United States
Environmental Protection
Agency
Office Of
The Administrator
(WH-550G)
21Z-1020
July 1991
SEPA
Protecting The Nation's
Ground Water:
EPA's Strategy For The 1990s
The Final Report Of The
EPA Ground-Water Task Force
Comprehensive Ground-Water Protection
Printed on Recycled Paper
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
JUN 2 8 1991
OFFICE OF
THE ADMINISTRATOR
Dear Friends:
Ground-water resources are of vital importance to this country - to the health of our citizens, the integrity
of many of our ecosystems, and the vigor of our economy. We must make every effort to protect the quality of
these resources, which are increasingly threatened by a variety of human activities from industrial by-products,
to excessive use of agricultural chemicals, to faulty business operations, and to improper disposal of household
wastes.
In 1984, the Environmental Protection Agency (EPA) issued a Ground-Water Protection Strategy which
articulated what was known about protecting ground-water resources and set out an appropriate role for the
Agency. Over the last several years, EPA and the States have made significant strides under the Agency's 1984
Strategy. Last year, the time was right to take a hard look at the Agency's ground-water protection efforts, and
to develop a more integrated approach for moving forward with this issue in the 1990s. We formed an EPA
Ground-Water Task Force of senior Agency managers from all offices with ground-water related responsibilities
to develop recommendations for providing a more integrated and effective approach to comprehensive protection
of ground-water resources. Significant input was provided to the Task Force by State and local governments,
other Federal agencies, environmentalists, industry, and public interest groups.
The outcome of this review is the report "Protecting the Nation's Ground Water: EPA's Strategy for the
1990s." This report states Agency policy, accompanied by implementation principles that reflect an aggressive
approach to protecting the Nation's ground-water resources; they will guide the course of EPA and State efforts
over the coming years. The policy puts clear priority on preventing ground-water contamination, recognizes that
ground water is a uniquely local resource for which States and local governments must assume primary
responsibility, and strives to improve EPA's coordination of ground-water activities under all our statutes and
programs. This policy will be reflected in EPA programs and resource allocations as we continue our partnership
with State and local governments, private industry and the public in addressing this issue.
Protecting our ground-water resources is one of the most complex environmental issues we face in the
1990s. With over 50 percent of the population relying on ground water as their primary source of drinking water,
and the recent EPA Science Advisory Board report which ranks the contamination of drinking water as one of the
higher risks to human health, we cannot delay protecting this resource. This Task Force Report reflects the
accomplishments and experience of the States and EPA over the last few years. Under this new and integrated
cross-program framework for action, we can all work together to ensure that this vital resource is available for use
by the present and future generations.
Sincerely
William K. Reilly
Administrator
Printed on Recycled Paper
-------
Contents
Page
Executive Summary 1
Part A: EPA's Ground-Water Protection Principles 5
Part B: The Federal/State Relationship in Ground-Water
Protection 9
Part C: EPA's Approach to Implementation 23
Part D: Agency Policy on EPA's Use of Quality Standards
in Ground-Water Prevention and Remediation
Activities 31
Part E: Ground-Water Data Management
Summary and Recommendations 33
Part F: ORD Ground-Water Research Plan 61
-------
Executive Summary
Background
A number of Federal
statutes provide EPA with
the authority to prevent and
control sources of ground-
water contamination, as well
as to clean up existing
contamination. During the
early 1980s, EPA recognized
that these authorities to
protect ground water were
fragmented among many
different statutes and were
largely undefined. As a
result, in 1984 the Agency
adopted a Ground-Water
Protection Strategy to
articulate both the problem
and EPA's role in a national
ground-water protection
program. Under this
Strategy, the Agency has
focused its efforts on four
major objectives:
• Building State capacity;
• Addressing sources of
contamination;
• Establishing ground-water
policy direction and
program consistency; and
• Coordinating EPA
programs
While this strategy was
effective in creating
momentum for States to
develop and implement
ground-water programs, the
passage of time and growing
body of experience indicated
that gaps remained in
protection efforts across the
country. It became clear
that there was a need to
assess our progress and
adjust our approach to take
into account recent changes
in statutory authorities and
our increased knowledge of
the issue by promoting
comprehensive protection on
the State and local level.1
In July 1989, EPA
Administrator William Reilly
established a Ground-Water
Task Force, chaired by
Deputy Administrator F.
Henry Habicht II, to review
the Agency's ground-water
protection program and to
develop concrete principles
and objectives to ensure
effective and consistent
decision-making in all
Agency decisions affecting
the resource. The Task
Force included membership
from all Headquarters offices
with ground-water protection
responsibilities and selected
Regional representation.
Several work groups were
created to develop recom-
mendations on issues of
special interest. In addition,
a substantial outreach effort
succeeded in obtaining input
on two key issues Agency
principles and the character
of the Federal/State
relationship from major
Federal, State, local, public
interest, industry and
agricultural leadership
groups and the Governors
and agency officials of all
States.
The outcomes of this
effort are policy and
implementation principles
that are intended to set forth
an aggressive approach to
protecting the nation's
ground-water resources and
direct the course of the
Agency's efforts over the
coming years. It will be
reflected in EPA policies,
programs, and resource
allocations, which will guide
EPA, States and local
governments, and other
parties with whom we work
in carrying out the Agency's
ground-water responsibil-
ities. This approach is
characterized by:
1 Under Federal statutes and EPA policy, Indian Tribes may be recognized as States for the purpose of
operating national environmental programs. Throughout this report, references to States also refer to
Tribal governments as well as the U.S. Territories.
-------
Protecting the Nation's Ground Water
Executive Summary
• Clear Statement of Policy:
This document sets forth a
clear statement of Agency
policy, which will serve as a
decision-making framework
for all Agency programs
relating to the ground-water
resource.
• Focus on Comprehensive
Resource Management:
This policy builds on current
State activities by providing
financial incentives for filling
in gaps in protection efforts
and building comprehensive
protection programs on the
State level. Under this
resource-based approach to
protection, States are to take
into account the total impact
of all sources of contamina-
tion as well as the unique
hydrogeologic features of
their resource. A critical
first step in developing and
implementing protection
programs and setting priori-
ties is to ensure that
currently used and reason-
ably expected sources, of
drinking water do not
present adverse health risks.
• Emphasis on Prevention
of Ground-Water Contami-
nation: Under this policy,
the Agency will place an
increased emphasis on
prevention of ground-water
contamination and strive to
achieve a greater balance
between prevention and
remediation activities.
• Clear Federal and State
Roles: EPA's policy clearly
articulates the principles
defining the EPA/State
relationship in ground-water
protection and provides for
developing the framework on
the State level for inte-
grating Federal and State
actions relating to the
resource.
• Adequacy of State
Programs: The Agency's
new policy describes EPA's
intention to refine over the
next year the definition of
the elements of a State
Ground-Water Protection
Program, and how each of
the elements must be
addressed to develop a pro-
gram that is "adequate" to
comprehensively protect a
State's resource. It also
describes how EPA will work
to provide greater flexibility
to a State in implementing
Agency programs when that
State has achieved an
"adequate" ground-water
protection program which
affords comprehensive
protection of the resource.
• EPA Oversight: In
keeping with the recognition
that States will develop and
implement their own unique
but adequate programs, EPA
oversight in the Agency's
ground-water related
programs will shift from a
program-specific basis to a
cross-program, resource-
based approach to be further
defined over the coming
year.
• Coordinated Funding: In
contrast with Agency
tradition, EPA will shift
from a traditional grants
mode into one characterized
by coordinated management
of current ground-water
related grants and the
incentive of increased
funding for States showing
progress with comprehensive
protection of the resource.
Documents to Guide
the Agency's Future
Agenda
A. EPA's Ground-Water
Protection Principles — This
document establishes that
the "overall goal of EPA's
Ground-Water Policy is to
prevent adverse effects to
human health and the
environment, and to protect
-------
Protecting the Nation's Ground Water
Executive Summary
the environmental integrity
of the nation's ground-water
resources." It also states
that,"... in determining
appropriate prevention and
protection strategies, EPA
will also consider the use,
value, and vulnerability of
the resource, as well as
social and economic values."
Additionally, the document
establishes principles related
to prevention, remediation,
and Federal, State and local
responsibilities.
B. The Federal/State
Relationship in Ground-Water
Protection — This document
contains an initial section
that outlines the broadly
applicable principles of the
Federal/State relationship,
e.g., the role of the States
and EPA, and the impor-
tance of resource-based
prevention efforts. This
document also includes a
second section that describes
EPA's new approach for
promoting comprehensive
protection of the resource
and provides a list of the
program elements commonly
found in "mature" State
ground-water protection
programs that provide
comprehensive protection of
the resource. This document
serves as an initial
framework for future work
in this area. In 1991, EPA
will hold workshops around
the country to provide the
Agency with State input on
both further refining the
elements and their descrip-
tions and on defining an
"adequate" State program.
In 1992, EPA will work with
each State to complete a
profile of its ground-water
protection programs based
on the final elements and
criteria for adequacy. These
profiles will identify gaps in
State programs and will
serve as the basis for grant
agreements for the States'
FY 1993 program efforts.
3
-------
Protecting the Nation's Ground Water
Executive Summary
C. EPA's Approach to
Implementation — This
section describes the specific
roles and responsibilities of
EPA program offices, both
in Headquarters and the
Regional Offices, in
implementing the Ground-
Water Protection Principles
and ensuring the develop-
ment and implementation of
State ground-water
programs, which will provide
comprehensive protection
(Parts A and B of the
report). It also describes the
initial implementation
actions the Agency will take
over the next few years.
D. Agency Policy on EPA's
Use of Quality Standards in
Ground-Water Prevention and
Remediation Activities — This
policy statement describes
how EPA will use maximum
contaminant levels (MCLs)
under the Safe Drinking
Water Act and water quality
standards (WQSs) under the
Clean Water Act as "refer-
ence points" in carrying out
ground-water programs. It
also describes how these
reference points will be
applied differently in
prevention and remediation
activities.
E. Ground-Water Data
Management — This
document discusses the
status of EPA's ground-
water data availability,
accessibility, and utilization.
It discusses how data
collected by EPA and others
are used in ground-water
planning and decision-
making at the Federal, State,
and local levels. Several
specific recommendations for
improvement developed by
the Task Force follow. Also,
an extensive computer and
data system modernization
effort now being undertaken
by EPA's Office of Informa-
tion Resources Management,
should result in a substantial
improvement in the avail-
ability and utility of ground-
water data over the coming
years. In FY 1991 the
Agency is moving ahead with
this initiative as well as
recommendations relating to
data consistency, quality and
automation, accessibility, and
data utilization.
F. Office of Research and
Development (ORD) Ground-
Water Research Plan — This
document describes the
research EPA plans to
undertake over the coming
years in response to the
needs of Agency programs.
It discusses research
activities needed to provide
the scientific knowledge base
for successfully preventing
and remediating ground-
water contamination. In FY
1991 and beyond, ORD will
conduct new research and
technology transfer relating
to three key areas of the
Agency's ground-water
protection efforts: the
Wellhead Protection
Program; State information
systems for preventing
ground-water contamination
from pesticides; and,
subsurface cleanup and
mobilization processes.
•
'
- :
ii
-------
Part A
EPA's Ground-Water
Protection Principles
The overall goal of EPA's Ground-Water Policy is to prevent adverse effects
to human health and the environment and to protect the environmental
integrity of the nation's ground-water resources; in determining appropriate
prevention and protection strategies, EPA will also consider the use, value,
and vulnerability of the resource, as well as social and economic values.
• In all events, EPA will execute this goal and the principles below in accordance with
Federal law.
• Adverse effects mean those risks that are significant to the affected population and
determined to be unreasonable where appropriate under relevant statute.
• EPA's fundamental premise is that the attainment of this goal is necessary to achieve
the sustainability of the resource and closely hydrologically connected surface water
systems, not just for the near term but for the future as well.
• In addition, because ground-water cleanup is extremely costly, and usually difficult and
in some cases impossible to achieve and demonstrate, EPA's goal is to emphasize
prevention of pollution where appropriate.
In order to achieve this goal, the Agency's principles are:
WITH RESPECT TO PREVENTION:
* Ground water should be protected to ensure that the nation's currently
used and reasonably expected drinking water supplies, both public and
private, do not present adverse health risks and are preserved for present
and future generations.
+ Ground water should also be protected to ensure that ground water that is
closely hydrologically connected to surface waters does not interfere with
the attainment of surface water quality standards, which is necessary to
protect the integrity of associated ecosystems.
4 Ground-water protection can be achieved through a variety of means
including: pollution prevention programs; source controls; siting controls;
the designation of wellhead protection areas and future public water supply
areas; and the protection of aquifer recharge areas. Efforts to protect
ground water must also consider the use, value, and vulnerability of the
resource, as well as social and economic values.
-------
Protecting the Nation's Ground Water EPA's Ground-Water Protection Principles
• Ground water is a uniquely local resource due to the ease with which small sources
can affect it, and the impact that use and hydrologic characteristics (e.g. vulnerability)
can have on its quality. As such, ground-water programs will require an appropriate
blend of several protection methods.
WITH RESPECT TO REMEDIATION:
* Ground-water remediation activities must be prioritized to limit the risk of
adverse effects to human health first and then to restore currently used
and reasonably expected sources of drinking water and ground water
closely hydrologically connected to surface waters, whenever such
restorations are practicable and attainable.
• Given the costs and technical limitations associated with ground-water cleanup, a
framework should be established that ensures the environmental and public health
benefit of each dollar spent is maximized. Thus, in making remediation decisions, EPA
must take a realistic approach to restoration based upon actual and reasonably
expected uses of the resource as well as social and economic values.
• In an ideal world of unlimited funds, prioritization would be unnecessary. However,
because resources do not permit all contamination to be addressed at once, the need
for prioritization must be recognized.
• Moreover, given the expense and technical difficulties associated with ground-water
remediation, EPA is emphasizing early detection and monitoring so that it can address
the appropriate steps to control and remediate the risk of adverse effects to human
health and the environment.
WITH RESPECT TO FEDERAL, STATE, AND LOCAL
RESPONSIBILITIES:
* The primary responsibility for coordinating and implementing ground-
water protection programs has always been and should continue to be
vested with the States. An effective ground-water protection program
should link Federal, State, and local activities into a coherent and
coordinated plan of action.
« EPA should continue to improve coordination of ground-water protection
efforts within the Agency and with other Federal agencies with ground-
water responsibilities.
-------
Protecting the Nation's Ground Water EPA's Ground-Water Protection Principles
Since ground water in any given area may be subject to contamination from a wide
variety of point and non-point source activities, coherence and coordination in any plan
of action are vitally important. EPA must ensure that the ground-water protection
programs it implements under the Clean Water Act (CWA), the Resource Conservation
and Recovery Act (RCRA), the Safe Drinking Water Act (SDWA), the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA), and the Federal
Insecticide, Fungicide, and Rodenticide Act (FIFRA), and the research programs that it
funds under these Acts, are directed toward achieving the principles outlined above. In
the design and timing of regulatory initiatives, EPA will address the highest risks. In
addition, the authority of each State to allocate water within its jurisdiction should not
be abrogated.
Given the uniquely local nature of ground-water pollution and use, the States and
localities must have primary responsibility for assessing and prioritizing risks to the
resource and for implementing programs to protect the resource within each state so
that it is available for various uses. However, where specific Federal responsibilities
are provided for under the law, the requirements of the law must prevail.
Not only must Federal, State, and local activities be linked to form a coherent plan of
action; but air, water, and land practices, to the extent practicable, must also be
examined in an integrated fashion to ensure protection of the ground-water resource.
-------
Part B
The Federal/State Relationship
In Ground-Water Protection
Background
Since the adoption of the
Agency's 1984 Ground-
Water Protection Strategy,
EPA has been providing
technical and financial
assistance under the Clean
Water Act to build State
capacity to protect ground
water in a comprehensive
manner. Further, EPA has
been implementing several
source-specific statutes that
protect and cleanup ground
water.
Over the last few years,
States have made significant
strides in developing and
implementing ground-water
protection strategies. Yet,
both the States and EPA
recognize that much remains
to be done to ensure
comprehensive protection of
the nation's ground-water
resource. State ground-
water programs vary consid-
erably from one State to
another and are often a
patchwork of Federal, State
and local source control
efforts, focusing on
individual sources of
contamination rather than
the resource as a whole.
Source control programs
tend to focus on sources that
present significant risks on a
national basis, but may not
represent the most impor-
tant threats at the local level
to either drinking water
supplies (and, therefore,
human health) or ground-
water recharge to aquatic
ecosystems. Many nonpoint
and small, dispersed sources
remain unaddressed and
commercial, residential, and
industrial development often
occurs with no recognition
of long-term impacts on the
quality of ground water.
As a result of the work of
the recent Agency Task
Force, beginning in FY 1992,
EPA will take a more
strategic approach to actively
assisting States in compre-
hensively protecting their
ground-water resources. The
Task Force identified the
need for EPA to step up its
efforts to coordinate more
fully Agency programs and
authorities at the EPA
Regional and Headquarters
levels, to help States build
comprehensive, integrated
programs that protect the
ground-water resource, to
provide a framework for
coordinating multiple
Federal programs and
activities at the State and
local level, and to make
optimum use of EPA grant
authorities to promote
Federal and State program
coordination.
The purpose of this
report is to set in motion a
more fully coordinated EPA
effort based on existing
Agency authorities. EPA
recognizes that, because of
the timing of this document,
the Regions and States have
already completed much of
the planning and negotia-
tions for ground-water
activities to be carried out in
FY 1992. To the maximum
extent possible, however,
EPA will work with the
States to promote aggressive
implementation in FY 1992
through vehicles such as
Regional grant amendments
and technical assistance.
This document consists of
three main sections: the
first section describes the
broadly applicable principles
of the Federal/State relation-
ship; the second describes
EPA's support of a new
comprehensive approach
which relies on State
Ground-Water Protection
Programs; and the third
section lists possible
elements of such State
programs, which are based in
large part on discussions
held with members of the
Administrator's State/EPA
Operations Committee.
Principles Defining
the Federal/State
Relationship
In preparing this report, the
Agency used "EPA's
Ground-Water Protection
Principles" as a starting
point for defining the
Federal/State relationship in
ground-water protection (see
Part A). The Agency
-------
Protecting the Nation's Ground Water
The Federal/State Relationship
believes, however, that there
are additional broadly-
applicable principles of this
relationship that need to be
set forth as well. They
include:
• State Role is Critical:
The Agency believes that
while EPA will continue its
role in controlling major
sources of contamination,
the States should retain the
primary responsibility for the
management and protection
of the ground-water resource
and in addressing diffuse
sources of pollution. Such
management may require
decisions about ground-water
allocation and land use
which are appropriately the
province of State and local
government. EPA should
support States in developing
ground-water protection
programs that adequately
protect the resource as well
as the framework for State/
EPA relations.
• Resource-Based Efforts:
States and EPA should
emphasize a resource-based
approach to protection, in
addition to the current
source control programs.
Under this approach, the
total impact of all sources of
contamination, as well as the
unique hydrogeologic
features of the resource,
should be taken into account
in developing and
implementing protection
programs. Further, in
addition to protecting
current drinking water
supplies, States should
designate ground waters for
protection that are
reasonably expected to be
drinking water supplies,
taking into account such
factors as: remoteness,
quality, cost of protection,
future growth and
population patterns, and the
availability and cost of
alternative water supplies.
• Emphasis on Prevention
and Sustainability: In
general, the Federal/State
relationship should be
structured so that ground-
water protection efforts are
enhanced and coordinated.
• Scientific and Economic
Research: EPA should
continue to conduct
scientific and economic
research on various aspects
of ground-water protection,
and provide standard setting
information to the States.
This includes developing
maximum contaminant
levels/maximum contaminant
level goals which relate to
health concerns, water
quality criteria which relate
to ecological concerns, risk
assessment information, fate
and transport data, and
information on the economic
10
-------
Protecting the Nation's Ground Water
The Federal/State Relationship
values and tradeoffs involved
in protection activities.
• Federal Consistency:
EPA should strive for
consistency among Federal
agencies and programs with
ground-water protection
responsibilities. For
example, the Agency intends
to work with the U.S.
Department of Agriculture
(USDA) to develop a joint
strategy for addressing issues
affecting the agriculture
community through the
ongoing USD A/EPA Work
Group on Water Quality.
Further, mechanisms should
be established or better
utilized for coordinating with
Department of Interior
(DOI), Department of
Energy (DOE), National
Oceanic and Atmospheric
Administration (NOAA),
Department of Defense
(DOD), and other Federal
agencies with ground-water
responsibilities.
• The Roles of Federal and
State Government in
Regulating Specific Sources
of Contamination Should be
Based on the Following
Factors:
1. In general, State and
local governments should
play the prominent regulatory
role. This is especially
appropriate when: a) the
activities of concern are
numerous (e.g., 23 million
septic tanks) or highly
localized (e.g., vary in impact
and number from State to
State) and nationally present
a low to medium risk poten-
tial; b) when land-use
management is a principal
protection approach; and,
c) when technologies cur-
rently exist or are easily
developed to address the
problem. Further, State and
local governments should
play the primary role in the
implementation of Federally-
mandated ground-water
protection regulations.
2. EPA should take a
prominent regulatory role as
currently authorized by law
when: a) there is a need to
establish regulatory con-
sistency (e.g., to limit
adverse impacts on interstate
commerce); b) when the
scope of the effort requires
national resources (e.g.,
research, regulations
addressing technically
complex environmental
problems); c) when State-by-
State efforts would create
unwarranted and inefficient
duplication (e.g., bans,
research); and, d) when
national security is involved
(e.g., the disposal of
radioactive waste).
• Differential Protection:
In implementing EPA pro-
grams, the Agency should
continue its policy of taking
into account the use, value,
and vulnerability of the
resource as well as other
social and economic values
in decisions affecting ground
water. This is necessary to
achieve EPA's overall
ground-water policy goal of
preventing adverse effects to
human health and the
environment and protecting
the environmental integrity
of the nation's ground-water
resources.
• Voluntary Approaches:
EPA should encourage
States to pursue voluntary,
nonregulatory approaches to
protecting the resource. For
example, the Agency is
currently working with
USDA under the President's
Water Quality Initiative to
involve States in fostering
effective prevention
approaches with the
agriculture sector.
State Ground-Water
Programs That
Provide Compre-
hensive Protection:
EPA intends to promote the
development and implemen-
tation of State Ground-
Water Protection Programs
(SGWPP) designed to
provide comprehensive
protection of the resource
and the framework to
coordinate programs and
activities under Federal,
State and local statutes and
11
-------
Protecting the Nation's Ground Water
The Federal/State Relationship
ordinances. A core premise
is recognition of the primary
State role in designing and
implementing programs to
protect the resource
consistent with distinctive
local needs and conditions.
This generally means that
EPA will provide broad
national guidance and use
financial incentives to
promote action. The Agency
recognizes that protecting
the ground water is a unique
and complex environmental
issue that requires a new,
non-traditional approach.
Clearly, a nationally
prescriptive program is not
appropriate; risk taking and
innovation are to be
rewarded.
• Over the next six months,
the Agency will hold, in each
Region, roundtable
discussions. State Directors
of Environmental Agencies
as well as State ground-water
program directors will meet
with EPA to reach
agreement on the elements
of a State program, which
would provide compre-
hensive protection; a
definition of the range of
"adequate" State programs;
and an EPA review process.
• Over the next year, EPA
will continue ongoing work
with the States to profile
and assess current State
ground-water protection
activities to obtain a
baseline of information and
help States identify gaps in
their current ground-water
protection programs. This
two-stage profile process
includes developing an
objective description of
current State activities and
then working with the State
in conducting a self-
assessment of its activities to
identify areas in need of
further work. A State's
current efforts will be
compared with the elements
of, and adequacy criteria for,
a comprehensive program
developed, in part, through
the roundtables process
described above. This
baseline information will be
used by the EPA Regional
offices in supporting State
efforts to develop and
implement programs that
provide comprehensive
ground-water protection.
Regional priorities,
milestones, and commit-
ments for the Agency's
ground-water related
programs will be set in a way
that are consistent with
individual State's needs and
circumstances.
• As States move toward
designing and achieving a
comprehensive approach to
protection of the resource,
EPA will review and concur
in ground-water quality
protection programs
submitted by the States.
The review will focus on
"adequacy" instead of
"consistency" - the threshold
question will not be whether
a State's program is
consistent with EPA criteria,
but whether a program falls
within a range deemed
"adequate" to protect a
State's ground-water
resource. The Agency, in
collaboration with the States,
will define a range of ways
to achieve "adequacy" rather
than one prescriptive
definition.
• EPA's review of State
programs will be flexible and
take into account the unique
characteristics of each State,
as well as the different
stages of development of
each State program. The
process will be interactive
and iterative, with the States
and EPA working together.
It will focus on assessing
programs to identify gaps
and providing EPA technical
and financial assistance to
States to address the gaps.
• The purpose of the
process of determining
adequacy is not to judge or
evaluate a State program in
a "pass/fail" manner, or
determine that a State's
program is "inadequate" if it
does not meet the criteria
EPA has developed in
conjunction with the States.
Rather, it is meant to be a
process in which EPA works
with States to help them fill
i:
-------
Protecting the Nation's Ground Water
The Federal/State Relationship
in gaps in State ground-
water protection programs.
The intent being to bring
these programs to a point
where the States are fully
capable of comprehensively
protecting the ground-water
resource, given an individual
State's particular needs and
circumstances. When EPA
can determine that a State
has reached this point, EPA
will seek to defer to State
standards, priorities, and
programs to the extent
authorized under Federal
statutes.
• EPA's non-concurrence of
a State's Ground-Water
Protection Program will not
imply inadequacy of specific
source management
programs and efforts within
the State either being
conducted or approved by
EPA or other Federal
agencies. However, non-
concurrence of a State's
Program could result from a
State not taking responsi-
bility for an expected role in
the implementation of
specific source management
programs or efforts.
• Using current ground-
water related grants, EPA
will support the development
and implementation of State
Ground-Water Protection
Programs designed for
comprehensive protection of
the resource. While all
States will initially be
eligible for funds, the
Agency, working with the
States, will define a range of
program characteristics that
will be used to assess State
progress toward achieving an
"adequate" comprehensive
program. Exemplary State
programs will receive an
increasing share of the
grants, while States showing
little or no progress will
receive reduced grant
amounts. Further, for States
with an "adequate" program,
the Agency oversight process
will focus less on defining
and overseeing individual
State actions and more on
the overall effect of the
program in comprehensively
protecting ground water.
States that elect not to
participate in the process
will not be able to avail
themselves of certain EPA
financial and oversight
benefits.
• To the extent authorized
by EPA statute and consis-
tent with Agency program
implementation objectives,
EPA will defer to State
policies, priorities, and
standards once a State has
developed an "adequate"
program. For States that
develop adequate State
ground-water protection
programs, EPA's policy will
be to look to or "defer to"
State policies, priorities, and
standards. Under this policy
of deference, EPA will study
and identify ways in which
the Agency can defer to
State decisions in imple-
menting Agency programs.
Implementation of this
policy for States with an
adequate ground-water
protection program will take
several forms.
— First, EPA will identify
ways to provide States
with greater flexibility to
target enforcement and
permitting activities
consistent with the States'
own policies and
priorities.
— Second, EPA will
establish policies for
reducing routine Agency
oversight of State
programs affecting ground
water.
— Third, in its development
of regulations and
guidance, EPA will
explore ways in which it
can provide for deference
to State ground-water
standards, regulations, or
policies. To the extent
authorized by EPA
statutes and consistent
with Agency program
implementation
objectives, EPA will
provide for consideration
of or deference to State
standards, regulations, and
policies. EPA statutes
generally provide that
Federally promulgated
13
-------
Protecting the Nation's Ground Water
The Federal/State Relationship
standards or regulations
serve as minimum levels
of protection. These
statutes, however,
generally reserve to the
States the authority to
adopt more stringent
standards or regulations.
Therefore, States already
have a significant role in
establishing applicable
standards for EPA
programs. The
Comprehensive
Environmental Response,
Compensation and
Liability Act (CERCLA)
is an excellent example of
a statute that provides an
important role for States
in decision-making.2
Finally, where State
regulations, standards or
policies would provide for
less stringent protection
than EPA regulations,
standards or policies,
there may be statutory or
regulatory prohibitions to
deferring to the State.
EPA, however, is
committed to exploring
opportunities for
providing for deference to
State regulations,
standards or policies as
authorized by EPA
statutes and consistent
with Agency program
implementation
objectives.
Common Elements of
"Mature" Ground-
Water Protection
Programs
As part of its role in
promoting development of
State programs that will
provide comprehensive
ground-water protection, the
Agency, in collaboration
with the States, will
determine over the next year
the key elements of a State
program.
Because of each State's
unique hydrogeological
characteristics and condi-
tions, the character of a
program that provides
comprehensive ground-water
- With some limitations, CERCLA provides significant opportunities for EPA to adopt State requirements
as part of CERCLA cleanup actions. Whether or not CERCLA cleanups would be based on provisions
of a State ground-water protection program depends first on whether the plan includes "ARARs." As
defined in section 121(d)(2) of CERCLA, ARARs are "applicable or relevant and appropriate
requirements" of other Federal or State environmental laws. For a State law requirement to be ARAR, it
must be promulgated (i.e., of general applicability and legally enforceable, see section 300.400(g)(4) (1990)
of the National Contingency Plan), substantive rather than administrative (see 55 Fed. Reg. 8756-57,
March 8, 1990), identified in a timely manner, and more stringent than the Federal standard (section
300.400(g)(4) (1990)). Where a State requirement is not directly applicable, EPA has discretion to find
the requirement to be ARAR because it is "relevant and appropriate" to circumstances at the site. Where
State standards include substantive requirements that are ARARs, the CERCLA remedy would be
required to meet or waive them. ARARs may be waived in six limited circumstances, such as where it is
impracticable to attain them, or for State standards, where the standard has not been consistently applied
(sec CERCLA section 121(d)(4)). Under CERCLA, where State plans, policies or guidelines do not
qualify as ARARs, EPA may nevertheless treat them as provisions "to be considered" ("TBCs") with
respect to the cleanup plan. TBCs would be evaluated and justified on a site-specific basis. The recently
revised NCP, in implementing CERCLA's cleanup program, demonstrates EPA's commitment to
providing a significant role for States in decision-making.
14
-------
Protecting the Nation's Ground Water
The Federal/State Relationship
resource protection will not
be identical in all States.
EPA will provide States with
great flexibility in addressing
the elements of a compre-
hensive program. A list of
elements commonly found in
"mature" ground-water
programs is provided below,
including a narrative
description of each element.
Using this universe of
potential elements, EPA, in
collaboration with the States,
will develop over the coming
year, a final set of elements
and adequacy criteria for
each element of a State
program that provides
comprehensive protection
for the ground-water
resource.
SETTING GOALS AND
DOCUMENTING
PROGRESS
• Ground-Water Protection
Goal which Accounts for
Present and Future Uses of
the Resource. The ground-
water protection goal is in
harmony with the national
ground-water protection goal
and the goal is established in
State statute. The ground-
water protection goal
accounts for present and
reasonably expected future
ground-water uses.
• Yearly Action Plan for
Achieving the Goal, which
Includes a Mechanism for
Evaluating Progress Toward
the Goal and Provides for
Periodic Review. The State
has an action plan that
describes how the State will
achieve its comprehensive
protection goal. The action
plan outlines outcomes that
are needed to assure that the
resource protection goal is
achieved; a process for
reaching those outcomes;
short- and long-term time-
tables, milestones, and
measures of progress; and
parties responsible for
achieving desired outcomes.
Usually, the plan reflects the
diverse authorities available
to the State to achieve its
goal, including land-use
authorities, public health
authorities, and enforcement
authorities.
CHARACTERIZING THE
RESOURCE AND SETTING
PRIORITIES FOR
ACTIONS
• Comprehensive Assess-
ment of Aquifer Systems for
Ground-Water Protection
Purposes. The State has an
ongoing, effective program
that provides basic infor-
mation on the occurrence,
movement, and quality of
ground-water resources
within its borders. This
program utilizes and inte-
grates the information
available from State geologi-
cal surveys, as well as
ongoing Federal assessment
and mapping programs, such
as those available from the
USGS and Soil Conservation
Service.
• Procedure for Inventory-
ing and Ranking Potential
Sources of Contamination
that May Cause an Adverse
Effect on Human Health or
Ecological Systems. The
State has a program for
identifying the existence,
location, and relative
magnitude/risk of anthro-
pogenic and natural threats
to ground-water quality.
The program is capable of:
(1) identifying specific
categories of activities which
pose threats to the quality of
the resource, (2) locating
geographic areas where such
threats/sources are
concentrated, and (3)
15
-------
Protecting the Nation's Ground Water
The Federal/State Relationship
identifying specific source
locations, facilities, plumes,
etc., deemed to pose a threat
to public health and or the
environment.
• Process Used for Setting
Priorities for Actions Taken
to Protect or Remediate the
Resource, Such as a Use
Designation/Classification
Scheme that Considers Use,
Value, Vulnerability, Yield,
and Current Quality, Includ-
ing Wellhead Protection and
Cost Benefit Analysis. The
State balances the timing,
ordering, and extent of
protection activity develop-
ment and implementation
based on a scheme that
reflects the risk to ground-
water quality, human health,
and ecosystem maintenance.
Prioritization schemes reflect
resource characterization
and source inventory efforts.
The State is encouraged to
adopt prioritization schemes
that consider such factors as
resource use and potential
use for drinking water and
other purposes, resource
sensitivity to contamination,
and the tradeoffs in cost and/
or effectiveness between
protection and remediation
options. Prioritization
schemes incorporate
priorities established in
Federal environmental
statutes.
DEVELOPING AND
IMPLEMENTING
PREVENTION AND
CONTROL PROGRAMS
• A Coordinated Pollution
Prevention and Source
Reduction Program Aimed
at Reducing and Eliminating
the Amount of Pollution that
Could Affect Ground Water.
A program to reduce and
eliminate the amount of
pollution that could poten-
tially affect ground water
with techniques, such as
wellhead and recharge area
protection programs, siting
criteria, improved manage-
ment practices and technol-
ogy standards, etc.
• Enforceable Quality
Standards that are Health
Based for Drinking Water
Supplies and Ecologically
Based in Areas Where
Ground Water is Closely
Hydrologically Connected to
Surface Water. Legally
defensible and enforceable
quality standards that could
be based on MCLs (or EPA
Health Advisory levels) for
drinking water and on
surface water quality criteria
established under the Clean
Water Act for ground water
closely hydrologically
connected to surface water
are a part of a comprehen-
sive program. In applying
standards, States should
distinguish between
prevention and remediation
activities - EPA's policy on
the use of quality standards
in ground-water prevention
and remediation activities is
one approach to which the
States can refer. (Note: It is
the State's prerogative to
determine whether to estab-
lish its own standards or to
use EPA's for actions under
State law.)
• Regulatory and Non-
regulatory Authorities to
Control Sources of
Contamination Under State
or Local Jurisdiction; e.g.,
Permitting, Siting, and
Zoning Authorities. The
State has authorities
necessary to manage the
contaminant sources
characterized in Element
Two. The State has received
or is making progress toward
receiving delegation of
EPA's contaminant control
programs. Regulatory and
nonregulatory authorities are
sufficient to control
additional sources of
contamination under State
or local jurisdiction. These
-------
Protecting the Nation's Ground Water
The Federal/State Relationship
authorities include, but are
not limited to, permitting
authorities; controls on
activities such as transport
regulations and facility
design standards; and land-
use regulations (e.g., zoning)
that limit where, when, how,
and if certain activities may
occur. Implementation and
enforcement authorities are
vested in local governments
where appropriate.
• Remediation Program
which Dovetails With RCRA
and Superfund and Sets
Priorities for Action
According to Risk. The
State has or is developing a
remediation program that
adequately addresses those
potential polluting activities
and sites not already covered
by EPA's remediation pro-
grams (e.g., hazardous waste
treatment, storage, and
disposal facilities — including
solid waste management
units at such facilities) and
sites not on the National
Priorities List.
• Monitoring, Data Collec-
tion, and Data Analysis
Activities to Determine the
Extent of Contamination,
Update Control Strategies
and Assess Any Needed
Changes in Order to Achieve
the State's own Ground-
Water Protection Goal. The
State's information
management activities
include the collection,
laboratory analysis, storage,
retrieval, and analysis of
ground-water data. The
State has a program to
ensure that the data
collected within the State are
consistent, of known and
reliable quality, and are
efficiently stored for retrieval
17
-------
Protecting the Nation's Ground Water
The Federal/State Relationship
and use. This data are
readily accessible to State
and local agencies for use in
analysis and decision making
such as ground-water
protection planning,
enforcement, trend analysis,
permitting and other
activities.
• Compliance and Enforce-
ment Authorities Given to
the Appropriate State and
Local Officials Through
Legislative or Administrative
Processes. Compliance
monitoring and enforcement
authorities are adequately
delegated to the appropriate
State and local officials.
• Water Well Program,
Including Private Drinking
Water Wells, Covering Areas
Such as Well Testing, Driller
Certification, Well Construc-
tion, and Plugging Aban-
doned Wells. The State has
standards for water well
construction, testing, and
driller certification to ensure
that wells are drilled and
finished in a manner that is
protective of public health.
These standards include both
public and private drinking
water wells. Additionally,
the State provides well
closure standards to ensure
that abandoned wells will
not act as conduits into
drinking water aquifers for
contaminants.
• Statement of How
Federal, State, and Local
Resources will be used to
Adequately Fund the
Program. The State
adequately funds and staffs
the Program. There is a
good match between
available revenues and
proposed expenditures.
• Public Participation
Activities to Involve the
Public in the Development
and Implementation of the
Program. The public is
involved in the development,
review, and implementation
of the Program.
DEFINING ROLES
WITHIN THE STATE, AND
THE RELATIONSHIP TO
FEDERAL PROGRAMS
• Delineation of State
Agencies' Responsibilities in
the Ground-Water Program
Covering Areas Such as
Planning, Implementation,
Enforcement, and Coordina-
tion. The State delineates
the responsibilities of State
agencies in planning, imple-
menting, enforcing, and
coordinating the Program.
The designation of a lead
agency, or formally estab-
lished institutional structure,
with responsibility for
coordinating program
implementation is recom-
mended. The State
addresses these issues with
respect to interstate and
regional organizations, if
applicable.
• Statement Indicating How
the State Will or Does
Provide Local Governments
With Authorities to Address
Local Ground-Water Protec-
tion Issues. The State
provides local governments
with the authorities to
address local ground-water
protection issues. The State
encourages local agency
involvement in all aspects of
ground-water protection,
including technical
assistance, training, and
financial assistance.
HAZARDOUS MATERIALS
REMOVAL PROJECT
' t.fO PESSOHNEV OMY
18
-------
Protecting the Nation's Ground Water
The Federal/State Relationship
• Statement of the State's
Role Under Ground-Water
Related EPA Statutes
Including RCRA, CERCLA,
SDWA, CWA, and FIFRA --
e.g. EPA-approved programs
such as RCRA authorization
should be listed and
integrated as part of the
State's overall ground-water
protection program yet
continue operating as free-
standing programs. The
State carries out its
responsibilities in delegated
and authorized Federal
programs. For any program
for which the State has not
been delegated implementa-
tion authority, the State is
striving to get such
delegation.
• Mechanisms for Dealing
with Other Federal Agencies
that Affect State Ground-
Water Programs Including
MOUs and Other Formal
Agreements. The State's
Program provides for
coordination with other
Federal Agencies that affect
State ground-water programs
(e.g., USDA, DOI, DOD).
• Statement Indicating How
the State Intends to
Integrate Water Quantity
and Quality Management.
The State addresses methods
that it will use to minimize
the impacts of ground-water
withdrawals on ground-water
quality. The approach
includes coordination
between the Stale agencies
responsible for quantity
management and quality
management.
• Coordination of Ground-
Water Programs with other
Relevant Natural Resource
Protection Programs,
Including Surface Water
Management. The State has
a mechanism for coordi-
nating and integrating the
planning and implementa-
tion of all State, local, and
Federal activities affecting
ground water. The
mechanism might include
commissions or task forces
that use inter-departmental
staff from all State and
Federal regulatory agencies,
including staff from agencies
not usually associated with
ground-water protection,
such as community develop-
ment and public works.
19
-------
Protecting the Nation's Ground Water
The Federal/State Relationship
TABLE 1
COMMON ELEMENTS OF "MATURE"
GROUND-WATER PROTECTION PROGRAMS
Setting Goals and Documenting Progress
» Ground-water protection goal which accounts for
present and future uses of the resource.
» Yearly action plan for achieving the goal, which
includes a mechanism for evaluating progress toward
accomplishing the goal and provides for periodic
Characterizing the Resource and Setting
Priorities for Actions
» Comprehensive assessment of aquifer systems and
their associated recharge and discharge areas.
» Procedure for inventorying and ranking potential
sources of contamination that may cause an adverse
effect on human health, or ecological systems.
» Process used for setting priorities for actions taken
to protect or remediate the resource, such as a use
designation/classification scheme that considers use,
value, vulnerability, yield, current quality, etc.,
including wellhead protection and cost benefit
analyses.
Developing and Implementing Prevention and
Control Programs
» A coordinated pollution prevention and source
reduction program aimed at eliminating and reducing
the amount of pollution that could potentially affect
ground water, including wellhead and recharge area
protection programs, siting criteria, improved
management practices and technology standards, etc.
» Enforceable quality standards that are health based
for drinking water supplies and ecologically based in
areas where ground water is closely hydrologically
connected to surface water (Note: For actions under
State law that are independent of any Federally
authorized program, it is the State's prerogative to
determine whether to establish its own standards or
to use EPA's standards).
» Regulatory and nonregulatory authorities to control
sources of contamination currently under State or
local jurisdictions, e.g., permitting, siting and zoning
authorities on the State and local level.
•» Remediation program that dovetails with RCRA and
Superfund and sets priorities for action according to
risk.
» Monitoring, data collection, and data analysis
activities to determine the extent of contamination,
update control strategies and assess any needed
changes in order to meet the ground-water
protection goal.
» Compliance and enforcement authorities given to
the appropriate State and local officials through
legislative or administrative processes.
» Water well programs, including private drinking
water wells, covering areas such as well testing,
driller certification, well construction, and plugging
abandoned wells.
* Statement of how Federal, State and local
resources will be used to adequately fund the
program.
# Public participation activities to involve the public
in the development and implementation of the
program.
Defining Roles Within the State and the
Relationship to Federal Programs
» Delineation of State agencies' responsibilities in
the ground-water program covering areas such as
planning, implementation, enforcement and
coordination.
« Statement indicating how the State will or does
provide local governments with authorities to
address local ground-water protection issues.
» Statement of the State's role under ground-water
related EPA statutes, including RCRA, CERCLA,
SDWA, CWA, and FIFRA, e.g., EPA-approved
programs such as a RCRA authorization should be
listed and integrated as part of the State's overall
ground-water protection program yet continue
operating as free-standing programs.
» Mechanisms for dealing with other Federal
agencies that affect State ground-water programs
(e.g., MOUs or other arrangements with USDA,
DOI, DOD).
» Statement indicating how the State intends to
integrate water quantity and quality management.
* Coordination of ground-water programs with other
relevant natural 'resource protection programs,
including surface water management.
21
-------
Part C
EPA's Approach to
Implementation
Headquarters Roles
and Responsibilities:
An ongoing Ground-Water
Policy Committee will be
established to oversee the
implementation of the
Agency "Ground-Water
Principles" and the State
Ground-Water Protection
Program. It will develop
overall program'policy
direction and integration and
work to improve coordina-
tion with other Federal
agencies. It will be co-
chaired by the Deputy
Assistant Administrator
(DAA) for Water and the
lead Deputy Regional
Administrator (DRA) for
Pesticides, RCRA, or
Superfund. Further, a
mechanism for providing
ongoing State input into this
effort will be established.
The Policy Committee will
function in the following
way:
Co-chair: DAA for Water
and Lead Regional DRA for
Pesticides, RCRA or
Superfund.
Membership: DAAs,
selected DRAs, key office
directors, and selected
regional division directors.
Responsibilities: to develop
overall program policy
direction and oversee
implementation of both the
integration effort within
EPA and the work with the
States and other Federal
agencies. This will include
carrying out an ongoing
active outreach effort to seek
the views and concerns of
both the States and Federal
agencies in implementing
this report and developing a
coordination plan for work-
ing with Federal agencies.
The Policy Committee will
report semi-annually to the
Deputy Administrator (DA)
and/or the Assistant Admini-
strators and Regional
Administrators.
Implementation Workgroups
will be formed as necessary
to develop policy and
program operations propos-
als and to support the Policy
Committee in the overall
direction of the effort.
These implementation
workgroups will be chaired
by selected representatives of
the DAAs as well as key
office director and regional
division directors. The
implementation workgroups
will include:
• A ground-water "regulatory
cluster" implementation
workgroup to coordinate
upcoming ground-water related
decisions made across
regulations, offices, and media.
The cluster approach will
help ensure that the
Ground-Water Principles
guide all Agency regulatory
actions relating to the
resource and help provide
for integration and con-
sistency in the development
of EPA regulations required
under Federal statutes. The
workgroup will develop a
work plan for the cluster
covering such topics as: the
coverage and timing for each
action; cross-cutting issues
that should be addressed or
resolved; effects of decisions
on one action for others in
the cluster. The key focus of
the cluster activity will be to
determine the appropriate-
ness of deferring to a
comprehensive State
Ground-Water Protection
Program (SGWPP) under
each regulation.
• A State Adequacy I
Oversight Implementation
Workgroup to support
implementation of the
comprehensive SGWPP
concept. This workgroup will
focus on finalizing the list
and definitions of the
elements of a State ground-
water protection program
that will result in
comprehensive protection of
the resource and the
adequacy criteria for each of
these elements. The
subcommittee will also
recommend the procedures
for EPA review and
concurrence of State
programs as well as the
Agency's continuing
oversight role. This
subcommittee will have
23
-------
Protecting the Nation's Ground Water
EPA's Approach to Implementation
primary responsibility for
ensuring State input into all
activities of the Ground-
Water Policy Committee.
• A Ground-Water Resources
and Program Implementation
Workgroup to address cross-
Agency ground-water related
resource, grants, and program
operating guidance issues.
This workgroup will work to
ensure that the Agency's
ground-water related
programs are supporting,
through annual operating
guidances and grant
guidances, the development
of State ground-water
programs that provide
comprehensive protection of
the resource. It will also
focus on developing a budget
strategy for supporting State
ground-water related needs
and priorities across Agency
programs.
Regional Office Roles
and Responsibilities:
Regional Offices will place
the authority for annual
planning and evaluation of
the EPA Ground-Water
Protection Program at the
DRA level. Each Region
should establish, or continue
to use its existing ground-
water coordinating
committee, chaired by the
DRA and composed of key
regional division directors.
The Regions will be
responsible for ensuring that
State officials are actively
involved in Regional
activities associated with
implementing this strategy.
The responsibility for
carrying out integrated
planning on a day-to-day
basis should be placed at the
division director level.
Regional responsibilities
include:
• Reviewing all activities of
the various programs with
respect to their impact on or
contribution to, the develop-
ment ofSGWPPs which
provide comprehensive
protection of the resource.
Such activities would include
assessing the use of available
program funding sources to
implement comprehensive
SGWPPs.
• Establishing specific
priorities, milestones, and
commitments for all programs.
The objective to support and
acknowledge SGWPPs that
meet certain adequacy
criteria redefines the basic
relationship between EPA
and the States with respect
to ground water. This
relationship requires a
change in the process
through which priorities are
set. It also requires
flexibility by EPA regarding
each program's requirements
and performance measures.
This shift, from a
predominantly source
control emphasis to a more
resource-focussed viewpoint,
will first require identifi-
cation of the institutional
barriers to change such as
the Agency's Strategic
Targeted Activities for
Results System (STARS)
and other management
controls. It is expected that
this shift will be fully
reflected in Regional
Strategic Plans, STARS and
other management tools by
1993.
• Utilizing available
resources in each program in a
creative and integrated manner
to build comprehensive State
programs, through the
development of Agency
operating guidance and the
identification of specific
initiatives which support
implementation of
comprehensive SGWPPs. The
SGWPPs will be used to
guide implementation of
EPA programs in each State.
For example, a special
Regional/Stale initiative
could be developed which
would allow relief from a
certain percentage of
STARS commitments for a
program in order to shift
resources to higher priority
activities that would better
meet the objective of
comprehensive protection of
the ground-water resource.
24
-------
Protecting the Nation's Ground Water
EPA's Approach to Implementation
• Establishing an integrated
State/EPA planning process in
order to reach agreement on
specific milestones and joint
commitments for action. The
first step in this new
planning process is the
ongoing development of
State profiles and self-
assessments, including State/
EPA workshops on how to
define "adequacy" as a basis
for approving State
programs and directing
additional Federal support
to each State for
development of a SGWPP.
• Conducting regular annual
evaluations of State, Regional,
and Headquarters progress in
implementing SGWPPs with a
process for revision and
planning. Through their
strategic plans, mid-year
reviews, and other planning
and evaluation efforts,
Regional offices should seek
continual improvement in
each program's responsive-
ness to joint State/EPA
milestones and agreements.
Initially, all programs should
be directed to look at how
they may do things different-
ly in response to this effort.
Specifically, how can
development of comprehen-
sive SGWPPs help each
program in what it does.
Some examples are:
— A coordinated Regional/
State data management
effort to allow more effective
reporting under State 305(b)
and other environmental
indicator reports.
— A comprehensive State
mapping effort to locate all
water wells, especially public
water supply wells, using the
same geolocator data
element (latitude/longitude)
to ease assessments of the
proximity to sources of
contamination. Aggressive
implementation of the
Agency's minimum data
element set must take place
in order to assure that
contaminant source locations
are consistently provided.
— A comprehensive State
vulnerability assessment
effort that can assist in
developing State Pesticide
Management Plans; targeting
mitigation measures under
State Nonpoint Source
Management Plans; and
prioritizing ground-water
areas for geographically-
targeted education;
permitting; enforcement and
clean up efforts across all
ground-water related
programs.
— A Geographic Enforce-
ment Initiative, integrating
all programs and selected
through a joint State/EPA
planning process, which
seeks to address a high
priority ground-water area.
25
-------
Protecting the Nation's Ground Water
EPA's Approach to Implementation
EPA/State Implemen-
tation: First Phase
1991-1993:
EPA intends to strengthen
the impressive progress the
States have made over the
last few years by helping
them build on their current
programs and providing
them with the financial,
technical, and management
tools to do so. The
cornerstone of this approach
is an increased EPA focus
on assisting States in
identifying and filling in gaps
in their current programs
and developing a mechanism
for integrating separate
programs and setting
priorities. This approach
will rely on coordinating
multiple ground-water related
grant authorities to help
States develop and
implement comprehensive,
resource-based programs.
This approach signals that
we are moving toward a truly
integrated program.
• As a demonstration that
EPA is pulling together all Us
programs and authorities to
achieve substantial progress
under existing legislative
authorities, the Agency will
promote EPA and State
program coordination in FY
1992. Based on an inventory
of potential funding sources
(see Table 2), Regions will
be asked to look creatively
at the inventory and to fully
explore ways to tie these
sources of Agency grant
funding together and/or
work out mutual work plans.
Potential options for
awarding grants to States
include one or more of the
following:
— Encourage each EPA
Regional program with
ground-water responsibil-
ities, under the leadership of
the Deputy Regional
Administrators (DRAs), to
participate in and contribute
resources for the purpose of
creating a formal ground-
water coordinating
mechanism in each State,
which will be responsible for
addressing the issues of
comprehensive State
program development,
program integration, and
priority setting.
— Profile current State
programs, based on a list of
elements of a comprehensive
protection program, to
establish a more detailed
information on current State
programs and to determine
where EPA and State priori-
ties intersect in order to
help direct EPA funding.
While all of the elements of
a State protection program
are important to an ade-
quate State program that
comprehensively protects the
ground-water resource,
three elements are of special
importance for States to
effectively implement
existing EPA requirements.
These particular elements
are of interest and concern
to Congress and other key
groups. Consequently, EPA
is encouraging Regions and
States to give special
attention to the following
three critical State program
elements in FT 1992:
(1) Establishing a formal
mechanism for
coordinating
authorities and
programs under various
EPA statutes;
26
-------
Protecting the Nation's Ground Water
EPA's Approach to Implementation
(2) Identifying the most
valuable, vulnerable
aquifers; and
(3) Evaluating or ranking
the highest priority
sources of
contamination.
Many State programs may
already adequately address
these three elements, while
others may need improve-
ment in one or more of the
areas.
— As an example of creative
grantsmanship, the Pesticides
and Ground-Water Programs
issued FY 1990 grant guid-
ance under the CWA
(Section 106) and FIFRA
grants to encourage States to
develop pesticide manage-
ment plans, clearly
integrating the activities
under each grant to promote
a coordinated approach
among State agencies.
While most other EPA/State
grant negotiations are well
underway and it is difficult
to make changes at this
point in time, Regions and
States are encouraged to use
mid-year grant amendments
to implement this model
and/or pursue other creative
grant mechanisms in FY
1992, with special emphasis
on accomplishing one or
more of the objectives
outlined above.
• By the end of 1991,
roundtable discussions will be
held in each Region to provide
the Agency with State input on
several key issues: (1) how to
fully define the list of
comprehensive program
elements; (2) how to
determine "adequacy" for
concurring with and funding
comprehensive protection
programs; and (3) how to
oversee State programs.
• In FYs 1992 and 1993,
the Agency will work to
institute enhanced and
integrated management of the
State Program effort —
including greater integration of
the management of grant
resources. During FY 1992
and 1993, the Agency's
current ground-water related
grants will be awarded to
States based on existing
allocation formulas including
any increased resources that
may be appropriated for the
program - starting in FY
1994, however, States
showing exemplary progress
toward achieving compre-
hensive protection and other
objectives of their
comprehensive programs will
receive increased amounts,
while States showing little or
no progress will receive
lower grant amounts. Once
the elements of a State
protection program are fully
defined and EPA and the
States reach closure on how
to determine adequacy, they
will serve as the basis for
determining whether a State
program is adequate to
achieve comprehensive
protection of its ground-
water resources and for
making adjustments to grant
amounts accordingly.
27
-------
Protecting the Nation's Ground Water
EPA's Approach to Implementation
TABLE 2
EPA's GROUND-WATER RELATED GRANTS
Statutory
Authority
Match
ELIGIBLE ACTIVITIES
LIPrFATIQNS
*
FY 91 $
APPfiOPfllATlON
CLEAN WATER ACT
106
104(b)
(3)
205(g)
2050) (1)
604(b)
205Q) (5)
201(g)
(1)(b)
319(h)
319(1)
None
None
None
None
None
40%
50%
General: Prevention & abatement of surface &
ground-water pollution.
Specific: Permitting, pollution control studies,
planning, surveillance & enforcement, assistance
to locals, training, & public information.
General: Pollution prevention, reduction, &
elimination programs.
Specific: Research, experiments, training,
demonstrations, surveys, studies, investigations.
Delegated administration of construction grants
program, 402 or 404 permit program, 208(b)(4)
planning program, & construction grants
management for small communities.
Develop water quality management plans.
Develop & implement nonpoint source
management programs.
Implement nonpoint source management
programs.
Carry out ground-water protection activities.
Allotment based on
extent of pollution
problem, not the
quality of the State
program. No
authorization ceiling
in FY91 .
Not for program
operation.
Not for
implementation; 40%
to regional
comprehensive
planning agencies.
201(g)(1)(b):
Construction grant
deobligations and
reallotment funds
available.
No more than 15%
of total available to
any one State.
Financial assistance
for demonstrations
only (cannot be
used for cost
sharing programs).
Limits on
administrative costs.
$150K per State.
$81.7 million
(Ground-water
portion: $12.2m)
$16.5 million
0
(Congress cut
off funding)
0
$16 million
0
(Congress cut
off funding)
$51 million
See 319(h)
-------
Protecting the Nation's Ground Water
EPA's Approach to Implementation
TABLE 2 (continued)
EPA's GROUND-WATER RELATED GRANTS
Stalutwy
Authority
Match
ELIGIBLE ACTIVITIES
LIMITATIONS
*
FYSH $
APPROPRIATION
FEDERAL INSECTICIDE, FUNGICIDE AND RODENTICIDE ACT
23(a)(1)
15%
General: Implement pesticide enforcement
programs.
$26.8 million
(Ground-water
portion: $5m)
TOXIC SUBSTANCES CONTROL ACT
28
25%
General: Establish & operate toxics control
programs.
Specific: Monitoring, analysis, surveillance &
general program activities (currently used for
asbestos & SARA Title III activities).
Authorization
expired in 1982.
Appropriations
committees should
be notified before
funds are used for
new ground-water
program.
$8.1 million
RESOURCE CONSERVATION AND RECOVERY ACT
3011
25%
General: State hazardous waste management
programs.
Specific: Planning for hazardous waste treatment,
storage & disposal facilities.
$83 million
SAFE DRINKING WATER ACT
1443(a)
1443(b)
25%
25%
Public water system supervision; State drinking
water programs.
General: Underground injection control programs.
Specific: Program costs, inventories, data
management, technical assistance, etc.
Funds available only
to States with
primacy.
Funds available only
to States with
primacy.
$47.5 million
$10.5 million
COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION & LIABILITY ACT
104(b)
10%
General: Superfund activities under core program
cooperative agreements.
Specific: Implementation, coordination,
enforcement, training, community relations, site
inventory and assessment, administration of
remedial activities, legal assistance relating to
CERCLA implementation.
Not for site-specific
activities.
$14 million
* Authorities in this matrix may be used to fund ground-water activities either in separate categorical grants or consolidated grants. Further, the
scope of eligible ground-water activities varies among authorities. Regions should consult their Grants Management Office and Regional
Counsel regarding these issues.
29
-------
Part D
Agency Policy on EPA's
Use of Quality Standards
in Ground-Water Prevention
and Remediation Activities
The purpose of this policy statement is to describe the approach the Agency will use
in making specific decisions with quality standards when carrying out EPA's ground-
water related statutory responsibilities.
When EPA is carrying out
its programs, the Agency will
use maximum contaminant
levels (MCLs) under the
Safe Drinking Water Act, as
"reference points" for water
resource protection efforts
when the ground water in
question is a potential
source of drinking water.
Water quality standards,
under the Clean Water Act,
will be used as reference
points when ground water is
closely hydrologically
connected to surface water
ecological systems. Where
MCLs are not available,
EPA Health Advisory
numbers or other approved
health-based levels are
recommended as the point
of reference. If such
numbers are not available,
reference points may be
derived from the health-
effects literature where
appropriate. In certain
cases, maximum contaminant
level goals (MCLGs) under
the Safe Drinking Water
Act, or background levels
may be used in order to
comply with Federal
statutory requirements.
Reference points are to be
applied differently for
prevention and cleanup
purposes.
• Prevention: Best
technologies and
management practices
should be relied on to
protect ground water to the
maximum extent practicable.
Detection of a percentage of
the reference point at an
appropriate monitoring
location would then be used
to trigger consideration of
additional action (e.g.,
additional monitoring;
restricting, limiting use or
banning the use of a
pesticide). Reaching the
MCL or other appropriate
reference point would be
considered a failure of
prevention.
• Cleanup: Remediation
will generally attempt to
achieve a total lifetime
cancer risk level in the range
of 10-4 to 10-6 and
exposures to non-carcino-
gens below appropriate
reference doses. More
stringent measures may be
selected based on such
factors as the cumulative
effect of multiple contami-
nants, exposure from other
pathways, and unusual
population sensitivities.
Less stringent measures than
the reference point may be
selected where authorized by
law, based on such factors as
technological practicality,
adverse environmental
impacts of remediation
measures, cost and low
likelihood of potential use.
31
-------
Part E
Ground-Water Data Management
Summary and Recommendations
Background
Over the last few years,
the management of ground-
water data in support of the
nation's ground-water
protection efforts has
become increasingly more
complex. Agency programs
addressing ground-water
protection have grown,
cross-program integration
has increased, and the sheer
volume of data that is
required and collected and
has to be managed, has
expanded significantly.
The Ground-Water Task
Force Subcommittee on
Data Management's Report
titled "Ground-Water Data
Collection, Accessibility, and
Utilization" was transmitted
to the Ground-Water Task
Force on October 25, 1990.
The complete document
follows this summary. It
discusses the many issues
that programs are facing as
they manage ground-water
data for decision making.
This document represents a
consensus of the programs
involved in data management
As a result of the issues
identified in the Report, and
in the context of a Ground-
Water Task Force
Subcommittee meeting held
on May 25, 1990, the Task
Force is making several
recommendations to address
Agency needs with respect to
ground-water data
consistency, quality, and
automation; ground-water
data accessibility; and
ground-water data
utilization: geographic
information systems (GIS)
and other applications.
Recommendations
Over the last several years
there have been many
successes in ground-water
data management by the
program Offices and OIRM.
In addition, each of these
Offices have additional data
management activities under
development. However,
most of these efforts are
focused on program specific
needs and not on the
integration across the
programs to develop a
comprehensive approach to
data management.
Therefore, the following
recommendations are
proposed to build upon what
has already been
accomplished and to fill in
the gaps created by the need
for cross program
integration.
Resources must be
provided for implementation
of these recommendations
because at the present time
there are no Regional data
management resources
similar to those available for
air or surface water data
management to implement a
ground-water data
management effort. A
corresponding budget
initiative is being developed
by Headquarters for the
Regions and Headquarters.
• Ground-Water Data
Consistency, Quality, and
Automation Recommendation:
Each Region should
develop a cross-program
policy on integrating and
improving the management
and use of ground-water data
within the Region.
Each Regional policy
would address but not be
limited to program needs,
data quality, automation, and
usage of the data for
decision making. This
Regional policy would be
consistent with EPA policy
on minimum set of data
elements for ground-water
and data standards. The
value of implementing this
policy at the Regional level
is that the programs directly
involved in each Region can
determine what data to auto-
mate, how to use informa-
tion already in EPA
Regional files, the cost of
making the data available
electronically, the link to
GIS, and other issues. The
Regional policy would also
consider the needs and
capabilities of the States,
local governments, and the
regulated community as key
players and users of ground-
water data. Region X which
has already implemented this
policy should provide the
33
-------
Protecting the Nation's Ground Water
Ground-Water Data Management
other Regions the benefits of
their experience.
• Ground-Water Data
Accessibility Recommendation:
Develop a Directory for
use by the Regions, States,
local governments, other
Federal Agencies, and the
ground-water community to
locate ground-water data.
The Directory would
establish a central pointer
system or "one stop
shopping" to identify the
many EPA, State, and other
Federal ground-water and
related data bases in
existence. The Directory
would have two tiers. The
first tier would contain
national information which
would be useful nationally.
The second tier would
contain information only
useful to each Region, such
as their State and Regional
data bases. This Directory
would begin to document
and build an institutional
memory of the existence and
the location of the data
collected by the Regions and
States.
• Ground-Water Data
Utilization: CIS and other
Applications Recommendation:
Incorporate more fully
the regional GIS capabilities
developed from pilot
projects into Regional
ground-water decision
making.
GIS is an emerging tool
for cross-media planning and
integrated environmental
management, and base
program activities such as
permitting, inspection, and
enforcement. In addition, it
is particularly useful in risk-
based priority setting of
Regional program commit-
ments and resource
requirements. GIS has been
found to be increasingly
useful in program planning
and priority setting activities,
once the investment in area-
specific mapping has been
accomplished. As EPA
begins using GIS in its
decision making, it is also
important to begin
promoting the use of GIS by
the State's in their decision
making process.
34
-------
Protecting the Nation's Ground Water Ground-Water Data Management
Data Management Subcommittee
Report to the
Ground-Water Task Force
"Ground-Water Data Collection, Accessibility,
and Utilization"
October 25, 1990
35
-------
Protecting the Nation's Ground Water
Ground-Water Data Management
Executive Summary
Ground-water data are
collected using different
methods and formats,
according to the needs of
individual EPA programs,
States, and other agencies.
Different data quality
objectives result in a range
of data collection elements,
dataset structures,
sophistication, and quality.
Data collection for EPA
decision-making includes
locating sources of
contamination, performing
risk assessments, and
initiating remedial actions.
Data collection for
identifying spatial and
temporal trends attempts to
discover ground-water
quality patterns, plan
national and regional
programs, and perform
research on ground-water
behavior. Advances in data
quality and quantity are
evident in Agency activities
such as RCRA facility
monitoring, the National
Pesticide Survey, and
identification of
ground-water quality
indicators. More baseline
data could be used to isolate
certain sources of
contamination, investigate
local and site-specific
problems, and advance
research. Options are
presented for improving
information capture, data
quality, management, and
dissemination.
Uneven data accessibility
reflects differences in data
collection among programs
and States. Data are often
scattered or cumbersome to
access. While recognizing
limitations in current data
accessibility, a significant
investment of resources and
multi-office agreement would
be necessary to affect a
major change. Specific user
benefits of any new,
standardized system should
be defined. Advances have
been made in data retrieval
systems, electronic bulletin
board systems, and
standardizing some aspects
of data entry. Options are
presented for using Agency
resources and leveraging
other agencies to improve
automation, and establish or
upgrade information
clearinghouses.
Data utilization tends to
follow the purpose for which
the data were collected;
however, EPA could do
more to utilize available
data. Patterns of data
utilization are closely linked
to ease of accessibility, user
knowledge, time available,
and proximity to appropriate
computer hardware and
software. Advances in data
utilization include use of
geographic information
systems (GIS), use of
ground-water models, and
numerical screening and
ranking systems for targeting
environmental priorities.
Options are presented for
encouraging data utilization
through improving data
retrieval systems, preparing
guidance, and performing
demonstrations.
36
-------
Protecting the Nation's Ground Water
Ground-Water Data Management
Data Collection,
Accessibility, and
Utilization
I. Background
A. What EPA Does in
Ground-Water Data
Collection, Accessibility and
Utilization
EPA programs have a variety
of approaches to managing
ground-water data. Activities
within the four major EPA
programs that collect
ground-water data are
summarized below.
1. Office of Solid Waste and
Emergency Response
(OSWER)
Ground-water data
collection under the
CERCLA, RCRA, and
LUST programs is
conducted to determine if a
release of hazardous
constituents has occurred
and the nature and extent of
ground-water contamination
from a hazardous waste site,
facility, or underground
storage tank. Ground-water
detection or assessment
monitoring is required of
owners or operators of both
LUST and RCRA facilities.
The purpose of these
monitoring activities is to
identify and remove a source
of ground-water
contamination and/or
prevent the introduction of
hazardous constituents or
petroleum products to the
ground-water environment.
Understanding site
hydrogeology is essential to
characterizing the
distribution and movement
of contaminants in the
subsurface environment. In
undertaking hydrogeologic
evaluations, therefore, the
following related data are
collected; 1) pertinent
information relating to
chemical or physical
properties of saturated
geologic units, 2) the
ground-water potentiometric
surface and, 3) the hydraulic
properties of the aquifer
(e.g., hydraulic conductivity,
transmissivity, storativity,
and velocity).
Data are typically
submitted in hardcopy report
format, however, for EPA-
lead Superfund sites,
chemical data generated
through the Contract
Laboratory Program (CLP)
are available electronically.
Generally, site-specific data
can then be accessed from
the Superfund RPM or
RCRA permit writer in the
EPA Regions, or their State
counterparts.
Both RCRA and LUST
track the status of
ground-water monitoring
through permitting in
RCRA, and by registering
tanks in LUST. Specific
regulations, which have been
issued to govern this process
are primarily implemented
by the States through
authorized programs. In the
Superfund program, EPA
responds to and tracks
releases or threatened
releases of hazardous
substances, pollutants or
contaminants, requires
responsible parties to
respond to releases or
threatened releases and
conducts oversight of their
response.
2. Office of Pesticides and
Toxics Substances (OPTS)
OPTS, in carrying out its
responsibilities, can request
and receive data relating to a
chemical's impact on ground
water. These data may cover
physical and chemical
characteristics, fate of the
chemical in the environment
studies, information on the
amount of material released
onto land or injected into
the soil, and ground-water
monitoring studies. Much of
the data obtained are
utilized in the assessment of
risk associated with the
chemical from its release
into the environment. The
Office also carries out
specific projects and research
to obtain data that supports
the improvement of its
regulatory decision process
and evaluates the impact of
37
-------
Protecting the Nation's Ground Water
Ground-Water Data Management
its regulatory decisions on
the environment.
The Pesticides in
Ground-Water Data Base
contains information derived
from monitoring studies
conducted by pesticide
registrants, universities, and
government agencies. The
data base identifies the
pesticides that have been
looked for in ground water,
the areas that have been
monitored, and the
pesticides that have been
detected. The data base will
be used by the Agency to
supplement the regulatory
process for pesticides. It is
being used to target
pesticides that are
contaminating ground water
and establish priority
candidates for regulation to
mitigate such problems. It
will also be used to highlight
vulnerable areas for which
reduced applications or
other restrictions may be
warranted, and to depict
data gaps where additional
monitoring should be
conducted. The ground-water
data base is presently printed
and distributed to the
Regions, States, and other
interested parties.
Consideration is being given
to making the data base
available via electronic
transfer through OPP's
Pesticide Information
Network.
A significant data
collection effort underway is
the National Pesticide
Survey (NPS). The primary
purpose of the NPS is to
characterize, for the first
time, the occurrence and
levels of pesticide residues in
rural domestic wells and
community system wells
across the nation using a
statistical design. A second
major purpose of the NPS is
to assess any major
associations among patterns
of agricultural pesticide use,
hydrogeologic characteristics
indicative of ground-water
vulnerability to pollution
and pesticide residues in
wells.
Information gained from
the planning stages of the
NPS is already being used by
EPA and pesticide
registrants in designing other
required studies. Health
Advisory Levels generated by
the survey have been used in
other efforts by OPP such as
the Agricultural Chemicals
in Ground-Water Strategy
and vulnerability measures
generated for US counties.
Multi-residue analytical
methods developed for the
NPS are currently being
evaluated for uses by EPA
and non-EPA parties. The
results of this study are
expected to be completed by
the end of 1990 or beginning
38
-------
Protecting the Nation's Ground Water
Ground-Water Data Management
of 1991. Interim findings
have been printed for
distribution to the Regions,
States, and other interested
parties.
Data collection also
occurs through chemical-
specific studies by
registrants. The data
required to support the
registration of a pesticide
attempt to predict its
degradation, terrestrial and
aquatic metabolism, mobility,
dissipation, and accumula-
tion in the environment.
Additional retrospective or
prospective ground-water
monitoring studies may be
required if a pesticide or its
degradates demonstrate
those characteristics of
persistence and mobility
generally associated with
chemicals that have a high
potential for contaminating
ground water. These data
are utilized in OPP's
exposure assessment and in
model simulations on the
pesticide. The results of
these data are currently held
in the Environmental Fate
and Ground-Water Branch
and are not readily available
to other parties. Considera-
tion is being given to making
the data base available via
electronic transfer through
OPP's Pesticide Information
Network.
In the Office of Toxic
Substances, ground-water
monitoring is a required
permit condition for TSCA
landfills. Regulations in 40
CFR section 761.75(b)(6)
address ground-water
monitoring for PCBs and
other parameters at TSCA
chemical landfills.
3. Office of Research and
Development (ORD)
ORD ground-water
research serves two
functions: providing support
for program office regulatory
and technical assistance
needs, and building a longer
term scientific understanding
of the subsurface as a basis
for EPA's current and future
activities regarding ground
water. As part of this
research program, ORD
collects and utilizes
ground-water data in certain
laboratory and field research
efforts. Most of this is
project-specific data
generation, such as
collection, storage, and
analysis of ground-water
quality data from field
experiments. An example
would be ground-water
sample data from a multi-
year field experiment. Some,
however, entail analysis of
trends in large sets of data,
such as identifying indicator
parameters among VOCs
from examination of
hazardous constituents
commonly found in ground
water at hazardous waste
sites nationally.
For research purposes,
data are collected and
utilized to fit the purposes
of particular research efforts.
For example, a research
project can be designed with
unique combinations of
sampling equipment,
sampling frequency,
statistical analyses, computer
data entry, and data
reporting format. These can
vary considerably, depending
upon the nature of the
project, judgment of the
researcher, and intended
product. Thus, considerable
variability is inherent in
research data collection and
utilization, despite general
aims of standardizing
laboratory and field
methods.
Accessibility to ground-
water data that ORD
collects and utilizes is also
variable. Most data can be
accessed by request from the
laboratory performing or
sponsoring individual
projects, or can be gleaned
from published reports or
journal articles.
There are also several
information clearinghouse
projects underway, as
explained in section IV.C.8.
of this Report. These
sources provide access to
project descriptions, articles,
reports, and models rather
than numerical ground-water
data.
An advancement is
underway to provide access
39
-------
Protecting the Nation's Ground Water
Ground-Water Data Management
to large ground-water
datasets. The International
Ground-Water Modeling
Center (IGWMC) has begun
to collect and automate
ground-water data from
several well-studied locations
in order to enhance the use
of these datasets for model
validation. This effort will
enable developers and users
of various ground-water
models to compare their
modeling results with field
data generated from well
characterized sites such as
the Cape Cod aquifer, which
have undergone long-term
monitoring by various
agencies with extensive QA/
QC procedures.
4. Office of Water (OW)
The SDWA and CWA
programs are largely
delegated to the States,
leaving OW itself in a policy
and oversight role. As such,
OW performs very little data
collection and utilization.
Office of Ground Water and
Drinking Water (OGWDW)
and its Regional Ground-
Water Offices do take an
active role in facilitating the
sharing and use of ground-
water related data sets.
OW maintains STORET,
EPA's computerized national
database system for environ-
mental monitoring data
related to the quality of
surface and ground water
wiihin the United States.
The system serves as a data
repository and analysis tool
for EPA, other Federal
agencies, State and local
governments, U.S. Terri-
tories, interstate
commissions, universities,
and Canadian agencies. The
Water Quality System
(WQS), the largest of the
STORET components,
contains data for over
700,000 ground- and surface
water sampling sites
scattered across the nation.
Data loaded into STORET
are not of consistent quality.
The SDWA does not
specifically require the
collection of ground-water
data. However, some State
drinking water programs do
require that public water
supplies (PWSs) collect and
report on the ground-water
quality where ground-water
wells are the source of
drinking water. The most
important users of ground-
water data in the Drinking
Water Program are the State
governments who are often
delegated responsibility for
program operation. EPA
Regions are responsible for
the oversight of the
delegated programs. OW
uses ground-water data to
help designate MCLs. Data
to support the creation of
new MCLs are obtained
from literature searches,
feedback from delegated
program, special studies, and
stratified random surveys.
OGWDW maintains the
Federal Reporting Data
System (FRDS) to support
the Drinking Water
Program. FRDS tracks
enforcement and violation
actions for PWSs and does
not contain routine
nonviolation site-specific
information such as water
quality of samples. Regions
and State-delegated pro-
grams enter data directly
into FRDS.
OGWDW has long recog-
nized the need for data on
the location of public supply
wells. In an effort to provide
this information, EPA and
the USGS have assembled
information on the location
of water-supply wells in the
southeast and northeast
regions of the U.S. The
information is currently
available for use in databases
and GIS.
The key decision-makers
using ground-water data in
the Underground Injection
Control (UIC) Program are
EPA Regions and delegated
States. The UIC program
functions that are supported
by various types of ground-
water data are: injection
authorization (by permit or
rule) and program enforce-
ment. Ground-water quality
data are not routinely
collected by permittees for
an injection well, but may be
made available for review by
program authorities through
40
-------
Protecting the Nation's Ground Water
Ground-Water Data Management
State Public Health
Departments.
ODW maintains the
Federal Underground
Injection Reporting System
(FURS) to support the UIC
Program. Data are supplied
by the Regions and State-
delegated programs. FURS
represents a national
inventory of underground
injection well facilities;
however, it does not
routinely have information
on individual wells.
B. What States and Local
Governments Do
States are responsible for
implementing and enforcing
many Federal policies and
standards. With the
assistance of Clean Water
Act grants, most States are
now developing and imple-
menting ground-water
protection strategies
addressing various sources of
contamination. States
collect ground-water data in
response to these Federally-
generated as well as State-
generated programs. A few
States have delegated data
collection responsibility to
local governments, which
also conduct some monitor-
ing for their own purposes.
Also, self-monitoring by
permitted businesses (e.g.,
public water supplies, RCRA
facilities) is a common
practice in ground-water
protection programs. There
is a great deal of variety in
the extent and quality of
State and local monitoring
programs.
Monitoring is conducted
to address a variety of needs
depending upon the program
requirements. Community
public supply wells are
monitored quarterly for
chemical and radiological
parameters as required in
the SDWA. Ground-water
monitoring is also required
as a permit specification for
sanitary landfills, sludge
disposal sites, RCRA facili-
ties, and TSCA landfills.
Results of the monitoring
are usually submitted on a
quarterly, semi-annual and
annual basis. Investigative
monitoring determines the
nature of contamination at
UST and CERCLA sites.
Research monitoring is
conducted on specific
problems or directed at a
defined project area. Each of
the programs has a different
regulatory authority,
program objective, and
requirements for conducting
the monitoring program. In
addition, each program has a
unique form of storing,
accessing and releasing
information. This may range
from hard copy filing systems
to computerized databases.
Hydrogeologic and related
geographic evaluations are
performed to identify
activities and/or areas where
ground water is contami-
nated or threatened and to
allow evaluation and
interpretation by managers.
Usually, this is performed
through research monitoring
and investigative monitoring.
Research monitoring is
directed at specific projects
to enhance understanding of
geologic and hydrologic
regimes. Investigative
monitoring, on the other
hand, is used to examine
various potential sources of
contamination which may
enter the ground-water
system.
Remediation of
ground-water contamination
is considered a high priority
in the States and many have
adopted guidelines and
policies which are more
stringent than EPA's health-
based and risk-based
requirements. These
requirements also extend to
solid waste management
facilities, and sensitive
watersheds/drinking water
sources. In many instances,
the owner/operator, or
responsible party's
requirement for remediation
is to cleanup to background
concentrations, i.e., complete
restoration of the damaged
aquifer to its previous
condition.
Status tracking is required
through several regulatory
and water quality programs.
41
-------
Protecting the Nation's Ground Water
Ground-Water Data Management
In most cases, it is the States
that implement and operate
the EPA's environmental
programs that address
ground water. For programs
such as RCRA, UIC, UST,
and PWSs, States are
required to enter permitting
and compliance status
information into national
databases such as HWDMS
or RCRIS for RCRA. In
addition to the national
environmental programs,
many States have developed
their own programs to
protect local ground-water
resources, and have
developed their own tracking
systems.
Laboratory and field
research in State and local
agencies varies, but is
generally conducted on a
limited scale. When
conducted, it is most often
related to site investigations.
Typically, these government
agencies rely on EPA,
USGS, other Federal
agencies, private sources,
and universities to provide
information related to
research advances in the
field of ground-water
management.
In the area of pesticides,
many States have initiated
ground-water monitoring
programs and have identified
areas where pesticide
contamination of water
resources is a problem. In
OPP's Agricultural
Chemicals in Ground-Water
Strategy (draft), monitoring
of pesticides in ground water
is emphasized as a feedback
mechanism for determining
the success or failure of
contamination prevention
efforts.
C. What Other Federal
Agencies Do
The USGS routinely collects
large amounts of
ground-water and surface
water data, and therefore
developed automated
systems for information
storage and retrieval. The
USGS operates
WATSTORE (Water Data
Storage and Retrieval
System), which includes
GWSI (Ground-Water Site
Inventory), an inventory of
wells, springs, and other
sources of ground-water and
relational information such
as hydrogeologic charac-
teristics, well construction
history, and water quality
measurements. Data are
loaded into STORET
monthly. NAWDEX
(National Water Data
Exchange) indexes available
water research data for user
access.
Other related information
retrieval systems at the
USGS, although not specifi-
cally for numerical
ground-water data are
WRSIC (Water Resources
Scientific Information
Center), which maintains
abstracts and bibliographic
citations on the scientific
literature and research in
progress, and various
clearinghouses. Related
mapping efforts includes
GIRAS (Geographic
Information Retrieval
Analysis System), and
standard hard copy geologic
and topographic maps.
These maps, which support
ground-water investigations,
are not consistently
automated.
Various research efforts
in ground water are
underway at the USGS. Two
large and significant data-
generating projects are
NAWQAP, (National Water
Quality Assessment
Program), where selected
areas of the nation will be
monitored extensively for
surface and ground-water
quality, and the interagency
Midwest Water Quality
Initiative, which is
investigating various factors
and processes governing the
effects of agricultural
chemicals on surface and
ground water. EPA
coordinates with USGS on
planning these two efforts.
Many other, smaller and
more specific research
projects generate
ground-water data which,
like EPA's, are not uniform
in specifications, frequency,
or format, and are not
routinely entered into large,
accessible databases.
42
-------
Protecting the Nation's Ground Water
Ground-Water Data Management
USDA's data collection is
essentially on soil types and
localities, however, a
bibliographic database,
including water management
information, is maintained.
USDA supports a national
ground-water quality
directory of Federal, State,
and private sector research
projects, and records data on
the results of their clean-
water program. Significant
increases in ground-water
research, data development,
and automation are planned
under the Midwest Water
Quality Initiative and Water
Quality Plan. EPA is
coordinating with USDA on
these activities.
DOE and DOD collect
and utilize ground-water
data in order to comply with
CERCLA, RCRA, and NRC
requirements. Compliance
entails intensive
ground-water monitoring,
hydrogeologic evaluations,
and ground-water program
tracking, as well as research
on fate and transport
processes, monitoring
instrumentation, and
remedial techniques.
Other agencies with
ground-water data collection
and utilization functions,
primarily connected with
research, are NASA, NSF,
NRC, BOM, and BLM.
II. Decisions Made with
Ground-Water Data
A. Permitting and
Compliance Under Federal
and State Programs
In the UIC program, States
have primacy for implemen-
tation and the decisions
affecting permitting,
compliance, and enforcement
activities. This includes
decisions on the operation of
underground injection well
systems and preventing their
impacts on ground-water
resources.
In RCRA, both the States
and EPA utilize
ground-water monitoring
data for permitting and
compliance decisions for
detection monitoring to
determine if a release has
occurred and assessment
monitoring to determine
extent and characteristic of
contamination. Results from
assessment monitoring can
lead to lengthy and costly
clean-ups. Also, RCRA
hazardous waste listing and
delisting decisions are
increasingly based on
national and site-specific
ground-water data.
Superfund National Priority
List sites are ranked in part
through evaluation of the
ground-water pathway, which
utilizes site-specific
ground-water data.
In the UST program, if
ground-water monitoring
indicates presence of free
petroleum product, the
owner/operator is required
to immediately notify the
State or local implementing
agency. The agency may
follow up with release
confirmation and corrective
action.
Under TSCA, OTS also
utilizes ground-water
monitoring data for
permitting and compliance
decisions. Such data are
used to determine if a
release has occurred from a
TSCA landfill, a remediation
project, or a PCB spill.
B. Risk Assessments
Ground-water contamination
is an issue at most hazardous
waste sites. Thus, risk
assessments based on
.ground-water data are
critical to the remedial
process. The risk assessment
process uses ground-water
data as part of the exposure
assessment step to predict
the extent of exposure and
the number of people
exposed to released contami-
nants, and the chronic
exposure concentrations.
These data are used to
43
-------
Protecting the Nation's Ground Water
Ground-Water Data Management
document contaminant
sources, pathways, exposure
points, and routes.
Using the ground-water
concentration data and site-
specific exposure scenarios,
the risk assessor calculates
daily intake of contaminants
from ground water by
ingestion and inhalation.
Chemical-specific
carcinogenic risks and
systemic hazard indexes are
calculated, then summed
across compounds and
exposure routes. Usually,
two separate sets of risk
estimates are prepared, the
first based on average
ground-water concentrations
and the second based on
maxima or 95% upper
confidence limits.
OTS assesses potential for
ground-water contamination
as part of its screening of
chemical suspects or as input
to fate and transport
modeling for releases. Fate
and transport models for
contaminant movement in
soil and ground water are
used for both generic and
site-specific assessments.
C. Remedial Actions
Ground-water data
generated during the
investigatory phase of a
CERCLA, LUST, RCRA, or
TSCA study are used for a
sequence of decisions.
Initially, the data are
reviewed as a means of
providing a three-
dimensional picture of a
contaminant plume, or the
immiscible petroleum
"pancake," in the aquifer. At
LUST sites, owners/
operators are required to
begin the removal of free
product upon detection. The
plume extent, the velocity
with which it moves, and the
environmental fate of these
contaminants are determined
in order to estimate risk to
potential receptors.
This information is also
used to notify potential
receptors of such risk. Once
a risk assessment is
conducted to predict any
impacts to these receptors,
target clean-up goals are
feasible. The number of
contaminants, their chemical
and physical characteristics,
concentration gradients
within the plume, and
tendency of the aquifer
matrix to interact with the
contaminants may all
preclude the use of current
remedial technologies.
Hence, reliable ground-water
data are not only critical in
determining the nature of
remedial activities, but also
may provide the basis for
deciding that certain
techniques are technically
infeasible.
D. Targeting of Oversight
Activities
In the RCRA corrective
action area, there are
thousands of solid waste
management units which are
candidates for permit or
enforcement action. Many
have ground-water releases.
Careful oversight of this
program will be necessary to
meet statutory deadlines.
Another area where over-
sight activities are targeted
with ground-water data is
Preliminary Assessment/Site
Investigations (PA/SIs) in
CERCLA.
In some Regions, data
bases with ground-water data
used by EPA programs are
downloaded into a
Geographic Information
System (GIS) which is then
used to target priority
attention of oversight
activities. The GIS can be
used to develop a ranking
system for corrective action
candidates using available
data and GIS mapping
techniques. Using GIS
technology, priorities for the
scheduling of future PA/SIs
can be established.
GIS is an emerging
method for targeting
activities and is assuming a
greater role. GIS is essen-
tially a tool for storing and
manipulating geographic
information in a computer.
44
-------
Protecting the Nation's Ground Water
Ground-Water Data Management
It is an information system
in which both spatial and
non-spatial data are stored,
analyzed and displayed. GIS
technology is unique in that
it integrates computer
graphic capabilities with an
automated database manage-
ment system, although it is
not necessarily limited to the
confines of a single, well-
defined software system. A
unique aspect of GIS is that
the maps created can be
organized into various
thematic layers, which can be
displayed in any combination
desired. By using presently
available data bases from the
USGS and EPA (DLG,
GIRAS, CERCLIS,
WHDMS, PWSS, UIC, etc.),
thematic coverages can be
created to display
ground-water quality and
assist managers in making
planning decisions.
Other methods for
targeting oversight activities
include environmental or
public emergencies, risk
assessments, informal
comparisons of risk, analysis
of cost effective options,
and a prevention-focused
approach using an aquifer
classification system.
E. Protection of Wellheads
and Vulnerable Aquifers
The Wellhead Protection
(WHP) Program, established
in 1986 by the Amendments
to the SDWA, is designed to
protect the recharge area to
public water supply wells
from sources of contamina-
tion. Unlike most EPA
Programs which are regula-
tory in nature and address
specific sources of
contamination, the WHP
Program is designed to assist
State and local governments
in focusing on the resource
itself through a comprehen-
sive analysis of the land uses,
geology, hydrology, and
institutional arrangements
impacting a public water
supply well, rather than on
controlling a limited set of
contamination sources via
State or Federal regulations.
Protection of aquifers
presents a myriad of
problems for the Federal,
State and local decision-
makers, which are often
hinged on the lack of
information. The vulner-
ability of an aquifer to
contamination mainly
depends upon the extent and
location of recharge areas in
relation to contamination
sources, depth to the
ground-water body, the
composition of the soil and
rocks overlying the aquifer,
the recharge rate, the nature
of the ground-water flow
system, and the potential for
biodegradation of contami-
nants. Much of the informa-
tion to support such a
vulnerability assessment is
not readily available.
Research on methods for
performing these assess-
ments is in progress.
F. Ground-Water Status and
Trends (indicators of water
quality)
Uniform "indicators" are
useful for the characteriza-
tion of ground-water quality
across local, State, Regional
and national areas. Ground-
water indicators provide
consistent models for the
presentation of ground-water
quality data and trends over
time. They can provide a
decision-maker with a better
grasp of the risks posed by
ground-water contamination
and help to improve his/her
ability to focus efforts on the
greatest risks.
G. Assessment of Pesticide
Impacts
Ground-water data are used
by OPTS as a basis for
regulatory decisions, measure
of the effectiveness of
regulatory decisions, a basis
for additional regulatory
actions, and as an indicator
of potential environmental
problems. When residues of
a particular pesticide are
detected in ground water at
a level of concern, OPTS has
a range of options available
to prevent or minimize the
contamination. Several of
the available regulatory
options are:
45
-------
Protecting the Nation's Ground Water
Ground-Water Data Management
a) Require additional
labeling that informs the
user of the pesticide's
leaching potential under
certain situations and steps
the user can take to reduce
the likelihood of the
pesticide to contaminate
ground water;
b) Classify the pesticide for
"restricted use" to be applied
only by an applicator who
has been trained and
certified on the use of the
pesticide;
c) Take steps to cancel
some or all uses of the
pesticide. The proposed
Agricultural Chemicals in
Ground-Water Strategy
would provide a framework
for States to develop a State
management plan for
preventing or minimizing
ground-water contamination
in lieu of cancellation.
III. Data Collection
A. Needs for Additional or
Different Data
1. Additional baseline data
A vast amount of data exists
within the ground-water
communily, often at broad
Regional or national scales
and collected by a multitude
of programs and organiza-
tions. Much of this data has
not been automated bv the
data holders. The data were
frequently collected under
inconsistent standards,
protocols, and quality
assurance programs, and
often focused on the narrow
needs of the collector. The
quality of much of the data
is not known and may
potentially be unreliable for
use in decision-making.
Site-specific, sub-county and
county data are often
lacking.
There is also a strong
need for more complete
health effects data and
drinking water standards for
comparison to ground-water
concentrations and
subsequent decision-making
on remediations.
2. Data for water quality
trend analyses
In addition to the need for
certain kinds of additional
baseline information, there
has been a growing aware-
ness of the need to collect
information to support
ground-water indicators in
an effort to characterize
ground-water quality across
local, State, Regional and
national areas and over time.
In FY 89, OGWDW com-
piled a series of ground-
water indicators for public
water supplies, hazardous
waste sites, waste and
industrial sites, area-wide
sources of nitrate
contamination, and area-
wide sources of pesticide
contamination. Region III
completed a pilot study with
Pennsylvania on the use of
ground-water indicators, with
mixed results on the ability
of indicators to predict other
aspects of water quality.
Additional work is needed to
refine the existing indicators
and to develop other
program and location
specific indicators to be used
in more fully characterizing
the quality of the Nation's
ground water. Inherent in
the process of using indica-
tors is the existence of
uniform data to support the
indicators. Currently, the
ground-water community
lacks such a program and
focus for uniform data
collection.
3. Data collection in
automated format
Currently, very little of the
ground-water data collected
by or requested by Federal,
State and local governments
are available in a readily
usable form. Ground-water
data submitted to govern-
ment agencies are commonly
in the form of voluminous
paper reports. This format
precludes the ability of staff
to perform rapid analyses of
spatial and temporal trends
and constitutes a significant
records management
46
-------
Protecting the Nation's Ground Water
Ground-Water Data Management
problem. The specific data
types that are missing or not
readily available in
automated format include:
• monitoring data most of
the existing data are in
hardcopy format; data were
collected under inconsistent
protocols and are sometimes
of unknown quality;
• inventories of sources of
contamination at State and
local levels - information to
support the inventories is
scattered or unavailable;
• hydrogeologic, land use
and natural resources data -
information to support
ground-water site analyses,
ground-water modeling,
vulnerability assessments,
etc. are scattered and often
only in hardcopy or map
format;
• zoning, tax, real estate
maps most remain in
hardcopy format;
• demographic data - some
demographic data are
available in machine-
readable format; however,
significant technical
resources are needed to load
and use the data on local
systems;
• well construction
documentation and well logs
at State, county, and local
levels most is in hardcopy
format.
• locations of public water
supplies - most is in
hardcopy only.
It is also important to
note that numerous data-
collection methodologies are
available; however, to obtain
comparable ground-water
monitoring data, consistent
data collection and analytical
methods must be used. This
list of methods must be
readily available to Federal,
State and local agencies as
well as the regulated
community and academia.
4. Research needs
Additional data collection
and analysis would improve
EPA's understanding of
sources of ground-water
contamination. For
example, the data generated
from intensive ground-water
monitoring under USGS'
NAWQAP survey could help
EPA understand the
significance of various point
and non-point sources of
ground-water contamination,
if the results can be clearly
related to specific sources.
In addition, the Midwest
Water Quality Initiative will
provide data for EPA's
purposes in understanding
transport and fate of
agricultural chemicals in
water. In both efforts, EPA
is coordinating with other
Federal agencies in order to
ensure that these data are
collected and analyzed so
that the results are useful to
EPA. In the latter case,
ORD has presented a
research proposal to
establish a cooperating
research role with USGS
and USD A. ORD would
participate by analyzing
subsurface processes and
ecological effects of
particular interest to EPA
research and program
offices.
EPA also has a need to
collect and have better
access to ground-water data
from closed or remediated
hazardous waste sites in
order to systematically
evaluate the effects of these
closures and remedies on
ground-water quality. A
research proposal to collect
and analyze such data has
been considered.
5. Resource implications of
additional data collection
Although several of EPA's
major programs gather
ground-water data for their
own purposes, the level of
funding for these programs
and the intended use of the
data vary. Similar data
gathering diversity also
occurs in the States. In any
data collection effort, the
47
-------
Protecting the Nation's Ground Water
Ground-Water Data Management
cost is a function of the
number of samples, the
number of compounds for
which each sample is
analyzed, and the level of
quality assurance. As EPA
has become increasingly
involved in gathering
ground-water data, levels of
quality assurance have
increased, minimum data
sets have been established
and the number of samples
and compounds analyzed has
increased. With these
increases have come
increases in costs.
In order to control these
costs, programs such as
Superfund, which historically
have generated large
amounts of site-specific data,
are now looking to manage
the volume of analytical data
gathered by using on-site
mobile labs, new screening
systems and methods of
analysis, and more efficient
quality assurance. All of
these activities are consistent
with the program's data
quality objectives. In other
programs, resource
constraints have already
resulted in careful choices
among activities related to
data acquisition, handling
and storage. For these
reasons, careful cost benefit
analysis must be included in
any proposals for additional
data gathering and changes
in data handling or storage.
B. Data Quality
All data used in the
management of the
ground-water resource must
be of known and
documented quality. In
order to evaluate the
"usefulness" of data, a
determination must be made
as to how the data will be
applied, e.g., health and
safety decisions, site
characterization, risk
assessment, etc. In many
instances, data collected at a
site may be suitable for
several categories of
decision-making. However,
the accuracy and precision of
the data must be specified in
order to determine if data
use for each decision is
appropriate. In the past,
there was little effort made
to define data requirements
prior to data collection. In
addition, much existing data
is of unknown quality
because most of it was
submitted by the regulated
community to comply with
the regulatory program
governing their activities and
verification of it's quality was
not fully assessed.
In addition to the
problem faced with unknown
data quality, data quality
objectives vary across all the
agency programs. DQOs are
the qualitative and
quantitative statements that
specify the quality of data
required to support Agency
decision-making. They
provide the substantive basis
for the detailed technical
design of procedures to be
used in data collection,
quality assurance and quality
control (QA/QC). DQOs
were established by each
program office to meet the
objectives of their decision-
making. Therefore, use of
one program's data may not
be applicable to another
because DQOs embody an
understanding of what
applications of the data will
be made and what limita-
tions of the data are
expected. For example,
DQOs under the Public
Water Supply program are
designed to meet established
regulatory standards, while
under the CERCLA
program, DQOs are
designed to meet lower
health based and/or risk
based standards.
C. Improvements and
Changes Underway
EPA is currently working to
improve data collection
through a number of
activities, including:
• Ground-Water
Indicators OGWDW
compiled a set of indicators
that the Agency and the
48
-------
Protecting the Nation's Ground Water
Ground-Water Data Management
States can use to track
progress and set priorities in
ground-water protection
efforts. The ground-water
indicators cover the
following areas of concern:
public drinking water
supplies; hazardous waste
sites; waste sites and
industrial sites; area-wide
sources of nitrate and
pesticide contamination.
OGWDW is currently
sponsoring State pilot
projects with New Jersey,
Minnesota, and Idaho to
further refine the current
indicators. The focus of the
pilots is on implementing
the indicators in the States'
SDWA 305(b) water quality
reports;
• Data Management
Standards EPA is currently
working on a number of
Agency-wide data and data
management standards which
will improve the collection
of ground-water and related
data. OIRM is completing
policy analyses which will
guide decisions concerning
Agency practices in the
management of facility and
spatial data. The proposed
facility data standard will
provide a much-needed link
for sharing data on facilities
across Programs, and will
improve EPA's capability to
maintain a central inventory
of basic information on
regulated facilities. The
spatial data standard will
establish a consistent
definition of spatial data
parameters for the Agency.
This standard is critical to
the successful implementa-
tion of GIS technology.
• OPPE has established an
Agency-wide workgroup on
electronic reporting
standards (ERS). ERS
would facilitate the
electronic transfer of
reporting data (e.g., from the
regulated community,
analytical labs) to EPA and
eliminate many
labor-intensive, paperbased,
routine data entry efforts.
The OPPE Workgroup is
drafting an Agency policy on
ERS and serves to
coordinate ERS activities
within EPA.
• QAMS Program For
each category of information
used by EPA, there are
appropriate procedures and
systems to enhance the
information's utility and
safeguard against errors.
The system which fulfills this
function for environmental
data is the mandatory
Agency-wide quality
assurance program, which
was officially established in
1979 and formally
documented in 1984 by
means of EPA Order 5360.1
("Policy and Program
Requirements to Implement
the Mandatory Quality
Assurance Program"). The
QAM Staff is charged with
overseeing the QA activities
of the Agency. QAMS has
focused its attention on the
development of conceptual
tools, such as Data Quality
Objectives, as well as on
implementation support and
education.
D. Options
1. In order for EPA to have
ground-water trend
information to establish
environmental goals for the
Agency, to evaluate the
quality of the environment,
and to evaluate the
performance of EPA
Programs, options for EPA
to assess the quality of our
nation's ground water
include:
• use the results of the
USGS National Water
Quality Assessment Program
(NAWQAP) (results due in
the mid 1990s);
• use State efforts to
provide the data through the
CWA Section 305 (b) reports
to Congress;
• use OGWP's guidance for
ground-water indicators, also
included in the 305(b)
report;
• conduct a national
assessment on a routine
basis using existing data
bases;
49
-------
Protecting the Nation's Ground Water
Ground-Water Data Management
2. Options for how EPA
can improve ground-water
data quality include:
• develop and use
consistent ground-water data
quality objectives across all
EPA Programs;
• develop and use Program-
specific ground-water data
quality objectives;
• require the inclusion of
information on data quality
in all databases containing
ground-water data.
3. Options for ways EPA
can develop and disseminate
more health effects
information on a faster basis:
• Increase resources to
OGWDW to expedite the
development of MCLs
(OGWDW is under a
Congressional timetable for
developing MCLs after the
initial 83 MCLs are in place.
The timetable requires the
development of 25 MCLs
every three years.);
• Increase resources to
EPA's peer review process
associated with the entry of
summary health risk
assessment and regulatory
information on chemical
substances into the
Integrated Risk Information
System (IRIS).
IV. Data Accessibility
A. What Kinds of
Ground-Water Data are Being
Requested from EPA
Programs?
I. Hazardous waste
programs
Information is frequently
requested from EPA's
.hazardous waste programs.
Requests are usually linked
to particular sites and
originate from Congress, the
regulated community,
environmental organizations,
the media, academia, and
other public agencies. Much
of the ground-water
information which the
hazardous waste programs
use is available for public
inspection, however it often
is stored in filing cabinets.
Enforcement-confidential
files, containing data from
sites or facilities in litigation,
is not easily accessible.
Similar limitations apply to
ground-water data that is
considered confidential
business information (CBI).
2. Pesticides and Toxic
Substances
OPTS responds to a variety
of requests from a multitude
of different constituents.
Requests for ground-water
information/data are received
from Congress, the regulated
industry, environmental
organizations, academia,
other Federal, State and
local agencies, public media,
and other interested parties.
The more focused and
sophisticated information/
data requestor, such as the
regulated industry or other
agencies, generally asks for
more scientific data whereas
public media and other
interested parties ask for
summary information.
OPTS' data are accessible to
the public after a CBI
clearance is performed. The
following is a list of some of
the more typical data
requests:
• A list of chemicals/
pesticides that demonstrate a
high potential to
contaminate ground water;
• Information/data on
chemical/physical
characteristics, the
environmental fate, and
toxicity to mammalian, aviah,
or aquatic organisms on a
specific chemical or a group
of chemicals;
• A copy of all the data
developed during a
particular monitoring project
or contained within a given
dataset;
50
-------
Protecting the Nation's Ground Water
Ground-Water Data Management
• Acceptable analytical
methodology for a chemical
or a group of chemicals;
• What monitoring studies
have been carried out for a
chemical or a group of
chemicals? Who were the
principal investigators?
Where can they be
contacted?
• Sources of other existing
datasets relating to
hydrology, hydrogeology, soil
profiles/characteristics for a
given geographical location,,
chemical/pesticide use sites,
etc..
• Where and what
chemicals/pesticides and
their levels, have been
detected in ground water;
• Information on the site
and the amount of a
chemical or chemical
released on the land or
injected into the soil;
• The concentrations and
locations of PCBs that have
been detected in ground
water.
3. Research
Research data are being
requested particularly on
remedial actions and
technologies. Hazardous
waste site investigators are
interested in which remedies
have been successful in
various scenarios, including
what concentrations of
hazardous constituents were
obtained from various
methods.
4. Other
Additional kinds of data that
are being requested as part
of ground-water analyses
include:
• hydrogeologic, land use
and natural resources data;
• zoning, tax, real estate
maps;
• demographic data; and
• well construction and well
logs at State, county, and
local scales.
C. Improvements and
Changes Underway
EPA is working to improve
the accessibility of ground-
water data and related
information through a
number of activities
including:
• Minimum set of data
elements for ground water -
OGWDW, supported by a
workgroup, developed a
minimum set of data
elements for ground water.
This set includes 22 data
elements, including
geographic, well/spring, and
sample/analysis descriptors.
These elements form the
core use, on which ground-
water data users can build
their own data base by
adding additional elements
to meet their specific needs.
EPA has adopted an Agency
Order which requires the
collection of the minimum
set by EPA and its
contractors whenever
ground-water data collection
activities occur. OGWDW
is also working with other
Federal agencies, State and
local governments, the
regulated community, etc., to
encourage them to
voluntarily adopt the
minimum set. OGWDW has
also initiated an effort to
develop final definitions and
formats for the minimum
data set through a
workgroup process.
• Region 10 Data
Management Order - Region
10 adopted a Regional
Order for Ground-Water
Data Management which
establishes consistent
procedures for organizing,
reporting, transmitting,
storing and retrieving
ground-water data in the
Region. The major
provisions of the Order
include: ground-water data
must be submitted to the
Region in electronic format;
the minimum set of data
elements must be collected
and stored; and all ground-
water data must be stored in
51
-------
Protecting the Nation's Ground Water
Ground-Water Data Management
a centralized Regional
ground-water data system.
The Order applies to all
ground-water data collection
activities directly carried out
by EPA staff or EPA
contractors, including
research and development,
enforcement, and permit
issuance.
• STORET enhancements
STORET is currently being
modernized by OW and
OIRM. Ground-water data
can now be retrieved using
the new user-friendly menu-
driven retrieval system as
well as the STORET
command language. Once
retrieved, the data can be
manipulated using SAS, or
presented in reports, tables,
graphs, plots and maps.
Data can also be down-
loaded to floppy diskettes.
Provisions have been made
in STORET for storing
information on the minimum
set of data elements for
ground water. In an ongoing
effort to improve STORET's
utility and user friendliness,
EPA is now working on the
development of user-friendly
menu-driven data entry
software as well as an
electronic data transfer
mechanism to facilitate entry
of monitoring data into
STORET. Data entry is still
voluntary, however, so
STORET provides the user
with a limited data set.
• EPA/State Data
Management Program EPA
initiated the EPA/State Data
Management Program in
1985. The goal of the
Program is to build and
maintain the infrastructure
needed; and, (1) for effective
State/EPA data management
and sharing; and, (2) to
integrate data across media
and programs so EPA and
State managers can target
their efforts on
environmental results.
There are currently two
phases of the Program in
progress: (1) data sharing by
providing direct
communication links to the
States for access to EPA's
national information
systems; and, (2) data
integration across programs
and media. Most States now
have direct communication
links to EPA's computers.
Many are using the national
systems for storage and
retrieval of data. EPA has
initiated Phase 2 efforts
through some State pilot
studies.
• Steering Committee for
Water Quality Data
Systems OW established
this Steering Committee in
1987 to guide the continued
development and manage-
ment of STORET and other
water quality systems. The
Steering Committee
activities are carried out by
EPA staff representatives
from OW's program offices,
OIRM, the Regions, and two
States. In FY89, the
Committee sponsored
Regional Forums on Water
Information Systems for
Regional and State staff.
The Forum;: provided a
setting for managers to
exchange ideas about EPA
and State activities related to
ground- and surface water
information. The Steering
Committee is currently
working on a data sharing
and system integration and
compatibility study to
evaluate OW's major systems
as well as a system
modernization study.
• Interagency Advisory
Committee on Water Data/
Ground-Water Subcommit-
tee - The Advisory
Committee on Water Data,
established by the Secretary
of the Interior, is chaired by
USGS and is composed of
representatives of Federal
agencies, including EPA,
that acquire or use water
data. The Ground-Water
Subcommittee provides a
forum for interagency
coordination and exchange
of ideas on ground-water
data management issues.
• Clearinghouses and
bulletin boards -
Clearinghouses and bulletin
52
-------
Protecting the Nation's Ground Water
Ground-Water Data Management
boards related to ground-
water information include:
- OGWDW Ground-Water
Bulletin Board OGWDW
has developed an electronic
ground-water bulletin board
for State and local govern-
ments on the LOCAL
EXCHANGE which is
focused on ground water and
wellhead protection issues.
— OSWER Bulletin Board -
a PC-based electronic
bulletin board for communi-
cations, dissemination of
computer programs and
databases related to solid
and hazardous waste
regulation, permitting and
enforcement, including
ground water.
— USGS Water Resources
Scientific Information Center
(WRSIC) - provides
abstracts and computerized
bibliographic information on
water-related scientific
information, and maintains
an information base on
water research in progress.
— USGS National Water
Data Exchange - assists users
of water data with the
identification, location, and
acquisition of needed data.
— National Water Well
Association's National
Ground-Water Information
Center - provides access to
bibliographic database
containing references on the
occurrence and utilization of
surface and ground water,
and on water well
technology. EPA/ORD
previously supported
"Ground-Water On-Line"
development, but now it is
wholly user supported.
- ORD's R.S. Kerr
Environmental Research
Laboratory has begun a
Superfund site remediation
technology clearinghouse, as
a service to technical EPA
and State staff in hazardous
waste programs.
— ORD sponsors a
ground-water model
clearinghouse at the
International Ground-Water
Modeling Center (IGWMC),
located at the Holcomb
Institute.
— ORD's Center for
Exposure Assessment
Modeling (CEAM) operates
an electronic bulletin board
system for distribution and
technical assistance on
exposure models from ERL-
Athens.
— A new, general ORD
bulletin board system
enhances communications
and public access to many
ORD publications, including
those on ground-water
research.
• The Office of Information
Resources Management has
published the Agency's
Information Resources
Directory (IRD) in response
to ever-increasing demand
for better awareness of
information resources and
greater information sharing
throughout EPA and its
partners in environmental
protection. The IRD is a
guide to a variety of widely
used information resources,
including information
services and centers,
information systems, and
datasets that are compiled
and utilized by OPTS.
In addition, the Office of
Pesticide Program maintains
the Pesticide Information
Network (PIN) which
presently is not listed in
IRD. The PIN contains a
compilation of monitoring
projects being performed by
Federal, State and local
governments and private
institutions. The database
contains a short synopsis of
each project, including
chemicals, substrates, and
location. It also lists the
name, address, and phone
number of a person to
contact to gain additional
information on a specific
project. The PIN is a free,
PC-based, network through
which all interested parties
may communicate and share
monitoring information.
53
-------
Protecting the Nation's Ground Water
Ground-Water Data Management
• Region III MERITS/
Temple Study (Regional
Assessment Study) - This
project employed GIS and
various databases to conduct
an integrated analysis to
identity and rank counties in
the Region with the most
endangered ground water.
The results of the study have
supported decision-making
on Regional program
priorities and resource
expenditures. A second
phase is underway for the
state of Pennsylvania,
refining the database usage
at a more detailed scale.
D. Options
I. Options for improving the
automation of monitoring
data obtained from the
regulated community, EPA
contractors, and EPA
Program Offices' projects
are:
• promulgate regulations
requiring that all new data
collected be automated and
transferred to EPA in
electronic format;
• publish EPA guidance
directing the automation of
data for carrying out and
reporting monitoring data;
• promote voluntary use of
electronic reporting by the
regulated community and
others to automate the data;
2. Options for EPA's role in
automating national
hydrogeologic, soils, and
aquifer characterization data
include:
• involvement of USGS and
the Soil Conservation
Service (SCS) in more EPA
projects which have side
benefits of data automation;
• encouragement of USGS
to institute a national
program;
• funding USGS to
automate data for EPA on a
case-by-case basis;
• working with USGS
upper management to
restructure their program to
more closely meet EPA's
needs;
• establishing an internal
information system at EPA
which would identify where
more in-depth information
can be located, and what
types of data are available.
The option of loading all
ground-water data into one
large, centrally accessible
electronic data base has
some appeal, but may not be
feasible. While a large data
base could provide almost
immediate access to data and
could be used for trend
analysis or responding to
Congressional inquiries on a
national scale, the cost of
loading, quality assuring, and
maintaining such a data base
may not be justified by the
benefits. These data are
accessible already through
various sources, although not
easily or immediately. EPA
could alternatively improve
coordination and access to
information available from
internal files, State, and
other Federal agencies, in
conjunction with GIS, to
highlight areas of concern.
(Areas of concern may
include sensitive aquifers or
areas of high ground-water
use for drinking water which
are potentially threatened by
a large number of under-
ground storage tanks,
hazardous waste sites, or
agricultural chemical use.)
3. Options of the Federal
government for improving
ground-water data access to
States and local
governments:
• national clearinghouse of
pollution sources/
contamination;
• national directory of
ground-water information;
• national database of
ground-water quality and
related data;
• modernization and
expansion of EPA's
STORET system;
54
-------
Protecting the Nation's Ground Water
Ground-Water Data Management
• improved State/Federal
partnerships;
• funding State systems.
4. Options for EPA to
ensure consistency among
the ground-water data that
are collected by EPA, the
States, and others include:
• regulations requiring EPA
and the States to collect data
using a specified format;
• EPA and States develop a
consistent format, but
participation is voluntary;
• implement EPA policy on
the minimum set of data
elements, which must be
collected by EPA and its
contractors; State
participation is voluntary,
but strongly encouraged.
V. Data Utilization
A. How Should EPA Improve
Utilization of Ground-Water
Data?
Individual program offices
utilize data they collect, but
EPA could do more to
utilize available data for
broader purposes. For
example, EPA needs to have
ground-water trend
information in order to
establish environmental
goals for the Agency, plan
future emphasis for
programs and to evaluate
program effectiveness,
evaluate the quality of the
environment, target
protection efforts and
perform gross level
screening, and to respond to
Congressional inquiries.
Assessing the
ground-water quality over
large areas of the nation is a
very difficult task.
Geographic Information
Systems (GIS) offers a
comprehensive means for
managing and assessing the
quality of ground water over
a large geographic area.
Also, it is an excellent tool
for assisting managers in
making planning decisions.
Utilizing ground-water
data can augment the
Agency's ability to perform
ecological assessments in
aquatic ecosystems.
Broadening the use of
ground-water data in our
ecological assessments would
improve our ability to better
define ground-water
remediation goals. There is
also potential for expanding
utilization of ground-water
data for analysis of other
environmental areas, such as
global warming effects.
Manipulation of
ground-water data through
predictive models also has
the potential to assist the
data user in making better
hydrogeologic decisions.
Although there are
limitations (see V.B.2), the
use of models is growing and
their optimum use should be
supported. Further
statistical comparisons of
ground-water data are
possible, e.g., through
STORET and SAS, and
other datasets and statistical
packages.
2. Targeting environmental
problems
In addition to the databases
described earlier,
ground-water data entered
into GIS can be used to
determine areas that are
undergoing environmental
stress by adding other
thematic layers such as
DRASTIC, pesticide usage
and population using ground
water for their drinking
water supply. A ranking
system can then be
developed that takes into
account a range of risk-
related factors including
potential sources and known
incidents of contamination.
Based on this evaluation,
environmental problems can
be targeted for priority
attention, both
geographically and by
specific EPA program.
Ground-water data are
also an essential component
of other methods for
targeting environmental
problems, including the
Superfund Hazard Ranking
System, which determines
the grouping of sites on the
55
-------
Protecting the Nation's Ground Water
Ground-Water Data Management
National Priorities List and
which sites are eligible for
funding, and the RCRA
location standards (draft),
which determines types of
locations environmentally
unsuitable for hazardous
waste facilities.
3. Research
EPA and State ground-water
data could be utilized more
fully and systematically to
interpret subsurface
contaminant behavior and
methods for prevention and
remediation of ground-water
contamination. If the range
of EPA and State
ground-water data were
more readily accessible and
of known quality, there
would be a greater potential
for research analysis and
interpretation on a national
or regional scale. This would
ultimately provide better
scientific understanding of
ground-water characteristics
and behavior.
B. Problems and Issues in
Data Utilization
1. Limited resources to
manage and use data
In enacting legislation
designed to address specific
environmental concerns in
several media, Congress
included ground water as an
area where attention should
be focused. As a result, each
media program established
its own unique set of
programmatic data elements
to assist in managing ground
water and report their
results to Congress.
Although these individual
data collection activities
have served the programs
well, their use in making
effective and consistent
planning decisions across all
Agency programs is
inefficient.
Data sets generated by
individual agencies or
programs are often ignored
by other agencies or
programs. Recognizing and
improving our ability to
utilize data generated by
other "media" programs is a
challenge facing the Agency.
At the same time, data users
must communicate their
needs to others who may be
willing to modify their
approach to collect or
manage data so that it is
more universally useful.
2. Tools for utilizing data
are sometimes unknown or
difficult to use
Utilizing statistical and
modeling tools in evaluating
ground-water data enables
staff to determine if
contamination exists,
estimate plume movement,
and evaluate its response to
various remedies. The
statistical methods of
establishing the presence or
absence of contamination
and the underlying need to
begin or end remediation are
important and currently
controversial issues. Many
ground-water flow and
transport models are well
documented and sophisti-
cated tools for processing
large amounts of data.
However, in real applica-
tions, input data are limited
and many assumptions must
be made. Further, skilled
staff and significant time
input are necessary to utilize
ground-water models
properly.
Data utilization via
models, statistical
comparisons, and GIS are all
hampered to some extent by
the same user-related
problems discussed in terms
of data accessibility. These
include user knowledge,
available time, and proximity
to appropriate hardware and
software.
3. Interpreting significance
of relational data
The technical procedures
involved in installing a well,
sampling the ground water,
and analyzing the samples
are all critical in determining
the value of ground-water
monitoring data. Therefore,
it is necessary that
information pertaining to
these procedures is included
in the data review.
Although some level of
56
-------
Protecting the Nation's Ground Water
Ground-Water Data Management
uncertainty is associated with
every data point,
professional experience and
judgment is critical to
identifying when and how
this relational information is
used.
4. Scales of data vary
The utilization of data for
program use and decision-
making is very scale-
dependent. For instance,
careful consideration should
be given when selecting the
scale at which spatial data is
entered into the GIS. Scale
is important in grid spacing
since large scale studies
require higher levels of
accuracy and finer grid
spacing. Regional data
exists at the 1:1,000,000
scale. EPA also has maps
for most of the country at
the larger 1:250,000 scale but
unfortunately the level of
accuracy is dramatically
decreased due to errors in
the GIRAS (land use)
database file. At the
1:100,000 scale, data exists
but sometimes in quantities
too great for a Regional
computer's current
capabilities. Therefore, EPA
should utilize large scale
maps only when a detailed
study is being performed or
for any high priority counties
as needed.
GIS and other mapping
scales are often smaller than
needed for hazardous waste
site evaluations. Other
examples of this
phenomenon of scale
difference are common when
using various databases, and
therefore hinder their
utilization.
C. Improvements and
Changes Underway
Computerized Geographic
Information Systems (GIS)
are being established to
varying degrees in the
Regions. GIS is a practical
tool that can qualitatively
manipulate large data sets of
environmentally sensitive
data. A GIS can vastly
improve on traditional
methods for capturing,
storing, updating, analyzing,
and displaying mapped
natural resources data. The
system allows the Regions to
integrate efforts in ground
water with other concerns
for water quality. Landfills,
Superfund sites, and
industrial facilities could all
be located in the database
and compared with the
location of water wells,
wetlands, or other
environmentally sensitive
areas. Applications of GIS
highlight program
interrelationships which may
not be recognized at this
time. Further, GIS can
enable us to focus
management decisions more
efficiently, and communicate
those decisions more
effectively to other offices
and the public.
• GIS in wellhead
protection program (WHP)
demonstration projects - In
an effort to encourage the
use of GIS in WHP and
ground-water protection
efforts, OGWDW is
sponsoring a series of pilot
projects at the county, State,
and Regional levels. These
projects are intended to
demonstrate unique and/or
transferable applications that
support the decision-making
process. Currently,
OGWDW is funding three
WHP GIS projects at the
local level: Carroll County,
MD (development of
ground-water management
performance standards and
county ordinances on land
use to be used in a WHP
Program); St. Charles
County, MO (development
of interpretive maps to used
in the development of a
WHP Program); and Santa
Clara Valley Water District,
CA (development of a model
ground-water management
strategy for a pilot recharge
area).
• ORD-Environmental
Monitoring Systems
Laboratory (EMSL) support
to WHP GIS projects -
EMSL is providing technical
support to OGWDW's GIS
projects. They are also
producing a guidance
57
-------
Protecting the Nation's Ground Water
Ground-Water Data Management
document on the implemen-
tation and use of GIS for
WHP that is focused on the
needs of local governments.
The document is scheduled
for completion in FY91.
• WHP Data Management
Demonstration Projects
OGWDW is initiating a
series of WHP data
management demonstration
projects based on a national
competition.
• In FY90, Congress
appropriated $500,000 to
EPA for grants to local
communities to show how
data management efforts of
local communities can assist
in better decision-making in
the implementation of WHP
Programs.
• OIRM System
Modernization Project
EPA recognizes that there is
a need to modernize its
information systems. The
traditional single media
approach to systems
development no longer
meets the Agency's
information needs. In an
effort to meet these
changing needs, OIRM
started a "System
Modernization Program".
The elements of the
initiative include: a Systems
Development Center (to
provide a central focus for
system development
activities and emerging
technologies); a
modernization fund (to fund
priority projects and create
incentives for moderniza-
tion); an OIRM support
team (to facilitate
information and technology
transfer as well as the
development of integrated
systems); and an Agency-
wide IRM Steering
Committee (to provide
guidance and set priorities
for the modernization
effort).
• Technology transfer
programs which include
ground water are operated
by several EPA
Headquarters offices: the
Office of the Administrator,
Office of Research and
Development, Office of Solid
Waste and Emergency
Response, and the Office of
Water. ORD operates the
Center for Research
Information (CERI), which
distributes research
publications and sponsors
training on ground-water
science and -engineering
subjects. Office of Water's
Ground-Water Protection
Division also distributes
documents and provides
training, mostly tailored for
State and local governments
and their needs in setting up
ground-water protection
programs.
• Hazardous waste
ground-water work stations
in Regions: OSWER's
Office of Program
Technology Support
(currently the Technology
Innovation Office) installed
ground-water work stations
in each regional office for
use by RCRA and CERCLA
personnel. The work
stations provide the means
to store and manipulate site-
specific ground-water data
from hazardous waste sites.
The work stations are a
collection of PC- based
hardware and software,
including CAD (Computer
Assisted Design) based
graphics and ground-water
flow and transport models.
Work station users can
communicate via the
OSWER electronic bulletin
board system. The work
stations can improve
ground-water decision
making, however, they are
not designed to foster
agency-wide access to
ground-water data.
The ground-water work
station has been used
primarily for graphical
representation of surface and
subsurface conditions and
the contouring of chemical,
as well as ground-water
elevation, data. The system
has been used on an uneven
basis partly due to the labor-
intensive exercise required to
input chemical data and
information regarding
aquifer properties. Also, the
-------
Protecting the Nation's Ground Water
Ground-Water Data Management
limited number of models
loaded into the workstation
and their inherent
assumptions limited it's use
at a significant number of
sites. Some Regions have,
however, "customized" their
work stations by adding
models and other software,
and have thereby made the
systems more useful.
Regional staff have found
the system valuable for map
preparation in anticipation
of briefings, meetings,
enforcement conferences,
etc. Most of the maps are of
large scale and are very
legible. Its use in permitting
and enforcement decision-
making is somewhat limited
to date partly because of
time constraints, workload,
changing priorities and other
factors. Some staff would
like to use the system on a
more frequent basis but find
it difficult to allocate the
time necessary to become
familiar with it. Personnel
assigned to the system on at
least a part-time basis to
enter site or project
information into the system
would improve utilization.
This would allow technical
staff to use their time on the
work station more
productively.
D. Options
1. Options for improving
the utilization of ground-
water data include:
• modernize STORET to
make it more "user friendly,"
as a mechanism to
encourage the use of the
system as a central ground-
water data repository;
• foster more data
coordination at the Regional
level through the use of GIS
as a tool for integrated
environmental management;
• devote more resources to
pilot and demonstration
projects in ground-water
data management which
have transferable
applications to EPA, State
and local decision-makers;
• issue generic guidance for
carrying out and reporting
monitoring studies to be
used by academia, industry,
Federal, and State officials.
59
-------
Part F
ORD Ground-Water
Research Plan: Strategy
for FY 1991 and Beyond
i
RESEARCH
61
-------
Protecting the Nation's Ground Water ORD Ground-Water Research Plan
Foreword
Ground water is a vital natural resource in the United States. Its quality is of foremost
concern for the future of human health and the environment. The importance of ground
water for consumption and other uses, as well as the interaction of ground water with the
rest of the hydrologic cycle and other aspects of the environment has become increasingly
apparent in a number of EPA programs. The Agency has therefore established standards and
undertaken various activities to protect and remediate this resource. To underscore the
importance of these activities, the Deputy Administrator convened an EPA-wide Ground-
Water Task Force to coordinate and direct future efforts.
There are three essential and inter-related requirements for EPA's ground-water efforts:
legislative authority, administrative framework, and scientific and technological know-how.
This document addresses the third requirement, particularly the role of research in building a
scientific understanding of how to prevent, predict, and remediate ground-water
contamination. This Plan presents the Office of Research and Development's strategy for
conducting subsurface and related research in support of EPA's programs.
Erich Bretthauer
Assistant Administrator for Research and Development
63
-------
Protecting the Nation's Ground Water
ORD Ground-Water Research Plan
Preface
This document describes a
ground-water research plan
for EPA's Office of Research
and Development (ORD).
The ground-water research
program is carried out by
ORD's Office of
Environmental Processes and
Effects Research (OEPER),
the Office of Modeling,
Monitoring Systems, and
Quality Assurance
(OMMSQA), the Office of
Environmental Engineering
and Technology
Demonstration (OEEDT),
and the Office of
Exploratory Research
(OER). Four ORD
laboratories have lead
responsibilities in ground-
water research: OEPER's
Environmental Research
Laboratories in Ada, OK
and in Athens, GA,
OMMSQA's Environmental
Monitoring Systems
Laboratory in Las Vegas,
NV, and OEEDT's Risk
Reduction Engineering
Laboratory in Cincinnati,
OH. ORD's Center for
Environmental Research
Information (CERI)
conducts educational
seminars and prints and
disseminates publications in
support of the ground-water
research program. The
overall program is
coordinated by the ORD
Matrix Manager for Ground-
Water Research, Peter W.
Preuss, Director of ORD's
Office of Technology
Transfer and Regulatory
Support. This Plan was
prepared by the Matrix
Manager and staff for the
Assistant Administrator for
Research and Development.
The Plan reflects the review
and contributions of the
ORD Ground-Water Matrix
Management Work Group
and the Deputy
Administrator's Ground-
Water Task Force.
Executive Summary
Ground-water research at
EPA encompasses several
different ORD programs
which are contributing to the
body of knowledge in this
emerging science. Efforts
are focused on serving EPA
programs which are requir-
ing an increasingly
sophisticated knowledge base
and greater technical
assistance in order to
develop and implement
environmental programs.
Two major themes or objec-
tives for future research are
prevention and remediation
of ground-water contamina-
tion. These objectives can
continue to be met through
focused research products
for EPA program clients,
supported by basic research
on subsurface processes,
monitoring and remediation
methods, while evaluating
and refining research results
based on field experience.
Of primary importance are
coordination with other
research agencies and
organizations, and
dissemination of research
expertise through technology
transfer and technical
assistance. Several ground-
water research initiatives are
highlighted in this Plan
which would serve these
goals. A significant research
initiative proposed for
consideration for FY 1992
concerns basic process
research on the behavior and
effects of agricultural
chemicals in ground water
and surface water.
Enhanced funding for
ground-water research
should be considered in
order to sustain its ability to
serve the Agency's needs.
Introduction
The Science Advisory
Board's, "Review of the EPA
Ground-Water Research
Program" (July, 1985)
concluded, among other
things, that ORD should
establish centralized
direction and management
for its ground-water research
program through a Ground-
Water Research Manager.
They recommended that this
Manager develop an inte-
grated, comprehensive
ground-water research plan.
The plan would address
research needs and activities
65
-------
Protecting the Nation's Ground Water
ORD Ground-Water Research Plan
spanning the various EPA
programs having ground-
water components.
ORD has responded to
these recommendations by
appointing a Ground-Water
Matrix Manager, who
coordinates with other ORD
Offices to analyze ground-
water needs and promote
new initiatives. This
Ground-Water Research
Plan summarizes the status
of ground-water research at
EPA, and proposes areas for
growth for fiscal year 1991
and beyond.
I. Background
ORD supports an active,
diverse ground-water
research program dedicated
to provide the scientific basis
for protecting current and
potential drinking water
aquifers, and interconnected
surface water resources, from
contamination. The inter-
related scientific fields of
hydrogeology, hydrology,
geochemistry, geophysics,
biochemistry, microbiology,
statistics, soil science, and
physical chemistry are
components of ground-water
research. Each field
provides a perspective on
what can collectively be
called ground-water science.
Research areas span source
control, detection, monitor-
ing, prediction, and remedia-
tion of ground-water
contamination. Five EPA
programs and their statutory
missions are served:
CERCLA, RCRA, CWA,
SDWA, and FIFRA
EPA's role is somewhat
unique in the Federal
ground-water research
community, due to our
regulatory missions and
timetables. For example,
EPA's need to monitor
ground-water quality and
remediate contamination to
drinking water concentra-
tions has generated research
into areas sometimes
untested by other organiza-
tions. Technology transfer
and technical assistance to
those implementing environ-
mental programs depends
upon a strong in-house
knowledge base, responsive
research agenda, and
assertive outreach program.
EPA's research effort in
support of environmental
programs is therefore
distinctive in purpose,
direction, and timing.
Other agencies cannot be
expected to fulfill this role.
Our challenge in working
with other agencies and
organizations is to identify
areas of common and
separate interest, so that
research is complementary
but not duplicative or
lacking.
To carry out its functions
in supporting ground-water
activities at EPA, ORD
conducts research in five
broad areas. These areas,
and some of ORD's
significant contributions, are
summarized below:
A. Subsurface Monitoring
The goal of this research
program is to produce
techniques and methodol-
ogies for detecting and
quantifying changes in
hydrogeology, and in
subsurface water quality.
Both direct sampling and
remote sensing approaches
are generated. This program
includes research on locating
and installing monitoring
wells; sample collection and
preservation; quality
assurance and quality
control; geophysical and
geochemical detection and
mapping of shallow
contaminant plumes with
both surface and downhole
methods; mapping deeply
buried plumes associated
with injection wells,
determining chemical
indicators of ground-water
contamination; developing
monitoring methodologies
for the unsaturated zone;
advanced monitoring
techniques such as real-time,
in situ monitoring of ground
water with fiber optic sensor
and fluorescence
spectroscopy; and external
leak detection devices for
underground storage tanks.
Most of ORD's subsurface
monitoring research has
been undertaken in response
66
-------
Protecting the Nation's Ground Water
ORD Ground-Water Research Plan
to the needs of the
CERCLA and RCRA
hazardous waste programs,
where immediate needs to
accurately sample and
analyze ground water have
challenged the state of the
science to develop
appropriate laboratory and
field techniques. ORD's
monitoring research and
development has advanced
EPA's ability to meet
environmental needs and
statutory requirements.
Some of ORD's most
significant contributions
have been in:
• fiber optic and x-ray
fluorescence remote sensing;
• unsaturated zone
monitoring for hazardous
waste facilities and
underground storage tanks;
• well construction
techniques to minimize
sample contamination;
• identification of indicator
parameters for ground-water
contaminants;
• methods for collection of
uncontaminated aquifer core
material;
• quality assurance of field
investigations;
• application of standard ^
geophysical techniques to "j
hazardous waste site
investigations;
• development of
geographical information
systems (GIS); and
• methods for statistical
comparisons of ground-water
monitoring data.
As these methods and
technologies are developed,
they are transferred to EPA
Regions, States, and the
public through guidance
manuals, training, reports,
and professional journals.
Case-by-case technical
support to program offices
in these areas is also a major
effort.
B. Transport and
Transformation
In order to predict the
movement of contaminants
in the subsurface, and
thereby predict potential
human and ecological
exposure, ORD maintains a
research program in
transport and transformation
of contaminants. Predicting
contaminant behavior in the
subsurface requires
understanding the
mechanisms and rates of
transport, and chemical,
physical, and biological
transformations of contami-
nants. Transport is often
Locking Casing Cap
Vent Hole
Protective Casing
Inner Casing Cap
Well Casing
Plug
Completion Depth
Typical design components of a ground-water monitoring well
67
-------
Protecting the Nation's Ground Water
ORD Ground-Water Research Plan
assumed to occur in the
dissolved, aqueous phase,
but may also occur in
separate, dissolved phases
such as in immiscible oils,
or sorbed to fine, colloidal
particles. The subsurface
environment affects the
oxidation state, and the rates
and types of chemical
transformations. These
transformations in turn
affect the solubility and
mobility of the contami-
nants. Transformation and
transport are therefore
intimately related processes.
ORD's research studies
these processes for various
contaminants in different
settings, and develops
models for predicting time of
travel and exposure
concentrations.
Recent developments in
transport and transformation
research include advances in
understanding the processes
that control these pheno-
mena, and integrating these
processes into mathematical
models for describing and
predicting the behavior of
contaminants in the
subsurface.
At the process level, there
have been recent advances
in:
• understanding the kinetics
of the partitioning of
contaminants between
ground water and aquifer
solids;
• the behavior of multi-
phase fluid systems of water,
oil, and air;
• the movement of metal
ions in response to chemical
conditions;
• abiotic transformation
pathways and rates;
• vapor phase transport
phenomena important in the
vadose zone;
• facilitated transport
resulting from the presence
of colloidal materials, or
cosolvents such as alcohols;
• the movement of
contaminants through
fractured rocks;
• aerobic and anaerobic
biotransformation;
• re-examination of the
capacity of pollution-
degrading bacteria to move
through soils and geological
material, which has
improved our understanding
of the partitioning of organic
compounds between ground
water and residual oily
material,
• understanding higher
order transformation
reactions;
• understanding
hydrodynamic dispersion in
relation to heterogeneity in
the hydrodynamic domain;
• a more definitive
description of the metals
sorption processes;
• mathematical descriptions
of the reduction of organic
pollutants in ground water.
Recent advances in
integrating process level
information into predictive
tools include:
• the development and
dissemination of the metal
speciation model
MINTEQA2;
• the pesticide soils
leaching model PRZM;
• the pesticide ground-
water leaching model
RUSTIC;
• the screening model for
vulnerable soils DBAPE, and
development of databases for
access through DBAPE;
• development of the
multimedia model
MULTIMED for predicting
the exposure from landfilled
solid and hazardous wastes;
• development and
application of the CEEPES
comprehensive
environmental management
68
-------
Protecting the Nation's Ground Water
ORD Ground-Water Research Plan
model to agricultural
chemicals.
Most of the transport and
transformation research in
ORD is performed in
support of the hazardous
waste programs, and their
needs in predicting the off-
site effects of ground-water
contamination from waste
disposal sites. Some is also
done to support the Office
of Pesticide Programs to
predict the leaching behavior
of agricultural chemicals. A
new effort is underway to
support the Office of Water
in determining the sorptive
properties of soils as a factor
in protecting wellheads from
contaminant migration.
C. In situ Subsurface
Remediation
ORD's ground-water
research in the area of
subsurface remediation is
developing effective, reliable
methods for restoring
contaminated soils and
ground water as close as
possible to their original
quality. This includes
methods for recovering
contaminants from aquifers
for further treatment,
reducing the volume or
toxicity of contaminants in
situ, monitoring and
modeling remediation
projects, and examining past
remediation and source
control efforts to identify
subsurface factors
contributing to their success
or failure.
Significant research
advances have included the
initiation of applied
bioremediation to the
subsurface, the development
of design tools for
remediation (i.e., the
BIOPLUME model), and
methods for performance
evaluation of pump-and-treat
technology. Other areas of
investigation include steam
stripping and soil vacuum
extraction of contaminants,
with an emphasis on
understanding the subsurface
processes governing the
results of remedial measures.
ORD's research in the
subsurface remediation area
has been performed in
support of EPA's drinking
water and hazardous waste
programs.
D. Underground Source
Control
EPA's Underground
Injection Control program
regulates the injection of
hazardous wastes into the
subsurface. ORD has a
research effort to develop
protocols for injection well
practices, injection well
integrity testing methods,
and to understand the
interaction of injected
material with subsurface
materials.
E. Technical Assistance and
Technology Transfer
Technical assistance
generally refers to one-on-
one assistance by ORD on
site-specific or problem-
specific Regional, State, or
National regulatory matters.
Technology transfer
generally refers to printed
documents, software
packages, and focused
training that are initiated
and budgeted by ORD.
Both are carried out by
ORD laboratories primarily
for Superfund staff in the
Regional Offices. This effort
is largely funded by OSWER
through the Superfund
Technical Support Project,
which provides support on
ground water as well as
other aspects of Superfund
site investigations and
remedies.
For example, the
RSKERL provides assistance
on subsurface remediation
problems through the
Subsurface Remediation
Technology Support Core
Team, operates an
information clearinghouse
on this subject, and transfers
technology from the
National Center for Ground-
Water Research, a
consortium of Rice,
Oklahoma, and Oklahoma
State Universities. Areas of
expertise include
hydrogeological aspects of
pump-and-treat aquifer
69
-------
Protecting the Nation's Ground Water
ORD Ground-Water Research Plan
remediation, in situ
bioremediation of soils and
ground water, geochemistry,
fluid and contaminant
transport, transformation,
and mathematical modeling.
EMSL-LV provides
assistance in detecting,
monitoring, site
characterization, data
interpretation, and
geophysical techniques.This
includes saturated and
unsaturated zone monitor-
ing, remote sensing,
mapping, geostatistics,
analytical methods and
quality assurance, borehole
and surface geophysics, and
x-ray fluorescence field
survey methods. A hotline
and on-site field training
facility are important
features of the technology
support program at EMSL-
LV.
At ERL-Athens, the
emphasis is on multimedia
(i.e., ground water, surface
water, and soil) exposure
and risk assessment
modeling of remedial action
alternatives. Through the
Agency's Center for
Exposure Assessment
Modeling (CEAM), support
is provided on applying
models to assist in risk-based
decisions. This includes
information on models and
databases that link ground-
water transport and
transformation to human
and ecological exposure
scenarios. Workshops and
an electronic bulletin board
serve to enhance technology
transfer and assistance.
RREL operates the
largest of the technical
support centers in ORD.
Support is provided on
engineering problems related
to but not specific to ground
water, such as soil and
above-ground water
treatment alternatives,
remedial construction
processes and materials,
source control, and
geotechnical methods.
Technical assistance and
technical support continue
to be a highly important part
of the ground-water research
program. In the future, the
services described above
could be further expanded to
others in need of scientific
and engineering expertise for
technical decision-making.
II. General Approaches
for Future Ground-
Water Research
A. Staying at the Forefront
of an Emerging Scientific
Field
Hydrogeology and
contaminant behavior is an
emerging field, and EPA's
scientific research is at the
forefront. EPA's contribu-
tion to the state of
knowledge is evidenced by
our contributions to the
literature, our sponsorship of
cutting-edge research by
universities such as Stanford,
Yale, Louisiana State,
Carnegie-Mellon, and the
consortium of Rice,
Oklahoma, and Oklahoma
State Universities, and our
participation in international
conferences (such as the
International Geological
Congress, and others).
Implementation of EPA's
environmental programs
need the best available
technologies and methods.
These needs demand that
supporting research be
innovative, state-of-the-
science, and timely. It is
essential therefore that
ground-water research be
supported so that it may
remain at the forefront.
B. Preserving Continuity
Another essential aspect of
the research program is
continuity. Research
projects studying flow,
sorption, transformation, or
model development often
require years of steady effort.
Field studies in particular
require multiple years of
observation. A successful
ground-water research
program must maintain
stability over time in order
to generate useful, tested
products. Ground-water
research should therefore be
part of the Agency's long-
term research agenda. Two
examples of on-going
research areas related to
70
-------
Protecting the Nation's Ground Water
ORD Ground-Water Research Plan
ground water which have
successfully adopted 5-year
plans are the Biosystems
Technology Development
Program and the Wellhead
Protection Research
Program.
C. Meeting Users' Needs
There are several categories
of users of EPA's ground-
water research. A primary
user of research is EPA
Headquarters program
offices, that develop
regulations, guidance, and
strategies for national
implementation. The
scientific underpinnings of
these documents are based
on ground-water research.
For instance, the Office of
Solid Waste, the major
supporting office for ground-
water research funding, uses
research results from fate
and transport modeling to
formulate hazardous waste
characteristic criteria.
A second primary
category of users is the
Regional, State, local
government staff, and
consulting community who
implement environmental
regulations, guidance, and
strategies. Technical field
manuals and technical
assistance activities are
generally geared to this
group. They represent the
largest segment of the user
community, and are
increasingly receiving more
of the research focus
through technology transfer,
technical assistance, and
training. Some examples are
technical assistance on
developing remediation
plans at Superfund sites, or
providing training on
sampling procedures. This
user group is also a valuable
source of information on the
application of ground-water
methods and techniques, and
can provide essential
feedback to research.
Third, basic research
projects feed into other,
more advanced research
projects which can eventually
lead to products or
predictions. For instance,
basic research in methods
development is necessary in
order to conduct quantitative
field or laboratory studies.
Research to develop
scientific principles of
sorption, transformation, and
migration provides the basis
for much of the research on
technological controls for
specific sources of ground-
water contamination.
Therefore, one of the
primary users of research is
researchers, who work
through iterative,
experimental processes to
develop products of use to
environmental programs.
Fourth, EPA contributes
to extramural knowledge and
applications in ground-water
science. Through
interagency agreements,
publications, participation in
conferences, and member-
ship in professional
organizations, EPA ground-
water research is shared
among users in the scientific
community for the better-
ment of all. Clearly, the
research plan should
emphasize environmental
program support, while
seeking the best balance
among the various user
groups.
The future trend will be
toward greater and more
innovative technology
transfer and technical
assistance to Regions and
their contractors, as well as
delegated States because
these groups are increasingly
responsible for carrying out
environmental programs and
are in need of technical
knowledge. This effort
cannot occur in the absence
of continued basic research
and development. Basic
research to maintain and
build our knowledge base
must be sustained so that
there will continue to be
technology to transfer.
D. External Coordination
Coordination plays a major
role in prevention and
remediation research. ORD
coordinates with other
federal agencies as well as
State governments and
private and public
institutions to promote
71
-------
Protecting the Nation's Ground Water
ORD Ground-Water Research Plan
information exchange and
produce better research
products. Some examples
are: current coordination on
the preparation of an
interagency research plan
with the USGS and USDA
on agricultural chemicals
and their effects on water
resources; ongoing coordina-
tion with these agencies at
field test sites for validating
pesticide leaching models
and performing site investi-
gations; participation in the
EPA/USGS Coordinating
Committee; recently co-
sponsoring a conference on
hazardous waste ground-
water research with the
Electric Power Research
Institute; and participation
in the Federal Coordinating
Council for Science,
Engineering and Technology
(FCCSET), which has
recently published a synopsis
of all ground-water research
supported by Federal
agencies. These types of
alliances, and coordinated
research plans and projects
will continue to be fostered
in the future.
Particular attention
should be paid to the special
expertise and perspective
various organizations can
bring to a research problem.
EPA's needs and expertise
are somewhat unique in the
research community due to
our regulatory missions and
timetables. Subsurface
processes that attenuate,
transport, or transform
synthetic chemicals and
metals, and sampling
strategies for point and non-
point sources, are examples
of areas where EPA
specializes. Our Agency's
mandates to protect and
remediate ground-water
quality have generated
research into areas other
organizations have not
explored. We must continue
to work with other agencies
to identify areas of common
and separate interest, so that
important research is
conducted but not
duplicated.
E. Dissemination of
Research Results
Technology transfer and
technical assistance are
important applications of
ground-water research. This
mechanism provides a direct
link between the researchers'
expertise and EPA's program
implementation at the
Headquarters, Regional, and
State levels. Various efforts
are underway, including
seminars and publications
disseminated from ORD's
Center for Environmental
Research Information
(CERI). These efforts also
support EPA's Ground-
Water Protection Strategy
(1984), which calls for
strengthening State ground-
water programs through
technical assistance and a
strong research program.
ORD's major technical
assistance activities in
ground water are supported
by and directed at Superfund
programs. However, other
programs such as RCRA are
equally in need of hazardous
waste remediation expertise,
and an institutional
mechanism for accessing all
appropriate laboratories for
short-term, intensive, site-
specific project support
should be considered.
F. Science Advisory Board
(SAB) Recommendations
The Science Advisory
Board's "Review of the EPA
Ground-Water Research
Program" (1985) identified a
number of needed
refinements, including the
need for increased resources
and the need for increased
technology transfer and
training. They indicated 16
specific recommendations for
filling research gaps among
monitoring, source control,
fate and transport, and
remediation. Some of those
recommendations have been
partially implemented, such
as CERCLA funding for
ground-water research,
increased funding for
monitoring, source control,
source minimization
research, and technology
transfer. Many, however,
have not been fully
72
-------
Protecting the Nation's Ground Water
ORD Ground-Water Research Plan
implemented due to resource
limitations and competing
priorities for research
funding. This includes
research on contaminant
sources not addressed by
specific Congressional
mandates, field validation of
predictive techniques,
assessment of field
applications of containment
techniques (caps, liners,
walls, hydrodynamic con-
trols), remedial actions in
fractured formations and in
karst topography.
The SAB also emphasized
the general need for sus-
tained, long-term research
and emphasis on environ-
mental protection at EPA in
"Future Risk: Research
Strategies for the 1990s"
(1988). The SAB's
"Resolution on Use of
Mathematical Models for
EPA for Regulatory
Assessment and Decision-
Making" (1989)
recommended, among other
things, that EPA increase its
model validation program.
To the extent practicable,
EPA should incorporate
these recommendations into
plans for future research.
G. Ground-Water Research
Legislation
Several bills have been
introduced in Congress over
the past several years calling
for additional ground-water
research and related
activities in the Federal
government. This legislation
would give EPA specific
authority and direction to
perform ground-water
research. Currently, EPA
derives this authority from a
number of different statutes,
such as the Safe Drinking
Water Act.
Major provisions of these
bills that affect EPA include
a new interagency research
oversight committee and an
education committee, a
research demonstration
program, environmental
profiles and research on
significant ground-water
contaminants, technical
assistance, training, and
technology transfer,
establishment of a ground-
water information
clearinghouse, establishment
of research institutes, and
grants to States to develop
and implement ground-water
strategies. Most of these
provisions are consistent
with parts of the existing
program, however the
research demonstrations,
environmental profiles, and
clearinghouse would entail
significant added emphasis in
EPA's research program.
The attention that
Congress has given to new
legislation in this area
underscores the importance
of existing work at EPA, and
reinforces the need for
additional research to serve
the needs of the Nation.
III. Growth Themes for
ORD Ground-Water
Research
Subject areas where
ground-water research
should seek to expand can
be broadly characterized by
two themes: prevention and
remediation.
A. Prevention
Prevention encompasses the
identification of threats to
ground water from point and
non-point sources, and
mitigating these threats
through a combination of
source control, management
practices, land use changes,
and institutional measures.
Prevention requires an
understanding of fate and
transport processes, use of
predictive techniques, and
monitoring to delineate the
threats to ground water.
One aspect of prevention
is wellhead protection, which
involves focused land and
source management practices
aimed at preventing
contamination of aquifers
which supply drinking water
wells. By characterizing the
vulnerability of aquifer
systems, local sources of
contamination, and likely
pathways and rates of
transport and transformation
to such wells, State and local
governments can develop
plans for protecting their
drinking water supplies.
73
-------
Protecting the Nation's Ground Water
ORD Ground-Water Research Plan
Wellhead protection
research includes methods
for delineating wellhead
protection areas, and
managing point-source/non-
point source contamination
threats.
Other aspects of the
prevention theme are
predictive tools, such as
models for flow, fate and
transport. Predictive models
can be used to support
management decisions to
prevent the introduction of
contaminants to the
subsurface or to prevent
exposure above a health-
based concentration at a
specified location. The
correct use of these models
depends upon the underlying
field and contaminant data
and assumptions that are
incorporated in the models.
Research into rate constants
and physical properties such
as hydraulic conductivity and
effective porosity can
therefore all be looked upon
as part of the prevention
goal.
Monitoring the subsurface
for early detection of leaks
from underground storage
tanks or waste impound-
ments, or seepage from
pesticide applications, can
also be considered an
integral part of prevention.
By employing various
sampling and remote
sensing methodologies near
the source of contamination,
actions can be taken to
prevent the spread of
contamination to ground
water.
B. Remediation
The success of ground-water
remediation efforts depends
largely upon understanding
subsurface processes in order
to design effective remedies.
For example, the success of
remediation may be govern-
ed by multiphase behavior of
contaminants, partitioning
among solid and fluid media,
biotic and abiotic transfor-
mations, and transport in
fractured media. In order to
remediate ground water at a
waste site, knowledge of
these processes and how they
are likely to operate under
given site-specific
environmental conditions is
essential.
Predictive tools such as
models are also part of
designing and tracking
remedial actions. For
example, the BIOPLUME
model predicts contaminant
migration affected by
oxygen-limited biodegrada-
tion, and can be used to help
plan a bioremediation
project. Monitoring is also
integral to remedial actions,
both for detecting contami-
nants and monitoring the
progress of ground-water
cleanup. For example,
assessing whether health-
based concentrations have
been reached at a site
depends heavily on the
monitoring techniques and
strategy utilized.
Knowledge of subsurface
conditions also interfaces
with the design of engineer-
ing methods and technol-
ogies for remediation. For
example, ground-water
pumping systems and prac-
tices must be compatible
with the local hydrogeology
and contaminant properties.
Because subsurface
remediation is relatively new
and much remains unknown
about the subsurface
processes and long-term
results of various remedies,
development and evaluation
of remedies must continue
to be a focus for research.
IV. Emerging Research
Topics
Within the prevention and
remediation themes, ORD
has identified a number of
emerging topics and research
needs in ground water.
A. Monitoring
Advanced monitoring
techniques that rely upon
non-intrusive, in situ, or
microelectronic techniques
hold promise for the future,
and may supplement or
possibly replace conventional
74
-------
Protecting the Nation's Ground Water
ORD Ground-Water Research Plan
laboratory "wet chemistry"
for ground-water monitoring.
Development of fiber optics
and x-ray fluorescence
(XRF) have been successful
for in-situ, real time
monitoring of some organics
and metal compounds,
respectively. For example, in
XRF, an x-ray is directed at
a sample, and in response
the sample emits induced
fluorescence in the x-ray
spectrum. A detector
analyzes the fluorescence for
both type and concentration
of inorganics. With further
refinement, it may be
possible to do at least
preliminary screenings for a
range of specific
contaminants at waste sites
or USTs with these methods.
The advantages in time and
cost savings, holding times,
chain of custody, and
laboratory requirements are
significant.
Other emerging topics
include monitoring strategies
for non-point sources of
contamination, long-term
monitoring strategies for
closed hazardous waste sites,
problems monitoring in wet
environments, remote
sensing methods for fracture
characterization, unsaturated
zone processes and
monitoring techniques,
monitoring strategies for
karst terrain, and new
applications for problem
solving with GIS.
B. Transport and
Transformation
The roles of organic carbon,
redox potential (eH), pH,
and solubility in aqueous
phase transport need better
understanding in order to
develop and rely upon
predictions of contaminant
transport. Facilitated
transport, a phenomenon
that refers to various
mechanisms whereby
contaminants move through
the subsurface at velocities
greater than expected by
considering solubility and
primary permeability alone,
merits greater understanding.
For example, sorption of
contaminants on colloidal
particles, and flow through
macropores facilitate
transport, and must be
accounted for in our
predictions of time of travel
and exposure. Although
anecdotal evidence exists
that this phenomenon
occurs, it is not fully
understood and is not
accounted for in operational
transport models.
Another research topic in
the area of contaminant
transport is complex wastes,
or wastes with several
components, densities, or
behavioral characteristics.
The separation of leachates
into water-soluble and
immiscible fractions can
result in plume stratification,
with light non-aqueous
phase liquids (LNAPLS)
floating above dense non-
aqueous phase liquids
(DNAPLS). A portion of
the former sometimes can be
EAST ARM GRAND
TRAVERSE BAY
' U.S. COAST GUARD j
Bioremediation of a Fuel Spill
75
-------
Protecting the Nation's Ground Water
ORD Ground-Water Research Plan
removed from the
subsurface, while the latter
settle in residual masses
which are not currently
amenable to conventional
removal methods. Another
complexity to this situation
is the chemical alterations
which take place in the
subsurface, sometimes
producing plumes of
degradation products more
toxic than the original waste.
The kinetics of adsorption
and desorption, collectively
referred to as sorption, must
be better understood to
predict transport reliably and
design remedies. This is
particularly applicable to
understanding the slow
desorption of residual
contaminants in the deep
subsurface. Remedies that
enhance desorption may be
necessary in some settings.
Most transport models
assume homogeneous
hydrogeology, while in fact
this is more the exception
rather than the rule.
Accelerated flow through
fractured media is one
important example of the
effects of heterogeneity on
transport. This phenomenon
needs to be better
understood and integrated
into transport models.
Transport, transformation,
and environmental fate of
non-point sources,
particularly agricultural
chemicals is of special
interest to EPA. For
Migration of a dense, non-aqueous phase liquid
(DNAPL) in the subsurface.
example, much remains to be
learned in the areas of
nitrate and pesticide
behavior in the subsurface in
order to predict fate and
effects with confidence.
Abiotic transformation
processes have been studied
for some time, but much
remains to be done, given
the large number of organic
pollutants. Recent
discoveries, for example,
show that certain
halogenated hydrocarbon
solvents may be hydrolyzed
or reduced over a period of
days or months to other
compounds having different
properties.
The mobility and
bioavailability of toxic metals
and metalloids depend on
the species of the metal,
which in turn is a function
of metal/metalloid chemical
properties and the
characteristics of the
subsurface. Improving our
understanding in these areas
is providing a better basis
for predicting exposures to
these toxic substances.
Little is known about the
fate of pollutants disposed of
in underground injection
wells. The conditions of
temperature and pressure in
this environment may greatly
accelerate the transformation
and transport of pollutants.
76
-------
Protecting the Nation's Ground Water
ORD Ground-Water Research Plan
Ground-Water Modeling
The National Research
Council, Water Science and
Technology Board,
Committee on Ground-
Water Modeling
Assessment's report
"Ground-Water Models:
Scientific and Regulatory
Applications" (September,
1989) contained a number of
recommendations applicable
to EPA ground-water
research. In summary, the
report recommends: (1)
continued validation and
refinement of ground-water
models, particularly those for
flow through the unsaturated
zone, fractured rock,
multiphase flow, and codes
linking mass transport and
chemical reactions; (2) the
role of bacteria in transport
and removal of
contaminants; (3) improving
the presentation of
uncertainty in model
predictions, and improving
our ability to estimate the
reliability of model results;
(5) continued efforts at
characterizing subsurface
processes through field and
laboratory studies; and (6)
developing approaches for
parameter estimation and
measurement techniques.
The Science Advisory
Board gave similar
recommendations in their
July, 1985 report, "Review of
the EPA Ground-Water
Research Program" and their
January, 1989 report,
"Resolution on Use of
Mathematical Models for
EPA for Regulatory
Assessment and Decision-
Making", particularly points
(1) and (3) above. Clearly,
future research in transport
and transformation should
address improvements in the
development, application,
and validation (i.e.,
laboratory or field
evaluation) of predictive
models that EPA uses.
C. Subsurface Remediation
Identification of
information requirements for
remedy selection, and
methods for subsurface
remediation continue to be
crucial areas for research.
Low and variable
permeability influence the
transport of contaminants, as
well as the dispersion of
surfactants used in clean up,
and pumping rates in pump-
and-treat operations. Other
important relationships
between subsurface condi-
tions and application of
remedial technology must
continue to be explored, in
order to maximize the
success of costly and time-
consuming remedial efforts.
Enhanced in situ methods
for biotic and abiotic
contaminant degradation is
an active research area that
merits greater attention.
The permanent solutions
possible through this
approach (as opposed to
moving contaminants to
treatment systems,
concentrating them, and
moving the residuals to still
other locations), and the
important alternatives these
methods provide to
unproven extraction
methods, render in situ
methods one of the most
important growth areas for
research. Processes for
transforming contaminants
in the subsurface to simpler,
less toxic compounds are
being explored for applica-
tion to remediation of
hazardous waste sites and
pesticide use.
Topics include in situ
bioremediation, where
microbes are stimulated to
degrade organic
contaminants in place. Use
of naturally occurring,
indigenous species is
showing promise for some
contaminants and settings,
while engineered microbes
are being developed for
others. It has been shown in
the laboratory and field that
certain organic wastes can be
converted into biomass and
harmless byproducts of
microbial metabolism. This
has begun to be demon-
strated in the field for
indigenous species with
hydrocarbon components of
gasoline and for chlorinated
compounds such as vinyl
chloride and DCE, with can
77
-------
Protecting the Nation's Ground Water
ORD Ground-Water Research Plan
be cometabolized with
methane. More highly
chlorinated compounds tend
to be more recalcitrant to
these methods, and may
require addition of microbes
with special biodegradative
functions. White rot fungus
has also shown to be
effective on a number of
contaminants including
DDT, PCBs, PAHs,
chlorinated phenols and
chlorinated dioxins.
The major limiting factor
in successful field application
of bioremediation, however,
appears to be transporting
the oxygen and nutrients to
the microbial populations so
that they may flourish and
metabolize the contaminants
rapidly. This transport
factor is a function of the
heterogeneity and hydraulic
conductivity of the site's
geologic media and distance
from the remedial applica-
tion to the contaminant
plume. In addition, in
certain anaerobic conditions,
reductive dechlorination can
be an effective bioreme-
diation method. In all
circumstances, the
importance of reliable site
investigations, monitoring
systems, and predictive tools
are evident.
Ahead in bioremediation
research is identification of
breakdown mechanisms for a
range of contaminants,
identification of alternative
electron acceptors (other
than oxygen), aerobic
degradation of solvents, and
the feasibility of adding
micro-organisms with special
metabolic capabilities. Of
equal importance is
overcoming hydrogeological
obstacles to employing
bioremediation in the field,
and developing methods for
enhancing transport of
nutrients to microbial
populations. This research
must be built upon methods
development and controlled
studies of biological
transformation processes.
Some of this research is
incorporated in ORD's
Biosystems research
program.
In the future, EPA may
be able to estimate and
enhance the rate and extent
of natural degradation
processes of many contami-
nants of concern in soils and
ground water. A major
emphasis should be to
approximate the extent of
contaminant reduction that
can be attained with
bioremediation to determine
whether the technology can
be used to meet EPA's
regulatory standards for
remediation and closure.
Abiotic remediation is
another topic that has an
unexplored potential. EPA
investigators are in the
process of isolating the
natural compounds responsi-
ble for the observed abiotic
reduction of several classes
of pollutants. These
compounds may be useful in
enhancement of degradation
processes.
V. Future Needs and
Support of ORD
Ground-Water Research
While significant strides
have been made in under-
standing various aspects of
ground-water science and
technology, ground-water
research is still in its infancy
in many respects. Unlike
surface water, ground water
is very difficult to observe
and measure in the field, it
moves slowly, and is strongly
influenced by the medium
through which it flows.
Further, contamination
results in different flow
characteristics as well as a
range of chemical interac-
tions and transformations,
most of which cannot be
quantitatively predicted at
this time.
The scope of research
needs has been broadened by
greater concern for ground-
water quality, new legislation
and regulations, better
problem identification, and a
tendency for investigations
to uncover ever greater
variability in the chemistry,
physics, and biology of the
subsurface. Research must
strive for but may never
attain solutions to every
contamination problem in
every hydrogeologic setting.
78
-------
Protecting the Nation's Ground Water
ORD Ground-Water Research Plan
EPA programs require
increasingly sophisticated
knowledge on which to base
complex, costly contamina-
tion prevention and remedia-
tion decisions. The impor-
tance of continued and
expanded supporting
research is paramount. The
value to EPA programs in
supporting ORD research
has been demonstrated by
such advances as in ground-
water monitoring practices,
site characterizations, tools
for risk assessments, remedy
selections at hazardous waste
sites, and pesticide leaching
models. Continued
sustenance of these and
other program office activi-
ties will depend in part on
future research in the high
priority areas identified
below.
VI. New and Proposed
Research
A. New research for FY
1990 and 1991
Three research initiatives
have been approved within
the last two fiscal years
which will address some of
the emerging topics
presented in this Plan.
1. Wellhead Protection
In September, 1988, ORD
and EPA's Office of Water
entered into a 5-year
research and technology
transfer agreement to
support State Wellhead
Protection (WHP) Programs.
States are currently
implementing WHP
programs in accordance with
the 1986 Amendments to the
SDWA. The purpose of the
research is to advance
fundamental understanding
and transfer information
regarding how to protect
ground-water supplies which
flow to drinking water wells
in various physical and
institutional settings across
the nation. ORD begins
research and development
activities for WHP in FY
1990.
Four research priorities
are envisioned. First, field
testing and verification for
WHP area delineation
methods will be undertaken,
including the refinement of
current modeling
approaches. Second, ORD
will evaluate the ability of
the subsurface to assimilate
certain amounts of
contamination without
impact to drinking water
supplies, and apply this
information to the
delineation of WHP areas.
Third, ORD will evaluate
and apply knowledge of
agricultural chemical
behavior, including use of
the RUSTIC model, for
delineating WHP areas.
Fourth, ORD will develop
WHP area ground water
monitoring strategies,
including definition of
optimal sampling and
monitoring designs.
The WHP research is
consistent with the
prevention theme for
ground-water research, as
well as ORD's approaches to
long-term basic research,
service to EPA client offices,
and technology transfer to
the States. It also will use
results from several
emerging topics identified in
this Plan, such as sorption,
model validation, transport
of agricultural chemicals,
and monitoring strategies.
2. Preventing Ground-Water
Contamination from
Pesticides: Information
Systems for State Use
The problem of pesticides in
ground water is national in
scope, but locally variable,
therefore accurate predic-
tions of pesticide transport
and transformation requires
specific information at the
local level. Evaluation of all
likely combinations of
pesticides, environmental
settings, and management
practices is virtually
impossible using random,
large-scale monitoring
studies or limited site-
specific investigations.
However, tools are available
to locate problem areas, and
develop strategies for
regulation and use of
pesticides on a local level.
79
-------
Protecting the Nation's Ground Water
ORD Ground-Water Research Plan
These tools include models
which have been developed
to predict the leaching of
pesticides to ground water,
data which has been
collected on soil properties
and other relevant environ-
mental factors, and
geographic information
systems (GIS) for displaying
and analyzing spatial
information. To date, these
types of tools have not been
systematically integrated into
a workstation framework for
State and local risk
management.
The main purpose of this
initiative is to provide such a
framework for States upon
which they can develop
locally meaningful pesticide
management plans. The
work will also include field
evaluation of monitoring and
modeling schemes. The
project will be carefully
coordinated with related
research on the effects of
agricultural chemicals on
water quality at the USGS
and USDA, in order to
ensure integration of
information and
dissemination of results.
3. Subsurface
Characterization and
Mobilization Processes
(SCAMP)
The potential effectiveness
of "pump and treat"
technology to remediate
contaminated ground water
and soils is largely unknown,
but widely practiced.
Further, the technology
sometimes fails to
accomplish the mandates of
the Superfund Amendments
and Reauthorization Act of
1986 (SARA) which states
that cost-effective
technologies be utilized for
the permanent remediation
of contaminated sites. The
successful application of this
technology in site remedia-
tion requires an under-
standing of site characteriza-
tion methods and the
processes controlling
contaminant transport and
mobilization in the
subsurface. Poor
understanding of these
processes and inadequate
site characterization are the
most common reasons that
pump and treat does not
perform as a cost-effective,
permanent remedy. This
does not mean that pump
and treat should be
abandoned, but that a
research program should be
carried out to significantly
improve its efficacy, and
current guidelines for the
implementation of this
technology should be
reexamined with new
recommendations for its use.
The overall objective of
the research is to acquire
process and characterization
information that will allow
development of a decision-
making framework for
predicting the appropriate-
ness and potential efficacy of
"pump and treat" for site
remediation. This research
will support the goals of the
Superfund and RCRA
programs by providing
information necessary to
improve remedial actions at
hazardous waste sites.
The effort will consist of
seven phases or activities:
1) consolidation of existing
information, and develop-
ment of a 5-year plan for
research and development
projects and outputs;
2) development of improved
methods for site characte-
rization; 3) research on
immiscible fluid flow and
residual saturation, and their
effects on pump and treat
methods; 4) research on
mass transport in
heterogeneous media, and its
effect on pump and treat
methods; 5) research on
contaminant sorption to
geologic materials, and its
effect on pump and treat
methods; 6) research and
development of accelerated
remediation methods, such
as combination of pump and
treat with use of surfactants
or micro-organisms; and
7) technical assistance and
technology transfer to
Superfund personnel.
The SCAMP research is a
fundamental part of the
ground-water remediation
theme of this Plan, and
several emerging topics
80
-------
Protecting the Nation's Ground Water
ORD Ground-Water Research Plan
including site characteriza-
tion, behavior of immiscible
substances, sorption,
bioremediation, effects of
heterogeneous media, and
model refinement. It also
strongly supports the
CERCLA and RCRA pro-
grams in site remedy
decisions, and responds to
several Regional research
priorities expressed in a
recent survey of Regional
Superfund offices. In
addition, it addresses several
research activities
recommended by the SAB,
as noted in Chapter 2 of this
Plan.
B. Proposed Initiatives for
FY 1992 and Beyond
Of the many remaining
research needs in ground
water, one high-priority
research area has been
identified for special
consideration in FY 1992
planning. With
consideration of limited
funding availability, the
initiative addresses some of
the emerging topics
discussed earlier in this Plan.
1. Mid-West Agrichemical
Subsurface/Surface Transport
and Effects Research
(MASTER)
EPA, USGS, and especially
USDA have various research
projects in progress studying
the effects of agriculture on
the quality of ground water
and surface water. Although
each agency has its unique
responsibilities and areas of
expertise and concentration,
there is mutual concern
about the fate of agricultural
chemicals as they move
through the environment
that could best be addressed
through a coordinated plan
of study. Such a plan was
drafted in February, 1989,
and selected the mid-
continent soybean and corn-
growing region to determine
the regional factors affecting
the distribution of atrazine,
an herbicide of long-standing
use, through the environ-
ment.
It is expected that
methodologies developed
through this interagency
research could be used by
the agricultural community
and others to predict the
effects of various soil,
hydrogeological, and climatic
factors and management
practices on the distribution
of agricultural chemicals on
ground and surface waters in
other parts of the U.S.
Collectively referred to as
the Mid-Continent Herbicide
Initiative/Mid-West Water
Quality Initiative", this
interagency effort will,
among other things, generate
basic and applied research
into the transport and
transformation of agricul-
tural chemicals in midwest
farmland. The information
afforded from this research
will provide a better basis
for predicting and
controlling the leaching of
agricultural chemicals into
drinking water aquifers.
Currently, ORD is not
funded to contribute to this
research effort other than as
an advisory body. However,
EPA's concerns with
environmental impacts of
pesticides, wellhead
protection, and non-point
source pollution suggest that
basic knowledge in this area
is of primary importance.
The interagency initiative
presents an excellent
opportunity to share and
contribute to an important
research effort. An
interagency work group has
met and agreed on several
proposed research areas for
EPA, should funding become
available.
Of particular benefit to
EPA would be the addition
of research components to
this interagency effort for
studying subsurface
degradation processes of
agricultural chemicals,
behavior of nitrates in
surface and ground water,
macropore flow in the
subsurface, testing and
improving EPA-developed
pesticide leaching models,
real time monitoring
methods, non-point source
monitoring strategies,
interaction of pesticide
runoff with wetlands and
81
-------
Protecting the Nation's Ground Water
ORD Ground-Water Research Plan
potential recharge to ground
water, and ecosystem effects.
This initiative would
address the prevention
theme of this Plan, and the
emerging topics of monitor-
ing strategies for non-point
sources, subsurface behavior
of agricultural chemicals,
and model validation.
MASTER is not entirely a
ground-water initiative,
however much of the
investigation is within the
scope of this Plan. Several
recommendations of the
SAB would be addressed by
this research, as discussed in
Chapter 2. The goals of this
initiative are also consistent
with the President's Water
Quality Initiative, EPA's
Agricultural Chemicals in
Ground-Water Strategy, and
the Agency's support for
inleragency coordination in
research.
2. Other Initiatives to
Consider for the 1990s
Other research initiatives to
consider for the future, in
line with the themes,
emerging topics, and
approaches discussed earlier
include:
• Further development of in
situ, real-time monitoring
devices, to provide faster,
less costly results for
planning, regulatory
compliance, and remedial
actions.
• Improving performance of
remedial technologies.
Identify and develop the
subsurface information and
methods necessary to
improve the selection, use
and performance of ground-
water remedial technologies.
• Environmental profiles, to
develop chemical-specific
reference documents
containing physical/chemical
properties, environmental
transport and fate
information, remedial
methods and treatability
information for significant
ground-water contaminants;
• Characterization of
subsurface heterogeneity,
and quantifying the
dispersion term in different
settings. This impacts the
results of virtually all of the
transport models EPA uses.
• Subsurface transport of
pathogens. Much remains to
be known about the public
health risk of viruses and
bacteria transported via
ground water to water
supplies.
• Abiotic transformations of
contaminants. Non-
biological transformations in
the subsurface are not well
understood for many
compounds, and have
significant effects on
mobility and toxicity;
• Methods for measuring
redox potential in ground-
water samples. This
property is essential for
understanding certain
reactions and modeling the
subsurface, yet current
methods may be inadequate
for measuring it.
• Potential effects of
alternative fuels use and
storage on ground-water
quality. While the use of
certain fuels may improve
ambient air quality, potential
leakage of highly mobile fuel
products from storage tanks
may endanger ground-water
quality.
• Effects of global warming
on ground water. Global
warming may have signifi-
cant impacts on ground-
water quality and quantity,
for example through water
table lowering of major
aquifers and changes in
recharge patterns.
• Enhancement of wellhead
protection research, such as
identifying and preventing
"unaddressed" sources of
contamination, e.g., from
Class V injection wells.
• RCRA Technical Support
Centers. Expand the existing
infrastructure for Superfund
technical support at ORD
laboratories to address
similar problems at RCRA
sites.
-------
Protecting the Nation's Ground Water
ORD Ground-Water Research Plan
• Enhancement of
technology transfer to State
and local users. New and
innovative means of
transmitting research results
can be developed.
• Analysis of water quality
trends in ground water used
for drinking water supplies.
There are various
approaches to analyzing the
growing body of information
on ground-water quality to
better understand national
and regional trends.
• Cumulative hydrologic
impact assessments. The
combined impact of sources
of contamination and
management practices on
aquifers could be
investigated to provide a
better measure of their
individual and combined
impacts on water resources.
C. Future Funding of ORD
Ground-Water Research
At the current funding level
of approximately $23
million/year (total R&D plus
S&E), ORD can respond to
some but not all of the
research needs expressed by
programs. To respond to a
range of needs, both on the
generic and site-specific
scale, on-going research and
new initiatives must be
better supported.
An increase in the
ground-water research
budget could potentially
support within five years a
significant improvement in
the development and
evaluation of databases,
codes, and field
methodologies to respond to
many of the outstanding
needs of EPA programs.
For example, an increase of
funds in transport and
transformation (currently
funded at approximately
$9M/yr.) could advance
current research efforts to
the stage where we might
understand and begin to
predict with some accuracy:
a) the behavior of major
classes of organic
compounds in major
hydrogeologic settings,
b) the transport of
contaminants in certain
complex environments, such
as fractured rock, c) abiotic
transformations of certain
common compounds, and d)
biotransformation in the
subsurface, particularly
under anaerobic conditions.
With an increase in the
monitoring budget (currently
at approximately $7M/yr.) we
could move forward in
developing advanced, low
cost screening and
monitoring techniques for
major contaminants. In
aquifer remediation
(currently at approximately
$5M/yr.) we could be much
farther along in developing,
evaluating, and predicting
the time and cost involved
with a number of subsurface
remedies. In underground
source control (currently at
approximately $lM/yr.) we
could significantly advance
our knowledge of the impact
of injection wells on the
subsurface and consequent
effects on ground water.
In technology transfer and
technical assistance
(currently at approximately
$lM/yr.) we could provide
much needed support for
information clearinghouses,
technology transfer to States,
and greater support for EPA
enforcement cases and other
site-specific ground-water
activities. We could make
major progress toward
improving data management
systems for storing and
accessing the vast amount of
information available for site
characterization.
A larger budget in general
would also improve our
ability to provide seed
money for promising
external projects, and
leverage other agencies and
organizations for cooperative
research efforts.
Congress has considered
new legislation for ground-
water research over the past
several years, including
authorization for additional
appropriations. The
potential impact on current
research activities is not
clear, however significant
new funds might be appro-
priated to carry out the
83
-------
Protecting the Nation's Ground Water
ORD Ground-Water Research Plan
legislative provisions, such as
research demonstrations,
environmental profiles of
significant ground-water
contaminants, and State
grants.
The potential results of
not advancing ground-water
research through some
mechanism (legislative or
otherwise) are: (1) early
contaminant detection and
ground-water protection
limited by untested
monitoring approaches,
(2) uneven predictability of
contaminant transport and
subsequent human and
ecological exposure, (3) poor
source control planning
where based on crude
predictions of contaminant
fate and transport, and
(4) inefficient or ineffective
remedial actions at
hazardous waste sites and
other ground-water
corrective actions.
Aside from these impacts
on implementation of EPA
and State programs, there
are potential impacts of a
lagging knowledge base for
future rulemaking and
national policy development.
A strong, current knowledge
base in ground water has
benefits for many aspects of
environmental programs.
S4
-------
NOTE TO THE READER:
This Ground-Water Task Force Report is a statement of
Agency policy and principles. It does not establish or affect
legal rights or obligations. This guidance document does not
establish a binding norm and is not finally determinative of
the issues addressed. Agency decisions in any particular case
will be made by applying the law and regulations to the
specific facts of the case.
------- |