October 1988

        TASK FORCE
        1987 Status Report
        1988/1989 Program Recommendations
        U.S. Environmental Protection Agency

        OSWER, Office of Program Management & Technology

October 1988

1987 Status Report
1988/1989 Program Recommendations
U.S. Environmental Protection Agency

OSWER, Office of Program Management & Technology

                         .^1 Protection Agency

                             TABLE OF CONTENTS
Chapter 1:  Introduction 	     1-1

     1.1  Background 	     1-1
     1.2  Task Force Mission and Strategy 	     1-2
          1.2.1  Compliance Evaluation 	     1-2
          1.2.2  Operations Assessment 	     1-2
     1.3  Organization of the Report 	     1-3

Chapter 2:  Facility Investigations 	     2-1

     2.1  Procedures for Facility Inspections 	     2-1
          2.1.1  The Facility Inspection Team 	     2-1
          2.1.2  The Facility Investigation and Analysis Procedures     2-2
     2.2  Technical Findings from the Facility Investigations 	     2-6
          2.2.1  Hydrogeologic Site Characterization 	     2-6
          2.2.2  Monitoring Well Location and Construction 	     2-7
          2.2.3  Sampling and Analysis 	     2-9
          2.2.4  Definition of Contaminated Plume and Corrective
                 Action 	     2-10
          2.2.5  Conclusions 	     2-12

Chapter 3:  Regional Infrastructure Assessment 	     3-1

     3.1  Project Goals and Review of Findings 	     3-1
     3.2  Personnel 	     3-2
          3.2.1  Issues and Observations	     3-2
          3.2.2  Recommendations 	     3-4
          3.3.3  Current Status 	     3-4
     3.3  Resource Utilization 	     3-4
          3.3.1  Issues and Observations 	     3-4
          3.3.2  Recommendations 	     3-5
          3.3.3  Current Status 	     3-5
     3.4  Communication and Coordination 	     3-6
          3.4.1  Issues and Observations 	     3-6
          3.4.2  Recommendations 	     3-7
          3.4.3  Current Status 	     3-7
     3.5  Information Management 	     3-8
          3.5.1  Issues and Observations 	     3-8
          3.5.2  Recommendations 	     3-9
          3.5.3  Current Status 	     3-10

Chapter 4:  FY88/89 Ground-Water Program Recommendations 	     4-1

     4.1  Recommendation 1:  Establish Ground-Water Technical
          Assistance Program 	     4-3
     4.2  Recommendation 2:  Improve Ground-Water Information Systems   4-4
          4.2.1  Cooperate with the OGWP/OIPM Data Management Process   4-4
          4.2.2  Develop Data Quality Objectives and Standards ....     4-5
          4.2.3  Develop and Implement the EASI-GW Workstation ....     4-5
     4.3  Recommendation 3:  Improve Ground-Water Training and Guidance 4-6
          4.3.1  Recent Efforts in Ground-Water Training and Guidance   ^-6
          4.3.2  Training and Guidance Recommendations 	    4 - 7


                              REFERENCE LIST

1.   HWGWTF,1 Facility Assessment Program Plan, October 1, 1985.

2.   HWGWTF, Ground-Water Task Force Operations Assessment Report,
     Operations Assessment Group, January 25, 1986.

3.   HWGWTF, Protocol For Ground-Water Evaluation, September 1986.

4.   HWGWTF, Quality Assurance Project Plan, September 12, 1986.

5.   HWGWTF, Regional Infrastructure Assessment, September 1987.

6.   Office of Waste Programs Enforcement, Resource Conservation and
     Recovery Act (RCRA) Ground-Water Monitoring Technical Enforcement
     Guidance Document, (commonly referred to as the TEGD),  September 1986,

7.   Office of Waste Programs Enforcement, Comprehensive Ground-Water
     Monitoring Evaluation (CMS) Guidance Document. December 1986.

8.   Office of Ground-Water Protection and Office of Information Resource
     Management, Ground-Water Data Requirements Analyses. May 1987.

9.   Ground-Water Workstation User's Manual, (undated).

10.  McGraw, memorandum to Division Directors, November 22,  1985.

11.  Skinner, memorandum to Division Directors, September 24, 1984.

12.  Stephen R. Wassersug, "Hydrogeologists Efforts on Recruitment/
     Training," memorandum to James Barnes, July 5, 1985.
     1 All of the HWGWTF reports are referenced throughout the
1987 Status Report and have been submitted as separate documents.  These
documents are available from the Office of Solid Waste and Emergency

                                 CHAPTER 1


     Subtitle C of the Resource Conservation and Recovery Act (RCRA) created
a "cradle-to-grave" management system to ensure that hazardous wastes are
transported, treated, stored, and disposed of in a manner that ensures the
protection of human health and the environment.  Since the passage of RCRA,
the Environmental Protection Agency (EPA) has codified extensive regulations
under 40 CFR Parts 264 and 265 imposing a variety of administrative and
technical requirements on owners and operators of hazardous waste
facilities.  These requirements are intended to minimize the release of
hazardous waste into the environment.

     An essential component of EPA's hazardous waste program is the Subpart
F ground-water monitoring requirements.  Ground-water monitoring is required
only of owners or operators of surface impoundments, landfills, land
treatment facilities, and certain waste piles used to manage hazardous -
waste.  The purpose of these requirements is to assess the impact of land
treatment or disposal facilities on ground water beneath the facilities.
Monitoring must be conducted for the life of the facilities, and land
disposal facilities must continue monitoring for up to thirty years
following closure.

     Complying with ground-water monitoring regulations is the most reliable
method by which an owner or operator can' determine if a land disposal
facility is leaking into and contaminating ground water.  The importance of
such monitoring cannot be overstated, as the volume and toxicity of disposed
wastes pose an enormous threat to the nation's ground-water supply.
Additionally,  in recent years wastes and waste residues from numerous CERCLA
clean-up actions have been designated for disposal at operating RCRA land
disposal facilities.  Only by accurately determining whether these
facilities are adequately protective of ground water can the Agency ensure
that it will not be necessary to transfer these wastes again in the future
at a significantly greater cost.  More important, a failure on the part of
the regulated community to comply with the Subpart F standards could lead to
ground-water contamination and threaten human health and the environment.

     Following the promulgation of ground-water protection standards in May
1980, it became clear that many land disposal facilities had not fully
complied with the ground-water monitoring requirements.  Inspections
conducted by the Agency revealed that some facilities had not installed
adequate ground-water monitoring systems, and EPA surveys demonstrated that
the regulated community needed additional technical assistance to achieve
full compliance.


     Cognizant of the importance of ground-water monitoring to the overall
success of the hazardous waste management program, the Administrator
established the Hazardous Waste Ground Water Task Force in'Fall 1984.  The
Task Force was charged with two major efforts:  (1) evaluating the level of
compliance with ground-water monitoring regulations at hazardous waste
disposal facilities; and (2) assessing the ability of EPA and States to
implement and enforce the ground-water monitoring standards.  These efforts
were undertaken over a three-year period.  The activities composing each of
these efforts are discussed below.
     1.2.1  Compliance Evaluation

     To accomplish this goal, the Task Force established a joint Regional,
State and Headquarters facility evaluation team to determine the status of
ground-water monitoring at operating RCRA hazardous waste facilities.  This
team was also directed to develop recommendations to correct any problems
discovered.  Specifically, the inspection team evaluated 58 commercial and
private land disposal facilities for compliance with the Subpart F standards
and potential compliance with Parts 264/270.  The team also investigated for
ground-water contamination and other monitoring system deficiencies.

     The Hazardous Waste Ground Water Task Force ceased activities as an
OSWER-program function on September 30, 1987.  Taking into consideration the
one-year phased process time to complete a facility investigation, the Task
Force completed all phases of work at 24 sites.  Work on the remaining 34
sites was transferred to the Office of Waste Programs Enforcement (OWPE).
OWPE completed these sites by the third quarter of FY 88.  The results of
the Task Force evaluation of the 24 sites are discussed in Chapter 2 of this
     1.2.2  Operations Assessment

     The Task Force conducted an operations assessment of EPA and State
ground-water monitoring programs to identify problems inhibiting the ability
of both EPA and States to implement and enforce the Subpart F rule.  The
assessment evaluated existing and planned training, guidance, regulatory,
and research programs in order to identify significant problems (e.g.,
consistency) and additional needs.  In addition, the study evaluated the
organizational infrastructure which support ground-water decisions at
Headquarters and in the Regions to identify areas that must be improved to
ensure the efficient implementation and enforcement of ground-water
monitoring standards.  With the exception of the Regional infrastructure
review, the results of this effort were submitted in a January 25, 1986
report to the Assistant Administrator for the Office of Solid Waste and
Emergency Response (Operations Assessment Group Task Force Report).  On
April 20, 1986, the Assistant Administrator adopted twenty of the
recommendations contained therein.  The results of the Regional

infrastructure review are discussed in Chapter 3 of this report.


     The remainder of the Hazardous Waste Ground Water Task Force 1987
Status Report is organized as follows:

     Chapter 2:  Facility Investigations.  This chapter outlines the
     procedures the Task Force used for the facility investigations.  In
     addition, it presents weaknesses under each of four technical areas,
     briefly presents Task Force recommendations to improve performance,
     highlights steps EPA has already taken to improve compliance, and
     describes current status of ground-water monitoring at the facilities

     Chapter 3:  Regional Infrastructure Assessment.  This chapter examines
     four aspects of Regional ground-water program infrastructure, including
     personnel, resource utilization, communications and coordination, and
     information management.  In addition, it presents problems with this
     infrastructure,  recommendations to improve Regional performance, and
     current status of Regional programs.

     Chapter 4:  FT 88/89 Ground-Water Program Recommendations.,  This
     chapter outlines three recommendations to improve implementation and
     enforcement of ground-water monitoring requirements.  These
     recommendations include modifying the Ground-Water Technical Assistance
     program,  improving the Ground-Water Information Systems, and improving
     ground-water training.

                                  CHAPTER 2

                           FACILITY INVESTIGATIONS
     During the field investigation phase of its activities, the Task Force
mission was to determine the level of compliance with ground-water monitoring
regulations.  Field investigations were conducted at 58 hazardous waste
facilities selected to represent the total universe of land disposal
facilities in the United States.  All ten Regions and each of the 50 States
were represented in this sample.

     The Task Force completed 24 of the 58 facility investigations.  Work on
the remaining 34 sites was transferred to OVFE.  The Task Force does not
believe that the results of the remaining investigations will alter the
picture we now have of the level of compliance and the nature of non-
compliance.  In this chapter, the procedures used to conduct facility
investigations and the Task Force's major findings are presented.


     In this section, the components of the facility investigation team and
the procedures used during the facility investigation phase of the Task
Force's activities are discussed.

     2.1.1  The Facility Investigation Team

     For each of the 58 facilities examined by the Task Force, an
investigation team reviewed available information, conducted field
inspections, performed sampling and analysis, and evaluated compliance with
ground-water monitoring requirements.  In most cases, the team included field
inspectors, permit writers, enforcement staff, legal counsel, sampling and
analytical personnel.  In addition, each inspection team was composed of
experts from the State and Region in which the facility was located and a
Core Team member (see below).  All decisions made by the inspection teams
were reached by consensus between the State, Regional and Core Team members.

     The Core Team was the headquarters-managed component of the Task Force's
field evaluation effort.   The Core Team was composed of investigators with
significant hydrogeologic training and extensive field experience and were
selected from the technical staffs of Headquarters, the Regions, and the
States.  The Core Team's weekly and quarterly meetings, as well as the
individual Task Force investigations, provided an ample opportunity for
information exchange; as a result, the Core Team's activities allowed the
Task Force to develop a comprehensive picture of the national state of
ground-water monitoring under the RCRA program.

     The Core Team organized individual facility assessments based upon EPA-
developed guidance and protocols, including the Technical Enforcement
Guidance Document and the Comprehensive Monitoring Evaluation.  In addition.

the Core Team served to:

     •  Ensure consistency and uniformity in the facility evaluation effort;

     •  Accumulate, on a nationwide basis, information concerning safe land
        disposal sites for Superfund wastes;

     •  Identify and evaluate problems encountered in the field, and direct
        the further development of guidance, training, regulation, and
        research programs;

     •  Provide a vehicle for technology transfer and training among Regions
        and States; and

     •  Provide contractor and organizational support to the program, and
        develop work plans, checklists, communications plans and other tools
        to assure smooth functioning of the effort.

     The National Enforcement Investigation Center (NEIC) also provided
valuable support to the Task Force's field investigation activities.  The
NEIC inspected the first facility in each Region.  This approach ensured
intra-Regional consistency by bringing a single team to the first evaluation
in each Region.  NEIC also used its extensive experience in conducting
investigations of this type to assist the Core Team's development of
protocols and standard operating procedures.

     2.1.2  Facility Investigation and Analysis Procedures

   •  The Task Force took great care to ensure the consistency and quality of
the facility investigation and analysis effort.  The NEIC's activities in
this regard are discussed above.  In addition, the Task Force developed a
program plan to coordinate the wide variety of activities associated with
this effort.  This program plan established a series of six steps that the
Task Force followed in evaluating specific sites.  An outline of the plan

     Step 1:  Planning and Protocol Development.  Before commencing facility
evaluation work, the Core Team, with the assistance of the NEIC, developed
plans, strategies, and protocols to ensure that Task Force activities were
consistent, well reasoned, and properly coordinated.  These activities
included the following preliminary work:

     •  Field inspection protocols.  The Core Team developed field inspection
        protocols, including entry plans, inspection standard operating
        procedures (SOPs), sampling protocols, chain-of-custody procedures,
        QA/QC procedures, and document control SOPs.

     •  Safety training.  The Core Team ensured that field staff obtained the
        proper safety training certification.

     •  Sampling contract.  The Core Team procured a sampling contractor,

        which ensured consistency by conducting sampling and providing
        necessary sampling equipment and glassware at all sites.

        Laboratory capacity.  The Core Team contracted reference
        laboratories, and evaluated them for RCRA methods.
              iications Strategy.  The Core Team developed a communications
        strategy for both the press and to handle community relations.  Since
        Regional communications staff implemented the strategy, specific
        plans were tailored to local situations.

     •  Technical Advisory Panel.  The Core Team assembled a team of experts
        with national stature to provide prompt advice and review on
        technical aspects of the investigation.

     •  Aerial photography.   The Core Team collected historic work-ups of
        aerial photos to establish the location of old units and glean other
        valuable site information.

     Step 2:  Data Procurement.  A contractor, under the direction of the
Core Team, collected all existing background information on each facility.
This work took approximately six weeks per site.  The following protocol
guided work at each site:

     •  Preliminary meeting.  Personnel from the Core Team, Region, and
        contractor attended a preliminary meeting, at the Regional office to
        confirm the location of relevant information (including aerial photo
        work-ups),  logistics for data gathering, and the CBI/sensitivity
        clearance status of Regional and State personnel.  These personnel
        also determined the need to obtain additional information from the
        owner or operator.   In addition, the preliminary meeting established
        the composition of the following components of the Regional team:

             The field inspection team (a small group) that would continue
             and complete facility evaluations after Core Team/NEIC
             involvement ceased; and

             The document control officer who coordinated activities
             regarding Toxic Substances Control Act (TSCA) confidential

     •  Record search by contractor.  The contractor then gathered relevant
        information with support from Regional personnel.  The Regions
        assisted this effort either by accompanying the contractor during the
        record search or by making preliminary calls to facilitate access at
        appropriate program offices.  In most cases, the contractor searched
        the following sources of information:  (1) Regional Office (RO)
        permit files; (2) RO enforcement/compliance files; (3) Headquarters'
        enforcement and compliance files,  if useful; (4) RO State
        implementation files;  (5) Environmental Services Division (ESD)
        files; (6)  State files, if useful;  and (7) on-site records of the
        facility (e.g.,  well logs and QA/QC data), if useful.

     •  Information management.  The contractor organized, copied, and
        forwarded these records to the Regional Office, State, NEIC,  and Core
        Team Document Control Officers.

     •  Communications plan.  The Task Force Communications Coordinator
        developed a facility-specific communications plan after consulting
        with the Regional Team leader and Regional communications (press and
        community relations) staff.

     Step 3:  Data Analysis.  After collecting background information on the
facility,  the Task Force analyzed the data and planned a site visit.   This
step involved the following tasks:

     •  Data evaluation.  One or more staff members from each of the
        participating groups (i.e., Region, State, NEIC, and Core Team)
        conducted an in-depth evaluation of the material gathered by  the
        contractor.   Members from each group then prepared notes regarding
        the following issues:

          -  possible areas of noncompliance with Subpart F requirements;

          -  possible existence and nature of ground-water contamination;

             other potential shortcomings in ground-water monitoring  system
             design and operation;

          -  validity and comprehensiveness of existing data; and

          -  activities that would be useful during the site inspection.

     •  Project inspection plan.   The NEIC (for the first facility in each
        Region) or the Region then developed a project plan for the facility
        inspection.   Such a plan determined the date and the objectives of
        the facility visit.   These objectives included, but were not
        necessarily  limited to:

             observing the owner/operator's sampling techniques;

             taking  samples;

             determining whether information submitted by the owner/operator
             is valid;  and

          -  closing information gaps identified during the record search.

     •  Redrafting the project plan.   Each group presented comments on the
        proposed project plan to NEIC or the Region,  as appropriate.   NEIC or
        the Region then issued a second draft.

     •  Consensus meeting.   A small group (maximum of two personnel from each
        participating group)  of team leaders and managers met at the  Regional


        office to resolve  remaining differences,  set  schedules, designate
        site visit  team members,  and provide  direction  for  finalizing  the
        project plan.

      Step 4:  Site  Inspection.   In most cases,  the  inspection team conducted
 the  facility inspection within a few weeks  of the Step  3 consensus meeting.
 The  Regional team leader scheduled the site visit and coordinated activities
 with all participants, including the facility owner or  operator, NEIC, Core
 Team members, State personnel, and contractors.   The  following protocol was
 followed during facility inspections:

      •  Inspection plan.   The field team conducted  the  site visit in
        accordance with the inspection plan,  and  used contractor support to
        manage s amp1es.

      •  Sampling and Analysis.  A contractor  managed  the packaging and
        distribution of samples.  All samples were  submitted to the Contract
        Laboratory Program laboratory for analyses  and  were occasionally
        split with the Regional  Environmental Services  Division (BSD)
        laboratory for quality control.  The  inspection team made an offer to
        split samples with the owner or operator's  laboratory and the  State
        laboratory.  Duplicates,  spikes and blanks  were also distributed.

      •  Consensus development.   Immediately following the facility visit, the
        inspection team met on a  daily basis  to compare inspection logs and
        reach a consensus  on the  team's findings.   Consensus was reached on
        the following:

             layout of the facility and surrounding area;

             observations  and evaluation of the sampling and analytical
             protocols used by the owner or operator;

          -  decisions concerning the adequacy of well  placement and other
             aspects of the ground-water monitoring system; and

          -  Judgements concerning whether  the owner  or operator was
             following the procedures established in  his assessment plan,
             where applicable.

     Step 5:  Technical Report.   After the  facility visit, the on-site
coordinator (NEIC or Region) drafted a facility evaluation report containing:

     •  observations and findings from the  data review  and on-site
        inspection;  and

     •  conclusions regarding regulatory compliance and probable nature and
        level of ground-water contamination.

     All regulatory groups involved with the  inspection reviewed the draft
report,  after which the technical staff met to present  comments and reach a
consensus.   NEIC or the Region revised the  report accordingly and issued a

second draft.  The Regional team leader then scheduled a technical consensus
nesting to discuss problems that arose during the evaluation.  Finally, SEIC
or the Region finalized the report in accordance with decisions reached at
this meeting.

     Seep 6:  Follow-up.  The Regional team leader arranged a management
consensus meeting of team leaders and managers to discuss appropriate
actions, develop a schedule for action, and determine which personnel would
take the lead on problems identified in the technical report.  The Regional
Office or State (as appropriate) then drafted orders or permit conditions, or
took other actions in accordance with their normal responsibilities.


     During its investigations, the Task Force found that nationwide
compliance with ground-water monitoring regulations can be hindered by
several problems resulting from poor facility management and faulty
laboratory methods.  In general, the deficiencies are related to che
following technical areas:

     •  hydrogeologic site characterization;

     •  monitoring well location and construction;

     •  sampling and analysis; and

     •  contaminant plume definition and corrective action.

   ,  This section considers each of the technical areas separately.  First,
it summarizes the findings of the Task Force investigation, identifying the
most prevalent weaknesses under each program area.  In addition, it presents
the Task Force recommendations to improve performance under each technical
area, and highlights the steps EPA has taken to implement the
recommendations.  Finally, this section briefly describes the current
compliance status under each technical area, and notes any improvements made
since the initial investigation.

     2.2.1  Hydrogeologic Site Characterization

     Proper design of a ground-water monitoring program requires that an
owner or operator describe a complete and accurate hydrogeologic
characterization of the site.   Defining hydrogeology is an iterative process
that requires a series of data collection efforts and analytical studies; the
result of one study guides the direction of the next and the result of each
study complements the previous one.

     In general, an adequate hydrogeologic characterization identifies
geologic and structural formations, soil and ground-water constituents,
information on the number and location of the different water-bearing zones.
the depth to ground water, and the direction and velocity of ground-water

flow.  The hydrogeologic  characterization  is  singularly  the most  important
aspecc of a ground-water  program because all  other components of  the program
(e.g., well location,  density,  construction,  capability  of detection, and
plume assessment  and cleanup  programs)  depend on  it.  Where site  hydrogeology
is not adequately characterized, facilities cannot monitor all potential
contamination pathways, and releases  from  disposal units may remain

     •  Task Force Findings.  The Task  Force  found that  of the 24 facilities
        for which it has  completed  its  investigation, none had performed an
        adequate  initial  hydrogeologic  characterization.  The most coaoon
        reason for this was a failure to obtain enough data to make accurate
        hydrogeologic  characterizations.   For example, some facilities did
        not conduct enough  exploratory  borings or monitor enough  piezoaeters.
        At times,  valuable  information  was lost or never obtained owing to
        incomplete and poorly maintained boring logs.  Since many
        hydrogeologic  characterizations were  conducted over five  years ago,
        the Task  Force was  unable to  locate original consultants  to explain
        how they  arrived  at their conclusions.

             However,  at  the  time of  the investigation,  almost every facility
        was in the process  of upgrading its hydrogeologic site
        characterization  in response  to an enforcement action by  the
        implementing agency.  Some  facilities were conducting their third
        hydrogeologic  investigation,  which is not uncommon.  In addition,
        some facilities were  in 'the final  stages  of hydrogeologic
        characterization, close to permit  issuance; others were beginning
        detailed  comprehensive  investigations that may last 2 to  3 years.

    ^ •  Task Force  Recommendations and  EPA Follow-up.  The Task Force
        recommendations included in each site-specific report were, in most
        cases, the  addition of  field  data  (borings, well samples, etc.) or a
        clarification  of  the  interpretation of existing  data.  In many cases,
        conclusions reached by  the Task Force served to  settle long-standing
        disputes  between  facility experts and the regulatory agency.  Task
        Force recommendations were  incorporated in proposed enforcement
        actions,  formed the basis for new enforcement actions, or, in some
        cases, were used  to modify an existing state permit.

     •  Current Compliance  Status.  The Agency found that facilities enhanced
        their efforts  after the implementing  agency took further  enforcement
        actions pursuant  to Task Force  recommendations.  The facilities'
        responses  to these  actions were generally adequate; consequently, the
        Regions report that most of the 24 facilities are now in  compliance
        with the  hydrogeologic  characterization requirements.

     2.2.2  Monitoring Veil Location  and Construction

     Proper location of ground-water  monitoring wells is also an  essential
component of an effective ground-water  monitoring and remediation program.
To ensure that contamination  is detected as soon as practical, an owner or

operator and implementing agency must have the ability to compare background
ground-water quality (i.e., ground water unaffected by contaaiiiants from the
facility) with ground-water quality in aquifers affected by leaks from the
facility.  This comparison requires that monitoring wells measuring
background quality be located upgradient from the facility in an area
unaffected by the facility.  In addition, owners or operators should locate
monitoring wells assessing ground water contaminated by the facility in areas
downgradient from the facility, with each well installed within the same
discrete aquifer.  Owners or operators must also ensure that wells do not
provide a conduit for cross contamination between different aquifers.

     Proper well construction is equally important.  Veils must be
constructed with sand and gravel packs of appropriate length and screen slots
of appropriate size.  In addition, owners or operators should install annular
seals between aquifers to prevent cross contamination.

     •  Task Force Findings.  All 24 facilities had some defects in either
        the construction or location of their monitoring wells.  The Task
        Force found that wells at some facilities were not located close
        enough to the point of compliance to immediately detect contamination
        at the waste management area.  Monitoring wells were located hundreds
        or, in one case, thousands of feet from the point of compliance.   In
        addition, some monitoring wells were spaced more than 1000 feet from
        each other.   Well spacing of this magnitude could only detect the
        largest contaminant plumes.

             At some facilities, the well designated to monitor background
        ground-water quality was, in fact, not located upgradient in an area
        unaffected by the facility.  Consequently, the samples intended to
        represent background water quality were affected by contaminants from
        the waste management units.  In these situations, statistical
        comparisons between upgradient and downgradient wells are of little
        use.  The inappropriate location of background monitoring wells
        hampered the ground-water monitoring efforts of at least five of the
        facilities evaluated, and was usually the result of an inadequate
        hydrogeologic site characterization.

             In addition, failure to install monitoring wells in correct
        water-bearing zones was a problem:

             -  At least three facilities had repeatedly compared the results
                of samples from wells screened in different water-bearing

                Three other facilities overlooked shallow water-bearing zones
                and instead monitored deeper aquifers.  These shallow zones,
                which the drillers ignored, are thin, and yield little water;
                however, samples from these formations are the first to
                indicate contamination.

                Some facilities had such long screens that they collected
                water from a number of water-bearing zones.  An influx of


                water from other zones dilutes concentrations of
                contaminants, masks the source of contaminants, and provides
                a conduit for cross contamination of the aquifers.

             The Task Force also found that improper well construction
        hampered ground-water monitoring efforts:

                Sand and gravel packs (filter packs) in wells were too long,
                some between 50 to 200 feet.  Excessively long filter packs
                cause the same problems as those caused by excessively long
                well screens:  water from several aquifers is collected,
                contaminants are diluted, and the source of contaminants is

             -  Facilities were not selecting proper well screen slot sizes
                (i.e., based on the grain size of the aquifer and filter
                pack).  Several monitoring wells were found to be constructed
                with certain screen slot sizes and filter packs because "that
                is what the driller always uses."  The Task Force noted that
                proper intake design, a relatively simple technique, should
                be more rigorously practiced by the monitoring well industry.

             -  At least two facilities did not have annular seals between
                aquifers to prevent cross contamination; while others had
                seals that were poorly constructed.

     •  Task Force RecoTrendations and EPA Follow-up.  The Task Force
        recommendations included sealing and abandoning inadequate wells, a
        better identification of upgradient areas and the increased training
        of State and Regional enforcement staff on proper well design,
        installation and maintenance.  The Regions responded by issuing
        enforcement orders or modifying existing orders.  EPA has increased
        field investigation training which includes monitoring well

     •  Current Compliance Status.  Facilities generally responded
        satisfactorily to the enforcement actions.  Many of the cases of non-
        compliance were remediated by the addition of monitoring wells, the
        abandonment of poorly constructed wells, or locating missing drilling
        records.   The Regions now report chat almost all of the 24 facilities
        have approvable monitoring systems.

     2.2.3  Sapling and Analysis

     Sampling and analysis is another major component in any ground-water
monitoring program.  Facilities conducting ground-water assessments must
collect samples in a systematic and precise manner to ensure the validity and
accuracy of data obtained.   Proper sampling procedures require,  among other
things, the collection of blank and duplicate samples and the strict
application of quality assurance/quality control (QA/QC) plans.   Similarly,
appropriate laboratory analysis requires the application of QA/QC procedures

 and  the  use  of spikes and blanks Co verify Che accuracy of data.

      •   Task Force Findings.   The Task Force  found that few of  the
         investigated facilities  strictly adhered to acceptable  sampling  and
         analysis  standards and procedures.  Problems often arose when
         facilities used field procedures that are discouraged in the
         Technical Enforcement Guidance Document (TEGD).   Specifically, the
         Task Force discovered the following:

                Facilities were  not consistently applying established quality
                assurance/quality control (QA/QC) procedures to verify Che
                accuracy of  lab  results.

              -  Facilities did not routinely  obtain blank and duplicate
                samples,  while those facilities that took these samples  did
                not use the  results obtained  from the lab in a  data usability

              -  Facilities that  had written QA/QC plans  were not consistently
                using them.

              -  Some facilities  did not use sampling equipment  dedicated to
                each well or  used impeller  driven pumps  and intermediate
                containers which allow degassing of the  sample.  Other
                facilities filtered all of  their samples.

              In addition,  laboratory audits conducted by the Task Force
         revealed  that some labs  still used  inappropriate test methods.
         Others did not take  into account  the  interferences  from general  water
         chemistry and QA/QC procedures.   Finally,  laboratories  did not always
         use  spikes and blanks  to verify the precision and accuracy of data.

     •   Task Force Rat^pmendations and EPA  Follow-up.   The  Task Force
         recommended that  the Agency take  enforcement actions against  those
         facilities that deviated significantly from standard sampling and
         analysis  procedures.   The Agency  initiated enforcement  actions at
         each facility to  require the upgrading of sampling  and  analysis

     •   Current Compliance Status.   The Regions  now report  that the
         facilities  have resubmitted their sampling and analysis plans, and
         that the  Agency has approved these  plans.   However,  systematic
         laboratory audits  have not been implemented in every Region.  The
         Agency has  continued to  pursue  this issue.

     2.2.4   Definition of Contaminated Plume  and Corrective action

     Before  effectively remediating ground-water contamination,  a facility
must first correctly define the  contaminated  plume.   Plume  definition relies
substantially upon  an accurate hydrogeologic  characterization,  adequate
monitoring wells,   correct  statistical procedures,  as  well as  sound laboratory

procedures.  When a facility completely assesses the nature and extent of a
plume, it can then initiace a comprehensive and technically sound corrective
action.  The basic objective of corrective action is to reduce ground-water
contaminant levels below background or health-based standards.

     •  Task Force Findings.   During its investigation, the Task Force
        discovered that some states are far more advanced in knowledge and
        experience with corrective action than others.   These states, which
        tend to be highly industrialized, quickly recognized and addressed
        ground-water contamination problems.   Some effective and highly
        complex ground-water restoration programs have been in effect since

             The Task Force found, however, that inadequate ground-water
        monitoring efforts at many sites often resulted in unsatisfactory
        plume definition and ground-water remediation efforts.  Facilities
        with ground-water contamination did not adequately assess the nature.
        or extent of the contaminated plume.

                The hydrogeologic characteristics of some sites were not
                adequately described or understood.  Without complete and
                accurate hydrogeologic data,  a facility cannot properly
                design a ground-water monitoring program (see Section 2.2.1).

                Some facilities attempted to define contaminant pluses only
                in terms of their length and width, while ignoring depth.
                The depth of the plume is rarely described because wells were
                poorly constructed and/or poorly sited.

             -  Some facilities did not correctly follow the statistical
                procedures required by the regulations to measure ground-
                water contamination levels.  Other facilities that did follow
                these procedures failed to apply an adequate response to the

             -  Although a number of facilities conducted a plume
                characterization in response to State or Federal enforcement
                action, many of these enforcement efforts needed to be
                improved.  Notices of Deficiency (NOOs) and orders requiring
                an assessment often resulted in contentious discussions
                between the Agency and the facility concerning the extent of
                the required investigation.

             With respect to corrective action, the Task Force found that of
        those facilities that had ground-water contamination, few had active
        ground-water cleanup programs in progress.  In addition, many
        corrective action programs did not meet Subpart F standards under 40
        CFR 264.100.  In some cases, poorly designed or poorly constructed
        monitoring systems were at fault.  Facilities were still in the
        process of assessing the extent of contamination, or, in some cases.
        still installing an adequate detection monitoring system.  The major
        problems with the existing corrective action programs were:

                Faciiicies initiated corrective action without an adequate
                hydrogeologic characterization.

                Some facilities had not thoroughly defined the type of
                contamination through an analysis of Appendix IX compounds
                (see 40 CFR 264, Appendix IX - Ground-Water Monitoring List).

                There was little or no basis for the design of some
                monitoring or remedial response systems.

             -  Some corrective action projects were inadequately supervised.

                Some facilities were attempting to clean up ground water
                containing contaminants for which cleanup levels had not been

                In some cases, the technology necessary to achieve adequate
                removal of certain types of contamination in complex geologic
                settings was unavailable.  For example, dense viscous
                hydrocarbons and low-yielding aquifers pose very difficult
                extraction problems.

        Task Force Reco"»^ypd^tions and EPA Follow-up.  When devising its
        recommendations to the Agency, the Task Force concluded that access
        to a large data base of geologic information and ground-water quality
        is necessary for characterizing contaminant plumes.  In addition, it
        determined that analyzing and interpreting data requires highly
        developed skills and knowledge and demands an extraordinary amount of
        time.   To respond to these needs,- the Task Force developed the
        Ground-Water Computer Workstation, a system designed to provide
        mathematical and graphic aids to facilitate and expedite compiling,
        illustrating, and interpreting data.  In addition, OSWER is currently
        developing proposed rules and amendments designed to provide a
        consistent and practical approach to establishing cleanup levels at
        RCRA facilities.

        Current Compliance Status.  The Agency expects that efforts to define
        plumes and conduct corrective action will improve as hydrogeologic
        characterizations and ground-water monitoring systems improve in
        response to enforcement actions.  It also expects these efforts to
        benefit from the greater use of the Ground-Water Computer
        Workstation, training and increased use of existing ground-water
        models, and the implementation of the new procedures to establish
        cleanup levels.
     2.2.5  Conclusions

     During the field investigation phase of its activities, the Task Force
found that the level of compliance with ground-water monitoring regulations
could be improved.  Facilities had not established adequate ground-water

monitoring programs, owing to incomplete hydrogeologic site
characterizations, improper monitoring well location and construction, and
careless sampling and analysis techniques.  Deficiencies in ground-water
monitoring programs resulted in incorrect plume definition and inadequate
corrective action efforts.

     In response to these problems, the Task Force recommended that the
Agency take several steps for corrective action of facilities that did not
comply with ground-water protection regulations or standard ground-water
monitoring procedures.  The Agency followed through on these recommendations
by enhancing enforcement activities against facilities that were out of
compliance.  Enforcement efforts ensured that facilities were made aware of
program areas that needed improvement and pressured facilities to correct
significant faults in their programs.  In general, enforcement activities
elicited a positive response from facilities, as the Agency noted substantial
improvement in the facilities' ground-water monitoring systems and
remediation efforts.  It is clear that the Task Force investigation and
subsequent response by the Agency and facilities have improved the ground-
water protection systems at these facilities.

     To improve compliance performance on a nationwide basis, the Task Force
believes that the regulatory agencies (Regions and States) must maintain
staffs with enough field experience to detect problems early in the
investigation process.  In many cases, the Task Force's field experience
enabled it to discover the incorrect methods and faulty reasoning that
resulted in ineffective ground-water monitoring, which may have been
overlooked by less experienced staff.

     The Agency is cognizant of these problems, and is examining ways in
which it can improve its role in technical assistance and as coordinator and
enforcer.  To accomplish this goal, the Task Force believes that EPA should
continue efforts to improve training programs for ground-water professionals
and increase the level of technical expertise at the Regional level.  For
instance, EPA recognized that ground-water professionals with adequate field
experience are in great demand, and has responded by developing programs to
train Regional staff in methods and strategies for field investigations.  The
Task Force encourages this training effort, a.nd suggests that each ground-
water professional include as part of his or her individual training program
an opportunity to observe field inspections and subsurface investigations.

     The Agency is further augmenting national compliance by involving
technical staff in quality control reviews of technical aspects of
enforcement decisions.  In addition, the Agency is enhancing its oversight of
enforcement actions to mitigate the need to conduct multiple actions.
(Issues concerning Regional personnel and infrastructure are discussed
further in Chapter 3 of this report.)

                                  CHAPTER 3

     The primary mission of the Hazardous Waste Ground Water Task Force was
to evaluate the level of facility compliance with RCRA-mandated ground-water
monitoring requirements, to determine the probable causes of noncompliance
and to recommend ways to increase the level of compliance.  While the Task
Force field evaluations of hazardous waste facilities addressed many of the
technical issues, which will enable the Agency to create a standard protocol
for use in evaluating a facility's ground-water monitoring program, EPA
recognized that two, non-technical program elements were equally important
for solving the problem of noncompliance:  (1) the elements of the RCRA
ground-water monitoring program itself (e.g., guidance documents, research
and development, training) as well as the EFA-promulgated regulations
pertaining to ground-water monitoring; and (2) the effects of the Agency's
infrastructure on program implementation.  The Task Force addressed RCRA
program content issues in the Operations Assessment Group (OAG) report
completed January 25, 1986.

     This chapter summarizes the results of the Task Force Study of the
Agency's infrastructure2 which focussed on the organizational and operational
aspects of RCRA program implementation.  Specifically, Section 3.1 outlines
the goals and findings of the Infrastructure Assessment project.  Subsequent
sections present the Task Force's findings relating to specific components of
the Agency's infrastructure:  personnel (Section 3.2), resource utilization
(Section 3.3), communication and coordination (Section 3.4), and information
management (Section 3.5).

     The goal of the Infrastructure Assessment project was twofold:  (1) to
identify those aspects of the various Regional programs that are effective in
promoting the successful implementation of the ground-water monitoring
program, and (2) to identify those aspects that seem to impede successful
implementation and to recommend solutions.

     The infrastructure project team consisted of four members of the Task
Force.  With input from EPA headquarters managers, other Task Force Core
Team members, and several Regional RCRA Branch Chiefs, the team drafted a
project plan and questionnaire, which would be used as the vehicle for
gathering information from Regional staff and management.  The questionnaire
focussed on how Regional programs were organized, staff expertise, how
     2 The term "infrastructure," as used in this report, refers to the
organizational framework, including personnel; how information is managed and
communicated; how authority and responsibility are delegated; and how
resources are used.

ground-water-related work was conducted, how data were managed, how
information was communicated, and how responsibilities were delegated within
Regional, State, and Headquarters program offices.  After receiving
additional input from the OSWER Ground-Water Steering Committee, the team
presented the plan to the Regional Hazardous Waste Division Directors in
March 1987.  The final project plan and questionnaire were completed a month
later, and the information-gathering interviews were conducted from May to
the end of August, 1987.

     The results of the study are based on interviews conducted in all ten
Regions.  The interview team usually consisted of Task Force Core Team
members and other Task Force Regional members.  Approximately 150 people were
interviewed, each for about one hour.  Interviewees included RCRA Branch
Chiefs, Section and Unit Chiefs, hydrogeologists and other RCRA staff, and
representatives from Superfund, the Environmental Services Division (ESD),
the Regional Office of Ground Water (OGW), Underground Injection Control
(UIC), and the Office of Regional Counsel (ORC).

     The Task Force found that the organization and operation of each
Regional office is unique and based upon management perceptions of how to
best coordinate the various tasks involved in implementing their ground-water
management programs.  As a result, there are, in effect, ten different
Regional infrastructures.  Nevertheless, the Task Force found that a number
of problems and issues were common to all ten of the Regional offices.  These
problems concern hiring and retaining staff, resource utilization,
communication and coordination, and data management.  These areas were
reported to affect the ability of the Agency and the authorized States to
produce complete and technically accurate work.

   N  The remainder of this chapter presents the findings of the Task Force's
infrastructure study and its recommendations for improving the efficiency of
the ground-water management program.

     3.2.1  Issues and Observations

     Compliance with ground-water monitoring regulations is largely
achieved by meeting the performance standards that EPA developed in response
to RCRA's mandate concerning the protection of ground water.  To enforce the
ground-water monitoring regulations the Agency must have on their staff
personnel who have the technical expertise to judge whether standards are
being met, and if they are not, to assist facilities in achieving the
required performance standards.

     Although Regional staff often consisted of individuals with a wide
variety of geologic experience, few were found to have specific academic or
field experience in the specialty of hydrogeology.  Most Regions reported
that the level of hydrogeologic expertise needed by the Agency was above
entry GS levels.  As a result, some Regions attempt to hire only highly
skilled staff at the upper GS  levels.  Several of the Regions interviewed

have had success in hiring experienced staff.  One Region attracted several
experienced and field-trained geologises and hydrogeologists with 5 to 10
years of well drilling and field mapping work from the U.S. Army Corps of
Engineers (USACOE).  Another Region reported that it had found staff with
experience in drilling wells and conducting pump tests at the U.S. Geological
Survey (USGS).   Two Regions have used information booths at geological
conferences or job fairs to attract job applicants.

     Hiring of the best possible skill mix also has been impeded by the
inability to "direct hire" ground-water specialists.  The Office of Personnel
Management (0PM) registers are often fully subscribed with "geologist," but
it can be difficult to find highly qualified individuals with hydrogeologic
and RCRA skills.  Two Regions have overcome this situation by obtaining
Regional direct-hire authority (as recommended in the Operations Assessment
Group (OAG) report).  Another Region has hired staff first as temporary
employees and later converted them to permanent when permanent positions were

     Hiring qualified staff is not the only problem.  Retaining experienced
hydrogeologists in the RCRA program continues to be a challenge.  Some staff
interviewees reported that when experienced people leave, complex technical
projects are often reassigned to junior-level staff who receive little or no
supervision or guidance from a senior-level hydrogeologist.  Most of the
hydrogeologic staff had only 1 to 3 years of experience.  The interviews
identified two major causes of turnover among technical staff:  low salary
and promotion potential; and lack of opportunity for skills enhancement.

     Nearly all technical staff identified low salary and limited promotion
potential as one of the major issues affecting their decision to stay with
the>RCRA program.   In two of the Regions•staff transferred to the Superfund
program and to the Office of Ground Water, which provided promotions to GS-13
positions.  In each of these cases, GS-13 positions did not exist in the RCRA
program and, in the staff's opinion, the creation of advanced technical
positions in RCRA was not likely to occur.

     Two Regions have pursued the OAG recommendation to create advanced
technical positions in RCRA for a hydrogeologist.  In both cases these
positions were created at the GS-13 level, and in both cases even this
level was insufficient to hold staff for very long.  No Region has created
technical track career ladders equivalent to middle and upper management
grades.   Several Regions expressed opposition to the policy of career
technical tracks.   They stated an unwillingness to single out one skill for
advanced salary potential, a reluctance to expend the time needed to
implement the policy, and a lack of funds to pay for the positions.

     The most often reported reason for hydrogeologist turnover is under-
utilization of professional expertise and lack of educational or skill
enhancement opportunities.  Advanced technical training was cited as a common
need.  In many cases sufficient training funds for advanced academic and
field courses were not available.  In other cases it was reported chat even
when funds for tuition were available, travel dollars were not.  In a few
cases, lack of equipment, such as ground-water modeling software and map work

facilities, was cited as a limiting factor; however, this particular
equipment has since been provided.

     3.2.2  Recomendations

     The Task Force supports the recommendations concerning the issues
expressed in the memorandum from Stephen Uassersug to James Barnes on July 5,
1985, and in Chapter 7 of the Operations Assessment Group (OAG) report dated
January 25, 1986.

     3.2.3  Current Status

     The overall career ladder for CERCLA technical professionals is being
evaluated within the On-Scene Coordinator/Remedial Project Manager (OSC/RPM)
support project.  This project can serve as a model for RCRA technical
professionals, and this possibility will be explored.


     3.3.1  Issues and Observations

     It is important to point out that as a relatively new area of
responsibility for EPA, the RCRA ground-water program has been especially
hard hit by the lack of rapid growth.  Other technical areas of
responsibility in the hazardous waste program (such as construction and
design of waste management units) require staff with professional engineering
backgrounds; a substantial number of the original engineering staff and
management of the Agency have been successfully redirected and their skills
applied to these areas of the RCRA program.  However, there was no pool of
hydrogeologists from which the Agency could draw to fill ground-water staff
positions.  Consequently, ground-water program management is forced to add on
hydrogeologic expertise.  Managers reported, however, that it is much easier
to fill vacancies with engineers, who can be brought on at senior level, than
with hydrogeologists, who are not covered by EPA's direct-hire authorities.
Since neither Agency growth nor a redirection of staff resources can be
counted on to solve the problems created by lack of hydrogeologic expertise,
the only remaining option is to make the best of hiring opportunities the
Agency does have to optimize the use of the current staff.

     The following comments about resource utilization were raised during the
interviews with Regional staff.

     •  The Agency should require that a hydrogeologist be present at land
        disposal facilities during some portion of site characterization and
        remedial activities.   Technical staff indicated that on those
        occasions that they have been present to inspect construction and
        other field activities, they had discovered and corrected problems
        that otherwise would have been overlooked if the oversight process
        had consisted only of a review of the project plan.

     •  Using contractors for RCRA investigations has often been

        unsatisfactory because contractor staff very often lack the necessary

        There is a. significant discrepancy between the full-time equivalent
        factors in workload models and what the Regions actually spend to
        complete ground-water evaluations.

        EPA must amend the workload models and State RCRA grants to include
        post-permit inspection of hydrogeologic field work, data review, and
        enforcement of special permit conditions, particularly as the RCRA
        facility investigations are conducted.

        There is not enough time to oversee and conduct technical reviews of
        State actions.

        The Task Force discovered cases in which Regions failed to follow up
        on progress made by facilities that were directed to take some
        specific action.

        Headquarters' program staff and review teams generally lack technical
        capabilities in ground-water management, and completing tasks is
        considered to be OSVER's top priority.
     3.3.2  RecoMendations

     Based on the results derived from the interviews with Regional Staff,
the Task Force made the following recommendations:

   •  •  OSWER, in coordination with the Regions, should conduct a
        comprehensive review of workload models and resource analysis with
        input from experienced hydrogeology staff.

     •  The Regions should be directed through Strategic Planning and
        Management System (SPMS) measures to conduct regular field activity
        inspections to ensure that permit and order conditions are being met.

     •  The Regions should anticipate the increase in workloads that will
        occur in the future as a result of permit compliance schedules,
        3004(u) orders, and 3008(h) orders -- and staff accordingly.  The
        follow-up work required will be resource-intensive as reports are
        reviewed, field presence is required, and appropriate enforcement
        actions are taken.   Work force planning similar to that for
        OSCs/RPMs is being considered to fulfill staffing needs.

     3.3.3  Current Status

     EPA has already implemented two out of the three Task Force
recommendations.  OSWER has an ongoing process for workload model review, and
field inspections are now included in SPMS commitments.  Work force planning
is in its early stages.


     3.4.1  Issues and Observations

     Effective communication and coordination within and among Regions and
between Regions and Headquarters is vital to the successful implementation of
the RCRA Subpart F program.  Historically, EPA Headquarters has not required
its Regional offices to follow specific organizational or communication
procedures, preferring to allow them the flexibility to develop a structure
that best meets their needs.  This approach allows individual management
styles to flourish and maximizes the strengths of their particular Regional
offices; however, it also relies heavily on the ability of Regional
management to compensate for the difficulty of coordinating ten different
organizations at the national level.

     The Task Force found numerous cases in which a specific organizational
structure worked well in one Region but was perceived as failing in another.
According to many interviewees, the central factor in either the success or
failure of any particular organizational structure was the degree to which
management was able to recognize problems when they arose and to set up
mechanisms to overcome them.

     In the Regions where dissatisfaction with the organization was
expressed, the Task Force found that staff and management often had
completely different perspectives on the existence and nature of
organizational and communication problems.  Managers tended to feel that any
difficulties were minimal, while their staff often felt that significant
problems existed and that communication of technical issues between
management and staff was ineffective or nonexistent.

     In the Regions where there was general satisfaction with the
organizational arrangement and internal RCRA communication, not only did
staff and management have similar perceptions, but there was other evidence
that they were committed to promoting effective communication and task
coordination.   The following are examples of the kinds of mechanisms found in
these Regions:

     •  Frequent (bi-weekly) formal meetings between all RCRA hydrogeologists
        and all RCRA section chiefs and the Branch Chief to discuss
        priorities, adjust workloads, and identify upcoming needs for
        technical support.

     •  Adherence to a formal concurrence policy requiring all parties with
        ground-water responsibilities to review and concur on actions before
        management signs a decision document.

     •  Active enforcement by management of performance expectations •- for
        example,  that their staff continually share information and take all
        perspectives into account before taking action.

     •  Keeping Regional management and technical staff informed of upcoming
        regulations, policies, guidance, and research by assigning a Subpart
        F lead.

     •  Assigning a single geologist to manage a site through enforcement and
        permitting actions even though hydrogeologic staff were divided
        between the permits and compliance parts of the program.

     •  Meetings held among hydrogeologists to discuss technical issues and
        national guidance and policy.

     •  Peer review of all hydrogeologic work by other hydrogeologic staff,
        or review of significant reports by a senior hydrogeologist.

     •  Using a ground-water routing slip to circulate technical journals,
        notices of training courses, and other professional notices among
        hydrogeologic staff.

     3.4.2  RecoBBendations

     Based on its observations and the information gathered during
interviews, the Task Force made the following recommendations concerning
communication and task coordination:

     •  Regional performance is linked to the SPMS, which tracks the number
        of permits and orders issued to facilities.  The Task Force
        recommends that OSVER hydrogeologists review draft permits for
        technical adequacy as well as for general completeness as part of the
        quality criteria in the RCRA Implementation Plan.

     •  Regional Management should assure the exchange of technical issues,
        ORD results, and Headquarters' policies and guidance among ground-
        water staff.

     •  Hydrogeologic work products should be reviewed internally for
        technical accuracy by hydrogeologists with experience in the RCRA

     •  Regions must assure consistency of their actions.  This function
        could be implemented by convening a peer review panel for exchanging
        information about various approaches as well as for conducting a
        technical accuracy review.

     3.4.3  Current Status

     The Agency, at both the Headquarters and Regional level, recognizes the
importance of effective communication and coordination of program
responsibilities.   The following action has been taken.

     •  The recent creation of the CERCLA Ground-Water Forums and the OSWER

        Bulletin Board has reduced the problem of exchange of information
        (e.g., ORD results, Headquarters' policies, and guidance) among
        ground-water staff.

     •  Some Regions have revised their organizational structure in order to
        improve communication among technical staff.

     •  Regional Division Directors are having OSVER hydrogeologists review
        draft permits for technical accuracy as well as for completeness.


     3.5.1  Issues and Observations

     The Regions were nearly unanimous in expressing the need for an
automated data management system to manage the increasing amounts of RCRA
ground-water data.  Currently, a tremendous amount of site-specific geologic
and ground-water data are generated at RCRA-regulated facilities.  As
voluminous as the data now are, the amount is expected to continue to
increase in the future, especially as plumes from solid waste management
units are mapped and their threats assessed.  According to the interviewees,
neither EPA nor State technical staff can adequately evaluate existing
information, which is often in the form of reports containing hundreds of
pages that in turn, contain thousands of individual analytical results.  As a
result, interviewees reported, permit writers and enforcement officers are
often forced to make decisions without the benefit of having reviewed all of
the hydrogeologic data.

     However, even if staff could thoroughly review all the collected data,
decisionmakers still might arrive at faulty conclusions because the quality
of the data is suspect.  RCRA-regulated facilities have the primary
responsibility for taking ground-water samples, analyzing the contents, and
reporting the results to EPA.  There are no uniform data quality standards or
reporting requirements.  Data of unknown quality are now submitted in varying
units of measure, in numerous formats, and without cross references to the
sampling method used, well location, well construction, or geologic unit in
which the well is screened.  All of this further compounds the obstacles
faced by Agency hydrogeologists.

     The data management issue is well known.  Nine out of ten Regions
expressed concerns about the resource drain caused by manual data management
The Office of Solid Waste earlier recognized the need for automated data
management and issued policy memoranda in 1984 and 1985 directing the Regions
to implement automated data management programs (see: Skinner to Division
Directors, 9/24/84; and McGraw to Division Directors, 11/22/85).  In
addition,  Headquarters revised the STORET program to make it usable for RCRA
ground-water and geologic data.

     The infrastructure interview teams, however, found that the system had
not been implemented because of competing program priorities and the lack of
specific implementation goals (e.g., State grant conditions, SPMS measures)

for complecing data automation and analysis.  Failure to allocate sufficient
resources to develop and maintain a data management system has been another
impediment.  Thus, Regions are left with two options:  to expend an
inordinate amount of time on manual examination of data or to review only
selected portions of the data.

     The Task Force interview team made the following observations concerning
data management within the Regions:

     •  Staff in one Region reported that it has already entered over nine
        megabytes of data from a commercial facility into a site-specific
        computer system designed by contractors.  The enormity of this data
        file suggests that any national system will need substantial storage

     •  In another Region, staff reported that the single personal computer
        available to them was constantly in use, limiting its availability
        for hydrogeological reviews.  This was especially true for modeling,
        which can involve days of computer time for calibrating, conducting
        sensitivity analyses, and running simulations.

     •  One Region used contractor assistance to develop a personal-
        computer-based data management and analysis system and then used
        contractor support to enter the RCRA ground-water data into the
        system.   The Region also has linked its personal computer to its
        word-processors so that technical staff can create and edit reports
        on one terminal and then send them electronically to clerical staff
        for final production.

   ^  •  One Region reported a successful-pilot project using the revised
        STORE! to store geologic information, well construction information,
        and RCRA ground-water data.

     3.5.2  RecoBMendations

     Based on the observations just discussed the Task Force made the
following recommendations:

     •  As a first step, the Agency should develop and promote a standard
        data reporting format.

     •  Even though having a uniform reporting format will ease the
        difficulty of tracking and entering data into a computer system, the
        ultimate goal of the Agency should be the electronic capture of
        facility data (e.g., reports submitted on diskette) thus eliminating
        the need for manual entering of the data and resource drain that

     •  OSVER, in coordination with the Regions, should implement a
        nationally consistent automated data management system with
        compatible hardware and software components in all Regions.

     •  OSWER must give clear program office direction to Regions and States,
        including performance goals and resources, in order to implement a
        ground-water data management system and to enter the relevant 1981 to
        present data that will be used as the bases for permitting, setting
        alternate concentration limits (ACLs), closure/post-closure, and/or
        enforcement decisions.

     •  OSWER must provide, build and maintain a central technical support
        group both to provide technical assistance to system users and to
        design system improvements.

     •  OSWER should direct the Regions to promote, through the grant
        process, the involvement of authorized States in continuing automated
        data management and doing adequate analysis in support of permit,
        ACL, closure/post-closure, and clean-up decisions.

     •  Regional management should show its support for an automated ground-
        water data system by allocating staff and contract dollars, and by
        promoting computer training and use among current staff.

     3.5.3  Current Status

     The Agency recognizes the need for improving data management and has
adopted several of the Task Force recommendations.

     •  The Agency is addressing the problem of lack of computer resources by
        authorizing the installation of additional personal computers and a
        ground-water work station in each Region.

     •  A special Agency task force is currently investigating the
        feasibility of developing a national automated data management system
        with a storage capacity sufficient to hold all data supplied by
        facilities and generated from facility reviews.

     •  A task force chaired by the Office of Water with OSWER participation
        is in the process of developing a standard data reporting format.

                                  CHAPTER 4


     Since the promulgation of EPA's ground-water monitoring requirements in
1980, efforts to protect the nation's ground water have benefited from
dramatic improvements in ground-water related knowledge, capabilities, and
technological skills.  For example, advances in research and development
(R&D),  analytical methods and technical capacity have led to a greater
understanding of subsurface hydrogeology.  These advances, in turn, h*ve
allowed environmental scientists to better characterize the migration of
contaminant plumes, and hence conduct more precise and effective remediation

     During its tenure, the Task Force has both experienced and contributed
to this evolution in ground-water technology.  While progress in this area
has undoubtedly enhanced the ability of environmental scientists to protect
ground water, the rapid pace and wide breadth of these scientific advances
present a significant management challenge to both Regional and State ground-
water programs.  Environmental program staff in both the public and private
sectors have defined this challenge as the need to:

     •  understand the changes being made to current regulations and

     •  use advances in ground-water technology and intelligence to measure
        the Agency's success in implementing existing regulations and

     •  recognize each site as a geologic configuration requiring individual
        attention; and

     •  balance statutory and administrative management procedures with the
        need to employ the level of technical quality criteria necessary to
        protect human health and the environment.

     In assessing and adapting to advances in ground-water intelligence and
technology, EPA managers must also remain cognizant of horizontal and
vertical management imperatives.  Vertical management is required to assure
continued maintenance and efficient utilization of ground-water technical
staff skills and management systems.  On the other hand, managers must
recognize that the ground-water program fits horizontally into the hazardous
waste program as a whole (i.e., permit approval, land ban, waste
characterization, closure, risk assessment, etc.).  Assessing how these two
imperatives interact and balancing their respective requirements has been and
will continue to be a primary consideration of EPA managers.

     Finally, EPA managers are and will be continuously challenged by some
facilities' unwillingness or inability to comply fully with the ground-water
monitoring requirements.  Although facilities often respond positively when

granted a certain degree of attention by the implementing agency (as
demonstrated in Chapter 2 of this report),  it is unlikely that the Regions or
States will have the resources to closely supervise the activities of all
land-based facilities.  Consequently, EPA managers must develop mechanisms by
which the Agency can ensure the greatest degree of compliance with the
personnel resources on hand.

     With these challenges in mind, the Task Force has been asked to use its
experience to make program recommendations for EPA's ground-water regulatory
program.  When developing its recommendations, the Task Force relied upon its
analysis and evaluation of data, information and experiences obtained through
(1) the investigation of 58 major land disposal facilities throughout the
nation, (2) recommendations made by the Task Force Operations Assessment
Group, and (3) information collected by the Regional Ground Water
Infrastructure Assessment Group.  In addition, the Task Force based its FY
88/89 program recommendations (see Sections 4.1 through 4.3) upon the
following principles:

     •  A recognition that authority and responsibility must be allocated
        vertically within the ground-water program and horizontally across
        governmental and program area lines;

     •  An understanding that implementing the Subpart F technology
        requirements demands rigorous attention to balancing a need for
        technical quality with the need to make timely environmental
        management decisions;

     •  A demand that management and staff have a clear understanding of
        system standards, process checks and balances, program objectives,
        and individual roles as defined by reasonable performance measures;

     •  Cognizance that ground water, while remaining a very important
        environmental program element, does not stand alone, but is
        influenced by a number of human and scientific factors, some of which
        are unknown.  Consequently, the ground-water program must be flexible
        enough to consider technological change.

     The Task Force also believes that proper implementation of its program
recommendations is indispensible to the success of its effort.  To this end,
the Task Force has established two general goals to serve as foundations for
the implementation of the recommendations that follow.  These goals are:

     •  Focusing continued ground-water program assistance on improving field
        performance, developing high-quality data and information objectives,
        and facilitating the improvement of Region and State management of
        the site-specific decision making process; and

     •  Application by the Office of Solid Waste and Emergency Response
        (OSWER),  Office of Program Management and Technology (OPMT) of its
        technology transfer and training strategies to provide improved
        ground-water program assistance to key management and staff

        professionals in the Regions and States.

     When reviewing the recommendations presented in this chapter, it ia
essential to keep in mind the findings of Chapters 2 and 3 of this report.
For example, Chapter 2 illustrates that gathering scientific data, analyzing
information, designing and implementing remedies, and ensuring compliance in
the field requires a substantial amount of time, special staff skills, and
persistance on the part of management.  Chapter 3 reinforces these findings
by further clarifying the communications and coordination challenges EPA
managers must surmount to implement and enforce an effective ground-water


     The ground-water technical assistance program consists primarily of
satisfying needs by providing direct assistance.  This type of assistance is
consistently recognized as among the best and most effective means of
transferring technology, as evidenced by the number of government agencies
employing some form of direct technical assistance.

     In fact, the OSWER Superfund Technology Support Centers program with ORD
addresses the need to transfer technology to technical staff in the Regions.
To provide for and fund technical assistance activities related to ground
water, the Task Force recommends that OSWER establish a similar comprehensive
ground-water technical assistance program for RCRA regional ground-water
staff by the third quarter of FY 89.  The Task Force believes that a well
coordinated technical assistance program .will promote the use of results from
applied research in the field.  This section outlines the fundamental
elements of this program.

     The Task Force believes that there are three fundamental elements of any
technical assistance program:  (1) the individual requesting assistance, (2)
the provider of assistance, and (3) the program that facilitates technology
transfer.  These elements are discussed below.

     •  Individual requesting assistance.  An EPA staff member who requires
        technical assistance to complete an assigned task and requests the
        delivery of such assistance.

     •  Provider of assistance.  An EPA staff member or ORD technical expert
        who has the capacity to screen requests, is familiar with issues
        relating to ground water, has access to and knowledge of a broad
        spectrum of assistance, and can provide financial support to deploy

     •  Assistant? pr?grflgl   A program that allows direct assistance either
        at the point of need (i.e., the requester's location) or at the point
        of knowledge (i.e., the provider's location).  The Task Force
        recommends that the program should perform the following functions:

               Provide a proactive coordinator who can easily receive

               Develop a criteria for screening assistance requests;

               Establish performance measures that guarantee swift action on
             .  all requests;

               Develop an efficient system for evaluating requests for
               technical assistance services and cost advance/reimbursements;

               Monitor assistance delivery and quality; and

               Document delivery of technical assistance.


     Throughout this report, the Task Force has argued that the Agency oust
enhance its ground-water information systems to more effectively implement
and enforce the ground-water monitoring requirements.  For example, the
Regional Infrastructure Assessment, as discussed in Chapter 3 of this report,
found a serious need for improved information management in the ground-water
program.  In making this finding, the Assessment cited the following

     •  The copious amount of geologic and ground-water data being generated
        at RCRA facilities;

     •  The varied nature of data input, which makes proper data analysis
        extremely difficult;

     •  Poor data quality;

     •  A lack of uniform data requirements or standards exist; and

     •  The general failure of owner/operators to improve their information
        collection processes.

     In this section, the Task Force presents three recommendations to
improve OSWER's ground-water information systems.  Collectively, these
recommendations provide a tactical foundation for ground-water information
issues that must be addressed over the next 3 to 5 years.  The Task Force
urged that the Agency initiate implementation of these recommendations in FY
88.  The recommendations are outlined below.
     4.2.1  Cooperate with the OGBP/OIRM Data Management Process

     In May 1987, the Office of Ground-Water Protection (OGWP) and the Office
of Information Resource Management (OIRM),  with the assistance of OSVER,
completed a report entitled Ground-Water Data Requirements Analysis for the

EPA.  The Data Requirements Analysis  Policy Committee  reached consensus on
the following issues:

     •   Investment  in  improved  ground-water data management is necessary and
         justified,  although improvements  should be phased  in over tine to
         limit risk  and minimize disruption;

     •   Existing and proposed projects  for  improving ground-water data
         management  must be carefully  coordinated and managed to maximize
         their benefits; and

     •   States, EPA Regions, and EPA  offices must voluntarily adopt new
         ground-water data standards and practices, since they cannot be
         imposed effectively from above.

     To  address these  issues, the Committee  urged the  Agency to develop data
management standards,  policy and guidance,  improve access  to ground-water
data across program lines and automation, and enhance  ground-water data
analysis capabilities.  In light of findings, the Task Force recommends that
OSVER establish an  ongoing ground-water information management strategy for
hazardous waste programs.

     4.2.2  Develop Data Quality Objectives  and Standards

     The States, Regions and Headquarters depend upon  the  submission of high-
quality  data by the public and  private  sectors to make proper regulatory and
enforcement decisions.  Poor data quality hinders these efforts, and is often
the direct result of unclear data quality standards or objectives.  Since
data providers often provide only the information they believe is required,
unclear  data quality standards  harm the Agency's ground-water program.  As
such, the Task Force strongly recommends that the OSVER program offices
develop  data quality objectives for use at hazardous waste sites.

     4.2.3  Develop and Implement the EASI-GW Computer Workstation

     In  1987, the Task Force initiated  a project with  the  Oak Ridge National
Laboratory (ORNL) to research and develop a.  ground-water computer workstation
capable  of integrating certain  useful independent applications software
programs.  By initiating this project,  the Task Force  hoped to facilitate
improved analyses of ground-water conditions at hazardous  waste sites, assess
more accurately the extent of further monitoring needed at a site, and
develop  a tool to improve data  access,  control and presentation capabilities.

     The first stage of the project was completed in September 1987, when the
Environmental Applications Software Integrator for Ground-Water (EASI-GW),
was pilot tested in Region 8 and National Enforcement  Investigation Center
(NEIC), both in Denver.  The pilot tests were successful,  and the Agency
approved the EASI-GW for implementation in each of the Regional RCRA Branch
Offices.  The systems  were installed  between October 1987  and October 1988.


     Effective ground-water technology transfer requires that the Agency
establish a comprehensive training program and issue relevant guidance
documents.  In this section, the Task Force reviews recent efforts made by
the Agency in this area and outlines several recommendations for improving
ground-water training and guidance.

     4.3.1  Recent Efforts in Ground-Water Training and Guidance

     OSVER has devoted a great deal of time and effort towards Improving
ground-water training and guidance.  The following documents reflect the work
accomplished by EPA and other agencies or institutes in this field:

     •  Ground-Water Protection Strategy. Office of Ground-water Protection,
        EPA,  1984.

     •  Ground- Water:   Strategies for State Action. Timothy R. Henderson, et
        al.,  Environmental Law Institute, 1984.

     •  Assessment of EPA's Hazardous Waste Enforcement- GAO, 1985.

     •  OSWER Training Needs Assessment. ETI, 1985.

     •  Porter, J. Winston, Ground-Water Training, memorandum, August 26,

     •  Guidance on Remedial Investigations Under CERCI^A. Office of Emergency
        and Remedial Response,  et al., EPA, 1985.

     •  Revised Draft Protocol for Ground-Water Inspections at Hazardous
        Waste Treatment. Storage and Disposal Facilities. Hazardous Waste
        Ground Water Task Force. EPA, 1986.

     •  Hazardous Waste:  Federal Civil Agencies Slow to Comply with
        Regulatory Requirements. GAO, 1986.
     •  Evaluation of the RCRA Suboart F Ground-Water Monitoring
        Final Report. Hazardous Waste Ground Water Task Force, EPA, 1986.

     •  OSWER Training Implementation Plan. OSWER Work Group, April 1987.
     •  OSWER Ground-Water Curri^vlyn) Plfln i  OSWER, Office Program Management
        and Technology,  1987.

     •  OSWER Ground-Water CurrJ7y jura, Implementation Plan. OSWER, Office of
        Program Management and Technology, August 1987.

     •  Resource Conservation and Recovery Act CRCRA) Ground-Water Monitoring
        Technical Enforcement Guidance Document.  Office of Waste Programs

        Enforcement, September 1986.

     •  Comprehensive Ground-Water Monitoring Evaluation f^ME) Guidance
        Document. Office of Waste Programs Enforcement, December 1986.

     Perhaps the most significant documents in this list are OSWER's Ground-
Water Curriculum Plan and Ground-Water Curriculum Implementation Plan.  Both
documents emphasize the top priority given to the topic of ground-water.
After examining 72 ground-water training and regulatory courses, the Ground-
Water Curriculum Implementation Plan prioritized 10 ground-water topics.
Exhibit 4-1 outlines these topics.

     During its tenure, Task Force management has played an active role in
developing ground-water training recommendations.  The Task Force's most
recent recommendations, classified as "fast track" topics,  are included
within the 10 prioritized training topics in Exhibit 4-1.  "Fast track"
topics are the most crucial topics, and could deliver the most immediate
     4.3.2  Training and Guidance Recommendations

     To improve ground-water training and guidance, the Task Force outlines
the following recommendations.

     Focus Contractor Support on Developing Ground-Water Training Program.
The Task Force recommends that a single support contractor develop and
deliver a comprehensive ground-water training program.  The Agency should
require the contractor to establish a data base that incorporates EPA
hazardous waste ground-water information as it is generated throughout the
training design process.  The contractor should also demonstrate the
technical ability and depth to be responsive to the varied demands of the
total ground-water program.  The Task Force believes that developing a
foundation of ground-water information will provide a progressive systematic
linkage between subject matters.  Such information should be maintained in a
manner facilitating transfer to other contractors should the need arise.
     Include Management Training Course in Ground-Water Training Program.
The Task Force recommends that the OSVER Training Work Group seriously
consider adding an advanced management training course for all Regional and
State managers that assess ground-water recommendations from technical staff.
The management course should focus on assessing the quality and quantity of
work performed.  In addition, the course should provide management with an
enhanced understanding of ground-water technology and an improved ability for
technical investigation and management/staff dialogue.  In short, the
training course should raise management's comprehension of ground-water
issues and enhance its capacity to coordinate technical staff utilization

     Modify Training Delivery Methods.  Because the technical skills employed
by Regional and State ground-water personnel often determine the measure of
success or failure of the ground-water program, training delivery methods are

of utmost importance.  Moreover, the Task Force believes that several
conditions, including management and staff changes, varied staff skill
levels, the rate of attrition of Agency personnel, the complexity of hiring
requirements, and program reorganization, makes it important for the Agency
to re-examine traditional methods of training delivery.

     The traditional lecture, case study, hands on demonstration, and
practical exercises will always be practical delivery methods and, in many
instances, are the best methods for teaching certain subjects.  Nevertheless,
the Task Force recommends that the Agency modify its training delivery
methods and consider other methodologies that are being successfully utilized
in the technical training process.

                                    EXHIBIT 4-1


                                                                    # Existing
                                                          Course      Course
Topic	    Level ay  Est. Cost by  Days £/  Coordination dy_

1.  Field Inspection Training      B,I       $49,710       3          17

2.  Monitoring In the Unsaturated  B,I       $49,710       3           7

3.  Hydrogeology/Hydrogeology      B,I       $64,470       3          14

4.  Geophysics:  Methods,
    Techniques, Equipment          I,A       $140,610      3           8

5.  Site Characterization          B         $72,060       3           6

6.  Computer Modeling              I,A       $115,920      3           4

7.  Well Technology                I,A       $184,290      3           9

8.  Transport and Geochemistry     I,A       $184,290      3           7

9.  ,RCRA Regulations               B     .    $58,750       3           4

10.  Sampling                       I         $208,100      3          14

(a)   B - Basic, I - Intermediate,  A - Advanced:  The implementation plan recommends
     3 basic, 3 basic to intermediate, 1 intermediate and 4 intermediate to advanced

(b)   Estimated "high" cost of the course.  Costs actually could be higher or lower
     than estimated after actual development,  depending on extent of technological

(c)   Estimated number of days required to deliver a "live" training course.  For
     example, if each Region received a single 3-day course in a single fiscal year,
     the schedule time required would be 30 days.   For cost purposes,  curriculum
     development, pilot testing, course adjustment and evaluation must be added to
     the actual number of delivery days.

(d)   The number of other existing courses that could contribute to help build the
     recommended course.  Based on review by the Training Work Group of 72 ground-
     water related courses.

     .,r-a\ Protection Agon*T
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