United States
   Environmental Protection
   Agency
Office of
Public Affairs (A-107)
Washington DC 20460
Volume 10
Number 6
July/August 1984
&EPA JOURNAL
   Protecting Ground Water:
   The Hidden Resource


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Protecting
Ground  Water,
The  Hidden
Resource
 A few years ago ground-water
 pollution was an almost
 unknown problem. Today
 ground water is one of the major
 environmental concerns. This
 issue of EPA Journal explores
 why and describes what the
 states and EPA are doing about
 it.
   Administrator William
 Ruckelshaus explains EPA's
 commitment to help protect this
 precious resource. Deputy
 Administrator Alvin Aim spells
 out the approach EPA has
 developed to  help insure that the
 nation's ground-water resource
 is not going to be lost.  The
 Assistant Administrator for
 Water, Jack Ravan, discusses
 federal-state relations in
 ground-water protection, an
 important factor because of the
 different  responsibilities at state
 and  federal levels regarding this
 resource.
   In  an interview, Marian Mlay
 discusses the ground-water
 problem  and how the Office of
 Ground-Water Protection which
 she  heads will help coordinate
 efforts to deal with it. The office
 was  recently created within EPA
 by the Administrator, who
 named Ms. Mlay to direct it.
   A  view from the states
 regarding the best way to
 address the nation's
 ground-water problems is
 offered by Governor Bruce
 Babbitt of Arizona, Chairman of
 the Subcommittee on Water
 Management of the National
 Governors' Association. In
 addition, water quality officials in
 five  states report on the
 particular ground-water
 problems they face and on the
 programs they have developed
 to deal with contamination. The
 states are Pennsylvania,
 Connecticut, New Mexico,
 Florida, and New Jersey.
      Bruin Lagoon, an abandoned hazardous waste site in Pennsylvania, next to a residential area.
      Wastes in the lagoon and storage tanks contaminated surface and ground water. The site is on
      EPA's National Priority List for Superfund action.
  Dangers to drinking water
posed by ground-water
contamination are described by
John M. Gaston, a sanitary
engineer with CH?M Hill, an
environmental consulting group.
Sources of pollution are
discussed in a piece by David W.
Miller, a geologist and partner in
Geraghty  and Miller, Inc., a
consulting firm specializing in
ground water. Potential links
between polluted ground water
and public health are described
in a piece by Dr.  Robert A.
Goyer, Deputy Director of the
National institute of
Environmental Health Sciences.
  A prognosis for the future of
the nation's ground water is
given in an article by Philip
Cohen, chief hydrologist of the
U.S. Geological Survey. EPA's
efforts to develop more effective
techniques to control
hard-to-get-at pollution of
ground water are described in an
article by Bob  Burke of the
agency's Office of Public  Affairs.
  Concluding the issue's
discussion  of ground water,
James T. B. Tripp, an attorney
with the Environmental Defense
Fund, writes about ground-water
pollution in Nassau County, N.Y.,
and the national lessons  it
suggests, and Dr. Thomas M.
Heliman, Chairman of the
Chemical  Manufacturers
Association's Environmental
Management Committee, gives
his perspective on the
ground-water problem.
  Regarding the  environment
generally, the magazine includes
excerpts from the June 19
speech by President Reagan to
the National Geographic  Society
in Washington, D.C., outlining
his views on the  issue.
  Special features include
Appointments and Update, a
summary of recent EPA
developments. LJ

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                               United States
                               Environmental Protection
                               Agency
                               Office of
                               Public Affairs (A-107)
                               Washington DC 20460
                                                             Volume 10
                                                             Number 6
                                                             July/August 1984
                           S-EPA JOURNAL
EPA is charged by Congress to
protect the Nation's land, air and
water systems Under a mandate of
national environmental laws, the
Agency strives to formulate and
implement actions which lead to a
compatible balance between human
activities and the ability of natural
systems to support and nurture life.
  The EPA Journal is published by
the U S Environmental Protection
Agency. The Administrator of EPA
has determined that the publication
of this periodical is necessary in the
transaction of the public business
required by law of this Agency Use
of funds for printing this periodical
has been approved by the Director
of the Office of Management and
Budget Views expressed by
authors do not necessarily reflect
EPA policy Contributions and
nqumes should be addressed to the
Editor (A-107), Waterside Mall. 401
M St.,  SW. Washington. D. C
20460. No permission necessary to
reproduce contents except
copyrighted photos and other
materials
 r-
                               William D. Ruckelshaus, Administrator
                               Josephine S. Cooper, Assistant Administrator for External Affairs
                               Jean Statler, Director, Office of Public Affairs


                               John Heritage, Acting Editor
                               Susan Tejada, Assistant Editor
                               Jack Lewis, Assistant Editor
                               Bob Burke, Contributing Editor
The Nation's Need
to Protect Ground Water
By William D.
Ruckelshaus 2

EPA's Ground-Water
Protection Strategy
By Alvin  L Aim 3

Coordinating Protection
Efforts—An  Interview
with Marian Mlay  5

A State/EPA
Partnership
By Jack Ravan 9

From the States'
Point of View
By Gov. Bruce  Babbitt 11
                              Protecting Ground-
                              Water: Five
                              States Report  13

                              Sources of Ground-
                              Water Pollution  17
                              Contamination
                              of Drinking Water
20
                              Potential Health
                              Effects from
                              Ground-Water Pollution
      22
The Ground-Water
Issue: Two
Viewpoints  30

President Reagan
Addresses the
Environmental Issue 35

Update: New
Agency Developments  36

Appointments  at EPA  38
                              EPA Researchers  Seek
                              Answers to Ground-Water
                              Contamination  24

                              The Future of
                              the Ground-Water
                              Resource 27
                               Front cover: Aerial view of a farm in
                               western Mary/and. Photo by Robert
                               Madden of Folio,
                               Photo credits: Steve Delaney;
                               Tracey A. Finger; Allan Wilson; U.S.
                               Geological Survey; USDA Soil
                               Conservation Service; National
                               Water We/I Association; National
                               Association of Conservation
                               Districts; Water Well Journal
                               Publishing Company; Atlantic
                               Richfield Company; Ohio Department
                               of Health; Newsday; Robert Madden
                               of Folio.
                                                             Design credits: Robert Flanagan;
                                                             Ron Farrah
 CSJ
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The  Nation's  Need
to  Protect  Ground  Water
 By William D. Ruckelshaus
 Administrator, EPA
  I pon my return to EPA in June of
^1983, it was clear that the nature of
the environmental threat facing our
society had changed markedly in a
decade. From its dominant focus on
conventional air and water pollutants in
the early 1970s, the agency has directed
its attention to toxic and hazardous
contaminants in all media. New
legislation to control these contaminants
has been enacted by Congress in the
form of the Resource Conservation and
Recovery Act, the Superfund law, the
Toxic Substances Control Act, the
pesticides act, and  amendments to the
Clean Air Act and the Clean Water Act.
Our experience in implementing these
statutes and evidence drawn from
extensive  monitoring and survey data
suggest that the contamination of our
ground-water resources constitutes a
major problem the  nation has too long
neglected.
  Shortly  after I returned to EPA, I set up
a task force of some of our best technical
and professional experts to develop an
agency strategy for ground-water
protection. The dimensions of the
challenge were clear:

• The consumption of ground water is
increasing at twice  the rate of surface
sources of fresh water and it won't be
long before most Americans will rely on
ground-water resources for drinking
water. Many regions and communities
simply could not exist  without clean and
dependable ground water.

• Ground water is  highly vulnerable to
contamination. Abandoned hazardous
waste dumps and thousands of poorly
regulated  hazardous waste facilities are
the most prominent sources of
contamination in the public's mind.

• Hundreds of thousands of landfills,
ponds and tagoons used for storing
wastes, and storage tanks containing
gasoline and other liquids may also be
polluting much of the nation's ground
water. There are also literally hundreds
of other major sources that range from
20 million private household septic
systems to various pesticides and
chemicals. A special problem exists in
coastal areas where depleted
ground-water aquifers are threatened by
salt water intrusion. The list of sources of
ground-water contamination keeps
growing as new sources are identified
and verified.

• Specific problems associated with
ground-water contamination are among
the most complex that EPA has ever had
to deal with. Ground-water
contamination is extremely difficult to
detect and monitor, and it is not readily
amenable to conventional cleanup
measures. At present, we simply do not
know how to clean up most
ground-water pollution.

  I directed the Ground Water Task Force
to produce four key outputs:

• A program to build and enhance
ground-water management institutions at
the state level;
• A program to begin to deal with
inadequately addressed sources of
ground-water contamination—in
particular, leaking storage tanks, surface
impoundments, and landfills;
• A general framework for making EPA
decisions affecting ground-water
protection and cleanup; and

• A strategy for strengthening EPA's
organization for ground-water
management at the headquarters and
regional levels.

  Some of the Task Force
recommendations have already been
implemented and others are being
actively pursued. The recommendations
provide a basis for comprehensive and
effective actions at all levels of
government to  protect and enhance our
nation's valuable ground-water
resources.
  I have complete confidence in our
nation's ability to provide protection for
its ground-water resources. I have seen
what federal, state, and local
governments have collectively
accomplished in the past when dealing
with other environmental difficulties that
seemed as challenging at the time as this
one is now.
  We will pull EPA's resources together
to address the issues involved. We
know that in most instances it is much
easier to prevent ground-water
contamination than to clean it up once it
happens.
  EPA is moving forward with vital
research aimed at improving our
capabilities to detect and clean  up
ground-water pollution. There's much we
still don't know about  these technically
complex issues but we have made
significant advances that were
unimaginable only a short time ago.
  We have every reason for optimism.
The skills and dedication of federal, state,
and local governments and the strong
national commitment to environmental
protection have served us well in the
past. They are equal to the challenges of
ground-water protection. D
                                                                                                       EPA JOURNAL

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EPA's  Ground-Water
Protection  Strategy
By Alvin  L. Aim
Deputy Administrator
Kjational environmental attention has
'^turned only recently to the problem of
ground-water contamination. During the
1970s, the nation's concern focused
mainly on natural  resources and
pollution we could see or smell. Federal
and state programs were developed to
address surface water and air quality,
specific types of contaminants such as
pesticides, and obvious sources of
contamination such as uncontrolled
hazardous waste sites. Few knew or
ready understood how seriously our
ground-water resource was being
compromised.
  Public awareness of and concern about
the problem  grew as reports of
contamination of drinking water wells
and well closings increased. State, local
and federal officials are responding to
public demands for enhanced protection
of ground water. These responses,
however, are hampered by a lack of
coordination  between responsible
agencies, limited information about the
health effects of exposure to some
contaminants, and a limited scientific
foundation on which to base policy
decisions.
  Recognizing the need to protect
ground-water quality as a national
concern, EPA Administrator William D.
Ruckelshaus  asked me  to create a
Ground-Water Task Force. Comprised of
senior representatives of EPA program
and regional  offices, the group was
charged with developing a strategy for
EPA's ground-water protection efforts.
The Task Force began work in June 1983,
using technical papers  and proceedings
from workshops and public hearings held
over a period of several years as a
foundation for their deliberations.
Preliminary conclusions of the Task Force
and a draft strategy were reviewed by
and discussed with Congressional staff,
state officials, and a wide range  of
industry and  environmental
organizations.
  After extensive analysis of EPA
statutory authorities as well as existing
state ground-water programs, the Task
Force concluded that the nature  and
variability of  ground water makes its
management the primary responsibility
of the states. However, a number of
significant federal authorities exist to
support states in the effort. The group
also found that since these federal  laws
                                       In a field hydrology class at Ohio's Wright
                                       State University, an instructor explains use
                                       of a rig to drill a ground-water monitoring
                                       well.
were enacted at various times for
separate purposes, some inconsistencies
in regulations and decisions made under
them have hindered a cohesive approach
to ground-water protection. In addition to
EPA's authorities, the Task Force found a
variety of state and local authorities that
can be used  to protect ground water.
Many states  have already begun
programs in  this area, and fostering the
continued development  of state
capability to  protect ground water was
deemed vital.
  The effort  to protect ground water will
be enormous, and it will require
sustained attention at all levels of
government  for a long period of time.
Given the finite fiscal and human
resources that are available, it is clear
that we must direct our  energies to
minimize future contamination, even as
we detect and manage contamination
associated with past activities. If we are
to focus our  efforts where ground-water
contamination would cause the greatest
harm, this suggests that we should
assign  highest priority to those ground
waters currently used as sources of
drinking water or that feed and replenish
unique ecosystems. In this context, EPA
developed  its Ground-Water Protection
Strategy.
  The strategy includes four major
components  that address critical needs.
They are:
• Building and enhancing institutions at
the state level;
• Addressing problems  associated with
inadequately controlled sources of
contamination;

• Issuing guidelines for  EPA decisions
affecting ground-water protection and
cleanup; and
• Strengthening EPA's organization for
ground-water management.

  With regard to building state programs,
EPA plans to offer several types of
assistance to states. EPA will make
existing grant funds available to  help
states develop ground-water protection
programs and strategies. EPA will also
JULY/AUGUST

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provide state agencies with technical
assistance in solving ground-water
problems, and will continue to support a
strong research program in ground water
more directed toward state needs.
  The second component of the strategy
is to begin addressing major sources of
ground-water contamination not now
regulated under federal  law.
Underground storage tanks, including
those storing gasoline, are becoming
recognized as a possibly serious and
widespread source of ground-water
contamination. EPA's Office of Toxic
Substances has begun studying the
nature, extent, and severity of the
problem, and the  agency is considering
possible regulatory approaches to ensure
proper design and operation of these
tanks. In the meantime,  the agency will
issue chemical advisories to alert tank
owners about the problem and will work
with states and industry to develop
voluntary steps to reduce contamination.
Direct regulation of tanks storing
hazardous waste is also  being
considered.
  In addition, the  agency is initiating
efforts to determine whether land
disposal facilities, including surface
impoundments and landfills handling
other than hazardous waste, require
further state or federal regulation.
Another recognized source of
ground-water contamination is the use of
pesticides; the agency is also stepping
up efforts to assess the  leaching potential
of pesticides and to adopt and implement
appropriate controls.
  The strategy's third component
recognizes the need for  consistency in
decisions affecting ground water that are
made by EPA's regulatory programs. In
thinking about building  consistency in
these requirements, we  encountered two
primary questions:

• How should we define the resource to
be protected?

• To what extent  should it be protected?
We have proposed guidelines which
divide ground water  into three classes,
based on the use  of the  water and its
vulnerability to contamination. Under the
guidelines, each would receive a different
level of protection.

  The highest level of protection is
reserved for "special ground waters."
These special ground waters,
characterized as Class I,  are particularly
vulnerable to contamination because of
their hydrogeologic characteristics. To
qualify as Class I, the ground water must
also meet one of two other requirements.
It must either be an irreplaceable source
of drinking water  for a substantial
population, or it must provide water for a
sensitive ecological system. To prevent
contamination of Class I ground waters,
EPA will initially discourage by  guidance,
and eventually ban by regulation, the
siting of hazardous waste facilities over
them. The agency will also place
additional restrictions on existing  land
disposal facilities in those areas. Further,
agency policy will be directed toward
restricting or banning the use of those
pesticides which are known to leach
through soils and are a particular
problem in ground water.  EPA's policy
for cleanup of contamination will  be
most stringent in these areas, generally
requiring cleanup to background or
drinking water levels.
  Class II includes ground waters that are
current or potential  sources of drinking
water or have other beneficial uses.
These ground waters, which comprise
the vast majority of ground water in the
nation, will receive levels of protection
consistent with  levels now provided for
under EPA's existing regulations.  In
addition, where ground waters are
vulnerable to contamination and are used
as a current source of drinking water,
EPA will propose banning  the siting of
new hazardous waste facilities.  EPA
policy will require contaminating facilities
in Class II areas to clean up to drinking
water quality or  background levels, but
exemptions will  be available to  allow a
less stringent cleanup level or plume
management effort under certain
circumstances when protection  of human
health and the environment can be
demonstrated.
  Class III — or ground waters that,
because of natural or man made
contamination levels, are not considered
potential sources of drinking water and
which have limited beneficial  use  — will
receive less protection than the other
classes.  However, technology standards
for hazardous waste facilities would
generally be the same. If such a facility
should leak, it could be granted a  waiver
to clean up to a less stringent
concentration limit for contaminants
since the ground water would already be
of limited value. However, such waivers
would not be available to facilities which
had caused the contamination that
precluded future use of the ground
water. EPA's Superfund program will not
focus its activities on protecting or
improving ground water that has  no
potential impact on  human health or the
environment.
  To improve the consistency and
effectiveness of EPA's current
ground-water programs, the guidelines
will be translated into specific
requirements in each of the agency's
relevant program areas. Many of these
programs are delegated to the states,
and for most programs states must
demonstrate that their  efforts are "no
less stringent" than the federal program.
However, in implementing these
guidelines, EPA will provide as much
flexibility as is possible under existing
statutes.
  The final component of the strategy is
strengthening EPA's organization to
focus on ground-water protection. We
have formally established a new
headquarters Office of Ground-Water
Protection within the Office of Water. It
will give the agency the kind of
leadership and coordination it has long
needed  to make ground water a genuine
priority. The Office will direct the
development of EPA policies and
guidelines for ground  water, and
coordinate the relevant activities of
program offices. In  addition, we are
establishing ground- water  staffs in each
of our regional offices, whose function it
will be to assist in ground-water policy
development and implementation, and
coordinate planning and technical
support for states devising  ground-water
strategies  of their own.
  I consider EPA's Ground-Water
Protection Strategy  an extremely
important  step in enhancing protection of
a vital resource and achieving
consistency  in regulatory requirements.
The strategy does not propose simple
solutions to the complex problem of
protecting our nation's ground-water
supplies. Rather, it provides a framework
for a strengthened federal-state
partnership that ensures the most
effective use of our  existing and future
resources  for protecting ground-water
quality.
  EPA's Ground-Water Protection
Strategy gives us the  tool for protecting
this important resource and making
sense out  of our many programs that
affect ground water. The strategy is now
driving a number of our regulatory
programs  toward sensible goals. The
strategy does  not propose simple
solutions to the complex problem of
protecting our nation's ground-water
supplies. But it does take us a long way
toward rationalizing our programs,
dealing  with uraddressed ground-water
problems, and creating the  kind of
state-federal partnership that is necessary
for effective action.  D
                                                                                                            EPA JOURNAL

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 Coordinating  Protection
 Efforts

 An Interview  with Marian Mlay
 In the following interview, Marian Mlay,
 director of EPA 's Office of Ground-Water
 Protection, discusses the ground-water
 problem and reviews EPA's efforts to
 help deal with it.
       Mlay
 \J.   When did the country begin to
 realize it has a problem with ground
 water?

 r\  The country has been aware for
 about the last five years, since some of
 the particular incidents of contamination
 in New England and New Jersey.
  People in the environmental
 professions understood earlier that there
 were problems. It's just that ground
 water did not become a public issue until
 some particular instances of
 contamination  became widely known,
 partly because of our new ability to
 measure ground-water contamination at
 much lower levels.
  Traditional contaminants, such as
 microbiological  contamination from
 septic tanks or outhouses, and certain
 natural contaminants have been known
for a long time.  But it's the new
awareness of manmade chemicals that
are toxic and getting into ground water
that has really heightened public
awareness of the problem.


 \JL    What is the nature of the
 ground-water problem?

 r\     We're finding ground water
 containing relatively high levels of
 manmade contaminants.  They are
 affecting both public and private drinking
 water supplies,  and drinking water is the
 most  direct transmitter of pollution and
 contamination  to people.
  People are very concerned about
 surface water because they see  it and
 smell it and have to be around it. By and
 large we expect to treat surface water
 when we use it for drinking water. But
 water from private wells and many
 smaller public water systems isn't
 treated. Now, with the more
 sophisticated methods of measurement,
 contaminants are being discovered in
 these sources. There is concern about the
 public health effects and about the cost
 to individuals and to the public water
 systems of treatment.
  We have also become aware of more
 and more kinds of activities that will
cause ground-water contamination. In
addition to large hazardous waste
facilities, there are gasoline storage
tanks, several million of which are
scattered around the country. There are
pesticide and fertilizer applications, and
highway de-salting. Ground water is
being spoiled by many different incidents
of contamination that come from
relatively benign or innocent looking
activities.
                                                                               Q
       What would you say the major
challenge is at this point—protecting
clean ground water, or cleaning up
contaminated ground water?

r\    Both. I don't know that we can
really separate the two.
  Clearly in our ground-water strategy
we want to place more emphasis on
protection, but it's easy to say, "Let's
protect everything, let's protect all
ground water, let's make sure that it's all
pristine." We know that's extremely
expensive and very difficult or
impossible.
  We can't stop all fertilizer use and we
can't rip up all the gasoline stations in
the country, so protection becomes a
question of assessing the use of that
ground water and protecting it for those
uses while trying to divert potentially
polluting  activities where possible to
areas where ground water will not be
affected.
                                                                                     is cleanup just as difficult?
Q

r\   In ground-water cleanup we have
a major  technical challenge. We just
don't know how to do it yet.  I'm using
the term cleanup in the context of
turning an aquifer (an underground
stratum  containing water) back into its
original, possibly pristine state.
  The typical way of trying to restore
ground water is to remove the source of
contamination, even to the point of
digging  out contaminated soils. But
you've got to  put the spoiled material
somewhere, and it will still have the
potential to contaminate something else.
JULY/AUGUST

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Once the source of the contamination
has been eliminated, usually the water is
pumped out, treated, and pumped back
again. Even in what I'd call some simple
cases involving a contaminant that's
fairly easy to get out of water, like
trichloroethylene (TCE), they've been
pumping and treating for five years and
they've still not gotten it all out. (TCE is a
volatile organic chemical  commonly used
as an  industrial solvent.)
  So the problem of actually restoring
aquifers is not solved technically. The
techniques that exist are extremely
expensive and can take forever.
  There are other techniques  for
protecting public health from
ground-water pollution: containment
approaches. For example, you can put a
well at the end of a plume of
ground-water contamination  spreading
from a particular source and pump it out
so that the plume doesn't move any
farther. You can prevent the pollution
from moving into a well system, for
example.
  There are other ways of protecting
drinking water wells from contamination
without cleaning up all the polluted
ground water. Because of the expense of
complete cleanup, we may have to
consider them in many cases.
  Some very  interesting research is
underway regarding ground-water
cleanup,  such  as stimulating or injecting
microbes underground to break down
chemicals more rapidly, but we're
probably five or ten years from being
able to use it.
Q
       Do you believe that we've got a
crisis on our hands with polluted ground
water?
A
       No. I think we have a long-term
problem, one that is not going to go
away easily, but it can be dealt with and
we need to do it. It will become a crisis
only if we ignore it.
Q
       How did you get involved in the
ground-water issue?
r\
       Two days after I began work with
the EPA Office of Drinking Water in late
1979 as Deputy Director, my boss, Victor
Kimm, and I were called to the
Administrator's office. The Administrator
was very concerned about ground water.
Those were the days when Superfund
legislation was being considered. Various
legislation had been proposed regarding
aspects of ground-water pollution but no
one was really thinking about the whole
resource.
  The Administrator saw the patchwork
which was beginning to develop and
wanted to prevent it. So he charged us
                                         with developing a ground-water strategy
                                         and, I must admit, I  walked out of the
                                         office and looked at Victor Kimm and I
                                         said, "What's ground water?" I really had
                                         no background in it  at all. So it was an
                                         educational process for me as well. I've
                                         become very  much  interested and  have
                                         seen the issue through since then.
                                         Q
       What is the significance of
Administrator  Ruckelshaus' action
creating an Office of Ground-Water
Protection?
                                         A
       It's extremely significant. Of all
the comments that we have been getting
on the agency's ground-water strategy
from people that we have asked about it
 — environmentalists, industries, state
people — they're unanimous that setting
up this office is extremely important for
EPA. They see it as a focal  point within
the agency to heighten awareness of
ground water as an important issue, to
coordinate policy across the agency, to
work with other federal agencies, and to
work with the states.
  Many people are  interested in this
issue and are grappling with it from their
own perspective. They have been looking
for leadership from EPA on the question,
not so much in the  form of regulations or
guidelines, but  as a resource to help
them work through their  problems. I
think we have a wonderful opportunity to
heighten awareness and work with
experts throughout the country to help
resolve the questions of how to protect
this very complex resource.
                                         Q
       What is the purpose of EPA's
strategy for protecting ground water?

r\    It has several  purposes. The basic
one is to say that EPA is truly concerned
about ground-water protection, about the
resource itself. Even though the agency
doesn't have direct authority as it has
with surface water and air,  it does
administer statutes that affect ground
water. We want to recognize more
formally that responsibility.
  The strategy is designed to clarify the
relationship between EPA and the states
on the issue of ground-water protection.
In ground-water quality the question  is,
how can we work together  within a
framework that recognizes both the basic
state responsibility for  ground-water
protection and the major federal  program
efforts to deal  with specific kinds of
contaminants like pesticides, hazardous
waste facilities, underground injection
wells, and so on? We're attempting to
clarify these roles.
  The strategy is also an attempt to
express our concern about  some sources
of contaminants which aren't being
addressed, and to define the extent of
the problem and  an appropriate federal
response. Contamination from
underground storage tanks is a good
example. We're getting a lot  of
information that they are a major
problem. Some states are doing some
interesting work in that area, but the
question we are addressing  is, when
does a problem like leaking tanks
become of national import and require
our action?
  I think finally the strategy  is an attempt
to get our own act together within EPA.
As we looked  at the various EPA
programs to deal with ground water, we
found that they all deal with  it differently.
They define ground water differently;
they protect it differently;  the kinds and
extent of regulations are different.  The
strategy is an  attempt to state a general
EPA policy on ground-water protection
and  then, over time, to make our own
programs conform to that policy. In that
way, both the regulated community and
states will  have a much more consistent
set of requirements to deal with as they
implement our programs.
                                                                                  Q
       Drafts of the strategy have been
criticized as relying too heavily on the
states to protect ground water. What is
your reaction to that?

 r\    We are  dealing within the existing
 legal framework. The states have the
 major  responsibility  in ground-water
 protection. The federal government has
 some major responsibilities as well but it
 does not cover every potential source of
 contamination, and I'm not sure that it
 should. The critics may feel that the
 federal government can solve  most
 problems. But in the case of ground
 water, many of the protective  actions that
 would have to be taken do involve land
 use, which traditionally in our  country
 has been under state and local
 prerogatives to control. I  think that it's
quite possible for us to forge a
 partnership with the  states which
respects those prerogatives and  yet has
an active and productive  federal  role.
Q
                                                                                        How will your office coordinate
                                                                                 the various parts of EPA in carrying out
                                                                                 the ground-water strategy?

                                                                                  r\    That's a good question. It doesn't
                                                                                  just involve EPA; other federal agencies
                                                                                  have a major interest in this. The states
                                                                                  are extremely interested and feel that
                                                                                  they have to be a part of the action.
                                                                                  Industry groups are  obviously very
                                                                                  interested; the environmentalists are very
                                                                                  interested, and so I'm going to have a
                                                                                  large number of group  activities.
                                                                                    We've set up or are in the process of
                                                                                  setting up several coordinating
i,
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  committees. It may sound bureaucratic
  but I think it's the only way we can do it.
    One is an oversight committee of the
  four assistant administrators at EPA with
  ground-water programs. Jack Ravan is
  the chair and we have Lee Thomas,
  hazardous waste and emergency
  response; Bernard Goldstein, research
  and development; and John Moore,
  pesticides and toxic substances. The
  committee also includes two regional
  administrators, Michael Deland of Region
  1 and John Welles of Region 8. This
  committee will  provide policy direction to
  the Office of Ground-Water Protection. It
  will also give us an opportunity to deal
  directly with the principal operating
  assistant administrators in identifying
  their major concerns and  in  directing our
  work so that it's beneficial to them. Most
  of the things which we are attempting to
  do are designed to enhance their efforts
  in ground water. The Office  of
  Ground-Water Protection is not going to
  be carrying out direct programs. It is a
  policy development and coordination
  office and it's going to be very small.
    Regional administrators are also
  setting up small regional ground-water
  coordination offices in  each  region with a
  function comparable to ours.
    We're setting up a steering committee
 Facts  About  Ground  Water
 What is ground water?
 Ground water is that part of underground
 water, that is below the water table.
 Ground water is in the zone of saturation
 within which all the pore spaces of rock
 materials are filled with  water.

 What is an aquifer?
 An aquifer is a body of permeable,
 saturated rock material capable of
 conducting ground water and yielding
 economically significant quantities of
 water to wells and springs.

 How much ground water
 does America have?
 The United States has approximately 15
 quadrillion gallons of water stored in its
 ground-water systems within one  half
 mile of the surface.

 How much ground water
 does America use?
 Annual ground-water withdrawals in the
 United States are on the order  of 90
 billion gallons per day, which is only a
 fraction of the total estimated water in
 storage.This represents  about a three-fold
 increase in American ground-water usage
 since I950. Most of this is replenished
 through rainfall and offsets the hydraulic
 effects of pumpage, except in some
 heavily pumped, arid regions of the
 Southwest.
   American ground-water  use is
 expected to rise to about 95 billion
 gallons a  day in 1985.

 What are the major uses
 of ground water?
 Public drinking water accounts  for 14
 percent of ground-water use  in the U.S.
Agricultural uses such as irrigation (67
percent) and water for rural households
and livestock (6 percent) account for 73
percent of American ground-water usage.
Self-supplied industrial water accounts
for the remaining U.S. ground-water use.
What percentage of
American drinking water
comes from ground water?

Approximately 50 percent of all
Americans obtain all or part of their
drinking water from ground-water
sources.

Where is America's ground water
most heavily concentrated?

The richest reserves of American ground
water are  in the mid-Atlantic coastal
region, the Gulf Coast states, the Great
Plains, and the Great Valley of California.

What is the largest
American aquifer?

The Ogallala aquifer, which extends from
the southern edge of North Dakota
southwestward to the Texas and New
Mexico border, is the largest single
American  aquifer in terms of
geographical area.

What are the most
important American aquifers?
The most  important American aquifer in
agricultural terms is the large
unconsolidated aquifer underlying the
Great Valley of California. The most
important  ground-water sources of public
drinking water are the aquifers of Long
Island, NY, which have the  highest per
capita usage concentration  in the U.S.
(see story  on page 30).
which involves all the office directors at
EPA: Office of Drinking  Water,
Superfund, etc.—all of the office directors
who have substantial ground-water
responsibility. They will be our
day-to-day operating  contacts, and we
are even now working very closely with a
number of them. We'll be setting up a
group of state officials,  a state-EPA
liaison group, so that we can get their
very direct involvement. They will
represent the major state interests  in
ground-water protection.
  We're setting  up an interagency
committee of the various federal
agencies such as the  U.S. Geological
Survey and the  Nuclear Regulatory
Commission and the  Departments of
Interior, Defense and  Agriculture. They
see the strategy as having potentially
substantial consequences for their
programs. By and large we have gotten
very enthusiastic support from this
group.
  We're also going to be having periodic
briefings and meetings with
environmental groups and industry
people and we hope to coordinate with
them in that way.
  By working with these various groups
on selected areas of concentration, we
think we can affect what's happening. It
will be a challenge. Obviously we can't
coordinate with  everything that goes on
within the agency on  ground water.
Q
       What difference do you think the
ground-water strategy will make in the
long run?
A
       Ground water will be a major
resource for EPA's attention, just like
surface water and air. I think that the
states and others will be able to help us
to use  the strategy as a way of focusing
our mutual concerns and giving as much
attention to ground water as we do to
those other resources. I think we can
help build a public awareness and a
foundation for cooperative action.
Q
       What kind of help will EPA be
giving the states in ground-water
protection? And how will this differ from
the way it has been?
A
       EPA has done a fair amount in the
past, particularly through the regional
offices. It's a question of more and
better.
  Certainly, one of the kinds of help that
we have given is grant support. Our
strategy contemplates enhancing that
through regions working with states on
their ground-water problems and
encouraging them to use our existing
grant resources to focus on the problems
that they see and to  develop their own
state plans and strategies.
JULY/AUGUST

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  We're also interested in enhancing our
existing research programs so that they
are directed toward the kinds of
problems which states see. We're going
to try to coordinate our research
planning efforts and state interests a lot
more closely than we have in the past.
  We're concerned about enhancing
technical assistance to states. The states
certainly are able to hire some expertise;
they're able to buy it through consulting
firms. But EPA has some very unique
people.  Some of our regional and
program people have expertise which we
hope to make available to the states
when they  have special problems.
  I am thinking of one situation in which
Maine was  suddenly confronted with
permitting  a phosphate mine. They had
never dealt with phosphate mining in
that state. Some people from our Atlanta
regional office who had permitted
phosphate  mines and some people from
the state of Florida with similar
experience  hopped on a plane to Maine
and  spent several days providing
technical assistance on that particular
ground-water issue. That kind of  help is
extremely valuable. We will be trying to
identify resource people within the
agency who can provide that kind of
consultation.
                                         Q
       What do you expect to
accomplish during the next year?
                                         A
Q
       How does EPA plan to deal with
sources of ground-water pollution which
are not covered by federal law? One of
the examples is underground storage
tanks.

r\    Our primary emphasis is in
helping the states develop the  capacity to
deal with ground-water problems
themselves by encouraging them to do
the necessary planning and providing
useful information. We can also help
insure that cleanup technology is
transferred from state to state through
shared experiences.
  The second approach is to consider
whether particular problems may require
further federal activity. Underground
storage tanks are one area we  are
looking at. We're trying to get a better fix
on the extent of the problem through a
fairly substantial survey which is now in
the final phase of design  by the Office of
Toxic Substances. We're assessing  the
extent of current control measures.
Should we conclude that  the problem is
big enough for federal action, then  we
are going to have to tackle it. We do
have authority under the  Toxic
Substances Control Act and several  other
acts to take various steps, such as
enforcement  under the Safe  Drinking
Water Act and the Resource  Conservation
and Recovery Act.
       I would like to get the
ground-water strategy out in public. I
want to have set in place the Office of
Ground-Water Protection and  the
regional ground-water offices so that
they are well-functioning institutions.
We're well on our way to that. I would
like to see as a part of that a much closer
working effort between our regions and
states in enhancing state ground-water
activities. We do have some state  grant
guidelines, but to help that along I hope
to have ground-water strategy guidance
in place, adopted by our various EPA
programs within the next year. We're
projecting to have draft guidelines within
the next six to nine months.
  I hope that within the next year  we will
be able to develop a ground-water
monitoring strategy which will provide a
better idea of what we and others, such
as states and the U.S. Geological Survey,
are doing to enhance knowledge of the
extent of contamination  and the nature of
the resource.
  Certainly, I'd like to see us have a very
good handle on  the storage tank
problem. I  don't think that all  the studies
we're planning will be completed  by
then, but we should have them well
underway.
  We are planning with the Office of
Research and Development to establish
an outside top level scientific  review of
our ground-water research. By the end of
the year we should have a major report
from this group  on the directions we
should be taking in ground-water
research.
                                         Q
       What process has been followed
 in developing the ground-water strategy?

 f\    The strategy has been under
 development since late 1979. We had a
 pair of workshops in June 1980, with
 participants from states, industry,
 academia, environmental groups, and
 local government. That group of 80
 people made the fundamental
 recommendations that we've been
 discussing. We had a public review of the
 draft strategy; we've had public hearings
 and gathered comments from hundreds
 of people that helped us put that early
 strategy together.
  Since Bill Ruckelshaus came in June of
 last year, we've put together an internal
 task force to review the results of that
 earlier work; to  review what's happened
 since, including the passage of
 Superfund;  and to consider a number of
 implementing actions. We put together a
 report for the  Deputy Administrator and
 went through several months of internal
debate. We had several meetings with
Deputy Administrator Al Aim and
assistant administrators. Our task force
went through the draft strategy in
considerable detail and finally came up
with a document that we all agreed on.
We briefed industry,  environmental
groups, states, Congress and other
federal agencies on our thinking.
  We got some comments and ideas
from those discussions, incorporated
them back into the strategy, and came
out with  a document in January. We
circulated it among key groups:  trade
associations interested in ground water,
organizations representing states, and
environmental groups. We sent copies to
Congress, to other federal agencies. Our
regional  administrators sent copies to the
governors and other  key state officials
and met  with them to gather their
comments.
  Aim met with representative state
officials here in Washington to get their
comments. We  had another series of
meetings with other federal agencies.
Now we  have arrived at a final document
which reflects all this input.
                                                                                 Q
       Is there any special comment that
you would like to make7

r\    One of the questions that comes
up so often is, why hasn't the job already
been done, and why can't we do it fast?  I
recall the book, In Search of Excellence,
in which the writer commented that
really good national firms take about ten
years to bring out a new  product line. A
ground-water strategy is at least  as
complex.
    We need  to think of ground-water
protection as a long term effort which will
evolve as our understanding of the
resource and related technologies
improves and as public understanding
of the issues  crystallizes. D
8
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 A  State/EPA  Partnership
 by Jack E.  Ravan
 Assistant Administrator for Water
                                        Contamination from land disposal: On
                                        Cape Cod. Massachusetts, ground water is
                                        pumped from a monitoring well into a
                                        bucket Non-biodegradable detergents make
                                        the water foam The detergents originated
                                        about a mile away at Otis Air Base, where
                                        they were disposed of on land between
                                        1948 and  1964  They seeped into the
                                        ground water. Thirty years later, in 1978
                                        when this photo was taken, they were still
                                        present in the ground water.
    Over the past ten years, the states and
    EPA have worked together to bring
about a remarkable reduction  in pollution
of rivers, streams, and lakes. In working
to clean up surface waters, we forged a
partnership based on mutual respect and
an understanding of each other's
capabilities. I  have seen this partnership
from both sides.  I have served in a state
office,  an EPA regional office,  and now at
EPA headquarters, and I can testify to the
importance of coordination. It  produces
results.
  A new challenge—the protection of
ground water—now confronts  many
environmental and other agencies at the
state and federal level. If we are to be
successful in controlling and preventing
ground-water contamination, we must
expand the state/EPA partnership which
serves so well in controlling surface
water pollution and in  other program
areas.
  ERA'S ground-water protection strategy
is an important step toward building a
state/EPA partnership for ground-water
protection. In  its early assessments of
ground-water issues and programs, EPA
found that states have  the clearest, most
direct authorities to protect ground-water
and that many states are developing
comprehensive ground-water programs.
The EPA strategy recognizes clearly
that states are responsible for
comprehensive management and
protection of ground-water resources. In
developing these programs, states assess
the nature and extent of ground-water
contamination problems, develop
appropriate pollution control programs,
and implement control programs on an
ongoing basis.
  EPA's primary responsibility  is to
ensure that national environmental laws
are implemented fully.  Many of these
laws — including the Safe Drinking Water
Act, the Resource Conservation and
Recovery Act, and the Superfund act —
have substantial ground-water
protection provisions. EPA is committed
to providing states with the methods and
means to carry out these federal
programs and to assist states in
developing the institutional capability to
design and implement comprehensive
ground-water protection programs,
including protection from pollution
sources which fall exclusively within
state jurisdiction.
  Over the next several years, EPA will
provide states with technical and
program development assistance, will
assure that states have maximum
flexibility in the  use of grant funds to
develop ground-water protection
programs, and will  direct research and
development  activities to specifically
address state  needs. Each of these
activities is described briefly below.

Technical Assistance

EPA will provide states with assistance in
addressing technical and program design
issues encountered in development of
ground-water protection programs. At
the EPA headquarters level, we plan to
support technology and information
exchange between the regions and
states. EPA regions will play an
important and expanded role in assisting
individual states with particular problems
on a case-by-case basis. EPA regions will
assist states in the following areas:

• analysis of technical or scientific
problems,
• design of state ground-water
protection  programs,

• management of ground water-related
data,

• seminars and conferences for state
staffs, and

• consultation on issues concerning
interstate aquifers.
JULY/AUGUST

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  EPA is just beginning to explore the
range of mechanisms available to deliver
technical and program development
assistance to states. Ideas being
considered include: exchanges of
personnel under the Intergovernmental
Personnel Act; designation of "national
experts" in various aspects of
ground-water protection; increased
support of scholarships for study in
critical ground-water fields; and regular
state EPA conferences or seminars on
pressing ground-water issues or technical
problems.

Grant Support

EPA is encouraging states to make full
use of existing grant programs to
develop ground-water protection
strategies and programs. The work EPA
will support is comparable to activities
begun over the  past several years by
states that are already developing
ground-water protection programs and
will include:

• development  of an overall state action
plan or strategy to  set ground-water
protection goals and to coordinate
ground-water programs  in various
institutions;

• identification  of legal and institutional
barriers to comprehensive ground-water
protection programs;

• development  of general ground-water
programs and design of source or
contaminant- specific ground-water
protection programs; and

• creation of a data management system
to increase the accessibility and quality
of information needed to protect ground
water.

Since a number of states have already
completed some of these tasks,  the
agency will also support activities to
assess the ground-water resource (e.g.,
mapping, selected  monitoring), which are
presented in a broad context indicating
how they fit into an overall state
ground-water strategy.
  Funds from a range of existing grant
programs are eligible to support
ground-water program development
activities, including grants under sections
205(j), 205(g), and 106 of the Clean Water
Act, the Underground Injection Control
program grant under section 1443(b) of
the Safe Drinking Water Act, and the
program grant under section 3011 of the
Resource Conservation and Recovery Act,
if RCRA program commitments are
completed.
  EPA regional administrators will work
with governors to direct grant support to
the state agency or program with the
most complete authority and capability to
undertake or continue statewide
ground-water strategy and program
development. Regional administrators
will also work with governors in
determining the  most appropriate grants
and levels of funding for ground-water
programs in order to assure effective
coordination among various state
agencies involved in  ground-water
protection.

Research and Development

EPA conducts a research program to
provide a broad  range of data and
information  for use by decision-makers
concerned with ground-water protection.
The program is directed toward
improving monitoring technology,
prediction and assessment tools, and
aquifer cleanup methods.
  In the near future, EPA will establish a
group of ground-water research experts
under the Science Advisory Board to
advise the agency of ground-water
research needs. The research group will
include  state officials and one of the
tasks of the  group will be to direct
research and development activities
more specifically toward designing the
tools and methods identified by states as
needed  to protect ground water.
  Other research programs also
contribute to the scientific  bases on
which decisions  about ground-water
protection are made. For instance, a
significant portion  of the research on  the
health effects and removal of drinking
water contaminants is directed toward
chemicals found in ground water.
Research to develop  and evaluate
technology for control of sources (such
as surface impoundments) and
improvements in methodology for
analyzing water samples for trace
constitutents also contribute to our
scientific capability. EPA will work to
assure that findings of research efforts
are made available to states in a useful
and timely fashion.

EPA Organization

In addition to assistance directed to
states,  EPA is taking steps  to improve
coordination of its own  programs. The
ground-water protection strategy
provides for developing
guidelines to improve consistency among
EPA programs related to ground water.
Many states have chosen to implement
EPA programs and have found that
inconsistencies in procedural and
substantive  requirements have made
coordination of EPA and existing state
programs difficult.
  States were also frustrated because
many voices  in  EPA seemed to speak to
ground-water issues. This problem
should be alleviated by the recently
established Office of Ground-Water
Protection that will speak for the agency
on overall ground-water issues and
policies. The  agency will also form a
State Liaison  Group to advise senior EPA
officials on ground-water programs and
issues. In addition, each EPA regional
office will establish a point of
coordination  for ground-water programs,
information, and activities. By setting a
clear course for our own ground-water
program, EPA is a  more reliable partner
for the states.
  In my years of public service I have
had the privilege of serving in both state
and federal governments. I have seen
agencies try to tackle a job alone and I
have seen them set out to work
cooperatively in the intergovernmental
system. Almost invariably, a partnership
among agencies brings the best result.
While we may not  always agree on a
particular issue, it is important that we
work together, share our views, and
express our differences. The EPA
ground-water protection strategy will offer
states and EPA an  opportunity to address
a serious problem  of mutual concern. I
will make every effort  to assure that
states receive the support and
cooperation they need to protect ground-
water. [  ]
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From  the  States'
Point  of   View
by Governor Bruce Babbitt
(D-Arizona)
   Protecting the quality of our
   ground-water resources is one of the
most difficult and complex environmental
and  public health issues of this decade.
Since we don't fish or swim in ground
water most traditional approaches to
water pollution control do not apply, and
we've assumed that it will continue to be
available,  in a pristine condition, for
drinking and other purposes. Today, we
know that ground-water quality has
deteriorated in many areas, with 40
states already having documented
instances  of serious contamination.
  The importance of protecting  this
resource cannot be overstated.  Over 50
percent of us rely upon ground water as
our source of drinking water. Ninety-five
percent of all rural households depend
on ground water. The  withdrawal of
ground water has tripled since 1950 and
now accounts for a quarter of all fresh
water used. These uses include irrigation,
drinking water, and industrial
applications.
  At the same time, the desirability of
preventing contamination, rather than
relying on corrective measures, is clear.
Arizona, in developing its ground-water
quality program,  compared annual
preventative and mitigation costs for
selected industrial impoundments,
surface mining activities, wastewater
treatment  plant removal processes, and
landfills. That study showed that in every
case the annual costs of prevention were
from six to ten times less than the cost of
cleaning up the contamination.  The
preventative approach is economically
justified, even without considering the
less  easily quantifiable and more
insidious public health effects arising
from contamination of ground water.
  While the value and vulnerability of
ground water and the  state of technology
make it clear that protection of the
resource and mitigation of existing
contamination are in our best interest, a
number of factors makes protection a
difficult task.
{Governor Babbitt is the Chairman of the
National Governors' Association
Subcommittee on Water Management.  The
subcommittee is developing
recommendations for state ground-water
protection.)
            *Bc
            3%
                                                      An irrigation well in Arizona
The Difficulty
of Protection
Undoubtedly the most important factor
which makes ground-water quality
protection difficult is the variability of the
resource itself. In some states, ground
water is ubiquitous — plentiful supplies
occurring in large shallow aquifers
encouraging development. In other areas,
and not necessarily distant locales,
ground water  may occur in small
quantities or at depths which preclude
economic use. Aquifers may be confined,
or may flow into each other in complex
hydrologic systems. Subsurface
conditions may be highly permeable, or
may effectively prevent recharge. The
rate of movement of ground water also
varies from inches to miles per year.
  Like any other resource, ground water
changes with use. A vast range of human
activities affects ground-water quality.
While the number of sources of
contamination makes it difficult to
achieve comprehensive controls, each
source will have a potentially different
impact on the ground-water resource,
depending on hydrologic and geologic
conditions at the site, as well as the rate
and nature of the discharge, and the
facility design. Contaminants may move
quickly to ground water, or may take
JULY/AUGUST
                                                                                                                  i I

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years to reach the aquifer. Once in
contact with ground water, similar
variations in transport rate occur.
  Finally, the art and science of
ground-water management are relatively
young. Historic involvement in the
development and protection of surface
waters has produced relatively plentiful
expertise and considerable data.
Unfortunately, this is not the case when
considering ground water. No common
monitoring system exists, and, while a
number of states have mapped their
aquifers and have sufficient data to
determine the location and quality of
their ground-water resources, most  states
do not have a comprehensive
understanding of ground-water
occurrence and conditions.
  In spite  of these difficulties, states are
progressing in their efforts to address
ground-water quality. Like the resource
itself, protection systems and goals  vary.

State Efforts

Whether aggressively pursuing
comprehensive programs or beginning to
examine the need for new regulatory
efforts, states are focusing on
ground-water quality protection. Activities
focus on several broad approaches that
are not mutually exclusive:

• Classification of aquifers by quality,
vulnerability, or use;

• Control of contamination sources on
either a site-specific basis, or by
discharger class;

• Development of numeric or narrative
standards for ground water quality; and

• Controls on land use, with emphasis
on facility siting or protecting of sensitive
recharge areas.

  While these broad approaches form the
basis for protection programs, other
factors bear heavily upon ground-water
program development. Soils and
geology, water yield, and linkages
between surface and ground water all
must be considered in planning for
protection of this resource.
  In  considering these factors and
combining them into regulatory or
management strategies, states must
make numerous judgments about current
and future users, the relationship
between statutory systems for allocation
and quality protection, the willingness of
an informed public to assume risks, and
the wisdom of depending upon the
development of new technologies for
mitigation of resource damage.
Population density,  levels and types of
industrial  activities,  and overall
dependence on the  resource exert major
influences over the design of protection
systems.
  A quick review of existing systems
reveals that states  have addressed these
considerations in formulating protection
strategies. Maine and New Hampshire
have, across-the-board, designated their
aquifers as drinking water sources. The
New Jersey system combines
classification standards and source
controls. Wisconsin has instituted a
non-degradation policy, while
Connecticut, North Carolina, and
Wyoming have intricate classification
systems.
  Arizona's ground-water quality
protection system takes a site-specific
approach to protection of current  and
future uses of ground water. Broad
narrative standards which focus on use
protection will be applied through a
system of permits on specific sources.
General permits, to guide classes  of
activities which are of concern in their
cumulative effects, as well as area
permits which would cover a number of
similar discharges  in a specific location,
are also proposed.
  The general belief that states possess
the legal authority  to control
ground-water quality requires careful
review. While the police powers of states
would presumably suffice in combination
with  general water quality statutes,
attempts to implement aggressive
protection strategies have triggered
successful legal challenges. A thorough
examination of the extent of state
jurisdiction and subsequent legislative
action are essential to the pursuit  of
comprehensive state protection.
  Putting  aside the question of legal
authority, it  is clear that states have a
basic responsibility for protection  of
ground-water resources. Less obvious,
but as important, is the role which local
governments can play in the
development and execution of state
programs. Both the New Jersey Pine
Barrens and Long Island, N.Y., are
models of local land use approaches to
ground-water quality protection. Bills in
the last two sessions of Congress  offered
the opportunity to enact, nationwide, a
voluntary state  local planning and
source control process relying on  the use
of zoning  and designation of sensitive
areas. Local and regional governments,
depending on their  interest, resources
and expertise, cannot be ignored as
potentially valuable components of
protection programs.
  The federal government also plays a
significant role in ground-water
protection. Federal activities directly
influence states and  the condition of the
ground-water resource.
Federal Efforts

The influence of federal agencies on
ground-water quality arises from a
variety of existing regulatory programs,
the collection and interpretation of data
on specific  ground-water resources and
related research and development, as
well as in the operation of federal
facilities.
  The federal regulatory picture is  a
patchwork of controls on sources and
quality-related uses of the resource. The
Resource Conservation and Recovery Act
is the most important federal statute
which seeks to  minimize ground-water
contamination.  The Act confers broad
authority to EPA {and through EPA to the
states) for hazardous waste management
and solid waste controls, including a
variety of permit standards as well as
authority to "restrain imminent hazards."
The Clean Water Act offers a regulatory
framework  which can protect ground
water as that resource is related to
surface water. The Toxic Substances
Control Act and the Underground
Injection Control portion of the Safe
Drinking Water  Act also regulate specific
sources of contamination. Other portions
of the Safe Drinking Water Act, in
regulating quality of water at the tap, can
be used to  drive ground-water protection.
And finally, the Superfund program is
already addressing the mitigation of
ground-water resource damage.
  EPA, in the preparation of its
ground-water strategy, has already
acknowledged that statutory authority
could be more effective if  it were better
focused and less hampered by
inconsistencies in terms and application.
The process for achieving  that goal will
be difficult, and the agency should be
commended for embarking on those
efforts. The involvement of states in the
process is crucial if changes in the
operation and scope of programs are to
be accomplished.
  Federal research, data gathering, and
technical and financial assistance are all
crucial to the development of effective
state protection programs. Immediate
needs include:

• Expedited EPA development of
drinking water standards for nationally
significant ground-water contaminants
and, in the  interim, the provision by EPA
of guidelines to assure consistency
among states in health protection and
enforcement actions;

• Development of additional methods to
assess contamination with emphasis on
both detection at the source and on the
quality of drinking water;

• Development of health and
environmental effects data for various
levels of contaminants in ground water;
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•  Elaboration of risk assessment and risk
management methodologies for ground-
water contaminants; and
•  Assistance in aquifer mapping, and
development of ground-water modeling
capabilities.
   Accelerated remedial action  at known
sources of contamination will also assist
in driving the development of  new
treatment and restoration technologies.
   Finally, the federal government, in
operating federal facilities including
military bases, must move aggressively
both to eliminate ground-water
contamination sources and undertake
cleanup activities. This area  is ripe for
acceleration.
   Left begging at this  point is the
question of the need for overarching
federal criteria or goals for ground-water
quality protection. It is on this question
that the most interesting public policy
debate affecting ground-water quality will
turn.
   The nature of the ground-water
resource and the large variations in
emphasis and structure among existing
state  ground-water programs  tend to
argue against the promulgation of a
national ground-water program. States,
with their inherent responsibility for
water allocation and protection activities,
jealously guard the right to control this
resource. But admittedly the pattern of
state  activities is uneven. Citizens of two
different locales should not suffer as a
result of different levels of health
protection.
   Yet the ability of national guidelines
and criteria to produce accelerated
ground-water protection is also
questionable. Inaction cannot be
attributed only to insensitivity. Limited
resources and the complexity of existing
environmental programs inhibit the
development of new protection
programs.
   While the jury is still out on  the need
for a  federal program, much can be done
to apply existing authorities and
resources throughout  government more
effectively. We must work with the tools
which are currently available, and resist
any attempts to  retreat from protecting
this most valuable resource, i
Protecting  Ground-Water:
Five  States  Report
What particular ground-water problems
do various states face? How do they
handle them? EPA Journal asked these
questions of ground-water officials in five
states.  Here are their reports:
         Robert E.  Moore
   Assistant Deputy Commissioner
      Connecticut Department
     of Environmental Protection
Providing safe drinking water to
Connecticut citizens is the primary goal
of the state's ground-water management
program. Approximately one-third of our
3,100,000 people rely on ground water
for their water supply source. Twenty
percent rely on individual household
welfs for drinking water without any
benefit of routine water monitoring to
assure potability.
  By March 1, 1984, the Department of
Environmental Protection had
investigated 493 well contamination
problems. Of those, 380 were private
domestic wells;  56, public water supply
wells; and 57, commercial wells. Most
problems were due to contamination by
solvents,  followed by pesticides, spills of
gasoline or oil, landfill  leachate, and
finally road salt. Most of the problems
have or are being resolved by
development of  a new source of supply,
treatment, use of bottled water, and
removal of the contamination source.
  Clearly  prevention of contamination
must be the main element of any
ground-water  management program,as it
is in Connecticut's, but other key
elements must include enforcement and
pollution abatement processes, control of
water withdrawal, monitoring, and
research.
  In 1980 the Department adopted
ground-water  quality standards along
with its surface water quality standards.
These standards set all goals and policies
for ground-water use and protection.
Four use standards or classes were
adopted: two (GAA & GA) suitable for
drinking water use without treatment
with no sources of pollution allowed; one
(GB) may not be suitable for drinking
without treatment due to past land uses
or disposal practices and no need exists
to restore these waters to potable
quality; and one (GO defining areas
which may be most suitable for certain
waste disposal activities such as landfills
and hazardous waste facilities due to the
hydrogeologic characteristics of the site.
The entire state has been classified and
mapped into these classifications. Over
90 percent of the land area falls into the
GAA or GA class, and less than  0.3
percent into the GC classification.
  In the work required to develop this
system, the mapping of hydrogeologic
characteristics, pollution sources, land
uses, etc., it became clear that our
management program lacked several key
tools which were needed to meet the
goals being set. The first was the control
of water withdrawal from the ground. In
1982 the Department prepared and
submitted to the General Assembly a bill
requiring a permit for the diversion of
surface or ground water over 50,000
gallons per day.  This bill was adopted as
Connecticut's Water Diversion Policy Act
of 1982 and provides to the Department
the authority to allocate the state's water
resources.
  Several other additions to our statutory
authority for enforcement and regulation
beyond the  present authorities requiring
permits for wastewater and leachate
discharges were needed and
subsequently pursued and adopted in
1982. They include:
1. The authority to ban by regulation the
use of toxic substances or priority
pollutants in septic system additives and
cleaners. Regulations requiring product
labeling and prohibitions have been
adopted.
2. The authority to set standards by
regulation for the design, installation,
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testing and removal of underground fuel
and chemical storage tanks (over 5,000
gallons). Regulations have been through
the administrative process and are
awaiting final adoption.

3. The authority to require persons or
municipalities who have polluted a water
supply wel! to provide potable water to
the affected persons. This law is a very
important and powerful tool designed  to
get safe drinking water to the people as
soon  as possible while the months or
years of cleanup activities go on. The Act
provides a municipality a grant to cover
50 percent of the capital costs of
providing potable water from funds
derived from a state hazardous waste
generators tax where there is no obvious
source of contamination or where the
responsible  party has no  assets.

4. The authority to delegate Department
authority to local municipal agents or
agencies. This allows development of
local ground-water protection programs
with a strong statutory basis. Delegation
of programs to towns will include:
administration of underground fuel
storage regulations, additional review
and permit of large septic systems (only
single residential and small commercial
are now delegated), expanded rights of
investigation and monitoring, and control
over many commercial activities.

Connecticut's ground-water program
direction for the future is towards
prevention through control of land uses
by state ground-water standards and
classifications and  by development of
comprehensive local  aquifer protection
programs. Our development efforts today
are aimed at providing education,
training, and assistance to towns in
establishing needed land  use controls
and establishing  locally enforceable
performance standards for small
commercial  and industrial establishments
(gas stations, laundromats, dry cleaners,
etc.,  and home industries such as photo
developing,  printing, etc.).
  We now feel we  have the tools to carry
out an effective, comprehensive
ground-water management program at
the state,  and soon, the local level. While
enforcement tools  are capable of solving
today's problems, the lack of national
drinking water standards  for pesticides
and other toxic, hazardous and
carcinogenic substances hinders and in
some cases  halts problem resolution and
stifles anticipation  and  prevention of
future problems. National standards for
maximum contaminant levels and
understandable risk factors must be
promulgated as soon as possible to
define safe drinking water and to allay
public confusion  and fear.
     Dr. Rodney S. DeHan
            Administrator
        Ground-Water Section
        Florida Department of
      Environmental Regulation
Florida is not known as a highly
industrialized state; yet it has its share of
potential point and nonpoint sources of
pollution. Examples of these are:

• Some 6,000 largely unlined surface
impoundments containing wastewater
that percolates  into the ground water;

• Some 7,000 drainage wells directly
discharging water or wastewater of lower
quality than the receiving aquifers;

• Some 40,000 underground storage
tanks that are either leaking or will
potentially leak contaminants into  the
ground water within the next two
decades;

• Large agricultural lands that receive
fertilizers and pesticides, some of which
find their way into  the ground water;

• Large stretches of coastal aquifers that
have been intruded with salt water;

• Hundreds of  potentially uncontrolled
hazardous waste sites and;

• Hundreds of  thousands of septic tanks,
some of which  are constructed in the
water table aquifers or are periodically
subject to submergence due to water
table fluctuation.

The current large scale contamination of
ground water by the pesticide ethylene
dibromide (EDB) is but one manifestation
of the potential problems facing the
resource.
  The Florida Department of
Environmental  Regulation (DER) has
developed Ground  Water Rules which
classify ground water into four classes
according to water quality as measured
by Total Dissolved  Solids (TDS). These
are:

Class G-l: "Single Source Aquifers" for
potable water use and having a TDS of
3000 mg/l (milligrams  per liter) or  less.
Aquifers in this category receive the
highest protection.

Class G-ll: Potable water use having a
TDS of 10,000 mg I or less. This class
constitutes the majority of Fiorida's
aquifers.
Class G-lll: Nonpotable water use having
a TDS of over 10,000 mg I  in unconfined
aquifers.

Class G-1V: Nonpotable water use having
a TDS of over 10,000 mg I  in confined
aquifers. G-IV aquifers receive the lowest
degree of protection.

The rules define the water quality
standards used in determining ground-
water pollution, monitoring, and cleanup
of polluted aquifers. The standards
include the Primary and Secondary
Drinking Water Standards, as well as the
narrative "Minimum Criteria" standard.
The latter includes any chemical agent
that is judged toxic, carcinogenic,
teratogenic or mutagenic.
  Until numerical  values are developed
for these standards, the DER will attempt
to prohibit the presence of such
chemicals in the ground water. In April
1984 Maximum Contaminant Levels
(MCL) for eight such chemicals were
added to Florida's drinking and
ground-water standards. Compliance
with the  new MCLs will be in effect by
June 1985 for community water systems
which serve 1,000 or more people, and
by January 1987 for those serving fewer
than 1,000 people.
  The DER has been delegated Primary
Enforcement  Responsibility "Primacy" for
the Underground  Injection Control (UIC)
Program. The Department  has developed
a UIC rule that is more stringent in
certain aspects than the federal
guidelines.
  In 1983 the Florida legislature enacted
the Water Quality  Assurance Act,
considered the most important
environmental legislation in decades.
Ground-water protection was addressed
in the act through fifteen steps,  including
data collection, a monitoring network,
protection of  public water supplies and
establishment of a Pesticide Review
Council. Other steps were a hazardous
waste management program, promotion
of public awareness and inspection of
package sewage treatment plants,
thought to be a potential ground-water
pollution source. Also, state funds were
provided to replace, match or augment
federal funds designated for building
sewage treatment facilities, cleanup of
contaminated sites, emergency cleanup
of spills,  and  other cases.
  The above programs and activities are
directed entirely towards the protection
of ground-water quality. Water quantity
issues such as availability and
consumptive  use permits are the
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responsibility of five agencies known as
the Water Management Districts (WMDs).
Considerable effort is underway to
achieve maximum interaction between
DER and the WMDs so that ground-water
quality issues are better coordinated.
  As our population continues to grow
so will our dependence on the
ground-water supply. One major issue
facing Florida in the  1980s is
accommodating the expected population
growth without destroying the
environment that instigated such growth
in the first place. Ground water is a
critical factor in this highly complicated
equation.
      John W. Gaston,  Jr.
                Director
      Division of Water Resources
      New Jersey Department of
       Environmental Protection
Ground-water contamination in the State
of New Jersey has of necessity received
rigorous regulatory attention. The
reasons are many. Approximately 50
percent of New Jersey's population and
80 percent of its area is dependent upon
ground water. Population density is high
and the state's geology is complex and
highly variable, ranging from fractured
shale and crystallines to cavernous
limestone and coastal plain sediments.
Compounding these conditions is an
economy heavily dependent upon
chemical and refining industries. The
Department of Environmental Protection
has estimated that between 10,000 and
15,000 firms in New Jersey are engaged
in the production of chemical and
petrochemical products. New Jersey also
generates about eight percent  of the
nation's hazardous waste, the highest of
any state. As an inevitable consequence,
aquifer contamination has occurred in
many locations through poor industrial
housekeeping, spills and accidents of all
types, deliberate dumping, illegal
discharges, leaks from subsurface
storage landfills, and so on.
  Avenues for the release of
contaminants  are ail too numerous.
Contamination has had, moreover,
decades of opportunity to reach the
state's unconsolidated and bedrock
aquifers. Contrary to public belief, most
of the pollution sources are at facilities
which had some type of permit to
operate. However, these earlier permits
did not consider ground water an integral
regulatory factor.
  Ironically, state and federal laws
passed in the 1970s inadvertently
increased the quantity of pollutants
discharged to the state's aquifers as
federal laws concentrated on "fishable
and swimmable" goals for surface
waters. To quote a predecessor of mine,
"Waste will  migrate to the area of least
regulation." This certainly proved to be
true in New Jersey as many surface
discharges were replaced by percolation
and evaporation lagoons, spray
irrigation, and landfills which accepted
chemical wastes. The growth of  New
Jersey's ground-water pollution control
program has paralleled a rising public
awareness of ground water and  its
possible contamination by toxic
substances.
  The first organized effort to investigate
ground-water pollution  in New Jersey
began in 1974 with four geologists.
Currently, there are  12 hydrogeoiogists
and geophysicists dedicated to
ground-water contamination
investigations.
  Today as we discuss  ground-water
problems and the potential for future
problem sites, I think it is critical  to
understand that  the State of New Jersey
has the most sophisticated and
comprehensive ground-water permit
program in the United States. Unlike
federal law,  New Jersey law requires that
any discharge of waste into the ground,
including non-hazardous waste,  must
have a permit and comply with water
quality standards. This  requirement
protects the future use of the resource
and controls discharge.
  This is illustrative  of the type of
commitment New Jersey has made to
implementing an aggressive ground-water
protection program. In this respect, New
Jersey is years ahead of most other
states.
        Maxine S. Goad
          Program Manager
        Ground Water Sect/on
    New Mexico Environmental
        Improvement Division
In New Mexico, much of which is arid,
water has historically been recognized as
a resource which  is limited, critical, and
basic. Ground water is particularly
                  Maxine S. Goad

important in this state because: 95
percent of the water supplied by public
systems is from ground-water sources;
three-fourths of the state's population is
supplied drinking water by these
systems; one-half of the total water
annually withdrawn for  all uses in New
Mexico is ground water; and the only
source of water in many areas of the
state is ground water.
  Potential sources of ground-water
contamination in the state include mining
and milling,  oil and gas production,
refinement and distribution, public  and
private domestic sewage disposal,
dairies, power plants, and  other industrial
discharges.
  In the 1970s,  concern  in  New Mexico
about ground-water quality led to the
development of a comprehensive
statewide regulatory program to protect
that quality.  The program has two basic
aspects: (1) setting ground water
standards (as of 1984, 35 numerical
standards plus a generic "toxic pollutant"
provision have  been adopted); and (2)
requiring by regulation that a  discharger
demonstrate he will not cause those
standards to be violated at any place of
present or foreseeable future use.
  This  combination results in a detailed
enforceable permit. The stated purpose is
to protect all ground water which has an
existing concentration of 10,000 mg I
(milligrams per liter) or less total
dissolved solids. The regulations apply to
all discharges of effluent or leachate onto
or below the surface of the ground,
including well injection,  seepage from
surface impoundments or leach fields,
land application of wastes, and any other
discharges which  may impact ground
water, except those specifically
exempted. Oil and gas production
activities, for example, were exempted
from these regulations because they
were covered by other state regulations
already in effect.
  Development of the standards and
regulations began in 1974; they were
adopted by the  New Mexico Water
Quality Control  Commission in 1977 after
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extensive public hearings and have been
upheld by the New Mexico Supreme
Court. Based on seven years experience
in administering them, the following
general observations can be  made:

(1) These regulations have proven
extremely effective in preventing
ground-water pollution from  new and
newly modified discharges; improving
pollution controls at facilities already
operating before the  1977
implementation of the regulations is
more difficult and progress has been
slow though steady.

(?.) Numerical standards define clearly for
all parties what is allowed, but cannot  be
adopted for all possible  pollutants;
therefore a generic provision for toxic
pollutants is also necessary.

(3) Having standards that apply in ground
water, rather than detailed design and
operation requirements, allows
consideration of site-specific conditions,
an important advantage in New Mexico
where hydrologic and geologic
conditions vary greatly.

(4) A substantial commitment of expert
staff is required for site-specific
evaluations.
New Mexico's regulatory program for the
protection of ground-water quality is well
established, workable and effective.
However, new industries and other new
facilities continue to  enter the state and
new knowledge is being acquired about
existing conditions,  resulting in
newly identified problems. It is necessary
that development of  the regulatory
program be a continuing process to cope
with these  newly identified problems, to
incorporate new knowledge, and to keep
the program at a high level of
effectiveness.
        Louis W. Bercheni

               Director
       Bureau of Water Quality
             Management
     Pennsylvania Department of
       Environmental Resources
The Pennsylvania Department of
Environmental Resources has been
aggressively involved in ground-water
quality protection since the early 1960s.
Our programs rely heavily on the
development and implementation of
regulations and permits to prevent and
abate pollution from all major sources
where disposal, treatment, and storage of
waste materials occur. We are also
committed to the inclusion of
ground-water quality considerations in
environmental planning. Our
ground-water quality staff initially
               Louis W.  Bercheni
consisted of a single unit composed of
five hydrogeologists. This has
subsequently grown to more than 50
hydrogeologists, distributed over three
bureaus in the Department.
  Much of our recent program growth
has been stimulated by federal expansion
into the areas of solid waste, hazardous
waste and mining regulation as well as
state program development. Rapid
changes in  internal  Departmental
structure and adjustments to these
regulatory demands have resulted in
extensive diversification in our program
requirements and approaches to problem
solving.
  Though all of our programs protect
ground-water quality for water supply
use, no legally specified ground-water
quality standards exist. Only a small
portion of our potential pollution sites
are monitored. Differences in  monitoring
design, sampling frequencies, chemical
parameters analyzed, ground-water
isolation characteristics, and data
management make  it difficult to conduct
comparative evaluations, hinder program
uniformity,  and result in inconsistent
levels of protection. In addition, although
ground water in  the Commonwealth is
generally of excellent quality, no effective
mechanism exists to give a true measure
of existing regional  water quality,  and
subsequently, to evaluate the overall
success of our program efforts.
  We  are currently developing
recommended program modifications to
solve  these problems. Our first step
would be to define ground-water uses
that are to be protected. The statewide
uses "water supply" and "surface water
maintenance" would be protected at the
EPA drinking water  standards and
surface water quality standards,
respectively, for  all ground water having
a total dissolved solids (TDS)
concentration of 10,000 mg.l (milligrams
per liter) or less. Specific siting criteria
would define special waters requiring
nondegradation.
  The only  ground waters with a natural
TDS concentration  of more than 10,000
mg.'l are deep, water-bearing formations
containing brines. These are unsuitable
for use and would remain  unprotected.
Design and monitoring standards
included in injection permits would
insure containment and protect overlying
ground water. The formal  delineation of
mixing and buffer zones would be
required for all major  land
treatment disposal systems.
  Microcomputers and ground-water
models are being used to check the
credibility and identify technical
inconsistencies in permit proposals.  A
Departmental task force has  been
established to review  and  implement
recommendations designed to improve
program uniformity.
  Data management and a viable
assessment mechanism are critical to the
success of our ground-water quality
management efforts. To improve this
program area, 478 ground-water basins
of approximately 100 square miles each
were delineated and prioritized by
evaluating quality, uses, pollution
sources,  and  pollution dispersion
potential. Basin boundaries were
computerized by EPA's Environmental
Photographic Interpretation Center and
placed in EPA's system for storage of
water quality data (STORET).
  A fixed station network consisting  of 25
stations in each higher priority basin is
being proposed to supplement ongoing
data gathering efforts  and  chronological
controls for data evaluation.  Surveys will
be relied on  to supply additional
information in areas where major data
gaps or significant pollution exist. Data
generated is to be used for quality trend
analyses, program evaluations,
permitting, facility site evaluations, and
to fulfill  systematic reporting
requirements such as  Section 305(b)
obligations under the federal Clean Water
Act. All monitoring data are being placed
on STORET. Unique data will be  stored
on microcomputer discs until such time
as evaluations are required, whereupon
they will  be placed on STORET with
other ground-water sources being
systematically monitored.
  In anticipating the public presentation
of our recommended program
modifications within the next few
months, the  Department held a seminar
for policy level decision makers in
Pennsylvania. It was conducted by
Geraghty and Miller, Inc., a ground-water
consulting firm, for representatives of all
Departmental environmental  advisory
groups and upper management level
staff on the fundamentals of  ground
water. The intent of the seminar was to
develop a basic understanding and
knowledge about the complex nature of
ground water. This should  enhance the
public's  participation and input on
recommended program modifications
which are critical to our future success. L
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Sources  of
Ground-Water
Pollution
by David W. Miller
(David Miller is a geologist and a partner in
Geraghty & Miller, Inc., a ground-water
consulting firm in Syosset,New York.)

   To the general public, the subject of
   ground-water contamination conjures
up pictures of people dressed in space
suits examining abandoned drums of
hazardous wastes. Although there are
hundreds of such sites across the nation
that obviously represent a  health  threat
to community water supply wells,
hazardous waste sites are only a very
small piece of a very complex picture
when it comes to describing potential
sources of ground-water quality
degradation. In fact, less than one third
of all sources of ground-water
contamination may be  caused by
regulated waste discharges such as
landfills and injection wells. Although
existing federal and state regulations
focus on waste discharges and hazardous
waste facilities, a majority  of water
supply contamination incidents appear to
be caused by nonpoint sources such as
accidental chemical spills, disposal of
toxic consumer products, leaks from
underground storage tanks, and  run-off
from urban and agricultural land.
  The sources of ground-water
contamination are essentially the same
as those for any other form of water
contamination. They include practically
every type of facility or structure installed
by man and are present in millions of
places across the face of the land. Some
sources or causes of ground-water
contamination involve discharges of
contaminants that are wastes or
wastewaters. Others involve discharges
of contaminants that are not wastes at all
but are represented  by stockpiles of raw
materials or the application of fertilizers
and pesticides. Still  others are not even
discharges but can be due to the
infiltration into the ground of polluted
river water or the intrusion of salt water
into a well because  of heavy
ground-water pumpage in a coastal area.


Some Major  Sources
of Ground-Water Contamination

Surface impoundments: Industrial
wastewater impoundments are a source
of serious ground- water contamination
Application         .                  '      •
because of their large number and their
potential for leaking hazardous
substances that are relatively mobile in
the ground-water environment. In some
heavily industrialized sections, for
example, the areal  extent and the toxic
nature of the contaminants have  ruled
out the use of ground water from
shallow aquifers. The contaminants cover
the full range of inorganic chemicals and
organic chemicals normally contained in
industrial wastewaters. Those
documented as having degraded
ground-water quality include solvents,
phenols, acids, heavy metals, and
cyanide.
  Surface impoundments are used by
industry to store wastewater as part of
the treatment process, and they are often
unlined. Pits, ponds, and lagoons are
also used in municipal waste treatment
processes and for storing agricultural  and
mining wastes. They  can range in size
from a swimming pool to hundreds of
acres. They number in the hundreds of
thousands  across the United States.
JULY/AUGUST
                                                                                                               17

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Landfills: Land disposal sites for solid
waste can be sources of ground-water
contamination because of the generation
of leachate caused by water percolating
through the refuse and waste materials.
Precipitation falling on a site either runs
off, returns to the atmosphere via
evaporation and transpiration, or
infiltrates the landfill. Contamination
problems are more likely to occur  in
humid areas, where the available
moisture exceeds the ability of the waste
pile to absorb water.
  Leachate from such sites  is a  highly
mineralized fluid with such  constituents
as chloride, iron, lead, copper, sodium,
nitrate, and a variety of organic
chemicals.  Where manufacturing wastes
are included, hazardous constituents are
often present in the leachate (e.g.
cyanide, cadmium, chromium, and
chlorinated hydrocarbons).  The  particular
makeup of the leachate is dependent
upon the industry using the landfill or
dump.
  There are about  20,000 land disposal
sites that accept municipal wastes. Most
are open dumps or poorly sited and
operated landfills,  and most receive
                                      some industrial wastes. There is no
                                      national inventory available on privately
                                      owned industrial land disposal sites.
                                      However, it is estimated that 90 percent
                                      of industrial wastes that are considered
                                      hazardous end up  in landfills  mainly
                                      because it is the cheapest of all waste-
                                      management options.

                                      Septic tanks and cesspools: Septic tanks
                                      and cesspools rank highest in total
                                      volume of wastewater discharged directly
                                      to ground water and are the most
                                      frequently reported sources of
                                      ground-water contamination.  Most of the
                                      reported problems are related to
                                      individual homesites or subdivisions
                                      where recycling of septic fluids through
                                      aquifers has affected private wells used
                                      for drinking water. Except in situations
                                      where the recycling is so quick that
                                      pathogenic organisms can survive, the
                                      overall health hazard from on-site
                                      domestic waste disposal is only
                                      moderate, with relatively high
                                      concentrations of nitrate representing the
                                      principal concern.
                                        Twenty-nine percent of the  population,
                                      residing in about 19.5 million
                                      single-housing units, disposes of
                                      domestic waste through individual
                                      on-site systems. Regional ground- water
                                      quality problems have been recognized
                                     only in those areas of the greatest
                                     density of such systems, primarily in the
                                     northeast states and in southern
                                     California. Across the U.S., there are four
                                     counties (Nassau and Suffolk, N.Y.; Dade,
                                     Fla.; and Los Angeles, Calif.), each with
                                     more than 100,000 housing units served
                                     by septic tanks and cesspools, and there
                                     are 23 other counties with more than
                                     50,000 such units. Data on discharge to
                                     industrial septic tanks are not available.

                                     Collection, treatment, and disposal of
                                     municipal  wastewater: Municipal
                                     wastewater follows one of three direct
                                     routes to  reach ground water: (1) leakage
                                     from collecting sewers, (2) leakage from
                                     a treatment plant during  processing, and
                                     (3) land disposal  of the treatment plant
                                     effluent. In addition, there are two
                                     indirect routes: (1) effluent disposal to
                                     surface water bodies that recharge
                                     aquifers, and (2) iand disposal of sludge
                                     that is subject to leaching. Although the
                                     volume of wastewater entering the
                                     ground-water system from these various
                                     sources may be substantial, there have
                                     been few documented cases  of
                                     hazardous levels of constituents of
                                     sewage affecting well-water supplies,
     Sources of Ground-Water Contamination

                                        Precipitation
                                                                   Evapo transpiration
                                                V;\V\\^\\N
            or Disposal           Pumping Well
              Injection Well
                                                                                                          Pumping Well
                                                                                                          \      I
                                                                                           Lagoon, Pit or Basin
Land Spreading     Septic Tank
Landfill, Dump or Refuse Pile
                    Cesspool   Sewer
                                Q
                                                                 Water Table


                                                                 Water Table Aquifer
                                                 Perception

                                                     t
                                                                 Confining Zone
                                                                 Artesian Aquifer (Fresh)

                                                                 .
                                                                 Confininq Zone
                                                                                                   Ground-Water
                                                                                                   Movement
                                                                                                   Intentional
                                                                                                   Input
                                                                                                   Unintentional
                                                                                                   Input
                                                                 Artesian Aquifer (Saline)
          Discharge or Injection
Ui
                                                                                                             EPA JOURNAL

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largely because the subject has not been
studied in detail.
Mine spoil piles and tailings: All forms of
mining can produce products or
conditions that contribute to
ground-water contamination. Although
every mine is a potential contamination
hazard, few studies of the effects of
mining on ground-water quality have
been carried out.
  With both surface and underground
mining, refuse piles and slurry lagoons
are probably the major  potential sources
of ground-water contamination. Where
aquifers underlie these sources, water
with a  high acidity (except in arid
regions) and an elevated level  of total
dissolved  solids can percolate  to ground
water.

Waste disposal wells: Industrial waste,
sewage effluent, spent cooling water,
storm water and oil field brines are
discharged through wells into  fresh- and
saline-water aquifers in  many parts of the
U.S. In the literature the greatest
attention has been given to deep
disposal of industrial and municipal
wastes through wells normally drilled
300 metres or more into saline aquifers.
About 300 such wells have  been
constructed in 25 states, 20 of  which  are
presently  operating. They pose a
comparatively small contamination threat
compared with the  many shallow wells
injecting contaminants into freshwater
aquifers or the tens of thousands of wells
reinjecting oil field brines into  deep
geologic units.
Accidental spills: Percolation of liquids
spilled at the land surface can  be another
serious threat if the ground is permeable
and allows downward percolation. For
example, many petroleum spills
penetrate  into the ground, travel
downward, and corne to rest on top of
the water  table. Underground storage of
chemicals, chemical wastes, or petroleum
products in steel or concrete tanks
presents a potential hazard  because
metal corrosion or concrete deterioration
may ultimately permit seepage of
contaminants into an aquifer.
  The leaching of soluble solids stored
on the land surface is another  practice
that can be responsible  for the
contamination of ground water. These
situations occur, for example, where
rainwater  dissolves soluble materials
from piles of highway de-icing salt or
where industrial raw materials have been
allowed to spill at railroad or truck
loading areas.
Types of
Contaminants

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

Biological organisms: Biological
contamination  of ground water occurs
when human or animal wastes enter an
aquifer. Microorganisms present in the
wastes may be carried by ground water
into nearby wells used for drinking water.
The first time an illness was traced to a
well contaminated with sewage was
during a cholera epidemic in London in
1854.
  The travel of bacterial pollutants
through the ground has been studied by
collecting samples from test wells.
Indications are  that the bacteria seldom
travel more than 100 feet from a source.
Exceptions are  where the aquifer is
fractured or cavernous, allowing bacteria
to travel rapidly for great distances.
Studies also have shown that bacteria
are largely removed by filtration.
Although most microorganisms die  out
rapidly in ground water,  bacterial
pollution may occur locally:

• In heavily populated suburban areas
where numerous septic tanks discharge
large quantities of waste into an aquifer.

• Near leaking  wastewater lines.

• From leaks in storm sewers, storm
sewer overflows, or flows directly from
city streets into the ground.
• Near improperly operating sewage
treatment lagoons and ponds.

• From poorly  designed  land-spreading
and wastewater recharge operations.

Inorganic chemicals: Inorganic chemicals
are substances  of mineral origin.
Inorganic chemical contamination differs
from biological contamination in a couple
of important ways: the persistence of the
pollutants, and  the difficulty of their
removal from water.
  EPA has set standards for  the
maximum permissible concentrations of
certain substances in drinking water. For
example, the standards require  that
concentrations  greater than 0.05
milligrams per liter of toxic elements
such as arsenic and chromium will
jeopardize a ground-water source for
drinking purposes. Levels of cadmium
greater than only 0.01  milligrams per liter
will also threaten supply wells. Excessive
concentrations of arsenic, cadmium, and
chromium in ground water are often
found where electroplating wastes have
been discharged into the ground. Lead
can get into the ground water where
gasoline has entered the aquifer through
leaking pipelines and service station
tanks.

Organic chemicals: Organic  chemicals
are substances containing predominantly
carbon, hydrogen, and oxygen. There are
many different kinds of organic chemical
contaminants  associated  with industrial
wastes. They represent a complex group
of byproducts and compounds produced
with major industrial products. Organic
chemical contamination is most often
caused by:

•  Solvents used for degreasing septic
tanks.

•  Spills and leaks.

•  Industrial, municipal, and  other wastes
disposed on land.

The Future

Today considerable effort is  being
expended toward investigating and
cleaning  up some of our  past mistakes,
especially those involving hazardous
wastes, that have led to the
contamination of ground-water supplies.
These activities, however, must be
matched in the future  by  the equally
important effort of preventing
ground-water  pollution in the first place.
Because  of the diverse nature of sources
of contamination and their widespread
occurrence, much of the responsibility for
protecting ground-water resources must
be left to state and local agencies. This  is
especially true because programs to
protect ground-water quality will not  be
successful unless they  reflect the close
relationship of the land, ground water
and surface water. Long-term
ground-water  quality depends on what
we do with the land.
  We are still learning more  and more
each year about the impact that various
sources of contamination can have on
ground water. In fact, as we  have
become more knowledgeable, our
emphasis on which source to concentrate
our regulatory efforts has changed
drastically over the decades. Thus, there
is  a critical need to give ground-water
resource  protection the high  national
priority that it  deserves and to  encourage
federal, state  and  local  agencies to
develop the required strategies and
programs to carry out  this priority.
JULY/AUGUST
                                                                                                                      19

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Contamination   of  Drinking
Water
 by John M. Gaston
    Prior to 1979 the common theme, at
    least  in California, was to abandon
 marginal drinking water sources obtained
 from surface streams (creeks, springs,
 lakes, etc.) and develop new ground-water
 sources  (wells). The public  health
 philosophy as preached by  the state and
 local agencies stressed the  hazards that
 might contaminate surface
 sources—waste discharges, livestock,
 illegal dumping, etc.—and praised the
 pure, pristine ground  water.
   To be  sure, there are many benefits to
 be seen  by developing a ground-water
 source for drinking water. These benefits
 include,  especially for the small
 community or individual, a lesser degree
 of maintenance, fewer treatment
 chemicals, a relatively trouble-free
 operation and, as it was thought at that
 time, the ultimate protection afforded by
 the depth of the well.
   In contrast to this, public health
 officials felt that many surface sources
 were disasters waiting for a time to
 explode. The threat of mine drainage,
 livestock waste contamination, illegal
 spills and countless other hazards
 awaited the  hapless water  system
 operator with the misfortune of having to
 deal with a surface water source. Those
 hazards in surface sources  still exist and
 the benefits of most ground-water
 systems still exist, but the water supply
 "community" or "industry" has learned
 quite a lesson since the late 1970s.

 • The myth of the protected, pristine
 ground-water source has been shattered.

 • Public confidence in the  water utility
 industry and the public health
 community has been shaken.

 • The professional water supply
 community — engineers, scientists, etc.
 — has been taken aback by recent
 (John Gaston is a senior consultant for
 water quality and treatment with CH-^M Hill,
 an environmental consulting firm, and
 former State Sanitary Engineer for the State
 of California.)
ground-water problems and, to state the
case politely, is "re-grouping".

• The laboratories and techniques
employed in water analysis are much
more sophisticated than in the recent
past and are able to  detect compounds at
very low (part per trillion) levels.

How did we get in this fix and what
have we learned in the process?
  The discovery of contaminated drinking
water wells in California in the late 1970s
was not unusual. It was unusual,
however, if the contaminant was
anything other than  nitrate or bacteria.
Common knowledge held that improperly
constructed wells could allow surface
water containing either land drainage or
other waste into the  well and thereby
contaminate the source.
  The nitrate contamination  problem
seemed to be prevalent in agricultural
areas and therefore was thought to be
directly  related to fertilizer or animal
wastes.  Indeed a direct cause and effect
was established in a number of wells
located  in feed lot and poultry areas.
Bacteriological problems also occurred  in
these areas and seemed to be directly
related to  poorly constructed wells.
  Other ground-water problems —
arsenic, fluoride, selenium, iron,
manganese — were  thought to be
naturally occurring, rather than related to
"outside"  contamination. These
problems were relatively scarce and
could either be treated (iron  and
manganese) or new  sources could be
developed to eliminate the problem.
  Most community water system
operators frequently test the water for a
variety of compounds and
constituents—bacteria, inorganic and
organic  chemicals. The testing
procedures and compounds  are
established by state  and federal law and
specific  Maximum Contaminant Levels
(MCLs) are set for each constituent. No
wells, at least in California, had shown
any sign of contamination by the
"regulated" organic  chemicals contained
in either the state or federal  listing.
 Honest Disbelief

 As a result of this long history of
 negative results from ground-water
 samples there was some honest disbelief
 when "unheard-of" organic compounds
 were discovered in the late 1970s. The
 reaction by the regulatory  agencies was
 confused. Many of the contaminated
 wells were on or near industrial sites,
 and the obvious connection between the
 site and the contamination was made.
 This happened in  specific cases involving
 two industrial  sites in California. Initially
 the fear was that the "protected"
 ground-water theory was wrong. This
 quickly changed to the position that
 these were "special" cases involving
 massive contamination and that
 ground  water as a sacred resource was
 still safe.
  Advances in analytical techniques in
 the laboratory about this time caused
 some consternation. When a group of
 "clean"  ground-water samples was being
 analyzed for one of the "special" case
 constituents, a low but consistent level of
 the contaminant was detected in all of
 the samples. This  caused the regulatory
 people—laboratory and engineers—to
 develop and advance the "laboratory
 error" theory that  was then to be used to
 explain the unbelievable. It was as
 though one day the sun came up in the
 east, proceeded to the north, and then
 set in the west. We were all confused
 until we discovered  that we had  moved
 to South America.
  Eventually a series of events led the
 regulatory agencies  to conclude that
 organic contamination of ground water
 was a fact. These events included:

 • The installation  and operation  of new,
 sophisticated analytical laboratory
 instruments provided by EPA grant
 funds;

 • The realization that there could only be
 a limited number of "laboratory errors";
• The independent confirmation of
contamination  by different  laboratories;

• The development and verification of
the theory that various organic chemicals
 .'I!
                                                                                                         EPA JOURNAL

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 could move downward through the soil
 and into the ground water.

   To quote an old bromide, the rest is
 history. As more samples were taken,
 more contamination was found. Similar
 reports from other states confirmed the
 phenomenon, and the "pre-1979
 syndrome" of pure, pristine ground
 water was dead. The  regulatory agencies
 began to  move ahead in several areas
 but, to the dismay of the consumer and
 public interest groups, more discoveries
 and questions were being raised without
 any hope for answers or solutions.
   ft was (and is) a classic regulatory
 dilemma. If one problem is found, should
 all resources be bent  to finding a solution
 to that problem, or should other
 problems be investigated at the same
 time? ff resources don't exist (and they
 don't) at the state or federal level to fix
 all these problems now, should we
 provide token support for each problem or
 should we concentrate only  on the
 biggest problems and let the others slide
 until we have the resources?

 Patterns Emerge

 Following a period of chaos, patterns
 have emerged to assist the regulatory
 agencies and the public:

 • It appears that many ground-water
 contamination sites can be located by
looking at land use patterns, industrial
grouping and other related factors. This
will save valuable laboratory resources
and allow the states to limit their
sampling to areas where problems are
more likely to be found.
• If contamination is found the levels are
likely to be fairly low—part per billion
range—and the lifetime risk from
ingestion low. Rarely have situations
involving acute hazards been found. This
is not to imply that organic
contamination is good or even
acceptable, but  it does buy some time for
the various agencies to fix the problem.

• Intermediate solutions have been
developed to either treat contaminated
sources or to provide alternate drinking
water sources to the impacted
population.
• Advice from toxicologists indicates that
a widespread epidemic is not
forthcoming or even probable. No
incidents of acute poisoning were
demonstrated and most of these
compounds have very long-term, if any,
effects.
• New laws at the state and federal level
have been promulgated to assist  in the
discovery and cleanup of many of the
problem sites.
                                                                                                                   .
  As more sites are found, and everyone
hopes that the frequency decreases soon,
several questions still exist in the mind of
the public and all other parties. For
example, if these problems were first
found in the late 1970s, how long before
that date did the contamination occur? If
ground water is contaminated and a
"responsible party" cannot be found,
who pays for the cleanup and treatment?
  The water supply industry has
traditionally been very low key and has
generally kept in the background. Now
the industry has been pushed into the
front row. Both the public and the
industry may feel deceived at some point
because everything was going smoothly
and steadily until the organics and
ground-water problem came along.
Several predictions might be made in
light of what we've seen in the recent
past:

• More contamination will be found and
those states that are not ready with
laboratory facilities and contingency
plans may suffer.

• Water rates will increase to cover the
costs  of monitoring and treatment of all
supplies.

• Analytical techniques will continue to
improve and some areas once thought to
be "clean" will turn out to be
contaminated.
• Water utilities will look more closely at
their existing physical facilities and may
choose to improve surface sources rather
than develop new ground-water capacity.

  In light of all this the public must be
terribly confused. It is faced with a
continuing barrage of bad news about
water supply. The water utility industry
must enlist the support of the public and
regain its confidence. The public, on the
other  hand, must take the time to
become informed and be willing to play
a role in the decision making process. If
the average citizen only knows what he
reads in the newspaper, the story may
not be complete and the decision making
may be very one-sided. Q
JULY/AUGUST
                                                                                                                      21

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Potential   Health  Effects
from  Ground-Water  Pollution
by Dr. Robert A. Goyer
There is a growing awareness of the
   potential toxicologic effects of synthetic
organic chemicals that have
contaminated ground-water sources of
drinking water. This awareness is the
result to some extent of monitoring
chemicals in fresh water supplies, as well
as the realization of the potential for
contamination from human activity.
Particular culprits are the thousands of
improperly located toxic chemical waste
dumps now found throughout the
country.
  The problem has received the attention
of a number of government and  state
health agencies;  the best known  reports
are from the Council on Environmental
Quality, New York State Department of
Health, and a four-volume National
Academy of Sciences report on drinking
water and health. The problem is further
highlighted in a recent editorial in
Science magazine.
  The topic has immense public  health
significance since it is estimated  that
roughly 50 percent of Americans receive
their drinking water from wells fed by
ground water. More than 700 specific
synthetic organic chemicals have been
identified in various drinking water
supplies. Nationally, 20 percent of public
water systems contain trace but
measurable amounts of volatile organic
contaminants; 28 percent of public water
systems serving  communities with
populations over 10,000 contain volatile
organic contaminants.
  Among these chemicals are pesticides,
organic solvents, and a long list of
halogenated compounds. Many are
known carcinogens; many have other
known toxicologic effects. But the
concentration of any one chemical is
likely to be very low. The public health
•':'  G , • ' is Deputy Directoi of the
N,itiun,il /n.',//(i/f(? of rnvnoninoiit;i/ tt(\ilih
       •
question, therefore, concerns what
possibilities there are, if any, that a
particular chemical contaminant or,  in
fact, the mixture of chemicals in drinking
water is likely to cause disease among
people in the general population.
  The response to this  question is
enormously complex and not completely
answerable at the present time. There are
now a number of studies designed to
investigate associations between the
drinking of chlorinated  surface waters
and cancer. These studies do suggest
increased risks of gastrointestinal and
urinary tract cancer, but comparable
studies on populations consuming only
well water are not available. However,
there is only  minor overlap between
chemicals found in disinfectant-treated
surface waters and in ground water.
  Health problems stemming from
surface drinking  water are thought to be
related to byproducts of chlorination,
particularly the four trihalomethanes
(chloroform, bromoform,
bromodichioromethane, and
dibromochloromethane). There are a
number of possible approaches within
the regulatory context for the control of
these substances, such as substitution of
other types of disinfectants, treatment to
reduce precursor concentrations, or even
removal after their formation.
  Synthetic organic chemicals in ground
water present a less predictable and less
controllable problem in spite of nature's
filtration and cleansing processes. For
instance, trichloroethylene (TCE),
probably the most commonly occurring
organic chemical contaminant in well
water, has been  found  in 13 percent of
community water supply wells in Nassau
County, N.Y., with maximum
concentration of 300 ppb (parts per
billion).In 1979, the  Pennsylvania
Department of Environmental Resources
found widespread contamination of
drinking water supplies in Montgomery
and Bucks counties, with a maximum
concentration of 1,400 ppb. Human
exposure was confirmed by detection of
metabolites of TCE in urine.
  The most direct way of establishing a
link between such exposure and effect on
health is by epidemiologic study,
particularly case control studies which
relate exposures in persons with and
without disease. Although such studies
are useful  in appropriate circumstances,
they are retrospective and often depend
on information from  death certificates for
diagnoses. Occupational, dietary, and
smoking histories are often incomplete or
unobtainable.
  In an effort to assess the influence on
health from TCE in Montgomery and
Bucks counties, physicians from the
Centers for Disease Control (CDC)
reviewed the number of deaths
attributable to liver cancer over the
19-year period, 1960-1978, and found no
difference with the incidence of this
tumor in the rest of Pennsylvania.
Weaknesses  of this approach are that the
population studied may not be large
enough to show small increases in
tumors or the period of  residency in the
region of investigation and, hence,
exposure to TCE may be too short to
allow a sufficient latency period for the
tumor to develop.
  Another problem common to
studies of  persons in the
genera! population is that it is often
difficult to find control cases without
exposures to the chemical(s) in question.
In  an effort to establish exposure to
synthetic organic chemicals among
residents of Love Canal, blood samples
were analyzed for synthetic organic
chemicals. A small group of young
volunteers, intended  to serve as
unexposed controls,  did indeed have
measurable blood levels of many of the
chemicals  in question.
  Furthermore, corrective action based
on evidence  of human disease is not
ideal public health action. Rather,
methods that are predictive and not
dependent on detection of illness seem
                                                                                                        EPA JOURNAL

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more desirable. Such approaches are
dependent on adequate toxicologic data
for the chemicals in question and
appropriate methodology for
extrapolation of the data to man. For
many of the organic chemicals found in
ground water, toxicologic evaluations
have been performed, particularly in
terms of characterization of carcinogenic
potential,  but quantitative estimates of
human  risk from such data require
additional refinements. A review of
current methodologies suggests that it is
possible to make crude estimates of
carcinogenic risk from animal data for
drinking water that contains synthetic
organic chemicals.
  Toxicologic data for prediction of
disease from synthetic chemicals for end
points other than cancer are also
available in terms of characterizing the
effect, but useful quantitative data of this
type are not common. Although there is
some evidence that TCE may be a
carcinogen, there is also evidence that
TCE and other structurally similar
halogenated hydrocarbons are
nephrotoxins (toxic to the kidney).
Experimental studies have shown that
chronic exposure to these compounds
may produce glomerular lesions
sometimes leading to the nephrotoxic
syndrome and renal  failure.
  Although cancer, as a toxicologic end
point, receives the major focus of
concern, chronic renal failure is also  a
major human  disease entity. The
incidence  for end-stage renal disease
may be as high as 15.6/100,000 people
per year, and the Social Security
Administration indicates that its cost for
the end-stage renal disease program was
$286 million in 1974 and is rising each
year.  Costs in 1984 are projected to be
more than $3  billion.
  There is also evidence that the
nephrotoxicity of TCE Is made more
potent by simultaneous exposure to
polychlorinated biphenyls and
polybrominated biphenyls. This serves
as a reminder that ground water
contaminated with synthetic organic
compounds is always a complex mixture
of chemicals, each with its  individual
potential for carcinogenicity and other
toxicities.
  Consideration of risk is almost always
calculated on the basis of toxicologic
data on single chemicals. But what about
synergistic or suppressive interactions
that may occur with exposure to
chemically-contaminated ground water?
Without direct experimental study of
each complex mixture in the proportions
present in nature, it seems virtually
impossible to be predictive with the
present state of understanding.
  Considerable thought has been given
to this problem. A  report of a National
Research Council Committee outlined a
number of  basic principles  underlying the
behavior and toxicity of mixtures, such
as chemical-chemical  interactions,
interactions with macromolecules, and
alterations  in cellular responsiveness or
reactivity because of the actions on one
or more members  of a mixture. These
principles, however, have not been
assembled  into any quantitative measure
of the toxicity of specific complex
mixtures.
  In the absence of a  more definitive
approach, a World Health Organization
criteria document on methods in toxicity
testing describes an additive model but
restricts the application  of the model  to
mixtures of chemicals that act at the
same site producing the same type of
acute toxic  effect and  having similar
dose-effect relationships. Even so, such a
model, when tested experimentally, may
determine an effective dose that is
greater or lesser than the predicted dose.
  And finally, factors of individual
susceptibility further complicate the task
of predicting the toxicologic effects of
complex mixtures of even single
chemicals in ground water. Such factors
may subtly or dramatically alter the
predictability of a biologic or toxicologic
reaction. These include stress conditions
of the host,  nutrition and dietary factors,
personal habits, and pre-existent disease
states.
  It has been shown that animals
exposed to hepatotoxins, such as carbon
tetrachloride, benefit from a diet that is
high in carbohydrates and low in fat,
whereas low caloric diets enhance  the
hepatoxicity of carbon tetrachloride.
Protein-deficient diets reduce the activity
of hepatic microsomal enzymes and the
level of cytochrome P450, resulting in
decreased ability to metabolize
xenobiotics, and diseases of the kidney
reduce the ability to excrete chemicals.
  From  these considerations, it becomes
apparent that the science of predictive
toxicology requires considerable
additional research. The potential
problems posed by synthetic organic
chemicals in ground water  add to the
urgency for  the further development  of
this science  and suggest a number of
specific  research needs. .
JULY/AUGUST
                                                                                                                        23

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EPA  Researchers  Seek  Answers
to  Ground-Water Contamination
by Bob Burke
Many Superfund On-Scene Coordinators
will be able to identify with the scenario
that follows. EPA has directed the
removal of tons of contaminated
materials from a hazardous waste dump
close to a residential area. In a public
meeting, the On  Scene Coordinator
reports that all immediate health threats
have been removed, but notes the
continued presence of ground- water
pollution beneath the site  area.
Neighbors begin pressing demands that
the ground water be restored to pristine
conditions as promptly as possible. The
On-Scene Coordinator realizes the
obstacles  involved in cleaning up ground
water at this particular site, but it is
difficult to articulate them clearly or to
make on-the-spot commitments. Months
of hard and often dangerous work seem
a/most obscured at that moment as a
very wide gap emerges between public
expectations and technical possibilities.
  Superfund officials aren't the only ones
who are often confounded by ground
water-related issues.  Ground-water
protection is a highly complex and often
frustrating issue that affects a host of
federal and state environmental
responsibilities. This story describes the
major challenges of ground-water
protection and some of the fascinating
and innovative areas of research and
field work that EPA is involved in to solve
these problems.

\J round-water pollution poses
challenges to research scientists and
environmental managers that defy
conventional measures for detecting,
monitoring, and cleaning up surface
water pollution. EPA research
laboratories at Ada, Okla.,and Las Vegas,
Nev., are working on these problems,
which fall into three broad but
interrelated areas.

Ground-water pollution is elusive.
Ground water  is extremely vulnerable to
pollution. Once a pollutant enters ground
water, it follows the flow of the hydraulic
gradient and forms an irregular,
sometimes finger-shaped form of
contaminated water called a plume. A
plume usually occupies a relatively  small
part of an aquifer that  can range from a
few feet to more than 2,000 feet beneath
the earth's surface. The plumes then
travel to points of ground-water
discharge which can be wells or surface
waters.
  Looking for a polluted plume or
locating its pathway into and through an
aquifer without knowing its point of
origin is akin to the proverbial search for
the needle in a haystack. It is often
difficult and expensive to determine
where a plume originated, what
pollutants it contains, its precise location
and configuration, and what private or
public water supply it may ultimately
pollute.
Ground-water pollution is latent. Ground
water generally moves slowly at
velocities that  can average from a few
feet per day to a few feet per year. The
contamination of ground water by any
source may go on for months or even
years before it is finally detected when it
reaches a public water supply or an
ecologically vital body of surface water.

Ground-water pollution is difficult to
clean up.  Natural transformation or
degradation of pollutants is often a  slow
process and may not occur at all because
of the nature of the subsurface
environment and the kinds of polfutants
involved. Restoration  of polluted ground
water, even under the  most favorable of
conditions, is time consuming, extremely
expensive, and technically challenging.

Ground-Water Prediction:
The Waterloo Field Study

Two major problems with detecting and
monitoring underground pollutants are
accessibility to the ground-water
environment and the heterogeneity of the
subsurface. Subsurface conditions
generally differ significantly over short
distances. Monitoring wells are
expensive and sample only a small
segment of the aquifers but are
practically the only way to access the
ground water. It is extremely  difficult to
observe the inception of pollutants from
various manmade sources and activities,
and their penetration of the earth's
surface on their way to a ground-water
supply. This missing picture of the
inception of ground-water pollution may
hold an important key to predicting the
various ways that pollutants will  behave
in ground water.
  Now researchers are working to
unravel as much of this puzzle as
possible in a  unique field  investigation
funded by EPA, and carried out by
Stanford University and the University of
Waterloo in Ontario, Canada.
  In 1982, a research team from the two
universities injected pollutants into a
shallow, relatively homogeneous,
uncontaminated portion of an aquifer in
Ontario, parts of which had been polluted
by an existing landfill. They used several
synthetic organic compounds (major
sources of ground-water contamination)
at different concentrations, and
monitored the ground water in order to
determine the behavior of each
contaminant.
  As expected, the pollutants  formed
plumes which are being monitored by
the team using a dense three-
dimensional network of sampling
wells. By September 1983, over 9,000
samples had  been taken using specially
designed devices to ensure sample
24
                                                                                                    EPA JOURNAL

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            •
                       I

  /  v

                                        v.
                                                                                                           vs
                                                                           .   \v
                                                                                H   ' *
 New extraction techniques have revealed many previously unknown microorganisms  The dense black spheres supported by a braided
 shaft in this photo are a new discovery. EPA researchers are trying to determine how well these "ground-water  bugs" degrade pollutants
 integrity. Most samples were taken in ten
 2-3 day sessions distributed over the year
 to obtain three-dimensional snapshots of
 how the pollutants were being
 distributed throughout the aquifer.
   There have already been some
 important observations in the ongoing
 Ontario field investigation. The size,
 shape, location, and movement of
 polluted plumes vary depending on the
 kind, quantity, and concentration of
 pollutants they contain. Estimates of
 concentration, location of the center of
 the plume, and  other pertinent
 information for  each pollutant have also
 been observed.  The study is leading to a
 better understanding of how specific
 pollutants may behave and move in the
 pathway from the earth's surface to the
 aquifer, and how these factors  influence
 subsequent movement and behavior
 within the aquifer.
   Various contaminants move through
 the subsurface at vastly different rates
 once they  are in ground water. This may
 have special significance for eventually
 predicting  how long various
 contaminants  are likely to pose health
 hazards and if and how they disperse in
 ground water.
For example, at an observation point
downgrade from the injection point, the
study showed  that chloride became
highly concentrated very shortly after it
entered into the ground water but was
almost totally  undetectable after 50 days
in the aquifer.  Dichlorobenzene,
conversely, showed no concentration at
all until it had  been in ground water for a
month,  but then it showed low levels that
remained relatively constant for at  least
several  months. The concentration  of
several  other pollutants also showed
sharp differences. These discoveries are
important, although further verification  is
needed under  different conditions from
those experienced in this study.

Biodegradation  Research:
Working with Ground-Water
Microorganisms
There was a time, not so long ago, when
most experts considered ground water
devoid of life.  Now, it appears that
ground  water  is often teeming with
microbes, some of which may be
potential allies in  cleaning up certain
forms of ground-water contamination. In
fact, the total biomass of bacteria in the
subsurface may be greater than the
biomass of bacteria in rivers and surface
soils.
  Research into these microbes is being
carried out by EPA's Robert S. Kerr
Environmental Research Laboratory in
Ada, Oklahoma, described in a recent
Smithsonian magazine as the "premier"
facility for ground-water research in the
United States. Using carefully controlled
procedures, researchers from this
laboratory have been learning  more
about "ground-water bugs" and their
ability to degrade various pollutants.
  The Ada laboratory's field team
examined subsurface organisms in
samples taken from a ground-water
aquifer near Lula, Oklahoma. Their
results clearly showed that certain
subsurface organisms degrade some of
the organic pollutants that may enter
their environment. Positive results have
been obtained for the chemical toluene,
as wel! as for styrene and bromo-
dichloromethane.  But problems
have been observed as well. There is
preliminary evidence, for example, that
trichloroethylene (TCE) occasionally
undergoes biotransformation which
results in an extremely undesirable
product called vinyl chloride.
  The precise environmental conditions
required for these various
transformations are, as yet, not
JULY/AUGUST
                                                                                                                      25

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                                         Work carried out af the EPA lab in Ada.
                                         Oklahoma is pan of the agency's ground-
                                         water research program. Here a scientist
                                         determines biodegradation by passing water
                                         containing organic chemicals through
                                         columns of authentic, uncontammated
                                         aquifer materials.
understood and research to characterize
the microorganisms in ground water is
still under way.
  The possibility of employing microbes
to degrade wastes and restore aquifers  is
fascinating even if the production of
contaminants such as vinyl chloride
demonstrates the possibility of some risks.
Can certain microbes be introduced into
contaminated ground water to degrade
specific pollutants? Can genetic
engineering  eventually produce
"superbugs" capable of  degrading
ground-water pollutants with which
existing microbes seem  unable to deal?
At present, answers to such  inquiries
remain in the realm of hopeful
speculation.
Other Research

EPA laboratories in Ada and Las Vegas
are engaged in other areas  of research
aimed at meeting the complex challenges
of ground-water  protection. Some of
these  include:

• Early warning  monitoring systems are
being examined  intensively by EPA's Las
Vegas laboratory with a view to detecting
the movement of pollutants before they
reach  ground water. These  systems rely
on tracking pollutant percolation in the
zone above the water table  known
technically as the "unsaturated
subsurface." This early warning
monitoring program involves soil testing
methods and the extraction of fluid
samples with suction devices. It is being
developed and tested for practical use in
hazardous waste land treatment
operations.
• The use of fiber optics for detecting
and monitoring the movement of
contaminated plumes in ground water.
Fiber  optic technology won't serve to
make  detection and monitoring programs
significantly more accurate, but it will
considerably reduce the costs associated
with locating and charting the movement
of small plumes  in relatively large
underground aquifers.

« Geophysical methods are aimed at
reducing the number of expensive wells
required for taking samples from
contaminated ground water. The present
system depends on drilling  a large
number of wells in a given  aquifer.
Improved  site selection may be able to
ascertain needed information from a
smaller number of wells which can
provide more representative samples.
Geophysical methods are also being
developed at the Las Vegas lab to map
salt water contamination deep in the
subsurface of oil fields where the salt
water is a major pollution problem to
fresh  ground water.
•  Under the Underground Injection
Control Program, research is being
carried out to develop methods for
locating abandoned wells and assuring
that injection wells maintain mechanical
integrity so that ground water is isolated
from sources of contamination.

• The development of various simulation
models which allow the prediction of
contaminant behavior according to the
type of ground-water system under
investigation.

Significant progress is being made in
areas of ground-water research  such as
locating pollution plumes and monitoring
the ensuing  changes in ground-water
quality. There are even some
breakthroughs occurring in the very
difficult area of rehabilitating polluted
aquifers.  These achievements are
important first steps in a long and
difficult journey toward the solution of
the nation's  ground-water problems. In
other areas,  however, we are still in our
infancy in dealing with many of the
problems involved. We must expand our
knowledge of  pollutant behavior in the
subsurface environment so that we can
better select sites for waste disposal and
treatment. We must evaluate the extent
of contamination at existing sites, carry
out remedial actions in a cost-effective
way, and deal with new chemicals in an
environmentally acceptable manner.
  Ground-water research may not be a
good line of work for those who are
impatient and  those who always expect
quick and tangible results from their
technical and professional efforts.
Instead, these  efforts require
perseverance,  discipline,  and the ability
to accept the realization that months and
years of extensive research may yield
incomplete results. The complexity of
ground-water issues makes EPA's
regulatory and research mission  both
challenging and frustrating. D
26
                                                                   EPA JOURNAL

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The  Future  of the
Ground-Water  Resource
Philip Cohen
Chief Hydrologist
U.S. Geological Survey
 T"he nation's ground-water resource,
 '  including both the liquid and the rocks
 that house it, is an important share of the
 national stock of water. Rising
 appreciation of  its economic and environ-
 mental significance is attracting
 unprecedented  protective and managerial
 attention.  A remarkably efficient crystal
 ball would be required to forecast the
 enlarging  role for ground water in  our
 society, and associated impacts on its
 quantity and quality.  Until such an
 instrument is perfected, estimates of
 future demands on ground water, and of
 the physical and chemical fate tying
 ahead for  it, must rely on conventional
 predictive methods. Principal among
 these are:

 • Accumulating knowledge of ground
 water, including its geological,
 hydrological, and chemical
 characteristics;

 • Lessons learned from past water and
 waste management practices;

 • Application of the hydrologist's
 growing ability to predict and to estimate
 quantitatively the responses of
 ground-water systems to imposed
 hydraulic,  chemical, and structural
 stresses; and

 • Employment of demographic,
 economic, and technologic projections to
 anticipate  future demands on the
 resource.

 Based generally on these approaches,
this article is an  effort to characterize
 factors that shape the future for the
 nation's ground  water.
Enlarging role
for ground water

It is reasonable to conclude that the
pattern of increasing ground- water
usage defined in past years, as illustrated
graphically in the chart on page 29, will
continue into  the near future.
Ground-water withdrawals in 1985
probably will  amount to about 95 billion
gallons a day, continuing to  be about
one-fifth  of the total freshwater usage in
the nation. To meet rising demand, well
fields will be enlarged, new well fields
constructed, and the number of
individual wells increased to supply
single homes and other small uses.
Augmentation of inadequate
surface-water supply systems may be
one principal  avenue of growth. Rapid
expansion of  metropolitan areas,
particularly in the water-short Southwest,
accounts for a sizable increase in public
supply ground-water pumpage during
the past half-century,  and that growing
demand is likely to continue as long as
the Sunbelt attracts new residents.
  The nation has also experienced
country-wide  and regional droughts with
the ground-water resource being the
focus of attention. Development of water
supplies capable of weathering long
periods of drought is an attractive goal
that increases in appeal with each
passing drought event. Although the
ground-water  resource is not immune to
drought,  its sheltered  environment and
the large volumes of ground water in
storage lend the resource to
supplementary water service  during
times when streamflow and surface
storage are deficient.
  The "drought resistant" characteristic
of ground water is already utilized on an
unplanned basis over much of the
country. For example, the extensive
drought of 1977 caused failure of surface
water supplies in California's  Central
Valley. However, increased pumping
from active irrigation wells, reactivation
of idle wells, and drilling of thousands of
new wells successfully maintained the
flow of irrigation  water and minimized
the impact of  the drought on food
production. Institution of organized plans
for supplementary irrigation pumpage
during drought throughout the nation
would result in a sizable increase in
ground-water usage.
  Irrigation, an established agricultural
practice in the West, is now being
adopted in humid areas of the country as
well. It is the largest usage of ground
water, amounting to slightly more than
60 billion gallons a day in 1980, when
pumpage exceeded one billion gallons a
day in eight western states and two
eastern states.
  In Nebraska, irrigation pumpage
amounted to 6.7 billion gallons a day in
1980.  The development of center-pivot
equipment, whereby a moving sprinkler
pipe rotates around a central supply well
to irrigate a large circular area, has led to
a manifold increase in irrigated acreage
and enlarged dependence on ground
water as a source of irrigation supply.
With the aid of center-pivot irrigation and
other  newly developed equipment,
irrigation usage of ground water in
Georgia rose 1,000 percent between  1975
and 1980.
  Large amounts of water will be
required for new  energy-producing
industries, particularly for the generation
of power. Wherever surface sources  of
water  are insufficient or already fully
committed, ground water is likely to  be
targeted for additional water supply. The
Madison Aquifer, for example, an
extensive and largely unutilized water
source lying beneath the Great Plains
states, is the subject  of intensive
investigation as a potential source of
water  for mining operations, coal-slurry
pipelines, and power generation.
  Finally, because of the decreasing
availability of surface sites suitable for
large water reservoirs and the
environmental objections they often
precipitate, ground water is becoming a
substitute source of supply for many of
the needs presently fulfilled by surface
reservoirs.
JULY/AUGUST
                                                                                                                 27

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Consequences of
expanding usage

Continued increases in extracting ground
water have unavoidable impacts. From a
hydraulic point of view, pumpage from
an aquifer or ground-water basin must
result in lowering ground-water  levels.
Deepening water levels, though
necessary to progressive development,
impose both a loss of well yield  and the
expense and power consumption of
increased pumping lift. The lower water
levels may also  reduce flows of
hydraulically connected streams by
decreasing natural discharge of ground
water to them. With continued pumping
and still further  declines in water levels,
water from streams may be  induced to
flow into ground-water systems.
Inflowing stream water of inferior quality
will  degrade the quality of ground water.
  Similarly, saline ground water
bordering the edges of the continent may
be induced to flow toward coastal well
fields, threatening freshwater supplies.
Upward movement of saline  water
underlying fresh ground water
throughout most inland areas is likewise
stimulated by pumpage of fresh ground
water, and may rise to contaminate fresh
supplies.
  Extracted ground water may be
returned to the ground-water system
after use by artifical recharge and
irrigation field seepage. Recycling of
ground water in these ways extends the
supply  but progressively reduces the
quality  of the water. In a somewhat
similar  manner, subsurface disposal of
liquid wastes adds to the volume of
ground water in storage but jeopardizes
its quality.
  Land  subsidence caused by the
extraction of ground water is less well
known  than problems of supply  and
quality, but this costly structural
phenomenon is becoming more
prevalent with increasing development of

In certain areas of the country,
ground-water quantity as well as quality can
he a serious problem.  Markers on this pole
in California's San Joaqum Valley indicate a
dramatic drop in the land surface — a toss
of 29 feet between  1925 and 7977.  The
subsidence was caused by ground-water
withdrawal, primarily for irrigation.
the nation's ground water. Subsidence is
associated with pumping from artesian
and semi-artesian aquifers containing
fine-grained sediments susceptible to
compaction  in response to the lowering
of water levels. Subsidence has been
identified in California, Arizona, Texas,
Louisiana, South Carolina, Virginia, and
several other states.
  The most  serious cases are in the
Santa Clara  and Central Valleys of
California and the Houston-Galveston
area where damaging land-surface
declines ranging from about 3 to 30 feet
have been measured. The textural
structure of  the sediments is altered
permanently by compaction, with
consequent  permanent loss of water
storage capacity. A long list of other
economically significant harmful effects
include structural damage to buildings,
levees, roads, and bridges;  inundated
coastal areas; and changes in grade of
canal systems and irrigated land slope.
  Deterioration of ground-water chemical
quality reduces its usefulness. During the
past decade a great deal of information
was published on the actual and
threatened degradation of the nation's
ground-water resource as the result of
intentional and incidental introduction of
waste liquids to the subsurface. Other
articles in this issue of EPA Journal
describe the geographic extent and
severity of contamination of the resource,
and measures being implemented to
cope with the situation.
  Although some degradation is
inevitable in our industrial society,
chemical deterioration of ground water to
the point of erasing its utility constitutes
virtually the same loss of resource
incurred by  voiumetric depletion, and
usually without having put the "lost"
water to a useful purpose. From a purely
hydrologic standpoint, a case can be
made for utilization of subsurface pore
space for controlled storage of waste
liquids in judiciously selected hydrologic
28
                                                                                                             EPA JOURNAL

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settings. However, much of the
ground-water contamination identified at
this time originated under circumstances
devoid of effective control measures and
with limited understanding of, or
indifference to, the receiving hydrologic
system.

The future

The slow rate of movement of ground
water — only a few feet to several
hundred feet a year in most cases —
imparts "slow motion" to the dynamic
changes taking place as the water
migrates from areas of influx  to areas of
discharge. These gradual hydraulic and
chemical changes distinguish  the
resource from stream systems in which
flow rates and quality changes are
relatively rapid. Accordingly, the
characteristics of hydrologic problems
and of management requirements
commonly  differ for the two
environments. A particle of water or
waste might enter and leave a stream
network in  a few days. Ground-water
problems are not "flushed away" so
easily.
  Thus, ground-water conditions
identified today are a legacy of past
events,  natural and man-engineered, and
left to natural hydrologic processes will
change  only slowly. Hydraulic, chemical,
and structural ground-water problems
confronted today will remain
problems—hopefully with some gradual
lessening of seriousness—tomorrow. A
ground-water reservoir depleted by
pumpage over a  period of decades may
require a similarly long (or longer) period
of rest to recover, unless artificially
replenished. A contaminated
ground-water reservoir will flush out its
degrading chemicals naturally only over
a long period of time. In the time frame
of practical planning, the chemical health
90
 80
70
Q

03
QL
W
c
_o
CD
O
c
o
60  ~
50  i
40
30
'20
10
            Total ground-wateg
            withdrawals

            Self-supplied industrial
                                                     Public supply

                                                     Rural supply
of the reservoir may never be restored
unless effective measures are instituted
to accelerate the process. Unfortunately,
economic and practicable reclamation
technology for ground water is in its
infancy.
  Presently, withdrawals of ground water
are on the order of only 10  percent of the
estimated natural flow through the
nation's ground-water systems. From a
national perspective, therefore, the
resource is far from overdeveloped, even
though locally the situation  varies widely.
Except for large parts of the Southwest
and certain smaller areas elsewhere,
increased ground-water pumpage
remains a viable option in water
resources management. Contamination,
too, has affected only a relatively small
percentage of the resource,  although
local cases of contamination are widely
prevalent. An improved future for the
nation's ground-water resource, then,
would  appear to rest on curtailment of
damaging practices; the introduction  of
well-informed, judicious management;
and patience while nature acts. With
regard to further development of the
resource and its protection from
deteriorating actions, good  management
can make a big difference. Clearly,
effective control of the influx of
contaminants would be a good
beginning. No insurmountable technical
or scientific barriers lie  in the path of
improved  management practices.
Institutional  barriers, however, as always
will present  major challenges. I
                                       1950  1955   1960   1965  1970   1975  1980
                                               Hi ground    '.er withdraw
                                         us,  /.•••
JULY/AUGUST

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The  Ground-Water Issue:   Two  Viewpoints
How serious is the nation's ground-water
problem? What should be done about it?
EPA Journal asked two experts looking
at the problem from different vantage
points for their views. James T. B. Tr/pp,
an attorney handling ground-water cases
for the Environmental Defense Fund,
describes the ground-water situation in
Nassau County, New York, and the
tessons he believes it offers nationwide.
Dr. Thomas M. Hellman, Chairman of the
Chemical Manufacturers Association's
Environmental Management Committee,
analyzes the ground-water issue from a
more general perspective. Their articles
follow:
Ground-Water
Lessons From
Nassau  County,
N.Y.

by James T. B. Tripp
Oome three million people live in Nassau
   and Suffolk Counties, Long Island, New
York. They all depend on the Island's
ground water as the sole source of water
supply. The island's ground water is also
the predominant source of fresh water
for the area's fresh water wetlands, rivers
and bays. Thus, the quantity and quality
of ground water are critical concerns to
Long Island's residents,  economy, and
environment.
   In part for these reasons, Long Island's
ground-water hydrology and quality are
perhaps the  most studied of any such
system in the country. The U.S.
Geological Survey, the New York State
Legislative Commission on Water
Resources Needs of Long Island, the
Long Island Regional Planning
Commission, the State of New York
Department of Conservation, the County
Health Departments, and Cornell
University have all undertaken extensive
studies of Long Island's aquifers. Nassau
County may rank  as the first county in
the United States to have discovered
measurable quantities of toxic organic
compounds in some of its  public water
supply wells. Those wells had to be
closed, almost ten years ago. Long Island
therefore often serves as a laboratory for
the nation in its effort to improve
ground-water protection and
management.
  Starting with the preparation of the
Long Island Section 208 Water Quality
Management Plan in 1975, Nassau and
Suffolk Counties identified their critical
recharge watershed areas where
precipitation flows deep into the water
table Glacial Aquifer and the deeper
Magothy Aquifer. In Long Island,  these
critical watersheds, with sandy soils
underlying them, are generally located in
the middle third  of the Island  and extend
out the Island's South  Fork. Much of their
original vegetation was oak brush and
pine barrens. Of this vegetation, only
remnants remain in central  Nassau  and
western Suffolk Counties. Eastern Suffolk
is better off in this regard.
  About 110,000 acres of largely
undeveloped pine barrens remain in
central eastern Suffolk County and the
South Fork. The  Long Island Regional
Planning Commission 208 Plan of 1978
designated most, but not all, of these
eastern Suffolk Pine Barrens as a  special
hydrogeological  zone which should be
subject to special land  use controls.

Halt Development?

Since the  ground water recharged
through these pine barrens  is of
remarkably  high  quality, and the sandy
soils would  allow for easy percolation of
contaminants, a group from the New
York State Legislative Commission on the
Water Resource Needs of Long Island,
Group for the South Fork, Museum  of
Long Island Natural Sciences, Friends of
the Earth, the Sierra Club, and the
Environmental Defense Fund published a
report entitled Watershed Planning  for
the Protection of Long  Island's
Groundwater (September 1982) in which
we recommended a virtual halt to
development in the remaining Pine
Barrens to retain it as a vast undergraded
watershed, with growth redirected to the
periphery of this  vital recharge zone. Two
of the eastern Suffolk County townships,
Southampton and East Hampton,  have
undertaken major rezonings of this
watershed within their  boundaries.
  Due to its size and development status,
Suffolk County can probably retain a
large enough reservoir of high quality
ground water through adoption of
aggressive watershed protection
programs.  Nassau County's situation is
much more problematic. Its population is
comparable to that of Suffolk County,
but its land size is only about one-third
as large. Further, much of its central
recharge area has experienced intensive
industrial, transportation, and residential
development. Thus, the major landfills
and industrial waste sites of Nassau
County are situated in this central
recharge zone away from the county's
coastal areas. Organic and other
chemical contaminants from these
sources are moving deep into Nassau
County's two major aquifers. Clearly, this
development pattern occurred in  Nassau
County at a time when the critical
recharge zone concept was unknown or
its soils were deemed to be effective
traps for contaminants.
  With a population of about 1.68 million,
daily withdrawal of about 180 million
gallons, and total estimated budget area
recharge of some 200 million gallons per
day, Nassau County does not, under the
best of circumstances, have much room
to maneuver to retain water supply self-
sufficiency. Already, on  a regional basis
within the county, ground water is being
mined. Further, as organic and nitrate
contaminants extend deeper and
laterally, quality considerations will
impose additional constraints on  supply
availability.
  Time is therefore running out for
Nassau County. While it  may consider
other supply options, such as imports
from New York's system or from  Suffolk
County, use of alternative supplemental
sources of  supply faces  economic and
political obstacles. What, then, should
Nassau County do to maintain
self-sufficiency  in water supply in a
cost-effective and environmentally
satisfactory manner?
  Some of us active in the preparation of
Watershed Planning for the Protection of
Long Island's Groundwater, joined by
 = '.'
                                                                                                   EPA JOURNAL

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                                                                                   Open spaces in Nassau County. In East
                                                                                   Meadow, Long Island, a golfer tees off at
                                                                                   Eisenhower Park, one of the county's most
                                                                                   well-used recreational areas and a pan of
                                                                                   its watersheds.
 others from New York Community Action
 Network and the Natural Resources
 Defense Council, have once again joined
 forces to address this issue. What is
 apparent is that policy debates should
 not continue forever; in Nassau County,
 the time for action is now.

 Six Components
 A ground-water action program for
 Nassau County must have six major
 components to meet this objective.
   First, while much of the Nassau County
 central  watershed is heavily developed,
 some 10,000 acres of it, in northern
 Nassau straddling and north of the
 ground-water divide, are not intensely
 developed. Local governments and  the
 county, with support from the state,
 should  designate these lands as a special
 protection  area and use their zoning
 powers to  limit future development with
 a view to preventing degradation of this
 ground water. While Nassau County does
 not have the extensive undeveloped
 watersheds of Suffolk County, it still has
 watershed lands which it should protect.
 Just because so much of Nassau
 County's central recharge area is
 intensely developed, designation and
 protection  through stringent land use
 controls of its remaining watershed is
 critical.
   Second,  EPA, the state, the county and
 its townships must proceed  expeditiously
 to implement a program for cleaning up,

JULY.'AUGUST
containing, and isolating the industrial
waste sites and landfills (some eligible
for Superfund support) in the central
recharge zone. Since the toxic
contaminants from these sources have
penetrated deep into the ground-water
system, remedial action to clean up the
polluted ground  water is probably
hopelessly expensive. However, through
removal and treatment of wastes on the
land surface, capping, and other
techniques, it should be possible to abate
introduction of more contaminants from
these sources into the ground water.
Sooner rather than later, the responsible
agencies must move beyond  assessment
and monitoring and take action  in the
field to contain, remove, and/or treat
these wastes.
  Third, private and public open spaces
used for golf courses and parks are
located throughout both the intensely
developed and less developed parts of
the central watershed. Fertilizers and
pesticides used on these lands are  a
major source of contamination.  The state,
county and towns should adopt limits on
uses of these chemicals to avoid further
contamination. They must recognize the
watershed, as well as recreational,
function of these lands.
  Fourth, because of the extent  of the
penetration of the ground-water system
by organic contaminants, some  of the
county's water suppliers will have to
install appropriate treatment technologies
to remove toxic pollutants, at least on an
interim basis. Use of such technologies
should not serve as an excuse for failing
to take other urgent action. It is far better
to have programs in place which prevent
contaminants from entering the ground
water in the first place. But Nassau
County does not have the luxury of
relying solely on preventive strategies.
Ideally, over time, supply treatment will
become less necessary as preventive and
control actions  protect and restore the
ground water.
  Fifth, the county should pursue
vigorously wastewater reclamation and
recharge.  Presently, much of the county
is sewered, and treated wastewaters are
discharged into coastal waters. Both in
terms of maintaining water supplies and
ground water-dependent ecosystems,
scientifically controlled reclamation and
recharge makes sense. The county, with
state and  EPA support, has sponsored a
5 million-gallon-a-day reclamation
recharge demonstration project. It should
pursue and expand this project, not
discontinue it,  as has happened.
  Sixth, water  supply conservation is a
necessity. Both carrots and sticks should
be used. The state has water well
regulations which in theory could  limit
withdrawals to achieve a conservation
management objective, although they
have not been so used. Water pricing
strategies tied to watershed  protection
and cleanup programs could also  serve
to dampen demand. In addition, required
use of water recycling systems and
water-conserving devices would further
conservation. Compared to other
alternatives, we expect that an
aggressive conservation program,
designed to reduce per capita demand by
15 to 20 percent, would be cost-effective.
What is needed are the institutional
reforms to implement such a program.
  Crises create opportunities. Nassau
County should face the reality of its
ground-water quantity and quality  crises
and act aggressively. If it does so,  it will
have established an action program from
which the  many communities in the
country that face ground-water quantity
and related quality problems could
benefit.
                         ,
                                    31

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The  Ground-Water  Issue:
       (continued)
Ground  Water:
A  Major Concern
by Dr. Thomas M. Hellman
ground water has become a major
^national issue that will continue to be
debated throughout the 1980s. The
ground-water issue is complex and the
political and economic stakes are
enormous.
  Ground water is an important resource
that contributes significantly to the
economic well-being of the nation. As a
society we have historically used ground
water for a wide variety of purposes and
we will continue to do so in the future.
Increasing use of ground water and
rapidly improving monitoring and
analytical capabilities increase national
attention to the issues of quality and
quantity.
  There has been an approximate 200
percent increase in this nation's
population in the past 80 years, but the
consumption of water on a per capita
basis  has increased 500-800 percent. This
is about 2,000 gallons of water used per
day for each man, women and child in
the U.S., and three times the per capita
water use by the Japanese. There is
growing concern that the supply of our
nation's ground water is being used at a
rate greater than the resource is being
replenished. Many experts compare
today's water problems to the energy
crisis of the 70s. Water, they predict, will
be the resource crisis of the 80s.
  Many states are facing the growing
reality that the crisis over water will not
abate in the near future. Southern
California and Arizona have battled one
another for the right to water from the
Colorado  River. Arizona won that legal
fight.
  Southern California is also trying to
gain access to the abundant water supply
of northern California. New Mexico,
Texas, and Colorado are locked in  a
dispute over rights to both surface and
ground water. The eastern half of
Colorado  wants more water from west  of
the Continental Divide. Native Americans
in the West have filed lawsuits claiming
rights to enormous amounts of water
based on  terms of peace treaties signed
during the 1800s. The list goes on, and
includes the eastern half of the country
as well as the western.
  The concern about this resource is
genuine for several reasons. First, the
supply  is  unevenly distributed. Most  of it
is concentrated in the eastern half  of the
United  States and in the Pacific
Northwest, while in the more arid
western regions of the country farmers
are competing with urban  residents and
industry for the available ground water.
  Another concern is the management  of
this resource. Historically, we have had
an abundant supply of ground  water for
all uses. But today we are  becoming
more aware of the limitations of this
valuable resource.  In order for  everyone
to have the continued access that we
have enjoyed in the past, we must begin
to protect and manage the nation's
ground water in a sound and rational
fashion. Safeguarding water quality and
quantity requires comprehensive
ground-water management on  a federal,
state, and local level.
  In looking at modern man's
achievements in ground-water
management, we see extraordinary
knowledge and skill in hydrology. On the
other hand we have ground-water
shortages caused by overpumping,
scattered chemical and biological
contamination, saline and contaminated
river water intrusion into fresh water
aquifers, and serious subsidence
problems.
  We are fortunate that the supplies of
ground water in this country are vast. If
we act now to apply our knowledge and
skills in  protecting this resource, we can
assure the development of a sound
ground-water management system
resulting in a supply of water for all uses.
Comprehensive ground- water
management is necessary to protect
public health and the environment while
responsibly maintaining multiple uses of
the resource. This type of an approach is
needed to insure that we do not misuse
our ground-water resource.
  Ground water is one of the nation's
most valuable, but least understood,
natural resources. Out of sight, ground
water is all too often out of mind.
However, new awareness and knowledge
of the effects of human activity on the
subsurface environment force us to
recognize that this resource — once
thought to be protected from pollution by
layers of soil and rock — is  indeed
vulnerable.
  One viable method of protecting
ground water is through the
development of a comprehensive
use-based classification system. The
concept of ground-water classification is
practical and technically feasible. A
ground water use-based classification
system provides a basis for planning and
action. Such a system combines a goal, a
management approach, a technical
approach and a state/federal relationship.

  A use-based classification system
maintains multiple uses of the resource
while protecting human health and the
environment. This is done by: a)
recognizing existing ground-water uses,
b) protecting future  ground-water uses,
 32
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c) accounting for the occurrence,
availability and chemical and biological
quality of  ground water, and d) ensuring
that  different uses of the same ground
water are compatible.
  The flexibility of this type of water
management system allows it to be
successfully applied on a micro- and a
macro-geographic basis. The concept of
classification is not a solution in itself but
a useful tool in  a comprehensive
ground-water management plan.
  Congress has already taken several
important steps toward protecting our
ground-water resources. Major
environmental legislation has been
enacted to control potential discharges to
aquifers. The requirements of existing
statutes such as the Clean Water Act  and
the Comprehensive  Environmental
                                                                                  Installing a samoimci oewco  •
                                                                                  well.
Response, Compensation and Liability
Act (Superfund) are reducing and
controlling industrial, commercial, and
municipal facility discharges that
contribute to ground-water
contamination.
  Several states presently have water
pollution control statutes that extend to
ground water.  Many states have  specific
statutory authority to develop
ground-water management systems.
Most of the western states have
implemented general permit systems for
allocating the quantity of ground water.
A few eastern states have followed suit,
although quantity is generally not a
priority because of an abundant water
supply.
  The question of who has the ultimate
authority over the management of
ground water is an  important  one. We
believe the states should have the
primary responsibility for developing
their own ground-water management
plan and implementing ground-water
policy. The federal role should be one of
adviser, funder, and supplier of technical
assistance and scientific information.
  Congress and EPA both have
determined that ground water  protection
will be one of their  primary activities
during the next few years. Congress is
currently addressing the reauthorization
of the Safe Drinking Water Act with
proposed bills  in the House and Senate,
and EPA has recently completed  a
ground-water protection strategy. It is
important that  we manage our ground
water so we can maintain multiple  uses
and assure that there is  a safe  and
sufficient supply of  water for all uses in
the years ahead.  I I
JULY/AUGUST

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34
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 President  Reagan  Addresses
the  Environmental  Issue
In a speech at the National Geographic
Society in Washington, D.C. June 19,
President Ronald Reagan discussed the
nation's environmental problems and the
Administration's programs to help deal
with them. Here are excerpts from his
remarks:
"Mow, I know as we near the end of this
    amazing and troubled century that you,
as all of us, are looking to the future. And
I  know that one of your great interests
and concerns is the environment —
conservation and ecofogy. You are
worried about what man has done and is
doing to this magical planet that God
gave us. And I share your concern.
  "What is a conservative after all  but
one who conserves, one who is
committed to protecting and  holding
close the things by which we live?
Modern conservatives in America want to
protect and preserve the values and
traditions by which the nation has
flourished for more than two centuries.
  "We want to protect and conserve the
idea that is at the heart of our national
experience, an idea that can be reduced
to one word: freedom. And we want to
protect and conserve the land on which
we  live — our countryside, our rivers and
mountains, our plains and meadows and
forests. This is our patrimony. This is
what we leave to our children. And our
great moral responsibility is to  leave it to
them either as we found it, or better than
we  found it.
  "But we also know that we must do
this with a fine balance. We want, as
men on earth, to use our resources for
the reason God gave them to us — for
the betterment of man.  And our
challenge is how to use the environment
without abusing it, how to take from it
riches, and yet leave it rich.
  "But I think the whole idea of
conservation has often been obscured
these past 20 years by some who have
attempted to seize  it as an issue,
politicize it, and claim it as their own. I
think there have been some who use the
conservation movement as an excuse for
blind and ignorant attacks on the
entrepreneurs who help the economy
grow — the farmers who make our food,
the  businesses that give us heat in winter
and coolness in the summer. This kind of
antagonism to all things that  speak of
business has tended to confuse the issue,
blur responsibility, and overshadow
sincere concern.
  "As I said in  my last State of the Union
message: 'Preservation of our
environment is not a liberal or
conservative challenge — it's common
sense.'
  "Our nation has taken great strides in
the decades since an old conservative
named Teddy Roosevelt led the charge to
create the national park system. From
that great beginning  step, we have
steadily expanded efforts to protect our
heritage of land and  water. We've been
proud to pick up the  mantle and move
forward in a number of important areas.
  "We've spent $737 million since  1981
as part of a billion dollar plan to repair
and replace national  park facilities...Even
as we grapple with getting federal
spending under control, the 1985 budget
request proposed that almost $160
million be made available to acquire new
lands for our national park and wildlife
refuge systems.
  "We're keeping a close watch on
endangered species.  With the leadership
of Secretary Clark, the Interior
Department has listed 23 species so far
this fiscal year, including the Wood Stork
and the Woodland Caribou.
  "Together, the federal government and
Ducks Unlimited have created a new
program to ensure the protection of
American waterfowl nesting areas. This,
by the way, reflects our attempts to work
closely with the private sector. The
non-profit Ducks Unlimited will work with
the Fish  and Wildlife  Service and fund
the protection of the waterfowl areas.
  "Just this past April, the Prudential
Insurance Company donated more  than
100,000 acres of wetland and forest areas
to the National  Wildlife Refuge System.
That's a  $50 million gift. And we rely on
private volunteers in  our national parks.
Last fiscal year, we had the help of more
than 22,000 volunteers who in all
donated more than a million hours of
their own time. And that was a taxpayer
savings of about $7 million.
  "Creating parks and wildlife refuges is
only a part of protecting our
environment, of course. I'm proud to
report that the most recent studies of the
Environmental Protection Agency show
that we've made great  progress in
cleaning up the air and water.
Many lakes and  streams have been
declared open for fishing and swimming,
after being closed to a whole generation.
EPA tells us that after a national
expenditure of $150 billion on air
pollution controls, concentrations of all
the major  pollutants are on a downward
trend.
  "We are moving forward in responding
to new challenges as well. In just three
years, we have tripled funding for the
cleanup of abandoned hazardous waste
dumps from $210 million in 1983 to S640
million proposed for 1985. We have
doubled funding for acid rain research in
each of the past two years. We're trying
to get a clear, scientific understanding  of
its causes  and effects.
  "And what we're aiming at is a policy
of common sense.
  "We have, all of us, over the past 20
years, reached consensus on the need  to
conserve our environment. Now, we
must come to agreement on how to do
it. And in coming together on that, we
must keep in mind the word balance, a
balance between the desire to conserve
and protect and the desire to grow and
develop, a balance between concern for
the good earth and concern for the
honest impulse to wrest from the earth
the resources that benefit mankind, a
balance between the overall demands of
society and the individual demands of
the free citizen.
  "If we rid our minds of cant, of empty
rhetoric, of mere politics, we'll strike that
balance naturally and together.
  "This is my great hope and in this you
have my complete commitment." D
JULY/AUGUST

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Update
A review of recent major EPA  activities and developments in the pollution control areas.
AIR

"Bubble Concept" Approved
The Supreme Court affirmed the
authority of EPA and state air
pollution control agencies to let
facilities use a "bubble concept"
to meet Clean Air Act
requirements more quickly and
inexpensively where  they add
new industrial processes or
modify existing ones.
  The court reversed a lower
court's decision, holding that
such "modifications" need not
be  subject to  the Act's most
stringent, time-consuming
requirements for "new emissions
sources" anywhere in the
country, if plant-wide emissions
do  not increase by significant
amounts. Capping developments
that began in 1979, the court
went on to note that EPA and
the 32 states  that had adopted
this "bubble approach" properly
balanced the  Act's twin goals of
economic growth and
environmental progress.
  The "bubble concept"
generally altows factories,
refineries, and other  sources of
air  pollution to treat all their
stacks and vents as though they
are enclosed  by a giant bubble,
getting more pollution control on
stacks that are easy to control in
exchange for reduced controls
on  those that are expensive to
control, so long as overall
emissions are reduced by the
same amount.

General Motors Recall
The General Motors Corporation
was recently ordered by EPA to
recall approximately  550,000
1980 model year vehicles that
are exceeding the federal
emission standards for oxides of
nitrogen. EPA's investigation
revealed that  these vehicles
exceeded the 1980 oxides of
nitrogen  standard because the
Exhaust Gas Recirculation
systems were defective.
  GM has begun to voluntarily
recall these vehicles but has
indicated that it would limit free
repair to those vehicles which
are under five years old and
have mileage under 50,000 miles
when brought into the
dealership. While this limitation
reflects GM's interpretation of its
responsibility under the Act, GM
and EPA are in litigation over
this issue. EPA believes the Act
requires  GM to recall and repair
all  of the cars at no cost to the
owner. This order reflects EPA's
view that all vehicles must be
repaired, regardless of age or
mileage when presented for
repaii
Proposed Funding Sanctions
A cutoff of federal highway
construction money for the
Detroit area of Michigan was
recently proposed by the EPA
because of the state's failure to
adopt an auto emissions
inspection program required by
the Clean Air  Act.
  The proposed restrictions
would withhold federal  highway
funds and air quality planning
grants from the state for use in
Wayne, Oakland,  and Macomb
Counties.
  Under the Act, areas of the
country which could not meet
federal ozone and or carbon
monoxide standards by  1982
were required to implement a
tailpipe emissions inspection
program  as a condition to
receiving a five-year extension of
the deadline.  The Detroit
metropolitan  area received an
extension after agreeing to such
a program but failed to start the
inspection program, as  required,
by Dec. 31, 1982.
 HAZARDOUS WASTE

 Superfund Contract
 A four-year $168 million
 Superfund contract—the largest
 awarded in EPA's history—has
 been granted to the Boston firm
 of Camp Dresser & McKee.
  The contract will provide
 technical assistance and
 resources to supplement the
 agency's hazardous waste  site
 cleanup program, which is
 authorized under the Superfund
 law (the Comprehensive
 Environmental Response,
 Compensation, and Liability Act).
  Under the new contract,  Camp
 Dresser & McKee (COM) will be
 involved in long-term cleanup
 actions for uncontrolled
 hazardous waste sites. The new
 contract will supplement current
 long-term cleanup capacity
 available under two contracts
 awarded by  EPA in 1982. The
 firm will undertake site
 investigations and feasibility
 studies, cleanup designs, initial
 long-term cleanup measures at
 sites, general technical  support,
 and oversight of some
 enforcement activities.

 Illinois Consent Decree
 EPA and the U.S. Department of
 Justice announced a proposed
 consent decree which would
require four companies which
disposed of hazardous waste at a
site in Greenup, III., to conduct a
surface cleanup of the 3.8 acre
site, which  at one time contained
four waste  lagoons and 13 tanks
containing wastes.
  The proposed consent decree,
lodged in the U.S. District Court
in East St. Louis, III., would take
effect if approved by the court
after a 30-day public comment
period.
  The companies involved are
the Aluminum Company of
America; CAM-OR, Inc.;
Northern Petrochemical Co.; and
Petroiite Corp. Also agreeing to
the consent decree, in addition
to the Justice Department and
EPA, were the State of Illinois;
Cumberland County, III.; and the
Village of Greenup.
INTERNATIONAL

US-USSR Environmental
Agreement
President Reagan has asked
William D. Ruckelshaus,
Administrator of EPA, to assume
the role of co-chairman of the
U.S.-U.S.S.R. Joint Committee
on Cooperation in the Field of
Environmental Protection. Yuriy
A. Izrael, chairman of the
U.S.S.R. State Committee for
Hydrometeorology and Control
of the Natural Environment, is
the Soviet co-chairman.
  The agreement — originally
signed in May  I972 and renewed
in May 1982 — provides for
cooperative activity and
information exchanges on 42
specific projects in the  areas of
air, water, and marine  pollution,
urban and agricultural  pollution,
nature conservation,
biological genetic effects, climatic
effects, earthquake  prediction,
arctic/subarctic ecosystems, and
legal/administrative measures.
  More than 2,000 American and
Soviet specialists have
participated in exchange visits,
with information exchanged on
flora and fauna conservation,
climate change, earthquake
prediction, and pollution
processes and effects.

Administrator in Europe
EPA Administrator William  D.
Ruckelshaus met with top
environmental officials in
Sweden, France, The Federal
Republic of Germany, and Great
Britain on matters of mutual
concern over a two-week period
beginning June 17.
  Ruckelshaus arrived in
Stockholm on the first leg of his
trip on June 17. The next day he
devoted to meetings with the
Swedish Ministry of Agriculture
and the National Environment
Protection Board.
  His next stop was Paris on
June 20, where he chaired  a
June 21 session of the
Organization of Economic
Cooperation and Development
(OECD). The 24-member OECD
discussed directions
environmental policies are
expected to take in the next
decade and beyond.
  While in Paris, Ruckelshaus
signed a U.S.-French
Memorandum of Understanding
with Mrs. Huguette
Brouchardeau, French Secretary
of State for the Environment and
the  Quality of Life, to  maintain
and enhance bilateral
cooperation between  the two
countries in environmental
affairs.
  From Paris, Ruckelshaus  went
to Munich to attend the
Multilateral  Conference on  the
Prevention of Damage to Forests
and Waters by Air Pollution in
Europe. This conference on acid
rain was held from June 24
through the 27th. The conference
considered a joint resolution for
controlling acid rain in Europe.
  The Administrator concluded
his European trip in London,
where he met with the Minister
of the Department of  the
Environment on June 28.
PESTICIDES
Wood Preservative Rules
EPA recently imposed
restrictions on three pesticides
used to preserve wood:
creosote, pentachlorophenol, and
inorganic arsenicals.
  The agency's  final action
restricts the sale and  use of the
wood preservatives to certified
applicators. Until now, anyone
could purchase  and use these
preservatives around homes and
farms. These pesticides account
for over 97 percent of the wood
preservatives used in this
country and for  one third  of all
agricultural and  industrial
pesticides (2.7 billion  pounds)
produced in the U.S.
  In addition, the commercial
wood pressure treatment
industry will be  required to
participate in a consumer
awareness  program to inform
users of pressure-treated wood
or treated wood products.
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  EPA will require appropriate
protective clothing, such as
gloves and  coveralls impervious
to the chemicals, in certain
applications of the wood
preservatives and in handling
freshly treated wood. Respirators
will be required in certain high
exposure situations.
  The registrants of
pentachlorophenol will also be
required to limit immediately the
dioxin contamination
(hexachlorodibenzop-dioxin or
HxCCD) in pentachlorophenol to
15 parts per million (ppm) and to
reduce that level to one ppm
within 18 months. The more
potent 2,3,7,8,
tetrachlorodibenzo-p-dioxin
(2,3,7,8-TCDD) has not  been
found nor will it be permitted in
pentachlorophenol. EPA said that
without these restrictions, the
risk to public health from using
these pesticides would outweigh
the benefits.

Larvadex Decision Deferred
EPA has  announced that it is
deferring a final decision on
whether or not to conditionally
register the pesticide Larvadex
until after it receives additional
test data.
  Larvadex (chemical  name,
cyromazine) was proposed to be
used as a feed-through
insecticide  to control the larvae
of flies found in manure of caged
layer hens.
  As part of the registration
requirements for a new
pesticide, EPA requires the
manufacturer to submit
teratology (birth defects) studies
conducted  with two different
animal species.
  These studies are required to
determine if a pesticide presents
a risk of birth defects or other
harm to developing fetuses.
  Until the additional data are
received, the agency will not
issue any additional emergency
exemptions for the use of
Larvadex or other
cyromazine-containing pesticides
and will terminate any
outstanding exemptions.
Presently, the agency  has
granted emergency use of
Larvadex in selected counties of
four states  to combat the avian
flue that threatens poultry
operations.
Monsanto Ruling
The U.S. Supreme Court held
that the I978  statute authorizing
EPA to make public the health
and safety  data on pesticides is
constitutional. The court vacated
a I982 lower court judgment
which had  enjoined EPA from
making public the results of tests
on pesticides concerning toxicity,
environmental fate, and wildlife
effects. The statute had been
attacked by Monsanto Company,
a major pesticide producer, as an
unconstitutional taking of
property rights granted under
state laws concerning trade
secrecy.
  Monsanto had claimed that the
I978 statute violated the  Fifth
Amendment of the U.S.
Constitution, which prevents the
government from taking private
property for public use without
providing just compensation.
The court's opinion said that
there was sufficient basis for
compensation available under
the law for any loss suffered by
Monsanto.
  The court said that although
Monsanto may have  property
rights in pesticide data, Congress
was free to provide by statute
that EPA might make the data
public. The court also upheld a
companion provision in the
pesticide statute  allowing other
businesses to obtain
registration by relying on data
previously submitted by firms
such as Monsanto, if they
offered to compensate the
original data submitter.
  With regard to data submitted
to EPA between  1972 and  1978
(when the pesticide statute
prohibited disclosure of the data
or unconsented use by other
businesses), the court said that if
EPA now discloses it to the
public or allows other businesses
to rely on it without Monsanto's
consent, Monsanto may be
entitled to recover damages in
the United States Claims Court.
Data submitted before 1972 or
after 1978 cannot give rise to a
claim  against EPA for "taking"
damages.
TOXICS
School Asbestos Meetings
Three public meetings were held
by EPA in June as part of the
agency's effort to improve its
asbestos in schools program.
The meetings were held June 14
in San Francisco; June 20 in
Chicago; and June 28 in Boston.
  On Nov. 16, 1983, the Service
Employees International Union
(SEIU) petitioned EPA, under
Section 21 of the Toxic
Substances Control Act, to
initiate rulemaking to require the
abatement of friable
asbestos-containing materials in
public and private  elementary
and secondary schools. In
addition, the petition requested
rulemaking concerning the
inspection and abatement of
friable asbestos-containing
materials in public and
commercial buildings.
  On  April  17, 1984, EPA  agreed
to consider the SEIU's requests
and seek public comments on
how EPA should modify its
program. EPA sought written
public comment, and held a
public meeting in Washington,
D.C. on May 7.

New PCB Standards
EPA announced a series of
separate actions on the
chemicals called polychlorinated
biphenyls 
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Appointments  at  EPA

                                                            Sanford W. Harvey. Jr.
                                                       i W. KOVLI  ••
Administrator William Ruckelshaus has
   appointed eight EPA employees to new
positions in the agency. The
appointments include a new Judicial
Officer, a Deputy Regional Administrator,
and a Special Assistant to the Assistant
Administrator of  EPA's Office of Water.
  The Office of Emergency and Remedial
Response and the Science Advisory
Board have new  Deputy Directors, while
new Directors have been named for the
State Programs Division in the Office of
Drinking Water, and  for the Facilities
Requirements Division and the Municipal
Construction Division of the Office of
Water Program Operations.

Louise Jacobs will serve as EPA's second
Judicial Officer, with initial specialized
responsibilities for civil rights and labor
standards decisions. Jacobs will be
delegated exclusive authority to issue
final EPA decisions in internal equal
employment opportunity and Contract
Work Hours and  Safety Standard Act
cases. She will also decide assigned
cases arising under the agency's
environmental statutes.
  Ruckelshaus said,  "We are fortunate to
have recruited  someone of Ms. Jacobs'
background and  professional reputation
to act as  the agency's second Judicial
Officer. Her assignment to initial
concentration on civil rights cases is an
indicator  of the importance I attach to
just resolution  of civil rights concerns."
  Jacobs joined EPA in 1979 as Director
of the Enforcement Division in the
Kansas City regional office. In 1982 she
came to agency headquarters to serve as
Associate Enforcement Counsel, first for
the Air Division and  later for the Water
Division.
  Prior to her EPA service, Jacobs was
Senior Staff Attorney for the U.S. Court
of Appeals for the Third Circuit in
Philadelphia. She has held several
positions with the Administrative Office
of New Jersey Courts,  including Staff
Attorney and Court Administrator. She
has also been engaged in the private
practice of law.
  Jacobs holds a bachelor's degree from
Seton Hill College and  a doctor of
jurisprudence degree from Seton Hall
University School  of Law, where she
served as a Notes Editor of the Law
Review and was named a Centennial
Scholar. She is listed in Who's Who
Among American  Women and Who's
Who in American Colleges and
Universities.

Alexandra B. Smith has been named
Deputy Regional Administrator for EPA's
Region 8 in Denver. Since 1980 she has
headed the Air and Waste Management
Division of Region 10 in Seattle.
  Between 1977 and 1980 Smith was
Chief of the Environmental  Evaluation
Branch in Region 10. In 1976 and 1977,
she was Director of EPA's Office of
Federal Affairs in Seattle.
  Smith began her government career in
1972 at the Department of Housing and
Urban  Development, where she was an
employee development specialist. She
also worked briefly for the National Park
Service in Harpers Ferry, W. VA.
  Before joining government service,
Smith worked for private companies in
Colorado and  New York and for
television stations in New York and
Seattle.
  In 1980 Smith received EPA's Gold
Medal for meritorious service, and in
1982 EPA's Bronze Medal.
  Smith received her B.A. in government
in 1967 from St. Lawrence University in
Canton, N.Y., where she held a New York
State Regents Scholarship. In 1968 she
received her M.A. from Syracuse
University and, in 1982, her M.B.A. from
the University of Washington.

Sanford W. Harvey, Jr., has been named
Special Assistant to Jack E. Ravan,
Assistant Adminstrator of EPA's Office of
Water.  Harvey comes to this position
from the Office of Enforcement and
Compliance Monitoring where he  has
been Associate Enforcement Counsel for
Special Litigation since April.
  Harvey came to EPA headquarters from
Region 4 in 1980, to serve as Deputy
Assistant Administrator for Mobile
Source, Noise and Radiation
Enforcement. In July 1981, he became
Director of the Office of Pesticides and
Toxic Substances Enforcement. The
following January, Harvey was appointed
Associate Enforcement Counsel in the
Office of Legal and Enforcement Counsel.
  Harvey joined EPA in Atlanta in  August
1978, as Regional Counsel for Region 4.
In April 1979, he was appointed Director
of the Enforcement Division in Region  4.
  Between 1975 and 1978, Harvey
worked for the  U.S. Army Corps of
Engineers as an Attorney-Advisor  and  as
an Administrative Judge on the Corps'
Board of Contract Appeals. From 1971
until 1975, he served in the U.S. Army
Judge Advocate General's Corps where
he was a Military Judge.
  Prior to military service, Harvey  was a
manpower analyst for ABT Associates, a
multi-disciplinary consulting firm in
Cambridge, Massachusetts.
                                                                                                         EPA JOURNAL

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L to R, EPA Administrator  William Ruckclshaus, Louise Jfic^ii-  ind • PA   .                '.    •       . ••.  .
appointed as the agency's  second Judicial Officer, with initial responsibility for civil riy                        ^
  In 1967 Harvey graduated with highest
honors from  Norwich University. He
received his J.D. from Harvard Law
School in 1970 and has been  admitted to
the Massachusetts and District of
Columbia Bars.
  Harvey received EPA's  Bronze  Medal in
1980. While in the Army, he was awarded
the U.S.  Army Commendation Medal and
the U.S.  Army Meritorious Service Medal.
He  is listed in Who's Who in American
Universities and Colleges.
Walter W. Kovalick, Jr., has been named
Deputy Director of the Office  of
Emergency and Remedial Response
(OERR) in EPA's Office of Solid Waste
and Emergency Response.  OERR
administers EPA's Superfund  program.
  Kovalick has been with EPA and its
predecessor agencies for over fifteen
years. Since October 1978,  he has been
Director  of the Chemical  Coordination
Staff of the Office of Pesticides and Toxic
Substances. Between 1974 and 1978, lie
served as Chief of the Guidelines Branch
in the Hazardous Waste Management
Division of the Office of Solid Waste and
Emergency Response.
  After  working two years at the
Department of Health, Education and
Welfare, Kovalick began his EPA career in
February 1970 as a  program advisor in
the Air Pollution Control Division at
Region  5 in Chicago. Between 1972 and
1974, he served as technical advisor and
consultant to the Region 5 Administrator
and Deputy Administrator in various
program areas.
  From  I979 through I98I, Kovalick
chaired  the regulatory development
work group of the Interagency Regulatory
Liaison  Group. For the past 16 months he
has been co-chairman of the Interagency
Toxic Substances Data Committee. In
addition, Kovalick has represented EPA  in
environmental programs of multinational
organizations such as the North Atlantic
Treaty Organization and the Organization
for Economic Cooperation and
Development. Kovalick also has served
as consultant to the federal government
of West Germany.
  Kovalick received his B.S. in industrial
engineering  from  Northwestern
University in June 1967. In 1966 he was
elected to Alpha Pi Mu, the Industrial
Engineering  Honor Society. In 1967
Kovalick won the American Institute of
Industrial Engineers' Award for Student
Excellence and the Hamilton Watch
Award bestowed by Northwestern's
Technological  Institute. In 1972,  after
studying on  a  National Honorary
Fellowship and an  EPA Traineeship,
Kovalick earned a master's degree in
business administration from Harvard
University.
                  Continued to next /),'>(/<'
JULY/AUGUST

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'
                                                             Hobert J  Blanco
                                                         A. Hanlon
Kathleen Conway has been named
Deputy Director of EPA's Science
Advisory Board. She comes to the Board
from EPA's Office of Health Research
where she has worked as an
environmental health scientist since 1977.
  In 1981-82 Conway served as Acting
Director for both divisions in the Office of
Health Research. She took a one-year
leave of absence from EPA in 1982-83 to
serve as program administrator for
health and safety  at IBM as part of the
President's Executive Exchange Program.
  Conway joined  EPA's Region 1 in
Boston in 1974 and worked there until
1977 as a sanitary engineer. Prior to
joining EPA, Conway was a junior
sanitary engineer at the  Central District
Health Office of the Massachusetts
Department of Public Health. She also
worked as a technical writer for Project
MISOE in Winchester, Mass., and as a
feature writer for the Hartford Courant.
  Conway received a B.S. in biology from
Tufts University in 1970. In 1977 she
completed her M.S. in sanitary
engineering and public health, also at
Tufts University.

Paul M. Baltay will fill the position of
Director, State Programs Division, Office
of Drinking Water, at EPA headquarters.
Since 1982 Baltay has been acting
Director of the State Programs Division.
For four years prior to 1982, he worked
as its Deputy Director.
  Baltay joined EPA in 1974 as Assistant
Director for Operations in the Program
Evaluation Division. In 1975 he received a
group citation EPA Silver Medal for his
work on several of EPA's Construction
Grants Task Forces.
  Baltay began his government career in
1967 at the Bureau of the Budget, which
later became the Office of Management
and Budget. Among other assignments,
he served as staff assistant to the
Director in 1969 and as a budget
examiner from 1970 to 1974.
  Baltay received his B.A. in  political
science from Union College in 1962. At
Union he was a Merit Scholar and a New
York State Regents Scholar. Baltay did
graduate work at Albany Graduate
School and the Maxwell School of
Syracuse University.


Robert J. Blanco has been appointed
Director of the  Facilities Requirements
Division in the  Office of Water Program
Operations at EPA headquarters. For the
past three years, Blanco has been Chief
of the Water Supply Branch at EPA's
Region 3 in  Philadelphia.
  Blanco joined EPA in 1971  as Chief of
the Environmental Impact Branch in
Region 3.  He held that position until 1975
when he became Chief of the Water
Planning Branch in Region 3.  In 1978
Blanco was  honored with EPA's Bronze
Medal  and appointed Chief of EPA's
Virginia/West Virginia Branch. He held
that position until 1980 when he served
briefly as acting Chief of the Air
Programs Branch in Region 3.
  Blanco studied engineering at New
York University, where he received his
B.S. in Civil Engineering in 1968 and his
M.S. in 1969. While at NYU, he received
the University's Trowbridge Award.

James A. Hanlon has been named
Director of the Municipal Construction
Division at EPA's Office of Water
Program  Operations in Washington.
Hanlon comes to EPA headquarters from
Region 5 in Chicago, where he has
worked since 1972.
  Hanlon began his EPA career as a civil
engineer in the Construction Grants
Branch of the Region 5 Water Division.
He worked in the Construction Grants
Branch from 1972 until 1978 when he
became State Management Assistance
Program  Manager in the Region 5 Water
Division.  For his work in this position,
Hanlon received EPA's Bronze Medal in
May  1980.
  Most recently he served as  Section
Chief of the Program Management
Section in the Municipal Facilities Branch
of the Region 5 Water Division.
  Hanlon studied civil and environmental
engineering at the University  of Illinois,
where  he received his B.S. with  high
honors in 1972. In 1977 Hanlon
received an M.B.A. from the University of
Chicago.  D
                                                                                 A resident of Vinton County, Ohio, stands
                                                                                 behind (he  18-foot-deep well (hat he
                                                                                 planned and constructed himself

                                                                                 Back cover:  Young green-backed heron
                                                                                 near Ocean Springs, Mississippi.
40
                                                                                                            EPA JOURNAL

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