The Federal Water Pollution Control Act Amendments of 1972 (public law 92-500) provide for comprehensive controls on surface water, but do not provide for specific regulatory control over subsurface water at the federal level. The only applicable regulatory provision of the act is for a federally approved state permit program which, among other things, requires a qualifying state authority to issue permits to control the disposal of pollutants into wells. Because of provisions in the new legislation requiring upgrading of the quality of discharges to both air and surface water, an increased assault on the quality of the nation's groundwater resources is anticipated. The EPA policy statement does not purport to have legal sanction, but rather puts the Agency on record as b ing opposed to the emplacement of materials by subsurface injection without strict controls and a clear demonstration that such emplacement will not interfere with present or potential use of the subsurface environment, contaminate groundwater resources, or otherwise damage the environment. The EPA policy does have some clout, however, in that it is designed to discourage the diversion of wastes treatable on the surface to the subsurface for the purpose of avoiding discharge permits or other provisions of P.L. 92-500, and most certainly will be used by the states in designing permit programs that will meet federal approval for the disposal of pollutants in wells.

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