Ground-Water Contamination

Transcription

1 United States Envionmental Potection Office of Wate (WHS50G) PA d40/ May 1990 GEPA A Review Of Souces Of Gound-Wate Contamination Fom ight Industy Technical Assistance Document

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3 A REVIEW OF SOURCES OF GROUND-WATER CONTAMINATION FROM IGHT INDUSTRY OFFICE OF WATER OFFICE OF GROUND-WATER PROTECl'ION US. ENVIRONMENTA PROTECTION AGENCY MAY 1990 Pinted on Recycled Pape

4 . ACKNOWEDGEMENTS This document was pepaed fo the Envionmental Potection Agency, Office of Gound-Wate Potection (OGWP) unde contact No. 68-C M. Kevin McComack of OGWP seved as Task Manage fo this poject, with assistance fom M. Steven Roy and D. Nobet Dee. c

5 EXECUTIVE SUMMARY This document addesses the potential impact of light industial activities on wellhead potection aeas. The tem "light industy" efes to industial, commecial, o etail establishments that manage substances o engage in manufactuing, fabication, o sevice activities that ae one step o moe emoved fom the poduction of pimay poducts fom aw mateial. These activities, which may pose a potential theat to gound-wate quality, ae minimally-egulated o non-egulated by Fedeal laws. Seveal States and local govenments have adopted innovative appoaches fo contolling light industies. These appoaches may involve souce identification, zoning and othe contols to limit land uses in wellhead aeas, and public education and technology tansfe to encouage industies to adopt management contols. Othe juisdictions have also placed stict pohibitions on activities that ae allowed in wellhead aeas, including esticting specific light industy types. These activities may be adopted as pat of a compehensive Wellhead Potection Pogam. Examples of these activities include:. I e e e e Wateshed Rules and Regulations - ocal o State agencies may adopt land-use plans to potect public wate supplies. Gound-Wate Management Aeas - State agencies may develop management plans fo designated aeas to institute land use and souce contols to potect gound-wate quality. Gound-Wate Standads - Many States have adopted standads to potect thei gound wate. Standads may be eithe numeic, specifying a maximum concentation fo a paticula contaminant, o naative, specifjing a geneal pohibition on types of dischages o identifying a geneal quality goal. Gound-Wate Classification - Seveal States have classified thei gound wate and specified diffeential potection measues accoding to the classification. The Fedeal Safe Dinking Wate Act Amendments of 1986 mandated the U.S. Envionmental Potection Agency (EPA) to wok with the States to develop Wellhead Potection (WHP) Pogams to potect gound-wate supplies of public dinking wate. Unde Section 1428 of the Act, each State and Teitoy was diected to submit a WHP pogam to EPA by June 19, Wellhead Potection Pogams have six majo components: (1) designation of oles and duties of State and local agencies; (2) delineation of wellhead potection aeas; (3) identification of contaminant souces; (4) development of management appoaches fo the wellhead aea; (5) pepaation of contingency plans fo eplacement wate supplies; and (6) planning and siting of new wells. This document discusses aspects of the thid and fouth components outlined above. i A vaiety of anthopogenic souces may theaten wellhead aeas, including heavy industy, waste disposal sites, light industy, on-site wastewate disposal, and agicultual pactices, as well as othes. While heavy industy and agicultue ae acknowledged and inceasingly ecognized as souces of contamination, light industy and on-site wastewate disposal ae also pevasive contaminant souces and fequently ae not subject to the same types of contols. F

6 Many types of light industies may theaten wellhead aeas. These industies ae found in inceasing numbes thoughout the United States, as light industial paks and sububan developments spead into fomely ual aeas. A numbe of light industy 'YpG ae addessed in this document, such as electoplating and polishing sevices, wood and lumbe teating opeations, funitue efinishing and epai sevices, auto epai shops, oad deicing opeations, scap metal and auto junkyad deales, and laundy and dy-cleaning establishments. These light industies manage a vaiety of contaminants, including heavy metal-containing solutions and acid baths in electoplating sevices, pentachloophenols and othe pesevatives in wood teating opeations, solvents and vanishes in funitue efinishing shops, used oils and degeases in auto epai shops, salts in oad deicing opeations, Spent battey acids and solvents in scap dealeships, and detegents and solvents such as tichlooethylene in dy-cleaning establishments. Because these light industies ae found in lage numbes thoughout the county, thee is a widespead potential fo wellhead contamination fom these souces. A wide vaiety of constituents have contaminated gound wate at light industial facilities. The most pevalent goups of contaminants include oganics and metalshnoganics. Typical oganic contaminants include benzene, dichlooethylene, dioxins, methylene chloide, pentachloophenol, pechloethylene, toluene, tichlooethane, tichlooethylene, and xylene. Typical metals/inoganics include asenic, chomium, coppe, lead, nickel, nitates, and sodium chloide. These contamination incidents ae most fequently associated with waste management and waste disposal activities. Following sound management contols can seve as an impotant component of a Wellhead Potection Pogam to contol gound-wate contamination by light industy. Many cases of contamination have been documented involving spills and leaks to soil, impope waste disposal in septic systems, and eleases fom undegound stoage tanks and pipelines. In a numbe of cases, light industies have pevented o minimized such contamination incidents by folloying management contols, such as stoing aw mateials and wastes on impemeable pads and in coveed aeas; collecting unoff fom mateial stoage aeas; placing dip pans unde machiney and in pocess aeas; segegating hazadous mateials fom disposal in septic systems; minimizing the intensive use of contaminants such as oad salts in sensitive aeas; inspecting and monitoing undegound stoage tanks and pipelines; cleaning up spills pomptly afte they occu; and taining pesonnel to follow sound mateial management pactices. Ove the long-tem, the potential fo gound-wate contamination by light industy can also be educed by adopting waste minimization pactices, such as waste ecycling, aw mateial substitution, and waste teatment. 1 i

7 TABE OF CONTENTS Page 1.0 Intoduction 1.1 Oveview of this Document Definition of "ight Industy" Summay of Data Collection fo this Document Analysis and Conclusions: The Theat to Gound Wate fom ight Industy Oveview of the Poblem: Raw Mateial and Waste Management 2.1 Phases of Mateial Management and Mismanagement and the Potential fo Gound-Wate Contamination Mateials Managed by ight Industial Facilities Analysis and Discussion Contols on ight Industy: Fedeal, State, and ocal Roles 3.1 Regulating Mateial Management by ight Industy unde Cuent Fedeal aw State and ocal Appoaches fo Contolling ight Industy Analysis and Discussion F c 4.0 Minimizing Gound-Wate Contamination by ight Industy 4.1 Management Contols fo Peventing Gound-Wate Contamination ong-tem Solutions: Pollution Pevention - Souce Reduction, Recycling, and Teatment Analysis and Discussion Conclusions Refeences c

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9 Page Intoduction 1.1 Oveview of this Document This document is one of a seies of Technical Assistance Documents (TADS) pepaed by the Office of Gound-Wate Potection of the U.S. Envionmental Potection Agency. This TAD discusses the poblem of gound-wate contamination caused by light industial aw mateial, poduction, and waste management pactices. While lage industies have come unde inceasing Fedeal and State egulation ove the past few yeas as a means of contolling activities that can esult in gound-wate contamination (U.S. EPA, 1987) thee is a gowing awaeness that othe smalle and eithe unegulated o minimally-egulated industies and businesses also manage mateials that may pose a theat to gound wate and wellhead potection aeas (U.S. Office of Technology Assessment, 1987). This TAD is intended to assist manages in identifymg and contolling potential light industial souces of contamination that may pose a theat to public wate supplies. EPA pepaed this document as pat of its ongoing effot to assist State and local govenments in developing Wellhead Potection Pogams. Wellhead Potection Pogams have six majo components (U.S. EPA, 1988): (1) designation of oles and duties of State and local agencies; (2) delineation of wellhead potection aeas; (3) identification of contaminant souces; (4) development of management appoaches fo the wellhead aea; (5) pepaation of contingency plans fo eplacement wate supplies; and (6) planning and siting of new wells. This document is designed30 suppot the thid and fouth tasks outlined above (i.e., the identification of light industial souces of gound-wate contamination and the development of management pogams to contol these souces). Specifically, this document focuses on a goup of industies that ae inceasing in significance in many wellhead aeas. The numbe of light industies in this county and the coesponding theat to public wate supplies is gowing. Futhemoe, many of these light industies ae locating in ual and sububan aeas which have not peviously been host to businesses that manage hazadous mateials. As a esult, wellhead aeas in these egions may become theatened. 0 Oganization This document is a pat of the seies of technical assistance documents pepaed by EPA to suppot State and local Wellhead Potection Pogams. Companion documents in this seies include DeveloDine a State Wellhead Potection Pomam: A Use s Guide to Assist State Agencies Unde the Safe Dinkine Wate Act (EPA 440/6-8&003), Guidelines fo Delineation of Wellhead Aeas (EPA 440/ ), and Wellhead Potection Poeams: Tools fo ocal Govenments EPA 440/ ). The infomation povided in these pevious documents is not epeated in detail in this TAD, howeve, those documents ae cited whee appopiate. Instead, this document focuses on light industies as a potential contaminant souce in Wellhead Potection Aeas and boadly discusses appoaches fo minimizing potential impacts. This document is oganized in six chaptes. In Chapte 1, following this intoduction, Section 1.2 defines what is Geant by the tem light industy. Section 1.3 outlines the methods the Agency used to gathe infomation chaacteizing light industv, and section 1.4 pesents a summay of the esults of the initial data-gatheing effot fo this document, including findings concening the extent of gound-wate contamination. Chapte 2 focuses on the mateials handled (Section 2.1) and the mateial management pactices followed (Section 22) by light industq that can lead to gound-wate contamination. Section 2.3 outlines geneal conclusions concening the light industial pactices that may theaten Wellhead Potection Aeas. i i

10 Page 2 Chapte 3 contains a discussion of Fedeal, State, and local contols to addess gound-wate contamination by light industy. This discussion fist outlines Fedeal Statutes in Section 3.1. Section 3.2 discusses State and local options fo contolling light industy, which may include land use estictions o zoning to contol the location of light industies ove vulneable souces of gound wate. Finally, Section 3.3 descibes an appoach that State and local govenments may adopt to develop pogams to contol light industies in Wellhead Potection Aeas. Chapte 4 focuses on the technical contols that light industies have adopted to minimize the potential fo gound-wate contamination. Section 4.1 descibes management contols that industies have followed to ensue that "good housekeeping" pinciples ae adopted at facilities, and section 4.2 discusses waste minimization techniques that some industies have instituted to limit the poduction of potential contaminants. The chapte concludes in Section 4.3 with an analysis of the ole these management contols and WaSte minimization techniques can play in a Wellhead Potection Pogam. Finally, Chapte 5 summaizes the findings of this document, and Chapte 6 lists the efeences collected by the Agency to suppot this analysis Definition of "ight Industy" As used in this document, the tem "light industy" efes to industial, commecial, o etail establishments that ae not geneally addessed unde Fedeal hazadous waste o hazadous mateial contol laws o egulations. This tem is not new. It has been used in the manufactuing and sevice sectos fo many yeas and has geneally been thought to define those manufactuing, fabication, o sevice industies that ae one step o moe emoved fom the poduction of pimay poducts fom aw mateial. Fo example, chemical manufactuing may be thought of as heavy industy, while paint fomulating is light industy. This document takes that definition one step futhe by also focusing on the waste geneation and management pactices of the industy to define its status. Fedeal hazadous waste laws and hazadous mateial contol laws and egulations ae discussed in Chapte 3 and geneally include the Resouce Consevation and Recovey Act (RCRA), Compehensive Envionmental Response Compensation and iability Act (CERCA o "Supefund"), Safe Dinking Wate Act (SDWA), Clean Wate Act (CWA), Toxic Substances Contol Act (TSCA), and Fedeal, Insecticide, Fungicide and Rodenticide Act (FIFRA). Although these laws have imposed contols on a wide ange of industies and hazadous mateial handling pactices, they have tended to focus only on the lage manufactuing industies which manage the majoity of hazadous wastes and hazadous mateials in this county. Othe smalle industies and businesses have not been as stingently contolled, eithe because the Fedeal statutes focus on industies that manage wastes o mateials above a theshold amount o because the mateials managed by the smalle industies ae not consideed "hazadous." Nonetheless, EPA and many States have discoveed that these lowe quantity o "non-hazadous" mateials managed by light industy can still contaminate Wellhead Potection Aeas. In cetain hydogeologic settings, even vey small amounts of hazadous mateial can contaminate lage aeas of gound wateg both community and pivate supply wells have been contaminated by light industies (Fod and Quales, 1987). Futhemoe, mateials that ae not geneally egaded as hazadous commonly contaminate gound-wate supplies. Such contaminants include nitates and biological substances, like bacteia and viuses.

11 c Page 3 As backgound fo this document, a data-gatheing effot was completed to chaacteize those light industies that pose the geatest potential theat to gound wate (see Section 1.3). Based on this effot, 20 light industy sectos wee identified as potentially significant souces of gound-wate contamination. These sectos include the following: Agicultual Poducts and Sevices Mining and Quaying Highway Deicing Textile and Appael Poducts umbe and Wood Peseving Pinting and Publishing Chemical Poduct Blending eathe Poducts Mineal Poducts: Glass and Cement Metal Poducts Machine Shops Electonics and Electonic Equipment Tanspotation Maintenance Scap Tade and Metal Containe Recycles Chemical and Petoleum Stoage and Sales Automotive Repai, Sevices, and Paking Pesonal Sevices: aundy, Pest Contol, and Photofinishing Repai Sevices: Funitue, Welding, and Septage Sevices Amusement and Receation Educational, Medical, and Engineeing aboatoies I The potion of the Ameican economy epesented by these light industies is gowing and dynamic - changing and adapting ove time. Hence, contolling these souces of contamination, especially in wellhead potection aeas, is inceasing in impotance. While the extent of light industial pactices is inceasing, the aeas o egions whee these industies ae found is also changing. As moe and moe sections of the county become "sububanized," light industies ae appeaing in fomely ual aeas and give ise to moe numeous souces of gound-wate contamination. Because public wate supply wellhead aeas ae often located in these ual o sububan egions, the widespead gowth in the numbe of contaminant souces is a majo concem with egad to wellhead potection. The gowth in light industial activity is best illustated by the evolution in industial paks fom the ealy developments that contained mainly heavy industies to today's light industial o high technology paks. Most cuent industial pak developments ae oiented towad the needs of light industy, eseach, and geneal office-type opeations. As a esult, the numbe of industial paks that ae now being zoned fo activities othe than heavy manufactuing has isen damatically in the last 10 yeas (Battelle, 1988) The development of industial paks has a long histoy in this county, and the natue of these paks has changed ove time. In geneal, industial paks can be chaacteized in one of five types, as descibed below. Howeve, it is difficult to detemine pecisely how many of these vaious industial pak types exist. A "high technology pak" may also be descibed as a eseach pak, industial pak, science cente, technology cente, o even an office pak. Hence, these five industial pak types should be thought of as a continuum (Battelle, 1988): I i.

12 Page 4 Reseach Paks. The majo activities associated with this type of development include eseach, engineeing, and cetain types of office and administative activities. In vitually evey case, these facilities exclude any business elated to light manufactuing, distibution, and cetain othe associated business activities. 0 Technolow Paks. The technology pak is chaacteized by eseach and development activities, high technology and light manufactuing activities, office and administative functions, and a wide ange of sevices. Technology paks ae simila to eseach paks, but also contain manufactuing components. Technology paks ae geneally less than 10 yeas old. e Officehlixed Use Paks. These developments povide facilities not only fo office-type opeations, but also fo a wide ange of light manufactuing, stoage, distibution, and othe business suppot sevices. "AAA" Industial and Distibution. Standad and "AAA" industial paks ae oiented towad poduction, sevice, and distibution. The "AAA" implies high gade, elatively clean industial and distibution pocesses. They often include distibution facilities, ail sidings, outside and undegound stoage, and activities that may poduce emissions and wastes. They have flexible land uses and have less igoous landscaping and achitectual design. i 0 Industial. These facilities epesent the olde type of industial pak They consist of basic industial components such as oil efineies and heavy manufactuing facilities. age volumes of aw mateials and wastes ae often stoed on these sites. Although managing these facility types is of citical impotance in wellhead aeas, these heavy industial paks ae not addessed in this document. Exhibit 1 outlines the continuum of industial pak types. The exhibit illustates the ange in ages of most paks fom olde heavy industy to newe light industy paks. Although not all light industies ae found in industial paks, the move to light industial development is inceasing. Hence, undestanding the potential gound-wate impacts associated with these industial paks is a citical component of effective wellhead potection. Wellhead Potection Pogam manages should be awae that many of these paks contain businesses and industies that manage hazadous mateials. The types and volumes of contaminants that may be intoduced into Wellhead Potection Aeas fom these light industial paks is discussed in the following chapte.

13 P' Exhibit 7 The Evoiution fom Heavy Industial to ight Industial Paks Y. Aveage - Many Old, age, Semi-Abandoned Pojects - AVERAGE AGE (YRS)/ REATIVE AMOUNT OF ACRES PRESENTY DEDICATED industlal 'AAA' omce/ Reseach lndusttd and Mlxod Technology Pak Dlstlbutlon us. Zoning: Heavy Industial U9M Industy Dlblbution mc./ Mlxd US. Re8each 'Ixed Us. Mce Reseach Type of Geneal Activities: Poductton - Deceasing wate demand to pocess/ deceasing volume of w8ste genemed Reseach Reseach Poductlon D'w&F and DeveC and and Admlnlsta- mcoad- opmem' Develop- Dlstlbutlon tlon ment ministation F

14 Page Summay of Data Collection fo this Document A limited data-gatheing effot was conducted to investigate the light industial activities outlined in this document. This effot focused on identifying the natue and extent of gound-wate contamination caused by light industial facilities. Because of the vey boad scope of the analysis, the data-gatheing effot was not designed to seve as a definitive chaacteization of eithe the light industy univese o the extent of wellhead aea contamination caused by light industial facilities. Instead, the data-gatheing effot povided only a "fist-cut" oveview of the scope of the poblem. Infomation was gatheed fom a vaiety of souces and included a boad liteatue eview and seies of phone contacts. Many of the infomation souces, howeve, povided eithe incomplete o pooly-documented case studies. Only those incidents with sufficient infomation to identify the chaacteistics of the contamination event accuately wee included in this eview. Futhemoe, those cases that could not be identified as involving non-. egulated o minimally-egulated light industial activities wee not included. Fo example, if the contamination incident esulted fom an illegal activity, such as "midnight dumping" of hazadous waste shipments, o a elease fom a egulated undegound chemical o petoleum stoage tank, the incident was not included in the eview. Infomation fo this document is based on 182 case studies of gound-wate contamination associated with light industial facilities. The cases identified in the eview do not, of couse, encompass the univese of known contamination incidents. The difficulties encounteed in gatheing the case study infomation indicate that moe cases of gound-wate contamination by light industy may have occued, but documentation fo those cases is not eadily available. Fo example, some cases of contamination may have been addessed though pivately funded and managed cleanups that involved little o no State o local govenment activity. As a esult, sufficient infomation to summafize such incidents is not available. EPA anticipates that moe cases of contamination may yet be discoveed as the level of awaeness concening gound-wate vulneability in Wellhead Potection Aeas inceases with time. Hence, the numbe of epoted and welldocumented cases of contamination may also incease. Nonetheless, the infomation gatheed to date does povide a limited indication of the natue and extent of the theat to gound wate posed by light industy. The chaacteistics of light industial waste and mateial management pactices that ae associated with gound-wate contamination incidents ae descibed in Chapte 2. In addition, Chapte 6 of this document lists the efeences that wee identified and used to chaacteize he light industy sectos and appopiate management contols and waste minimization techniques fo aw mateial and waste.management. 1.4 Analysis and Conclusions: industy The Theat to Gound Wate fom ight Ove seventy light industies that ae associated with documented contamination incidents wee investigated fo this document. These light industies include agicultual, light manufactuing and pocessing, mining, oad maintenance, waehousing and wholesaling, tanspotation, pesonal and business sevice, eseach, and entetainment activities. The incidents of gound-wate contamination eviewed by EPA encompass uban, sububan, and ual settings in ove 30 States. Many of the contamination incidents wee noted to have occued eithe nea public wate supplies o in Wellhead Potection Aeas. Futhemoe, many of the incidents involved documented contamination of public and pivate wate wells; howeve, it is not possible to estimate eithe the numbe of wells closed due to light industy contamination o the numbe of people exposed to contaminants.

15 Page 7 In esponse to these findings, a discussion of management contols that have been used by some light industies is povided in Chapte 4 of this document. That discussion pincipally addesses the poo housekeeping pactices found in many of the light industy case studies. In these examples, many light industies have not adequately managed aw and waste mateials by failing to cleanup leaks and spills o by disposing of compounds impopely, such as dischaging industial wastes to septic systems o diectly to the soil. Also, impope mateial stoage in uncoveed o unlined stoage aeas and handling of containe and tank insate fom pesticide and chemical stoage units was implicated as a contamination souce in a numbe of cases, as well as leaks and uptues of undegound stoage tanks and mateial handling pipelines. Finally, the misuse o oveuse of mateials such as oad salts and pesticides was identified as a contamination souce. Among the light industies eviewed in this epot, a few stand out as having a high potential fo contamination of gound wate. These light industies include electoplating and polishing sevices, wood and lumbe teating opeations, funitue efinishing and epai sevices, auto epai shops, oad deicing opeations, scap metal and auto junkyad deales, and laundy and dy-cleaning establishments. The potential fo gound-wate contamination caused by these light industies is widespead, as these types of businesses ae found in lage numbes thoughout the county. Thei geneal chaacteistics ae as follows: 0 ElectoDlates and Metal Fabicatos: The industies in this secto manipulate the fom o modify the suface of metals physically, chemically, and/o electically. Typical pocesses include foging, stamping, etching, engaving, coating, polishing, ginding, painting, and electoplating. The by-poducts of these activities include not only metal scaps but a wide vaiety of chemicals and solutions that pose a theat to gound wate. Of special inteest ae wastes such as spent solvents and still bottoms, paint esiduals, acid and alkaline solutions, plating 'and stipping solutions, waste oils, heavy metal wastewate sludges, and metal dusts (US. EPA, 1986). These wastes may each gound wate though delibeate and accidental dumps, accidental spills, leaks, and floo wash (Envionment Canada, 1984). 0 Wood Peseves and Teates: The wood peseving industy encompasses establishments pimaily engaged in teating wood, sawed o planed in othe establishments, to pevent decay and to potect against fie and insects (U.S. EPA, 1986). Typical wood pesevatives include pentachloophenol (PCP), ceosote, chomated coppe asenic, and ammoniacal coppe asenate. These pesevatives ae applied to the wood by steaming, boultonizing, and kiln o ai dying eithe unde pessue o in a vacuum. All of these pocesses poduce wastewate teatment sludges. Wastewate sludges fom ceosote and PCP pocesses ae listed as RCRA hazadous wastes. Othe wastes include leftove pesevative mateial in delivey containes; pocess steam condensate containing wate with ceosote, PCP, wood fibes and othe mateials; sludge fom pocess tank, stom unoff fom wok aeas containing spilled and leached pesevatives; and pocess cooling wates that come in contact with the wood pesevatives. "Kick-back" of pesevatives fom the wood fequently occus esulting in pesevatives being spead I

16 Page 8 aound the teatment aea. In addition, pesevatives may leach fom teated wood stoed in yad stoage aeas. While the amount of pesevative that leaches fom wood is typically quite low, all pesevatives ae somewhat soluble in wate. Some peseves have installed dip tacks and pads in stoage aeas to collect leached pesevatives, but this pactice may not be followed at all facilities (U.S. EPA, 1986) Funitue and Wood Stippes and Refinishes: Funitue stippes commonly use methylene chloide to emove the finish fom a piece. Methylene chloide is dissolved in a solution of methanol o isopopyl alcohol and wate; smalle quantities of acetone, pechlooethylene, and toluene may also be pesent. The mixtue is applied by bush, spay, o dipping; the finish is scaped o bushed off; and the piece is insed befoe efinishing. Some funitue stippes may use a five-step pocess that entails dipping in a methylene chloide stipping solution, followed by a caustic bath, inse, neutalization with hydochloic o phosphoic acid, and final inse (Connecticut Dept. of Envionmental Potection, 1984). Methylene chloide stipping solution is commonly ecycled in the funitue industy; caustic solutions, howeve, become weake with use and must be discaded. These wastes typically contain high concentations of methylene chloide along with alcohols, metals, and othe solvents. Many shops engaged in funitue stipping also conduct funitue efinishing opeations. These shops may handle stains, containing mineal spiits, pigments and alcohol; vanish, shellac, o polyuethane, containing denatued alcohol, esins, petoleum distillates and toluene diisocyanate; o enamel, lacque, and acylic paints, which contain toluene, pigments, halogenated hydocabons, and glycol ethe. F Auto ReDai ShoDs: Auto epai activities encompass such opeations as glass eplacement, tansmission, exhaust system and engine epai, and tie eteading. Most businesses in this goup ae small scale opeations employing less than ten pesons. This is especially tue fo auto bodybaint shops which ae specialized and may employ one to thee wokes (Tennessee Depatment of Economic and Community Development, 1986). age scale opeations usually ae less specialized and may povide a full ange of epai and maintenance semces. The majo theat to gound wate posed by these industies aises fom the disposal of such waste poducts as gasoline, diesel fuel, oil, and degeasing solvents. Auto body and paint shops poduce spent paintbolvent waste which is classified as a RCRA ignitable hazadous waste. 0 Road Deicing ODeations: Highway depatments, thei contactos, and othe pivate paties stockpile and spead substantial quantities of deicing mateials on steets and othe paved aeas. Gound wate may be affexted by impope stoage o by washoff of these mateials fom

17 Page 9 oad sufaces. Excessive o impope application to steet sufaces adds to the potential fo contamination. Salts ae commonly used as highway deicing agents, alone o in combination with abasives such as sand, gavel, o ash. Sodium chloide is by fa the most commonly used deicing agent. Calcium chloide is also used, often togethe with sodium chloide. Uea, an oganic chemical, is geneally used on aipot unways athe than salts because it is less coosive. e e Scap and Junkvads: Scap yads, salvage yads, junk yads and metals ecycles, which accept o buy scap automobiles, white goods such as efigeatos and scap metals, ae found thoughout the county. The vast bulk of the mateials managed in these yads ae stoed in the open, often diectly on the gound, whee metal coosion and oil eleases can occu. These establishments most often gathe feous and nonfeous metals fo seconday smelting and ecycling. Battey beaking, o the disassembly of automobile stoage batteies fo ecovey of the lead plates inside, may occu. Baels o dums used to contain hazadous mateials -- with o without some o all of thei contents -- may also be handled and ecycled by such facilities. Agicultual chemical and pesticide containes make up the bulk of ecycled dums, especially in the Midwest. Many ecycles puchase the baels and clean them up fo esale as tash o stoage containes. Pocesses used to stoe, handle, clean, and tanspot these containes can cause gound-wate contamination. Substantial quantities of used oil, gasoline, and antifeeze also may be geneated in these yads. PCB-laden oils may be eleased fom lage electic utility tansfomes and can be eleased fom small capacitos and tansfomes included in household appliances. Combustible fuels may be ecoveed fo sale o fo on-site buning. aundv and Dv Cleanine Establishments: Dy cleaning entails laundeing gaments in non-aqueous degeases and solvents athe than wate and detegents. micaly, the gaments ae agitated within lage machines containing the solvents then spun, emoved, and died in a sepaate machine. The contaminated solvents ae filteed, distilled, and etuned fo euse. Distillation can be done in-house with the appopiate equipment. Newe dy-cleaning machines, efeed to as dy-to-dy machines, ae entiely self-contained and do not equie the tansfe of wet gaments to a die. The theat to gound wate fom dy cleaning opeations stems fom the solvents used fo the cleaning pocess. The most common solvent used is tetachlooethylene (also called pechlooethylene), although fluoocabon-113 and petoleum solvents ae used as well (U.S. EPA, 1987). All thee of these solvents ae volatile and toxic and capable of contaminating gound wate. The most common outes of solvent elease ae though spills duing handling and stoage (solvent typically is tanspoted and stoed in 55 gallon dums) and leaks

18 Page 10 fom cleaning equipment gaskets and othe inteconnections (Institute fo ocal Self-Reliance and Connecticut DEP, 1984). Spent filte sludges and catidges, used fo ecycling the solvents, also can contain significant amounts of esidual solvent. To a lesse extent, dying vents allow the condensation and dipping of solvents onto the gound, and wate collected duing solvent distillation (typically less than one gallon pe month) can cause contamination if not collected and disposed of popely (Institute fo ocal Self-Reliance and Connecticut DEP, 1984). Although many of the above-listed light industies have been identified as past souces of gound-wate contamination, much of this potential theat to Wellhead Potection Aeas is being mitigated though the adoption of impoved aw and waste mateial management pactices. ight industies ae instituting these pactices as a esult of the enfocement of existing Fedeal, State, and local laws and though voluntay adoption of impoved mateial management pactices. With egad to existing Fedeal law, RCRA standads fo hazadous waste management equie that geneatos manage thei wastes popely in tanks o containes and aange fo tanspot of the wastes to pemitted on-site o off-site disposal facilities. Many of the past cases of impope waste management at dy cleanes, electoplating facilities, and wood peseves, fo instance, ae being pevented by RCRA standads fo small and lage quantity geneatos (see Chapte 3). In addition to contols mandated by Fedeal law, cetain State and local authoities ae enfocing moe stingent standads on the siting of light industies and the pactices followed by the industies. The liabilities associated with impope waste management have also led many industies to adopt management pactices that ae potective of the envionment. Futhemoe, the inceasing costs associated with waste management and disposal have encouaged industies to adopt waste minimization techniques to limit the geneation of waste poducts. As a esult, many of the types of past contamination incidents eviewed by EPA will be pevented in the futue. Nonetheless, while light industial management pactices ae impoving, many of the mateial handling pocesses followed by light industy still emain unegulated o minimallyegulated. As discussed below in Chapte 3, geneatos of less than 100 kg/month of hazadous waste ae not stingently egulated unde the cuent RCRA pogam. In addition, leaks o spills of aw mateials o poducts ae not contolled unde RCRA and may not be fully addessed unde CERCA o othe authoities. Futhemoe, thee ae no data available to accuately assess the extent of voluntay adoption of management contols and waste minimization techniques by light industy. Theefoe, Wellhead Potection Pogam manages and othe State and ocal officials should be awae that existing contols may not be adequate to ensue that hazadous mateials ae managed in a manne that will pevent contamination of Wellhead Potection Aeas. Potecting these public wate supplies may equie local juisdictions to eithe impose limitations on the siting of light industies in Wellhead Potection Aeas o encouage the widespead adoption of management contols. Examples of such State and local pogams ae discussed in Chapte 3. The following chapte povides a boad oveview of the aw and waste mateials managed by light industies that may pose a theat to Wellhead Potection Aeas. - i i '. i.

19 , Page Oveview of the Poblem: Raw Mateial and Waste Management This chapte descibes the mateial management phases and potential contaminants handled by light industies. The chapte concludes with a discussion of the significance Of light industial mateial management fo wellhead potection. 2.1 Phases of Mateial Management and Mismanagement and the Potential fo Gound-Wate Contamination EPA has identified five geneal phases of mateial management by light industy that may pose a theat of gound-wate contamination: 0 Raw mateial and poduct delivev, tansuot. and tansfe. eaks and spill incidents may occu while managing aw and waste mateials duing tanspot between stoage and use locations, though pocessing aeas, and to disposal sites. 0 Raw mateial and poduct stoape. Contaminants can be eleased into gound wate when stoage tanks o containes fail. Rusted baels can leak; holding tanks can fail due to faulty design, constuction, o maintenance; fies, collisions, and othe accidents may cause spills, and impope opeation may esult in unplanned eleases. 0 Mateial Docessin! and manufactuinq Poduction pocesses ae subject to malfunctions, spills, o leaks o may involve planned eleases of mateials. 0 Waste ManaPement and Disposal. On-site waste teatment and disposal may cause gound-wate contamination (e&, in septic systems which ae pooly designed o inappopiate to teat the waste poducts) o may involve mateial-handling pocesses subject to accidents. Disposal into sewes may lead to contamination if sewes leak. 0 Pocess and site maintenance. Potential contaminants may be eleased duing the maintenance of buildings, equipment, o vehicles. Gound-wate contamination can occu at any one of these phases of mateial management. Exhibit 2 illustates the fequency with which the vaious phases wee involved in the gound-wate contamination incidents eviewed by EPA The exhibit demonstates that contamination incidents ae most fequently associated with waste management and waste disposal activities. w-?- c

20 Page 12 EXHIBIT 2 Distibution of Mateial Management Phases in Gound-Wate Contamination Case Studies d Q u) 9 0 t a E z Managomont and 8toago Pooolng and Manu- Unknown Malntonanoo Tanpot and Dlpoal Tanto faotwhg Mateial Management Phases i. 1 Data fo this exhibit wee compiled fom the summay of 182 case studies of gound-wate contamination at light industial facilities.

21 Page 13 Waste management geneally involves packaging o pepaing wastes fo off-site shipment and tansfeing wastes to stoage aeas though pipelines o othe conduit. Releases can occu though leakage fom waste containes o tempoay stoage tanks. In addition, a numbe of light industies have expeienced eleases fom pipelines used to tanspot wastewates to stoage tanks o containes fo futhe teatment o management. Because light industies geneally do not dispose of thei waste mateials on-site, pope waste management pio to off-site shipment is citical fo the potection of Wellhead Potection Aeas. Such management pactices include inspecting waste stoage tanks and containes to ensue that they ae not leaking and maintaining catchment basins and bems to contain eleases. Futhemoe, emoving waste mateials fom a light industy site in a timely manne helps to ensue that the wastes will not be abandoned and left in place. Impope waste disposal has also occued at many light industy facilities. Any occuence of impope waste o mateial management that esults in a elease to soil o gound wate which is not cleaned up constitutes impope waste disposal. Fo example, light industies, such as auto epai shops o electoplates, have expeienced eleases to soil that have not been addessed though soil excavation o othe emediation. Such impope waste disposal often leads to gound-wate contamination. Some light industies also impopely dispose of thei hazadous wastewates in septic systems o othe on-site wastewate disposal systems which ae not capable of adequately teating many hazadous wastes. As a esult, contaminants dischaged into a septic system may pass though the system s soil infiltation field and into gound wate. Popely segegating wastes and peventing hazadous wastes fom enteing septic systems is the best means of ensuing that such gound-wate contamination will not occu. All of the phases of mateial management at individual light industial facilities ae also pevalent at light industial paks, although the natue of the potentially contaminating activities may diffe with the diffeent pak types. Futhemoe, the layout and constuction of the paks themselves may impact wellhead aeas by affecting wate unoff pattens and by intoducing fetilizes and pesticides into the aea as pat of landscaping pactices. In geneal, the numbe of potentially contaminating activities, as well as the quantities of contaminants, inceases with the degee o level of industial activity at an industial pak. The quantity of contaminants pesent also geneally inceases with the degee o level of industial oientation, although the hazad posed by even a small volume of contaminants may still be sevee. Fo example, a small amount of a vey hazadous mateial intoduced into a wellhead aea fom a mixed use pak could be moe hamful than lage amounts of a less hazadous substance intoduced fom a heavy industy pak. The industial pak activities with the potential to contaminate gound wate ae illustated in Exhibit Mateials Managed by ight Industial Facilities ight industies manage a wide ange of mateials that may potentially contaminate gound wate. Vitually all mateials managed at lage o heavy industy facilities ae also found at light industy facilities, though in smalle quantities. In geneal, these contaminants include the following: 0 Petoleum Poducts. Fuels (e.g., gasoline, diesel) and thei additives (benzene, xylene), gease, oil, and PCBs.

22 Page 14 EXHIBIT 3 INDUSTRIA PARK ACTMTIES WITH POTENTIA TO CONTAMINATE GROUND WATER Stoage, On-Sile Science Technology omce/ "M" - Paks Paks Mixed Use Industial Industial Above-gound stoage containe o impoundment failue Undegound stoage tank failue 0 eaks, spills, fis 0 DbpoPl On-site septic tank, teatment inadequate, seepage lagoon Sewe leak PoeeaPinglPoducllon eaks, spills, oveflaws ~ p o t e ~ ~ f e Spills (lage quantity) 0 eaks (small quantity fom pipeline o vehicle) some 0 M.inc~nce AcliviUes Handling, use, disposal of cleaning mateials Handling, use, disposal of waste mateial (e.g., used oil).nhping Maintenance and salt application Impoundments and svcam~ Vegetation maintenance Iivestock (ducks and gee=) 0 0!! 11 Souce: Battelle, 1988

23 Page 15 0 Othe Oganics. Chemicals used as solvents, pocess chemicals in pinting, photogaphy, textiles, dy cleaning, electonics, funitue stipping, tanning, efigeants, lubicants, dyes, adhesives, pesevatives, disinfectants, and as feedstocks fo chemical, phamaceutical, and plastic poduction. 0 Pesticides. Oganic chemicals used fo insecticides, fungicides, hebicides, and odenticides. 0 Metals and Othe Inoganics. Acids, alkalis, metals, salt, cyanides, detegents, and nitates. 0 Micooganisms. Viuses and bacteia. Exhibit 4 illustates the fequencywith which contaminants managed by light industy wee epoted in the case. As demonstated in the exhibit, a wide vaiety of constituents have contaminated gound watet at light industial facilities. The most pevalent geneal goups of contaminants obseved in the case studies include oganics and metalshnoganics. Although these categoies ae vey boad and encompass a lage numbe of constituents, the case study infomation geneally is not sufficiently detailed to suppot a moe specific analysis. Fo those case study epots that do contain constituent-specific infomation, typical oganic contaminants include benzene, dichlooethylene, dioxins, methylene chloide, pentachloophenol, pechloethylene, toluene, tichlooethane, tichlooethylene, and xylene. Most of these oganics appea to be used as solvents in poduction o cleaning pocesses.?pical metals/inoganics epoted in the case studies include asenic, chomium, coppe, lead, nickel, nitates, and sodium chloide. i The following section analyzes the implications of the case study findings with egad to wellhead potection. 23 Analysis and Discussion Infomation fom the light industy gound-wate contamination case studies summaized in Sections 2.1 and 2.2 encompasses a wide ange of industy types, mateial management pactices, and contaminants. Although the tue extent of Wellhead Potection Aea contamination caused by light industy is unknown at this time, the data gatheed fo this analysis eveal cetain pattens conceming the theats light industy pose to gound-wate quality. The most pevalent mateial management phase associated with the gound-wate contamination cases involved waste management and disposal. Impope stoage of aw mateial and poduct stoage was cited as the next most common contamination souce. The pedominance of waste management and disposal activities in the gound-wate contamination cases is not unexpected. These cases involve activities such as impope disposal in septic systems and illegal dumping o abandonment of wastes. Although many of these pactices ae cuently addessed by RCRA equiements (see Chapte 3), illegal o negligent disposal may still occu. Similaly, aw mateial and poduct stoage has also come unde inceasing egulatoy contol, especially fo those pactices involving undegound stoage tanks (RCRA Subtitle I). Enfocing existing Fedeally-mandated standads and contols fo waste management and poduct stoage may seve as one means of limiting contamination esulting fom these mateial management phases at light industy facilities. f i

24 Page 16 EXHIBIT 4 Distibution of Mateials Managed by ight Industial Case Study Facilities d 100 SO e0 i 40 c 20 0 Otho Mo1.h and Potoloum Potloldo Unknown Mloo- Ogmia Inoganlo Poduot oganlm Mateials Managed... Data fo this exhibit wee compiled fom the summay of 182 case studies of gound-wate contamination at light industial facilities.

25 Page 17 The pevalence of the oganic and inoganic constituents obseved in the case studies is also expected. The oganic contaminants ae pimaily solvents used as pats cleanes and as caies fo othe substances. These oganics ae used in a vaiety of light industies, such as wood peseving and dy cleaning, and many of the oganics ae mobile in the soil and gound wate envionments. Similaly, the inoganic constituents obseved in the case studies ae also in widespead use by light industy, especially in electoplating and metal fabication industies. Most all of the constituents obseved in the case studies ae egulated as hazadous wastes by RCRA o hazadous substances by CERCA. The exceptions include nitates, sodium chloide, and BOD, although these contaminants ae also addessed unde dinking wate citeia. In sum, the case study findings indicate that: (1) waste management and poduct stoage pocesses pose the most pevalent elease theats to gound wate, and (2) a wide vaiety of potentially hamful constituents ae managed at light industy facilities and ae involved in elease incidents. f

26 Page 18.

27 Page Contols on ight Industy: Fedeal, State, and ocal Roles In this chapte, we outline the vaious Fedeal contols that may affect light industy pactices. Selected State and local initiatives ae also discussed. The chapte concludes with an analysis of the inteelationships among Fedeal, State, and local activities and the manne in which they can be used togethe to develop an efficient and effective means of evaluating and egulating gound-wate theats fom light industial souces. EPA pepaed this discussion to help Wellhead Potection Pogam manages and othe officials undestand and develop appopiate management contols fo light industy within thei juisdictions. 3.1 Regulating Mateial Management by ight Industy unde Cuent Fedeal aw A vaiety of Fedeal laws and egulations contol the management of hazadous mateials and wastes. Howeve, many of these Fedeal equiements impose only limited contols on light industy, while leaving cetain potentially contaminating activities o substances unegulated. The following section descibes seveal of these Fedeal laws and egulations. The discussion highlights the manne in which these equiements eithe do o do not apply to cetain light industy pactices. The majo Fedeal Regulations contolling the management of hazadous mateials ae: RCRA (Resouce Consevation and Recovey Act); CERCA (Compehensive Envionmental Response, Compensation and iability Act); SDWA (Safe Dinking Wate Act); CWA (Clean Wate Act); TSCA (Toxic Substances Contol Act); and FIFRA (Fedeal Insecticide, Fungicide, and Rodenticide Act). The application of each of these egulations to light industy management pactices is discussed below. Resouce Consevation and Recovev Act (RCRA). RCRA addesses the management of hazadous and solid wastes unde Subtitles C and D of the statute, espectively. These potions of RCRA addess only was> mateials and not aw mateials o poducts. Fo example, pesticides that ae packaged fo sale ae not a hazadous waste. The mateial may become a hazadous waste, howeve, when the pesticides ae discaded. In contast, unde Subtitle I of RCRA, standads ae povided fo undegound stoage tanks (USTs) that ae used to manage chemical and petoleum poducts. Each of these RCRA pogam aeas may impose contols on cetain activities of light industy. Subtitle C of RCRA ecognizes thee classes of hazadous waste geneatos (40 CFR ): (1) geneatos of geate than 1,OOO kglmonth of hazadous waste (lage quantity geneatos); (2) geneatos of between 100 and 1,OOO kglmonth of hazadous waste (small quantity geneatos - SQGs); and (3) geneatos of less than 100 kglmonth of hazadous waste (conditionally exempt small quantity geneatos o vey small quantity geneatos - VSQGs). age quantity geneatos and most small quantity geneatos must meet specified equiements, including: obtaining an EPA ID numbe, popely managing the waste in tanks o containes (40 CFR ). manifesting off-site shipments of the waste, and maintaining ecods and egula epoting. Geneatos of less than 100 kg/month of hazadous waste, o

28 Page 20 conditionally exempt small quantity geneatos, howeve, ae not equied to meet the technical equiements fo RCRA geneatos (40 CFR 261.5). Many of the types of light industies descibed in this document fall in this class of conditionally exempt small quantity hazadous waste geneatos. Exhibit 5 illustates the elative beakdown between the numbe of small quantity geneatos and vey small quantity o conditionally exempt geneatos. Estimates of the beakdown between SQGs and VSQGs suggest that thee ae appoximately 175,000 geneatos in the 100 to 1,OOO kg/month categoy and geneatos of less than 100 kg./month (US. EPA, 1985). Although EPA estimates that these two goups of geneatos epesent appoximately 98 pecent of all hazadous waste geneatos in the United States, the total volume of waste managed by these goups amounts to less than 0.5 pecent of the total quantity of waste geneated annually. Nonetheless, these small and conditionally exempt geneatos still manage appoximately 630,000 metic tons of hazadous waste pe yea (US. EPA, 1985). The vast numbe of these geneatos and the elative lack of egulatoy contol on thei opeations aises the potential fo gound-wate contamination. Concens that aise fom the activities of these opeations can be taced, at least in pat, to seveal factos: 0 Many opeatos of smalle facilities ae not awae that they may be geneating hazadous wastes, o that thei disposal pactices could esult in contamination of gound wate. 0 Facilities that do not geneate lage volumes of waste may nonetheless handle lage volumes of hazadous aw mateials which should be of concen to local plannes seeking to potect thei wate supply. Wood peseves, funitue stippes, and pesticide applicatos ae only thee examples of industies that typically do not geneate lage volumes of waste, yet may have lage volumes of chemicals stoed on site. 0 Even small volumes of hazadous aw o waste mateials can contaminate a wate supply, paticulaly if the mateial is dischaged in a Wellhead Potection Aea. Cetain types of wastes that typically might be managed by light industies have been specifically exempted fom egulation unde RCRA These wastes include agicultual imgation etum flows, mateials that ae ecycled in closed systems, and wastewates that ae disposed of in sewes o publicly-owned teatment woks (POTWs) (40 CFR (a)). Futhemoe, ecycled mateials such as used batteies and used oil ae not egaded as hazadous waste unde RCRA. Howeve, if these mateials ae disposed of, they must be managed as hazadous waste. RCRA Subtitle D egulates othe types of wastes defined as solid wastes, including household gabage, mining wastes, wastes fom oil and gas poduction, and cement kiln dust waste (40 CFR 261.4@)). It is impotant to note, howeve, that although these "solid wastes" must be managed in compliance with the citeia outlined unde RCRA Subtitle D, these citeia apply only to the solid waste management fadties that ultimately dispose of the waste (40 CFR Pat 257). In effect, the light industies that geneate solid waste ae not egulated unde RCRA Subtitle D. Hence, light industies that ae eithe geneatos of solid waste o conditionally exempt geneatos of hazadous waste ae only minimally egulated by the RCRA hazadous waste contols.

29 Exhibit 5 Paee 21 Distibution of Small Quantity Geneatos by Industy Goup: SQGs and VSQGs Othe Mfg. Othe Non- Manufactui ng 13% Vehicle Maintenance 70% Constuction 3 yo SQGs (2100 kg/mo) Othe Mfg. 9% 1 Manufactuing = Non-Manufactuing Othe Nom.Manuf act I 22% Vehicle Maintenance 48% Constuction 13% VSQGs (400 kg/mo) Souce: Small Quantity Geneato Suwey data and analysls of seconday Industies I

30 Page 22 The Subtitle 1 pogam of RCRA egulates appoximately 1.5 million undegound stoage tanks that ae used to stoe chemical and petoleum poducts. The pogam bans the installation of unpotected new tan@, equies tank ownes to notify EPA of the numbe Of tanks in use, establishes standads to clean up eleases fom the tanks, and imposes technical standads and inspection equiements fo existing tanks (40 CFR Pat 280). Subtitle 1 diffes fom Subtitle C and D in that it applies technical standads to pocesses that manage poducts, not wastes. The UST pogam addesses the petoleum stoage tanks used by light industies, such as automobile sevice stations and dealeships, and the chemical stoage tanks found at light industies, such as agicultual supply sevices and cetain electoplating shops and electonic equipment manufactues. Howeve, the UST pogam applies only to tanks with at least ten pecent of thei volume buied undegound. Futhemoe, the following types of tanks ae specifically exempted fom the Subtitle I contols: fam and esidential tanks with a holding capacity of less than 1,100 gallons; on-site tanks stoing heating oil; septic tanks; pipelines egulated unde othe laws; suface impoundments; systems fo collecting stom wate and wastewate; flow-though pocess tanks; and liquid taps o associated gatheing lines elated to opeations in the oil and natual gas industy (40 CFR Pat 280). Thus, although Subtitle I pesents a level of potection against leakage fom cetain types and volumes of hazadous mateials containes, non-egulated activities within a wellhead aea can pose an equivalent theat to a wate supply. Futhemoe, RCRA does not stipulate povisions that goven aw mateials handling pactices within an industy. e Comuehensive Envionmental Response. Comuensation, and iabilitv Act JCERCA). The best known component of CERCA is the emedial action pogam which addesses past eleases of hazadous substances to the envionment. Many cases of goundwate contamination by light industy ae cuently being addessed unde Supefund. In addition, Title I11 of the Supefund Amendments and Reauthoization Act of 1986 (SARA) imposes cetain emegency planning and notification equiements on facilities that handle hazadous mateials. The fist of these equiements, found in sections ,311, and 312 of Title 111, is known as the "emegency planning and community ight-to-know" pogam. This pogam equies facilities to notify State officials of the pesence of "extemely hazadous substances" at thei location, and to supply local officials with a list of all mateials stoed on site in volumes that exceed theshold quantities established by EPA (40 CFR Pat 355 and 40 CFR Pat 370). These povisions wee adopted to enable communities with paticipating facilities to establish emegency planning and notification pocedues, based on the mateials located within the community. Section 302 authoizes State officials to designate additional facilities (e.g., those which handle lesse amounts of egulated mateials) as subject to the planning equiements. II Additional povisions within Title I11 elate to notification equiements fo eleases of hazadous mateials. Section 304 of SARA equies immediate notification to local and State emegency planning committees if any of the listed hazadous substances ae eleased fom a facility (40 CFR Pat 3024 and 40 CFR Pat 355), as well as follow up emegency notice. A second pogam, unde SARA Section 313, equies that all eleases of hazadous substances, both outine and accidental, as well as off-site shipments of waste containing listed toxic chemicals, must be epoted to EPA (40 CFR Pat 372). Although both of these pogams equie light industies to notify EPA of eleases of hazadous substances, Title 111 contains no explicit cleanup equiements. Title 111, like RCRA, does not impose any conditions on mateials handling pactices; it only equies inventoies and epots. e Safe Dinking Wate Act fsdwa). The SDWA mandates contols on cetain waste management activities to pevent the contamination of dinking wate supplies. In paticula, EPA has pomulgated egulations unde the SDWA to contol the disposal of wastes in undegound injection wells (40 CFR Pat 144). The SDWA egulates five geneal classes of undegound injection wells. Class I wells ae those that ae used to dispose of hazadous o othe industial waste. Class I1 wells ae used to dispose of mateials such as bines and oil dilling wastes. Class I11 and IV wells ae othe types of disposal wells which ae fa less

31 Page 23 common. Class V wells include the emaining types of waste disposal wells, including shallow dy wells and cetain types of septic systems. Many contamination events caused by light industy involve the impope disposal of wastes in these Class V wells. Although some contols ae now being imposed on disposal in Class V wells, impope waste disposal by light industy in these wells still occus. Changes to the Fedeal egulatoy equiements may impose tighte contols on disposal in Class V wells in the futue. The 1986 amendments to the SDWA include povisions that equie States to establish Wellhead Potection Aeas aound public wate supply wells. These povisions equie, among othe things, the identification of all potential souces of contamination within the Wellhead Potection Aeas and a desciption of contol measues to potect the Wate Supply. These activities and contol measues include light industial opeations. Clean Wate Act (CWA). The CWA addesses the estoation and maintenance of the chemical, physical, and biological integity of the Nation s wates though the eduction and elimination of toxic pollutant dischages; poviding States with financial assistance fo the constuction of publicly owned waste teatment woks; development and implementation of aeawide waste teatment management plans fo the contol of pollutant souces in each State; development of technology necessay to eliminate pollutant dischage into oceans, coastal and navigable wates; and fo assessment and management of nonpoint souces of pollution nationwide. Povisions unde CWA applicable to the contol of light industial souces of goundwate contamination include nonpoint souce pollution contol pogams (Section 319), effluent pemitting guidelines (Section 304), and stomwate pemitting equiements cuently unde development unde the National Pollutant Dischage Elimination System (NPDES; Section 402). Toxic Substances Contol Act SCA). TSCA egulates the use of new and existing chemical substances and mixtues. Unde Section 5 of TSCA, manufactues of new chemical substances must notify EPA though the submittal of a pe-manufactue notice (PMN) at least 90 days pio to commencing manufactue o impot of the substance fo non-exempt commecial puposes. EPA will then eview the new chemical substance and may impose estictions on the manufactue, pocessing, distibution, use, o disposal of the substance. In some cases, companies may have conducted toxicity testing pio to beginning to manufactue the substance. As a esult of this pocess, EPA may estict the use of cetain chemical poducts eithe handled o poduced by light industies. TSCA also egulates the use and disposal of polychloinated biphenyls (PCBs). Fo.example, EPA is instituting a nationwide pogam in which the PCBcontaining fluids in electic tansfomes and capacitos ae being eplaced with othe polyelectolytes. BCA futhe equies that waste PCBs fom these and othe applications must be disposed of in appoved landfills o incineatos o EPA-appoved altenative disposal technologies. ight industies that eithe use machiney containing PCBs o collect scap mateials containing PCBs must comply with these TSCA contols. 0 Fedeal Insecticide, FunPicide. and Rodenticide Act (FIF RA). FIFRA addesses the egistation and use of pesticides in the United States. The act has been used to indiectly potect gound wate though the pesticide egistation pogam. A manufactue must geneally submit a vaiety of health and safety data befoe EPA can egiste a pesticide (40 CFR Pat 152). If EPA detemines that use of a pesticide will esult in uneasonable advese effects on the envionment, including gound-wate contamination, EPA may deny egistation. Among othe options, EPA can impose packaging and labelling equiements and estict the use of a pesticide. Cancellation of a egistation is also possible if poduct use geneally causes uneasonable advese effects on the envionment. Each pesticide must

32 Page 24 have a label that contains detailed diections fo use. All uses, including light industy, must comply with these equiements. Amlicabilitv of Fedeal Contols to ight Industy The peceding discussion illustates that cetain light industial pactices ae egulated by Fedeal law, pincipally unde Subtitles C and I of RCRA. These egulations, howeve, ae limited to the listed waste disposal and stoage pactices and mateials. While the egulations do goven most majo geneatos, much of the light industial secto is exempt. Povisions of SARA Title I11 apply to any facility that uses hazadous mateials in excess of the listed theshold quantities, but even this expansion of the egulated community does not encompass all light industial facilities. Futhemoe, the statute only equies an inventoy of mateials; management pactices o guidance ae neithe povided no mandated. TSCA and FIFRA impose estictions on the use of a limited numbe of mateials that could pose a theat to a community's gound wate, and the SDWA egulates some activities that affect gound-wate quality. Thus, the Fedeal pogams, although poviding compehensive egulation of majo geneatos of waste and handling of select mateials, povides little egulation of poduction pocesses and small-scale waste management pactices. These limitations can be taced in pat to the shee numbe of facilities that would be bought unde the Fedeal umbella, if it wee to become all inclusive. Additional constaints on a Fedeal ole aise fom taditional eliance on State egulation of activities elating to the gound-wate esouce. Vaious States and local govenments have taken additional steps to potect thei gound wate, which include measues elating to light industial activities. Many States and local govenments have adopted contol pogams unde the boad mandates of RCRA, CERCA, o othe Fedeal o State statutes. A compehensive summay of State and local pogams is beyond the scope of this document. Nonetheless, in the following section we biefly descibe State and local appoaches fo contolling light industies. This chapte concludes with a desciption of the inteelationship among Fedeal, State, and local pogams and how the vaious authoities can be combined to pevent the occuence of gound-wate contamination fom light industial activities. 3.2 State and ocal Appoaches fo Contolling ight Industy The Fedeal govenment delegates to the States a boad police powe to legislate on behalf of the public health, safety, and welfae. This powe can be used to potect goundwate esouces fom vaious foms of industial contamination. While the authoity is boad, it is tempeed by limitations imposed by the pinciple of Fedeal peemption, language found in State constitutions, and ulings of Fedeal and State couts. Pogams adopted by States that can help to potect gound wate fom contamination due to light industial activities include: Wateshed Rules and Regulations - ocal agencies in New Yok State, fo instance, ae authoized to adopt land-use plans to potect public wate supplies.

33 Page 25 0 Gound-Wate Management Aeas - Washington State s Depatment of Ecology will designate aeas that have identified concens ove gound-wate quality; a management plan is tailoed to suit the local needs. 0 Gound-Wate Standads - Many States have adopted standads to potect thei gound wate. Standads may be eithe numeic, specifylng a maximum concentation fo a paticula contaminant (see, e.&, Alaska, New Hampshie, Texas), o naative, specifylng a geneal pohibition on types of dischages o identifylng a geneal quality goal (see, e.g., Aizona, Michigan, Noth Caolina). Some States have adopted both types of standads to ensue compehensive potection of the esouce. 0 Gound Wate Classification - Seveal States (e.g., Connecticut, South Caolina, Vemont) have classified thei gound wate and specified diffeential potection measues accoding to the classification. A numbe of States, such as Illinois and Wisconsin, have enacted legislation to authoize adoption of gound-wate potection measues by local govenment. Illinois legislation includes povisions that authoize the ceation of setback zones aound wells and an inventoy of facilities and activities suounding the wellhead (Illinois Municipal Code, Section ). Wisconsin municipalities wee given authoity to adopt zoning odinances to encouage the potection of goundwate esouces by legislation passed in 1984 (Wisconsin Assembly Bill 595). The town of Rib Mountain in Maathon County, Wisconsin, adopted landuse egulations to potect its gound-wate supplies. The odinance uses ovelay zoning to ceate two disticts within the echage basin fo municipal wells. ands ovelying the sand and gavel aquife have geate estictions imposed on use than moe upgadient aeas in the wateshed. Commecial and industial uses ae pohibited in Zone A, which is in close poximity to the wells. In Zone B, these uses ae allowed as conditional uses, if they meet cetain equiements to potect gound wate. ocal govenments have othe souces of egulating authoity in addition to goundwate specific State legislation; police powes have been delegated to local govenment in most States. This authoity can be implemented to potect gound-wate supplies by means of diect o indiect contols, such as land-use plans, zoning odinances, site plan eview, and design standads. Health odinances ae an effective means fo communities to egulate potential contaminants though thei police powes. This appoach contols mateials use egadless of the location of the facility, as opposed to egulating the location of the facilities. i In 1979, the Cape Cod Planning and Economic Development Commission (CCPEDC) developed a model health odinance fo use by towns on the Cape to contol the use, stoage, and disposal of toxic and hazadous mateials. The model odinance has thee majo components: 0 Pohibition - Dischages of toxic o hazadous mateials ae pohibited. P

34 Page 26 0 Registation - Ownes o opeatos of facilities stoing a quantity of mateials which exceed a theshold amount (established in egulations by the town) must egiste the type and amount of mateials with the Boad of Health (BOH). 0 InspectionEnfocement - The BOH is authoized to conduct inspections of sites whee toxic and hazadous mateials ae stoed o used. In pactice, the BOH identifies all fims o individuals who may be subject to the odinance, notifies them of the need fo compliance, povides a list of mateials consideed to be toxic o hazadous and theshold amounts of the mateials, and supplies a egistation fom which must be completed within a specified peiod of time. The BOH will inspect the facility if the foms ae not completed on time. If inspection eveals that foms ae in eo o unsatisfactoy pactices ae obseved, the BOH may equie coective measues to impove stoage, use, o disposal pactices. Fines fo violation.of coective odes ae up to $200 pe day. The Town of Banstable adopted the model odinance as a Town Bylaw in 1979, the fist community in the nation to adopt a local toxic and hazadous mateials handling bylaw. Banstable is a majo business and population cente located in the middle of the Cape, with the lagest concentation of light industial and commecial development. Ninety pecent of these establishments ae located within a fou squae mile aea and all ae within the zone of contibution fo seveal of Bamstable's public wate supply wells. Since seveal hunded facilities ae affected by the town's bylaw, a stong implementation pogam has been undetaken. Banstable officials wee paticulaly concemed that the only industial zone in the town ovelies the zone of contibution fo eight public wells supplying Hyannis. A lage pat of the industial aea is occupied by a pivately-owned industial pak which, as of 1986, was only five pecent developed. The town does not wish to discouage development, but must act to'potect the wate supply, which cannot be moved. Additional facilities of concem ae located outside the industial pak, but within the zones of contibution. The Banstable BOH eceived a technical assistance gant fom CCPEDC to pay fo a staff peson woking with the local health agent fo a yea to compile a compehensive list of mateials consideed to be toxic o hazadous, and to develop the egistation fom. Since then the BOH pocedues and foms have been efined, and the BOH epots that 100 pecent compliance with the bylaw by coveed facilities has been achieved with only two visits. One of the most influential land-use contol appoaches utilized by local govenments involves zoning. ocal govenments typically establish zoning and subdivision equiements that pescibe types of appoved uses fo land and buildings. Industial zoning odinances taditionally divide industial aeas into "light" and "heavy" disticts. The contols

35 E Page 27 on heavy industies ae geneally moe estictive, as these industies ae consideed most offensive. Some communities, howeve, have ecognized the potential fo contamination fom light industy and have imposed faily compehensive contols on these activities when they ae located in Wellhead Potection Aeas. The Dade County, Floida, Wellfield Potection Pogam is an evolving set of activities that wee initiated in the mid-1970's when volatile oganic compounds wee detected in a numbe of wate supply wells. The souces of these compounds included leakage and unoff, spills and impope disposal, and effluent fom heavy and light industial activities, domestic and municipal waste teatment plants, leaking sewe systems, and agicultual and uban unoff. Development of the pogam was undetaken pimaily within the Dade County Depatment of Envionmental Management to ensue long-tem potection of dinking wate. Section 208 studies unde the Clean Wate Act allowed the county to delineate wellfield aeas of influence and establish a basis fo egulating hazadous mateial use, stoage, and disposal. The Dade County Wellhead Potection Odinance egulates the type and density of wastewate dischaged within each of five zones in the aea of influence, based on soil conditions. The odinance pohibits the use of hazadous mateials within the aea of influence. The Dade County pogam povides the following estictions on light industy within the wellfield potection zones: No new hazadous mateials activities; No new nonesidential activities except on sewes; Only "low isk" nonesidential activities pemitted; Annual pemitting and inspection of all nonesidential uses; Density estictions as a function of tavel time to wells; No expansion of existing uses unless a net decease in envionmental isk is demonstated, Pogessively moe stingent stomwate disposal equiements as wells ae appoached, Best available technology is equied fo sewe constuction; Expedited seweing of unseweed aeas; Canal constuction o impovement to ceate hydaulic boundaies between wells and pollution souces; Expedited cleanup of known pollution souces; Ceation of appoved hazadous waste tansfe stations outside of the potection zones; imitations on tanspotation of hazadous mateials though the potection zone;.

36 Page Installation of ai,stipping equipment at wate teatment plants to educe volatile oganic compounds which may aleady be in the gound wate; and 15. Vaiances equie a 4/5 affimative vote fom the appeals boad. The peceding examples illustate some of the egulatoy tools that can be used by local officials to potect thei wate supply fom identified theats. Equally impotant to an effective pogam is an undestanding of the gound-wate system and the potential fo contamination. This undestanding and evaluation is citical to ensuing that a egulatoy pogam addesses potential poblems without being ovely estictive. Citizens of Spokane, Washington fomed a planning goup in 1977 to develop a stategy fo potecting thei undegound souce of dinking wate. The committee spent thei fist yea developing a data base of gound-wate quality, and eaching a common level of undestanding of gound-wate hydology and wate pollution poblems befoe beginning to develop a plan. Thei study showed that wate quality was deteioating due to human activities, including industial development and chemical spills esulting fom stoage, tanspotation, and use of chemicals. Specific incidents that could be taced to industial souces include the contamination of pivate wells by oganic cleaning solvents leaching fom a county landfill, and contamination of additional wells by cyanide oiginating fom pot linings disposed of at an aluminum eduction plant. The citizen's goup eleased a Wate Quality Management Plan in 1979, which included ecommendations fo contolling chemical spills and leaks though a combination of land use and zoning egulations, development and enfocement of best management pactices, and public education. Odinances adopted by Spokane County in 1983 established an Aquife Sensitive Ovelay Zone and established pocedues fo pope handling and disposal of hazadous and citical mateials in the home and the wokplace. The zoning odinance encouages business and industy using "citical mateials" to locate outside of the sensitive aea by setting pefomance citeia fo facility design which equie the etention of spills o leaks and the pevention of subsuface infiltation by defined mateials, as well as pohibiting chemical waste disposal in the sensitive aea. The citical mateials odinance and citical mateials handbook include equiements fo management contols fo handling and stoage of mateials; spill pevention, contol, and clean up plans; and identifying citical mateials and citical mateials use activities. Building pemits fo new constuction ae eviewed to detemine chemical use and to check fo appopiate design whee chemicals ae used o stoed. Seconday containment is equied fo undegound stoage tanks and associated piping, and spill esponse and shipping equiements have been established fo tanspotation of citical mateials. By adopting the tem "citical mateials" the committee sought to avoid confusion o the limitations associated with Fedeal and State hazadous waste egulations.

37 Pojects poposed in the sensitive zone ae compaed with a Citical Mateials Activity ist developed fom an Industial Suvey pefomed by the Washington Depatment of Ecology (DOE) and an Industial Waste Suvey pefomed fo DOE. A eview of spills in the Spokane aea evealed that spills geneally esult fom the tansfe of liquids between containes o fom mateial tansfe lines. The odinance, theefoe, contains guidelines that include povisions fo mateials handling: Pane 29 e e e Employee taining; Mateials popeties to be consideed when choosing a mateial fo a specific containment o stoage use; and Citeia fo detemining the equied containment volume fo secondaxy systems (e.g., include potential pecipitation and nieans fo sepaating pecipitation fom chemicals). The odinance also equies facilities that elect to locate in the sensitive aeas to pepae a spill plan. The plan is to include facility-specific infomation: i e e e e Desciption of physical facilities and the natue of opeations utilizing citical mateials; Notification pocedues in the event of a spill, Identification of potential souces of spills; Spill contol pocedues; and Taining pogams fo pesonnel. The mateials manual also contains design concepts to stimulate ideas fo mateials containment (e.&, coveed loading aeas, double walled pipes, peimete dains, and floo dains). ocal citizens have voted to ceate aquife potection disticts, which assess a monthly use chage of $1.25 pe month to all customes located ove the aquife and an additional $1.25 pe month to all those who dischage wastes though a dainfield system. These funds, supplemented by a $ sales tax, defay the costs of new seweage pojects and fund additional aquife potection pogams. All commecial and industial customes Within a distict ae equied to connect to a sewe within one yea of its completion, while new facilities ae equied to connect immediately. Commecial and industial facilities outside of sevice aeas must connect to county sewes unless the utilities distict detemines that connection is not economically feasible. Placing diect limitations on development is only one of the options available to local officials. Regulatos can condition appoval of a poposed development on the adoption of management plans by the develope o popety manage. Developes of pivate industial p'

38 Page 30 paks, fo example, can be equied to (o can voluntaily impose) covenants, conditions, and estictions (CC&Rs) on pak tenants that seve to supplement zoning estictions. The CC&Rs often act in conjunction with zoning contols to impose limits on industial "nuisances." Fo example, the lessee may be equied to submit a detailed site plan containing a epot which addesses envionmental issues elated to the opeation, such as the volume of hazadous wastes poduced o the anticipated load on sewage teatment facilities. CC&Rs may also pohibit dischages of hazadous mateials fom a site o estict the use of undegound stoage tanks. Wellhead Potection Pogam manages can use these public and pivate contols to assist in gound-wate potection. Additional infomation egading the potential tools fo potecting gound wate can be found in the publication Wellhead Potecion Pogams: Tobls fo Govenments, USEPNOGWP. 3.3 Analysis and Discussion The peceding sections indicate that thee is no single souce of authoity fo evaluating o egulating light industial pactices. Thee ae, howeve, a vaiety of statutes at both the Fedeal and State levels which can povide the means fo evaluating and "izing theats to Wellhead Potection Aeas. ocal govenments have additional options available to them though thei police powes and taditional land-use planning and egulation techniques. Two of the initial steps to take in developing a management pogam fo light industy involve the evaluation and definition of 1) the esouce to be potected, and 2) the potential souces of concem. Resouce evaluation is beyond the scope of this document. The eade is efeed to EPA's Guidelines fo Delineation of Wellhead Aeas (EPA 440/ ) as a stating point fo this effot. Seveal of the egulatoy authoities cited in this section, howeve, can be used to ascetain the natue of light industial opeations; an integal pat of evaluating souces. The pemit and notification equiements of RCRA and SARA Title 111, espectively, povide two avenues fo identification of light industial activities in Wellhead Potection Aeas. The files of the State division of hazadous waste contain the name, location, and mateials handled fo all RCRA geneatos in a given State. This souce of infomation can povide a fist level of scutiny by identifying most of the majo and many of the mino handles of hazadous mateials in the vicinity of a wemeld. The Small Quantity Geneato povisions of RCRA encompass many light industial facilities. In addition, some States have used thei RCRA authoity to egulate Vey Small Quantity Geneatos, those facilities that geneate less than 100 kg/month of hazadous waste. Massachusetts' VSQG pogam, fo instance, equies such facilities to egiste with the Depatment of Envionmental Quality Engineeing (DEQE). Although these facilities ae not equied to obtain a RCRA ID numbe o manifest, they must comply with cetain epoting equiements: 0 Types and quantities of hazadous waste poduced, Recycling, teatment, o disposal plans; and 0 Name and location of facility o geneato eceiving VSQG waste. The VSQG equiements effectively expand the available data base to include all geneatos of hazadous waste. Although this option povides additional infomation fo egulatos and plannes, the pogam also ceates an additional administative buden - the atio of VSQGs to SQGs is appoximately 26 to 1.

39 Page 31 0 Public Paticipation Massachusetts has incopoated anothe featue into its SQG pogam which could be of value to any State o community seeking to educe light industial contamination of gound wate. The hazadous waste division of DEQE has established a public paticipation goup that woks with industies and local govenments looking at behavio pattens and poviding compliance assistance. Fact sheets, videos, infomation pogams, and othe educational mateials ae all pat of the compliance assistance pogam. As noted in the Cape Cod expeience cited above, industies ae often willing and able to eliminate poblem aeas once they have the infomation in hand to ecognize and coect potential poblems. The State pesonnel ae able to addess a wide audience by poviding taining and infomation to local govenment officials, who can use these methods in thei own community. These techniques can be used effectively at both the State and local level with only a limited expenditue of esouces. 0 Inventoying The notification equiements of SARA Title 111 dictate that all facilities handling quantities of hazadous mateials in excess of EPA theshold amounts must povide a list of these mateials to community plannes. The significance of these equiements is that they apply to quantities of mateials that ae involved in the manufactuing o othe pocesses at the facility, not just the waste mateials. These equiements allow community and State officials to obtain an expanded pictue of-the light industial scene, since many facilities may handle sufficient quantities of hazadous mateial to qualify fo Title 111 notification, yet not geneate the amounts of hazadous - w necessay to equie filing as a RCRA lage quantity geneato. Wood peseves o funitue stippes, fo example, may handle o stoe lage volumes of mateials but geneate only small amounts of waste. Mateials handling is as significant as waste handling in the vicinity of the wellhead, because poo pactices in eithe aspect of facility opeations can esult in contamination of the wate supply. Although the Title I11 egulations do not include the authoity to egulate mateials handling, local officials, amed with the knowledge of stoage and use of hazadous mateials in the wellhead aea, may decide to impose mateials handling equiements though local contols. 0 Souce Identification The SDWA Amendments of 1986 equie States to develop management plans fo wellhead potection, including identification and contol of potential souces of contamination. Some States have aleady established pogams to accomplish these same goals. States wishing to adopt a Wellhead Potection Pogam can utilize the infomation available though RCRA and Title 111, as descibed above, to identify souces of contamination. State initiatives can also povide explicitly fo adoption of local goundwate potection measues. Any of these measues at the State level can incopoate povisions that include contols on light industy.!- Once a community has identified the Wellhead Potection Aea and the location of light industial facilities that ovelie the Wellhead Potection Aea, plannes will need to detemine the theat that these facilities pose to the wate supply. Each eommunitywill need to eview and evaluate the existing famewok of State and Fedeal contols and detemine whethe additional potection is needed fo thei wate supply. As noted above, few of the cuent egulatoy pogams povide contols on mateials handling, poduction pocesses, and management of small quantity waste steams. ocalities may detemine that local initiatives ae needed to povide adequate safeguads against contamination. This decision will be based in pat on the natue and extent of the Wellhead Potection Aea and, in pat, on the govening local politics.

40 Communities can use the wide ange of planning authoities and police powes available to fashion a Wellhead Potection Pogam specific to thei own needs. The examples povided in Section 3.2 illustate some of the options that local govenments have adopted to potect Wellhead Potection Aeas fom light industial contamination. Each community should efe to these and othe examples, but fashion thei own pogam to meet thei own situation. The appopiate decision fo some communities may be to estict all industial activities in the wellhead aea though zoning. Othe communities may detemine that a limited ban, coupled with contols on activities is appopiate. These contols can be in the fom of design standads fo facilities to educe the chance of contamination in the event of a elease, bans on the use of cetain mateials, o estictions on use in the fom of mateials handling o best management pactices. The following chapte pesents desciptions of some light industial pactices that pose potential theats to Wellhead Potection Aeas and the management contols that have been used by some industies to addess the potential fo contamination., R

41 .- Page Minimizing Gound-Wate Contamination by ight Industy Seveal contol techniques have been used by light industy to pevent gound-wate contamination. These techniques ange fom low-cost management contols to moe sophisticated technology-based waste minimization techniques. This section pesents an oveview, illustated with case studies, of management contols and waste minimization pactices fo potecting Wellhead Potection Aeas. The section concludes with an analysis and discussion of the ole of industy goups and local govenments in pomoting the use of management contols. 4.1 Management Contols fo Peventing Gound-Wate Contamination This section discusses seven management contols that have been ecommended by vaious State and local govenments and that have been adopted by many light industies. These management contols ae diectly applicable to wellhead potection. The following seven management contols illustate the boad ange of activities that many light industies have adopted to educe the theat of gound-wate contamination in Wellhead Potection Aeas. (1) Contolling sdillage in loading and unloading of aw mateials and wastes (Connecticut Depatment of Envionmental Potection, 1984). Spillage may occu at mateial tansfe points (e.g.,-loading and unloading aeas) at a vaiety of light industies, such as gas stations, small fuel stoage facilities, fam co-ops, o chemical stoage facilities. Though poo opeating pactices, gasoline, oil, pesticides, fetilizes, and chemical solvents ae fequently spilled on the gound. Impope use of hoses duing mateial tansfes also esults in spillage. When these spillage poblems can not be avoided, contamination can best be pevented though the installation of catchment basins beneath mateial handling aeas. These basins may dain to holding tanks. Spilled mateial can then be emoved to a teatment facility fo final disposal o, if the waste is compatible with the local POTW opeations, the waste may be teated and dischaged to municipal sewe lines. These catchment basins should be coated with impemeable mateials to pevent the leakage of mateials though the basin to gound wate. Example: An agicultual supply company in Hospens, Iowa has caused contamination of nine wells, including two munkbal wells. Appaniateiy 31,000 squae feet of soil was found to be contaminated at the mateials loading opeations aea. Contaminants included pesticides and cabon tetachloide. The handling pactices employed at the loading aea wee the pimay cause of the gound-wate contamination. The theat can be addessed by installing basins that dain to holding tanks with pope seconday containment. (2) ma nag in^. Many pesticide applicatos, asphalt mixing tucks, cop dustes, and lawn sevices clean off thei holding tanks and/o spaying equipment on open gound. Such cleaning should only be conducted ove catchment basins and contaminated unoff fom the cleaning pocess should be collected fo on-site ecycling and euse o offsite management (Cape Cod Aquife Management Poject, July 1988) Example: A cop dusting company in Maianna, Floida outine& puged and then pushed the a@lane s pesticide tanks onto the p od afie each dusting un. This pactice esulted in soil contamination and subsequent contamination ofpublic wate supply wells. The co?ata?ninant plume is 2,OOO feet in length and contains many diffeent types of pestickdes. Clealy linked to the puging and

42 Page 34 unoff fom insing the pesticide tanks, this gound-wate contamination could have been avoided with minimal unoff contol. (3) Peventing impope disuosal in septic svstems o dv wells. ight industia1 geneatos of solvents and othe hazadous wastes, such as auto epai shops, electoplates, funitue stippes, ca washes, dy cleanes, and light manufactuing plants, have been known to dispose of thei wastes in septic systems o dy wells. The types of wastes that ae disposed in septic systems and dy wells should be stictly contolled (U.S. EPA, 1986). Septic systems geneally consist of wo units: a septic tank and a leaching system. Bacteia in the septic tank anaeobically decompose solid mateial dischaged into the tank. Effluent fom the septic tank then flows into the soil leaching system. As the wastewates flow though the soil leachfield, some pollutants ae filteed, sobed onto the soil, o undego aeobic degadation. Although septic systems can effectively teat and dispose most domestic wastewates, these systems cannot teat all wastes. Nitates and volatile oganic solvents ae geneally not emoved in the septic tank no ae they bound in the soil. Futhemoe, the ability of the soil to immobilize heavy metals, pathogens, and phosphates can be exhausted ove time. As a esult, if these contaminants ae intoduced into the septic system, they can migate elatively easily though the soils and into the gound wate. Hence, disposal of industial wastewates containing metals and oganic solvents should be pevented. These types of wastewates can be disposed eithe though hook-up to a sewe system o though the use of "milk-un" pick-ups to gathe and tanspot hazadous mateials fo disposal. Dy and shallow wells have also been cited as an impotant souce of gound-wate contamination. Contamination has occued though impope disposal of wastewates in these wells and though the movement of suface contaminants into the wells duing stom events. These wells include municipal, industial, iigation, and livestock wells and unplugged test holes. Many olde wells ae impopely constucted with an absence of casing. Theefoe, contaminants that ente the wells can move into all wate-beaing stata. Futhemoe, these abandoned wells ae fequently left uncapped, inceasing the likelihood fo contamination. Disposal in these wells is contolled by the undegound injection contol pogam unde the Safe Dinking Wate Act. Dischaging to shallow wells should be pevented and the waste management shifted to ecycling o off-site disposal. in addition, all abandoned wells should be capped to pevent the eatq of any contaminants. ExamDIe: A mtchess County, New Yok dy cleane outinely disposed solvent wastes into the company's septic system. This impope waste management caused a 1,500 foot long plume of vaious hazadous solvents and metals that contaminated wells fo an apatment comple The emedial action cost $2 million. Rope handling and disposal of the wastes could have complete& pevented the gound-wate theat. (4) Minimizing the intensive use o oveuse of mateials. such as oad salts and agicultual chemicals. Many incidents of gound-wate contamination have been linked to the stoage and use of oad salts. Futhemoe, agicultual chemicals ae fequently used to contol vegetation gowing in utility o oad ightsf-ways. Peventing o limiting the use of these mateials in aeas of high gound-wate vulneability o switching to othe methods of oad and ight-of-way maintenance will help minimize gound-wate contamination. Fo example, abasives o othe oad deices such as potassium chloide have been substituted fo sodium chloide, which is a cummon gound-wate contaminant. Similaly, in some aeas Wellhead Potection Pogam manages ae etuning to mechanical methods of vegetation