United States
                   Environmental Protection
                   Agency
Office of
Solid Waste and
Emergency Response
EPA-540-F-98-051   ""
OSWER 9320.8-01 FS
PB98-963326
September 1998
SEPA        Evaluating Ground Water  Plumes
                   Under the  Hazard Ranking  System
  Office of Emergency and Remedial Response
  State, Tribal, and Site Identification Center (5204G)
                        Quick Reference Fact Sheet
 This fact sheet provides information on potential National Priorities List (NPL) sites evaluated as contaminated ground water
 plumes with no identified source of contamination and how such sites are evaluated under the Hazard Ranking System (HRS).
 It defines steps that should be taken before a ground water plume can be evaluated as a source of contamination and summarizes
 scoring considerations for sites that consist solely of a ground water plume. Responses to commonly asked questions about
 evaluating contaminated ground water plumes at potential NPL sites are also presented. This fact sheet provides guidance only
 and may be amended by EPA on a site-specific basis.
 BACKGROUND

 The HRS is the primary tool that EPA uses to place
 hazardous   waste  sites  on  the  NPL  under  the
 Comprehensive Environmental Response, Compensation,
 and Liability Act (CERCLA). NPL sites are those sites at
 which  releases  or potential  releases  of  hazardous
 substances pose a threat to  human  health or  the
 environment. For HRS purposes, "site" is defined as:

     Area(s) where a hazardous substance has been
     deposited, stored, disposed or placed, or has
     otherwise come to be located. (55 FR 51587,
     December 14,1990)

 In some instances, ground water has become contaminated,
 and the source of the contamination has not been clearly
 identified.  These sites are referred to as ground water
 plume sites. While the HRS specifically excludes from the
 definition of "source" those volumes of air, ground water,
 surface water, or surface water sediments that have become
 contaminated through  migration, it  does  make  an
 exception:

     "... in the case of either a ground water plume
     with no identified  source or  contaminated
     surface water sediments with  no  identified
     source, the plume or contaminated sediments
     may be considered the source."
     A contaminated ground water plume is generated when
     hazardous substances, pollutants, or contaminants enter an
     aquifer system.  Contaminants can enter and spread
     horizontally and vertically through the aquifer system by
     infiltration,  migration,  interaquifer  exchange,  and
     interaction with surface  water.   This  movement of
     contaminants  throughout  an aquifer is usually in the
     direction of ground water flow but can spread against the
     predominant flow direction. In the case of dense non-
     aqueous  phase  liquids   (DNAPLs),  for  example,
     contaminants may follow a localized geological contour at
     the bottom of a formation which may not conform to the
     hydrologic gradient

     The Extent of a Ground Water Plume Site
     Since ground water plume boundaries change over time
     with the introduction of additional contaminants from an
     unknown source and  the  dispersion  of contaminants
     through the aquifer, the extent of a plume is difficult to
     define. For HRS scoring purposes, ground water samples
     which meet HRS observed release criteria may be used to
     delineate plume boundaries.

     The purpose of listing sites on the NPL is to identify
     releases and potential releases that are priorities for further
     evaluation, not to identify the extent of the site. Defining
     the boundaries of a contaminated ground water plume in
     precise geographical terms would require more information
     than is routinely available at the listing stage. The same


         U.S. Environmental Protection Agency
         Region  5, Library (PL-12J)
         77 West Jackson  Boulevard,  12th Floor
         Chicago, IL 60604-3590

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considerations that impact the definition of all sites come
into play in defining ground water plume sites.

An NPL site listing encompasses all areas found to be
contaminated.  Therefore, in evaluating ground water
plumes with no identified source, the extent of the plume
site is not limited by actual property boundaries. The site,
however,  is  also limited  to  those  areas  that  are
contaminated.   Owners of property above aquifers
contaminated by migration of hazardous substances from
a source outside the property may not be responsible for
cleanup if the property owner did not cause, contribute to,
or exacerbate the release ("Announcement and Publication
of Final Policy Toward Owners of Property Containing
Contaminated Aquifers," 60 FR 34790, July 3,  1995).
Liability will be assigned to those parties contributing to
the plume when those parties are identified.

Naming Ground Water Plume Sites
To avoid  confusion, sites consisting of ground water
plumes with no identified source generally should be
named according to the geographical area in which the
plume is located (i.e., XYZ Ground Water Plume),  instead
of including potentially responsible parties in the site name
(i.e., Smith Co. Plant).  Regardless, the site as defined by
the HRS is neither equal to nor confined by the boundaries
of any specific property from which the site name is
derived.

EVALUATING A GROUND WATER PLUME AS A
SOURCE

The first step in evaluating a plume site is to show the
contamination of an aquifer.  Generally,  contaminant
plumes are identified as a result of routine monitoring of
drinking water supplies. Additional ground water sampling
to confirm  the elevated concentrations  and  establish
appropriate  background  levels will  verify  that  a
contaminated ground water plume is present While the
exact extent of the plume may not be defined, all samples
used to characterize the ground water plume should meet
the criteria for establishing an observed release.  Areas
lying between such samples should be considered a part of
the plume, unless information indicates  contamination
should not be inferred between these points.

Once ground  water contamination  is  documented, an
attempt should be made  to identify a source in the area
which has caused or contributed to the plume.  If hazardous
substances  in the plume can be attributed to a specific
source in the vicinity, the actual plume is not considered the
source. In this case, the identified source of the plume is
evaluated as the source and the plume is considered an
observed release attributable to that source.

The  source of ground water contamination  can be
designated  as unidentified if, within the context  of an
expanded site investigation (ESI) or equivalent effort which
involves sampling, the original source of the ground water
contamination has not been documented. The ESI should
at least include a site reconnaissance in the vicinity of the
observed release samples,  record  searches, employee
interviews,  and sampling for information on possible
origins of the ground water contamination. The attempt to
identify a  source  should be  discussed  in the  HRS
documentation record and potential sources and potentially
responsible parties should be identified.
                     EXHIBIT 1
       UNIDENTIFIED VS. UNALLOCATED
                     SOURCES
       Under the HRS, the terms unidentified and
       unallocated are not equivalent.

       •    An unidentified source is an example of
            the HRS source type "other."  A source
            may be classified as unidentified when a
            contaminated ground water plume  or
            surface water sediment  contamination
            exists,  but  the  original  source  of
            contamination is unknown and cannot be
            identified through the appropriate means.

       •    An unallocated  source  is not  an  HRS
            source type.  Unallocated sources are
            used to account for the hazardous waste
            quantity at a site where the hazardous
            substances cannot be associated with a
            specific source.  A ground water plume
            should not be considered an unallocated
            source.

       Source: The Hazard Ranking System guidance
       Manual, Interim Final, OSWER Publication
       9345.1-07,1992.
After the source  of contamination  is  designated  as
unidentified, the source for HRS scoring is classified as
"ground water plume with no identified source."   The
ground water plume should be evaluated as the source with
an HRS source type of "other."  Once the ground water
plume has been established as a source, the extent of the
plume is generally considered as the extent of the site. An

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unidentified source should  not  be confused  with  an
unallocated source (refer to Exhibit 1).

In summary, make note of the following points before
evaluating a ground water plume as a source:

•    The area of known ground water contamination has
     been established by sampling or inference using the
     observed release criteria outlined in Section 2.3 of the
     HRS.

•    A reasonable search for potential sources of ground
     water contamination indicates that no definite source
     of ground water contamination has been identified
     (the level of effort to identify the original source
     should be equivalent to an ESI).

HRS SCORING CONSIDERATIONS OF GROUND
WATER PLUMES AS SOURCES

As for any site, an HRS score is calculated for the ground
water pathway for each aquifer at or below the source at the
site or, in this case, the contaminated ground water plume.
Assign the highest ground water  migration score for an
aquifer as the ground water migration pathway score for the
site. In general, the aquifer in which the ground water
plume has been  identified will  score  higher  than  an
underlying aquifer evaluated for potential release, except
when  the  underlying   aquifer  is  associated  with  a
significantly larger target population.   Then the target
factor category value must be sufficient to compensate for
the lower likelihood of release factor category value.

Evaluating Likelihood of Release
The likelihood of release factor category  reflects either an
observed release to an aquifer or the potential to release to
an aquifer. The presence of a ground water plume with
contaminant levels significantly above background in an
aquifer constitutes an observed release to that aquifer.

Documenting  the presence of a ground water plume
involves  establishing an observed release  by chemical
analysis.  Establishing an observed release by chemical
analysis requires documenting that the concentration of at
least one hazardous substance in the ground water plume is
significantly  increased  above  its  background  level.
Background samples should be selected to demonstrate that
the release cannot reasonably be attributed to any known
source. As stated in the HRS, to establish an observed
release by chemical analysis at a ground water plume site,
no separate attribution is required. As discussed below,
only those substances identified as being in the plume are
used in selecting toxicity and mobility values.
Data presented  in  the  HRS documentation  record  to
characterize a contaminated ground water plume should be
of  known  and  documented  quality.    Well  siting,
installation, completion, and  development  should be
performed according to protocols specified in EPA ground
water monitoring guidance, in particular, The Hazard
Ranking  System  Guidance Manual,  Interim  Final,
OSWER Publication 9345.1-07 (1992).  In addition, all
guidelines  specified in  the guidance manual regarding
similarity of background and observed release samples
should be  met.  For example,  Section 5.2 of the HRS
Guidance  Manual, Selecting Appropriate Background
Samples,  states  that  background and  release samples
should be representative of the same portion of the aquifer
that is being evaluated (see HRS Guidance Manual, page
67). Once an observed release has  been established by
chemical analysis, the analytical data  used to associate the
hazardous substances with the plume may also be used to
define the extent of the source and the  site for HRS scoring.

As discussed in Section 7.1 of the HRS Guidance Manual,
Determining Aquifer Boundaries and Number of Aquifers,
with multiple aquifers, determining  the potential for the
release to migrate to an underlying  aquifer may also be
necessary.  In this case, the contaminated ground water
plume is evaluated for each of the four potential to release
factors (containment, net precipitation, depth to aquifer,
and travel time), as for any other source.

Evaluating Waste Characteristics
At  a contaminated  ground water plume  site with no
identified  source,  hazardous  substances eligible for
consideration  in   determining  the  pathway  waste
characteristics factor category value are those that meet the
observed release criteria.  Mobility and toxicity should be
evaluated for all observed release hazardous substances in
the ground water plume.

In  evaluating ground water mobility,  any  hazardous
substance meeting the criteria of an  observed release by
chemical analysis to an  aquifer underlying a source  is
assigned a mobility  factor value of one (1), regardless of
the aquifer being evaluated.  Therefore, a mobility factor
value of one (1) is assigned to any hazardous substance in
the ground water plume that is used to characterize the
contaminated plume (i.e., all substances that meet observed
release criteria).

As the extent of ground water plumes are not completely
characterized during  the site investigation  process,  a
definitive hazardous waste quantity cannot be adequately
determined at the listing stage. When evaluating the
hazardous waste quantity at sites consisting solely of a

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ground water plume, only three of the four hazardous waste
quantity tiers apply to the source: hazardous constituent
quantity (tier A); hazardous wastestream quantity (tier B);
and volume (tier C). The area measure (tier D) cannot be
evaluated because the hazardous waste quantity table (HRS
Table 2-5) does not provide a divisor for  source type
"other" in this tier.

Further considerations may restrict the application of tiers
A and B. Tier B wastestream data, for example, is unlikely
because its availability would imply some knowledge of an
originating source of contaminants in the plume.  If such
information is available, the originating source should be
evaluated rather than the plume. Tier A is to be used only
when the mass of CERCLA hazardous substances "is
known or is estimated with reasonable confidence."  Given
the inherent uncertainty in establishing the extent of ground
water plume sites, it is unlikely that sufficient analytical
data will be available to characterize most such sites to this
degree.

While data for tiers A and B may be available, it is more
likely that the volume tier will be the best available means
of evaluating the source hazardous waste  quantity.  For
HRS purposes, the area! and vertical extent of the plume as
delineated by ground water samples that meet observed
release criteria should be used in evaluating the volume
measure.  Therefore, the hazardous waste quantity for a
plume site with no identified source can be determined by
measuring the area within all observed release samples with
the vertical extent of contamination, to arrive at an estimate
of the plume volume.

If the volume of the plume cannot be determined or if it is
not cost effective to do so, a volume of greater than zero
cubic yards can  be used if it is explained that the presence
of contaminants in the plume demonstrates the presence of
some unknown quantity. In this case, minimum hazardous
waste quantity factor values may be assigned. The HRS
specifies that if the hazardous constituent quantity is not
adequately determined, and if any target is subject to Level
I or Level n concentrations, assign a value of 100 as the
minimum pathway hazardous waste quantity factor value.
If none of the targets are subject  to Level I or Level II
concentrations,  assign  a minimum value of 10  as the
pathway hazardous waste quantity factor value, if the
hazardous  constituent  quantity  cannot  be adequately
determined (55 FR 51587,  December 14, 1990). If the
plume is established exclusively with contaminated wells
that are not associated with target populations, additional
sampling may be advisable to determine whether the extent
of contamination can be expanded to encompass target
wells. The objective is to characterize the threat posed by
the plume as thoroughly as possible within the limited
context of an expanded site inspection.  The need for
additional  sampling  will  depend  on  other  waste
characteristics factor values (i.e., toxicity) and the number
of targets involved.

Evaluating Targets
As with all sites, evaluate targets for ground water plumes
based on nearest well, actual and potential contamination
of the population, resources, and wellhead protection areas.
The following are specific factors  that  should  be
considered at sites when a ground water plume with no
identified source is evaluated:

     Ground Water Target Distance Limit
     The 4-mile target distance limit and associated
     distance rings should be measured from the
     geometric center of the area of observed ground
     water   contamination.     The   area   of
     contamination should be based on samples that
     meet observed release criteria.

     Establishing Actual Contamination
     Actual contamination is established for  drinking
     water  wells that  meet  observed release criteria.
     Evaluate other drinking water wells within the 4-mile
     target limit, including those within the area of the
     plume that do not meet the observed release criteria,
     under potential contamination.  If a drinking water
     well has been closed due to contamination from the
     plume being  evaluated, classify the pre-closure
     population associated with the well as subject  to
     actual contamination. Actual contamination cannot
     be inferred for drinking water wells that are screened
     within the dimensions of the plume. If none of the
     drinking  water  wells  are   subject  to  actual
     contamination, select  a nearest well factor value
     based on the shortest distance to any drinking water
     well, as measured from the geometric center of the
     ground water plume (55 FR 51587, December 14,
      1990).

 QUESTIONS AND ANSWERS

 Q: Can a contaminated ground water plume formed by
     the drainage of leachate from a  landfill be evaluated
     as the source at a site?

 A: If the contaminants in the plume can be attributed to
     the landfill, the plume should not be scored as the
     source. In this case, the source at the site should be
     classified as a landfill.

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Q:  If we have data on one or two likely sources, but
    information shows there are other likely sources as
    well, can we list the site as a ground water plume?

A:  Yes. The issue is attribution. If data are available
    that allow definite attribution of contaminants to a
    particular source, that source should be evaluated
    independently. If attribution is not possible, the site
    can be scored as a plume.

Q:  If a ground water plume is conclusively determined
    to be coming from one large facility that has a single
    owner, but the exact source of the contamination is
    not known, should  the plume be considered the
    source?

A:  If the proper effort to  identify  a source  is
    unsuccessful  at the site,  then  the scorer should
    consider evaluating the facility as the source under
    HRS source type "other." This may be done when
    contamination  is attributed  to  operations  or
    processes at the facility but not to a specific source.

Q:  If two  distinct  ground  water plumes  with no
    identified source commingle and one of the plumes
    consists of petroleum products and the other contains
    CERCLA eligible hazardous substances, can the
    release be listed on the NPL?

A:  The release of any CERCLA  eligible hazardous
    substance may be listed on the NPL  Petroleum
    products may not be used in scoring under the HRS.
Q:  If a ground water plume with no apparent identified
    source is documented, but soil-gas samples show
    contamination at a nearby  area  with the same
    substances,  should the contaminated  soil or the
    plume be evaluated as the source?

A:  Since soil-gas data do  not establish  actual soil
    contamination or ground water contamination at a
    site, the contaminated ground water plume can be
    considered a source if observed release samples are
    available and there is no other information to link
    the plume with the soil-gas samples. The soil-gas
    samples, however, should be further investigated to
    determine if such a linkage exists.

Q.  Do  site  boundaries  correspond  to  property
    boundaries at ground water plume sites?

A.  No.  Ground water plume sites are defined by the
    locations of wells showing elevated concentrations
    of CERCLA hazardous substances.  All substances
    considered to be present in the plume must meet
    HRS observed release criteria.

Q.  Does site name imply the extent of the site or identify
    responsible parties?

A.  Not for ground water plume sites. In most cases, the
    name assigned to such sites will be  that of a
    geographic location. Depending on what is known
    about the plume,  the name  selected should be
    specific enough to indicate the general area of the
    plume but broad enough so as not to appear to
    suggest any particular source.

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U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Float
Chicago, tl  60504-3590

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