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

\ PflO^
MAY 1 5 1980
Dear Workshop Participant:
Welcome to this workshop on Ground Water Protection
Strategy. As EPA looks into the 1980s the protection of
the nation's ground water resources rates as a high priority
in the Agency's mission.
The purpose of this week's workshops is twofold:
o To examine the issues of ground water protection
with a diverse group of experts representing
government, industry, environmentalists, public
interest groups, and others: and
o To recommend for consideration by EPA policy makers
your preferred strategies for ground water
Further elaboration of the workshop scope and purpose is
provided in Chapter I of the enclosed document.
To the end of fulfilling these purposes, we've invited
many knowledgeable people to attend and participate in the
workshops. Each of you will play an important role in helping
EPA develop an effective and workable approach to dealing with
the formidable challenge of protecting our ground water resources.
All the EPA representatives here are anxious to listen to your
views. I can assure you that the workshop results will play an
important role in helping EPA formulate its Ground Water
Protection Strategy.
Again, welcome, and best wishes for a productive workshop.

Sunday: Evening
Monday: Morning
Reception, Dinner, Welcome, Orientation
Plenary Session I
The Ground Water Problem, Elements
of a Strategy for Ground Water
Protection, Possible Goals
Work Groups
The Goal for a National Ground
Water Protection Program
Plenary Session II
Work Group Reports (5 minutes each)
Presentation/Discussion: Mechanisms
to Achieve the Goal—Management,
Control, and Other
Work Groups
Management, Control, and Other
Even ing
Tuesday: Morning
Work Group Rooms Available for Continued
Discussions (optional)
Plenary Session III
Work Group Reports (10 minutes each)
Pr e sent at ion/Di scusslon : Federal,
State, and Other Roles
Work Groups
Federal, State, and Other Roles
Di nner
Wednesday: Morning
Plenary Session IV
Work Group Reports (5 minutes each)
Presentation/Discussion: R&D Implica-
tions, Goals (revisited), Pulling
Together a Complete Strategy, and
Pr iorities
Work Groups
Develop Recommendations for All Ele-
ments of a Ground Water Protection
St rategy
Work Group Rooms Available for Continued
Discussions (optional)
Plenary Session V
Work Group Presentations of Ground
Water Protection Strategy Recom-
mendations (one-half hour each)
Di sc ussion
Lunch	Open
The topical agenda for Workshop II will be identical, running
from Wednesday evening to Saturday noon. A detailed agenda
will be distributed at each workshop and will show specific
times, coffee breaks, room locations, etc.

(as of 5/22/80)
Mr. Seth J. Abott
Manager Conservation Group
Arco Oil and Gas Company
1086 Hartford Building
400 N. St. Paul
Dallas, Texas 75201
Mr. George W. Adrian
Engineer, Water Quality
California Water Service Company
P.O. Box 1150
San Jose, California 95108
Dr. David Burmaster
Water Specialist
Council on Environmental Quality
722 Jackson Place
Washington, D.C. 20006
Dr. Larry W. Canter, Director
College of Engineering
University of Oklahoma
202 West Boyd
Norman, Oklahoma 73039
Mr. Jack C. Carmichael, Director
Solid Waste Management Division
Texas Department of Health
1100 West 49th Street
Suite T713
Austin, Texas 78756
Dr. Mark Coleman
Head of CSSE's Solid Waste Committee
c/o Water Quality Services
Oklahoma Dept. of Health
1000 Northeast 10th Street
P.O. Box 53551
Oklahoma City, Oklahoma 73152
Mr. Jeffrey L. Dauphin
West Michigan Environmental
Action Council
1324 Lake Drive, S.E.
Grand Rapids, MI 49506
Mr. Bruce DeBrine, Deputy State
Department of Water Resources
1313 Sherman Street
Denver, Colorado 80203
Mr. Walter L.T. Hang
New York Public Interest
Research Group
5 Beekman Street
New York, New York 10038
Mr. Thomas J. Junor
Executive Vice President
Long Island Builders Institute
425 Broad Hollow Road, #425
Melmute, New York 11746
Douglas E, Krings
Senior Environmental Engineer
Mobay Chemical Corporation
Penn Lincoln Parkway West
Pittsburg, PA 15205
Mr. Reginald A. LaRosa
Acting Commissioner
Department of Water Resources
Environmental Conservation Agency
State Office Building
Montpelier, Vermont 05602
Dr. Jay Lehr, Executive Director
National Water Well Association
500 Wfest Wilson Bridge Road
Worthington, Ohio 42085
Mr. William Marks
Assistant Bureau Chief
Environmental Bureau
Department of Natural Resources
Box 30028
Lansing, Michigan 48909

Mr. Don Maughan
Assistant State Water Engineer
Arizona Water Commission
Water Rights Administration
22 North Central Avenue
Suite 550
Phoenix, Arizona 85004
Ms. Hester P. McNulty
Vice President
Boulder County Board of Health
2160 Vassar Drive
Boulder, Colorado 80303
Ms. Phyllis McQuaid
Mayor, City of St. Louis Park
5005 Minnetonka Street
St. Louis Park, Minnesota 55416
Mr. David W. Miller
Senior Vice President
Geraghty and Miller, Inc.
6800 Jericho Turnpike
Syosset, New York 11791
Mr. D. James Miller
Assistant Director of
Environmental Affairs
Freeport Minerals Company
Commerce Building
P.O. Box 61520
New Orleans, Louisiana 70161
Mr. T. Udell Moore
County Judge
212 City County Building
El Paso County, Texas 79901
Mr. Colin Morrissey
Director Dade City
Department of Environmental
Resources Management
909 S.E. First Avenue
Miami, Florida 33131
Mr. Kenneth C. Mueller
Vice President and Assistant
Assistant Manager
Missouri Water Company
11610 Truman Road
Independence, Missouri 64051
Mr. Jerry Mullican
Director of Underground
Injection Control
Texas Railroad Commission
P.O. Box 12967
Austin, Texas 78711
Dr. Evelyn Murphy
Senior Lecturer
Massachusetts Institute
of Technology
Building 9, Roan 534
77 Massachusetts Avenue
Cambridge, Massachusetts 02139
Dr. David Ortman
Conservation Representative
Friends of the Earth
4512 University Way, N.E.
Seattle, Washington 98105
Mr. John Osgood, Chief
Ground Water Management Unit
Ground Section
Division of Water Quality
Pennsylvania Department of
Environmental Resources
P.O. Box 2063
Harrisburg, Pennsylvania 17120
Mayor Paul Redfearn
830 Bonneville
Springfield, Missouri 65802
Mrs. Mary Lou Reed
Route 3 Box 687
Coeurd'alene, Idaho 83814
Mr. Kenneth Rubin
Technical Assistant
U.S. Water Resources Council
2120 L St., N.W.
Washington, D.C. 20037
Mr. Steve Sedam
Ohio Environmental Council
850 Michigan Avenue
Columbus, Ohio 43215
Ms. Fay Sinkin
Edwards Aquifer Protection Assoc.
215 Crescent Street
San Antonio, Texas 78209

Mr. Peter J. Smith
Director, Bureau of Public Water
New York State Department of Health
Empire Plaza "Dower Building
Albany, New York 12237
Mr. Joseph W. Spear, Director
Special Waste Division
John Sexton Contractors
900 Jorie Boulevard
Qakbrook, Illinois 60521
Mr. B. C. Spigner
Chief Hydrologist
South Carolina Water Resources
P.O. Box 4515
Columbia, South Carolina 29210
Mr. Hugo F. Thomas, Director
Natural Resources Data Center
Department of Environmental
Hartford, Connecticut 06115
Mr. James Tripp
Environmental Defense Fund
475 Park Avenue South
New York, New York 10016
Mr. William R. Walker
Water Resources Center
North Main Street
Blacksburg, VA 24060
Mr. Leon Williams, Gouncilman
Fourth District
City of San Diego
City Administrator Building
202 C Street
San Diego, California 92101

(as of 5/22/80)
Mr. C. Steven Allred, Director
Idaho Department of Water
State Office Towers Building
450 West State Street
Boise, Idaho 83720
Ms. Candace M. Ashmun
Executive Director
New Jersey Association of
Environmental Commissions
Box 157
Mendham, New Jersey 07945
Ms. Genevieve Attwood-Ferrari
State Legislator
1216 First Avenue
Salt Lake City, Utah 84103
Dr. Vinton W. Bacon
Professor of Civil Engineering
Room East 332, EMS Building
P.O. Box 784
Milwaukee, Wisconsin 53201
Ms. Carla M. Bard, Chairwoman
Water Resources Control Board
P.O. Box 100
Sacramento, California 95801
Ms. Carole A. Barth
Citzens for a Better Environment
536 West Wisconsin Avenue
Suite 505
Milwaukee, Wisconsin 53203
Mr. Craig Bell
Assistant Director
Western States Water Council
220 South 2nd East, Suite 200
Salt Lake City, Utah 84111
Mr. F. Douglas Bess
Associate Director of
Environmental Affairs
Union Carbide Corporation
Building 3005
P.O. Box 8361
South Charleston, West Virginia 25303
Mr. Carl J. Blabaum, Director
Bureau of Water Quality
Wisconsin Department of Natural
Box 7921
101 South Webster Street
Madison, Wisconsin 53707
Mr. William R. Bryson
Chief Geologist
Oil Fill and Environmental
Geology Section
Kansas Department of Health
and Environment
Building 740, Forbesfield
Tcpeka, Kansas 66620
Mr. Gene E. Cronk, Director
Water and Sewers
111 E. Pennington
P.O. Box 27210
Tucson, Arizona 8 5701
Ms. Maggie Dean
Technical Director
Environmental Affairs
American Textile Manufacturers
Institute, Inc.
1101 Connecticut Avenue N.W.
Washington, D.C. 20036
Mr. Rodney S. DeHan
Administrator, Ground Water Section
Department of Environmental
2600 Blair Stone Road
Twin Towers Office Building
Tallahassee, Florida 32301
Dr. Virgil H. Freed, Head
Department of Agricultural Chemistry
Director of Environmental Health
Science Center
Oregon State University
Corvallis, Oregon 97331

Mr. Frank B. Friedman
Director, Environmental Health
& Safety
ARCO Chemical Co.
515 South Houser Street, Suite 455
Los Angeles, California 90071
Mr. John S. Fryberger, Hydrogeologist
Senior Vice President
Engineering Enterprises, Inc.
1225 West Main, Suite 215
Norman, Oklahoma 73069
Mr. James Geraghty
Geraghty & Miller Inc.
844 West Street
Annapolis, Maryland 21401
Mr. Thomas A. Gildehaus
Vice President
Deere & Company
John Deere Road
Moline, Illinois 61265
Dr. Charles Groat, Director
Louisiana State Geological
Department of Natural Resources
P.O. Box G. University Station
Baton Rouge, Louisiana 70893
Mr. William Home
Study Manger
Hudson River Basin Study
Department of Environmental
50 Wolf Road
Albany, New York 12233
Mr. Charles C. Johnson, Jr.
CC Johnson and Associates, Inc.
8757 Georgia Ave
Silver Spring, MD 20910
Mrs. Josephine Jones, Chairperson
Georgia Clean Water Coalition
10 River Court Parkway, N.W.
Atlanta, Georgia 30328
Mr. Eleanor Kesim
Mayor, City of Elkhart
229 South 2nd Street
Elkhart, Indiana 46514
Dr. Lee Koppleman
Executive Director
Long Island Regional Planning
Dennison Boulevard, Veterans Highway
Hauppauge, New York 11787
Mr. Harry E. LeGrand
Independent Hydrogeologist
31 Yadkin Drive
Raleigh, North Carolina 27609
Mr. Willam L. Lewis
Senior Environmental Advisor
Public Affairs Department
Exxon Company, U.S.A.
P.O. Box 2180
Houston, Texas 77001
Dr. Perry McCarty
Professor of Environmental
Department of Civil Engineering
Stanford University
Stanford, California 94305
Mr. Rose McCullough
715 S. 14th Street
Lincoln, Nebraska 68508
Mr. John S. Moore, Manager
Land and Noise Pollution Control
Illinois Environmental Protection
2200 Churchill Road
Springfield, Illinois 62706

Mrs. Ruth Neff
Tennessee Environmental Council
P.O. Box 11422
Nashville, Tennessee 37202
Mr. D. Monte Pascoe
Executive Director
Colorado Department of Natural
1313 Sherman Street
Denver, Colorado 80203
Ms. Merilyn B. Reeves
Natural Resources chair
League of Woman Voters U.S.
16506 Forest Mill Court
Laurel, Maryland 20810
Mr. Arnold Schiffman, Director
Division of Water Resources and
New Jersey Department of
Environmental Protection
P.O. Box CN 029
Trenton, New Jersey 08625
Dr. William A. Speary, Jr.
Environmental Counsel
Browning-Ferris Industries Inc.
300 Farinia Bank Building
Houston, Texas 77030
Mr. Leonard Wood, Hydrologist
United States Geological Survey
Water Resources Division
12201 Sunrise Valley Drive (411)
Reston, Virginia 22092
Dr. David Zwick
Clean Water Action Project
1341 G. Street, N.W.
Washington, D.C. 20005
Mr. Robert Strasser
11240 S.W. Lynnvale Drive
Portland, Oregon 97225
Dr. Roger W. Strohbehn
Chief of Water Branch
500 Building, 12th Street, S.W.
Room 428
Washington, D.C. 20250
Mrs. Jackie Warren
Environmental Defense Fund
475 Park Avenue South
New York, New York 10016




The Environmental Protection Agency (EPA) is concerned
about the growing evidence that ground water, a resource that
has always been considered relatively pollution free, is widely
contaminated and that the nature of its contamination poses
potential major health problems. Since ground water contamina-
tion is often difficult to detect or control, its prevention,
or at least its early detection, is a crucial environmental
and public health responsibility for the future.
Although there are some existing ground water protection
measures authorized by the Clean Water Act (CWA), an Underground
injection Control (UIC) program recently instituted under the
Safe Drinking Water Act (SDWA) , and a hazardous waste program
developed under the Resource Conservation and Recovery Act (RCRA),
fundamental policies concerning how this nation should ulti-
mately address the broad issue of ground water protection have
not yet been developed. In establishing a ground water protec-
tion strategy, EPA would like to build these new federal pro-
grams in a collaborative effort with state and local governments
who have some ground water protection programs under way. The
broad participation of affected industries, businesses, and
public services; concerned environmentalists; groups with broad
public interest and support; and professionals in related fields
is also encouraged.
Because of the far-reaching effects of the problem, the
ground water protection strategy is being developed based on
broad public debate and participation. Rather than the usual
EPA proposal of a draft strategy and request for public comment,
this approach involves workshop discussions of the policy choices
that appear critical to the formulation of a ground water pro-
tection strategy, after which EPA will propose a strategy (or
set of alternative strategies) for public consideration and
eventual implementation.
The problem at hand is immense and represents decades of
neglect. Protecting ground water is a long-term effort. The
strategy development represents an important step in a lengthy
process which must involve the collaboration of all affected
institutions. In addition, as the country begins to impose pol-
lution requirements on the disposal of waste on or into the land,
it is closing off the last unregulated medium for waste disposal.
Simultaneously one must begin to identify and consider the most
environmentally satisfactory disposal schemes for various

The planning process began in the winter of 1979, when
the EPA Administrator assigned the Office of Water and Waste
Management (OWWM) responsibility for developing a ground water
protection strategy under the direction of the Assistant Ad-
ministrator for Water and Waste Management and the Deputy As-
sistant Administrator for Drinking Water. Administrator Costle
stressed that a ground water strategy should:
•	Look well into the future to assure that the
quality of ground water is protected as a re-
source for future generations;
•	Explore openly alternative approaches to ground
water protection and not be bound by existing
policy or law;
•	Concentrate on broad policy issues rather than
narrow regulatory or technical choices;
•	Fully involve representative state officials
as well as other concerned groups through direct
pa r t i c i pa t i o n ;
•	Stress cooperation and interaction with other
affee ted inst i tut ions; and

Stress the relationships between ground water
and surface waters, including wetlands.
The strategy must also be focused on key issues that are
critical to ground water quality in order to have the most im-
pact. For example, it is not intended to deal directly with
tap water issued, such as current or proposed drinking water
standards or treatment technologies. Likewise, the ground water
depletion issue is not a major focus. While depletion is a cri-
tical ground water issue in many sections of the country, this
strategy will focus on issues related to ground water quality.
It will be important to recognize the problem of ground water
depletion because depletion can contribute to quality problems,
and its management and control can affect the management of pro-
grams related to ground water quality. Nevertheless, it is not
expected that this strategy will deal with ground water deple-
tion as an independent issue.
To fulfill the requirements above, EPA outlined a three
phase approach.

Phase I, which has been completed, involved the
assembling of current information on ground

water use and pollution, state laws and pro-
gram^, and the state of the art in ground water
protection. In addition, numerous groups and
individuals were contacted to elicit ideas on
issues and approaches and to identify knowledge-
able participants for Phases II and III.
Special emphasis was given to obtaining the
suggestions of representative state officials.
•	Phase II will consist of a pair of workshops to
which a small, knowledgeable group of represen-
tative state, local, environmental, business and
industry, public interest, and professional
persons will be invited to explore and analyze
the issues presented in the working papers and
to recommend preferred policies. Out of the
workshops should come a wide range of recom-
mendations for EPA's consideration in the next
pha se.
•	In Phase III a strategy (or alternative
strategies) that reflects the views of the
workshops will be published by EPA in the
Federal Register and widely distributed.
Public hearings on the subject will then be
held in at least five locations throughout
the nation.
The ground water protection strategy should provide:
•	A clear enunciation of the problems and issues
being addressed and the goals and objectives to
be achieved;
•	A greater national recognition and understanding
of ground water problems;
•	A national program with fully defined federal
and state roles;
•	A comprehensive Agency ground water protection
policy that will apply to all programs affecting
ground water from data collection to management;
•	A stronger set of relationships among federal,
state, and local governments; and

• A meaningful short-term action plan and a strat-
egy for dealing with ground water problems over
the long term.
This document is organized into two parts. The first
part—Chapters II and III—describes the nature of the ground
water problem and outlines current EPA programs directed toward
its resolution.
The second part—Chapters IV through VII—describes a de-
cision process for arriving at a strategy and analyzes the major
policy issues that must be considered in selecting the best
strategy. The analysis sets forth decision options and briefly
analyzes each. The options cover four sequential topics: goals
mechanisms to achieve the goals; federal, state, and other roles
and research and development and other implications for near-
term programs.
A set of appendices containing further analyses of partic-
ular issues is also included for background reading by workshop
The options discussed in Chapters IV, V, and VI present a
range of the points of view that were expressed by different
people during the research for this workshop. These options
provide a menu of choices that could be made in developing a
ground water protection strategy. The options are neither ex-
haustive nor mutually exclusive. They are intended as starting
points for discussions in the workshops and may be modified as
participants feel it appropriate. Elements of separate options
may be combined as the work groups identify and formulate the
components of a ground water protection strategy.
The conference will contain six key elements, as follows:

I. Full-Group Discussions—Review
of the Working Papers
Full-group discussions will take place in the main meeting
room at several points during the workshop. The purpose of
these discussions will be to identify and discuss the principal
issues as indicated in this document and other issues as raised
by the workshop participants in preparation for the more de-
tailed discussions that will occur among individual teams.
II. Team Discussions
At several points during the workshop, the participants
will break into four teams. Each team will be expected to
independently select options and develop a tentative position
on the topic assigned.
Ill. Brief Team Progress Reports
At the conclusion of each of these team working sessions,
each team will present to the full working group a five- to ten-
minute report of its tentative position on the given issue.
These reports will not be considered binding on any team. Their
purpose will be to provide an indication of each team's progress
and direction.
IV. Team Preparation of Integrated
Starting in the afternoon of
workshop, each team will be asked
the preceding sessions to prepare
mendations related to the options
the second full day of the
to draw upon its work of
an integrated set of recom-
defined in this document.
V. Team Presentations
On the last morning of the workshop the group will be
joined by members of EPA's ground water policy committee.
Each team will be expected to make a twenty- to thirty-minute
presentation of its recommendations to the full group with
appropriate visual aids. Following each presentation a brief
question-and-answer period will be allowed to answer questions
of substance and clarification.

VI. Final Discussion
After the team presentations, the participants will dis-
cuss the issues raised and the recommendations made. The
workshop will not attempt to reach a consensus on individual
issues. Its focus will be on obtaining a full discussion of
issues and recommendations for EPA1s subsequent use in draft-
ing a proposed ground water protection strategy.


Ground water is the least understood of our major natural
resources. In both science fiction and courts of law it tradi-
tionally has been erroneously described and treated as "under-
ground streams." Despite the general lack of awareness and un-
derstanding surrounding it, ground water is an important source
of the nation's water supply. Use of it has grown sharply
over the years but its availability has decreased because of
pollution and, in some areas, because of depletion.
This chapter, along with the appendices, presents a descrip-
tion of ground water as a resource, including past and future
use projections. It also describes damage that has been done
to ground water by various contaminants and pollution sources,
discusses the difficulty of protecting and cleaning up ground
waters, and outlines what federal and state programs exist that
can address ground water pollution problems.
Ground water has become an increasingly valuable resource
over the past thirty-five years. Ground water withdrawals in
the United States quadrupled from 21 billion gallons per day in
1945 to 82 billion gallons per day in 1975. The increase from
68 to 82 billion gallons per day in the five-year period 1970-
1975 was particularly pronounced.
Most of this increased use can be attributed to agricultural
irrigation. In 1950, 21 billion gallons of ground water were
used for irrigation purposes. In 1975, 57 billion gallons—or
approximately 70 percent of the ground water withdrawn nationwide—
were used for irrigation activities, and ground water constituted
41 percent of the total amount of water so used. Since ground
water is withdrawn primarily for irrigation purposes, the total
amount of it used is bound to be affected by changes in agricul-
tural policy and practices.
Increased energy costd, as they increase the cost of pump-
ing ground water for irrigation purposed, will affect this major
sector of ground water use. Data indicate that for a 300-foot
lift in the Central Valley of California pumping energy costs
increased from $3.30 per acre-foot in 1970 to $12.00 per acre-
foot in 1980. In the short run, such energy price impacts in
the agricultural sector may manifest themselves as an increase

in the amount of dryland or unirrigated farming and as a shift
in the type of crops grown. For example, along the Ogallala
Aquifer in Texas, cotton, a water-intensive crop, is being re-
placed with sorghum and other crops that are less water intensive,
For the future, total ground water withdrawal projections
range from 70 to 100 billion gallons per day in both 1985 and
2000.1 The range is expected to remain the same during this
fifteen-year period because the cost of pumping will serve as
a constraint on the demand for ground water.
Additional background data on ground water and its uses are
provided in Appendices I and II. Included there is information
on the regional levels of ground water use as well as national
statistics on patterns of use.
Ground water can be contaminated by a variety of sources.
The degree of threat depends on the nature (toxicity) and volume
of the contaminant that is generated by a particular site or ac-
tivity, the characteristics of the material underlying the site,
and the particular geological and hydrological conditions of the
area. For instance, a landfill that is underlain by 200 feet
of impermeable clay would pose little threat to an artesian
aquifer beneath the clay, but a landfill located on a permeable
material with a shallow depth to water could pose a serious
threat. Appendices III, IV, and V discuss ground water con-
tamination in detail.
Contamination by Municipal and
Industrial Waste Disposal Sites
Disposal of municipal and industri
a source of serious concern because of
waste, the large number of sites involv
of much of the waste, and the inadequac
to protect ground water at many of the
of the magnitude of this problem vary,
illustrat ive:
• A 1979 study by an EPA contractor indicated
that 32,000 to 50,000 disposal sites may
contain hazardous waste, and that of these
al wastes on the land is
the large volumes of
ecJ, the hazardous nature
y of the precautions taken
sites. While estimates
the following data are
"'"These projections are based on the Water Resource Council's
First and Second National Assessments and ground water data
generated by the United States Geological Survey. (See
Appendix II for a more detailed analysis.)

1,200 to 2,000 could pose potential danger
to public health or to the environment.
• EPA estimates that approximately 57 million of
the 378 million tons of liquid and solid indus-
trial waste generated in 1978 were hazardous
and that this amount will grow by 3.5 percent
each year. About 80 percent of these hazardous
wastes are improperly disposed of in landfills
or lagoons and pose a threat of ground water
Very few land disposal sites are lined and few
have leachate collection systems; studies have
estimated that about 75 percent of all active
and inactive sites leach. Unfortunately, there
are no firm data on the total number of land
disposal sites. Among existing estimates are
these :
—A 1978 Waste Age survey identified approxi-
mately 15,000 active municipal landfills,
of which only 35 percent were in compli-
ance with state regulations.
—A Fred C. Hart Associates' report estimated
the number of active industrial landfills
to be 75,700 and the number of abandoned
sites to be as high as 100,000.
—Another Fred C. Hart Associates' report
estimated that 19,365 sites, either land-
fills or lagoons, are needed to handle the
current stream of hazardous waste and that
50,644 active and inactive sites contain
potentially dangerous amounts of hazardous
wa ste .
The Surface Impoundment Assessment, funded by
EPA and conducted by the states, has identified
24,500 industrial impoundments and 173,000 total
impoundments. Because of the hazardous nature
of much of the waste placed in industrial im-
poundments, states were asked to perform detailed
assessments of industrial sites. Preliminary
analyses of 8,200 industrial sites indicate the
following :
—Most—70 percent—are unlined and possibly
allow contaminants to enter the ground.

—Moreover, 30 percent are not only unlined',
but also overlie usable aquifers and are
on permeable soil; of these, one third are
within one mile of a water supply well.
—About 50 percent hold liquid wastes that
may contain hazardous constituents.
—At 95 percent of the sites no ground water
monitoring is done.
Contamination by On-lot Disposal
Systems and Radioactive Disposal Sites
Domestic on-lot disposal systems also represent threats to
public health. The primary concern in their case is the large
number of sites and the potential for bacteriological and chem-
ical contamination. Recent studies indicate that significant
amounts of organic contaminants have been introduced into ground
water through septic systems. Buried storage tanks are also of
concern because of the nature of the contaminants (primarily gaso
line) and the significant number of such sites in areas of high
population density.
Radioactive waste disposal sites pose a potential long-term
threat to public health. Some ground water contamination has
been associated with leakage from the temporary storage areas
in which wastes are held prior to transfer to permanent sites.
Radioactivity is also associated with the wastes produced by
sources such as uranium mines and mills and by the mining and
milling of phosphates and metallic ores such as copper.
Other Threats
Some sources of contamination endanger public health by
introducing into ground water potentially hazardous materials
that would not normally be detected by a user. Other forms
of contamination make ground water more obviously unusable.
For example, salt water encroachment (often caused by overpump-
age of adjacent fresh water), brine injection wells, and high-
way de-icing salts may cause localized problems in the contin-
ued use of ground water as drinking water and for irrigation.
Abandoned wells can create problems, too, if constructed such
that water in poor-quality aquifers can enter aquifers of good
quality through uncemented well bores. While artificial re-
charge is considered a viable technique in some parts of the
country for conserving ground water supplies that would other-
wise be wasted through evaporation or runoff, there is concern

that recharge of ground water by some types of water (for ex-
ample, treated industrial or municipal waste water) could pre-
clude its use. Recharge using municipal waste water can also
create bacteriological problems that might preclude domestic
Ground water contamination implies more than such threats
to public health. It also involves economic and environmental
costs. Water quality changes induced by major ground water with-
drawals for agricultural activities, for example, can result in
reductions in net economic benefits. For instance, irrigation
can lead to an increase in the salinity of ground water which
in turn can lower crop yields. Similarly caused changes in
ground water quality can also increase the costs for users who
need to treat the water to enable continued use.
Activities related to mining waste disposal and acid mine
drainage pose a threat to ecosystems as well as to certain uses
of ground water. For instance, mine drainage and waste piles
can result in excessive heavy metals in ground water that would
preclude its use as drinking water without major treatment.
A more detailed discussion of such threats to ground water
can be found in Appendices III and IV.
Contamination by Organic Chemicals
Drinking water drawn from the ground has generally been
viewed as a pristine resource, unspoiled by human activities.
Recent information, however, has revealed that many ground
waters are contaminated by organic chemicals. The data are
particularly disturbing in that many of these chemicals are
known or suspected carcinogens. Moreover, they have frequently
been detected at levels that are orders of magnitude higher
than those generally found in surface waters.
As a result of these discoveries, federal and state agen-
cies have increased their monitoring efforts and new data are
being produced continually. Most of this monitoring is concen-
trated in areas where contamination is suspected, making it
difficult to generalize about ground waters. However, it is
clear that a widespread problem exists and that many more cases
will come to light as more monitoring is done.
As a result of these monitoring efforts, at least twenty
communities in Massachusetts have discovered their public water
supplies to be severely contaminated with one or more synthetic
organic compounds: sixteen incidents have occurred in Connect-
icut, twenty-five in Pennsylvania, twelve in New York, and one
or more in each of twenty other states. New Jersey and Califor-
nia have also detected large-scale contamination in ground water.

For example, the municipal landfill in Jackson Township,
New Jersey, was licensed by the state to receive waste water
sludge and septic tank wastes, but it now appears that dumping
of chemicals has also occurred at the site. As a result, ap-
proximately 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 ^g/1) , benzene (330 nq/1) ,
toluene (6,400 /ig/1) , trichloroethylene (1,000 ,ug/l) , ethylben-
zene (2,000 /uq/1) , and acetone (3 ,000 jug/1) .
As of March 1980 over 8,000 chemical determinations for
volatile organic compounds had been performed on well water by
state agencies. While a large number of compounds have been
detected in these and other analyses, chlorinated organic sol-
vents have been found most frequently, sometimes at very high
levels. Several of these solvents have been shown to cause
cancer in laboratory animals.
Most frequently found was trichloroethylene, an industrial
solvent and degreaser which is also used as a septic tank cleaner.
This compound was found in one third of the samples tested, with
concentrations as high as 35, 000 /uq/1. (This should not, however,
be interpreted to mean that one third of the nation's drinking
water supplies contain measurable levels of trichloroethylene:
the state monitoring was concentrated in areas where contamina-
tion was expected, and a representative sample would undoubtedly
show lower levels. Such data, however, are not yet available.)
Other volatile organics frequently found in ground water
include tetrachloroethylene; 1,1,1-trichloroethane; 1,1-dichloro-
ethane, and dichloroethylenes. These data are described in more
detail in Appendix IV.
Strategies to control ground water contamination must take
account of the major differences between ground water and sur-
face water. Compared with surface water contamination, ground
water contamination is much more difficult to detect in a timely
manner and to clean up once discovered. For ground water, it is
also harder to predict the movement of certain constituents with
time. Further, it is extremely difficult, if not impossible at
our current state of knowledge, to analyze changes in ground
water quality as a result of a particular land-use activity.
These difficulties are related both to the physical character-
istics of ground water and to the diversity of means by which
it can be contaminated.

Slow Movement of Ground Water
Although some ground waters have very rapid rates of move-
ment in the feet-per-hour range, such as through limestone, most
have velocities in the feet-per-year range. The slow movement
of ground water can create difficulties because large amounts
of contaminating material can enter the ground water without
detection. For instance, if a monitoring well is located at
or near the point of use and the actual source of contamination
is a long distance away, contamination could continue for many
years before detection.
Ground water flow characteristics are usually predict-
able in that a plume of contaminants is fairly narrow and may
not extend through the entire thickness of the aquifer. If a
basin-wide monitoring program, however, relies on randomly se-
lected wells, detecting contamination in a timely manner will
be almost impossible unless a well happens by chance to be lo-
cated immediately down-gradient to a contamination source. This
fact has important consequences for the design of a monitoring
program, as discussed below. Even more importantly, new manage-
ment techniques will have to be developed to avoid serious pub-
lic health risks which may occur as these plumes enter the area
of influence of drinking water wells.
Monitoring Difficulties
There is currently no data base from which the magnitude of
the ground water contamination problem can be determined. The
large amounts of data gathered by the states and the U.S. Geolog-
ical Survey have generally not focused on the types of problems
that have more recently become the object of concern, particu-
larly hazardous waste disposal and contamination by synthetic
organic chemicals. The data that are available are largely anec-
dotal, that is, based on investigation of particular instances
of contamination, such as those described in Appendices III and
IV, and it cannot be determined with confidence how representa-
tive these cases are. Increased attention to ground water con-
tamination problems is likely to lead to efforts to improve
this data base and, to some extent, to redirect current monitor-
ing efforts.
Ground water monitoring is much more expensive than surface
water monitoring, since it is necessary to drill a well in order
to monitor a new location. In addition, the design of a monitor-
ing system should be tailored to the kind of contamination problem
that is being studied.
For example, localized sources of pollution such as land-
fills and surface impoundments produce plumes of contamination
around the site. Because of the slow movement of ground water,

these plumes will frequently be limited in size (although con-
tinually growing). Therefore, any monitoring plan using wells
scattered over a large area is likely to miss most of them, thus
producing a misleading result. This suggests that the appro-
priate unit of sampling for such a plan is the potentially pol-
luting site, rather than the aquifer. That is, monitoring wells
should be located near the sites and positioned so that they
can detect pollution if it is occurring.
Many such potentially polluting sites either currently have
monitoring wells around them or will be required to drill moni-
toring wells by regulatory programs now being established. This
will make it feasible to select a random sample of such sites
and monitor the quality of ground water in their immediate vicin-
ity. Such a survey would yield systematic and representative
data which could validly be generalized to conclusions about
the extent of pollution from such sources.
Areawide sources like fertilizer use can affect large ground
water areas and they are more easily detected by the conventional
aquifer surveys. Generally, basin-wide monitoring detects a
problem only when contamination has reached a stage where water
quality changes are regional in nature. This is especially true
if the monitoring program relies on wells that are designed for
water supply, particularly if they are of limited depth. There-
fore, building monitoring networks to provide an accurate pic-
ture of changes in ground water quality is expensive and diffi-
cult to accomplish. This is a fundamentally different problem
from monitoring surface waters where access is seldom difficult.
Diversity of Sources of Contamination
Protecting ground water from pollution is further compli-
cated by the varying nature of the sources of pollution. These
sources can be classified according to industry involved, type
of waste, or regional distribution.
Localized sources, though numerous, are subject to control
on a site-by-site basis. Generally, contamination from such
sources occurs in a localized area around the site. Pollution
from areawide sources, such as agricultural practices and high-
way de-icing, often covers a wide area and is less subject to
site-specific controls. Controls may involve changes in opera-
tion (for example, a "best management practice" such as con-
trolled use of fertilizer) rather than direct expenditures on
control technology. See Appendix V for a discussion of the
major sources of ground water contamination.

Restoration or Cleanup
If a large area of contamination is found, it may be ex-
tremely difficult and expensive to institute an aquifer clean-
up program. Cleanup is difficult because of problems in defin-
ing the area of contamination; because of the large amounts of
water that have to be removed, treated, and returned to the
aquifer; or because of the difficulty of changing hydraulic
gradients to control the direction in which the unwanted con-
taminants are moving. In contrast, surface waters move quite
rapidly and generally flush an area clean in a relatively short
time once the discharge of pollution has stopped.
Numerous federal laws deal in some way with ground water
management or protection, yet neither these laws nor existing
state programs fully address the range of problems presented by
ground water pollution. They are a patchwork of efforts that
fail to cover some of the most serious problems. Appendices
VU, VII, and IX document each of these federal laws and pro-
grams, and Appendix VIII discusses current state ground water
management programs.
A brief summary of the major sources of ground water con-
tamination and the current approaches to their control is pre-
sented in Table II-l. In most instanced, for each major source
of contaminatiori, there is an individualized approach to control
on the part of stat£, local, and federal agencies.
Federal Efforts
EPA has recently turned its attention to ground water pro-
tection. Despite several specific references to ground water
in the Clean Water Act (CWA), Congress did not explicitly confer
federally enforceable authority in the sections of that Act.
Courts narrowly interpreted the Act's ground water provisions,
and the Agency itself, for many reasons—lack of resources and
pressures to deal with surface waters among them—deferred ac-
tion that would protect ground waters. Ironically, in some
situations Agency actions resulted in increases in ground water
pollution by diverting pollution from surface waters to the
In recent years some provisions of the Clean Water Act have
been used to increase ground water protection. Most notable is
the Water Quality Management program required by Section 208 of
the CWA. It served as the catalyst that enabled many states to
develop ground water management programs and particularly to


Table II-l
Sources of
Primary Basis of Current Control Efforts
Waste Disposal Sources

Landfills, Dumps, and
Surface Impoundments
Federal regulations and state delegation under RCRA
Mining Wastes
Previously BMPs for active mines and little for abandoned mines,
1977 Surface Mining Act initiated permit and reclamation program
On-lot Waste Water
Disposal Systems
Generally local or county control under state health regulations,
with evaluation of alternatives under 208 funding
Radioactive Wastes
NRC authority, sometimes delegated to states
Sludge Management via
Land Spreading
BMPs developed at federal level
Underground Injection
Wei Is
New UIC program of federal standards and state enforcement under
the Safe Drinking Water Act
Abandoned Sites
Superfund (1f enacted) would begin to provide federal assistance
Non-Disposal Sources

Abandoned Wells
Limited state programs, some expansion of program under UIC
Accidental Spills
Federal advice available, sometimes assistance; RCRA and Section
311 of the CWA will extend authorities and funding
Agricultural Practices
Primarily recommended BMPs, with selected regulations under FIFRA
and CWA
Artificial Recharge
BMPs under development by EPA and selected cities
Highway De-icing
BMPs at state levels
Petroleum Exploration
and Development
State programs in past, now UIC and RCRA add federal standards for
injection wells and lagoons
Underground Storage
Tanks and Pipelines
Some local or state standards for construction, few inspection

Increased Salinlty
State and local efforts
Salt Water Encroachment
State and local efforts
Source: Appendix V, "Analysis of State and Federal Programs by Pollutant Source."
experiment with innovative ways of dealing with non-point source
problems. Grants to the states for pollution control programs
provided under Section 106 of the CWA, and the creation of co-
ordination mechanisms such as state/EPA agreements, have also
strengthened state abilities in ground water protection.
Nonetheless the major elements of the CWA have not thus
far been directed to ground water protection. For example,
EPA has construed Section 303 (Water Quality Standards) to
apply to ground water only in unique and narrow circumstances.
Accordingly, it has not developed a program of nationally con-
sistent ground water quality standards. Further, there are

conflicting judicial opinions as to EPA's authority to issue
NPDES permits related to ground water protection.
Several provisions of the Safe Drinking Water Act (SDWA)
relate to ground water protection. One of these creates the
Underground Injection Control program which establishes minimum
standards for injection well design and operation and state
program requirements. The Act provides for regulation of in-
jection wells by permit or by rule. EPA regulations specify
procedural and technical requirements for the program, includ-
ing construction, operating, and monitoring requirements for
injection wells. The Act envisions state assumption of the
primary responsibility for enforcement of the standards. A
limiting factor with respect to this program is that it is in-
tended to protect ground waters that are current or potential
sources of drinking water, thus only restricting pollution in
single-use sources and disregarding other uses and ecological
Another provision of the SDWA is the sole-source Aquifer
Protection Program (Section 1424 .e.) which provides a mechanism
for state, local, or regional agencies to petition EPA to pro-
tect recharge zones of special aquifers by designating them
sole-source aquifers. A limiting factor of this provision is
that it only protects recharge zones from the federally funded
projects that might contaminate them. Non-federally funded
projects are not regulated. Despite this and other limitations,
it is the only EPA program that uses recharge zone protection
as a ground water management tool.
The Resource Conservation and Recovery Act (RCRA) of 1976
provides for control of the land disposal of municipal waste
and the generation, treatment, storage, and disposal of haz-
ardous waste. EPA regulations provide for a manifest system
to track hazardous wastes from the point of generation to the
ultimate disposal site. They also provide for the permitting
of hazardous waste management facilities, including technical
requirements for disposal sites. This Act also provides for
federal standards for disposal of nonhazardous waste?, but these
standards are not federally enforceable. Again, this Act pro-
vides for delegation of enforcement responsibility to the states.
The newly launched UIC and RCRA programs provide signifi-
cant funds for state grants, which may greatly improve the abil-
ity of the states to fund ground water protection programs.
The Surface Mining Control and Reclamation Act of 1977 under
the administration of the Department of the Interior provides
authority to control surface mine pollution; protection of ground
waters is explicitly included. The Uranium Mill Tailings Radia-
tion Control Act of 1978 mandates EPA to establish radiation

standards for uranium mill tailings and the Nuclear Regulatory
Commission to implement and enforce the standards.
Other EPA laws such as the Toxic Substances Control Act
(TSCA) and the Federal Insecticide, Fungicide, and Rodenticide
Act (FIFRA) have the clear potential in certain circumstances
to ban substances that are of particular danger. Finally, EPA
has proposed Superfund legislation which is now under consider-
ation in the Congress. This authority, when passed, will sup-
port the cleanup of abandoned hazardous waste sites. More dis-
cussion is included in the appendices.
Thus, federal programs provide for explicit, well-developed
regulatory approaches for some threats to ground water quality
and devote only incidental attention to others. Hazardous waste
disposal and underground injection are well covered by mandatory
federal programs that are now entering the implementation phase.
Federally funded projects in the recharge zones of designated
sole-source aquifers are regulated, but other projects in those
areas are not. Potential ground water impacts of surface mining
and the uranium fuel cycle are covered by programs designed to
deal with those activities comprehensively. EPA has used Sec-
tion 208 of the Clean Water Act to encourage states to develop
ground water management programs. But the other sources of
ground water pollution, discussed above and in Appendix V, are
not subject to federal control programs.
State Efforts
The state governments have been faced with a difficult
challenge for many years in the area of ground water quality
management. The combination of the technical complexity of
the problem, the competition within state governments for admin-
istrative and financial resources, and the lack of any central
coordinating federal program have all made significant progress
in the area difficult. Some states have been able to achieve
notable progress, while others have not been able to win adequate
support to make ground water protection a high priority.
Approximately 60 percent of the states rely on general laws
as the basis for ground water protection. Laws specific to par-
ticular sources of ground water pollution or related activities
exist only sporadically, are often not explicitly designed to
protect ground water quality, and commonly include grandfather
clauses that exempt existing pollution sources. Laws that do
exist to protect ground water from specific sources of pollution
are not generally applied in a coordinated program aimed at
ground water protection but implemented by diverse agencies
whose primary responsibilities are not directed at ground water

Few if any states have a centralized program to protect
ground water from all major sources of contamination. Typically,
a public health agency has (or shares) authority over on-lot
waste water treatment. An environmental agency will have author-
ity over most other ground water pollution source^, although in
several states the authority for individual sources of contami-
nation belongs to more than one agency (that is, oil- and gas-
related issues are under a separate authority from industrial
waste sites) . A third agency may have responsibility for ground
water quantity issues. In addition to the state agencies pos-
sessing regulatory authority, other agencies such as a state
geological survey or the state soil conservationist are involved
in data collection or in providing technical assistance.
There are attempts in several states to coordinate efforts
through multi-agency advisory committees or task forces. How-
ever, many relationships that exist among the personnel of vari-
ous state agencies are informal, and subject to the traditional
forces of turf, personalities, and available resources.
State staffing and budgetary limitations will, for the most
part, determine the ultimate form and organization of ground
water protection efforts. It appears that no state has the re-
sources or funding it needs. For example, several states have
septic tank regulations or regulations on oil-well drilling but
insufficient manpower to adequately enforce them. A broad extra-
polation from data collected regarding the number of person-
years currently involved in state ground water protection pro-
grams indicates that about 525 person-years of professional/
technical effort are expended each year by all states.
A state's efforts in the protection of its ground water
and its commitment in resources is a function of whether it per-
ceives a problem. The level of concern varies tremendously be-
tween states. In some instances a state may not, at this time,
be a heavy ground water user and may be complacent concerning
the issues. Other states—New Jersey and Washington, for
example—are developing fairly large staffs devoted to ground
water issues and appear to be in the forefront in developing
innovative approaches to ground water protection.
In order to round out the general information needed to
give a reasonable picture of existing state ground water protec-
tion program^, ground water standards were selected as one bar-
ometer of state programs. Five states have standards in effect,
six are currently reviewing or processing proposed standards,
and another seven are currently involved in drafting ground
water quality standards. Thus1, nearly 40 percent of all states
are either taking or have taken steps to develop specific stand-
ards to protect ground water quality. However', ground water
standards may be very different from state to state?, with each

state emphasizing the parameters and levels needed to ensure
its own protection. Further discussion can be found in Ap-
pendix VIII.
In additiori, major sources of ground water pollution vary
from state to state. For example, in Washington and Vermont,
on-lot waste water treatment is considered the most severe prob-
lenf, while in New Jersey, surface impoundments that are leak-
ing toxic wastes are the greatest source of pollution. Programs
also vary substantially between states. In regulating septic
tanks, programs vary from requiring permits to inspecting con-
struction to regulating system installers. Attitudes toward
land-use controls also vary. In Washington, sensitive aquifers
and recharge areas have been identified, and courts have held
the right to deny permits for septic tanks on these aquifers
based upon ground water contamination. In Vermont, land-use
controls are seen as the last resort.
Information essential to proper management of the ground
water resource is also lacking in many states. In a prelimi-
nary inventory, six states were identified as having substantial
knowledge of their ground water resource. Nine states are in
the process of inventorying. Five states have a particular
inventory, and twenty-seven states have no systematic inventory.
In additiori, there are growing political pressures in most
states to limit expanding state bureaucracies. There is a trend
toward establishing limits on budget and personnel increases,
particularly in areas supported by federal funds. A more de-
tailed discussion of state ground water management programs can
be found in Appendix VIII.
Effect of Federal Programs
A number of federal programs are being delegated to the
states for management over the next two to five years. Some
of these directly deal with ground water management--the UIC
and RCRA program^, for example. Other programs much more indi-
rectly related include the construction grants program for the
construction of secondary treatment plants. The delegation of
existing environmental programs has tremendous implications for
state governments. The principal impacts will be to impose mini-
mum federal standards as established in the statutes and to pro-
mote significant new levels of federal grant assistance.
Thus it is clear that there is a growing interest in and
concern about ground water management on the part of the states.
Many state agencies are involved in ground water protection.
Existing resources, data bases, and available expertise are ex-
tremely limited. As a result, there will be fierce competition
for resources in state governments.

The establishment of the following research categories
first took focus in the fall of 1976 on the advice of a group
representing various EPA Offices, universities, the USGS, state
agencies, consultants, and the National Water Well Association.
These have subsequently 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 Atmos-
phere 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
E'unding levels for such research were highly restricted
until recently but are now being expanded significantly. Each
of the research categories is discussed in detail in Appendix X.


A national strategy is not wholly synonymous with a federal
strategy. Rather, it implies a consensus on the part of all
concerned--federal, state, and local governments; business;
industry; and others--as to what problem is to be addressed;
what objectives are to be achieved in alleviating the problem;
and what constitutes the most effective, efficient, and feasible
way of achieving those objectives. Central to the development
of a national strategy is specification of the roles the partic-
ipants are to play. The type and extent of these roles depend
on many factors—history, current law, capacity to provide needed
resources, and the degree to which the problems are being ad-
dressed through current efforts, among them.
For ground water protection, EPA has in mind both a national
and a federal strategy. Obtaining a national perspective will
ensure the development of a federal strategy that is relevant to
and supportive of related efforts, most particularly the efforts
of state and local governments. It will also serve as a response
to the mandates of the President's June 6, 1978, Water Policy
Message, which directed federal agencies to expand federal-state
dialogue and cooperation on ground water issues. The strategy
should clearly delineate the larger context in which EPA works—
on the federal level and with state and local governments—and
provide the framework within which EPA decision making on ground
water protection can take place.
Strategies imply choices—from the broadest determination
of goals and objectives and alternative courses of action to
implementation of the chosen course through laws, regulations,
and resource devices.
For the purposes of this workshop, this series of choices
will be dealt with as follows. First, the major strategic issues
that emerged in Phase I of the planning process will be identi-
fied, analyzecT, and discussed. Then, the workshop participants,
in four groups of ten persons each, will be asked to carefully
look at the alternatives, add new ones, discard those thought
unworkable, and recommend the strategy choices considered most
appropr iate .

A strategy for ground water protection must include defini-
tion of each of the following elements:
• A national goal for the protection of ground
water ;
A management process for setting priorities
for regulatory and other actions under the
assumption of limited resources;
An appropriate set of control mechanisms based
on considerations such as cost effectiveness
and technological and political feasibility;
The roles federal, state, and local govern-
ments are to play in carrying out aspects of
the strategy;
The research and development needed to support
these mechanisms and roles; and
A set of action steps for the short term and
one for the long term (recognizing that future
actions are based on research) , including
resource requirements.
Each of these elements will be discussed during the work-
shop, approximately in the sequence in which they are listed
above. Work groups will discuss them and make recommendations
in each area. The final strategy recommended by each work group
will represent a pulling together of the various recommendations
into one overall statement.
Strategic options for each of these elements are detailed
in subsequent chapters. Table III-l summarizes those options
in four columns, corresponding to the first four elements of a
strategy as listed above. The various columns in the table re-
flect the sequence of steps that the workshop participants will
follow to develop their recommendations. First, teams will dis-
cuss goals and select the one that they recommend as the goal
for a national ground water protection strategy. Next, teams
will address the two topics under the general heading "Mechan-
isms." They will be asked to select one or more of the options
(or develop additional options) under both topics—management
approach and technical requirements. Finally, participants will
discuss federal, state, and local roles in implementing the
strategy and will select one or more of the options provided
(or develop an additional option).
As each team selects options in the columns across Table
III-l, it will define a unique potential strategy for ground
water protection. The choices in various columns must relate
111 -2





Management Approach
Technical Requirements
Federal/State/Local Roles
(select one)
(select one or more)*
(select one or more)*
(select one or more)*
• To protect all
• Uniform Require-
• Best Management
• States take primary
ground waters at
ments Everywhere (p. V-3)
Practices (BMPs) (p. V-9)
responsibility for imple-
their present levels

mentation of federally
of quality (i.e.,
a Classification of
• Technology-Based
developed national
nondegradation) (p. IV-2)
Ground Haters (p. V-4)
or Effluent
standards (p. VI -3)

Standards (p. V-10)

• To assure that all
• Classification of

• States prepare and
ground waters are
Contaminants (p. V-5)
• Ground Hater
submit program
protected everywhere

Qual ity
plans for federal ap-
up to sane specified
f Classification of
Standards (p. V-1I)
proval in response to
level (e.g., a drinking
Sources of

federal minimum require-
water standard) (p. IV-3)
Pollution (p. V-6)
• Economic Incentives
ments (p. VI-4)

and Other
• To protect ground

Approaches (p. V-12)
• States prepare indiv-
waters to the levels

idual program plans con-
necessary for pro-

sistent with broad
jected future

federal guidelines,
uses (p. IV-4)

subject to federal

approval primarily on
• To protect only

procedural grounds (p. VI-5)
those ground waters

that are used as

• State and local govern-
drinking water

ments set and enforce
sources, and to

standards consistent with
rely on monitoring

broad federal goals; the
or treatment for

federal government pro-
use of unprotected

vides technical assis-
ground waters (p. IV-6)

tance and support (p. VI -7)

• States develop plans

and programs; the federal

government provides sup-

port and technical assis-

tance only (p. VI-8)
Note: Page numbers following each option indicate location of discussion in text.

~Select or develop one option, or select more for different categories of problems, etc.

to one another logically, in the context of the strategy, but
there is no predetermined correspondence of options in one col-
umn to those in another; any management approach could at least
theoretically be combined with any technical requirement, and
so on. Any horizontal path through the table, from an option
in one column to some other option in each of the other columns,
will define a potential strategy.
For illustrative purposes two scenarios of potential strat-
egies are described below. These can serve as examples of the
ways different options from Table III-l can be combined to de-
velop strategies. Although these scenarios are purposefully
sketchy, they can also serve as examples of the format in which
teams might present their recommendations to the full workshop.
I. Goal
• To assure that all ground waters are protected
everywhere up to some specified level.
II. Management Approach
• Classify sources of pollution, with an emphasis
on industrial sources.
III. Technical Requirements
•	Technology-based standards for industrial sources
of pollution (e.g., hazardous waste sites,
landfills, injection wells).
•	Strict requirements for new sources; require-
ments for existing sources constrained by
•	Opportunity for local case-by-case variation
based on engineering and hydrogeological con-
•	Limited exceptions allowed for some standards
(for example, sole-source aquifers, exempted
aqui fers) .

Federal, State, and Local Roles
•	The federal government sets uniform minimum
technical standards for major sources and
specifies conditions for exceptions.
•	States that accept responsibility for the pro-
gram apply standards to individual facilities,
write permits, and undertake inspection and
enforcement roles.
•	States may adopt standards which are more
stringent than federal standards.
V. Implications for the Near Term
•	R&D is needed to support the technology-based
standards for specific sources.
•	Guidance from EPA to states is needed on how to
administer variances.
•	Personnel staffing and training is needed for
writing permits, performing inspections, and
conducting enforcement actions.
VI. Pros and Cons
•	straightforward to administer.
•	Similar in concept to successful air and surface
water pollution control programs.
•	Average level of protection will be too little
in some areas, too much in others.
•	Does not take advantage of siting as a control
•	Neglects areawide sources.

I. Goal
•	To protect ground waters to the levels necessary
for projected future uses (considering the eco-
nomic and social value of use versus protection).
II. Management Approach
•	Basic premise is that water quality degradation
will be allowed in some areas while strict con-
trols will be applied in other areas.
•	The central element is classification of ground
waters according to use. Ground waters would be
classified into three or four use categories
depending on their present quality, the avail-
ability of alternative water supplied, and the
value of other uses.
•	Each classification would have an associated
regulatory framework that could vary from state
to state.
III. Technical Requirements
•	Best management practiced, through siting', would
be a major aspect of the control strategy for
new sources. Nondegradation (no new sources)
might be appropriate for the highest ground water
classification category.
•	This approach relies on the ground water planning
process (including public participation) to ar-
rive at and implement appropriate levels of control.

This allows but does not require numerical ground
water quality standards.
IV. Federal, State, and Local Roles
• States and local institutions must design and
implement ground water classification schemes
and associated regulatory frameworks.

•	Control strategies will vary considerably from
area to area, reflecting differences in the
importance of ground water and its uses around
the country.
•	The federal government will provide technical
assistance on ground water classification and
other topics, and require and approve state
plans largely on procedural grounds.
Implications for the Near Term
•	R&D is needed to provide technical support for
ground water classification systems by state
and local governments.
•	Guidance is needed from EPA to the states on
current basis for classifying ground waters.
•	Planning guidance and assistance is needed from
EPA to the states.
•	Personnel staffing and training in states for
planning and program implementation is required.
Pros and Cons
•	Allows tailoring of programs to local condi-
tions. Forces weighing of social values
•	Takes advantage of siting controls.
•	Places much greater burden on both the resource
and institutional capacities of states and
•	Many states presently lack the ability to carry
out such a program.
•	Previous programs along these lines have had
mixed results.


Selection of a goal related to ground water protection is
the necessary starting point for the determination of a national
ground water strategy. The term "goal" is used here in the
sense of a broad mission or an overall statement of purpose.
The recommended goal should thus encompass the whole of what
the ground water strategy aims to accomplish.
The goal statements described herein were variously advo-
cated by those interviewed in Phase I of the strategy develop-
ment. They should be evaluated in a discussion that is largely
independent of considerations of how the goal is to be reached--
that is, through what management and regulatory mechanism^, by
whorrf, and in what time frame. These are subjects of following
In recommending a goal for the ground water strategy, it
is important to be realistic. One must take into account, for
example!, the competing national interests that will be affected.
There is always some cost, economic or other, to protecting any
natural resource. There is also a social cost, perhaps long
term, to not protecting such a basic natural resource as ground
water. The recommended goal should thus reflect an appropriate
balancing of such interests.
The four alternative statements of the national goal for
ground water protection identified in Phase I are the following:
•	Option 1—To prptect all ground waters at their
present levels of quality (i.e., nondegradation).
Protect all ground water from any further degra-
dation^ and possibly attempt to restore some
aquifers that are already contaminated.
•	Option 2—To assure that all ground waters are
protected everywhere up to some specified level
(e.g., a drinking water standard). Limit ground
water contamination to maintain this quality
level, perhaps.with reference to some desirable
drinking water standard (drinking water presum-
ably being the socially most important category
of water use) .
•	Option 3—To protect ground waters to the levels
necessary for projected future uses. Protect
ground water based on use', and perhaps project

uses based on population forecasts, availability
of surface water, and present ground water qual-
ity. This would include making some tradeoffs
between ground water protection and other activ-
ities. Allow contamination to levels consistent
with anticipated ground water uses.
•	Option 4--To protect only those ground waters
that are used as drinking water source^, and
to rely on monitoring or treatment for use
of unprotected ground waters. Do not protect
waters that are not now, or will not in the near
future be, drinking water sources. Allow their
contamination and rely on monitoring or treat-
ment technologies to render the water usable if
and when it is needed.
These option^, and others which could be proposed', should
be measured against general standards of feasibility and
adequacy before being endorsed. Some of these general criteria
are suggested in the following list:
•	Is the goal attainable?
•	Will the goal assure reasonable availability
of ground water for future uses?
•	Is the goal generally feasible*, from technical',
economic', and political perspectives? (These
will be dealt with in more specific terms in
later chapters.)
•	Is the goal consistent with the nation's other
environmental goals?
Each of the major options for a goal and its supporting
rationale are described below.
This goal represents the strongest view of protecting
ground water as a valuable and irreplaceable asset. It focuses
on total control of all sources of contamination and includes
the possibility of restoring some polluted aquifers.
Advocates contend that only with such a strong goal will
adequate ground water protection be accomplished. Representa-
tive comments in favor of this goal are the following:

"Water is essential to human life. With surface water
being extensively used in many areas of the United
Stated, protection of ground water may be essential
to future populations."
"Ground water contamination is the most subtle and
dangerous form of pollution. We can't see, smell,
or sense it and we can barely monitor it. It lasts
for decades, maybe centuries, and may prevent future
generations from having a source of potable water."
Those opposing this goal typically comment:
"In many areas, ground water will never be needed be-
cause surface water supplies are abundant or the
areas are uninhabited. Why force businesses to close
or incur higher costs to protect something that will
never be used?"
"In oil field areas, additional petroleum production
is far more important than ground water quality. Be-
sides, the water may already be unusable."
This goal focuses on the fact that any individual area
of ground water may be needed at some time. Although advo-
cates concede that a particular aquifer may be used for many
different purposes, they insist that aquifers should be pro-
tected to a specified quality level. That quality level
would presumably be high enough that most, if not all, major
water uses would be compatible with it.
Some supporters of this goal advocate using some appropri-
ate drinking water standard as the basis for the uniform level
of protection. Reference to such a standard might be based in
part on the assumption that drinking water is the socially most
important water use.
Typical comments in favor of this option are the following:
"We can't predict where population centers will be, or
how adequate surface water quality and quantity will
be, a hundred years from now. Since we cannot be sure
of future ground water need£, we should ensure that
all ground water is protected to a desirable quality
1 ev el ."

"Since we really don't know what our future pattern
of ground water uses will be in the long term, we
should protect ground waters to a single set of
standard s
Those opposed to this statement of the goal tend to view
maintaining a single quality level everywhere as unrealistic,
especially in areas where future use of an aquifer is deemed
unlikely. Examples of ground waters that are not expected to
be used are those in the sulfur fields in southern Louisiana^
and aquifers in areas with abundant high-quality surface water
supplie s.
Those opposed to this option cite views such as these:
"Water quality standards are changing every few years.
How can we know now what we'll consider safe 50 or
100 years from now?"
"We see water treatment technology as changing rap-
idly. Rather than have to protect ground water every-
where, we may be able to rely on technology to treat
water when and if we need it."
"We have to be discriminating. We can't afford to
protect water everywhere. We have to single out
the places where it's most important and focus our
efforts there."
This goal relies on forecasts of anticipated water use
and suggests that ground water quality be allowed to deteri-
orate to levels consistent with those anticipated uses. Fore-
casts logically consider population projections?, land-use pat-
tern^, industrial expansion plan3, and agricultural needs, which
are then translated into anticipated ground water demands.
Different uses require varying levels of water quality.
Therefore, the necessity for controls can depend significantly
upon the intended uses. Examples of major use categories are
•	Drinking water
•	Irrigation
•	Source for surface stream flow

• Livestock drinking water
•	Industrial cooling water
•	Industrial process and other water use
•	Mining
•	Other energy-related uses (e.g., coal slurry)
This option also implies that tradeoffs will have to be
made between ground water protection and other activities. It
acknowledges that certain industrial and other activities may
be of higher priority than ground water protection and, though
they may pollute aquifers, should perhaps be continued based on
a societal judgment of priority. Frequently cited high-priority
activities are energy production, highway de-icing, and agri-
cultural practices related to irrigation return flow and fer-
tilizer use.
This option also provides the opportunity to build in flex-
ibility in the definition of ground water use and in defining
hyd rolog ical , geological, and climatic conditions, etc., which
will permit accommodation of regional variations.
Those favoring this option feel that since some uses re-
quire higher quality waters than other uses, and because ex-
pected uses can be forecast, ground water protection standards
should be set according to predicted uses. In support of this
option they comment:
"This goal is flexible and responsive to local and
regional needs. It strikes a good balance between
protecting ground water and setting ground water
quality goals that are unrealistically high."
"We should enable some polluting activities to continue
where it won't affect future uses, as long as we
monitor and control those activities."
Those opposing this goal tend to rely on the arguments
supporting Options 1 and 2 above. Others also cite such
concerns as these:
"Predictions of the future are almost always wrong.
We may be endangering our only drinking water sup-
plies in some areas when we permit degradation
below drinking water standards."

"Twenty years ago you'd never have guessed there'd be
a Lake Havasu City out in the desert in Arizona.
That's where the London Bridge is now. How can you
forecast where water will be used and where it won't?"
"We know so little about ground water. It would be
impossible to set appropriate standards and to con-
trol and monitor polluting activities. It just
wo uldn't wo rk ."
The supporters of this goal prefer a limited governmental
program and would restrict ground water protection to waters
that are now, or in the near future will b£, drinking water
Under this goal contamination of non-drinking water sources
would be allowed. Monitoring could be used to detect whether
contamination has spread to any areas where it would affect
uses. Treatment technologies would be utilized if ground waters
became too contaminated for other desired uses. Typical views
favoring this goal are the following:
"Economic activity is this country's lifeblood. To
interrupt it where ground water protection is un-
necessary would be counterproductive."
"Let's minimize federal red tape. Where industry is
not damaging ground water that is needed for other
purposed, why add requirements like monitoring to
meet quality standards?"
"Let's not subsidize industries that want to use
ground water. If they are going to use it, then
they can bear the cost of treating it to the level
that meets their needs, just like they would have
to if they were on a major river."
"Why pay a substantial cost to treat all the water
or waste we put into or onto the ground when we
end up needing only a very small fraction of the
ground water? Why not just pay to treat the much
smaller quantity of ground water we use?"
Those opposing this goal favor one of the first three op-
tions and cite views such as those reported in support of them.

They also offer the following concern:
"Allowing significant contamination of any ground
water particularly with toxic and hazardous materials
is an almost irrevocable decision since restoration
or exotic treatment before use is economically or
technically infeasible."


This chapter deals with the range of governmental approaches
available for protecting the nation's ground water resource.
The range is considered in the broadest sense to cover all types
of requirements, including recommended management practices,
engineering or technological standards, waste disposal regula-
tions, and even economic incentives.
The focus of this discussion is on the mechanisms that could
be utilized to achieve the goal or goals that arise out of evalua-
tion of the previous chapter. It is separate and distinct from
any consideration of the roles of federal, state, and local
agencies. Many of the mechanisms could be developed with either
the federal or state government assuming primary authority for
certain key aspects of the program. This chapter, however, is
concerned solely with the management and technical approaches;
potential federal, state, and other roles are dealt with in
Chapter VI.
The management and technical mechanisms which establish
the framework for protecting ground water can embody much flex-
ibility. Different mechanisms could be used to deal with dif-
ferent sources of contamination, for example. These mechanisms
could also provide flexibility in dealing with different hydro-
logical, geological, and climatic conditions and thereby accom-
modate regional differences.
The discussion of mechanisms herein is divided into two
major sections. Any strategy for ground water protection must
include a position on each:
•	Management Approach. A consideration of whether
regulatory standards should be applied uniformly
across all regions, industries, and types of con-
tamination. If not, then how should variations
be incorporated?
•	Technical Requirements. A discussion of the range
of approaches to encouraging or requiring technical
The following options for each of these sections were identified
in preconference discussions by EPA:

Opt ions
Ma nag ement
1.	Uniform Requirements Everywhere
2.	Classification of Ground Waters
3.	Classification of Contaminants
4.	Classification of Sources of Pollu-
Techn ic al
Requi rements
1.	Best Management Practices (BMPs)
2.	Technology-Based or Effluent
3.	Ground Water Quality Standards
4.	Economic Incentives and Other
To facilitate work group discussion and evaluation of these
options, they are further described below. It should be remem-
bered that these options are neither mutually exclusive nor total-
ly exhaustive.
There are wide-ranging opinions as to whether require-
ments for ground water protection ought to be uniformly applied
throughout the country or varied to accommodate local conditions.
The range of opinion comprises four major management options:
•	Option 1—Uniform Requirements Everywhere. En-
sure that the requirements, whatever they are,
are uniformly applied everywhere, regardless of
differences in geological conditions, uses, and
alternative water sources.
•	Option 2—Classification of Ground Waters. Differ-
entiate control requirements on the basis of ground
water classifications that reflect the intended use
of ground water in a specific area. The classifica-
tions could be based on aquifer vulnerability (that
is, geology and hydrology), quality, present and
projected uses, and the availability of alternative
sources of water.
• Option 3—Classification of Contaminants. Establish
priorities for various types of contaminants. As
with current distinctions between "conventional" and
"priority" pollutants in effluent standards, the po-
tential contaminants of ground water could be clas-
sified, for example, according to toxicity, adsorp-
tion in the soil, and long-term fate.

• Option 4--Classification of Sources of Pollution.
Determine priorities for protection based on some
classification of sources of contamination. Sources
could be categorized by type of facility, such as
surface impoundments, or by industry. Classifica-
tions of high- and low-priority sources could be
based on expected volumes, chemical composition,
and method of waste disposal.
Each of these options and its supporting rationale are
described below.
Option l--Uniform
Requirements Everywhere
Supporters of this position tend to believe that control
requirements ought to be applied uniformly everywhere in the
country. To them, neither the present availability of adequate
surface waters nor the lack of projected ground water uses in
an area provides justification for controlling sources of pol-
lution in some areas differently than in others.
Some advocates of this option voice concerns about equity,
and do not want strict controls imposed on some plants in an
industry and not on others.
Representative comments in support of this option include
the following:
"We are concerned about ground water protection as a
critical environmental and public health issue for
the future. We must protect this critical resource
everywhere for future generations."
"We cannot afford to allow variation in our program of
ground water protection because the significant ad-
verse effects of contamination often do not show up
until ten or twenty years later. Also, once ground
water becomes contaminated^ it remains so almost
The principal arguments put forth against this option gen-
erally are that it is unrealistic and uneconomical. This option
would require strong protective measures everywhere even though
only some areas of the country warrant them. A typical comment
of this type is:
"It just doesn't make sense to protect ground waters
that may already be polluted", to the same degree as
fresh water is protected somewhere else."

Option 2--Classification
of Ground Waters
This approach would establish priorities for ground water
protection on the basis of local geological and hydrological
conditions and the importance of specific ground waters. Its
advocates contend that these characteristics are sufficient to
distinguish between places where ground water protection should
be strict and those places where it should be relaxed. Such
priority designations could be the basis for restrictions on
the types of activities, such as mining or waste disposal, that
would be allowed in the vicinity of ground waters of certain
classi fications.
One input to the classification of a ground water zone
could be the physical conditions that provide some degree of
natural protection from contamination. These would identify
particularly vulnerable situations as candidates for strict
controls. Data could include rates of ground water movement
and replenishment.
A second input to such classification could be the ground
water's intrinsic value in terms of yield, water quality, and
the availability of alternative water supplies in an area.
A third element of the classification process could be
based on the uses that are or that will be made of the ground
water. Use categories that would justify different levels of
protection include drinking water, irrigation, livestock, sur-
face stream base flow, industrial supply, and waste disposal.
Some supporters of this option suggest relying on use designa-
tion as the primary basis of classification.
People who advocate this approach to applying controls
contend that the highest levels of protection should be given
to ground waters that are important sources of drinking water
and have particularly vulnerable geology, yield, and quality.
These people also feel that lower levels of protection are war-
ranted in cases where there are ample supplies of surface water,
where ground waters are already contaminated, where the ground
water is of low yield, or where there is a high social value
placed on the contaminating activity.
Representative comments in support of this option include
the following:
"We know at the local and state levels which areas of
ground water are really critical to our region and
which are highly susceptible to contamination. Those
are the only ones for which we want to impose strict
controls. For the others a much more modest program
is all we need

"This approach can give us the flexibility to address
regional differences. By having explicit differen-
tiation on the basis of geological, hyd rolog ical ,
and other conditions, we'll have a rational basis
for regional variation in ground water protection
"We can't do everything at once. We need to keep our
priorities straight and take action to protect the
ground waters that really need it."
Opposition to this point of view comes primarily from two
directions. One is that described in favor of broad protection
under Option 1 above. The other questions both the technical
and economic feasibility of ground water classification. Some
representative comments in this area are these:
"There are real difficulties describing ground waters.
Some people make it sound simple, but it's more
complex: there isn't just one aquifer under most
areas; there are usually many different soil strata;
yields and water quality vary throughout an aquifer;
the direction and speed of water movement must be
considered; and we can't define exact boundaries to
an aquifer."
"This is an expensive process and may not be needed
for some states. How would you distinguish where it
is and isn't to be required?"
"A classification process would create a demand for
detailed mapping information which is not available
"The manpower needed to undertake classification of
all the nation's aquifers is simply not available."
Option 3—Classification
of Contaminants
This approach would establish priorities for ground water
protection on the basis of the toxicity of the potential
Its proponents contend that the previous optiort, classi-
fication of ground waters, would lead to unnecessarily strict
requirements. In particular', they feel that less toxic con-
taminants, like the "conventional pollutants" under the Clean
Water Act, would present little threat to most ground waters
and would therefore require little regulation. In the absence

of such classifications, though, they expect that requirements
would be geared to the most toxic substances and would impose
unnecessary burdens on sources with "conventional" wastes.
The following are representative comments from supporters
of this option:
"All wastes are not equal. We should be singling out
the 'bad actors' with respect to ground water in terms
of adsorption in the soil, long-term fate, and effec-
tiveness of current treatment technologies. Then we
should focus our efforts on the worst categories."
"It's more efficient to prioritize actions by the ser-
iousness of the contaminants than by the type of plant
or production process involved. After all, it's the
contaminants we're really concerned about. It may
also be simpler to classify these than to develop
standards or regs for dozens or hundreds of industries."
"This approach could be consistent with the current
hazardous waste program and the government's car-
cinogen policies which rely on identifying serious
chem ical s."
Opponents to this option tend to feel that the scientific
data required to implement it is difficult and costly to develo
and maintain.
"There are thousands of chemicals in existence?, and
just because one has been identified as serious under
the toxics program or the hazardous waste regulations
doesn't necessarily mean it is a problem for ground
"We don't need to tie ground water protection to a
massive database of chemicals. We can specify what
constitutes adequate control in most situations
just by looking at the geology and other local
cond it ions."
Option 4—Classification of
Sources of Pollution
This approach would set priorities for protection based
on the type of contaminating facility (source) or industry in-
volved. Its proponents contend that there are certain sources,
such as industrial leach fields, which should be singled out
for high-priority treatment. Likewise*, some argue, there are
certain industries that are more likely than others to dispose
of large volumes of wastes that could threaten ground water.

Both the new hazardous waste program under the Resource
Conservation and Recovery Act (RCRA) and the Underground In-
jection Control (UIC) program under the Safe Drinking Water
Act set requirements applicable to different classes of facil-
ities. Source-specific requirements represent the traditional
approach to the control of air and water pollution. This ap-
proach is most often utilized in conjunction with technical
requirements that are technology-based standards.
The major sources of pollution that are mentioned as
threats to ground water are listed in Table II-l of Chapter II
and are described in Appendices III and V. There are various
ways of listing the sources, with sixteen categories used in
the unranked list in Chapter II. For purposes of developing a
ground water protection strategy, one could recommend a differ-
ent technical approach for each source category, or one could
attempt to group sources in ways that would simplify the strat-
Representative comments from supporters of this option
include the following:
"We should adopt a national priority listing of ground
water contamination sources as a way of focusing at-
tention on the most serious threats to ground water."
"Some sources of contamination, such as surface impound-
ments in developed areas, consistently pose problems
for ground water and we ought to be very tough on them."
"If we're going to make any progress in a national pro-
gram, we have to assign some priorities to different
sources of pollution so we can tell people where to
devote their effort."
"I don't care who makes the choices, whether it's the
feds or the states, but there has to be a difference
between the way we control some sources versus others."
The opposition to this approach to an overall ground water
strategy seems to focus on the administrative and technical
burden of issuing separate requirements for numerous classes of
sources and/or industries. Comments which represent this point
of view include the following:
"The government can't afford the manpower and time to
develop regulations for every source or industrial
category. It should develop a broad program and
treat everyone the same."

"The continued risk posed by any given facility is so
largely a function of local factors like soil condi-
tions and proximity to drinking water sources that
controlling contaminant sources alone may distort
the resulting priorities."
There are several possible approaches to encouraging or
requiring technical control measures that will prevent ground
water contamination. Most of these could be used in conjunction
with any of the management approaches described in the previous
section. By pairing a specific management approach with an ap-
proach to technical requirements, one can define the core ele-
ments of a ground water protection program.
The four major options for technical requirements that
arose from EPA's preliminary research for the workshop are pre-
sented below. Other approaches and variations or combinations
of these should also be considered wherever participants feel
it appropriate to do so.
•	Option 1—Best Management Practices (BMPs).
Utilize "rules" that specify the best management
practices to follow in various situations.
This would provide the flexibility to tailor
requirements to individual situations. It could
also relieve state and federal officials of the
burdens of specifying strict standards and ad-
ministering a permit program.
•	Option 2—Technology-Based or Effluent Standards.
Establish standards for allowable levels of pol-
lutant "discharge" to ground waters based upon
industry processes and available control tech-
nologies. These could include standards for
three phases of a facility's life: (a) design
and construction, (b) operation and maintenance,
and (c) closure and post closure.
•	Option 3—Ground Water Quality Standards. Estab-
lish ground water quality standards. These could
be based upon present water quality criteria
for certain uses such as drinking water. They
could also specify maximum levels of contamina-
tion based on the ability of present water treat-
ment technology to remove the contaminants prior
to water use.

• Option 4—Economic Incentives and Other Approaches.
Establish some set of discharge allocations,
ground water contamination fees, noncompliance
fees, or other mechanism to provide incentives
to businesses and others to meet the national
ground water protection goal. Most, if not all,
such incentives must be utilized in conjunction
with one of the three other options above to
provide a means of deriving the appropriate
levels for fees, allocations, and so on.
Each of these options and its supporting rationale are
described below. It is entirely possible that a ground water
protection strategy could employ one of these approaches for
some polluting activities and another for different activities.
Option 1—Best Management
Practices (BMPs)
This approach to control requirements offers the flexibil-
ity for dealing with individual cases on a site-specific basis.
Rather than specifying mandatory standards, it encompasses
"rules" which are guidelines for various situations. As a re-
sult, the rules can be specified by the government with somewhat
greater ease than that involved in developing and implementing
stricter standards.
Another significant feature of best management practices
is that they can be publicized and required on a broad basis
without necessarily mandating a permit program. It is possible,
for example, to advise landfill operators of the best management
practices to be followed in the construction and operation of a
landfill in order to protect ground water without ever requiring
the operator to file a permit application.
This option is intended to cover both operating practices
and standards for the initial design, construction, and location
of facilities. Often BMPs have been primarily focused on day-
to-day operating practices in areas such as agriculture. The
same approach, however, has also been applied to guidelines for
the location and design of on-lot disposal systems, for example,
and could be extended to other types of facilities. A phrase
which is sometimes used to describe these facility-oriented
standards, in contrast to operating practices, is "Best Engineer-
ing Judgments" (BEJs) . In the discussion of this option, the
term "BMP" is used broadly to include both.
Typical comments from those who favor this option for con-
trol requirements include:

"Ground water protection is basically a local problem,
so we need to establish broad guidelines in the form
of BMPs and then let local decision making take over
to tailor requirements to the local situation."
"BMPs are the only thing you can do in some cases.
How else are you going to handle these areawide prob-
lems? The only solution is to carefully manage their
Opponents of this approach seem to feel that BMPs aren't
strict enough and won't lead to any real changes. Typical
comments include:
"BMPs are only effective when dealing with an areawide
problem. Otherwise', technology-based standards are
probably more effective at getting new controls in
"BMPs are not effective unless they are part of a
regulatory program that can follow up in the field
and make sure they are followed."
Option 2—Technology-Based or
Effluent Standards
This approach to control requirements is based on industry-
specific or process-specific standards relating to the handling,
storage, and disposal of substances that could contaminate
ground water. Thug, this parallels the water pollution control
program for surface waters under the NPDES program.
Proponents of this option contend that strict standards
can and should be established for a number of key industries and/
or sources of potential contamination. Representative comments
"The way to ensure consistent, adequate protection is
to specify technology standards that are clear and
precise. We should tell people, for example!, exactly
how to build surface impoundments—what liners to use*,
how deep the liners should be!, etc. This is the best
way to create enforceable programs."
"It's industrial and other processes that we have to
control. We can't control specific chemicals because
we don't know exactly where they are?, but we sure can
find and regulate plants and landfills."

"Tradeoffs have to be made between the ideal level of
control possible in each industry and the actual tech-
nologies available. We have to make those decisions
industry by industry because each one is different and
adherence to a single uniform standard might shut down
whole industries."
Opponents of this approach frequently cite the administra-
tive workload involved in establishing specific standards for
industries and sources. The following comments are typical:
"Look at the BAT (Best Available Technology) standards
under the Clean Water Act. They're a technical night-
mare— they require years of technical and regulatory
development. They've been working four years on those
and they're still far from finished."
"Why go to all the trouble to set up standards for every
possible situation? Each state will have a different
set of industries which is the problem ther£, and you'd
never finish setting standards to cover them all."
Option 3—Ground Water
Quality Standards
Rather than control the activities that might contaminate
ground water, this approach focuses directly on the ultimate
goal — ground water quality. Proponents point to the appro-
priateness of basing decisions directly on the parameters of
concern rather than on an indirect measure. Typical comments
in support of this position are these:
"Let's not beat around the bush. If we want water kept
clean let's just say so and then leave it up to individ-
ual companies to decide how they want to do it."
"Hard as it may be to set ground water standards, that's
a lot fairer way to set controls than any other method.
Then the burden is on the operator to be sure he has a
location or a process which is safe."
People who oppose this approach do so primarily because of
the technical difficulties associated with monitoring ground
water. The following is a typical view:
"Ground water standards sound greatf, but they're im-
practical. Monitoring is expensive and you never
really know for sure that you haven't missed a plume.
Where do you monitor—in which direction', how far from
the activity, at what depth, with how many holes?"

Option 4--Economic Incen-
tives and Other Approaches
The final approach to control requirements suggested during
Phase I interviews was to utilize some form of economic incen-
tives or other innovative approaches rather than one of the more
traditional regulatory approaches described above.
Advocates of this option drew on the experience and liter-
ature of air and water pollution programs for ideas. Potential
suggestions include:
•	Discharge allocations, which would allow a plant
a specific daily or other allocation of waste
that could be disposed of. These could be mar-
ketable so that the most cost-efficient controls
would likely be implemented first across a broad
range of industries or sources.
•	Ground water contamination fees or taxes which
would be paid to a government body by sources
causing contamination. The fees would raise the
cost of doing business in a manner that causes
contamination, thereby creating an incentive for
prevention. The fees would also build up a fund
to cover the costs of treatment if and when it
was required in order to use the ground water.
•	Noncompliance fees, which would be levied on any
sources not in compliance with applicable standards.
These would be computed to remove the economic
advantage that each source obtains by failing to
install treatments, alternative disposal systems,
and the like.
Proponents of these approaches point to the flexibility
they provide at local levels. Typical comments include:
"Pollution shouldn't pay. We should make it more ex-
pensive to pollute than to operate in compliance with
the laws."
"Some plants aren't as able to reduce pollution as
others, but why should the government have to figure
that all out? Just assign everybody a target level
of reduction and let them get it wherever they can
negotiate it."
Opponents to this approach are skeptical. They say:

"Incentives sound great, but you have to do more work
to set up the right fees or allocations than if you
just set standards in the first place."
"Trading waste allocations for ground water is too
complex. The chemical composition of two wastes will
always differ, and two sites may have different
hyd rogeology."
"Economic incentives are especially difficult to admin-
ister, particularly because of the low level of knowl-
edge on ground water."
While evaluating these options and selecting one or more
(or variations) from each of the major groups as the core de-
sign for a ground water protection program, it is important to
be pragmatic and to consider issues affecting feasibility and
effectiveness. One should not attempt to address these issues
in detail during the strategy development but must be confident
that they will contribute to the success of the recommended
strategy once it reaches the implementation stage. Some of
these issues are:
• Effectiveness in meeting the selected goal
•	Administrative feasibility
•	Relative resource requirements (is one
approach more or less expensive than another,
and for whom?)
•	Technological feasibility, for monitoring and
•	Modeling and analytical capabilities to link
discharges to changes in ambient ground water
•	The institutional framework needed for implemen-
tation and assuring that due process occurs
where contamination will be allowed
•	The likelihood of obtaining desired actions on
the part of those causing the pollution


This chapter deals with the range of approaches that is
available for managing the implementation of a ground water
protection strategy. The roles to be played by federal, state,
and local governments and others must be considered within the
context of the goals selected for a national ground water pro-
tection strategy. The definition of these roles requires balan-
cing significant national interests on the one hand with the
need for state and local flexibility in dealing with local and
regional problems on the other hand. Clearly, these roles will
differ for various elements of the strategy.
Existing programs which have ground water impacts encompass
a broad range of federal and state roles. Under the Clean Water
Act, the federal government specifies standards while responsi-
bility resides with the states for issuing permits and institut-
ing enforcement actions. Other programs provide more indepen-
dent authority to the states. The more recent programs under
the Safe Drinking Water Act, such as UIC, and under the Resource
Conservation and Recovery Act require by statute that the fed-
eral government establish national standards. The states are
then responsible for implementing approved programs.
There are varying opinions as to the appropriate level of
involvement for federal, state, and local governments in carry-
ing out various aspects of a ground water protection strategy.
The range of opinion comprises five major administrative options:
•	Option 1—States take primary responsibility for
implementation of federally developed national
standards. States would take responsibility
for writing permits, conducting site inspec-
tions, instituting enforcement actions, and per-
forming other steps necessary to implement the
program. The federal Agency would design the
program and establish minimum standards. The
federal role would include specifying monitoring
requirements, and1, as appropriate, specific am-
bient standards or technology-based standards.
•	Option 2—States prepare and submit program plans
for federal approval in response to federal min-
imum requirements. These federal requirements
could be based on ground water quality standards
or on technology-based or other similar standards.
State governments would have the responsibility

to design programs to meet them. Within that
context, for example, a state's program could
spell out how the classification scheme is to
be implemented, how the minimum standards will
be carried out, what standards will be set for
other categories of pollutants or sources not
covered by federal standards, and finally what
the details of the state's enforcement program
will be. Responsibility would reside with the
state to define the role of local and other or-
gan ization£, and the federal government could
provide financial support and technical assist-
ance to the states.
Option 3--States prepare individual program
plans consistent with broad federal guideline^,
subject to federal approval primarily on pro-
cedural grounds. This approach delegates author-
ity to state and local governments to develop
implementation programs that are patterned
specifically to meet local and regional needs.
Federal approval of the plans would be mainly
to ensure that consideration has been given to
all appropriate issues, including the need for
surveys and assessments; that required state
statutes and implementing regulations have been
developed; that broad public participation has
been obtained; that the required agreements
exist between involved state and local agencies
and other government groups; that there is com-
pliance with existing federal standards; and that
the proposed plan meets certain broad objectives.
Option 4—State and local governments set and
enforce standards consistent with broad federal
goals; the federal government provides technical
assistance and support. This option places
primary reliance on the state and local govern-
ments for the development, implementation, and
enforcement of a ground water protection program.
The federal EPA only conducts research, pro-
vides technical assistance, and assures that
states meet the broad federal goals.
Option 5 States develop plans and programs; the
federal government provides support and techni-
cal assistance only. This approach places full
responsibility on the states for determination
of the goals and objectives of a ground water
protection program. State and local governments

then develop, implement, and enforce the program
while the federal government provides support as
needed .
Each of these options and its supporting rationale are dis-
cussed below. However, one must remember that the federal,
state, and local roles could vary for different elements of a
ground water protection strategy.
Supporters of this position believe that the approach is
consistent in concept with other successful environmental pro-
grams. In addition, it is easy to administer', particularly if
limited exceptions to the uniform standards are allowed.
Supporters also favor the approach because it allows
states to impose more stringent standards where they deem a
local or regional need to be significant.
Some advocates express support because they believe that
this approach encourages the broadest possible federal techni-
cal assistance, federally sponsored research and development
projects, data gathering assistance', and active exchange of
information across states.
Representative comments in support of this option include:
"Our society has become so complex and companies and
people are so mobile that oftentimes federal standards
for national programs appear to be unavoidable."
"Ground water supplies are so important to the na-
tional economy and ecology that federal intervention
into state and local management programs is neces-
sary. Uniform national standards would accomplish
this needed protection."
"Only a national, uniform approach would yield effec-
tive coordination of the many laws, programs, and
mechanisms needed to manage ground water resources."
"Congress has already initiated some programs in this
area by statute—programs like NPDES and now RCRA and
UIC. We have a good start; let's continue in the same
d irection."
VI -3

Opponents of this approach argue that regional, state, and
local differences make national standards inappropriate. Addi-
tionally, current state and local control programs might not be
integrated appropriately in a centrally mandated approach.
Representative comments against this option include:
"Because ground water basins are almost exclusively
internal state matters, the biggest role in a na-
tional ground water strategy should be left at the
sta te 1evel."
"Federal regulation should be held in abeyance and
only used in regard to interstate, international,
or state inaction situations that endanger public
health, national defense, national energy programs,
or something else clearly in the national interest."
"Considering where we stand nowaday^, a set of uni-
form national standards can do little to lessen the
present overlapping and confusing array of too many
cooks stirring the broth. This approach would only
add more overlap and confusion to the question of
who has jurisdiction over what."
"Any kind of national approach just isn't appropriate.
Ground water problems in the East are completely
different than in the West—Colorado is concerned
about problems associated with energy development,
while New Jersey is worried about chemical dumps."
This option puts a significant responsibility on the
states to develop and implement appropriate ground water pro-
tection plans within a set of criteria developed by the federal
The federal role under this option is an active one. it
could involve the federal EPA establishing technology-based
standards for various sources and quality goals or standards
for each state or ground water area. Furthermoref, the federal
Agency would have an active responsibility to perform a substan-
tive review of each state's proposed plan to guarantee that it
meets all applicable standards and will achieve the established
goals. in states that choose not to assume primary responsi-
bility for the prog rairt, the federal government could also take
on the states* role.

The states under this option would have the opportunity to
assess local and state priorities and to incorporate them into
their proposed plans. Within the federal guidelines each state
could then tailor its own program to focus efforts on certain
sources, contaminants, and so on. After approval of their plans
the states would have primary responsibility for implementation
and enforcement.
Supporters claim that other environmental programs are de-
veloped and managed with this approach. Typical comments in
support of it are the following:
"Some states are doing a great job already, but
others are doing nothing. The feds have to set
standards and make sure every state is meeting
at least some consistent minimum goals."
"Look at the air pollution control program. There's
a lot of flexibility to accommodate local and area-
wide differences. Some plants may have standards
very different from those at similar plants a few
miles away because of local conditions."
"The program should be basically a state and local
one', but you need the federal involvement to get
some consistency across states ancJ, frankly, to
get them all moving."
"Over the next five years the role of the federal
government should be to set minimum program expecta-
tions and time schedules for the states to develop
proposed programs. State failure to meet such min-
imum expectations and time schedules should result
in federal intervention where ground water pollution
has become a serious public health problem or a threat
to continued beneficial use of the ground water."
Comments in opposition to this option tend to parallel the
statements given in support of Options 1 or 3, favoring either a
stronger federal role or a more independent state role.
This approach assigns substantive program responsibilities
to the states and gives to the federal government a procedural
role to ensure that the states are doing their job.
The federal role under this option is an important one',
but it is not focused on standard-setting. EPA in this case

would establish guidelines for how states should develop their
plans. These would presumably identify critical ground water
problems to ensure that all states at least consider a consis-
tent minimum range of issues. The guidelines would also include
procedures for public participation, recommended or required
timetables, and requirements for coordination of the various
state and local agencies involved in activities significantly
affecting ground water.
After establishing these guidelines, the federal govern-
ment would ensure that the states meet the guidelines in pre-
paring their plans, would see to it that adequate progress is
made by the states in implementing these plans, and would pro-
vide technical and possibly financial assistance.
The state role under this option would be to work with
the local governments and others (1) to develop ground water
protection programs, including management and regulatory mech-
anisms as appropriate; (2) to implement the programs; and (3)
to carry out the enforcement and oversight necessary under the
prog rams.
An important distinction between this option and Option 2
concerns the regulatory and management mechanisms for ground
water. Under Option 2 those mechanisms, for example a commit-
ment to use ground water classification, would be decided
nationally and implemented by every state nationwide. Under
Option 3 it is possible that each state could reach its own
decision on the approach it favors, with the potential result
that half the states would utilize ground water classification
schemes and half would not.
The supporters of this option favor state and local deci-
sion making for what they believe is a very local problem.
Typical comments in support of this option include:
"The types of problems affecting ground water1, such
as septic systems, may occur nationwide, but their
significance is radically different from area to
area. There's just no way you can set national
standards that make sense in all of the different
local situations you'll find."
"I believe in a hands-off policy in decision making
where states have ground water pollution under rea-
sonable control', but the feds should be a catalyst
or motivator to the strengthening of weak state pro-
grams and should help states with no viable programs
get started."

"A lot of the decisions affecting ground water are
essentially land-use decisions, such as where land-
fills will go. Those should primarily be local de-
cisions, not made at the state level. It's up to the
EPA to provide the tools, though, such as guidance in
the classification of aquifers and maybe even in the
provision of some nationwide ground water mapping."
Those opposing this option tend to feel that it would re-
sult in too fragmented an approach to ground water protection,
Typical comments include:
"We'll end up with a patchwork of different programs
across the country. Protection won't be consistent,
and states in which agriculture and industry interests
are strong may be unable to withstand the pressure
to relax standards."
This option focuses on the desire of states and localities
to continue to implement ground water programs according to
their own schedules, designs, and capabilities. The federal
role would only be one of identifying broad national goals,
recommending voluntary guidelines, providing technical assis-
tance, and perhaps providing financial assistance.
Supporters of this approach contend that states are acting
and will continue to act in their self interests. They claim
that states with serious ground water problems will take ag-
gressive steps on their own to protect ground water. They point
to present state programs and especially to actions taken in the
recent past to support their claim.
Typical comments in favor of this option include:
"We don't need a federal 'stick' as long as we have
access to a 'carrot.' The most important elements of
federal support are general guidance, funding, basic
data', and technical expertise. State programs will
employ these resources appropriately."
"The federal government is best able to fund ground
water research and to identify broad problem areas.
It should stick to providing that kind of help
and leave the regulatory and management functions
to the states who are closer to the problem."

Opponents express many of the arguments presented in sup-
port of Options 1 and 2 above. They also comment:
"There are substantial reasons for a nonrigid, cen-
tral theme in ground water programs. A national pro-
gram with fully defined federal and state roles will
give people something to react to along a meaningful
time schedule."
"It's difficult enough to set up one ground water pro-
tection program, let alone fifty separate programs.
Let's introduce some efficiency and do some things
just oncg, such as develop a ground water classifi-
cation system."
"If federal agencies are excluded from active parti-
cipation in ground water management, and subsequent
pollution problems arise, why should federal re-
sources be used to rescue state and local government
mismanagement? "
This option assigns program responsibility exclusively to
the states. The federal role would only be one of providing
support at the request of the states.
Supporters say that the examples of existing ground water
protection programs are proof that states are acting responsibly
on their own. Even states with weak programs, according to
supporter^, are doing as much as possible given existing re-
sources. State and local governments, they contend, are setting
priorities and proceeding in a responsible manner.
Supporters also point to the existence of numerous federal
agencies that could aid states appropriately without single-
agency coordination at the federal level.
Typical comments in favor of this option include:
"States are already doing a lot on their own. Over
twenty states have ground water programs underway,
and the states with the most serious problems are
doing the most. We need to be left alone to use our
limited resources where they'll get us the most
bene fit."
"Federal funding is essential and appreciated, but
states are certainly capable of accepting block

grants and allocating the funds to state and local
programs according to our own priorities."
Opponents generally favor the more active federal involve-
ment presented in Options 1 and 2. Typical arguments offered
by opponents of this option are the following:
"Suref, some states are moving ahead and implementing
good ground water programs. But a lot aren't and
without federal prodding we aren't going to see sig-
nificant environmentally responsible progress in
some states."
"Without federal involvement and federal requirements,
states would never get any political or financial
support from their state or local governments."
It is important to realistically evaluate the responsi-
bilities for state and federal agencies implied by any given
set of program recommendations. In particular one must consider
the functions and related tasks that would be carried out and be
assured that the tasks would be performed most appropriately and
efficiently compared with other program designs and that the
desired actions are likely to result from the recommended pro-
gram design.
Many responsibilities for a ground water protection pro-
gram could be carried out at the federal', state, or local level.
However, the division of labor should be rational. There may be
situations where the national interest is a dominant!, overriding
concern, as is likely in broad issues relating to public health
and safety. For example!, in the interest of public health, re-
sponsibility for setting a ground water standard for toxic sub-
stances could be more appropriately assigned to a federal agency
than to states or localities.
Some tasks may require resources and capabilities that are
only available, or at least most efficiently applied, at the
federal level. An example could be the establishment of a
classification scheme, in which case it may be more efficient
for one federal system to be implemented than for fifty states
to develop fifty different approaches to such programs.
Alternatively, some problems may be so unique to local and
regional areas that they cannot be effectively resolved on a
national level. An example of this may be highway de-icing
prog rams.

In considering these issues one ought to contemplate the
full range of tasks that would be required to fully design and
implement a recommended ground water protection strategy. Tasks
that may be required could relate to monitoring', ground water
mapping1, technical computer modeling, writing of regulations,
inventorying of sources, permit writing, performance of inspec-
tions, and management of enforcement efforts.
It is neither appropriate nor necessary to identify all
the tasks during strategy development. It is important, how-
ever, that one be confident that the kinds of tasks to be
included in a ground water protection program can be feasibly
and effectively accomplished if and when the recommended strat-
egy is actually implemented.


Once the broad outlines of the strategy are clear*, it is
important to identify implications for short-term actions.
These can help identify what EPA should consider initiating in
the coming months in order to make progress on significant
elements of the strategy within the next two to five years.
Short-term potential actions to be considered by the work
groups fall into the following categories:
•	Research and Development
—Accelerate development of guidance on toxi-
cological significance of unregulated contam-
inants of ground water.
—Expand research in fate and effect of ground
water contaminants, and on predictive tools to
link discharges to anticipated changes in ground
water quality.
—Expand technology transfer.
—Expand ground water mapping efforts.
—Identify best practices for safe disposal.
•	Monitoring
—Assess existing ground water monitoring efforts.
—Initiate a national study of organic contami-
nation in drinking water derived from ground
wa ter.
—Add focus to existing programs to identify hot
spots and gather other data.
—Mandate consistent practices and parameters
for existing monitoring programs.
—Coordinate data collection efforts and make
them compatible so that they can be aggregated
to provide state and national trends and status.
•	Guidelines
—Develop guidelines for states and others on
ground water classification categories that
integrate geology, hydrology, control tech-
nologies, and use categories.
—Expedite development of design standards for
on-lot disposal systems, storage tanks, etc.

--Develop model state laws.
—Develop voluntary guidelines for development
of state ground water plans.
•	Hot Spots
--Assert ground water authority in current legis-
lation to deal with high-priority problems.
—Review growing data on contamination incidents
to help identify high-risk situations for added
study .
•	State Capacity
—Develop and run training programs in ground
water planning, monitoring, etc.
—Require planning and initial ground water
classification through existing legislation
or programs.
—Increase the availability of federal grant funds
for state ground water protection programs.
•	Personnel
—Take steps to expand the training of profes-
sional personnel through universities for high-
level staff, and through vocational education
and retraining programs for technicians.
—Assess the manpower needs of state, local, and
federal agencies to implement a program.
•	Coordination
—Better coordinate existing and new ground water
protection programs.
—Improve mechanisms for positive federal/state
cooperation on planning and implementing ground
water programs, sharing successful experience
and technical assistance on critical issues.