EPA/440/6-85/008
stes
3ntal Protection
Office of December 1985
Ground-Water Protection (WH-550G)
Washington DC 20460
Ground-Water
Monitoring Strategy
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A GROUND-WATER MONITORING STRATEGY
FOR THE
U.S. ENVIRONMENTAL PROTECTION AGENCY
This document was prepared by:
U.S. Environmental Protection Agency
Office of Ground-Water Protection
Dr. Norbert Dee, Senior Scientist
With assistance from:
Office of Ground-Water Protection
Ground-Water Monitoring Work Group
and Ground-Water Monitoring Workshop
and
Temple, Barker & Sloane, Inc.
under contract no. 68-01-7002
December 1985
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
6 !986
MEMORANDUM
SUBJECT
FROM
Transmittal of EPA's Ground-Water
Monitoring Strategy
Lawrence J. Jensen
Assistant Administrator for Water
TO:
J.^Winston Sorter
Assistant Administrator for
Solid Waste and Emergency Response
John A. Moore
Assistant Administrator for
Pesticides and Toxic Substances
The Administrator
Attached is the final Ground-Water Monitoring Strategy
for EPA. It was prepared as a cooperative venture among the
Office of Drinking Water, Office of Solid Waste, Office of
Emergency and Remedial Response, Hazardous Waste Ground-Water
Task Force, Office of Pesticide Programs, and Office of
Management Systems and Evaluation, under the leadership
of the Office of Ground-Water Protection (OGWP).
Recognizing the important role of the States, Regional
Offices, EPA Headguarters, and other Federal Agencies such as
the United States Geological Survey in implementing an effective
Ground-Water Monitoring Strategy, OGWP convened a series of
work groups with governmental, technical, and environmental
experts to establish the Monitoring Strategy's priorities
and objectives. This process culminated in a work shop in
the Spring of 1985 which helped formalize a framework for an
integrated strategy.
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-2-
These same offices are now beginning to implement the
Ground-Water Monitoring Strategy. The first steps in this
multi-year process have been initiated within the EPA programs,
and between EPA and the States and other Federal Agencies.
We look forward to keeping you informed about the developments
of these efforts and welcome an opportunity to discuss our
plans with you personally.
Attachment
cc: Howard M. Messner
Assistant Administrator for
Administration and Resource Management
Milton Russell
Assistant Administrator for
Policy, Planning & Evaluation
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TABLE OF CONTENTS
Paqe
Executive Summary 1
Acknowledgements 11
I. Introduction and Overview 1-1
The Problem 1-1
EPA's Monitoring Strategy 1-2
Relationship to EPA's Ground-Water Protection
Strategy 1-3
II. Strategy Context, Approach, and Objectives II-l
Context II-l
Approach II-2
Objectives II-3
III. Action Plan for Implementation III-l
Characterize the Nation's Ground-
Water Resources Illrl
1. Current Activities III-2
2. Proposed Solution III-5
3 . Implementation Plan III-5
Identify New Contamination Problems III-7
1. Current Activities III-7
2. Proposed Solution III-9
3. Implementation Plan III-9
Assess Known Problems to Support
Regulatory Development and Standard Setting and
Respond to Site Specific Problems III-ll
1. Current Activities III-ll
2. Proposed Solution 111-13
3 . Implementation Plan 111-13
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TABLE OF CONTENTS (continued)
Page
Assure Compliance with Regulations 111-15
1. Current Activities 111-15
2. Proposed Solution 111-18
3 . Implementation Plan _ 111-19
Evaluate Program Effectiveness 111-21
1. Current Activities 111-21
2. Proposed Solution 111-22
3. Implementation Plan 111-23
Improve Data Quality 111-24
1. Current Activities 111-24
2 . Proposed Solution 111-27
3 . Implementation Plan 111-27
Develop Ground-Water Data Management System 111-29
1. Current Activities 111-29
2. Proposed Solution 111-32
3 . Implementation Plan 111-33
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EXECUTIVE SUMMARY
Environmental monitoring is an essential part of EPA program
activities—from planning and research to rule making, compli-
ance, and pollution control to evaluating program effectiveness.
In order to acquire and successfully use information on the broad
range of environmental problems—their causes, their public
health implications, and their potential for control—Federal,
State, and local officials must identify the need for and collect
environmental data on these issues. Therefore, the Deputy Admin-
istrator has directed all appropriate EPA offices to develop
environmental monitoring strategies. The Office of Ground-Water
Protection (OGWP) has the responsibility for developing the
Ground-Water Monitoring Strategy.
For the purpose of this strategy, "ground-water monitoring"
is broadly defined as the set of activities that provide chemi-
cal, physical, geological, biological, and other environmental
data required by environmental managers. This definition recog-
nizes that monitoring activities take place at hazardous waste
facilities, public drinking water wells, and other locations
where people need information on ground-water quality, quantity,
and flow.
GROUND-WATER MONITORING STRATEGY
The Ground-Water Monitoring Strategy provides a cross-Agency
analysis of the need for and use of ground-water monitoring data.
Within this approach, individual program monitoring strategies
focus on their program's specific needs while the Ground-Water
Monitoring Strategy focuses on the interrelationships between
programs and the overall direction of the Agency's ground-water
monitoring effort. As the blueprint, or framework, for EPA's
ground-water monitoring decisions and activities, the strategy is
designed to:
• Be broad in scope and not address specific details of
any program monitoring requirement
• Focus on a five-year horizon for implementation, with
both short-term and long-term action items
• Recognize that the job is complex and that EPA and
others are interested in considering what constitutes
an appropriate overall ground-water monitoring program
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• Provide a balance in the strategy implementation plan
between general action items and a detailed work plan
• Focus on solutions to the ground-water monitoring prob-
lems identified in the Office of Technology Assessment
(OTA) report Protecting the Nation's Ground Water from
Contamination* and other reports, and not restate their
analyses
The Ground-Water Monitoring Strategy focuses attention and
resources on improving the fundamental activities of ground-water
monitoring. For this reason, the strategy stresses the need for
improving the .quality and management of ground-water data col-
lected and analyzed by or on behalf of EPA programs. The stra-
tegy concentrates on upgrading existing Agency activities and
filling the gaps between these activities. Such an effort re-
quires the identification of data users, uses, and accessibility.
This is the first attempt by the Agency to do this on a compre-
hensive scale for an environmental issue.
The strategy does not recommend major new monitoring efforts
such as a national ground-water monitoring network for the
Agency, principally because most experts agree that such a net-
work would not be cost-effective. However, new ground-water
monitoring activities targeted to support a specific objective
may be appropriate.
The strategy is broad in nature, covering both short-term
and long-term aspects of ground-water monitoring. Implementation
of the strategy, therefore, requires a phased approach based on
resource availability and the timing of activities. The strategy
is built around the overall goal of improving ground-water moni-
toring but focuses on the key short-term activities needed to set
the foundation for the remaining activities.
THE PROBLEM
Ground-water monitoring in the United States is in the early
stages of development and is hampered by many problems, as has
been pointed out by the Office of Technology Assessment* and in
other technical reports. The OTA report thoroughly reviews the
*Washington, D.C.: U.S. Congress, Office of Technology Assess-
ment, OTA-0-233, October 1984.
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sources of ground-water contamination and the problems of ground-
water monitoring. The problems and issues it identifies serve as
the setting for the Ground-Water Monitoring Strategy.
At present, usable data on ground water are limited and
often not readily accessible; what does exist is fragmented among
the various Federal, State, and local agencies directly or pe-
ripherally involved in ground-water decision making. Other than
the work conducted by the U.S. Geological Survey (USGS) on the
quantity of natural ground-water contaminants, there has been no
concentrated effort at the Federal level to assess the need for
ground-water data and plan for its collection, analysis, and use.
Such an effort needs to focus on determining (1) who needs the
data, (2) how the data will be used, and (3) how accessible the
data are.
The Ground-Water Monitoring Strategy was designed to respond
to monitoring needs extending beyond those of EPA alone. The
USGS and other Federal agencies, as well as many State and local
organizations, are actively involved in ground-water monitoring
and research. The strategy, therefore, is broad, considering the
data needs of a wide variety of users.
RELATIONSHIP TO EPA'S GROUND-WATER PROTECTION STRATEGY
The Ground-Water Monitoring Strategy is a major outgrowth of
the EPA Ground-Water Protection Strategy and responds to a number
of needs identified there:
• Strengthen State Programs. One of the strategy's major
purposes is to assist State decision makers in develop-
ing and gaining access to needed ground-water monitor-
ing data.
• Cope with Contamination Sources of National Concern.
The extent and consequences of many sources of ground-
water contamination are not sufficiently documented,
hampering decision makers' efforts to protect the pub-
lic and the environment. The strategy addresses ways
in which the information needed for documentation might
be acquired.
• Create Policy Framework. The EPA's effort to achieve
consistency in ground-water protection is centered on a
differential protection policy implemented in part
through ground-water classification. The strategy
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recognizes that this effort depends on the availability
of site-specific and regional ground-water data.
Strengthen EPA's Internal Ground-Water Organization.
The strategy will help EPA review (1) its approach to
monitoring, (2) the need for and use of ground-water
monitoring data, and (3) how that data can be made
accessible to other environmental decision makers.
OBJECTIVES OF GROUND-WATER MONITORING
Ground-water monitoring is viewed as a continuum of activi-
ties ranging from defining background conditions, to defining the
performance of the waste treatment and storage facilities, to
defining the success of EPA programs in protecting the ground-
water resource. The Ground-Water Monitoring Strategy addresses
this range of activities through seven monitoring objectives,
each of which is summarized below. Ground-water monitoring
research is not identified as a separate monitoring objective,
because it was addressed by the Science Advisory Board through a
committee on ground-water research. EPA recognizes that research
is an integral component of monitoring activity and is important
to the development of more effective monitoring programs.
Objective 1; Characterize
The Nation's Ground-Water Resources
This objective seeks to answer the question, What is the
nature of the ground-water resource? It involves broad-based
monitoring activities aimed primarily at collecting background
data on ground-water resources and their settings. These data
serve as a baseline against which to assess ground-water quality
and the implications of contamination. Environmental managers
require such data to make decisions on how to classify an area,
site a new manufacturing or hazardous waste treatment facility,
or develop a ground-water protection plan.
Objective 2; Identify
New Contamination problems
This objective seeks to answer the question, Where are the
problems? It is forward-looking in that its intent is to provide
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information on previously unidentified threats to ground-water
quality. These threats may exist at unidentified hazardous waste
sites or may be new "generic" problems affecting the entire
United States. Both types of threats are considered in this
objective. Data on new problems are crucial to environmental
managers at the Federal, State, and local levels who are respon-
sible for not only reacting to existing problems, but also of
anticipating future problems.
Objective 3: Assess Known
Problems to Support Regulatory
Development and Standard Setting
and Respond to Site-Specific Problems
This objective seeks to answer the questions, How serious is
the problem? and What should be done? It involves monitoring to
assess known problems—those in which ground-water contamination
has previously been identified--in order to support regulatory
and standard-setting requirements and respond to site-specific
problems. Unlike Objective 2, which focuses on the identifica-
tion of problems, Objective 3 focuses on determining the sources
and extent of contamination and the needed response. Environ-
mental managers at the Federal level use such ground-water qual-
ity information to determine (1) the extent of a given local,
State, or national problem, (2) whether it constitutes a problem
for Federal involvement, and (3) whether new or extended efforts
(e.g., studies, information documents, regulations, and legisla-
tion) should be undertaken.
Objective 4; Assure
Compliance with Regulations
Environmental programs generally require some type of moni-
toring to determine compliance. This objective seeks to answer
the question, To what extent is compliance being achieved? The
objective is broad in that it encompasses many different regula-
tory programs, yet it is narrow in that its definition is
straightforward and there is little overlap with other monitoring
objectives. Program managers, permit writers, inspectors, and
enforcement officials who are responsible for controlling or
abating the consequences of contamination are highly dependent on
such ground-water monitoring data to determine if the regulated
community is in compliance.
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Objective 5; Evaluate
Program Effectiveness
This objective seeks to answer the question, Is the Agency
achieving its objectives? and Are the targets correct? It in-
volves the collection of ground-water monitoring data to evaluate
regulatory effectiveness in protecting ground water. Such evalu-
ation can then be used to assess priorities for changing regula-
tory programs, rules, standards, and procedures, and so that
relevant findings can be reported to the public. Regulatory
evaluation data are important to regulatory managers, and regu-
lated entities, as well as the general public, all of whom are
concerned with the degree to which the Agency is achieving its
goals of ground-water protection and improvement.
Objective 6; Improve Data Quality
This objective involves activities that will improve the
quality of ground-water monitoring data and ensure that correct
and useful data are obtained. Implicit in the objective is the
belief that improving quality-assurance and quality-control pro-
cedures will contribute to the overall improvement of ground-
water monitoring. Environmental managers, regulators, environ-
mentalists, and legislators have to make important decisions that
depend heavily on ground-water quality monitoring. They have to
know if the public is being appropriately and sufficiently pro-
tected. Reliable and defendable ground-water quality data are
essential for all decision makers to make informed judgments.
Objective 7; Develop Ground-Water Data Management System
This objective involves activities for improving ground-
water data management. It includes activities such as determin-
ing data to be collected, developing protocols on data entry, and
making the data accessible to the users. The environmental pro-
gram manager who has oversight responsibilities can use ground-
water quality data for analyzing trends at facilities and sites,
for selecting facilities and sites that may need inspection or
review, and for reviewing permits. Ground-water quality data are
also needed for reviewing siting decisions made by State or local
agencies, determining ground-water classification, and assessing
the ground-water resource.
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Action Plan
The action, or implementation, plan for each objective is
shown in Table 1. The first element in the table is a descrip-
tion of the desired outcome or proposed solution in implementing
the strategy. The second and third elements are, respectively,
the short- and long-term plans for implementation.
The Ground-Water Monitoring Strategy will be implemented by
EPA's program offices and the Regions in addition to the Office
of Ground-Water Protection. EPA will work closely with the
states in supporting their ground-water monitoring efforts. The
strategy sets the framework for all to participate in the imple-
mentation.
Table I
GROUND-WATER MONITORING STRATEGY
Objective
Proposed Solution
FY 86 Tasks (Lead)
FY 87-91 Tasks (Lead)
1) Characterize the
nation's
ground-water
resources.
Develop a system to charac-
terize ground-Mater resources
that is accessible to Federal,
State, and local users. The
USGS has the lead for achiev-
ing this objective. EPA will
work to ensure that the USGS
data is relevant to the needs
of Federal, State, and local
environmental managers and
will convey to USGS the water
quality and aquifer character-
ization needs and priorities
of the Agency and other
organizations.
1) Implement Memorandum of
Understanding (MOU) be-
tween EPA and DOI (OGWP,
Regions),
2) Convene EPA/USGS coordi-
nating committee to coor-
dinate review of USGS
National Water Quality
Assessment Program and
related programs (various
EPA programs, Regions;
OGWP coordination).
3) Convene regional work
groups for developing
regional needs and
implementation plans
(Regions, OGWP).
4) Work with USGS in its
activities under these
agreements (all Agency
programs; coordination by
OGWP).
5) Work with states in the
characterization of their
ground-water resources.
1) Continue working rela-
tionship with USGS
(OGWP, Regions).
2) Develop a means of eval-
uating MOU (OGWP).
3) Continue supporting
states with their
ground-water resources.
(continued)
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Table I (continued)
GROUND-WATER MONITORING STRATEGY
Objective
Proposed Solution
FY 86 Tasks (Lead)
FY 87-91 Tasks (Lead)
2)
Identify new
contamination
problems .
Develop a formal process to
systematically identify new
and emerging sources and types
of ground-water contamination.
Through this process it will
be possible to make better use
of existing and new informa-
tion at the site and national
levels.
1) Develop pesticides and
toxics ground-water pro-
tection strategies that
identify data gathering
requirements (OPP, OTS,
OGWP).
2) Develop a framework for
identification of new
problems (OGWP),
3) Initiate development of
new approaches to conduct-
ing in-field investiga-
tions of both existing and
unaddressed sources
(ORD).
1) Evaluate existing data
sources across programs
to identify new and
emerging problems (Re-
gions, states, OGWP).
2) Undertake an overview
analysis of little-known
sources of ground-water
contamination (OGWP).
3) Continue research into
new in-field measurement
techniques (ORD).
Objective
Proposed Solution
FY 86 Tasks (Lead)
FY 87-91 Tasks (Lead)
3)
Assess known
problems to
support
regulatory
development and
standard setting
and respond to
site-specific
problems.
Develop a formal process to
assess problems identified in
Objective 2 and to determine
which problems should be fur-
ther analyzed by the Agency.
This process should enable
Federal, State, and local
agencies to efficiently and
effectively collect and ana-
lyze existing data, prioritize
future efforts to examine new
and existing problems that
require further analysis, and
determine the appropriate
level of regulatory action.
The assessment addresses
problems at both the site and
national levels.
1) Complete current studies
to examine ground-water
contamination problems of
national concern (OSWER,
OW, OPTS, ORD).
2) Incorporate into Agency an
ongoing mechanism to exam-
ine problems that require
further analysis (OGWP).
3) Program Offices will con-
sider developing regula-
tions or guidelines based
upon results of studies
(OSWER, OW, OPTS).
1) Implement mechanism for
selecting problems for
further analysis
(OGWP).
2) Continue studies under-
way to examine ground-
water contamination
(OSWER, OW, OPP).
(continued)
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Table I (continued)
GROUND-WATER MONITORING STRATEGY
Objective
Proposed Solution
FY 86 Tasks (Lead)
FY 87-91 Tasks (Lead)
4) Assure compli-
ance with regu-
lations.
Develop a process for the
regulated community to provide
scientifically defendable,
verifiable data that is acces-
sible to ground-water mana-
gers. This process should
encourage the regulated com-
munity to continue current
compliance monitoring efforts.
1) Evaluate the status at
existing commercial and
on-site hazardous waste
land disposal facilities
(OSWER/Task Force).
2) Update test methods for
laboratory procedures to
provide consistency within
RCRA and Superfund
(OSWER).
3) Prepare ground-water moni-
toring enforcement docu-
ment (OSWER).
4) Define process for estab-
lishing verification pro-
gram (OGWP, OSWER, ORD).
5) Concurrently with imple-
mentation of items 1, 2,
and 3, develop a process
to consider and review
which methods/procedures
may be appropriate for
Agency-wide application
(OGWP, OSWER, ORD, et al).
1) Work with Task Force and
OSWER to implement
methods/procedures that
have Agency wide appli-
cation (OGWP, OSWER,
ORD).
2) Implement a verification
program that addresses
well installation, samp-
ling, and laboratory
analysis and would en-
sure (OSWER) that the
regulated community
complies with the moni-
toring guidelines and
regulations.
Objective
Proposed Solution
FY 86 Tasks (Lead)
FY 87-91 Tasks (Lead)
5)
Evaluate program
effectiveness.
Develop criteria that measure
the Agency's ground-water
protection efforts and prog-
ress toward attainment of
ground-water program goals.
1) Develop conceptual frame-
work for measuring envi-
ronmental results (OGWP,
OMSE).
2) Review data needs for
measuring effectiveness
(OGWP, OMSE).
1) Initiate data gathering
for effectiveness
criteria (OGWP).
2) Establish baseline for
effectiveness measures
(Agency).
(continued)
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Table I (continued)
GROUND-WATER MONITORING STRATEGY
Objective
Proposed Solution
FY 86 Tasks (Lead)
FY 87-91 Tasks (Lead)
6) Improve data
quality.
Develop procedures and pea-
grans to improve the quality
of data from all EPA programs.
Requires consistency and veri-
fication in monitoring activi-
ties in order to improve qual-
ity assurance and quality
control of Mater quality and
aquifer characterization in-
formation.
1) Develop a process within
Agency to ensure consis-
tency in ground-water
monitoring guidance (OGWP
Program Offices).
2) Develop ground-water per-
formance measures for
installation, sampling,
and laboratory analysis
(ORD).
3) Define a process for
establishing a verifica-
tion program (OGWP, OSWER,
ORD, et al).
4) Implement data quality
objectives in ground water
across the Agency (ORD).
5) Implement a training and
technology assistance
program in ground-water
monitoring (OSWER, ORD).
1) Work with Hazardous
Waste Ground-Water Task
Force and OSWER to con-
sider which methods/
procedures have Agency-
wide application (OGWP,
OSWER, ORD).
2) Implement verification
programs within the
Agency—see Objective 4
(OSWER).
3) Continue research in
field methods and labor-
atory analysis (ORD).
Objectives
7) Develop ground-
water data
management
system.
Proposed Solution
Develop a ground-water data
management system for storing
all ground-water quality and
related well information so
that ground-water data can be
accessible to ground-water
managers. This system should
provide EPA and other program
managers with easy access to
ground-water information.
FY 86 Tasks (Lead)
1) Perform a requirements
analysis to more specifi-
cally identify uses and
users of ground-water data
(OGWP, OIRM).
2) Develop and implement a
short-term management
approach for ground-water
data (OGWP, OIRM, OSWER,
Regions).
3) Initiate inter-Agency
discussions on data
management (OGWP, OIRM,
Regions).
4) Provide technology
assistance in data
management to states
(Regions, OGWP).
FY 87-91 Tasks (Lead)
1) Draft and finalize a
ground-water data man-
agement system based
on requirements analysis
(OIRM, OGWP, OSWER).
2) Construct, install, and
pilot test ground-water
data management system
(OIRM, OGWP, OSWER).
3) Complete system and
transfer information to
use community (Regions,
OGWP).
4) Establish institutional
link with other Federal
and State agencies
(Regions, OGWP).
Key to Abbreviations:
001
MOU
OGWP
OIRM
OMSE
OPP
OPTS
ORD
OSWER
OTS
OW
- Department of
- Memorandum of
- EPA Office of
- EPA Office of
- EPA Office of
- EPA Office of
- EPA Office of
- EPA Office of
- EPA Office of
- EPA Office of
- EPA Office of
Interior
Understanding
Ground-Water Protection
Information Resources Management
Management Systems and Evaluation
Pesticide Programs
Pesticides and Toxic Substances
Research and Development
Solid Waste and Emergency Response
Toxic Substances
Water
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11
ACKNOWLEDGEMENTS
This document was prepared with the assistance of a Work
Group of EPA headquarters and regional personnel and representa-
tives from Arizona, New Jersey, and Wisconsin. This Work Group
developed the framework and provided the substance for a Ground-
Water Monitoring Workshop held in April 1985. The results of
this workshop were used to formulate the Ground-Water Monitoring
Strategy. To the following persons and the staff of the Office
of Ground-Water Protection, grateful acknowledgement of their
contribution is made:
Michael Annarummo, Rhode Island Department
of Environmental Management
Walt Barber, Waste Management, Inc.
Jennie Bridge, New England Interstate Water Pollution
Larry Canter, University of Oklahoma
Edwin H. Clark, II, Conservation Foundation
Scott Cunningham, Union Carbide Corporation
Swep Davis, Environmental Testing and Certification (ETC)
Joe DeCola, USEPA, Region I Ground Water Office
Norbert Dee, USEPA Office of Ground-Water Protection
Rodney DeHan, Florida Department of Environmental Regulation
Richard H. Dreith, Shell Oil
Donald A. Duncan, South Carolina Department of Health
and Environmental Control
Alan Egler, E.I. Dupont
David Friedman, USEPA, RCRA
C.W. Fetter, University of Wisconsin
William J. B. Gburek, U.S. Department of Agriculture
James P. Gibb, Illinois State Water Survey
Clint Hall, Robert S. Kerr Environmental Research Laboratory
Maureen Hinkle, National Audubon Society
Ron Hoffer, USEPA, Office of Ground-Water Protection
Bob Holmes, USEPA, Office of Research & Development
Mark Horwitz, USEPA, Region V Ground Water Office
Susan Keith, Arizona Division of Environmental Health Services
Kevin Kessler, Wisconsin Department of Natural Resources
Tommy Knowles, Texas Department of Water Resources
William Kucharski, Pacific Power and Light
Arnold Kuzmack, USEPA, Office of Drinking Water
Robert Landers, USEPA, Superfund and Office of Research and
Development
William T. Lawhon, International Growers, Inc.
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12
Harry LeGrand, Consultant
Jay Lehr, National Water Well Association
Phil Lindenstruth, USEPA, Office of Information Resources
Management
Nancy Lopez, US Geological Survey
Duane Marshall, National Council of Air & Stream Improvement
Marian Mlay, USEPA, Office of Ground-Water Protection
Robert Michaels, Natural Resources Defense Council
Bill Mullen, USEPA, Region X Ground Water Office
Thomas J. Nicholson, US Nuclear Regulatory Commission
James E. Norris, CIBA-GEIGY
Wade Nutter, University of Georgia
Ruth Patrick, Academy of Natural Sciences, Philadelphia
Howard Reiquam, El Paso Natural Gas
Arnold Schiffman, New Jersey Department of Environmental
Protection
Geary Schindel, Kentucky Division of Water
Dave Severn, USEPA, Office of Pesticide Programs
Velma Smith, Environmental Policy Institute
Richard Spear, USEPA, Environmental Services Branch
James M. Stratta, US Army, Environmental Hygiene Agency
Jack Sutclife, Santa Clara Valley Water District
Randy Sweet, Sweet Edwards and Associates
Lynn Torak, US Geological Survey
James Tripp, Environmental Defense Fund
Peter Truitt, USEPA, Office of Management Systems and Evaluation
Burnell Vincent, USEPA, RCRA
James Wallace, Law Engineering Testing Company
Cheryl Wasserman, USEPA, Office of Compliance Analysis and
Program Operations
Gary Welch, St. Joe Minerals Corporation
Charles Whitehurst, USEPA, Office of Ground-Water Protection and
Hazardous Waste Ground-Water Task Force
Ira Whitman, Consultant
Carol Wood, USEPA, Region I Ground Water Office
Doug Yoder, Dade County Environmental Resource Management
Department
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A GROUND-WATER MONITORING STRATEGY
FOR THE
U.S. ENVIRONMENTAL PROTECTION AGENCY
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I. INTRODUCTION AND OVERVIEW
The Ground-Water Monitoring Strategy presents the Agency's
approach for improving the availability and quality of ground-
water monitoring information, enhancing its accessibility to
environmental decision makers at EPA and at the State and local
levels, and expanding monitoring to new areas of concern. The
strategy concentrates on coordinating and improving EPA's activi-
ties in monitoring ground water and in working with other Federal
agencies and the states to increase the accessibility of our
nation's ground-water database. The strategy is presented in
three chapters.
• Chapter I describes the strategy, the problem the stra-
tegy responds to, the development of the strategy, and
the relationship of the strategy to the Ground-Water
Protection Strategy.
• Chapter II describes the strategy's context, approach,
and objectives.
• Chapter III describes EPA's plan and programs for the
seven objectives over the next five years, including
both long-term goals and short-term steps.
THE PROBLEM
Ground-water monitoring in the United States is in the early
stages of development and is hampered by many problems, as has
been pointed out in the Office of Technology Assessment (OTA)
report Protecting the Nation's Ground Water from Contamination
and other technical reports. The OTA report provides an excel-
lent review of the sources of ground-water contamination and the
problems of ground-water monitoring. This review will not be
reiterated in the strategy, but the problems and issues identi-
fied in the OTA report serve as the strategy's setting.
At present, usable ground-water data are limited and often
not readily accessible; what does exist is fragmented among the
various Federal, State, and local agencies directly or peripher-
ally involved in ground-water decision making. Other than the
work conducted by the U.S. Geological Survey (USGS) on the quan-
tity of natural ground-water contaminants, there has been no
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concentrated effort at the Federal level to assess the need for
ground-water data or to plan for its collection, analysis, and
use. Such an effort needs to focus on determining who needs the
data, for what purposes they are needed, and how accessible they
are. The Ground-Water Monitoring Strategy is the Agency's first
attempt to do this on any comprehensive scale for an environ-
mental issue.
EPA'S MONITORING STRATEGY
The strategy has been prepared by the Office of Ground-Water
Protection (OGWP) in response to both the request from the Deputy
Administrator of EPA on December 23, 1983, and the request for
updated strategies from the Administrator on March 11, 1985.
In these requests, Agency management specifically called for
a Ground-Water Monitoring Strategy that would cut across all
Agency programs and address those generic problems and issues
faced by all programs. The Agency places monitoring in the fol-
lowing context:
"Environmental monitoring, defined as the broad set of acti-
vities providing . . . environmental data required by envi-
ronmental managers, is an essential part of all our activi-
ties. ... A system of credible, accurate, and correctly
applied monitoring information is essential to our overall
credibility as an Agency."
The OGWP began the development of this strategy by organi-
zing an EPA Work Group on ground-water monitoring. The group
consisted of representatives of State governments, EPA regional
and program offices, and the USGS. A workshop, built on the work
of this group, was conducted to solicit opinions from government,
industry, public interest, and academic experts on ground water
regarding the best approach for the Ground-Water Monitoring
Strategy. Results of the workshop, which was held in Washington,
D.C., on April 8-11, 1985, have been incorporated into this
document.
For the purpose of this strategy, ground-water monitoring is
broadly defined as the set of activities that provide chemical,
physical, geological, biological, and other environmental data
required by environmental managers. Under this definition, moni-
toring includes:
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• Planning the collection of ground-water data to meet
program objectives and information needs
• Designing monitoring systems and studies
• Selecting sampling sites
• Well installation
• Collecting and handling samples
• Lab analysis
• Reporting and storing data
• Assuring the quality of data
• Analyzing and interpreting data, and making it availa-
ble for use in decision making and reporting to the
public
This definition recognizes that monitoring activities take
place at hazardous waste facilities, public drinking water wells,
and other locations where people need information on ground-water
quality, quantity, and flow. The focus of monitoring activities
is, in large measure, determined by statutory mandates requiring
government agencies and the regulated community to monitor
ground-water quality. Although within this definition the term
"ground water" is defined only for the saturated zone, monitoring
activities include data collection for both the saturated and the
unsaturated zones.
RELATIONSHIP TO EPA'S GROUND-WATER PROTECTION STRATEGY
In August 1984, EPA issued its Ground-Water Protection
Strategy, which set forth EPA's approach to addressing the com-
plex and highly important issue of protecting ground water from
man-made contamination. It focused on several major objectives:
• Strengthen State ground-water programs through the
development of State institutional capabilities
• Cope with sources of ground-water contamination that
are of national concern but for which substantial
problems remain
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• Create a policy framework for guiding EPA programs that
provides greater consistency and coherence among the
programs
• Strengthen EPA's internal ground-water organization
The Ground-Water Monitoring Strategy is a major outgrowth of
the Ground-Water Protection Strategy and responds to a number of
issues raised there. For example:
Strengthen State Programs. Assisting State decision makers
to develop and gain access to ground-water monitoring data is one
major purpose of this strategy, as is providing the assistance
in a way compatible with State needs and efforts.
Cope with Contamination Sources of National Concern. The
extent and consequences of many sources of ground-water contami-
nation are not documented, making it difficult for decision
makers at any level of government to make wise decisions about
the degree of protection, control, or cleanup necessary to pro-
tect the public health and the environment. This strategy ad-
dresses how that information might be acquired and used for this
purpose.
Create Policy Framework. A differential protection policy
for ground water, as implemented in part through ground-water
classification, is at the heart of EPA's effort to provide con-
sistency in ground-water protection. This policy takes into
account the value, use, and relative vulnerability of the ground
water and depends on the availability of relevant site-specific
and regional ground-water data. The classification system can be
used to set priorities on where more ground-water monitoring data
are needed to make decisions about the various classes of ground
water.
Strengthen EPA's Internal Ground-Water Organization. The
Ground-Water Monitoring Strategy is one of several management
tools that will help EPA review (1) its approach to monitoring,
(2) the need for and use of ground-water monitoring data, and
(3) how those data can be made accessible to other environmental
decision makers.
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II. STRATEGY CONTEXT, APPROACH, AND OBJECTIVES
The Agency has recognized that current ground-water monitor-
ing activities are deficient and that significant improvements
are necessary to meet the needs of ground-water decision makers.
The Ground-Water Monitoring Strategy provides a framework for
systematically addressing the most critical monitoring needs of
the Agency.-
CONTEXT
The Ground-Water Monitoring Strategy provides a cross-Agency
analysis of the need for and use of ground-water monitoring data.
Within this approach, individual program monitoring strategies
focus on their specific program needs while the Ground-Water
Monitoring Strategy focuses on the interrelationships between
programs and on the overall direction of the Agency's ground-
water monitoring effort. Once the strategy is adopted by EPA,
each program will be expected to address those activities identi-
fied in the strategy for which it has primary responsibility.
These activities will in turn become part of the program's moni-
toring effort. Cross-Agency activities identified in the strat-
egy will be the joint responsibility of the Office of Ground-
Water Protection and the programs involved in the activities.
As the blueprint, or framework, for EPA's ground-water mon-
itoring decisions and activities, the strategy is designed to:
• Be broad in scope and not address specific details of
any program monitoring requirement
• Focus on a five-year horizon for implementation and
include both short-term and long-term action items
• Provide a balance in the implementation plan between
general action items and a detailed work plan
• Focus on solutions to the ground-water monitoring prob-
lems identified in the OTA's Protecting the Nation's
Ground Water from Contamination and other reports, and
not restate their analyses (a short problem definition
is, however, provided for each monitoring objective)
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II-2
The applications of the Ground-Water Monitoring Strategy
extend considerably beyond EPA itself. The USGS and other Fed-
eral agencies, as well as many State and local organizations, are
actively involved in ground-water monitoring. The strategy,
therefore, considers the data development capabilities as well as
the needs of a wide variety of users and producers of ground-
water monitoring data.
APPROACH
The focus of the Ground-Water Monitoring Strategy is based
on the recommendations of participants in the Ground-Water Moni-
toring Workshop, EPA program offices, and the Hazardous Waste
Ground-Water Task Force.* All the objectives identified in the
strategy are important and must be addressed to protect our
nation's ground-water resources.
The strategy emphasizes improving existing Agency activities
and filling the gaps between these activities. It does not
recommend major new monitoring efforts such as a national ground-
*0ne major potential source of ground-water contamination is
hazardous waste land disposal facilities. Under authority of
the Resource Conservation and Recovery Act (RCRA), the U.S. EPA
since 1981 has required such facilities to monitor their s,ites
for evidence of ground-water contamination. But recent EPA
studies show that many of them have not complied effectively
with the requirements. Noncompliance not only makes it dif-
ficult to ensure that facilities are performing properly, but
also limits the facilities' usefulness as depositories for
wastes taken from Superfund sites.
Because of these findings, EPA and the states have substantially
stepped up inspection and enforcement efforts. In addition, EPA
has created a special task force to investigate the adequacy of
ground-water monitoring at 58 commercial and on-site facilities
around the country that dispose of hazardous wastes on land.
Task force members include personnel from EPA headquarters and
regional offices, the states, and EPA's National Enforcement
Investigations Center. The task force has two major goals:
(1) to determine whether regulated facilities are meeting RCRA
requirements to protect ground water from contamination by
hazardous materials, including wastes from Superfund sites; and
(2) to identify and evaluate any causes of poor compliance and
recommend solutions.
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water monitoring network for the Agency; this concept was univer-
sally rejected at the Ground-Water Monitoring Workshop as unfeas-
ible and unusable. However, new ground-water monitoring activ-
ities targeted to support a specific objective, such as resource
characterization or problem identification, may be appropriate.
Because the strategy concentrates attention and resources on
improving the fundamental activities of ground-water monitoring,
it also emphasizes the need for improving the quality and manage-
ment of ground-water data collected and analyzed by or on behalf
of EPA programs.
OBJECTIVES
Monitoring of the nation's ground waters is conducted by a
variety of public and private organizations. Federal agencies
such as the USGS, U.S. EPA, and the Department of Agriculture
(USDA) collect a broad range of information on ground water
through monitoring. The types of data collected vary widely,
with USGS efforts focused on broad-based ground-water quality and
quantity data and EPA efforts generally focused on ground-water
contamination data. In addition, most states conduct ground-
water monitoring.
Several approaches to monitoring are used by these organiza-
tions to determine the impact of both natural and man-made con-
taminants on ground-water quality. These approaches include
(1) ambient monitoring to help define background information on
ground-water quality, status of the ground-water resource, and
the ground-water flow system; (2) point of contamination monitor-
ing to define the extent of contamination at Resource Conserva-
tion and Recovery Act (RCRA) sites and other hazardous waste
disposal facilities; (3) point-of-use monitoring to define con-
tamination, if any, in drinking water supplies by sampling di-
rectly from the "water tap"; and (4) a combination of the three
approaches to more completely define contamination at a partic-
ular facility or as part of a monitoring network.
Ground-water monitoring can, therefore, be described as a
continuum of activities ranging from defining background to de-
fining the performance of the waste treatment and storage facili-
ties to defining the success of EPA in protecting the ground-
water resource. To carry out these monitoring activities suc-
cessfully, the following questions must be answered:
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• Who needs the data?
• For what purpose are data needed?
• How accessible are data?
The Ground-Water Monitoring Strategy addresses this wide range of
activities through seven monitoring objectives. The first five
objectives concern the basic uses of ground-water monitoring
data: (1) characterizing the ground-water resource, (2) identi-
fying new contamination problems, (3) assessing current contamin-
ation problems, (4) assuring compliance with regulations, and
(5) evaluating the effectiveness of environmental programs. The
last two objectives encompass support activities for the first
five: (6) improving data quality and (7) improving data manage-
ment. The support objectives relate to all uses of monitoring
data and are essential for reliable and useful data.
EPA recognizes that research is an important component of
ground-water monitoring. Much effort is being devoted to ground-
water research by federal and state agencies, including EPA
through its Science Advisory Board. The Ground-Water Monitoring
Strategy identifies some areas that may require continued or
additional research activities in order to support the Strategy's
objectives. However, research has not been addressed as a
separate objective of ground-water monitoring since it has been
reviewed extensively by the Science Advisory Board. Earlier this
year, the Board outlined its recommendations for appropriate
research activities to support the Agency's ground-water
programs.
The following chapter describes the strategy's action plan,
specifying short- and long-term implementation steps for each of
the seven objectives.
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III. ACTION PLAN FOR IMPLEMENTATION
The following sections describe the activities necessary to
implement the Ground-Water Monitoring Strategy. Each of the
seven objectives is discussed separately. Since the strategy is
broad in nature, covering both the short-term and long-term as-
pects of ground-water monitoring, its implementation requires a
phased approach based upon resource availability and the timing
of activities. The strategy is built around the broad goal of
improving ground-water monitoring but focuses on the key short-
term activities needed to set the foundation for the remaining
activities.
The action plan for each objective includes three key ele-
ments. The first element defines the objective's uses and users
and describes current EPA and other Federal and State ground-
water monitoring activities and their limitations in meeting the
needs of decision makers. These limitations reflect the percep-
tion of decision makers that current monitoring activities do not
provide adequate or sufficient data to support informed and rea-
sonable decisions and that a better approach to collecting and
using monitoring information must be developed by EPA.
The second element is a description of the desired outcome
of implementing the monitoring strategy. It is presented as a
proposed solution that provides a direction or focus for the
implementation plan, i.e., the target for the next five years.
The third element describes the implementation plan for the long
and the short term, balancing general action items with a
detailed work plan.
The next step in the process will be for the programs
involved in the implementation to agree on the specific tasks
that need to be performed and the schedule for their completion.
Once these tasks are adopted by the Agency, they will become part
of each program's work plan.
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III-2
CHARACTERIZE THE NATION'S GROUND-WATER RESOURCES
1. Current Activities and Monitoring Needs
Uses and Users
This objective seeks to answer the question, What is the
nature of the ground-water resource? It involves broad-based
monitoring activities aimed primarily at collecting background
data on the ground-water resource and its setting. The data
serve as a baseline against which to assess ground-water quality
and the implications of contamination.
The results of background studies are useful in many ways.
States that have undertaken ground-water classification programs
require background data to decide where to locate the class
zones. Some states may also use the data in making siting deci-
sions for new manufacturing or hazardous waste treatment plants.
Basin studies and related water-resource investigations that
describe the hydrogeologic system within which ground water flows
are fundamental elements in the establishment of effective moni-
toring programs. In USGS water-resource investigations, for
example, hydrogeologic data are collected, analyzed, and synthe-
sized to form a conceptual model of the flow system in a study
area. This model is tested, refined, and used to evaluate the
quantity and quality of the ground-water resource. The evalua-
tion frequently involves simulation or statistical analysis- By
establishing a technically sound information base, such investi-
gations provide the hydrologic understanding necessary for the
establishment of meaningful, long-term monitoring programs.
The users of this type of monitoring information will in the
future require data on a large number of water quality param-
eters. In addition to the measures historically taken, they will
need data on organics, rate and direction of flow, soil type,
depth to ground, and geologic factors.
Environmental managers at the Federal, State, and local
levels with responsibility for the overall protection of ground
water within their jurisdictions have a need for ground-water
resource characterization data. In order to develop a workable
and justifiable ground-water protection plan, they must assess
the setting of the resource, including its use, quality, relative
vulnerability to contamination (e.g., flow, soil types, depth to
water table, rainfall), as well as the use of the land over the
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resource, e.g., landfills and surface impoundments, pesticides
and fertilizer use, location of major industrial activities, and
septic tanks.
Decisions that such managers might make include how to clas-
sify different ground-water areas, the extent of protection
required in each class, whether public or private water systems
are threatened, and whether to use land use controls, management
control technologies, or other methods to protect the resource.
Current EPA Activities
EPA does not focus its monitoring activities on resource
assessment or characterization, although EPA programs require
resource assessment information to support their activities. For
example, Superfund site investigations involve collecting inform-
ation on ground water at the site and in the surrounding region.
This information enables site investigators to identify regional
ground-water flow characteristics and thereby evaluate the extent
of local contamination and the potential for contaminant migra-
tion. Similarly, RCRA site investigators monitor around the site
to determine local flow conditions and the potential for migra-
tion of contaminated plumes. As EPA's classification system is
implemented, data on basin and subbasin hydrogeology will un-
doubtedly make a valuable contribution to characterizing re-
sources for informed decision making.
Other Federal Activities
The USGS is the principal Federal agency conducting ground-
water resource investigations, which it performs through a var-
iety of Water Resources Division programs. The Federal-State
cooperative program was developed to support hydrologic data
collection activities and water-resource investigations, with
costs shared equally by the USGS and the cooperating State and
local agencies. Much of the information used for planning, de-
veloping, and managing the nation's water resources is derived
through this program. Areas of investigation are selected
through a collaborative effort between USGS and various State
agencies. Work is performed mostly by USGS personnel, with sup-
port from outside contractors for drilling and sampling.
The USGS has also proposed a program to describe water qual-
ity on a national scale, called the National Water Quality
Assessment Program (NAWQAP). Other existing USGS activities
include the Regional Aquifer System Analysis Program (RASA),
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which focuses on describing ground-water flow and natural ground-
water chemistry in the systems; a National Water Resources Condi-
tions report is published monthly to provide information about
the availability, quantity, quality, and use of water resources;
and a Toxic Waste Ground-Water Contamination Program, which
supports regional field studies, intensive investigations, and
research focused on specific contaminants, and provides Federal
and State agencies with earth-science information that relates
land use and hydrogeology to contaminant fate in ground water.
Recent activities under RASA include studies of aquifer
systems in the northern Great Plains, the High Plains, Califor-
nia's Central Valley, and the Snake River Plain. NWRC recently
developed an information system to support the identification of
water issues, characterize current water conditions, and evaluate
the water resources assessment activities of other agencies. The
Toxic Waste Program is investigating the ground-water transport
mechanisms under field conditions for contaminants such as oil,
gasoline, organic chemicals such as TCE, sewage, and heavy
metals.
State Activities^
State water-resource investigations are conducted, to a
large extent, through the USGS Federal-State cooperative program.
Over 900 State and local agencies from all 50 states, Puerto
Rico, and the Trust Territories participate in this program.
Federal funds are appropriated by Congress and matched on a 50-50
basis by cooperating State agencies for the performance of tech-
nical-support activities and ground-water resource evaluations by
USGS personnel.
Limitations
The availability of data necessary to evaluate ground-water
quality on a national scale is limited. The problem exists for a
number of reasons, foremost of which are the large scale involved
and the physical and chemical intricacies of ground-water sys-
tems. Although a substantial quantity of ground-water data has
been collected over the years, much of it concerns inorganic
constituents and therefore is of marginal utility for evaluating
the presence of the important man-made organics and trace metals.
Moreover, most water-quality investigations have been conducted
in response to specific problems, such as point-source contamina-
tion, and therefore may not lend themselves to regional or
national interpretations.
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There are good reasons why a national ground-water monitor-
ing program does not exist today. Ground-water velocities are
low in comparison to surface-water velocities, so a contaminant
introduced into a ground-water system does not mix rapidly with
the existing water in the aquifer. Moreover, the flow paths,
concentration, and chemical evolution of the contaminant are
either unknown or difficult to ascertain. In most cases, identi-
fying the source and extent of contamination is made problemati-
cal by the complex physics and chemistry of the flow system.
This complexity can obscure correlations of water-quality data
between wells placed in the same aquifer or in aquifers that
appear to be hydraulically connected. Furthermore, information
of fundamental importance, such as details of well construction
and the physical integrity of well casings and screens, is com-
monly lacking. For these reasons, the difficulty of rectifying
current shortcomings in ground-water monitoring and achieving a
meaningful national program should not be underestimated.
2. Proposed Solution
The Ground-Water Monitoring Strategy proposes the develop-
ment of a system that adequately characterizes ground-water re-
sources and is accessible to Federal, State, and local users.
Although the USGS has the lead in developing this system, EPA
will work to ensure that the USGS data is relevant to the needs
of Federal, State, and local environmental managers.
3. Implementation Plan
The following steps will be taken by the Agency to implement
this plan:
1985-1986
• Implement the Memorandum of Understanding (MOU) between
EPA and the Department of the Interior (DOI), which
addresses the coordination between the USGS and EPA in
research, data collection, and technical assistance for
ground-water quality protection (OGWP, Regions).
• Convene high-level EPA/USGS coordinating committee to
coordinate review of USGS National Water Quality As-
sessment Program and related programs to ensure that
they support, to the extent possible, the needs of EPA
and other environmental agencies (OGWP, selected pro-
grams, Regions).
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TII-6
Convene regional EPA/USGS work groups to develop spec-
ific needs and implementation plans that consider both
national priorities and regional concerns (Regions,
OGWP).
Work with USGS to initiate activities under these
agreements, such as collecting data on organic contami-
nants in ground water, where appropriate, and incorpor-
ating this information in State and Federal databases,
as necessary (all Agency programs: OGWP coordinates).
Work with the states in the characterization of their
ground-water resources through their ground-water
monitoring strategies and state/USGS co-op program
(OGWP, USGS).
1987 and Beyond
• Continue the working relationship described above with
the USGS (OGWP).
• Develop a means of ensuring that the implementation of
the MOU takes place and is evaluated periodically.
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III-7
IDENTIFY NEW CONTAMINATION PROBLEMS
1. Current Activities and Monitoring Needs
Uses and Users
This objective seeks to answer the question, Where are the
problems? Monitoring for this objective focuses on tracking down
new problems of ground-water contamination. In this sense it is
forward-looking, with the intention of providing systematic in-
formation on the existence of previously unidentified threats to
ground-water quality.
There are two components to this objective. One is focused
on identifying threats at specific sites that may pose a danger
to ground-water supplies within a limited geographic area. The
other component is focused on identifying problems that exist on
a regional or national level in order to assess the seriousness
and extent of these problems. This latter component involves the
collection of data on ground-water problems that may persist over
broad areas and affect large populations. These may be contam-
ination problems due to certain pesticide use practices or
resulting from corrosion of underground storage tanks. Monitor-
ing to achieve this objective does not involve the collection of
broad data on the ground-water resource but rather concentrates
on collecting data at specific sites where contamination may
occur and across broad regions facing a common contamination
problem or threat.
The following examples of site-specific monitoring illus-
trate its coverage: (1) many companies have undertaken monitor-
ing to determine if one or more of their plants has caused
ground-water contamination; (2) similarly, local governments,
such as counties, cities, and towns, have initiated ground-water
monitoring to determine if their activities have led to the con-
tamination of ground water.
When addressing large-scale contamination across a wide
area, environmental managers at the Federal, State, and local
levels have the responsibility not only of reacting to existing
problems, but also of anticipating problems that may affect the
public in the future. Without obtaining information on new con-
tamination problems—whether directly from ground-water monitor-
ing or indirectly from other sources—environmental managers will
always be in a reactive mode, solving rather than anticipating
problems.
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III-8
Current EPA Activities
Several efforts to identify new problems are currently
underway at EPA. At the broad level, the RCRA program includes
ongoing efforts to identify new incidents of soil and ground-
water contamination at sites handling "non-hazardous" wastes. In
addition, studies under the Clean Water Act and Safe Drinking
Water Act (SDWA) have been used to identify new problems.
The National Pesticide Monitoring Plan also addresses the
identification of new problems. One objective of the plan is to
document the occurrence of pesticide-related illnesses and inci-
dents in order to identify emerging pesticide use and exposure
problems. Ground-water monitoring activities are an important
component of this effort and may include or be coordinated with
other ground-water monitoring activities undertaken by EPA or
other agencies.
At the site level, RCRA and Superfund are conducting invest-
igations to identify new or additional problems of ground-water
contamination. These efforts are conducted primarily at existing
facilities.
Other Federal Agencies
One objective of the USGS Federal-State cooperative program
is to provide background information for ground-water investiga-
tions. As such, this program could serve as an early-warning
system for detecting emerging broad-scale water problems. The
USGS was the first to detect Temik contamination in Rhode Island.
Other Federal monitoring activities not discussed in this docu-
ment, such as those undertaken by USDA and the Department of
Energy (DOE), could also serve this purpose.
State Activities
State and EPA monitoring activities to identify new ground-
water problems have not always been well-planned, although exam-
ples of monitoring to identify new problems emerge all the time.
Some monitoring activities have been reactionary, responding to
specific events. Other monitoring activities have been under-
taken in response to more persistent problems, such as monitoring
to identify problems in the Edwards Aquifer and the High Plains.
State agencies often initiate monitoring activities to identify
the nature and extent of aquifer contamination or depletion
through the USGS Federal-State cooperative program.
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Limitations
.Although there is a growing awareness of the need to iden-
tify new generic problems as early as possible, EPA and other
Federal and State agency monitoring activities are not organized
for or particularly effective in meeting this objective. USGS,
for example/ acknowledges that identifying new problems is not
the primary purpose of its generalized resource assessment activ-
ities. EPA's efforts, in turn, have largely focused on previ-
ously identified problems.
It is important to note that some private initiatives to
identify problems at industrial facilities have been undertaken;
however, information collected through such efforts is often
argued to be proprietary and therefore is not readily available.
2. Proposed Solution
The Ground-Water Monitoring Strategy proposes the develop-
ment of a formal process to systematically identify new, emerging
sources and types of ground-water contamination. The process
will utilize existing sources of information, such as program
offices, regional offices, states, national experts, and ground-
water monitoring, to identify these potential problems. The
focus of this objective is on improving the use of these existing
sources of information.
3. Implementation Plan
The following action steps will be undertaken by the Agency
to implement this plan:
1985-1986
• Develop a Pesticides Ground-Water Protection Strategy
(Office of Pesticide Programs [OPP], OGWP, others)
and a Toxics Ground-Water Protection Strategy (Office
of Toxic Substances [OTS], OGWP), which would identify
data-gathering and other related authorities under
the Federal Insecticide, Fungicide, and Rodenticide Act
(FIFRA) and the Toxic Substances Control Act (TSCA) to
anticipate new problems, areas particularly susceptible
to contamination, and new sources of contamination.
Problem identification would take place at both the
site and national level (OPP, OTS, OGWP).
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Develop a framework for the identification of "new"
potential problems and the setting of priorities for
future analysis or action by the Agency (OGWP).
Initiate development of new approaches to conducting
in-field investigations of both existing and "unad-
dressed" contamination sources, such as new models,
statistical approaches, measurements of the unsaturated
zone, and remote fiber spectroscopy (Office of Research
and Development [ORD]).
1987 and Beyond
• Evaluate existing data across programs to identify new
or emerging problems. EPA would work with the states
to determine areas of potential concern (Regions,
states, OGWP).
• Undertake the overview analysis of all sources of
ground-water contamination with emphasis on sources
that little is known about (OGWP).
• Continue research into measurement techniques (ORD).
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ASSESS KNOWN PROBLEMS TO SUPPORT REGULATORY
DEVELOPMENT AND STANDARD SETTING AND RESPOND
TO SITE-SPECIFIC PROBLEMS
1. Current Activities and Monitoring Needs
Uses and Users
This objective seeks to answer the questions, How serious is
the problem? and What should be done? It uses monitoring to
assess known problems—those in which ground-water contamination
has previously been identified—in order to support regulatory
and standard-setting requirements and respond to site-specific
problems. Tn contrast to Objective 2, which focuses on the
identification of problems, Objective 3 determines the source and
extent of contamination in order to formulate some action, e.g.,
site cleanup or development of a new regulation.
This type of monitoring is a common first step in responding
to certain types of broad or generic ground-water threats and the
need for regulations to address them. For example, recent atten-
tion has focused on leaking underground storage tanks, and a new
EPA-sponsored survey is underway to determine the seriousness of
this potential source of contamination.
But, as with Objective 2, monitoring to achieve this objec-
tive is not necessarily national or regional in scope. Site-
specific monitoring is also possible. For example, the objective
could include local monitoring around a municipal solid waste
landfill known to be a ground-water threat. Similarly, it could
involve a manufacturing company tracking a chemical spill or leak
by monitoring ground water to determine the fate and transport of
the materials.
Another example of this type of monitoring is the collection
of data to project the movement of plumes of contaminants in
ground water. Such monitoring is now underway at hundreds of
RCRA sites and most of the CERCLA sites on the National Priority
List.
Environmental managers at the Federal level use ground-water
quality assessments to determine (1) the extent of a given local,
State, or national problem, (2) whether it constitutes a problem
for Federal involvement, and (3) whether new or extended efforts
(e.g., studies, regulations, and legislation) should be under-
taken. Examples of this type of application include the major
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expansion of the effort by the Office of Pesticide Programs to
reassess the registration of over 100 potential leachers, to
survey the extent of current pesticide contamination in ground
water nationally, and to enlist the authorities of other statutes
and programs to respond to known incidents of contamination and
assist in assessing health effects.
Environmental managers also depend on ground-water quality
data for the development of drinking water standards under SDWA.
The level of contaminants in public drinking water systems is one
of the three principal factors used to determine a Maximum Con-
taminant Level (MCL). Measures of contaminant levels are crucial
to deciding if a given chemical occurs in drinking water with
sufficient frequency to warrant a standard.
Program managers who control certain chemical products
(e.g., pesticides and toxic substances) require ground-water
quality data to determine whether or not a chemical leaches to
ground water and the risk to human health and the environment
from its continued use. These determinations underlie decisions
to limit or ban the use of such products.
Current EPA Activities
Many activities in this area are currently underway at EPA.
Surveys and studies are being conducted by OPP and the Office of
Drinking Water (ODW) on pesticide contamination, by ODW on in-
organics and radionuclides in drinking water, by OTS on leaking
underground storage tanks, by RCRA on nonhazardous landfills, and
by the Office of Water (OW) on Publicly Owned Treatment Works
(POTW1s)/Lagoons. In addition, site assessments are conducted by
Superfund and by RCRA in their monitoring programs.
Other Federal Agencies
Agencies conducting site-specific assessments include, for
example, the Department of Defense in its programs to control and
clean up contamination on military bases (e.g., Superfund-type
sites and TCE contamination on Air Force bases).
State Activities
State environmental agencies conduct many problem assessment
monitoring activities that parallel those undertaken by EPA.
Some states actively extend monitoring programs to assess known
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problems, generally in response to specific concerns. For exam-
ple, some states have conducted monitoring at municipal landfills
to determine the extent of ground-water contamination and to
develop State-level responses to this potential problem. How-
ever, this monitoring is usually on a site-by-site basis and is
not intended to set standards or regulations.
Limitations
The principal limitation of ground-water monitoring to as-
sess known problems is the ad hoc, unplanned nature of the as-
sessment activities for broad or generic problems. Although many
such efforts are underway, they are often uncoordinated and not
always based on statistical sampling procedures. As a result,
the data are generally so specific to the study conducted that it
may be insufficient to support decision making or to guide regul-
atory action.
Moreover, new initiatives are expensive and difficult to
undertake. Planning and coordination could lead to better use of
resources, reduced costs for the collection of a given amount of
data, and better priority-setting in the selection of sites or
problems to study. Given the cost of many of these general pur-
pose studies, the efficiency question must be investigated, i.e.,
can the study serve multiple purposes?
2. Proposed Solution
The Ground-Water Monitoring Strategy proposes the develop-
ment of a formal process to systematically determine what sources
of ground-water contamination should be analyzed for further
Agency action. This formal process is a continuation of the
systematic approach for assessing new problems described in Ob-
jective 2. EPA will make use of multipurpose studies in these
decisions.
3. Implementation plan
The following action steps will be undertaken by the Agency
to implement this plan:
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1985-1986
Complete current studies (e.g., Pesticides and Drinking
Water, Drinking Water Inorganics and Radionuclides)
that assess the national occurrence of ground-water
contamination (Office of Solid Waste and Emergency
Response [OSWER], OW, OPTS, ORD).
Establish a process, through an ongoing institutional
mechanism such as the Agency operating plan, to examine
ground-water contamination problems that appear to be
of national concern in order to determine those requir-
ing a complete analysis. This process will be used to
determine whether additional large-scale study efforts
are needed, or whether sufficient knowledge exists to
deal with the contamination problem immediately
(OGWP).
Develop regulations or guidance, as appropriate, based
upon the results of these studies. OGWP will develop
technical information publications (TIPs) guidance
where no program currently has responsibility. If
sufficient data exists and studies are not needed, OGWP
will issue information documents (OSWER, OW, OPTS).
1987 and Beyond
• Implement a mechanism for the selection of problems
requiring further analysis (OGWP).
• Continue current studies on ground-water contamination
(OSWER, OW, OPP).
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ASSURE COMPLIANCE WITH REGULATIONS
1. Current Activities and Monitoring Needs
Uses and Users
Environmental programs generally require some type of moni-
toring to determine compliance. This objective seeks to answer
the question, To what extent is compliance being achieved? Moni-
toring under this objective is aimed at determining if ground-
water contamination has been or is being caused by violations of
standards or regulations. It is generally intended to lead to
initiation of enforcement or corrective action at a specific
site. The objective is broad in that it encompasses many dif-
ferent regulatory programs, yet it is narrow in that its defini-
tion is straightforward and there is little overlap with other
monitoring objectives.
There are numerous current instances of monitoring to
achieve this objective. RCRA rules, for example, require the
installation and use of ground-water monitoring wells at all per-
mitted hazardous waste landfills, surface impoundments, waste
piles, and land treatment facilities. A second example is the
3DWA requirement that community water systems monitor for various
contaminants listed in the Interim Primary Drinking Water Regula-
tions .
Program managers, permit writers, inspectors, and enforce-
ment officials who are responsible for controlling or abating the
consequences of certain sources of contamination are highly de-
pendent on ground-water monitoring data to determine if the regu-
lated community is in compliance.
The manager of regulated sites where ground-water contamina-
tion has occurred (e.g., Superfund) or might occur (e.g., lagoon,
industry with underground tanks) needs to use ground-water moni-
toring data to determine if environmental requirements are being
adhered to, if leaking has occurred, if the site is being cleaned
up, and if the contaminant is moving off-site and threatening
drinking water supplies. The success of protection or cleanup
schemes is also highly dependent on the placement of monitoring
wells and the collection of accurate monitoring data.
Managers of public water systems, which rely on ground
water, require ground-water quality data to assess the quality of
water supplies, the need for and type of treatment required to
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adhere to drinking water standards, and the action required to
avert loss of an existing water supply.
Current EPA Activities
EPA has developed numerous regulations that require ground-
water monitoring to ensure compliance. These have generally been
developed by individual program offices in response to specific
statutory requirements. A major recent focus of EPA has been on
improving compliance with RCRA regulations on ground-water moni-
toring.
Much of this monitoring is carried out by the regulated
entities themselves and not by Federal, State, or local govern-
ments. For example, the RCRA regulations require under Sub-
title C that hazardous waste landfills, surface impoundments,
waste piles, and land treatment facilities conduct ground-water
monitoring at their own sites. Similarly, regulations under the
SDWA require individual water utilities to monitor at the tap the
quality of the drinking water that is drawn from both ground-
water and surface-water sources. Other EPA ground-water monitor-
ing efforts are associated with NEPA, Construction Grants, and
the Underground Injection Program.
The ground-water quality data collected at the site or
facility are used to assess its compliance with existing regula-
tions. The data are not always reported routinely to EPA and
stored in a data management system accessible to users such as
permit writers, enforcement officials, planners, and policy
analysts.
Other Federal Activities
EPA has the primary federal role in this area. Other Feder-
al agencies that use ground-water monitoring data to ensure com-
pliance are the Nuclear Regulatory Commission, the Office of
Surface Mining, and the Department of Defense.
State Activities
Virtually all states have some active programs to monitor
compliance with ground-water protection regulations. All states
with primacy under ground-water related statutes (Clean Water Act
[CWA], RCRA, Safe Drinking Water Act [SDWA]) are involved in
ensuring compliance.
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As stated above, most of this ground-water monitoring is
conducted by the regulated entities, such as hazardous waste
commercial landfill operators, and not by State or local govern-
ments. Local officials may, however, be involved in ensuring
compliance with such ground-water protection efforts as septic-
tank and road-salting standards. In addition, some states have
required ground-water monitoring efforts under the NPDES
program.
Limitations
The most pervasive concerns about the use of ground-water
quality data to measure compliance are the lack of common stand-
ards and procedures to guide monitoring activities, the regulated
community's credibility in conducting self-monitoring, the qual-
ity and credibility of the monitoring data produced, the lack of
standards for assessing ground-water contamination, and the re-
porting of all relevant data to EPA or the states.
Many of the monitoring standards and procedures used to
define compliance, like those for all other types of monitoring,
are new and based on a science that is rapidly evolving. As a
consequence, some environmental programs require or suggest pro-
cedures while others suggest none at all, leaving the regulated
community confused about the proper method of monitoring. This
confusion extends to well drilling, sampling, and laboratory
testing protocols. Personnel may be untrained or unaware of the
most appropriate techniques or, worse yet, may not utilize them
without some compulsion.
Public concerns have been raised about the appropriateness
of self-monitoring given the high costs often associated with the
discovery of problems. Studies of RCRA sites have shown high
levels of noncompliance, where wells were never sited or sampling
never taken. However, the participants of the Ground Water Moni-
toring Workshop felt that there was no viable alternative to
having the regulated community monitor itself. Other alterna-
tives would require an enormous commitment of Federal resources.
Further, the overall quality and credibility of the data
produced for compliance purposes, as well as other purposes, is
not high. This stems, in part, from the undefined procedures,
the relative complexity of the procedures even under the best of
circumstances, and the lack of highly skilled personnel needed to
undertake this kind of work.
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The selection of ground-water contaminants to be tested at a
site depends on the program for which the samples are being col-
lected. For example, if an RCRA Interim Status site is in the
detection phase, four indicator parameters (conductivity, pH,
TOX, TOO are the primary focus of compliance testing. However,
if an RCRA site is in the assessment phase, relevant parameters
from Appendix VIII (up to 385 parameters) are required for
testing. In addition, a Superfund sample would be tested for 150
parameters and a drinking water sample would be tested for 22
parameters.
To determine whether any serious contamination exists, the
results of the laboratory tests for each of the parameters need
to be compared to a standard (MCL) or health advisory. At
present, there are 21 primary and 12 secondary MCLs that can be
used to determine the extent or seriousness of the ground-water
contamination at a site. Additional MCLs for drinking water
quality are being proposed by the Agency, and health advisories
are under development.
Ground-water quality data from some programs are not rou-
tinely provided to and stored in a data management system by the
states or EPA and, therefore, are not directly available for some
uses, such as review of permit requests, comparison of sites
having similar contamination, comparison of the effectiveness of
remedial action across various sites, emergency response to
spills, siting of new facilities, and requests from Congress and
other government agencies. Decisions in many cases are made
without the use of all ground-water quality and related data from
the relevant facilities and sites. In the RCRA Interim Status
program, for example, EPA and the states rely on the regulated
community to notify EPA only if there is a problem. Given uncer-
tain reliability of the indicator parameters (e.g., false nega-
tives), instances of ground-water contamination may go un-
detected. Significant resources are used to collect ground-water
data; if the data are not made easily available to EPA and the
states now, they will be lost to all present and future users.
2. Proposed Solution
The Ground-Water Monitoring Strategy proposes the develop-
ment of a process for the regulated community to provide EPA and
the states with scientifically defendable and verifiable ground-
water quality monitoring data that are accessible to ground-water
managers. The Agency also needs to develop standards or health
advisories to evaluate ground-water contamination (this need
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is currently being addressed by the Agency in other activities.
and will not be discussed in this Strategy).
Although many approaches were considered, it was the recom-
mendation of the participants in the Ground-Water Monitoring
Strategy Workshop that the regulated community continue to be
responsible for monitoring its facilities to determine compli-
ance. However, a verification program should be established to
enhance the credibility of the monitoring data and ensure that
monitoring is done correctly.
3. Implementation Plan
The following action steps will be undertaken by the Agency
to implement this plan:
1985-1986
• Evaluate the status of ground-water monitoring at ex-
isting commercial and on-site hazardous waste land
disposal facilities and recommend improvements in moni-
toring related to consistency with regulations, gaps in
guidance, content of training needed, technical gaps
needing research, methods of sampling and analysis,
quality assurance, etc. The evaluation is being con-
ducted by the Hazardous Waste Ground-Water Task Force
(OSWER).
• Update the Test Methods for Evaluation of Solid Waste
Physical/Chemical Methods (846 Guidance) and provide
for consistency within RCRA and Superfund (OSWER).
» Prepare a Ground-Water Monitoring Enforcement Document
to address current compliance problems and inconsisten-
cies (OSWER).
• Define a process for establishing a verification pro-
gram to ensure high-quality data—see the data quality
objective (OGWP, OSWER, ORD).
0 Concurrent with the implementation of the preceding
steps, develop a process to determine which methods/
procedures may be appropriate for Agency-wide applica-
tion or how they might be made applicable (OGWP, OSWER,
ORD).
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1987 and Beyond
• Work with the Task Force and OSWER to implement meth-
ods/procedures that have Agency-wide application (OGWP,
OSWER, ORD).
• Define a process for establishing a verification pro-
gram that addresses well installation, sampling, and
laboratory analysis and would ensure that the regulated
community will comply with the monitoring guidelines
and regulations issued by the Agency (see the data
quality objective).
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EVALUATE PROGRAM EFFECTIVENESS
1. Current Activities and Monitoring Needs
Uses and Users
The objective seeks to answer the questions, Is the program
achieving its objectives? and Are the program targets correct?
It involves collection of ground-water monitoring data to measure
regulatory effectiveness in protecting ground water. The data
can then be used to set priorities for modifying regulatory pro-
grams, rules, standards, and procedures.
Many environmental programs have as one of their goals the
protection or. improvement of ground-water quality. Such programs
include RCRA, Underground Injection Control (UIC), cleanups under
the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA), the pesticide program under FIFRA, and
State and local programs that limit road salting and regulate
septic tank use. In addition, the national and State ground-
water strategies are leading to the introduction of other actions
to protect ground water. Regulatory managers, regulated enti-
ties, and the general public are concerned with the degrae to
which each of these programs is achieving the goal of ground-
water protection or improvement. Monitoring under this objective
would provide measures of program effectiveness.
Current EPA Activities
The evaluation of program effectiveness is generally under-
taken as regulatory programs reach their mature phases (such as,
currently, the Clean Air Act (CAA) and Clean Water Act (CWA)
programs). Since ground-water-related programs are much less
mature, there are few activities to assess program effectiveness.
One example, however, is FIFRA's pesticide program, which will
use ground-water monitoring data to determine whether its pesti-
cide registration requiraments are adequate to protect ground
water from contamination.
Other Federal Activities
Other Federal agencies may use ground-water monitoring data
to evaluate program effectiveness but such activities were not
reviewed under this strategy.
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State Activities
For the same reasons as noted above for EPA programs, few
State activities use ground-water monitoring data to evaluate
program effectiveness. As State programs that protect ground
water mature, they will begin to establish effectiveness measures
and collect data needed to quantify these measures.
Limitations
The principal limitations to evaluating program effective-
ness are the lack of clear measures and the paucity of data to
use with these measures. In addition, resources have not been
devoted to program effectiveness evaluations in ground-water
protection programs as they have developed over the last several
years. This allocation of resources is the logical result of the
need to devote nearly all efforts to regulatory development and
enforcement in the early stages of new programs.
Even if additional resources were devoted to evaluating
program effectiveness, the task would not be easy. Clear meas-
ures are difficult to identify, and the data needed to use the
measures may have to be collected from new monitoring efforts.
For example, some programs are currently able to measure their
progress only in terms of dollars spent, sites "cleaned up," or
quantities of soils and contaminated materials removed. None of
these measures is adequate to determine the effectiveness of a
program in protecting ground water from further contamination.
Furthermore, ground-water data currently collected by RCRA,
Superfund, and pesticides programs are very costly to obtain and
are not being considered for use on any Agency-wide evaluation
basis. The data are not assessed from an overall framework to
evaluate the performance or the effectiveness of ground-water
protection efforts.
It is important to begin this effort now so that as ground-
water programs mature, it will be possible to evaluate their
effect. More important, these measures will allow EPA to make
any necessary mid-course corrections.
2. Proposed Solution
The Ground-Water Monitoring Strategy proposes the develop-
ment of criteria to measure the effectiveness of the Agency's
ground-water protection effort. The criteria will focus on the
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effect of EPA's efforts on our nation's ground-water resources
and not on administrative measures.
3. Implementation Plan
The following action steps will be undertaken by the Agency
to implement this plan:
1985-1986
• Initiate conceptual work to develop criteria for meas-
uring environmental results, and develop a plan for
obtaining the necessary data (OGWP, Office of Manage-
ment Systems and Evaluation [OMSE]).
• Review the data needs for the effectiveness measures
with the program offices and other Federal agencies
such as the USGS to help develop adequate data to meas-
ure results. Utilize existing data to the degree pos-
sible, and initiate new programs as required (OGWP,
OMSE),
1987 and Beyond
• Initiate the gathering of data for measuring environ-
mental results. This may include new sampling from
existing wells or new uses of existing data from these
wells (Agency programs).
• Develop a baseline to be used to assess the progress
and effectiveness of the Agency (Agency programs).
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IMPROVE DATA QUALITY
1. Current Activities and Monitoring Needs
Uses and Users
Environmental managers, regulators, environmentalists, and
legislators have to make important decisions that depend heavily
on ground-water quality monitoring. Many questions must be ad-
dressed: Is the public being appropriately protected? What is
the extent of the threat? Are the controls and cleanup appro-
priate and sufficiently protective? Reliable and defendable
ground-water quality data are essential for all decision makers
to make informed judgments about these important issues. Without
high quality data, problems of substantial proportion may be
overlooked while relatively limited problems are exaggerated.
The most fundamental requirement for all ground-water moni-
toring programs is, therefore, to implement quality controls that
ensure the data are adequate for their intended uses. While this
is true of monitoring in any medium, it is especially true in the
ground-water field where monitoring is complex and costly. Also,
because of this complexity and cost, investments in reliable
quality controls can pay some of the best returns by increasing
the likelihood of multiple uses of the monitoring.
The quality of ground-water monitoring data is affected by
several major variables:
• Well location—How was the well located? Was a site
assessment conducted when selecting the location? Is
it an up- gradient or a down-gradient location?
• Well construction—How was the well installed,
screened, and cemented? How was the sample interval
selected? How were geologic samples taken? What mate-
rials were used in the well construction? Was the
surface sealed properly?
• Sample collection and custody—How was the well purged
prior to taking the sample? What type of container was
used? What in-field analyses were run? Was the sample
fixed or preserved? How was it transported? At what
temperatures was the sample preserved? How long was it
in transit from collection to the lab? Were field
blanks used?
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• Laboratory analysis—What type of analytical procedures
were used? What analyses were run? Was the sample
split and were replicates run?
• Methods development and promulgation--There are major
gaps in the generally available, recommended methods
for ground-water monitoring. There is not a coordi-
nated, consistent set of recommended procedures across
EPA -programs for ground-water monitoring, much less
across Federal agencies and State programs. Where such
methods exist, they are in the form of "guidance,"
which cannot be used effectively or enforced, or are
geared toward a research rather than an operational
setting. In addition, these methods and procedures are
incorporated into a "game plan" that is constantly
being revised because of technological changes. This
leads to multiple directions from the Agency.
• Trained field personnel—Selection of the correct pro-
cedure from the "available" list is difficult and not
always understood by people and organizations in the
field: hydrologists, well drillers, people collecting
and transporting samples, and laboratory personnel. It
is difficult for an industry that is engaging people or
laboratories to undertake work required under Federal
programs to determine whether they are competent and to
hold them accountable if they fail. In addition, there
is a shortage of trained personnel to implement proce-
dures properly.
• Enforcing the methods—Even with the best intentions,
there is a continuing challenge to ensure that the
right methods are actually used on a day-to-day basis.
Allegations have been made that even the best labora-
tories sometimes cut corners under the pressure of
heavy workloads and tight deadlines. If that is true
in laboratories, where supervision is readily avail-
able, the problem could be even worse in well construc-
tion and sampling, which is done at remote locations
with little or no supervision.
With today's increasing emphasis on finding, assessing, and
acting upon a wide range of ground-water problems, improving data
quality is a critical need that affects ground-water monitoring
for virtually all users and uses at all levels: local, State,
and Federal. In general, improved quality increases in impor-
tance as one deals with more and more complex sampling problems,
such as those associated with volatile substances and trace
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quantities of pollutants. Improvements in quality are also vital
to enabling the broadest possible range of uses of whatever
ground-water monitoring data are actually collected and analyzed.
Current EPA Activities
Activities to improve the quality of ground-water data are
currently under way in several EPA programs. The Office of
Research and Development requires that carefully defined quality
assurance/quality control (QA/QC) protocols be-designed for all
data gathering activities (Data Quality Objectives). The Office
of Solid Waste and Emergency Response has issued technical gui-
dance for monitoring under RCRA, describing procedures for well
location, design, and construction and sample collection and
analysis.
Guidance under Superfund has also been developed, although
procedures for analyzing certain substances under Superfund regu-
lations differ from procedures under RCRA regulations. Under the
Safe Drinking Water Act, public water utilities are required to
follow well-defined procedures for securing samples and conduct-
ing lab analyses. However, no guidelines on field monitoring
procedures have been developed.
Other Federal Activities
The LJSGS's Techniques for Water Resources Investigations and
other reports provide guidance to USGS regional and district
offices on procedures for ground-water investigations. This
series is reviewed continually in order to develop procedures
that meet the needs of users of USGS data, including USGS offices
and State agencies involved in cooperative ground-water investi-
gations. Criteria for data inputs to the WATSTORE database are
currently being reviewed. No information on other Federal agen-
cies has been reviewed.
State Activities
State QA/QC procedures, where they exist, are generally
specific to each individual State monitoring program.
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Limitations
A variety of procedures and guidances are currently in place
within individual programs for ground-water quality monitoring.
However, it is not clear that these procedures are particularly
effective ways of ensuring data reliability or usefulness, or
that they are being carefully followed or enforced. Further,
procedures are not available for all programs and they differ
from program to program.
Industry representatives have reported that they "cut and
paste" ground-water quality monitoring procedures from the vari-
ous guidances and booklets available from the many different
Federal programs in order to provide their employees and contrac-
tors with protocols to follow. State officials have implored the
Agency to issue guidance with some authority on when, for exam-
ple, PVC pipe should be used, a seemingly simple yet controver-
sial decision. Others have expressed concern about standardizing
procedures that are still rapidly evolving, recognizing that once
EPA puts something into guidelines or regulations it does not
have the flexibility to make rapid changes as technologies
change.
2. Proposed Solution
The Ground-Water Monitoring Strategy proposes the develop-
ment of procedures and programs to improve the quality of data
obtained and reported by all EPA programs involved in ground-
water compliance, assessment, research, and problem identifica-
tion. High-quality data require consistency and verification in
ground-water monitoring installation, sampling, and laboratory
analysis across all EPA programs.
3. Implementation Plan
The following action steps will be undertaken by the Agency
to implement this plan:
1985-1986
o Develop a process within the Agency to ensure consis-
tency in ground-water monitoring guidance (installa-
tion, sampling, and laboratory analysis) across all
programs. The process will address who should be in-
volved, what the procedure is, how it should be done,
etc. (OGWP, program offices).
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• Develop ground-water monitoring performance measures
for installation, sampling, and laboratory analysis
(ORD).
• Define a process for establishing a verification pro-
gram for ground-water monitoring that includes all
elements of monitoring from well installation through
laboratory analysis (OGWP, OSWER, ORD, et al).
• Implement cross-Agency data quality objectives for
ground-water quality monitoring (ORD).
• Implement a training and technology assistance program
in ground-water monitoring (OSWER, ORD).
1987 and Beyond
• Work with the Hazardous Waste Ground-Water Task Force
and OSWER to consider which methods/procedures have
Agency-wide application—such as Test Methods for Eval-
uating Solid Waste (846 guidance), Ground Water Moni-
toring Enforcement Document, and Data Quality Objec-
tives (OGWP, OSWER, ORD).
• Implement verification programs within the Agency--see
objective on assuring regulatory compliance (OSWER).
• Continue research in field methods and laboratory anal-
ysis (ORD).
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DEVELOP GROUND-WATER DATA MANAGEMENT SYSTEM
1. Current Activities and Monitoring Needs
Uses and Users
This objective involves the improvement of data management.
The objective would lead to activities that improve data availa-
bility and accessibility by promoting greater compatibility bet-
ween ground-water databases.
Data management activities include determining the data to
be stored by the computer, developing protocols on data entry,
and making the data accessible to the users. Effective data
management requires that these activities be well planned and
well coordinated. Data management procedures are important in
ensuring that:
• Data are adequate and of sufficient quality to support
effective decision making
• Data are available and easily accessible
• Data are easily interpreted for analysis
Therefore, improving data management procedures will ensure
greater utility of data to decision makers and will also enhance
the ability of decision makers to evaluate threats to ground-
water supplies and develop approaches to alleviating these
threats. For EPA, improved management will mean more efficient
collection and storage of information and more effective use of
data for a variety of purposes and programs. For site assessment
and cleanup, for example, the effectiveness of various solutions
can be determined by comparing ground-water quality data from
different facilities or sites having similar contamination prob-
lems. Although site conditions may vary, the insight gained in
such a comparison is valuable. Furthermore, accessible and easy-
to-use ground-water monitoring data are crucial to the management
of the hazardous waste and Superfund programs and are important
in determining compliance and cleanup decision factors.
Two major needs in data management have been identified.
The first concerns the adequacy and completeness of the data.
The second concerns the accessibility of the data. The concern
with data completeness arises from the need for different kinds
of data, including information on testing methods, rock and soil
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characteristics, contaminants in ground water, ground-water flow
parameters, and well construction. The level of detail of this
information varies considerably among databases. The concern
with accessibility arises from the need for users of ground-water
monitoring data to receive this data in an acceptable format and
in a reasonable period of time. Users of monitoring data are
often unable to utilize data stored in other databases because of
differences in data format and/or time-consuming manipulation
necessary to transfer the data.
Current EPA Activities
EPA maintains the STORET database on the Agency's IBM
370/168 computer in Research Triangle Park. This database con-
tains water quality data for both surface and ground waters.
Data are stored for several Federal agencies and over 40 State
agencies and includes chemical, physical, biological, and radio-
chemical analyses of water samples and many other types of infor-
mation. On a monthly basis, STORET receives data from the USGS
WATSTORE data system (see "other federal activities" below) and
incorporates surface- and ground-water data from USGS-State coop-
erative investigations. STORET also receives data from some
State agencies on a regular basis; WATSTORE receives data from
states only upon request.
EPA's Office of Pesticide Programs is currently investigat-
ing the use of STORET for the National Pesticides Monitoring
Program. OPP hopes to set up several files in STORET to store
pesticide monitoring information, including data on pesticide
contamination of surface and ground waters and human and environ-
mental exposure to pesticides through these and other media. OPP
anticipates that use of STORET will significantly improve access
to nonproprietary data and also provide access to STORET's graph-
ics and statistical package capabilities. OPP plans to include
quality assurance parameters with each record so that all OPP
human and environmental exposure information is of a known quali-
ty. RCRA also has set up a protocol for the storage of RCRA
monitoring data on STORET. The Superfund program is investigat-
ing the use of STORET.
Other Federal Activities
The U.S. Geological Survey currently collects data at thou-
sands of stream-gauging stations, lakes and reservoirs, surface-
water quality stations, sediment stations, water-level observa-
tion wells, and ground-water quality wells. Each year many
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water-data collection sites are added while others are discontin-
ued; thus large amounts of diversified data, both current and
historical, are amassed by the USGS's data collection efforts.
The USGS WATSTORE system consists of files in which data are
grouped and stored by common characteristics and data collection
frequencies. Ground-water data reside in the Ground-Water Site-
Inventory file (GWSI) designed to (1) meet the need for storage
of nationally standardized ground-water data and (2) provide
nationwide computer access. GWSI contains" an inventory of wells,
springs, and other sources of ground water and includes data on
site locations and identification, geohydrologic characteristics,
well-construction history, and one-time field measurements such
as water temperature and pH. The file is designed to accommodate
nearly 300 data elements and currently contains data for 900,000
sites. Data in WATSTORE's Water-Quality File include results of
chemical, physical, biological, and radiochemical analyses of
surface and ground waters collected through USGS-State coopera-
tive investigations and other USGS, State, and local ground-water
investigations. These data are stored and made available through
STORET.
The QSGS Water Resources Scientific Information Center
(WRSIC) provides abstracts and computerized bibliographic infor-
mation on water-related scientific literature and maintains an
information base of water research in progress. The USGS also
maintains a National Water-Data Exchange (NAWDEX), an index of
water data locations used by USGS to assist users of water data
with the identification, location, and acquisition of needed
data.
USGS is now developing a National Water Information System
(NWIS), incorporating WATSTORE, WRSIC, NAWDEX, and other comput-
erized bibliographic information into a master file. Revisions
of existing systems should improve the efficiency and utilization
of USGS computer resources.
State Activities
Florida, South Carolina, Wisconsin, Texas, New Jersey,
Minnesota, Arizona, New York, Connecticut, New Hampshire, and
Rhode Island are among the many states that have developed or
are now developing ground-water databases or data management
systems. Some states enter their ground-water monitoring data
directly into STORET. Other states provide data from baseline
monitoring programs managed by the USGS and State regulatory
programs on a "request only" basis. These data are most often
requested by USGS for entry into WATSTORE.
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Limitations
STORET was designed to store parametric surface-water data
provided by EPA and other Federal agencies but was not designed
as a repository for ground-water data. Since its inception,
STORET has been modified to include ground-water data and now
receives data from the USGS WATSTORE Water Quality File on a
monthly basis. Two primary limitations of STORET are (1) the
lack: of quality control over data accepted into the system, and
(2) the absence of hydrogeologic and well data associated with
the water quality data. STORET is further limited by the lack of
standard protocols for data elements, i.e., the data entered into
the system reflect the data requirements of the investigators who
conduct monitoring rather than a prescribed set of data require-
ments for all monitoring. This may be entirely reasonable for
the parties conducting monitoring, but the result is a wide vari-
ance in the kind of data collected and stored in STORET and in-
consistent levels of detail in national ground-water data. Fur-
thermore, users of ground-water data may find it difficult to
identify useful information for a particular location, since the
data only reflects the needs of the principal ground-water in-
vestigator. Another limitation of using STORET is that data must
be specified by parameter and site location in order to be re-
trieved from the system. This makes data access time-consuming
and requires the user to specify data requirements as carefully
as possible.
As with STORET/ WATSTORE is limited for use in national
appraisals of water quality because the data are derived to a
large extent from investigations of point sources. Also, much of
the data are for inorganic constituents, whereas many of the
serious water-quality problems today are caused by man-made
organics. Finally, although WATSTORE, unlike STORET, does have a
companion system (Ground-Water Site Inventory) to describe hydro-
geology and well characteristics, the association of the two
databases is cumbersome. USGS is nearing completion of a program
to overcome this limitation.
These systems as currently constructed limit decision makers
who wish to incorporate their data into ground-water or aquifer
management, contaminant or source control, and decision enforce-
ment or evaluation.
2. Proposed Solution
The Ground-Water Monitoring Strategy proposes the develop-
ment of a Ground-Water Data Management System for storing all
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ground-water quality and related well information so that the
data can be made easily accessible to ground-water managers for
permitting, planning, compliance, and enforcement. This Ground-
Water Data Management System will build upon existing information
systems at EPA and other Federal agencies.
3. Implementation Plan
The following action steps will be undertaken by the Agency
to implement this plan:
1985-1986
• Perform a requirements analysis to identify more
specifically the users and uses of ground-water data
and the types of data needed by the users. Compile
results for use in development of a Ground-Water Data
Management System for the Agency (OGWP, Office of
Information and Resource Management [OIRM]).
• Develop and implement a short-term approach for manage-
ment of ground-water data until the results of the
requirements analysis can be implemented. Initial
review indicates that a revised STORET will meet the
short-term needs of ground-water data management (OGWP,
OIRM, OSWER).
• Initiate interagency discussions on data management to
provide consistency across the agencies, with particu-
lar emphasis on the USGS data management system (OGWP,
OIRM).
• Provide technology assistance in data management to
states (Regions, OGWP).
1987 and Beyond
• Draft and finalize a Ground-Water Data Management Sys-
tem based upon the requirements analysis (OIRM, OGWP,
OSWER).
• Construct, install, and pilot test the Ground-Water
Data Management System (OIRM, OGWP, OSWER).
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Complete system documentation and hold seminars and
user-oriented workshops to transfer technology to user
community (Regions, OGWP).
Establish institutional linkage with other Federal and
State agencies for data sharing (Regions, OGWP).
S. Government Printing Office 1986—620-458/40660
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