  water  if  it is
 critical to the maintenance of
 endangered species.
 Potentially significant role in
 ground-water protection—but limited
 to weak "coordination" requirements
 which are not enforceable.
 Limited potential role—any real pro-
 tection authority would be borrowed
 from CWA's nondegradation protection
 for "outstanding national resource
 waters of CWA's101(a) and 40 CFR
 35.155(e)."  A determination of "no
 direct and adverse effect" must be
 provided bv the Secretary of
 Aqriculture or Interior for any
 Federal action affecting water
 resources of a study category or
 designated river under Section 7(a),
 7(b) Of WSRA.

                                                     U, S. Department of the Interior  (DOT)
                                                  Heritage Conservation and Recreation,Service
                                                Coverage of the Act
                                                  Potential Future Role in Ground
                                                  	Water Strategy	
   Land  and Hater Conservation Fund
   16 U.S.C.  4601-4  through  4601-11
Assists  in preserving, developing, and
assuring accessibility to the quality
and quantity of outdoor recreational
Acquisition contributes to
preservation for recharge, and
restricted use which may protect
water quality from degradation.
                                                     U. S. Department of the Interior  (DOI)
                                                National Park Service and Office of Surface Mining
   National Park System Minimi Activity
   Regulation  P.L. 94-429  (90 Stat.
Regulates mining activity within areas of the
National Park System to prevent or minimize
damage to the environment and other resource
                                                   U.S. Department of the Interior  (DOI)
                                                      Office of Surface Mining
   Surface Mining Control and
   Reclamation Act
   30 U.S.C. 1201 et seq.
SMCRA has high potential future
role in ground water strategy in
limited areas.

Control of surface activities,
such as erosion control, has high
potential impact on ground
water by affecting runoff to
recharging ratios.  Surface coal
mining may directly impact ground
water by hitting water tables,
or lowering them for mining needs.
                                                  Abandoned mine land reclamation
                                                  will reduce the number of acid
                                                  mine drainage incidents and other
                                                  toxic material leaching problems.
                                                  There is high potential for EPA
                                                  coordinating with OSM on ground-
                                                  water quality issues.

                                                 U.  S.  Department  of  the  Interior  (DOI)
                                                     Office  of  Surface Mining
                                                 Coverage of  the Act
                                                  Potential Future Role in Ground
                                                 	Water Strategy	
   Appalachian Regional Development
   Act of  1975   40 App. U.S.C.  205
   Water Resources Research  Act
   42 U.S.C. 1961-1961C-8
M  Saline Water Conservation Water
,L  Act of 1971
*•  42 U.S.C.  1959-1959h
   Act  of  March  3,  1879
   43 U.S.C.  31  (and  subsequent
Makes financial contributions to States
in the region to seal and fill voids in
abandoned coal mines and abandoned oil
and gas wells, and to reclaim and
rehabilitate lands affected by the strip
and surface mining and processing of coal
and other minerals.

Conducts research, investigations,
experiments and the training of
scientists in the fields of water and
of resources which affect water.

Supports research and studies of development
of processes and equipment for converting
saline water, engineering and technical
work for development of desalting processes
and plant design concepts for scaled
demonstrations, methods for recovery and
marketing of by-products as offsets
against treatment costs; reduction of
impact on environment from discharge of
brine into water and economic studies and
surveys on wa,ter production costs; information
concerning relation of desalting to other
aspects of comprehensive water resource

   U.S. Department of the Interior  (DOI)
        U.S. Geological Survey

Establishes functions of the Geological
Purvey.and designates USGS as the lead agency
for coordinating the activities of all Federal
agencies in the acquisition of certain water
data from streams, lakes, reservoirs,
estuaries and ground water,  USGS also provides
for cooperative  (joint) fundina of aeolooical
survev scientific and technical investigations
with State and local Governmental aaencies.
Control and abatement of mine
drainage pollution on abandoned
and active mine sites improves
quality of water recharging
Contributes to needed manpower
supply and knowledge development
for groundrwater protection.
Provides data base on amount,
quality, location, movement,
and changes in U.S. water supply
for decisionmaking regarding
protection and enhancement of
ground-water quality.

Housing and Urban Development (HUD)

Coverage of the Act
 Potential Future Role in Ground
	Water Strategy	
  Housing and Community Development
  Act of 1974
Establishes a grant program to undertake
a broad range of community development
activities including the Community
Development Block Grant 'Program and the
Economic Development Administration
 National Housing Act
 Pub.  I,.  479, 48 Stat. 1246.
 12  O.S.C. 1701 et sea.
To ensure adequate and safe housinq
for the Nation's peculation.
 Federal grants, loans,  guarantees
 and other financial assistance
 programs support projects which
 directly impact the environment.
 EDA funds physical on land facilities
 which impact solid waste, water and
 air pollution.   These projects
 are subject to environmental controls
 when the nature of the  activity
 constitutes a major Federal action
 requiring an environmental impact
 statement under NEPA or the
 activity must meet specific site,
 size, or pollution criteria or

 The individual  Federal  actions may
 be dimensionally small  (in size, money
 or resources) but are pervasive and
 potentially significant when con-
 sidered in the  aggregate on a
 regional basis.  In terms of finan-
 cial resources, the aggregate Federal
 investment exceeds EPA's construction
 grants program.

 As with other Federal community
 and economic development pronrams
 projects receiving Federal
 financial assistance are pervasive
 in their geographical distribution
 and should be considered in any
 national ground-water protection

                                                  Nuclear Regulatory Commission
     Coverage of the Act
 Potential Future Role in Ground
	Water Strategy	
Energy Organization Act of 1974
The Uranium Mill Tailings Radiation
Control Act of 1978
Atomic Energy Development and Control
Water Resources Planning Act
42 U.S.C. 1962 et seq.
Regulates the development of nuclear power

Mandates the EPA to establish minimum radiation
standards for uranium mill tailings and the
Nuclear Regulatory Commission (NRC) to imple-
ment and enforce the standards

Regulates development, use, and control of
atomic energy including the regulation of the
disposal into the ocean or sea of by-product,
source, or special nuclear waste materials
as defined in regulations or orders of the

          Water Resources Council

Provides for the optimum development of the
Na.t±on*s natural resources through the
coordinated planning of water and related
land resources, through the establishment
of a water resource council and river basin
commissions, and by providing financial
Assistance to the States in order to increase
State participation Jn such planning
 direct impact
 direct impact
 Stimulates increased agency
 effort in the planning and protection
 of ground-water resources in
 Federal programs.  The Council's
 Principles and Standards for
 Planning Water and Related
 Land Resources set forth general
 water planning stipulations that
 increase emphasis on ground water
 in agency planning.

 The Manual of Procedures now
 being developed by the Water
 Resources Council aids imple-
 mentation of the Principles and
 Standards and transmits
 around water planninq measures to
 Federal agencies.

                                                   All  Federal Agencies
                                              Coverage  of  the Act
                                                                                          Potential Future Role in Ground
                                                                                          	Water Strategy	
National Environmental  Policy Act
42  U.S.C. 4321 et  seq.
Clean Mater Act
Section 101
Clean Water Act
Section 102

Clean Water Act
Section 104(a)(5)
                                         The National  Environmental  Policy Act of
                                         1969 (NEPA) mandates  the  preparation of an
                                         environmental impact  statement  for major
                                         Federal actions  significantly affecting the
                                         quality of  the human  environment.  As water
                                         construction  projects as  well as other
                                         Federal activities  commonly have an impact
                                         on  the  ground-water resource, an environ-
                                         mental  impact statement is  one  of the tools
                                         that should be used by Federal  agencies in
                                         the planning  process  as it  relates to the
                                         ground-water  resource.  Agencies subject
                                         to  Principals and Standards generally are
                                         required to meet NEPA responsibilities
                                         in  conjunction with activities  according
                                         to  Agency Procedures.  A  Council on
                                         Environmental Quality Memorandum dated
                                         November 19,  1976,  provides  guidance and
                                         Instructions  to Federal agencies for
                                         evaluation of the impact  oC  federally
                                         assisted projects on  ground-water supplies.
                                             Environmental Protection Agency  (EPA)
                                        Restoration, maintenance of chemical, physical
                                        biological integrity of Nation's waters;
                                        prohibition of discharge of toxics; development
                                        and implementation of areawide management
                                        planning process; prevention, reduction,
                                        elimination of pollutants

                                        Development of comprehensive program to
                                        eliminate pollution
                                        Establish oround-water surveillance oronram
                                        with States, political subdivisions and
                                        other Federal aqencies.
I/ See Appendix VI for more detailed analysis.

                                                Environmental, Protection Aerencv  (EPA)
     Coverage of the Act
 Potential Future Role  in Ground
	Water Strategy	
   Clean water Act
   Section 201
   Clean Water Act
   Section 202(a)(2)
   Clean Water Act
   Section  106
<  Clean Water Act
M  Section  208
08  Clean Water Act
   Section  209

   Clean Water Act  (State/EPA
   Aqreement Development)

   Clean water Act
   Section  303
    Clean Water Act
    Section 303(e)
    Clean Water Act
    Section 304(e)
    Clean Water Act
    Section 304m
Grants for construction of treatment works
to achieve pollution control goals of the

Grants for innovative or alternative projects
can be for 85% of cost of construction rather
than 75%

Grants to assist States in administering
programs for the prevention, reduction,
and elimination of pollution

Development and implementation of areawide
waste treatment management plans

Level B Basin Plan
Emphasis of linkages between programs covered
under CWA. RCRA and SDWA

Water quality standards to protect highest
possible uses for surface water bodies;
includes pollutant level allocations where

Planning process for surface water no State
may receive NPDES authority without this

Best management practices of ancillary
activities of point source discharges of
section 307(a) toxic pollutants and
section 311 hazardous  substances

Guidance on precautions of nonpoint source
water pollution

                                                  Environmental Protection Agency (EPA)
                                                  Coverage of the Act
                                                  Potential Future Role in Ground
                                                 	Water Strategy	
     Clean Water Act
     Section 311(j)
     Clean Water Act
     Section 311

     Clean Water Act
     Section 402(b)(1)(D)

     Clean Water Act'
     Section 404
     Clean Water Act
     Section 405

     Clean Water Act
     Federal Hater Policy Initiatives
     Clean Water Act (Regs.)
     Section 35.918-3

     Clean Water Act
     Section 35.925-2
Regulations to prevent spills of hazardous
substances into surface water from vessels
and onshore and offshore facilities

Cleanup and cost recovery of spills of
hazardous substances

Control well disposal
Regulatory.  Defines requirements for
standard setting, permitting, exempting
categories, state program delegation,
and enforcement

Guidelines on POTWs sludge disposal
Combining specific statutory require-
ments to achieve common or comple-
mentary environmental goals

          All Agencies

Issues surrounding ground water

     Environmental Protection Agency (EPA)

Requirements for discharge of effluents

The project must be consistent with any
applicable approval water quality
management plan

                                                  Environmental Protection Agency (EPA)
                                                  Coverage of the Act
                                                                                          Potential Future Role in Ground
                                                                                          	Water Strategy	
    Clean Water Act
    Section  35.927-1
    Clean  Water  Act
    Appendix  A

    Clean  Water  Act
    Appendix  E
Guidelines for
Preparing Facility
Plan {May 1975)
     Wastewater  Treatment Pond
     (Technical  Bulletin)

     Evaluation  of  Land  Applications
     System (Technical Bulletin)
Infiltration/inflow analysis to be
performed to show possible existence
of excessive I/I in the sewer system

Cost-effectiveness analysis guidelines
requires evaluation of the costs and
effects of flow reduction measures

Innovative and alternative technology
guidelines—identifying and evaluating
criteria.   Alternative includes aquifer
recharge.Innovative methods include those
that involve greater recycling and
conservation of water resources

Analysis of existing conditions
should assess impacts of the various
Alternatives; including no action, on
water quality (.incl. ground water)

Discusses protection of ground water
from pond seepage

Enviornmental assessment of this alternative
must assess impacts on ground water
     Federal  Insecticide,
     Fungicide  and  Rodenticide Act
     Sections 6(b)  and  6(c)
                                        Regulatory product licensing and use
                                         restriction.   Protects health and  the
                                         environment  by prohibiting the uses
                                         of pesticides shown  to ca,use unreasonable
                                         adverse effects.

     Environmental Protection Agency  (EPA)
          Office of Solid Waste

     Coverage of the Act
 Potential Future  Role  in  Ground
	Water  Strategy	
     Section 3004
     Section  4004
    Section  4005
    Section 1421
    Section 1422(a)

    Section 1424(a)

    Section 1424(e)

    Section 1431(a)
Protect health and environment by prescribing
minimum acceptable control technologies and
facility standards for treatment storage and
disposal of hazardous waste.

Health and environment, by prescribing those
practices in waste disposal which are
environmentally acceptable and prohibiting
all facilities to determine not to be in

Health and environment—State assessment,
by-requiring facilities' Administrator
to publish a list of all prohibited

Protection of underground drinking water
sources by Underground Injection Control
Program (UIC)

State/Federal procedures for program

Designation of Underground Sources of
Drinking Water and Permitting procedures

Protection of sole sources of drinking water
that are from the ground

Provides Administrator authority to take
control and actions when public water
systems are subject to contamination which
may present an imminent and substantial
endangerment £f State/locals have not taken
appropriate action

                APPENDIX VIII


     A tremendous diversity exists among the States
concerning types of laws and regulations addressing ground
water protection, levels of sophistication in ground-water
management, available funds and resources, for there is
diversity in the degree of States' reliance on ground water,
its availability and quality, and the uses of ground water.
In addition, organizational structures for managing ground
water differ from State to State.  These factors, along with
the lack of any existing State by State analyses of ground
water management, make it extremely difficult to present a
detailed and accurate picture of the status of State programs
without undertaking a substantial amount of original research
beyond the time frame of the Ground Water Strategy.

     The following information presents a general overview
of State ground-water laws and regulations with some specific
State examples.  Three aspects of State management are
addressed: ground-water quality laws, locational controls,
and ground-water allocation systems.


     State agencies involved in ground-water management
operate under various and diverse laws.  The most common
type is the broad environmental law governing pollution of
the "waters of the State."  Typically, waters of the State
are defined as "(a)11 streams, lakes, ponds, marshes, water-
courses, waterways, wells, springs, reservoirs, aquifers,
irrigation systems, drainage systems, and all other bodies
and accumulations of water, surface and underground, natural
and artificial, public or private, which are contained
within, flow through, or border upon, the State or any
portion thereof."  (e.g., Minnesota Environmental Protection
Law, Ch. 115).  The emphasis of these statutes  is largely
organizational; that is, they are designed  to set up
departments or agencies that in turn are charged with
preparing and enforcing regulations for management and
control.  A 1978 survey showed that approximately 60% of the
States rely on general laws as a  basis for  ground-water
protection.  Eleven states rely on  individual laws  (separate
pieces of specific legislation which deal with  particular
sources of pollution, usually activities, and aspects of

ground-water protection) for their ground-water protection
activities.  These statutes may be in addition to existing
environmental laws (e.g., North Carolina) or may be adequate
in themselves to provide the requisite protection (e.g.,
Washington, Idaho).  In seven States, general environmental
protection laws with specific reference to ground water are
used to effect ground-water protection.  As of this writing,
at least nine States have ground-water quality standards
(Virginia, South Carolina, Maryland, Utah, New Mexico,
New York, New Jersey, California, and Florida).

Control of Waste Disposal Sites

     Solid Waste Disposal - Prevention of ground-water
pollution is a major purpose of solid waste disposal
regulations. Control of waste disposal sites includes solid
waste disposal, individual wastewater systems, and deep well
disposal of wastes.  Most States have statutes that prohibit
disposal of solid waste without a permit from a State or
local agency.  The statutes typically authorize a State
agency to adopt regulations and leave it to that agency to
set requirements for the varying conditions that may exist.
In some cases the regulations classify sites according to
the types of waste that are acceptable (e.g., California).
Often the regulations contain special provisions for hazardous
waste disposal, usually by defining the category and
prohibiting disposal without specific agency approval.

     Individual Wastewater Disposal Systems (Septic Tanks) -
In contrast to solid waste disposal regulations, prevention
of ground-water pollution has not been a major purpose in
the regulation of individual wastewater systems, such as
septic tanks.  These regulations are primarily directed at
protecting the health of the septic tank user and his near
neighbors. Statutory authority for septic tank control is
usually contained in some basic authority of a State agency.
Their control is specified in regulations and administration
is primarily though local health officers with State super-
vision.  Typically regulations include a requirement that the
owner obtain a permit and additional requirements for soil
reports and percolation test, minimum lot size, maximum
slope,  design of system, etc.  Some States require that septic
tank installers and septic tank pumpers be registered (e.g.,
Ohio).   Some regulations are directed at maintenance and
sludge disposal.

     Deep Well Disposal - States have enacted  statutes  directed
at disposal of wastes in deep formations  where such  wastes
will be permanently isolated from contact with fresh water
resources and from human activity.   Some  States specifically
prohibit the practice.  Section 402(b) of the  Clean  Water
Act and Section 1421 of the Safe Drinking Water Act  have
given the States impetus to address  deep  well  disposal.
Generally States only allow deep well disposal if  there is
no other feasible method.

     The terms of State water pollution control laws general-
ly apply to pollution of surface and ground water  from oil
and gas operations.  Provisions in oil and gas laws  to
prevent water pollution compound those in water pollution
control laws providing, in effect, special requirements for
oil and gas regulatory activities.  For example, all but a
few States require installation of surface casing  to protect
all known aquifers penetrated by oil and  gas drilling
operations and that this "string" be cemented to the sur-
face.  Most States allow use of earthen pits or lagoons for
storage of brine produced in connection with oil or  gas;
however, a number of these States severely restrict  their
use.  Almost all States require that an applicant for a
permit to drill an oil and gas well file  a performance bond,
but most States do not provide funds for  the plugging of
wells where no responsible person can be  located.

Control of Well Construction and Operation

     Water Wells - Most States license water well drillers
and regulate installation and abandonment of water wells.
Regulations may have three functions —  1) a public health
function to assure wells provide a safe  drinking water
supply, 2) the consumer protection function of ensuring  an
efficient well, and 3) prevention of pollution of ground
water through entry of surface water or  polluted ground
water into aquifers containing better quality water.  Older
regulations tend to emphasize the public health function; a
number of recent regulations are clearly directed at
protection of ground-water resources. Typically, water well
statutes require that  a permit be obtained by  anyone who
drills or reopens  a well.  Regulations are often technically
detailed.                       '

Control of Land Spreading of Potential Pollutants

     Irrigation Using Waste Water - Spraying of wastewater
effluent on land as a disposal method is specifically regu-
lated in only a few States.  Most States treat such disposal
on a case-by-case basis related to water quality standardst
the same as any other discharge.  Maryland specifically
requires a discharge permit for wastewater effluents
disposed of by means of spray or other land irrigation
systems.  New York, Pennsylvania, Florida and Idaho
all address the question in varying degrees of detail.
California's Water Reclamation law applies broadly to any
use of treated wastewater, whether for land disposal,
injection for recharge, or otherwise.

     Land Disposal of Wastes - Regulatory provisions gov-
erning municipal wastewater treatment and disposal fre-
quently anticipate that sludge will be spread on the land.
In most States the basic provision of State law applicable
to land spreading of industrial wastes is the prohibition in
its water pollution control law against polluting State
waters.  A State with only this provision generally has the
burden of showing that pollution of surface or ground water
is resulting from the sludge disposal.  Pennsylvania has
changed this burden with its "potential pollution" statute
which allows the State, where storage, disposal, etc., of
materials create a danger of water pollution, or where
regulation is necessary to avoid pollution, to require by
rule that the activity be conducted under a permit or it may
make an order regulating the activity.  Various types of
special laws may apply to spreading of industrial sludges.
Massachusetts Hazardous Waste Regulations require site
approval.  New York applies its Industrial Waste Scavenger
Law and a number of States utilize their solid waste
disposal laws.
Control of Storage Areas

     Some laws affecting waste disposal refer to storage as
distinct from disposal, such as solid waste disposal laws,
animal feedlot regulations, deep well disposal regulations,
oil and gas drilling laws (surface pits to store oily wastes,
water, mud, and brine), and coal strip mine reclamation
laws. In most States collections of industrial waste are not

subject to any special regulations  but are  considered  simply
as sources of  pollution which may be  maintained  only under
an NPDES or State permit.   A State  with only  general
statutory provisions may find itself  in the position of
having to prove that ground-water pollution is occurring
as a result of a storage activity before it can  prohibit
or otherwise control the operation.  To overcome this  burden
States have expanded on their control authority  in various

Control of Mining and Quarrying

     State water pollution control  law provisions typically
apply to pollution discharges from  mining operations.   Some
States also have provisions specifically directed at  mining
which control water pollution as an incident  to mining
activity.  These statutes  often require a permit.  Surface
mining reclamation laws commonly contain provisions directed
at preventing water pollution as one of several objectives
of., carrying on strip mine  operations with minimal damage
to the environment.  Surface mining law and regulations
also contain provisions requiring certain practices in
handling coal, soil and wastes to prevent acid production.

Control of Transportation and Handling of Fluids

     Interstate pipelines are under the jurisdiction of the
Federal Department of Transportation.  Pipelines under State
jurisdiction may be controlled by  the public utilities
regulatory agency or under a specific  statute (Delaware
requires a permit for construction of  any pipeline facility.
The  possibility of ground-water pollution caused by leaky
sewers has been given little attention  in regulations.
Where a State agency has the authority  to approve sewer
construction it may as a matter of policy prohibit
construction of a sewer line within a  specified distance of
a well used for water supply.  Delaware has  an  unusual
requirement that one must obtain a permit  to construct any
sewer or pipeline which conveys  liquid waste.
     Various programs exist  for  coping with  spills.  These
have not been directed at ground-water protection  in  the
past.  Ground water, will not necessarily benefit from spill
response—for example,  if a  chemical  were  held  behind a
temporary embankment where  it  can  infiltrate into  the ground
rather than allowed  to drain into  a  river  and be diluted.


     Under the general heading of locational controls there
are several mechanisms which have been utilized to protect
ground water quality.  Principal among these is zoning.

     Zoning - zoning refers to the division of land into
districts in which certain uses are permitted, often as of
right but sometimes subject to conditions.  Zoning power is
founded on the power of government to regulate use without
compensation based on a showing that the restriction pro-
motes the public health, safety, morals or welfare of the
community,  it is generally exercised at the local level.
In recent years the courts have expanded these tests to cover
legitimate environmental concerns.  For example, in
Hackensack Meadowlands Comm. v. Municipal Landfill Authority,
68 N.J. 451 (1975), New Jersey Supreme Court upheld
a law prohibiting the disposal of waste collected
outside the State's territorial limi-ts.  One justification
for the law was the need to protect ecologically sensitive
areas from the increasing pressures for sanitary landfill
sites.  Another example is a Dade County, Florida zoning
ordinance limiting development to minimum five acre lots
over the Biscayne Aquifer.

     In addition to minimum lot size zoning, other zoning
techniques include zoning for protection of open space
(e.g., flood plain zoning), and subdivision controls and
performance-oriented zoning techniques (e.g., planned unit
development, matching land use with land capabilities,
effluent allocations).

     Zoning regulations may contribute to the protection of
ground water,  even when that is not their primary goal, for
example, by limiting the density of residential development
or by channeling industrial activities into specified areas.

     Designation of Environmentally Sensitive Areas - Zoning
is primarily a tool to accommodate development.  Critical
areas programs focus first on the environmental resource and
only secondarily on the type of development that can be
accommodated.   The function of regulation in these areas is
primarily to preserve an ecologically valuable resource,

such as a wetland or an aquifer recharge zone.   Control of
development has also served water quality objectives.   Also/
critical areas programs often include a data collection and
inventory component that could include water quality
information.  Critical areas approaches are generally  State-
wide programs and can cover a larger area than  local zoning
authorities.  One example of a critical areas approach is
the North Carolina law which provides for designation  of
"capacity use areas" to protect ground-water quantity  and
to limit saline intrusion.  In New Jersey, the  Central Pine
Barrens have been designated a critical area for sewerage
purposes to limit development in that area.

     Because of the obvious relationship between ground-water
depletion and ground-water quality it is important to be
aware of the provisions of the various allocation doctrines.
The law governing ground-water use in the United States
generally follows one of the four doctrines discussed below.
Obviously there are variations on how these doctrines are
applied in different States.  The traditional legal
classifications of ground water often do not reflect a
modern understanding of hydrology.  Court decisions based
on these classifications add to the complexity of ground-
water management.

Absolute Ownership Rule

     Under the English or common law rule of absolute owner-
ship the right to use water is based solely on land owner-
ship.  A landowner is unrestricted in his use of underlying
ground water except that he cannot act maliciously or
negligently.  He is not liable if his use interferes with
that of another.  Under the rule of absolute ownership a
landowner may waste ground water, use it on lands not over-
lying the aquifer or sell the water.  This rule is
essentially the law of capture under which every landowner
has the right to pump as much ground water as he can without
regard to the rights of others.

     Texas, Louisiana, Arkansas, Missouri, Minnesota, Indiana,
Ohio, Pennsylvania, Vermont, Massachusetts, Connecticut,
Maine, Rhode Island, South Carolina, Georgia, Alabama,
Mississippi and, in part, California and New Jersey follow
the absolute ownership rule.

Reasonable Use (American) Rule

     Under the American rule of reasonable use the right to
use ground water is also based on land ownership.  It differs
from the absolute ownership regarding the amount of ground
water that can be used and where it can be used.  Under the
reasonable rule a landowner is entitled to the reasonable
(i.e., not wasteful) use of ground water.  Reasonableness
is based on the relationship between the ground water use
and the use of the land where the well is located.  Use on
distant lands is unreasonable per se.  The reasonable use
rule is followed in Arizona, Nebraska, Iowa, Illinois,
Michigan, Kentucky, Tennessee, Florida, North Carolina,
Virginia, Delaware, West Virginia, Maryland, New York, New
Hampshire, and Wisconsin.

Correlative Rights

     The correlative rights doctrine is basically a judi-
cial extension of the reasonable use rule to resolve ground
water disputes among landowners.  Under California law the
doctrine of correlative rights refers to the relationship
between overlying landowners and ground water appropriators.

Prior Appropriation

     In most western States the doctrine of prior appropria-
tion has been applied to ground water.  The right to use
ground water is based on obtaining a State permit which may
limit the amount of water withdrawn.  Conflicts among ground
water users are usually resolved on the basis of priority
(first in time is first in right).  States following the
prior appropriation doctrine include Washington, Oregon,
Idaho, Nevada, Montana, Wyoming, Utah, Colorado, New Mexico,
North Dakota, South Dakota, Kansas, Alaska, and in part,
California and New Jersey.

     The remainder of this paper presents descriptions of
several State ground-water quality standards programs as
examples of different State approaches.

                         NEW MEXICO

The Standards Program

     In New Mexico, ground-water standards are numbers that
represent the pH range and maximum concentrations of  ground-
water contaminants which still allow for the present  and
future use of ground-water resources.  New Mexico's ground-
water standards are incorporated into its "Regulations for
Discharges Onto or Below the Surface of the Ground."   The
regulations are designed to protect for present and future
use as domestic and agricultural water supply all ground
water of the State which has an existing concentration of
Total Disolved Solids (TDS) of 10,000 mg/1 or less.  In
addition, the Regulations are designed to protect those
segments of surface waters which are gaining because  of
ground-water inflow, for uses designated in the New Mexico
Water Quality standards.  The standards apply (with certain
exceptions) to all new discharges starting operations post
1977.  Older discharges are being brought under the
regulation one-by-one.

     The standards are administered by the central office of
the Environmental Improvement Division (BID) of the Health
and Environmental Department which enforces the standards
for most activities.  The Oil Conservation Division of the
Energy and Minerals Department (EMD) regulates oil and gas,
CO2 and geothermal activities; the Coal Surface Mining Bureau
of EMD regulates coal mining activities.  The respon-
sibilities of the various agencies are defined by statute
making the relationships between the agencies formal.  The
State EPA Agreement (SEA) is not used to coordinate
activities between the agencies.

     Degradation of the ground water is allowed up to the
limit of the ground-water quality standard.  If the existing
concentration of any contaminant exceeds the standard, due
to natural conditions, no degradation beyond the existing
concentration is allowed.  Contamination predating the
standards as a result of man's activities are not
specifically required to be improved; however, in the event
of an emergency or public nuisance action may be taken.


     New Mexico's ground-water quality standards do not
address depletion.  The depletion of ground water is the
responsibility of the State Engineer of the Water Resources

     Activities having potential for ground-water de-
gradation are required to perform self-monitoring.  Since
standards may not be exceeded at a point of future use,
monitoring is done at the present or future point of with-
drawal or the property boundary, whichever is closer to
the point of discharge.  Monitoring requirements such as
frequency and points of measurement are established on a
case-by-case basis.  Reporting requirements are developed in
conjunction with the monitoring plan.  Violations are
determined through the self monitoring and reporting
requirements and some independent surveillance performed by
the Environmental Improvement Division (BID).

     Enforcement begins by informal contact such as phone
calls, visits and letters to obtain voluntary compliance.
These contacts are "tracked" and a file is built in the
event formal enforcement is needed.  Formal enforcement has
not frequently been required; if necessary, the State's
Water Quality Act allows fines and imprisonment.

     The EID is in the process of establishing an automated
data management system based on the U.S. Geological Survey's
OMNIANA system.  Currently, information is filed and
retrieved manually.

     Total State resources allocated to ground-water
protection were not identified.  Two people perform areawide
monitoring but field follow-up on self monitoring requirements
appear to be less than one man-year per year.  Resources
expended on enforcement are also not specifically identified.
The Agency has access to lawyers within the Division including
two lawyers who work specifically on water (surface and
ground) pollution control problems.


     The EID feels that the standards have been successful
for the covered parameters.  The State determined that the
standards approach is more practical than effluent limi-
tations for ground-water protection because the impact of
any effluent discharge depends on the hydrologic-geologic
setting thereby making a uniform effluent limitation in-

     Virginia uses ground-water quality "criteria" and
ground-water quality "standards" as tools to manage ground
water. State Water Control Board (SWCB) "criteria" represent
guidelines to allowable concentrations of specific con-
stituents.  State "standards" are health based, allowable
concentrations of specific constituents that are not to be
exceeded under enforcement penalty.  Virginia's ground-water
quality standards have been in effect only since 1977.
Consequently, some significant policies relating to
implementation of the ground-water management program using
the quality criteria and standards are still evolving.  For
example, the point at which measurements are to be taken to
determine compliance with state criteria and standards for a
particular source of potential contamination has not yet
been determined.  Virginia's water quality criteria and
standards are not uniform statewide.  The allowable con-
centrations of constituents for which criteria exist and
four of the standards (pHr NHU-N, N02-N, NC^-N) vary depend-
ing upon which geological province tne ground water is
located within.  This was necessary to take account of the
natural water quality differences in the State's four
different geological provinces. The criteria and standards
are used as a tool to limit the degradation of ground-water
quality by specific known contaminants.


     In addition to application of the criteria and
standards, the State has a policy which specifies that the
discharge of contaminants (even those for which a standard
does not now exist) can not contravene present or future
uses of the ground water.

     In those areas where it is found that the ground water
quality does not meet the criteria and standards due to
natural conditions, it is State policy to prevent further
degradation; in those areas where it is found that the
ground-water quality does not meet the criteria and
standards due to man's activities, the state policy is to
attempt to restore the water quality to its natural
(pre-pollution) condition.  While State law refers to a
requirement for non-degradation, what is actually pursued
is a policy of reasonable degradation as it is perceived
that complete non-degradation is not possible if most of
man's presently routine activities are to be allowed to be

     Aquifer depletion and drawdown problems are addressed
by use of designated ground-water Management Areas, two of
which currently exist within the State.  Management Areas
can be established by the State Water Control Board acting
independently or by local petition to the Board.  Criteria
for establishing a Management Area include:  interference
between two or more wells, depletion or potential depletion
of a water supply and contamination or potential contamination
of ground water as a result of pumping practices.  Once a
Management Area has been established, major industrial uses
within the area are subject to control.  At this time,
agricultural withdrawals are not subject to regulation.

     Implementation of the ground-water management program
is achieved through both the Virginia Water Control Board
staff and the State Health Department.  Ongoing activities
with ground-water contamination potential such as land
fills, waste lagoons and land spreading of wastes are managed
by the State Health Department through a permit system.
The VWCB manages NPDES permits for point sources, non-dis-
charge waste lagoons and all non-active waste sites.

     New sites of potential contamination require the site
operator to monitor as a condition of obtaining a permit.
Existing sites are being required to monitor as state

resources permit.  Previously used sites, currently closed,
are not subject to monitoring requirements.  The State Water
Control Board also manages a monitoring network.

     All monitoring (including site monitoring by permit
holders) is linked to a data management computer having
sorting and analytical capability.

     Total State resources allocated to ground water pro-
tection activities are difficult to establish the State
Water Control Board, however, has a staff of 15 geologists
and technicians working in ground water within its central
office and the six regional offices.  Estimates of State
Department of Health resources devoted to ground-water
protection are not available at this time.

     In regard to the 14 routes of ground-water contamination
found to be significant nationally, Virginia's efforts
currently are directed primarily at controlling contamination
from landfills, waste lagoons, land spreading and NPDES point
sources.  Virginia is currently developing controls for
s urf ace impoundmen ts.

     Although the State Water Control Board has the authority
to take action against any source of contamination that
causes the ground water standards to be exceeded, credible
preventive programs for the major routes of potential con-
tamination (excluding the sources above) do not currently

     Ground-water quality standards have been used  in
Virginia1 ground-water management program for only  two years.
While a firm track record has not yet been established, State
Water Control Board personnel feel that the use of  ground-
water quality standards contribute to managing their ground-
water resources.

                          NEW YORK


     For many years New York has had a ground-water quality
standards program which basically addressed non-organic     '
contaminants.  By 1977 it became clear that organic compounds
were contaminating ground water in the State, so in 1978,
new ground water quality standards which included numerical
criteria for organics were put into effect.  The water
quality standards program is administered through the Depart-
ment of Environmental Conservation (DEC) and its nine re-
gional offices, which have responsibility for air quality,
water quality, and solid waste.  The Department of Health
(DOH) administers the water supply program and the Depart-
ment of Transportation (DOT) controls petroleum-related
The Standards Program

     Numerical standards are identified for 83 pollutants.
The standards for organics are the same as the drinking
water standards developed by DOH.  There are three classes
of ground water in New York:  Class GA includes water whose
best usage is as a source of potable water; Class GSA waters
which are saline waters; and Class GSB which are receiving
waters for disposal of wastes.  The numerical criteria
apply only to Class GA water; however, State policy is that
the best usage of ground water in the State is potable water
and, therefore, all aquifers in New York are treated as
Class GA.  Although there is no requirement to clean up
existing poor quality ground water, further impairment of
quality is not allowed.  Thus for example, even if a ground-
water aquifer has naturally high arsenic levels, additional
arsenic or other pollutants may not be introduced beyond the
levels allowed in the standards.  The standards apply to all
sources of pollution except that effluent standards and/or
limitations for discharges to Class GA waters do not apply

     (1) The discharge of sewage without the admixture of
industrial waste when:  (i) a disposal system, point source
or outlet consists of a subsurface sewage disposal system
designed, constructed and maintained in accordance with
guidelines and standards satisfactory to the Department;

(ii) monitoring facilities are utilized in accordance  with
requirements as may be specified by the Department;  and
(iii) the disposal system is designed to discharge and
discharges less than 30,000 gallons per day.

     (2) Normally accepted agricultural practice of  utilizing
chemicals and fertilizers for growing crops for human  and
animal consumption.

     (3) The potential renovative capabilities of a waste
management system employing land application techniques and
land utilization practices may be permitted for a discharge
provided it has been demonstrated to the satisfaction  of the
Commissioner after his consultation with the New York  State
Commissioner of Health that:  (i) there shall be no actual
or potential public health hazard; (ii) applicable water
quality standards shall be met in the saturated zone;  and
(iii) applicable water quality standards shall not be  con-
travened in any adjacent waters of the State.

     These exceptions are not to be construed to allow any
discharge which would preclude the best usage of Class GA

     For organics, no dilution (mixing zone) is allowed.
For inorganics there is a two-to-one dilution allowance.

     DEC in Albany is responsible for policy and regulation
development.  The program is administered on a day-to-day
basis by the nine regional DEC offices.  The area in New
York with the worst ground water problems is Long Island,
under the jurisdiction of DEC Region I.  That Region
delegates responsibilities to Nassau and Suffolk Counties,
which have large health departments.  DEC and DOH pay these
counties fifty percent of their personnel costs; in turn
the counties perform monitoring and enforcement activities
for the State.  The counties report annually to the State
and, of course, report emergencies as they arise.  DEC, DOH,
DOT, USEPA, and local governments have close working rela-
tionships and work effectively together to address ground
water pollution problems.  In New York, the State Pollution
Discharge Elimination System (SPDES) administered by DEC
includes the delegated NPDES program for surface water and a

State program for ground water.  Thus effluent  limitations
are  included in permits for ground-water dischargers.

     In Region I, violations of ground-water quality
standards are usually discovered by the county health
departments through their delegated responsibilities to
administer the SPDES program and monitor for DOH.  This
program contains self-monitoring and monthly reporting
provisions similar to those in the NPDES program.  In
addition, the counties have an active program to identify
organics-related problems.  Nassau and Suffolk Counties
both monitor existing water supply and USGS wells.  In
addition, Suffolk County has two-well rigs and a team of
drillers and is in the process of drilling 300 monitoring
wells.  On Long Island there are three vertical levels of
aquifers.  The top most aquifer is an extremely porous glacial
aquifer, the middle aquifer (the Magothey) is also porous and
the bottom aquifer is the Lloyd, which has a limited water
supply.  Rapid population growth and a lack of central sewage
facilities led to nitrate pollution of the glacial aquifer
by septic systems.  The Magothey is the primary source of
public water supply.  The Lloyd is used where there has been
saline intrusion into the Magothey.  Monitoring occurs at
all three levels.

     DEC, through the county health departments, monitors
for pollution control purposes by letting the wells run from
the aquifer.  DOH monitors the water supply distribution
system through the health departments.  Region I DEC has
requested funds in its budget proposal so it can also
perform monitoring.   The counties report annually to DEC.
In addition, DOT monitors wells in regard to its petroleum
responsibilities.  A current ground-water problem is
resulting from failures of underground gasoline tanks.  DEC
and DOT are working closely to address this problem.

     When the county health departments have informed a
polluter of a violation,  they will attempt to resolve the
problem on an informal basis.   If this fails and the
correction does not involve a capital cost, the matter will
be referred to the DEC Regional Office.  If the Regional
Office does not succeed,  eventually the matter would be

referred to the DEC Commissioner who has broad power to
issue orders.  When a capital expenditure is involved,  a
compliance schedule would be established and incorporated
into the SPDES permit.  If the compliance schedule is not
met, there would be an administrative hearing and the
Commissioner would issue an order.  If that order were not
complied with, the matter would be referred to the Attorney
General for legal action.

     Where there is an emergency situation, if it involves
petroleum, DOT would become involved through a clean up fund
established by the State (maximum $25,000,000).  This
legislation allows DOT to request the company to stop the
accidental spill and clean it up.  If the company does not
act, DOT can address the problem through use of the clean up
funds and then institute legal action through the Attorney-
General's Office to obtain reimbursement.  No parallel
program exists for non-petroleum spills.  Thus the emphasis
is on preventive action such as county laws requiring test-
ing and rebuilding of underground tanks.

     Ground-water depletion is monitored in order to
identify problems related to saline intrusion.  As central
sewage treatment systems are developed,  the recharge to
ground water is reduced, thus increasing the  incidence of
salt water intrusion.

     Historically, New York State's water pollution programs
have been oriented toward surface water.  In recent years
there has been reorientation toward ground-water protection.
Generally there is still a need for better monitoring and
more enforcement personnel.

     Like many other states, California's water pollution
 and water management programs have focused more on  surface
 water than ground water.


     Comprehensive ground-water management has not been
undertaken in many overdrafted areas of the State.  Except
in a few areas, ground-water extraction is not managed
to the same extent as oil and gas production, timber
harvesting/ mining/ or even surface water diversions.
California's ground water is usually available to any pumper,
public or private, who wants to extract it, regardless
of the impact of extraction on neighboring ground-water
pumpers or on the general community.  This lack of manage-
ment has contributed to such ground-water quality problem
as seawater intrusion into fresh water aquifers.  Steps
to combat water quality problems should include ground-
water management choices which will vary with the types and
extent of ground-water quality degradation, as well as with
the availability of water generally.


     California's programs to protect ground-water quality,
while somewhat fragmented, are fairly comprehensive in
scope.  A statewide program for water quality control has
been established on a regional basis.  This program covers
ground water as well as surface water.  Regional Water
Quality Control Boards and the State Water Resources
Control Board are required to establish water quality standards
for ground water.  A permit program for dischargers ensures
that these standards are met.

     The State Department of Water Resources monitors the
numbers and kinds of wells which are drilled statewide and,
generally monitors the State's aquifers.

     Finally, the State Department of Health Services
monitors the waters of the State in general, using the health-
based water quality standards to protect the State's aquifers.
The State,  through the Department of Health Services, has
adopted the numerical NIPDWR standards as its own for purposes
of ground-water protection of aquifers utilized as a drinking
water supply.  In addition,  MCLs have been separately adopted
for several other compounds not included in the NIPDWR.
The State policy is that all ground-water resources of drinking
water quality should be maintained at that quality.  If any

drinking water standard is violated by either a current or
an intended use of an aquifer, that use must be either
modified in order to comply with the standard in question
or discontinued.  This policy has apparently worked very
well, due in no small part to the exceptionally good natural
quality of much of the ground water in California.   Obviously,
cooperation between the various agencies charged with ground-
water quality protection is essential.  Fortunately,
coordination between these agencies, to date, has been very

     It should be noted that the future of the California
ground-water program is uncertain.  Firstly, several
agricultural areas have discovered a pesticide, DBCP, in
their aquifers.  It is not known at this time what effect
this will have on current ground-water policy.  Secondly,
the State is currently considering the adoption of MCLs
for volatile organic chemicals commonly found in ground
water.  Such an adoption will almost certainly affect the
current users of ground water in California, possibly to
the point where treatment prior to use will be necessary
on an expanded basis.

             APPENDIX IX




                   OTHER FEDERAL AGENCIES

     Several Federal agencies have programs which directly
or indirectly impact ground-water management and which
are interrelated with EPA programs.  These are summarized
as follows:


     EPA and USDA have been cooperating in an agricultural
nonpoint source strategy.  Approximately $100 million in
Agricultural Conservation Program (ACP) and Rural Clean
Water Program (RCWP) funds, utilizing Soil Conservation
Service (SCS) technical resources, are being directed to
special projects to implement best management practices
(BMPs) to protect water quality.  States are using EPA
208 funds to evaluate the projects and to establish State
operational agricultural programs.

     The detailed soil maps prepared by the SCS are a
valuable data base.  Over 65 percent of the Nation has
been mapped for soils.  The maps delineate contrasting
soils in two acres or more*  For each soil horizon perme-
ability is estimated.  Among other data collected are the
soil structure (the patterns of cracks and pores), thickness
of the horizon, clay content, cement and the pH of the
horizon.  These maps are often used as a basis for on-lot
design or first cut analyses for other waste disposal

     The SCS also administers the Rural Abandoned Mine
Program (RAMP) which was established by the Surface
Mining Control and Reclamation Act of 1977.  Up to 20% of
the money collected yearly for the Abandoned Mine Reclamation
Fund is allotted to the Secretary of Agriculture to
control and prevent erosion and sediment damages and to
provide conservation and development of soil and water
resources of unreclaimed mined lands and lands affected
by mining.  Where a surface or undergound coal mine
operation has significantly affected the hydrological
balance, corrective action may be taken.  Landowners,
including the owner of water rights, residents or tenants
may submit a plan for correction action and if approved,
the Secretary of Agriculture may enter into a cost-sharing
relationship with the landowner providing up to 80% of
the funds necessary for reclamation of a land area not to
exceed 120 acres.



     The Nuclear Regulatory Commission (NRC) is responsible
for ground-water protection needed as a result of uranium
processing at UF6 facilities.  There are two types of UF6
conversion facilities:  a dry process and a wet process.
The wet process generates liquid which must be stored in
an on-site lagoon.  The lagoons are required to have
double liners and a detection system for leakage from the
top liner.  A second pond must be available to hold
liquid from the first pond in the event of a leak.  The
pond is dried by evaporation and the residue is then
buried.  Where rainfall is too high to reduce the liquid
waste by natural evaporation high energy consumption
artificial evaporation is used.

     NRC also has responsibility for regulating source and
by-product material from uranium recovery operations and
associated mill tailings.  EPA establishes Best Management
Practices and Standards and prepares Environmental Impact
Statements for milling operations.  The Department of Energy
provides funds for the cleanup of inactive milling sites,
is conducting research on mill tailing operations and is
currently storing high spent radioactive material.


     The Office of Surface Mining (OSM) is the regulatory
agency for surface mining activities throughout the
United States.  States are able to take over their role
as a regulatory agency if they submit plans to OSM for a
program equal to,  or more stringent than,  the Federal
program.  If the State submits no application, or if its
plan is deemed inadequate by OSM, the Federal Government
will operate a surface mining regulatory program within a

     The OSM regulations establish requirements which in
the course of mining activities maintain or restore to an
equivalent state the hydrological balance impacted by mining
activities.  Before engaging in mining operations, an
operator must make a statement to OSM (or the State) on
the action's probable hydrologic consequences.  Based on
these stated consequences the Federal or State government
regulatory agency will approve or require modification
of the project.


     The State regulatory agency, or OSM must also determine
what are the likely cumulative hydrological impacts to an
area or region which presently has mines or is likely to be
mined in the future.  This is slightly different in intent
than the statement of probable hydrological consequences
in that that statement referred largely to the localized
vicinity of the mine whereas this discussion is area, or
region wide.

     The Office of Surface Mining also operates the
Abandoned Mine Land Reclamation Program.  Funds for the
program are collected through fees levied against the
operators of active coal mines which then become part of
the Abandoned Mine Reclamation Fund.  The fund may be
used for the protection of public health, safety, general
welfare and property from the danger of the adverse
effects of coal mining practices; the restoration of land
and water resources and the environment previously degraded
by adverse effects of coal mining practices; research and
demonstration projects relating to the development of
surface mining reclamation and water quality control
program methods and techniques; protection, repair,
replacement, construction or enhancement of public
facilities; and the development of publicly owned land
adversely affected by coal mining practices.

     One-half of the Fund's moneys are to be used for
the State Land Tribal programs; 20% of the Fund is used
to support the Soil Conservation Service's Rural Abandoned
Mine Program; 5% of the Fund which assists small operators
of active mines in developing hydrologic studies and
water quality analysis.


     The Oil and Hazardous Substance Liability spill
response program (Section 311) is operated under shared
Coast Guard and EPA authority.  There is a functional
geographic division as to which agency responds — the
Coast Guard responds to spills in coastal waters and EPA
responds to spills in inland waters  (not affected by
tidal influence).  In addition, the Coast Guard responds
to spills which are transportation-related  (e.g., pipelines)
while EPA responds to nontransportation related spills
(e.g. off-shore platforms) regardless of where they are


     Section 311 itself does not protect ground water.  If,
however, a spill enters the ground water and subsequently
appears in the hydrologically related surface water and if
a causal reference between the two events can be made, then
there can be a Section 311 response.


     The Office of Water Research and Technology ad-
ministers a program of water resources research and
training, including research on new technology and more
effective methods for resolving local, State and nationwide
water resources problems; training water scientists,
engineers and others through their on-the-job participation
in research work; and facilitating water research coordination
and the application of research results through dissemination
of information about ongoing and completed research.  The
Office of Water Research and Technology provides funds to
a State university Water Resources Center in each State to
support research projects.  During FY 1980 the Office of
Water Research and Technology provides $11 million to the
fifty-four centers, including approximately $1 million for
research associated with ground water.

     Office of Water Research and Technology also operates
a Saline Water Research and Development program with a
budget of $12 million.  This is a national program to advance
the technology of desalination and to determine the applic-
ability of desalinized water to water-short areas.  The use
of brackish ground water as source water for desalination
is considered in this program.

     Office of Water Research and Technology's other major
program is that of Conservation, Reuse and the Water
Problems of Urbanizing Areas for which the combined FY 80
budget is $3.6 million.  Ground water is an area of interest
in the conservation and reuse program.


     The USGS is the principal Federal Water data collection
agency.  The USGS Cooperative Program, the Survey, Investi-
gation and Research program (SIR) and transfers to USGS from
other Federal agencies had available in FY 79 about $60-70
million for ground-water related activities.  Ground-water
quantity and quality phenomena are a sizeable portion of the
Geological Survey's water resource research effort (within


     The Federal/State Cooperative Program includes both
surface and ground-water investigations.   In 1978 the USGS
joined in cooperative water resource investigations with
610 State and local agencies.  While USGS staff performs
most of the work, one-half of the Cooperative Program funding
comes from State or local agencies.  Major ground-water
activities generally deal with aquifer geological charac-
teristics, hydrologic questions associated with the adminis-
tration of the resource and the delineating of aquifers on
maps.  General background monitoring is performed to a
limited degree in all States but where field circumstances
dictate intensive monitoring may occur.  Salinity problems
have been a major focus of attention within the Cooperative
Program but more recently organics and heavy metals have
become objects of analysis.

     The Cooperative Program is generally conducted within
a political subdivision, the Regional Aquifer System Analysis
(RASA) Program is conducted on a regional basis, and across
State lines where necessary.  RASA projects have been selected
on the basis of criteria including:  1) the significance of
the aquifer system as a present or potential supply of
water — particularly its significance to the national economy
or, at least, to the economies of more than one State; 2)
the severity of the water problems facing the project area;
3) the potential water needs in the project area — parti-
cularly those connected with energy projection, increasing
irrigation, and increasing urban development; and, to a
lesser extent, water quality.  The RASA budget for FY 1980
is $14 million.

     RASA studies currently underway include;  California
Central Valley, Northern Great Plains, High Plains, Cambro-
Ordovician aquifers of the Northern Midwest, carbonated
aquifers of the Southeast, alluvial basin aquifers of the
Southwest, Atlantic Coastal Plain, Snake Plain, and Central
Midwest Carbonate aquifers.  Future plans call for initiating
three or four new studies each year.  The average length of
study will be four years.  The program is expected to peak
in FY 82.

     Each study will address water quality as well as hy-
draulics.  The present water-quality distribution throughout
the study area will be described and an effort will be make
to interpret this distribution in terms of the original
flow pattern, the changes in response to development, and
the associated geo-chemical processes.  The products of
these investigations are designed to complement the Survey's
continuing program of cooperative ground-water investigations.


     Until recently, little has been done to describe where,
how, and in what quantities water is used.  In recognition
of this deficiency, USGS began the National Water Use Data
Program by implementing investigations in 16 States during
FY 1978.  Full implementation is expected in FY 1982.

     It should be noted that at rapidly increasing rates
USGS efforts are turning to water quality investigations
of the subservice.  USGS field offices are also increasingly
providing input into EPA efforts through responses of the
Cooperative Program to requirements which EPA Places on
State agencies.



      The Nation has entered a period of increasing  interest
 in the protection of the quality of its ground water. A
 recent prolonged drought in certain of  the  Western  States
 resulted in the agricultural community  turning to the
 utilization of ground water to prevent  an economic  catastrophe.
 At about the same time,  drinking water  in the North Atlantic
 States was  found to contain traces  of organic compounds believed
 to be carcinogens.  Concurrently,  ground-water contamination
 from waste  disposal sites was reported  from all parts of the

      While  regulations were being prepared  in response  to
 the Safe  Drinking Water  Act,  the  Resource Conservation  and
 Recovery Act and the Toxic  Substances Control Act came  into
 being,  placing additional burdens on the Agency in  this area.
 In construction grants,  conventional waste  treatment systems
 could only  be justified  if  it could be  demonstrated that they
 were superior to land application systems.   For the first time
 EPA began to seriously consider ground-water resources  in
 planning  under Section 208  of the Clean Water Act.

      The  preparation of  regulations and their support docu-
 ments,  the  designation of sole source aquifers, enforcement
 actions,  area-wide  planning,  and  the protection of  drinking
 water,  as well as water  for other uses, created a new need
 for  technical information by  all  facets of  the Agency.  To a
 considerable extent this  information did not exist, and it
 was  found that much of the  technical information applicable
 to air  and  surface  water  was  not  transferable to the sub-
 surface environment.  The  aim  of this paper  is to identify
 those information gaps and  to suggest ways  to fill  them.

     A meaningful research  strategy necessarily requires
 that the  type  of technical  information  needed by the user
 community be  identified and placed  into discrete categories.
 The difference  between that information required and that
 known for each  category constitutes  a listing of research
 needs.  These needs, when expressed  in  terms of completion
 time, dictate  resources requirements  for their completion
 and constitute  a research plan.

     There are areas which  are not included within this
 research section, yet they are salient parts of any effort
 to protect underground water and will be addressed elsewhere.
For example, a monitoring system may be required to establish
background water quality, define areas of existing contami-
nation, and characterize existing sources of contamination.


In addition, existing legal and institutional mechanisms
and constraints for ground-water protection must be determined
before any program can be fully effectual.

     There are two other important areas not included in
this research portion of the ground-water protection
strategy since they have been arbitrarily defined out of
the scope of this effort because of the desire to concen-
trate on areas not addressed in other efforts such as
surface water or drinking water protection.  These are
health effects and water treatment, particularly with
respect to organic contaminants.

     The following research categories were first developed
in the Fall of 1976 on the advice of an advisory group
representing various EPA Offices, universities, the USGS,
State agencies, consultants, and other interested associations.
Subsequently, they have been refined based on the views of the
Agency's Science Advisory Board, the National Drinking Water
Advisory Council, the Subcommittee on the Environment and
Atmosphere of the House Committee on Science and Technology,
and various continuing committees within EPA.  The research
categories are:

               Methods Development
               Contaminant Transport and Fate
               Subsurface Characterization
               Specific Sources of Contamination
               Aquifer Rehabilitation
               Information Transfer
               Technical Assistance

     Methods development refers to any technology used to
conduct ground-water investigations.  This can be as basic
as the location, drilling, and completion of various types
of monitoring wells or as complex as the identification of
sources of ground-water contamination.

     Contaminant transport and fate studies refer to the
development of quantitative information concerning contaminant
movement and the processes of immobilization and transformation
in both the saturated and unsaturated zones.  Listed in increas-
ing orders of complexity, the classes of contaminants for which
this information is required are:  salts, nutrients (primarily
nitrogen and phosphorus), metals, organics, and bacteria and

     Specific sources of contamination constitute the
primary cause for concern among most regulatory agencies
and others whose concern is the protection of ground-water
quality.  It is important to note that the previous research
categories are necessarily precursors to investigations
of specific sources.  The following nineteen sources of
ground-water contamination are listed in priority according
to their pollution potential by volume. It is a useful, even
if imperfect, list which suggests that the top few sources are
more pervasive than the last; it does not suggest that any
one source is innately of more concern than the one which
immediately follows.  For example, subsurface disposal systems
are considered a major problem because of their numbers and
distribution, yet in another sense industrial surface impound-
ments, though less numerous, often contain a more hazardous
waste.  The magnitude of the health risk posed by an individual
source is a function of toxicity, volume, geological siting
and proximity to use.

               1.   Subsurface Disposal Systems
               2.   Petroleum Exploration and Development
               3.   Landfills and Dumps
               4.   Agricultural Practices
               5.   Surface Impoundments
               6.   Natural Leaching
               7.   Land Application of Wastes
               8.   Artificial Recharge
               9.   Water Well Construction
              10.   Ground Water Development
              11.   Waste Piles and Stock Piles
              12.   Mining
              13.   Storage Tanks and  Transmission  Lines
              14.   Accidental Spills
              15.   Drainage Wells and Sumps
              16.   Surface Water
              17.   Highway Salting
              18.   Industrial Disposal Wells
              19.   Air Pollution

     Aquifer rehabilitation generally  refers to  the restora-
tion of water quality  in an aquifer after it has become con-
taminated and the waste source isolated or  removed.   This is
often ineffectual with present technology and  conceptually is
a costly undertaking both with respect to money  and time—this
emphasizes the need to concentrate on  aquifer  protection  rather
than restoration.   Unfortunately, there are many cases where
the subsurface has  been contaminated by hazardous waste thereby
threatening drinking water  and restoration  is  imperative  re-
gardless of cost.   Thus the need  for a research  effort into
rehabilitation techniques.

      Information transfer refers  to  the  conversion  of
 technical  information  obtained  through research to  some
 media available  to  the user  of  that  information.  The
 capacity to  react to instances  of ground-water  pollution,
 as  well  as the ability to predict changes  in ground-water
 quality  is hampered, to a large extent,  by a lack of in-
 formation  and training.

      Technical assistance is an extension  of information
 transfer directly by research personnel  to other parts of
 the Agency,  State and  local  personnel, and others requiring
 such assistance.

     Methods development is basic to all aspects of ground-
 water quality protection ranging from the development of
 sound aquifer management plans to enforcement activities.
 For example, both simple and complex ground-water models
 are required to understand the subsurface environment and
 make predictions on the impacts of development as a water
 supply and the consequences of waste disposal and treatment
 practices on ground-water quality.

     Methods for characterizing aquifers in terms of their
 potential as a water supply and methods for evaluating
 waste disposal sites are integral parts of basin management

     Monitoring techniques and the use of tracers play
 important roles in all aspects of ground-water investigations.
 For example, they serve to establish background quality and
 quantity conditions, determine when waste disposal facilities
 have failed, show fault in contamination cases, and provide
 information for research activities.

     Unfortunately,  many cases of ground-water contamination
 have been reported in all parts of the country and undoubtedly
 others will be found in future years.  There is an increasing
 need for technical information which will allow contaminated
 aquifers to be restored and will isolate sources of con-
 tamination from aquifers.

     Finally, there  is a need for better and more unified
data storage and retrieval systems which account for
horizontal and vertical dimensions as well as time.

     Information on contaminant transport and fate is needed
in order to evaluate the effects of human activities on
changes in ground-water quality.  Basically, the type of
information required is the characterization of movement of
classes of contaminants through classes of geological
materials.  This includes an understanding of sorption,
chemical and biological degradation, volatilization, and
fixation.  As mentioned earlier, information is required
for salts, nitrogen and phosphorus, metals, organics, and
bacteria and viruses in geological material ranging from
sands and gravels to clays.

     Subsurface characterization information is needed in
order to evaluate the subsurface as a receptor of contami-
nants and improve our ability to identify and predict
changes which will occur as a result of residence in the
subsurface.  Characterization information will be in terms
of the physical, chemical, and biological properties of the
subsurface environment.  The need for technical information
varies as a function of the proposed regulatory option.
For example, a no-discharge option would preclude the use
of the subsurface as a receptor of contaminants resulting
in no need for this type of technical information. Conversely,
options involving ground-water standards, aquifer management,
or the establishment of protection zones will require
thorough information on subsurface characterization.

     The technical information required for specific
sources of contamination is dependent upon the type of
control option selected.  For most options, however, this
information consists of:  (1) the number and location of
each source; (2) a characterization of contaminants entering
and leaving the source; (3) the availability, feasibility,
and effectiveness of control or management measures, in-
cuding design and construction, operation and maintenance,
closure, and on-site treatment of effluents; and  (4) as
mentioned earlier, methods for monitoring the effectiveness
of controls.  Although zero discharge or total containment
is not practical for all of the identified waste sources,
it is feasible for some.  In this case, monitoring
methodology is needed to assure that containment is

     Technical needs for aquifer rehabilitation are of
two parts.  One is the actual rehabilitation of the con-
taminated saturated and unsaturated zone and the other is
the removal or isolation of the source of contamination.
Basic to these needs is information for determining the
source of aquifer contamination and a decision tree for

whether remedial action is necessary or feasible and the
extent of rehabilitation which is required.  Since some
contaminants pose more of a potential threat to public
safety and to the subsurface environment than others,
economic, social, and engineering information is required
to assist in decisions between rehabilitation and the
development of alternative water supplies.

     Information transfer needs are as varied in technical
content as the audience to which they are to be directed.
It can be estimated that persons adequately trained to
plan and carry out ground-water quality investigations
number only in the hundreds in this country, while those
required at all levels of government and in the private
sector number in the thousands.  It is clear that increasing
this technical base is paramount to all aspects of ground-
water protection and use.

     Reports are needed, based on existing knowledge, con-
cerning the proper methods for conducting field investi-
gations including monitoring well construction and siting,
proper sample collection, and the fundamentals of contami-
nant transport and fate both in the unsaturated and
saturated zones.

     This material can take several forms including state-
of-knowledge documents, techniques manuals, general
educational films, video tapes, and information centers.

     Technical assistance is in a very real sense an
extension of information transfer by research personnel
to other parts of the Agency, State and local personnel,
and others requiring such assistance.  Technical assistance
is a personnel intensive effort usually involving those
who are recognized as experts in their field.  Therefore,
inordinate use of their time for this purpose is particularly
costly in terms of established research goals.  Technical
assistance can be provided in the form of drafting regulations
and support documents; planning for specific ground-water
investigations; special state-of-knowledge reports; special
analytical services? training for Regional, State, and
local personnel; providing advice and expert testimony in
enforcement actions; and other consultation as requested.


     The amount of research directed toward ground water
has increased dramatically in recent years even in countries
outside the United States who have traditionally been
active in this area. Worldwide, it appears that this
increased emphasis stems from water shortages,  surface
degradation, and reliance on underground water  resources.

     Because of increased efforts in ground-water research,
much of the technical information to come from that research
will not appear in technical journals within the next few years,
It is important for the development of this research plan
to estimate the general direction of ongoing research to
help outline information gaps in future years.

     Methods development as related to ground-water quality
protection differs from that of surface water technology
primarily in overcoming problems of inaccessibility.  In-
accessibility causes the unpredictability, difficulty, and
expense of obtaining representative data and limits the
options available for monitoring water quality, for
developing technology for predicting pollutant movement
in the subsurface, and for reclamation of contamined
ground water.

     Some work has been done on a number of geophysical
techniques to indicate changes in ground-water quality
but these techniques have not progressed to the point of
replacing expensive monitoring wells except in ideal
conditions. Even though a great deal of work has been
accomplished in methods for installing monitoring wells,
serious problems remain with alterations of the physical,
chemical, and biological properties of the subsurface.

     Coring techniques have been developed for collecting
samples of anaerobic bacteria but these are restricted to
rather shallow depths and limited to a few types of geological

     Methods are available to sample water wells for most
inorganic parameters.  Technology is available for
collecting uncontaminated, representative samples for
trace organic and biological parameters in relatively
shallow subsurface environments.

     Although there has been some work in the development
of indicator parameters for classes of contaminants, this
remains one of the major deficiencies in many aspects of
ground-water investigations.


     Mathematical models have been used extensively in
ground-water investigations primarily in flow analyses
and mass transport of conservative pollutants.  Only about
20 percent of the world's existing models are generally
usable for one reason or another, principally because of

     Active work in the United States ranges from the
development of tracer techniques to well completion and
monitoring methods.  Other work deals with methods to pre-
dict the effect on ground water of certain mining activities
and technology for sampling in the unsaturated zone.

     On an international basis, ground-water research
also appears to be shifting to considerations of trace
organics both in modeling and transport kinetics. Poland
is attempting to isolate sources of contamination using
resins, France is developing seismic techniques applicable
to shallow geology, and the United Kingdom and Israel are
working on methods to isolate viruses.

     Most transport and fate studies have traditionally
been associated with inorganic contaminants and, to a
lesser extent, metals.  A great deal of information exists
in these areas even if imperfect in minor ways.  There has
also been a great deal of work concerned with the transport
and fate of nitrogen and phosphorus compounds in the sub-
surface.  Of these areas, knowledge in the movement of
metals and nitrogen compounds is the most lacking.

     Knowledge concerning the transport and fate of in-
organic contaminants in both the saturated and unsaturated
zones is particularly fragmentary.  Until very recently,
a false sense of security concerning this problem existed
among most regulatory and research groups because of the
inflated conception of the attenuating capacity of the
soil mantle for organic compounds.  Current information
permits only generalized conclusions concerning the
movement of a few organic compounds. In the subsurface
environments, mathematical expressions capable of providing
a first generation predictive ability for a selected group
of organics in some subsurface environments are under develop-

     Considerable attention has been devoted to the trans-
port and fate of pathogenic microorganisms in the subsurface
because of the long-recognized health implications associated
with this class of contaminants.  Nevertheless, knowledge
in this area remains less than definitive, particularly
in the case of viruses.


     Active work in the United States is concerned with
the transport and fate of nutrients and metals while that
associated with organics remains limited.  Exceptions to
this lie with the USGS and work supported by EPA.

     Most international transport studies are concerned
with metals and conservative pollutants.  Sweden,  the
Netherlands, Switzerland, and to some extent the United
Kingdom are doing excellent work in organics transport.

     Subsurface characterization studies of the earth's
crust below the upper soil mantle have not been concerned
extensively with the nature of this environment as a
receptor of pollutants.  Through the efforts of researchers
in such fields as agriculture, petroleum engineering,
geology, geochemistry, and hydrology, we know a great
deal about various aspects of the composition and structure
of the earth's crust and how water moves through it.  Un-
fortunately, available information is inadequate to describe
what occurs when pollutants are introduced into subsurface
regions since the need for such information has been
recognized only recently.

     Although little, if any, work of this nature is
under way in the United States, Australia, Germany, Poland,
and the Netherlands have some activity with the upper
soils in land application projects.  There is some evidence
that this type of work is under way in the USSR but details
are difficult to obtain.

     Information on specific sources of contamination is
abundant in the literature.  The amount of information pre-
cludes extensive discussion in this document; however,
certain generalities can be made.  For example, even
though a great deal of information exists concerning septic
tanks, this is mostly concerned with design and the contri-
bution to ground water of such contaminants as coliform
bacteria, nitrogen, phosphorus, and total dissolved solids.
Little is given on viruses, trace organics, nitrogen losses
to the atmosphere, or allowable septic tank densities.

     Most work associated with the development and pro-
duction of oil and gas deals with salt water while little
is provided about drilling fluids, chemicals used in
treating wells, corrosion inhibitors, and other drilling

     Although leachates from purely municipal landfills
and dumps have generally been characterized, the presence
of industrial wastes in municipal dumps however, makes
such a characterization very difficult.  In most cases,
information on the location of these sites is nonexistent.

     There have been a number of investigations relating
to the leakage of surface impoundments even though the
treatment of trace organics is somewhat limited.  The
current EPA Surface Impoundment Assessment, which is
nearing completion, will give a much better idea of the
potential impact of this method of waste disposal on
ground water.

     Specific sources of contamination are being studied
constantly throughout the world.  These studies pre-
dominantly deal with waste dumps, agriculture, ground-
water recharge, land application of wastes, and well
construction. Belgium has worked with industrial spills
of hydrocarbons, and New Zealand is concerned with agri-
culture, septic tanks, and land application projects.  The
USSR has done considerable work associated with mining.

     Aquifer rehabilitation studies conducted to date
have been directed toward prevention, including causes
and occurrences, procedure for control, and methods
for monitoring. Case histories of 116 ground-water con-
tamination incidents reveal that remedial action is
usually complex, time-consuming, and expensive.

     About the only large scale work in this area is on-
going in Switzerland and Germany.  The Swiss have established
emergency procedures for pumping and treating contaminated
ground water in spill areas.  A university in Germany has
established a research and demonstration project for
pumping, treating, and recharging contamined ground

     Information transfer is an area of shortcoming for
the scientific community in general and ground-water
scientists in particular.  There is probably no resource
as heavily used and yet so commonly misunderstood by its
users,, managers, and regulators as ground water.  This is
evident in the survival and even proliferation of folklore
regarding the "water witch" even among otherwise sophisticated

     The most common ground-water information medium
in the past has been, and continues to be, technical reports
or publications in technical journals.  Ground water science
is truly a multidisciplinary effort. Articles on ground-water
quality may be found in journals of geology, hydrology,
engineering, chemistry, agriculture, and microbiology,
as well as others.  The U. S. Geological Survey has for
many years published ground-water reports, primarily re-
lated to water quality and availability. Quality aspects
were usually, though not always, limited to the more
conservative constituents such as chlorides or sulphates,
or other natural pollutants.

     Since 1967, EPA and its predecessor agencies have
published a limited number of reports on ground-water
research.  Also, many of the State water agencies publish
reports on the status of their ground-water resources.

     Despite its widespread use, there are perhaps only
three national periodicals devoted exclusively to ground
water.  The National Water Well Association publishes the
Water Well Journal monthly and the Ground Water Journal
bimonthly.The Water Well Journal is directed primarily
at the water well driller while the Ground Water Journal
is devoted to the more technical and scientific aspects
of ground-water management, including quality.  The Water
Information Center of Syosset, New York, publishes the
monthly Ground Water Newsletter, a synopsis of current events
related to ground-water management.

     The second most common form of formal ground-water
information transfer is technical meetings.  An early
national meeting devoted exclusively to diverse ground-
water quality problems was a 1961 symposium entitled "Ground
Water Contamination," sponsored by the U. S. Public Health
Service and held at Cincinnati, Ohio.  A number of national
technical meetings, most notably those sponsored by the
American Geophysical Union, have devoted a portion of their
programs to ground-water related issues.  Since 1971, EPA
and the National Water Well Association have conducted
four national Ground Water Quality Symposia and published
proceedings on each.

     Because of the recent great interest in ground water
and ground-water management, in 1978 EPA established a
Clearinghouse for Ground-Water Models at Holcomb Research
Institute. The purpose of the Clearinghouse is to make
existing ground-water models more accessible to the
user and improve communication between management and
those who provide technical services employing models.



     Recent and ongoing ground-water research indicates
a response to new technical information needs rather
than a departure from traditional ground-water inves-
tigations.  In addition to the increased emphasis in
ground-water protection, these information needs result
from the fairly recent and widespread discovery of trace
organic compounds in the subsurface environment, regulations
requiring better monitoring methods, and the desire for
more accurate information concerning land use practices
and their effect on this water resource.

     The following areas of research are suggested to
address existing technical information deficiencies.  They
are necessarily categorical in extent rather than a
detailed listing of specific projects.  In some instances
the suggested work is an extension or modification of
existing technology while in others the work is entirely

     In methods development a series of basic tools are
identified as deficiencies in ground-water investigation
and management projects.  For example, additional modeling
capabilities are required to address economic and management
problems and those in mass transport, particularly of
organic and biological contaminants.

     Aquifer characteristics require definition beyond the
traditional hydrogeologic parameters.  Improved determi-
nation of aquifer boundaries and recharge zones are
required along with the ability for geophysical and
hydrogeologic mapping for land use evaluations.  The
improvement or adaptation of existing logging technology
is suggested.

     Traditional ground-water monitoring technology falls
far short of current and future needs.  A great deal of
improvement is required in the manner of drilling, com-
pleting, and sampling monitoring wells for specific
purposes.  Research is needed on methods for monitoring
leakage in the unsaturated zone and in general the effects
of waste disposal practices on ground water.  In-situ
monitoring, remote sensing, and the proper use of
tracers are all areas of required development or improve-


     Of paramount importance is the improvement and
perhaps standardization of methods for storage and
retrival of ground-water data.

     A great deal of work is required in contaminant
transport and fate particularly in organic and biological
contaminants.  Some work remains with respect to metals
particularly in changing oxidation-reduction phases.  With
all of the work that has been accomplished with respect
to nitrogen, additional and perhaps extensive efforts
remain to characterize the transport and transformation
of the compounds of this element in the subsurface
environment.  Extensive research will be required to
develop classes of contaminants and selecting an indicator
for each of these classes in developing transport and
transformation information.  This is particularly true
with respect to organic, bacteria and viruses, and to a
lesser extent, metals.  An important goal of this area of
research is the development of indicators for monitoring.

     Since almost no work is completed or underway in
subsurface characterization, all needs must be addressed
by new research.This is an extremely important area
about which little is known but which ultimately will
lead to criteria for work disposal site selections. Initial
efforts should be directed toward defining the nature of
the subsurfaces environment in terms of its innate
physical, chemical, and biological characteristics and
developing a unified theory correlating these findings
with contaminant transport.  Even before this is attempted
considerable work will be required which could fall under
the methods development category and would be applicable
to monitoring.  For example, a method must be developed
to directly or indirectly measure the redox potential with

     Research needs on specific sources of contamination
are too diverse and lengthly for a complete discussion
here.  It should be restated that research in methods
development, transport and fate, and subsurface characteri-
zation, are paramount in addressing specific sources correctly,
By way of example, research concerning septic tanks should
be aimed at developing density criteria.  The effluent
from these systems should be characterized to determine
the controlling parameter in terms of density.  In the
past nitrate has been used for this purpose in lieu of
organic or perhaps viral contaminants due to the lack of

of information on content or the transport characteristics
of those parameters.  Once this information is obtained,
density becomes a function of subsurface characteristics.

     Examples of research in petroleum exploration and
development would at least initially center around salt
water disposal practices.  Definitive ways to determine
the extent of ground-water contamination from this source
are lacking.

     Additional research is needed to determine the per-
meability or effectiveness of liners to the constituents
of leachates in landfills or wastes stored in lagoons.

     Like septic tanks, additional work is required to
evaluate current design standards for land application
systems in terms of the organic and biological content
of the waste with consideration of the subsurface
characterization at a specific site.  The same considerations
hold true with land farming or land applications of all
residuals from municipal and industrial waste treatment and
mining operations.

     Research in the area of aquifer rehabilitation will
be both innovative and an extensive or improvement of existing
technology.  A very extensive area of research is required
in the physical or hydraulic isolation of waste sources
and the treatment of contaminated ground water either
insitu or upon removal.

     Information transfer and technical assistance are in
a sense related with respect to an Agency strategy on
ground-water protection.  Systems must be developed
for distributing existing and future technical infor-
mation to the user community in a form applicable to
their needs.  Extensive efforts must be dedicated to
increasing the number of specialists in all facets of
the ground-water industry through training and other
information exchange media.  Better techniques must be
developed for exchanging technical information with
other countries.  An information center could serve
as a way to make information readily accessible to all
parts of the Agency, other Federal Agencies, consultants,
and particularly the States.  A system to report incidences
of ground-water contamination should also be established.
Finally, a system of providing limited technical assistance
to the Agency and the States in specific areas is needed.

  U.S. OOVEHMEHT PRINTING OFFICE 1989 -0- 311-726/3886


                        ACRONYM LIST
ACEC      Areas of Critical Environmental Concern
ACOE      U.S. Army Corp of Engineers
ACP       Agriculture Control Program
BAT       Best Available Technology (Water Quality)
BCT       Best Conventional Technology
BLM       Bureau of Land Management
BMP       Best Management Practice (Water Quality)
BPT       Best Practicable Control Technology

CAA       Clean Air Act
CFR       Code of Federal Regulation
CHEMTREC  The Chemical Transportation Emergency Center
CWA       Clean Water Act; also known as the Federal Water
          Pollution Control Act (FWPCA)
CZMA      Coastal Zone Management Act

DOC       Department of Commerce
DOD       Department of Defense
DOE       Department of Energy
DOI       Department of Interior
DOT       Department of Transportation
EDA       Economic Development Administration
EDC       1,2-dichloroethane
EIS       Environmental Impact Statement

FIFRA     Federal Insecticide, Fungicide, and Rodenticide Act
FLPMA     Federal Land Policy and Management Act
FMAF      Financial Management Assistance Project
FWCA      Fish & Wildlife Coordination Act
FY        Fiscal Year
HUD       Housing and Urban Development

MCL       Maximum Contaminant Level (Drinking Water)
MERL      Municipal Environmental Research Laboratory
MOD       Millions of Gallons per Day
MOU       Memorandum of Understanding
MPRSA     Marine Protection Research and Sanctuaries Act
NAAG      Needs Assessment Advisory Group
NCI       National Cancer Institute
NEPA      National Environmental Policy Act
NFMA      National Forest Management Act
NIPDWR    National Interim Primary Drinking Water Regulations
NPDES     National Pollutant Discharge Elimination System
          (Water Quality)
NRC       Nuclear Regulatory Commission
NSPS      New Source Performance Standards (Air Quality)
NURP      Nationwide Urban Runoff Program
OCS       Outer Continental Shelf
OCZM      Office of Coastal Zone Management
ODW       Office of Drinking Water
OPTS      Office of Pesticides and Toxic Substances

OSM       Office of Surface Mining
OWPO      Office of Water Program Operations
OWWM      Office of Water and Waste Management

POTW      Publicly Owned Treatment Works
PWS       Public Water Supply

R&D       Research and Development
RAMP      Rural Abandoned Mine Program
RASA      Regional Aquifer System Analysis Program
RCRA      Resource Conservation and Recovery Act;  enacted as
          amendments to the Solid Waste Disposal Act
RCWP      Rural Clean Water Program

SCS       Soil Conservation Service
SDWA      Safe Drinking Water Act; enacted as amendments to the
          Public Health Service Act
SEA       State/EPA Agreement
SIA       Surface Impoundment Assessment (Drinking Water)
SIR       Survey, Investigation and Research Program
SMCRA     Surface Mining Control and Reclamation Act
SMSA      Standard Metropolitan Statistical Area
SSA       Sole Source Aquifer
STORET    National System to Store and Retrieve Water Quality
            Monitoring Data
TCE       Trichloroethylene
TSCA      Toxic Substances Control Act


UIC       Underground Injection Control
USDA      U.S. Department of Agriculture
USFS      U.S. Forest Service
USGS      U.S. Geological Service

WPRS      Water and Power Resource Service
WRC       Water Resources Council
WSRA      Wild and Scenic Rivers Act