UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
JFK FEDERAL BUILDING, BOSTON, MA 02203
REGIONAL ASSESSMENT
COMPREHENSIVE GROUND WATER PROTECTION PROGRAM
NOVEMBER 1993
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
JFK FEDERAL BUILDING, BOSTON, MA 02203
REGIONAL ASSESSMENT
COMPREHENSIVE GROUND WATER PROTECTION PROGRAM
NOVEMBER 1993
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TABLE OF CONTENTS
Section Title Page No.
EXECUTIVE SUMMARY E-l
l
I. INTRODUCTION 1
A. BACKGROUND 1
B. OBJECTIVES 2
C. PROCESS 2
II. WATER RESOURCE PROTECTION - FUTURE 4
A. HOLISTIC APPROACH 4
B. USE AND VALUE 5
C. GROUND WATER STRATEGIES 6
III. RESULTS 8
A. BARRIERS TO COMPREHENSIVE PROTECTION. 8
B. ANALYSIS OF RECOMMENDATIONS 13
HEADQUARTER RECOMMENDATIONS 13
REGIONAL RECOMMENDATIONS 14
PROGRAM RECOMMENDATIONS 15
IV. CONCLUSION 26
APPENDICES
APPENDIX A - SURVEY QUESTIONNAIRE
APPENDIX B - TEAM PLAYERS
APPENDIX C - PROGRAM INFORMATION FROM SURVEY
APPENDIX D - PROGRAM & REGIONAL RECOMMENDATIONS
APPENDIX E - HEADQUARTER RECOMMENDATIONS
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EXECUTIVE SUMMARY
REGIONAL ASSESSMENT (REGION I)
I. INTRODUCTION
A. OBJECTIVES OF THE REGIONAL ASSESSMENT
In a gesture of solidarity with the states, Region I
initiated a "Regional Assessment11 of sixteen (16) ground
water-related programs. The objectives of the Regional
Assessment are to: 1) establish a baseline of how EPA
programs function; and 2) identify program recommendations
for better cross-program interaction and support of
comprehensive protection.
B. REGIONAL ASSESSMENT PROCESS
Interview process.
An extensive survey questionnaire was prepared and used in a
series of interviews with each of the 16 ground water-
related programs. The questionnaire was developed using the
6 Strategic Activities and Adequacy Criteria, as described
in the CSGWPP guidance.
Program teams were established, consisting of a ground water
program state coordinator and a member from each of the
ground water-related programs. The regional programs
perceived benefits gained through their participation in the
Regional Assessment.
Baseline Information and Recommendations.
The information developed was used to generate the following
data: 1) baseline information of each program's current
activities and approaches; and 2) program recommendations,
lead contact, and timeframe for implementing each
recommendation (See Appendix C & D).
II. WATER RESOURCE PROTECTION - FUTURE DIRECTIONS
A. HOLISTIC APPROACH
Region I has designated Resource Protection as one of its
goals for Fiscal Year 1994. Through the integration of
programs, critical resources which deserve special attention
due to outstanding value shall be targeted for special
consideration. The principles of Resource Protection is
further complemented by the Water Division's support of a
holistic approach to Water Resource Management for both
state and federal water programs. Through such support,
water programs are encouraged to expand their program focus,
thereby conducting activities and setting priorities based
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E-2
on a thorough understanding of the water resource, including
surface water, ground water and wetlands.
Examples such as the following illustrate several ways in
which regional programs shall be further integrated in
acknowledgement of the interaction between surface water and
ground water, and in support of a holistic approach to Water
Resource Management:
1. Support greater consideration of ground water
protection in surface water programs;
2. Institute formal process for considering ground water
protection into NPDES permits and as a factor in
priority setting;
3. Use pretreatment inspection opportunities to provide
education and outreach materials to permittees
describing Pollution Prevention, BMPs, and ground water
protection;
4. Maps and background information about the importance
and location of priority resources shall be provided to
all water-related programs;
5. State ground water, surface water, and wetland resource
coordinators shall continue to regularly meet.
6. Program 106 integrated grant guidance distributed to
the States shall encourage CSGWPP support;
7. New program initiatives, such as the source water
program, shall be encouraged in order to promote
overall coordination of surface water and ground water
resources;
8. Training shall be provided to EPA program staff to
improve understanding of potential impacts of program
activities on all resources.
B. RESOURCE PROTECTION BASED ON USE AND VALUE
Ground water use, value, and vulnerability will provide the
common tool to geographically target federal and state
resources to meet our mutual goal of "preventing adverse
effects to human health and the environment and protecting
the environmental integrity of the nation's ground water."
Program recommendations provided herein reflect areas where
the programs shall implement measures to further support a
state directed approach to ground water management, based on
the use and value of the resource. For example, the Region's
Superfund and RCRA C Corrective Action Programs shall factor
wellhead protection areas into their priority ranking
systems to determine: 1) where to focus remediation efforts;
and 2) the extent of restoration to the area. Similarly,
the NPDES Program may designate major permits based on high
value ground waters within priority watersheds, and adjust
for the impacts of permitted discharges within or near
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critical ground water areas hydrologically connected to the
receiving surface water body.
The Ground Water Management Section (GWMS) has a
responsibility to facilitate a dialogue to resolve questions
concerning this new approach. In particular, the Region's
Programs need: 1) clear definitions of use, value, and
vulnerability as applied consistently at the federal and
state levels; 2) statewide data and/or maps indicating the
locations of ground waters with designated uses and relative
values defined by the State; and 3) guidance on how to apply
ground water use, value, and vulnerability to mutually
support resource protection and other strategic
environmental priorities. Resolution of such issues shall
be a high priority for the GWMS in Fiscal Year 1994.
III. RESULTS
A. BARRIERS TO COMPREHENSIVE PROTECTION
Background.
A principle goal of this assessment is to identify ways that
Region I can achieve more comprehensive ground water
resource protection. Inevitably, there are barriers that
slow progress toward our goal. During program interviews
and the initial assessment process, several types of
barriers were identified that impede our ground water
protection progress. Generalized barriers that impede
Region resource protection have been divided into eight
principle types. These barriers are described below:
Resources (staff and financial)
Information (availability, quality, accessibility)
Coordination
Ground Water Resource/Contaminant Source Identification
Awareness and Communication about Ground Water Programs
Grants (timing, flexibility, guidance,conditions)
Institutional Restrictions (Regulations, policies)
Public Outreach/Education
Summary of Program Recommendations According to Barriers.
Overcoming barriers to more comprehensive and effective
resource protection requires broad EPA support. Figure 2
shows the number of recommendations identified to overcome
the principle barriers. Such recommendations have been
further divided between recommendations requiring
Headquarters, Regional (e.g. Leadership Team) or Program
Action. Based on the number of recommendations identified
per barrier, Coordination of Activities, Information
Management and Systems, and Institutional Restrictions were
the most commonly identified impediments to comprehensive
resource protection, with a total of 41, 40, and 23
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Figure 2
RECOMMENDATIONS TO ADDRESS BARRIERS
TO A
COMPREHENSIVE GROUND WATER PROTECTION STRATEGY
10 Programs Addressed
BARRIERS
^ Total Recommendations
"Require HQs Action
^if.
^ Require Region Action
*" Require Program Action
BARRIERS
COOR - Coordination
(NFC - Information
INST - Institutional
RESR - Resources
GWIA - GW Issue Awareness
GWID - GW Resource Identification
O/ED - Outreach/Education
GiRTS - Grants
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E-4
recommendations, respectively.
The majority of the recommendations listed for most programs
under the Information Management barrier have been
identified as requiring Headquarters/Regional action (40
total; 23 HQ/Regional). Therefore, due to the scope of the
recommended changes, actions taken to overcome this barrier
must happen at the upper management level. In comparison,
greater than 70% of both the Coordination and Institutional
Recommendations have been identified as requiring program
action, reflecting the ability of changes which address such
barriers to occur more easily at the operational level.
B. ANALYSIS OF RECOMMENDATIONS
1. HEADQUARTERS RECOMMENDATIONS
Although the focus of this Regional Assessment was on
identifying ways to improve coordination and integration
among the regional programs, over 25 recommendations
requiring Headquarters action were identified.
Approximately half of the recommendations addressed the
Information Management and Institutional barriers. Examples
of such recommendations are listed below:
Information Management.
a) Encourage HQ to include mandatory data entries and
reporting requirements for longitude and latitude;
b) Improve the availability and accessibility of EPA data
systems, including PCS and FRDs, and their ability to
link with Geographic Information Systems (CIS);
c) Increase the availability and use of Global Positioning
Units (GPS);
d) Provide adequate resources to support enhancement of
regional/state information management systems.
Institutional.
a) During reauthorization of major statutes (e.g. CERCLA),
recommend changes for consistency with CSGWPP guidance;
b) Promote through legislative and operational changes the
use of "use and value" of the resource as a critical
tool in program activities and priority setting;
c) Encourage creative use of Supplemental Environmental
Projects (SEPs) for prevention projects;
d) Continue to promote linkages between the Public Water
Supply (and other programs) and Ground Water Protection
Programs.
In addition to the above recommendations, many programs
expressed a lack of direction and support on comprehensive
ground water strategies from their national programs.
Approximately 56% of the programs interviewed did not
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receive instructions from their HQs program to support the
comprehensive ground water approach. This inadequate cross-
program commitment from the national programs is reflected
in limited discussion of CSGWPP at national program meetings
and operating guidances. Therefore, some regional programs
believe that without clear direction, business as usual may
prevail.
2. REGIONAL RECOMMENDATIONS
As described in Figure 2, approximately 70 recommendations
have been identified by the programs as changes which
require Regional Action (e.g. Leadership Team).
The following 3 recommendations were agreed upon by the
Region I Ground water Policy Committee as Regional
Recommendations to be forwarded to the Leadership Team for
review/action (date - January 1994):
a) Assign staff/dollars to establish a cross-program
workgroup (e.g. QAT) to overview an assessment of the
region's information management capacity and needs to
support program priority setting. This workgroup would: 1)
examine information availability, accessibility and systems,
building on the state and federal information management
programs; and 2) determine options for increasing
information management capacity where appropriate to support
resource based priority setting;
b) Institutionalize gathering of accurate
longitude/latitude of contaminant source information (e.g.
RCRA facilities, NPDES facilities) in all programs. A
regional cross-program group should be established or merged
with Ed Conley's Good Science Group to lend consistency to,
and set guidelines for locational data gathering. This
recommendation shall address the need expressed by the
programs for accurate locational data to use in priority
setting;
c) Send message to "take a risk" in the creative use of
Supplemental Environmental Projects (SEPs). Enforcement
settlements may include support for resource protection
activities (e.g. support local wellhead protection efforts
in cases where contamination impacts drinking water
supplies; and require protection programs when supplying
alternative water supplies).
3. PROGRAM RECOMMENDATIONS
Theme: Resource Based Protection Approach
Increasingly, Regional programs7 guidance and support to
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Figure 5
DO REGIONAL PROGRAMS CONSIDER GROUND WATER RESOURCE
CHARACTERISTICS IN THEIR PRIORITY SETTING?
GW Characteristics
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16 Programs
Number of Programs
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Figure 6
CONSIDERATION OF NEEDS AND COORDINATION WITH LOCAL GOVERNMENTS
ON GROUND WATER AND CSGWPP ISSUES
s^ _• •' . _ _ • . _ . . _ _ __-... --''-- ' -*
16 Programs
14
a. Do Program objectives
include
working directly with local
governments or interest groups?
b. Does Program consider
Locals' needs in Program's GW
protection planning & efforts?
XlYES
ZllMO
03 NOT APPLICABLE
c. Would local
efforts/info.
benefit Program's ability
to protect GW resources?
d. Does the Program perceive
benefit from discussions with
Locals about local GW
protection?
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E-6
state programs are promoting greater awareness of resource
based priority setting, coordination and decision making.
However, currently, ground water related programs do not
routinely use a number of ground water resource
characteristics for setting priorities, including land use
and aquifer protection. As illustrated in Figure 5, of the
ground water related characteristics programs reportedly
considered, wellhead protection areas (WHPAs) were the most
familiar and most frequently cited.
The following examples indicate program areas where ground
water resource based activities are occurring:
1) the Underground Storage Tank (UST) program has begun
focusing field presence and record inspections in EPA
designated sole source aquifers;
2) the Underground Injection Control (UIC) program has
been advising state UIC programs to focus attention on
wellhead protection areas and to participate in state
multi-media inspections;
3) the national NFS guidance for FY 94 approved funding of
resource based wellhead protection activities as one
means of preventing surface and ground water
contamination.
4) the PWSS program uses frequent contact, program
support, and outreach to water suppliers,
organizations, and their state programs, to encourage
delineating wellhead areas and identifying
contamination threats within them.
RCRA C, Corrective Action, and Superfund programs
recommended they could use locations of critical resource
areas, such as current and expected wellhead protection
areas, to aid in prioritizing and selecting "new starts" for
remedial attention. Towards this approach, Superfund has
undertaken a major contractor effort for accurately locating
latitude and longitude of all public water supply wells
throughout Region I.
Figure 6 indicates the Region's favorable belief that local
programs can provide supplemental assistance.
Involving local communities, with their management
authorities to establish protection bylaws and health
ordinances, and to conduct inspections of commercial
activities, is essential to resource based protection. To
further encourage this, PWSS has recommended it will request
states to share with local communities their results of
sanitary surveys conducted on ground water and surface water
PWS systems.
Theme; Awareness and Coordination
There are a variety of ways awareness and coordination among
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the Region's programs is occurring. For example,
familiarity of programs occurs through routine contact on
program activities. It occurs through contact on special
geotargeted projects such as the Merrimack River Initiative,
Regional activities such as Quality Action Team or
participation on regional workgroups such as the Pollution
Prevention Task Force. For coordination purposes, all
cross-program teams are tracked on LAN Tracking System.
Finally, the Water Division tracks grants and other
initiatives for easy distribution among staff.
States developing adequate Nonpoint Source Management Plans
and Pesticide State Management Plans can expect relying on
them to significantly satisfy Regional review of those
programs for CSGWPP endorsement.
Coordination in developing the Regional Assessment resulted
in new awareness and further understanding of programs'
roles in ground water efforts and CSGWPPs. Pollution
Prevention has recommended to serve in a consulting role to
ground water committees for addressing specific issues.
Many programs including NPS, SW, NPDES, SF, RCRA C, UIC, and
others, sought a stronger role for the GWM program for
coordinating and distributing ground water resource
information.
UST, RCRA C, and the other grant oriented programs, agreed
to continue to insert into grant guidance and workplans, the
requirement for working with the states7 ground water
programs on developing CSGWPPs, and to participate on the
state ground water coordinating mechanisms/committees.
The Marine and Estuarine Protection (M & E) program
recommended they will improve its involvement with the with
GWM and NPS, especially for coastal areas. The Pesticide
program expressed it would improve support and coordination
with the NPS, Bays/Near Coastal and the PWSS programs.
Superfund identified beneficial links with the Ground Water
program and together have accepted several recommendations
to improve coordination between the two programs.
Recognizing the natural interconnection between surface and
ground waters, the Water Quality Management (WQM) and GWM
programs accepted recommendations to improve communication
and education across the programs.
Through national and Regional annual grant guidance, and/or
grant conditions, all ground water related programs will
continue to specify the need for their state programs to
coordinate with states' ground water programs in developing
and implementing its CSGWPP, and to participate in their
state's ground water coordinating mechanism.
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Theme: Information
Programs agreed to define their information needs and
expressed a willingness to address action recommendations.
The Marine and Estuarine Protection, Pesticides, UIC, and
Ground Water programs expressed their need to improve
locational data and to increase the use of Global
Positioning System (GPS) units to gather the data.
Programs accepted considering ground water as a critical
resource area for their activities, but needed to obtain
related information. They recommended that ground water
resource information be coordinated through the GWM program.
Programs including UIC, Superfund, UST, GW, RCRA C, and
others, expressed commitments to support obtaining accurate
latitude and longitude through contractors at remedial
sites, in-field inspections, permit requests. Some programs
have committed to working with their state programs to have
latitude and longitude accurately reported for all new
sources prior to operation and to note when systems are
taken off-line.
Several programs including RCRA C, Stormwater, UIC, Ground
Water Management and PWS expressed a desire for workstation
on-line data system access, and for improved availability
and accessibility, particularly for integrated data
management and access.
IV. CONCLUSION
Developing a Regional comprehensive approach to protecting
ground water is a continuing and evolving process. It is
one that will necessarily involve state, regional, and local
players, which will cause new and recurrent issues to
surface and resurface until adequately addressed. Updating
the Regional Assessment may also be necessary as States
develop and implement state CSGWPPs calling for Regional
support and flexibility based on their unique needs and
circumstances.
Appendix D lists the program recommendations identified
through this Regional Assessment. Programs have committed to
implementing recommendations which were acceptable and could
be addressed in FY'94 and FY'95. Other remaining
recommendations will be tracked and addressed as progress is
made and resources permit. The Region looks forward to
successful implementation of the many actions, through the
participation of all national, regional and state programs
and in support of comprehensive ground water protection.
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REGIONAL ASSESSMENT
I. INTRODUCTION
A. BACKGROUND
1990 GW Protection Strategy.
In 1990, EPA issued its 1990s Ground Water Protection
Strategy, establishing principles and elements for a
"comprehensive" ground water protection program. It
recognized that current protection efforts are fragmented and
occur along particular statutory authorities. The Strategy
specifies an approach of bringing together the capacities of
existing programs in a more cohesive and coordinated style,
across all government levels, to comprehensively manage and
protect ground water resources.
The Strategy calls for states to develop "Comprehensive State
Ground Water Protection Programs (CSGWPP) ." It also specifies
for EPA Regions to similarly improve coordination and
integration among their ground water-related programs and to
support implementation of state CSGWPPs. Some basic tenets of
the Strategy include the following.
• States have the primary role and responsibility to direct
protection efforts;
• Preventing pollution is the principle objective, and is
preferable to clean-up;
• Remedial efforts should be commensurate with, and guided
by, the use and value of the resource;
• Coordination and integration of programs, across
government levels, are the means to a cohesive approach;
• Establishing priorities and activities on a resource
based approach.
1993 EPA Final Guidance for CSGWPPs.
Developed with considerable state input, the guidance
identifies six strategic activities and criteria for
determining the adequacy of states' programs for
comprehensively protecting GW. Successful implementation of
the 6 Strategic Activities demonstrates that a state is
comprehensively protecting its ground water resources based on
its goals and priorities. The Guidance further recognized that
attaining fully integrating comprehensive programs across all
state, federal and local activities, could take several years.
Therefore, as an interim measure of progress, and a
demonstration of a state's commitment to implement a
comprehensive program, EPA issued two "sets" of criteria,
"Core" criteria for an interim level of progress, and the
criteria for the "fully integrating" level of implementation.
The states in Region I are concurrently initiating activities
to develop their Core Comprehensive State Programs, and
concurrently identify areas of improvement to achieve fully
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integrated programs.
B. OBJECTIVES OF THE REGIONAL ASSESSMENT
Responding to EPA's Ground Water Strategy, and to states'
observations that EPA is an impediment to states' practicing
coordinated comprehensive programs, states requested that EPA
also review its own ground water-related programs.
Accordingly, in a gesture of solidarity with the states,
Region I initiated a "Regional Assessment" of sixteen (16)
ground water-related programs. The objectives of the Regional
Assessment are to: 1) establish a baseline of how EPA programs
function; and 2) identify program recommendations for better
cross-program interaction and support of comprehensive
protection.
To take a similar approach to states developing their CSGWPPS,
information for the Regional Assessment was developed
according to the 6 Strategic Activities and criteria, as
described in the CSGWPP guidance. This approach will also
result in complimentary state and EPA programs.
The process for developing the Assessment was intended to
involve as many senior staff and management as possible to
improve the "cultural awareness" of ground water protection
roles and issues. The Assessment does not present general
information on each program since that is available in program
pamphlets, introductions to regulations, orientation
materials, or other program documents. Rather, the Assessment
looks at how the programs function internally, with other
Regional programs and with state counterpart programs. It is
intended to be an effective, action oriented document seeking
to identify and commit programs to undertake recommendations
which will improve ground water resource management and
coordination, both Regionally and with the states.
C. REGIONAL ASSESSMENT PROCESS
Interview process.
An extensive survey questionnaire was prepared and used in a
series of interviews with each of the 16 ground water-related
programs (see Figure 1) . The questionnaire was developed using
the 6 Strategic Activities and Adequacy Criteria, as described
in the CSGWPP guidance. In general, the focus of the program
interviews were on how programs worked internally, with other
Regional programs and with their respective state programs.
See Appendix A for the survey questionnaire.
Program teams were established, consisting of a ground water
program state coordinator and a member from each of the ground
water-related programs. In an interview style, each program
team responded to the Survey questionnaire to generate the
Regional Assessment's information. See Appendix B for the
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Figure 1
PLANNING & :•
. MANAGEMENT
bivisio
N '"::;;;.:..• '•
- POLLUTION
PREVENTION
- INFORMATION
MANAGEMENT
-* FEDERAL
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: Y;.WASTE:G::'V r:.;!:
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-DIVISION: :
.REGIONAL
PROGRAMS
DRA/WASTE
MGMT:
_ UNDERGROUND
~ STORAGE TANKS
~ RCRA C
~ RCRA D
SUPERFUND
AFFAIRS
* FEDERAL
FACILITIES
DIR
; WATER:;
; :; MANAC
;: ^DIVISION;;;
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~ QUALITY
: ;AIR = :!:•::: ; ::- ; • ^ENVIRONMENTAL
.;i:!iiWiANA!QE'WJiENf :!;:•, SERVICES
^DIVISION :;" DIVISION
- PESTICIDES
UNDERGROUND
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16 Programs
*To be Included FY '94
- NPDES
STORMWATER
MARINE &
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GROUND WATER
MANAGEMENT
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listing of the team members representing their programs.
As indicated in Table 1, the regional programs perceived
benefits gained through their participation in the Regional
Assessment.
Baseline Information and Recommendations.
The information developed was used to generate the following
data: 1) baseline information of each program's current
activities and approaches; and 2) program recommendations,
lead contact, and timeframe for implementing each
recommendation. The Regional Assessment presents the baseline
material in the section entitled "Program Information from
Survey Responses," (see Appendix C). Similar to the Survey
format, baseline information was developed and presented
according to the six Strategic Activities and Adequacy
Criteria. The program baseline materials provide the
justification and rationale for the identified barriers and
recommendations. .
The Regional Assessment also presents "Recommendations" for
each program's implementation or involvement. They are the
heart of the Regional Assessment process and report. These
recommendations are the feasible tasks and objectives the
programs have accepted to implement and have assigned a time
frame and a program person to be responsible for
implementation. Predominantly, the recommendations focus on
efforts for programs to improve their coordination and
integration with other Regional and state programs, and on
information management and locational data (latitude and
longitude) issues.
Draft Recommendations and findings from the interview process
were presented to Region I's Ground Water Policy Committee
(GWPC), for their briefing. Among those, three
recommendations having significant cross-program and Regional
implications were highlighted for GWPC adoption, for elevation
to the Region's Leadership Team. See Section III.B.2., for
the three recommendations adopted by the GWPC. As progress is
made, other significant Regional recommendations may be
deliberated by the GWPC. Otherwise, recommendations will be
addressed at the program level. Several recommendations for
HQ programs which require a national "fix" are also presented.
See Appendix 0 for the listings of program, Regional and HQ
recommendations, as outlined on a program basis.
Uncertainties.
The process was effective for involving all state coordinators
from the Ground Water Management program, but by the same
token, was also complicated by having so many conducting the
interviews. Not all questions were asked by the program
interviewers and there were some differences in interpretation
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Table 1
PERCEIVED BENEFITS GAINED BY PROGRAM
THROUGH PARTICIPATION IN CSGWPPS
• GROUND WATER MANAGEMENT
- Coordination and integration could lead to better understanding
of the roles of the Programs in GW protection and lead to
better coordination among them
- Establish rapport with staff and line of communication
with managers
- Expectation of better GIS capabilities with all Programs
participating
• INFORMATION MANAGEMENT
- Will allow Programs to design their programs to better
support other programs
- Better position to provide information to other Programs
for other uses
- Can better support Information Management and Regional
goals
• MARINE & ESTUARIES
- Very little
• NPDES
- Watershed approach coordination
- Possible multimedia and Pollution Prevention
coordination
• NONPOINT SOURCE
- Project integration will provide opportunity to address
the interaction of surface water and ground water, as an
example: surface water can be limitedly improved with
improvements to ISDS that affect ground water quality
• POLLUTION PREVENTION
- Better understand ground water priorities
- Ability to distribute P2 Outreach to a wider audience
• PESTICIDES
- Contributes to assure better review of Pesticide's State
Management Programs (SMPs)
- Contributes to better understanding of GW protection
goals and priorities
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Table 1 (Cont)
PERCEIVED BENEFITS GAINED BY PROGRAM
THROUGH PARTICIPATION IN CSGWPPS
• PUBLIC WATER SUPPLY
- Improved protection of public health through source water
protection, vulnerability assessments and waivers
- Use of source control programs to identify and inspect threats
• RCRA C
- Sharing or networking of GW protection priorities and
state's priorities.
• RCRA D
- Limited benefits to this Program
• SUPERFUND
- Ability to support states as trustees of GW, consistent
with CSGWPP strategy.
- Opportunity to continue a dialogue for federal and state
waste programs to be consistently implemented and coordinated
- If flexibility on use of federal GW classification schemes,
as specified in the NCR can be provided, then EPA will be
able to more fully rely on the states for decisions relating
to GW resources.
• STORM WATER
- More complete understanding of environmental
impact of Programs on GW protection.
- Opportunity to share information so better decisions
can be made to minimize impact.
- Information sharing.
• UNDERGROUND INJECTION CONTROL
- Coordination of Program activities will result in better
protection of GW resources
• UNDERGROUND STORAGE TANKS
- Coordination of State Program Activities will result
in better protection of ground water resources
• WETLANDS
- Protection of Wetlands
• WATER QUALITY MANAGEMENT
- Improved coordination and understanding between Programs
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of questions and responses. Compiling information
consistently across pertinent programs required revisiting
some programs to obtain necessary information. Therefore,
while trends may be accurately extracted from an evaluation of
the data, in some cases it may be misleading to derive
specific conclusions from a limited analysis of the
information.
II. WATER RESOURCE PROTECTION - FUTURE DIRECTIONS
A. HOLISTIC APPROACH
Region I has designated Resource Protection as one of its
goals for Fiscal Year 1994. Through the integration of
programs, critical resources which deserve special attention
due to outstanding value shall be targeted for special
consideration. The principles of Resource Protection is
further complemented by the Water Division's support of a
holistic approach to Water Resource Management for both state
and federal water programs. Through such support, water
programs are encouraged to expand their program focus, thereby
conducting activities and setting priorities based on a
thorough understanding of the water resource, including
surface water, ground water and wetlands.
With respect to ground water, a holistic approach to water
resource management shall emphasize the interconnections
between surface water and ground water. While surface waters
and ground waters were once considered two separate systems,
scientists and environmental planners now recognize that
ground waters and surface waters are hydrogeologically linked
and directly impact each other, both in terms of water quality
and water quantity. An example of an approach which targets
integrated resource protection activities and priorities at
the federal, state and local levels is the Merrimack River
Watershed Initiative. Building on the successful integration
efforts of the Merrimack River Watershed Initiative, regional
programs shall further appreciate the benefits of a broad
resource-based approach to environmental management. As
specified in the Initiative's Declaration of Cooperation,
participants of the Initiative have agreed to recognize the
interaction between surface water and ground water, and
acknowledge the link between land use and water quality.
As a result of the Regional Assessment, EPA Region I has
identified several areas where implementation of program
recommendations shall significantly support coordination of
ground water and surface water protection efforts. Examples
such as the following illustrate several ways in which
regional programs shall be further integrated in
acknowledgement of the interaction between surface water and
ground water, and in support of a holistic approach to Water
-------
Resource Management:
1. Support greater consideration of ground water protection
in surface water programs through discussions within EPA,
and with states, local and other federal agencies;
2. Institute formal process for considering ground water
protection into NPDES permits and as a factor in priority
setting;
3. Use pretreatment inspection opportunities to provide
education and outreach materials to permittees describing
Pollution Prevention, BMPs, and ground water protection;
4. Maps and background information about the importance and
location of priority ground water, surface water, and
wetlands resources shall be provided to all water-related
programs, where available;
5. State ground water, surface water, and wetland resource
coordinators shall continue to regularly meet.
Coordinators shall be responsible for distributing
relevant information to programs and reviewing work plans
to identify potential resource impacts and concerns;
6. Program 106 integrated grant guidance distributed to the
States shall encourage CSGWPP support;
7. New program initiatives, such as the source water
program, shall be encouraged in order to promote overall
coordination of surface water and ground water resources
for the protection of human health;
8. Training shall be provided to EPA program staff to
improve understanding of potential impacts of program
activities on surface water, ground water and wetlands
resources.
B. RESOURCE PROTECTION BASED ON USE AND VALUE
Use, value, and vulnerability of the ground water resource
form the common thread which links all ground water-related
programs at the federal, state, and local levels. These three
factors, embodied in the Agency's ground water policy goal,
provide the basis for defining and applying differential
protection in a consistent manner across programs and
agencies. The final CSGWPP guidance states EPA and the States
must keep prevention of contamination as the first priority
and, when prevention fails or contamination exists must
establish the goal of remediation to restore ground water to
its designated use. Furthermore, the Guidance emphasizes that
a realistic approach to restoration is needed based upon the
-------
actual and reasonably expected uses of the resource, as well
as on social and economic values.
Region I states use a combination of mechanisms to define use
and value, typically through ground water classification
systems and Wellhead Protection Programs. However, further
discussion is needed to ensure consistent application of these
terms. Upon further clarification, ground water use, value,
and vulnerability will provide the common tool to
geographically target federal and state resources to meet our
mutual goal of "preventing adverse effects to human health and
the environment and protecting the environmental integrity of
the nation's ground water."
Program recommendations provided herein reflect areas where
the programs shall implement measures to further support a
state directed approach to ground water management, based on
the use and value of the resource. For example, the Region's
Superfund and RCRA C Corrective Action Programs shall factor
wellhead protection areas or other identified high value
ground waters into their priority ranking systems to
determine: 1) where to focus remediation efforts; and 2) the
extent of restoration to the area. similarly, the NPDES
Program may designate major permits based on high value ground
waters within priority watersheds, and adjust for the impacts
of permitted discharges within or near critical ground water
areas hydrologically connected to the receiving surface water
body.
Regional programs have generally expressed a willingness to
embrace new ways of doing business, namely a state directed
resource-based approach to program activities and priorities.
However, the Ground Water Management Section (GWMS) has a
responsibility to facilitate a dialogue to resolve questions
concerning this new approach. In particular, the Region's
Programs need: 1) clear definitions of use, value, and
vulnerability as applied consistently at the federal and state
levels; 2) statewide data and/or maps indicating the
locations of ground waters with designated uses and relative
values defined by the State; and 3) guidance on how to apply
ground water use, value, and vulnerability to mutually support
resource protection and other strategic environmental
priorities. Resolution of such issues shall be a high
priority for the GWMS in Fiscal Year 1994.
C. GROUND WATER MANAGEMENT STRATEGIES FOR FY'94
To promote ground water protection as an integral part of a
holistic water resource-based approach to environmental
management, Region I's Ground Water Management Section shall
pursue the following:
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1. KEY DIRECTIONS
A. implementation of the Wellhead Protection
Programs (WHPPs)
All states in Region I have approved WHPPs. These programs
provide a broad framework for ground water protection in New
England. However, the success of WHPPs and ultimately ground
water protection across all boundaries lie solely with
effective implementation. In particular, a critical element of
each WHPP is the appropriate delineation of the Wellhead
Protection Areas (WHPAs), a necessary tool for focussing
awareness and activities in multiple programs and at all
levels of government.
B. Federal/State/Local Coordination
Ground water protection activities cast a broad net across
numerous governmental agencies, with a major emphasis at the
operational level on community ground water efforts. In view
of competing resources, support for such local efforts shall
be best accomplished through coordinated activities and
partnerships from all levels. In an effort to communicate
ground water protection strategies to targeted local audiences
who are most directly impacted by the quality of the
resources, the Ground Water Management Section shall foster
partnerships, and support state and local technical assistance
and outreach.
c. Promotion of Ground water Protection
Through comprehensive ground water efforts at the state and
federal levels, a greater awareness of ground water as a
sensitive resource shall be achieved and integration of ground
water-related programs promoted. In addition, continuing
public education efforts shall be sustained to keep alive the
message of resource protection. To support such communication,
the Ground Water Management Section shall facilitate
information gathering and sharing for an expanded network of
community, state and federal ground water protectors.
Particular support shall be provided for implementation of
program recommendations, including providing programs
information on critical ground water resources.
2. ACTION ITEMS FOR GROUND WATER MANAGEMENT SECTION
A. Implementation of WHPPs
Support Technical Assistance Conferences:
Target communities for technical assistance on wellhead
delineations;
Facilitate sharing information on Wellhead Demonstration
-------
8
projects;
Support efforts to identify critical ground water
resource areas and share information among programs;
Pursue funding mechanisms to support state/local WHP
efforts.
B. Federal/State/Local Coordination
Facilitate discussions with federal and state programs on
defining resource protection based on "use and value";
Conduct state/local needs assessment;
Identify local ground water contacts, including Regional
Planning Commissions;
Through the Regional and State Assessments, identify
areas for greater state flexibility and opportunities for
ground water integration;
Utilize Regional Planning Commissions to facilitate
state/local communication and coordination;
Conduct monthly conference call with state partners;
Support local outreach efforts and technical assistance;
Continue comprehensive planning and foster broad water
resource awareness.
C. Promotion of Ground Water Protection
Facilitate successful implementation of program
recommendations from Regional Assessment;
Develop and implement a communication strategy at local,
state and federal levels to promote ground water
protection;
Implement strategy to generate and institutionalize
gathering of information on the success of the program;
Promote efforts to include ground water in critical
presentations and at environmental forums;
Educate broad audiences.
III. RESULTS
A. BARRIERS TO COMPREHENSIVE PROTECTION
1. Background
Effective protection of ground water and other resources is
complicated. Ground water protection, like many of our other
resource protection efforts, cross traditional program and
jurisdictional boundaries. However, comprehensive protection
of multiple resources is essential if we are to achieve the
greatest environmental gains.
A principle goal of this assessment is to identify ways that
Region I can achieve more comprehensive ground water resource
-------
protection. Inevitably, there are barriers that slow progress
toward our goal. During program interviews and the initial
assessment process, several types of barriers were identified
that impede our ground water protection progress. Generalized
barriers that impede Region resource protection have been
divided into eight principle types. These barriers are
described below:
• Resources (staff and financial)
• Information (availability, quality, accessibility,
integration)
• Coordination (within and among Headquarters, Region,
States and Locals)
• Ground Water Resource and anthropogenic Contaminant
Source Identification
• Awareness and Communication about Ground Water Programs
• Grants (timing, flexibility, guidance, grant conditions)
• Institutional Restrictions (Regulations, policies,
organizational culture, operational procedures)
• Public Outreach/Education (awareness, availability and
accessibility of information and activities)
2. Description of Barriers
a. Resources
Sparse financial and staff resources were identified as
hindering support for and implementation of resource
protection. Many programs interviewed felt that staff
resources do not match our responsibilities for evaluation,
planning, coordination, and implementation. In addition, many
programs indicated that significant financial resources were
needed for general program assessment and implementation, as
well as information management system and data enhancements
that could increase our ability to better protect critical
resources.
b. Information
Information describing the Environment and regulated
activities were identified as essential to supporting
comprehensive resource protection. Issues identified as
barriers to ground water resource protection specifically, and
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10
resource protection generally can be divided into the
following four issue areas: data availability, data quality,
data accessibility, and information integration.
The poor availability of quality and useful information
describing the conditions and locations of regulated
activities, contaminant sources, critical resources, and
threats to resources, was identified by many as slowing
progress toward comprehensive resource protection. The
accessibility to these types of information (the ease,
convenience, effectiveness, and speed of access) was viewed by
many as important to routine resource protection decisions.
Many programs indicated that in order to make broader cross
program use of data possible, there was need to overcome
barriers impeding information sharing and to agree on
information standards and key types.
Environmental information provides the basis that we use to
affect environmental protection. Figure 2 illustrates the
number of times program recommendations were identified under
the Information Management barrier. As illustrated by this
Figure, the programs interviewed felt that better and more
efficient use of information would improve our effort to
provide comprehensive protection for a broad spectrum of
critical resources.
c. Coordination
Coordination and the development of formal and informal
cooperative agreements within and among Headquarters, the
Region, States and Locals is necessary if we are to understand
and support mutual efforts to protect and manage environmental
resources. Cross program coordination was identified by many
programs as important to improving resource protection
effectiveness and consistency within the Region and with the
New England States. EPA and state initiatives with watershed
and geographically targeted resource protection focus will
necessitate significant internal and external cooperation that
many felt we are not prepared for. Finally, increasing
emphasis on developing state and local environmental
protection and management capacity, and the promotion of local
leadership of resource protection will require substantial
coordination of our collective environmental protection
efforts.
d. Identification of Ground Water Resource and of
Contaminant Sources.
Identification of critical environmental resources and
contaminant sources is essential for improving programs and
strategies to protect important resources. Resource and
contaminant source information was identified as critical in
-------
Figure 2
RECOMMENDATIONS TO ADDRESS BARRIERS
|| . "• J ; ' ' TO A II | :' :': ; . ill
COMPREHENSIVE GROUND WATER PROTECTION STRATEGY
C/)
10 Programs
BARRIERS
*—'Total Recommendations
I Require HQs Action
^
7K Require Region Action
* Require Program Action
BARRIERS
COOR - Coordination
INFO - Information
INST - Institutional
RESR - Resources
GWIA - GW Issue Awareness
GWID - GW Resource Identification
O/ED - Outreach/Education
GRTS - Grants
-------
11
the coordination of prevention and remediation efforts across
programs, because resource protection is a principal basis for
setting priorities. Many programs felt that the Agency would
be better able to improve EPA and State efficiency and
effectiveness of resource protection efforts if critical
resources could be identified and delineated. By focusing our
efforts on a universe of critical resources, as identified by
EPA and the States, the Agencies could encourage a broader
spectrum of programs to apply their resource protection
abilities to high priority areas. Accordingly, application of
such efforts would not only result in more comprehensive
protection but may also be more economical.
e. Ground Water Program Awareness
Regional programs with impact on ground water resources need
to be aware of ground water protection initiatives so that
they can better support comprehensive resource protection
goals. There is a need to share information about regional
ground water protection activities. Generally, programs
interviewed felt that their efforts to protect ground water
and support state and local efforts could be enhanced with
broader knowledge of activities and direction of ground water
protection. Increased program awareness can also improve
regional comprehensive ground water protection.
f. Grants
Grants are a principal mechanism used by EPA to support
implementation of environmental protection. Enhancement of
grant documents and grant processes can be used to accomplish
comprehensive resource protection. Programs felt that grants
could more extensively use guidance and procedures to
encourage or require cross program communication and
coordination, in support of comprehensive state ground water
protection. Some programs indicated that variable timing of
grant awards by different programs, and the inflexibility to
use grant resource to support ground water and resource
protection presented significant barriers to comprehensive
protection. As indicated by the program recommendations,
grants seem to offer many opportunities to support cross
program integration of ground water and other resource
protection efforts.
g. Institutional Issues
Institutional barriers are external and internal restrictions
that limit staff and program ability to effectively accomplish
environmental protection. Institutional barriers typically
reduce our capability and extend the time needed to accomplish
goals, and may result in a reduced willingness to change
organizational impediments. Often our capability to work
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12
efficiently is impeded by regulations, policy, resources,
logistics, training, and technical limitations and operational
inefficiency. Similarly, our capabilities can be reduced by
organizational cultural phenomena such as politics, turf
battles, program policy, personal agenda, and limited vision.
These types of institutional barriers are identified by many
programs as slowing environmental progress. Increased program
involvement, education, communication, and coordination that
is focused on comprehensive resource protection will present
opportunities to identify and address substantive
institutional barriers.
h. Public Outreach and Education
Sustained successful protection of environmental resources is
dependant on informed action of knowledgeable members of the
environmental community. Directors of EPA, state, local, and
private environmental programs can more effectively support
resource protection, if they understand how their efforts and
those of others can lead to more comprehensive resource
protection. One of EPA's goals is to affect broader public
action supporting environmental protection. Public
involvement is a key means to actualizing this goal.
Ground water resource protection decisions commonly occur
locally. It is important to understand and consider local
perspectives when developing strategies to:
prevent contamination
control contamination
protect resources
manage resource use
Develop environmental standards
Assess resource use and value
Most programs indicated that environmental value could be
added in promoting better understanding of ground water
resource issues. The programs perceived a value to broader
outreach efforts that promote resource protection and
management. In particular, active outreach and initiatives
that provide educational materials and technical help can
support broader public roles in environmental protection.
3. Summary of Program Recommendations According to Barriers
Overcoming barriers to more comprehensive and effective
resource protection reguires broad EPA support. Table 2 shows
the number of recommendations identified to overcome the
principle barriers. Such recommendations have been further
divided between recommendations reguiring Headquarters,
Regional (e.g. Leadership Team) or Program Action. Based on
the number of recommendations identified per barrier,
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Table 2
BARRIERS TO A COMPREHENSIVE GROUND WATER PROTECTION STRATEGY
NUMBER OF RECOMMENDATIONS TO PROGRAM BARRIERS
P
R
O
G
R
A
M
INFO. MGMT.
NONPT . SOURCE
NPDES
PESTICIDES
PWSS
RCRA C
STORMWATER
SUPERFUND
UIC
UST
TOTALS
RESR
4/4
1/0
2/2
4/2
1/1
0/0
1/1
1/1
14/11
INFO
7/7
3/0
1/1
5/1
8/3
4/4
3/3
6/3
3/1
40/23
COOR
3/1
2/0
4/1
1/0
8/0
8/4
3/0
5/0
3/1
4/0
41/7
GWID
3/3
1/0
1/0
1/1
2/2
1/0
1/1
10/7
GWIA
1/1
1/0
1/0
1/0
3/1
3/0
2/1
1/1
13/4
CRTS
1/1
2/2
1/1
2/0
6/4
INST
1/1
2/0
2/0
1/1
2/0
3/1
7/2
3/1
1/0
1/1
23/7
O/ED
2/2
1/0
2/0
1/0
3/1
9/3
TOTALS
21/19
7/0
11/1
7/5
15/1
30/14
23/10
17/5
16/8
9/3
156/66
Recommendation Numbers = Total # Recommendations for Program /
# Program Recommendations Requiring Regional Action
BARRIERS
RESR - Resources
INFO - Information
COOR - Coordination
GWID - Ground Water Resource Identification
GWIA - Ground Water Issue Awareness
CRTS - Grants
INST - Institutional
O/ED - Outreach/Education
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13
Coordination of Activities, Information Management and
Systems, and Institutional Restrictions were the most commonly
identified impediments to comprehensive resource protection,
with a total of 41, 40, and 23 recommendations, respectively.
The majority of the recommendations listed for most programs
under the Information Management barrier have been identified
as requiring Headquarters/Regional action (40 total; 23
•HQ/Regional). Therefore, due to the scope of the recommended
changes, actions taken to overcome this barrier must happen at
the upper management level. In comparison, greater than 70% of
both the Coordination and Institutional Recommendations have
been identified as requiring program action, reflecting the
ability of changes which address such barriers to occur more
easily at the operational level.
The breakdown of the total number of recommendations for
selected programs according to the eight principle barriers is
presented in Table 2. This breakdown illustrates three
principles: 1) the honesty of the programs in assessing their
activities and priorities, and their willingness to find new
and creative ways to achieve their goals; 2) the majority (90
out of a total of 156) of the program recommendations can be
implemented at the operational level; and 3) the extent of the
challenge to provide EPA support from Headquarters and among
Regional programs to overcome regional/national barriers
toward comprehensive ground water protection.
B. ANALYSIS OF RECOMMENDATIONS
1. HEADQUARTERS RECOMMENDATIONS
Although the focus of this Regional Assessment was on
identifying ways to improve coordination and integration among
the regional programs, over 25 recommendations requiring
Headquarters action were identified.
As illustrated by Figure 2, approximately half of the
recommendations addressed the Information Management
and Institutional barriers. Examples of such recommendations
are listed below:
Information Management.
a) Encourage HQ to include mandatory data entries and
reporting requirements for longitude and latitude;
b) Improve the quality, availability and accessibility of
EPA data systems, including PCS and FRDs, and their
ability to link with Geographic Information Systems
(CIS);
c) Increase the availability and use of Global Positioning
Units (GPS);
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14
d) Provide adequate resources to support enhancement of
regional/state information management systems to support
resource protection.
Institutional.
a) During reauthorization of major statutes (e.g. CERCLA),
recommend changes for consistency with CSGWPP guidance -
state directed resource-based approach;
b) Promote through legislative and operational changes the
use of "use and value" of the resource as a critical tool
in program activities (e.g. remediation decisions) and
priority setting;
c) Encourage creative use of Supplemental Environmental
Projects (SEPs) for prevention projects;
d) Continue to promote linkages between the Public Water
Supply (and other programs) and Ground Water Protection
Programs.
In addition to the above recommendations, many programs
expressed a lack of direction and support on comprehensive
ground water strategies from their national programs. As shown
in Figure 3, 56% of the programs interviewed did not receive
instructions from their Hqs program to support the
comprehensive ground water approach. This inadequate cross-
program commitment from the national programs is reflected in
limited discussion of CSGWPP at national program meetings and
operating guidances. Therefore, some regional programs believe
that without clear direction, business as usual may prevail.
Recommendations requiring Headquarters action are listed by
program in Appendix E. In addition, although not specifically
designated as a Headquarters recommendations, many of the
regional and program recommendations have transferability to
the national programs (see Appendix D).
2. REGIONAL RECOMMENDATIONS
As described in Table 2, approximately 70 recommendations have
been identified by the programs as changes which require
Regional Action (e.g. Leadership Team). These recommendations
reflect the perception that due to the scope of recommended
changes, actions require upper management support and
consequently cannot be easily implemented at the program
operational level.
On September 30, 1993, Region I's Ground Water Policy
Committee met to: 1) discuss the preliminary findings of the
programs interviews; 2) determine a process for finalization
of the Regional Assessment; 3) review the Regional
Recommendations; and 4) identify which Regional
Recommendations shall be presented to the Leadership Team for
Regional Action. Understanding resource constraints, the
highest priority items were identified, thereby allowing
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Figure 3
Regional Programs Heive Received Instruction From Their HQs Program
To Support The Comprehensive Ground Water Protection Approach
YES
GWM
NPS
PEST
SF
SW
UIC
UST
NO
INFO
M&E
NPDES
P2
RCRA C
RCRA D
WETLD
WQM
PWSS
No
9
16 Programs
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15
consideration of a few "big" actions while taking many "small"
actions at the program level.
The following 3 recommendations were agreed upon by the Region
I Ground Water Policy Committee as Regional Recommendations to
be forwarded to the Leadership Team for review/action (date -
January 1994):
a) Assign staff/dollars to establish a cross-program
workgroup (e.g. QAT) to overview an assessment of the region's
information management capacity and needs to support program
priority setting. Such program/regional priority setting shall
support Resource Protection, Environmental Justice, and
targeted initiatives like the Urban Lead Project. Since this
exercise would examine information management capacity to
support priorities based on a number of regional initiatives,
representatives from key priority teams would be invited to
participate. This workgroup would: 1) examine information
availability, accessibility and systems, building on the state
and federal information management programs; and 2) determine
options for increasing information management capacity where
appropriate to support resource based priority setting;
b) Institutionalize gathering of accurate longitude/latitude
of contaminant source information (e.g. RCRA facilities, NPDES
facilities) in all programs. A regional cross-program group
should be established or merged with Ed Conley's Good Science
Group to lend consistency to, and set guidelines for
locational data gathering. Institutional efforts may include:
a) changes to permit applications; b) grant conditions to
states; c) increased use of GPS units for inspectors and EPA
contractors; d) use of EPA's information gathering authorities
via mass mailing; and e) greater coordination across programs.
This recommendation shall address the need expressed by the
programs for accurate locational data to use in priority
setting, as illustrated in Figure 4.
c) Send message to "take a risk" in the creative use of
Supplemental Environmental Projects (SEPs). Enforcement
settlements may include support for resource protection
activities (e.g. support local wellhead protection efforts in
cases where contamination impacts drinking water supplies; and
require protection programs when supplying alternative water
supplies). The Multi-media Enforcement Group shall be
encouraged to look harder where projects may result in
significant resource protection. This recommendation is
consistent with a recommendation to HQ to revisit the SEP
guidance and allow greater flexibility.
3. PROGRAM RECOMMENDATIONS
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Figure 4
LOCATIONAL INFORMATION
Latitude/Longitude Data
16 Regional Programs
Yes - 13
NA- 1
No- 3
No- 2
Yes - 8
NR- 1
NA- 4
Programs Aware of
EPA Locational Policy
NA - Not Applicable, NR - No Response
Programs has Need
for Locational Data
in Priority Process
No- 7
Program Encourages
States to Obtain
Locational Data
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16
Several prominent themes were identified during program
interviews which characterize regional cross-program ground
water protection activities. This section will focus on four
major themes: 1) Delegation; 2) Resource Based Approach; 3)
Awareness and Coordination; and 4) Information. A summary of
each theme will be followed by a description of current
practices, and program recommendations to be implemented to
address these areas.
Delegation
To a great extent in Region I, state programs (except NPOES in
three states) have received delegation, primacy, or primary
responsibility under negotiated grants, to administer all
possible programs. States are heavily vested with program
responsibility. This fulfills one of the major tenets of
EPA's Ground Water Protection Strategy for states taking the
primary responsibility for directing ground water protection.
States have greater latitude to set priorities and administer
the programs than if administered by the Region.
Much of the efforts and responsibilities in the major ground
water related regional programs are in state oversight.
Accordingly, the Region's opportunities for impacting states'
activities is generally during program approvals, annual grant
guidance and workplan negotiations, and at mid-year
evaluations. However, the Region does retain some inspection
and enforcement authorities in cases of permit and source
control programs.
Information and recommendations presented in the Assessment
could apply similarly to state programs where states have the
lead activity.
Theme; Resource Based Protection Approach
The "resource based approach" to preventing and cleaning-up
contamination in critical resource areas is one of the key
principles of EPA's Ground Water Protection Strategy. It is
receiving increased support and popularity as it is embodied
in the following:
"watershed protection"
"aquifer protection"
"wellhead protection"
"resource protection"
"source water protection"
Some programs have already included aspects of a resource
based approach into their decision making. In the Nonpoint
Source (NPS) program, competitive grants have been issued to
states where significant water resource areas have been
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17
identified in their State Nonpoint Source Management Plans.
Most recently, the NFS program has issued guidance for states
to identify their priority ground water resource areas.
Another example is the NPDES program issuing permits on a
watershed basis.
Ground Water Resource Based Activity
Current Practice.
Increasingly, Regional programs' guidance and support to state
programs are promoting greater awareness of resource based
priority setting, coordination and decision making. However,
currently, ground water related programs do not routinely use
a number of ground water resource characteristics for setting
priorities, including land use and aquifer protection. As
illustrated in Figure 5, of the ground water related
characteristics programs reportedly considered, wellhead
protection areas (WHPAs) were the most familiar and most
frequently cited.
Wellhead protection areas have been inconsistently considered
in program activities (see Table 3) . Most programs expressed
and understand the importance of WHPAs, but in some instances
neither national guidance nor the priority ranking practices
have included consideration of wellhead protection areas. For
example, RCRA C's National Corrective Action Priority System
(NCAPS), and the program's follow-up Environmental Benefits
Review do not address the presence of public water supply
wells as being different from other types of wells.
Furthermore, RCRA C and other Regional multi-media inspection
programs, do not set inspection and enforcement priorities
based on wellhead protection areas or other critical
resources.
The following examples indicate program areas where ground
water resource based activities are occurring:
1) the Underground Storage Tank (UST) program has begun
focusing field presence and record inspections in EPA
designated sole source aquifers;
2) the Underground Injection Control (UIC) program has been
advising state UIC programs to focus attention on
wellhead protection areas and to participate in state
multi-media inspections;
3) the national NPS guidance for FY 94 approved funding of
resource based wellhead protection activities as one
means of preventing surface and ground water
contamination.
4) the PWSS program uses frequent contact, program support,
and outreach to water suppliers, organizations, and their
state programs, to encourage delineating wellhead areas
and identifying contamination threats within them. Water
suppliers, if they are implementing wellhead protection
programs, can be eligible for receiving waivers from
certain monitoring requirements.
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Figure 5
DO REGIONAL PROGRAMS CONSIDER GROUND WATER RESOURCE
CHARACTERISTICS IN THEIR PRIORITY SETTING?
GW Characteristics
Water
Quality
Availability
Access/Yield
Wellhead
Protection
Aquifer
Protection
Land Use
Watershed
Protection
'II/////////////////h
rV////////
11
NTTIS
//////////rv
Yes
ElNo
L_J Unknown/Not Applicable
16 Programs
0 2 4 6 8 10
Number of Programs
12
-------
Table 3
WELLHEAD PROTECTION
WHP PRIORITIZATION
WHP IMPLEMENTATION
PROGRAMS
GWM
INFO
M & E
NPDES
NPS
P2
PEST
PWSS
RCRA C
RCRA D
SF
DIC
DST
WETLD
WQM
*(D
Considers
WHP in its
Priorities
Yes
*NA
Yes
Yes
Yes
NA
NA
Limited
No
Yes
Yes
Yes
Yes
Somewhat
Somewhat
*(2)
Encourages
State WHP
Priorities
Yes
NA
Yes
No
Yes
Somewhat
Yes
Yes
No
Yes
No
Yes
Yes
Somewhat
Somewhat
*(3)
Knows of
State WHP
Goals
Yes
No
Somewhat
No
Yes
Yes
Somewhat
Yes
Somewhat
No
No
Yes
Somewhat
Somewhat
No
*(4)
Considers
WHP in
Activities
Yes
NA
Somewhat
Yes
Yes
Yes
Yes
Limited
No
Yes
Yes
NA
Yes
Somewhat
Somewhat
*(l) Does the program consider Wellhead Protection (WHP) as a
Program priority for controlling contaminant source activities?
*(2) Does the Program encourage/require state programs to define
and use WHP as a high priority for controlling contaminant source
activities?
*(3) Is the Program knowledgeable of state WHP programs and
their goals?
*(4) Does the Program consider WHP areas in its activities and
decision making?
*NA Not Applicable
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18
Overall, WHP is the only primary and routine ground water
resource characteristic used in setting priorities.
Impediments to Resource Based Practice.
There are a couple of primary impediments to resource based
activities: 1) data availability on resource characteristics;
and 2) the lack of institutional awareness within state,
Regional and HQ programs. To actively incorporate a resource
based approach as a method of carrying-out program work and
objectives on a daily basis, better tools are needed.
Programs need current and accurate information on location and
characteristics of critical water resources, land use,
contamination sources, and populations. All levels of
government need to participate in identifying, obtaining and
using such information, through a state directed CSGWPP.
Until recently, there has been little awareness and
institutional precedent to move from a predominantly control
oriented style of protection to a resource based one. With
added awareness gained from the interview process for the
Regional Assessment, programs have expressed interest on
directing more attention to activities, including inspections,
in wellhead protection areas, if states can provide maps
showing critical ground water resource areas - like PWS wells
and WHPA locations. However, in many cases this information is
not complete. Except for Rhode Island which has all WHPAs
delineated, states are still in the early stages of
implementing their WHP programs and delineating WHPAs. In two
states, preliminary and interim WHPAs for community systems
exist. Therefore, the Ground Water Management Section must
continue to work aggressively with the states in the area of
wellhead delineation.
Obtaining resource characteristics and the locations of
resource areas (such as wellhead protection areas, sand and
gravel aquifers, recharge areas, etc), would allow programs to
direct their activities to protecting them.
Program Recommendations and Commitments to Resource Based
Approach.
Programs now recognize that with limited program resources,
attention should be focused on protecting the critical
resource areas, and to encourage state programs to do the
same. To move in that direction, RCRA C recommends setting
its priorities for inspecting and conducting enforcement
activities on facilities and generators within wellhead
protection areas. RCRA C further recommends use of grant
mechanisms to encourage state programs to pursue resource
based inspections.
Superfund reported that resource based considerations
associated with watershed protection and wellhead protection
are not generally applied. However, all priority setting
schemes do use proximity or distance to private and public
water supply wells. RCRA C, Corrective Action, and Superfund
-------
19
programs recommended they could use locations of critical
resource areas, such as current and expected wellhead
protection areas, to aid in prioritizing and selecting "new
starts" for remedial attention. Towards this approach,
Superfund has undertaken a major contractor effort for
accurately locating latitude and longitude of all public water
supply wells throughout Region I. States are providing their
latest well addresses/locations and are reconciling
differences between state and Region I locations.
Other programs are also making commitments for resource based
activities, including the Ground Water Management program's
commitment to coordinate with state ground water to obtain and
distribute ground water resource information (including
wellhead protection area mapping) to the Region's programs.
NPDES, Underground Injection Control, and others indicated
needing water resource information such as wellhead protection
areas for incorporating resource factors into their
inspection, permitting, prioritizing and for discussions with
their State programs.
In the Nonpoint Source program, the resource based approach is
increasingly occurring. For the last two years, the program
has supported resource-based state wellhead protection
projects with Clean Water Act (CWA) S.319 funding. In FY 93,
two projects included wellhead protection efforts for working
with towns to inventory contaminant source and institute
controls and BMPs and a state multi-program enforcement
approach. In FY 94, National and Regional grants guidance
promoted ground water resource based priority setting by
identifying and supporting grant activities in significant
aquifers or wellhead protection areas. In addition, the
Nonpoint Source program will continue to support critical
ground water resource based targeting by allowing some
flexibility for assessment and planning activities towards
implementing protection projects.
Figure 6 indicates the Region's favorable belief that local
programs can provide supplemental assistance.
Involving local communities, with their management authorities
to establish protection bylaws and health ordinances, and to
conduct inspections of commercial activities, is essential to
resource based protection. To further encourage this, PWSS
has recommended it will request states to share with local
communities their results of sanitary surveys conducted on
ground water and surface water PWS systems. Sanitary surveys
conducted by the PWSS program will be provided to state
drinking water programs with encouragement to also share them
with communities. The RCRA C inspection program also favors
providing inspection results to communities - "makes sense for
building partnerships."
Themet Awareness and Coordination
The Ground Water Protection Strategy recognizes that
-------
Figure 6
CONSIDERATION OF NEEDS AND COORDINATION WITH LOCAL GOVERNMENTS
ON GROUND WATER AND GSGWPP ISSUES
16 Programs
14
a. Do Program objectives
include
working directly with local
governments or interest groups?
b. Does Program consider
Locals' needs in Program's GW
protection planning & efforts?
YES
7]NO
3 NOT APPLICABLE
c. Would local
efforts/info.
benefit Program's ability
to protect GW resources?
d. Does the Program perceive
benefit from discussions with
Locals about local GW
protection?
-------
20
"coordination" is the primary mechanism for developing and
implementing comprehensive protection programs. without
creating statutes and regulations that mandate a new
comprehensive program, the Strategy prescribes use of current
authorities and program practices, brought together through
coordination, for building ground water comprehensive
protection.
Current Practices.
The Region's programs indicated that there are benefits to be
gained by each program, and in resource protection as a whole,
by bringing together the various ground water related
activities from among all programs (see Table 1) .
Comprehensive ground water protection relies on fitting
fragments of existing programs together. The Region's
programs (including NFS, Pollution Prevention (P2),
Stormwater/NPDES (SW), NPDES, PWSS, and others) have indicated
that awareness of each other's functions and needs would be
beneficial to them.
There are a variety of ways awareness and coordination among
the Region's programs is occurring. For example, familiarity
of programs occurs through routine contact on program
activities. It occurs through contact on special geotargeted
projects such as the Merrimack River Initiative, Regional
activities such as Quality Action Team or participation on
regional workgroups such as the Pollution Prevention Task
Force. In addition, there are over 50 cross-program teams in
the Region. For coordination purposes, all of them are tracked
on LAN Tracking System. Finally, the Water Division tracks
grants and other initiatives for easy distribution among
staff.
The interconnection between programs and administrative
efforts is important. For instance, the Quality assurance
Team (QAT) on Grants issues prompted the Region's policy for
issuing all grant guidance to states on or before May 1. This
was the major issue states raised to the Region during state
CSGWPP Roundtables. States had indicated that EPA impedes the
states' abilities to practice comprehensive programs, because
they received grant guidance and grant awards at different
times, precluding good planning across the states' programs.
The Water Management Division has taken a proactive approach
to coordination when it formed a cross-program team for each
Region I state. Teams are composed of state program
coordinators from each of the water programs. State
coordinator teams have developed charters and are meeting to
review annual state objectives and work plan activities for
grant programs, identify significant state initiatives, share
information on projects and state activities and identify
issues relating to resources, staffing or overall performance.
Program coordination from outside of the Water programs are
welcomed and encouraged to attend.
-------
21
At the program level, Table 4 characterizes coordination among
the ground water related programs and identifies whether each
program believes current coordination is adequate. As
indicated by the Table, there are several closely linked
ground water related programs. They include the NFS program,
the Ground Water Management (GWM) program and Underground
Injection Control (UIC) programs. Each has a designated
program contact who works closely with other contacts on
reviewing annual grant guidance and state workplans,
negotiating final grants and approving management plans.
There is a close link also between the Pesticides and the
Ground Water Management programs. Current emphasis is on
developing and reviewing draft Generic Pesticide State
Management Plans. States developing adequate Nonpoint Source
Management Plans and Pesticide State Management Plans can
expect relying on them to significantly satisfy Regional
review of those programs for CSGWPP endorsement.
Superfund has had longstanding assistance from the PWSS
program for developing risk assessments. The Superfund
program also continues to support contractor assistance to
complete locating all public water supplies to a one second
accuracy in all Region I states.
Program coordination with federal agencies is presented in
Table 5.
Program Recommendations and Commitments to Program Awareness
and Coordination.
Most respondents to the Regional Assessment felt cross-program
state coordinator teams would be useful and expressed
willingness to participate on such teams. The Ground Water
program will consider proposing to the Water Management
Division and Ground Water Policy Committee formalizing Region-
wide state coordinator teams.
Coordination in developing the Regional Assessment resulted in
new awareness and further understanding of programs' roles in
ground water efforts and CSGWPPs. With little prior awareness
for ground water issues and CSGWPP initiatives, several
programs including P2 and SW/NPDES programs, had an
opportunity to view their programs in the context of the
Regions ground water efforts and committees. Pollution
Prevention has recommended to serve in a consulting role to
ground water committees for addressing specific issues. In
addition, to promote ground water coordination and awareness,
the P2 program would present emerging issues and concerns
related to ground water in the P2 forums. Similarly, the GWM
program would continue participation on the Region's Pollution
Prevention Task Force "to maintain communication and ensure
integration."
Many programs including NFS, SW, NPDES, SF, RCRA C, UIC, and
others, sought a stronger role for the GWM program for
-------
Table 4
CROSS PROGRAM COORDINATION PERTAINING TO GROUND WATER
PROGRAM RESPONSES - PROGRAM COORDINATES WITH:
P
R
0
G
R
A
M
I
N
T
E
R
V
I
E
W
E
D
GWM
INFO
M & E
NPDES
NPS
P2
PEST
PWSS
RCRA C
RCRA D
SF
SW
UIC
UST
WETLD
WQM
G
W
M
***
3/A
2 /A
3/1
4/A
4/A
4/A
4/1
3/1
U
4/A
2/1
3/A
3/A
3/A
3/1
I
N
F
O
3/A
***
2/A
2/1
3/1
4/A
3/A
4/A
3/1
U
4/A
2/1
2/A
3/A
2/A
3/A
M
&
E
3/1
3/A
***
4/A
4/A
4/A
2/A
U
2/A
U
3/A
3/1
2/A
2/A
3/A
4/A
N
P
D
E
S
2/1
3/A
2/1
***
3/A
4/A
3/A
3/1
2/1
U
3/A
4/A
2/1
2/A
2/A
4/A
N
P
S
4/A
3/A
4/A
2/1
***
4/A
4/A
2/1
2/1
U
2/A
4/A
3/A
2/A
3/1
4/A
P
2
4/1
2/A
2/A
3/1
4/A
***
3/A
U
4/A
U
3/A
2/1
3/1
3/A
2/A
3/1
P
E
S
T
4/A
3/A
2/A
2/A
3/1
4/A
***
2/1
2/1
U
2/A
2/1
2/A
2/A
2/1
2/1
P
W
S
S
4/1
3/A
2/A
3/A
3/A
4/A
2/1
***
3/1
U
4/A
3/1
3/A
3/A
2/1
2/1
R
C
R
A
C
2/1
3/A
2/A
3/A
2/A
4/A
2/A
2/1
***
U
4/A
2/1
2/A
4/A
2/A
2/1
R
C
R
A
D
2/1
3/A
2/A
3/A
3/A
4/A
2/A
2/1
2/A
***
3/A
2/1
U
3/A
2/A
2/1
S
F
4/1
3/A
2/A
3/A
2/A
4/A
2/A
4/A
4/1
U
***
2/1
U
3/A
2/1
2/1
S
W
3/A
2/A
3/1
4/A
3/1
4/A
2/A
2/1
2/A
U
U
***
3/1
2/A
2/A
4/1
U
I
C
4/A
2/A
2/A
2/A
3/A
4/A
2/1
2/A
2/1
U
3/A
2/1
***
3/A
2/A
2/1
U
S
T
2/1
3/A
2/A
2/A
3/A
4/A
U
2/1
3/A
U
3/A
2/A
U
***
2/A
2/1
W
E
T
L
D
2/1
3/A
3/A
4/A
4/A
4/A
2/A
2/1
2/A
U
4/A
2/1
U
2/A
***
3/1
W
Q
M
2/1
3/A
3/A
4/A
4/A
4/A
2/A
2/1
2/A
U
4/A
2/1
U
2/A
4/A
***
GWM - Ground Water Management
INFO - Information Management
M&E - Marine & Estuaries
NPS - Nonpoint source
P2 - Pollution Prevention
PEST - Pesticides
PWSS - Public Water Supply Level of Coordination:
SW - Storm Water 4 - Frequent, Recurrent
SF - Superfund 3 - Occasional, Sporadic
UIC - Underground Injection Control 2 - Rarely to Never
UST - Underground Storage Tanks U - Unnecessary
WETLD - Wetlands Adequacy of Coordination:
WQM - Water Quality Management A - Adequate
A dash (-) indicates no information available, a (?) indicates information unknown. I - Needs Improvement
-------
Table 5
REGIONAL PROGRAM INTERACTION WITH FEDERAL AGENCIES
IN
GROUND WATER PROTECTION ISSUES
REGIONAL PROGRAM
Ground Water Management
Information Management
Marine & Estuaries
Nonpoint Source
Pollution Prevention
Pesticides
Public Water Supply
RCRA C
RCRA D
Stormwater/NPDES
Superfund
UIC
UST
Water Quality Management
Wetlands
FEDERAL AGENCY
FAA, FHA, FmHA, HUD,
IHS
FWS, SCS, USGS
COE, FWS, NOAA, SCS,
USGS
USCG
NOAA, SCS
ASCS, FS, FWS
COE, USGS
USDOE
USDOT
SCS, USDA
None
None
None
COE, FWS, USGS
FHA, NOAA, SCS
ATSDR, COE, FWS,
NOAA, USGS
SCS
None or ?
COE, FERC, FS, FWS,
NOAA, SCS, USGS
COE, FS, FWS
FEMA, FERC, FHA, SCS
LEVEL OF
INTERACTION
Occasionally
Occasionally
Routinely
Routinely
Rarely
Routinely
Occasionally
Rarely
Frequently
Rarely
Routinely
Routinely
Occasionally
Routinely
Routinely
Occasionally
Occasionally
Routinely
Occasionally
ATSDR - Agency for Toxic Substances and Disease Registry
ASCS - Agricultural Stabilization and Conservation Service (USDA)
COE - U.S. Army Corps of Engineers (DOD)
FAA - Federal Aviation Administration (DOT)
FEMA - Federal Emergency Management Agency
FERC - Federal Energy Regulatory Commission
FHA - Federal Highway Administration (DOT)
FmHA - Farmers Home Administration (USDA)
FS - U.S. Forest Service (USDA)
FWS - U.S. Fish and Wildlife Service (DOI)
HUD - Dept. of Housing and Urban Development
IHS - Indian Health Services (DOI)
NMFS - National Marine Fisheries Service (DOC)
NOAA - National Oceanographic and Atmospheric Administration(DOC)
SCS - Soil Conservation Service (USDA)
USCG - United States Coast Guard (DOT)
USGS - U.S. Geological Survey (DOI)
-------
22
coordinating and distributing ground water resource
information. In response, the GWM program accepted a
commitment to coordinate with Regional, federal, and state
agencies to obtain and distribute current information on
wellhead protection areas, other state recognized resource
areas, sole source aquifers and high yield sand and gravel
aquifers. GWM would also provide state resource management
plans that identify or define priority resources. Ground
Water Management program will also work with its state
programs to identify data layers and information Regional
programs could use from the state programs. Continuous
dialogue is necessary now to understand current inventories
and data gathering efforts.
UST, RCRA C, and the other grant oriented programs, agreed to
continue to insert into grant guidance and workplans, the
requirement for working with the states' ground water programs
on developing CSGWPPs, and to participate on the state ground
water coordinating mechanisms/committees.
The Underground Storage Tank program is generally a state
operated program, and annual guidance plays an important role
in coordination. Through the programs, annual grant guidance
the program will encourage increased coordination between the
States UST/LUST programs and the ground water and wellhead
protection programs. Currently, state LUST programs are
considering WHPAs in prioritizing activities. Internally, the
Region's UST program will coordinate and share inspection
results with the Ground Water Management staff.
Several programs expressed a desire and commitment to improve
coordination with other programs. However, constraints are
already affecting programs ability to do so. PWSS and RCRA D
are constrained now from any further coordination beyond
current levels because of limited time and resources. To the
extent resources allow, PWSS would seek further coordination
with the NPS, RCRA C, UST, RCRA D, and other Federal
Facilities programs. RCRA C also expressed concern that
constraining resources may also affect substantial future
coordination efforts.
The Marine and Estuarine Protection (M & E) program
recommended they will improve its involvement with the Ground
Water program, in its activities and with technical staff.
Similarly, it will work to better its coordination with the
NPS, especially for coastal areas. The Pesticide program
expressed it would improve support and coordination with the
NPS, Bays/Near Coastal and the PWSS programs.
Superfund identified beneficial links with the Ground Water
program and together have accepted several recommendations to
improve coordination between the two programs. Jointly, they
will formalize procedures for coordinating on significant
site-specific ground water issues, such as ground water
reclassification, technical impracticability waivers, and
-------
23
creative use of Supplemental Environmental Projects. Like
other programs, Superfund expects to coordinate on using
wellhead protection areas and public water supply locations,
if plotted on CIS maps, for use in determining site
priorities.
Recognizing the natural interconnection between surface and
ground waters, the Water Quality Management (WQM) and GWM
programs accepted recommendations to improve communication and
education across the programs.
Program's Commitments for Coordination with States' Programs.
Region I's states are heavily vested with the delegation,
primacy, or approvals through grant mechanisms, for
administering federal and state ground water related
protection efforts. Consequently, most of the Region's ground
water related programs provide some oversight of state
programs. Coordination, primarily through national and
Regional guidance, sets the direction of program activities.
Annual evaluations oversee the progress state programs are
making.
coordination among state programs is vital, and Regional
facilitation to encourage and support it is important.
Coordination among state programs is the primary objective and
tool for states to implement Comprehensive State Ground Water
Protection Programs.
Through national and Regional annual grant guidance, and/or
grant conditions, all ground water related Regional programs
will continue to specify the need for their state programs to
coordinate with states7 ground water programs in developing
and implementing its CSGWPP, and to participate in their
state's ground water coordinating mechanism.
Regional programs will undertake several actions with their
state programs. Superfund will initiate discussions to
cooperatively understand state and federal differences between
the programs, and to support consistent approaches to priority
setting and determining clean-up objectives. One potential
outcome might be the use of one (1) list of hazardous waste
sites and a priority sequence to cooperatively evaluate and
remediate such priority sites.
The Nonpoint Source and Ground Water Management programs will
coordinate with states to identify ground water priorities
necessary for the grant support and preparation of the revised
FY 94 Nonpoint Source Management Plans. The Stormwater/NPDES
program will improve coordination with GW to encourage
identification of water resource protection priorities and to
develop resource protection strategies. It will prepare fact
sheets for their permit writers, applicants and state
programs. Stormwater agrees with the recommendation to
establish a Regional/State mechanism to prioritize program
activities.
-------
24
In a very important outreach connection to states, and
eventually local officials, the P2 program on request will
coordinate development and distribution of related ground
water and pollution prevention outreach materials. In CSGWPP
meetings with state officials, this type of "hands-on"
information was cited as being critical to state and local
inspectors wishing to promote "good neighbor" relations
between local officials and commercial establishments. The
UIC program will encourage its state program to participate in
the states' multimedia inspections and to increase efforts to
inform state inspectors about UIC issues. The Pesticides and
Ground Water programs commit to improving awareness of state
wellhead protection programs by state pesticides programs.
For the most part, programs saw the importance of local
community involvement in overseeing and managing potentially
contaminating activities. They acknowledge the supplemental
role locals can play in the Region's and state's activities.
(See Figure 6). The degree to which programs work directly
with locals through technical assistance, demonstration
grants, and remedial response, varies among programs. GWM,
PWSS, UIC, and NFS programs support community efforts directly
and through state funded programs. Assistance generally
supports building local capacity for managing their resources
by instituting BMPs, local by-laws or health ordinances and
inventorying local contaminating land use activities.
Remedial response activities assist communities directly.
Contamination incidents often raise community awareness for
instituting their own controls.
Three new opportunities were identified to improve community
awareness and promote local efforts. The RCRA C program
recommends furnishing results of inspections to local boards
of health or other official boards. PWSS agrees to provide
results of their sanitary surveys to state drinking water
programs and will encourage that they be provided to local
boards. PWSS will promote that states do the same.
Superfund will initiate opportunities to establish a mechanism
for communicating with local ground water managers to gain
information on contaminated sites, to verify site locations
(latitude and longitude) and to identify land uses and
management controls.
Theme; Information
"Information" evokes concerned sentiments from those who
believe we cannot manage effectively without it, to those who
say we cannot afford to get it. Information can improve the
program ability to identify priorities, take a resource based
approach to protection and provide a measure for assessing
progress in ground water protection.
Current Practice.
The Regional Assessment survey and dialogue with Regional
-------
25
programs clearly indicated the need for improved information
management and locational data acquisition at the Regional and
state levels. Accordingly, one objective is to
institutionalize information practices at state and federal
levels, and in commercial business activities.
The programs' need for available and accurate information is
reflected in its support for the following:
• applying resource based approach of protection (watershed
and aquifer protection)
• identifying locations of critical resources
• identifying locations of contamination threats
• setting priorities for EPA and state:
inspections and enforcement (RCRA C, UIC, UST, etc)
remedial response (Superfund, RCRA C - NCAPS,
Corrective Action new starts, UST, etc.
targeting areas by "use" and "value"
• directing nonpoint source funding to priority ground
waters
• directing outreach to communities at greatest risk
• providing mapped resource and contamination threats to
local officials and public
• determining Environmental Equity projects
• conducting special initiatives like the Merrimack River
Initiative, or other geotargeted projects
• coordinating with states for annual grant objectives and
workplans and tracking deliverables.
Program's Commitments on Information.
Programs agreed to define their information needs and
expressed a willingness to address action recommendations.
The Marine and Estuarine Protection, Pesticides, UIC, and
Ground Water programs expressed their need to improve
locational data and will work to increase the availability and
use of Global Positioning System (GPS) units to gather the
data.
Programs accepted considering ground water as a critical
resource area for their activities, but needed to obtain
related information. They recommended that ground water
resource information be coordinated through the GWM program.
As indicated previously, the GWM program will work with PWSS
and state programs to obtain and display the location of
public water supply wells and any wellhead protection areas
currently mapped.
The most commonly expressed need was for locational
information and resulted in the recommendations to obtain
accurate latitude and longitude data.
Programs including UIC, Superfund, UST, GW, RCRA C, and
others, expressed commitments to support obtaining accurate
latitude and longitude through contractors at remedial sites,
-------
26
in-field inspections, permit requests. Some programs have
committed to working with their state programs to have
latitude and longitude accurately reported for all new sources
prior to operation and to note when systems are taken off-
line.
Several programs including RCRA C, Stormwater, UIC, Ground
Water Management and PWS expressed a desire for workstation
on-line data system access, and for improved availability and
accessibility, particularly for integrated data management and
access.
Probably the most problematic issues the Region faces for
implementing resource based operations are the fragmented
nature of information management across multiple programs, and
the availability of and access to accurate locational
information on water resources and potential contamination
sources.
IV. CONCLUSION
Developing a Regional comprehensive approach to protecting
ground water is a continuing and evolving process. It is one
that will necessarily involve state, regional, and local
players, which will cause new and recurrent issues to surface
and resurface until adequately addressed. Updating the
Regional Assessment may also be necessary as States develop
and implement state CSGWPPs calling for Regional support and
flexibility based on their unique needs and circumstances.
Appendix D lists the program recommendations identified
through this Regional Assessment. Programs have committed to
implementing recommendations which were acceptable and could
be addressed in FY'94 and FY'95. Other remaining
recommendations will be tracked and addressed as progress is
made and resources permit. The Region looks forward to
successful implementation of the many actions, through the
participation of all national, regional and state programs and
in support of comprehensive ground water protection.
-------
Appendix A
-------
COMPREHENSIVE GROUND WATER PROTECTION PROGRAM
REGIONAL ASSESSMENT
STRATEGIC ACTIVITY 1
ESTABLISHING A GROUND WATER PROTECTION GOAL
TO GUIDE ALL RELEVANT PROGRAMS IN THE REGION
GROUND WATER POLICY COMMITTEE
Implementation Subcommittee
Data Management Committee
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Region I
Regional Assessment
Criteria Questionnaire
Strategic Activity 1
EPA's Ground Water Protection Goal
EPA's ground water protection goal and policy is presented in
"PROTECTING THE NATION'S GROUND WATER: EPA'S STRATEGY FOR THE
1990's - The Final Report of the EPA Ground-Water Task Force," July
1991. It has been further clarified and stated in the "Final
Comprehensive State Ground Water Protection Program Guidance,"
December 1992. EPA's ground water protection goal affects all
ground water-related programs, unless guided otherwise by statute
or regulation.
EPA's overall goal is "to prevent adverse effects to human health
and the environment and to protect the environmental integrity of
the nation's ground water." Except where specified though
regulation or statute, the EPA goal statement notes 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."
In place of criteria, programs should address the following
questions:
a. Has the program received instructions or encouragement from
their HQ program to support and incorporate the Strategy's
comprehensive protection approach into...
- program's internal activities and priorities ? yes, no
- with their state program's activities ? yes, no
b. Has the program discussed or otherwise communicated with their
state program regarding CSGWPP goals/activities ? How..
program director/senior management meetings
annual national/regional program guidance
annual negotiated work plans
grant conditions
other
c. Briefly, identify state ground water protection program goals
or objectives which conflict with the program's ?
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COMPREHENSIVE GROUND WATER PROTECTION PROGRAM
REGIONAL ASSESSMENT
STRATEGIC ACTIVITY 2
ESTABLISHING PRIORITIES, BASED ON CHARACTERIZATION OF GROUND
WATER RESOURCES, IDENTIFICATION OF SOURCES OF GROUND WATER
CONTAMINATION, AND PROGRAMMATIC NEEDS, TO ASSURE DIRECTION
OF ALL RELEVANT REGION I PROGRAMS AND ACTIVITIES TOWARD THE
MOST EFFICIENT AND EFFECTIVE MEANS OF ACHIEVING OUR GROUND
WATER RESOURCE PROTECTION GOAL
GROUND WATER POLICY COMMITTEE
Implementation Subcommittee
Data Management Committee
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Region I
Regional Assessment
Criteria Questionnaire
Strategic Activity 2
1. Determine if EPA Region I Program has established basic
definitions and approaches for a coherent priority-setting
process and is applying them in a consistent manner that supports
protection of around water resources.
a. Does program set priorities after considering program
activity impact on ground water resources?
b. Indicate the ways the prioritization scheme(s) support
protection of ground water resources.
c. Indicate if prioritization is:
required by regulation or statute
required by HQ
required by Region
beneficial to program
a documented process
consistently used
formal or informal
d. Indicate if prioritization rationale has been established
with input or involvement by states or other EPA programs.
How?
e. List program areas where this type of prioritization occurs
and identify activity prioritized. (Prioritization name, if
any) .
Assign degree of threat to resource or people
Geotarget sites or resources for attention
Specifying order of inspections
Specifying order of enforcement
Specifying order of sanitary surveys
Determining staffing levels (investment /
disinvestment)
Others (please identify any others).
f. Does the program encourage or require states to prioritize?
g. Do states prioritize similar activities?
h. How does state prioritization scheme(s) differ from
programs?
i. Indicate programs in Region or states whose activities and
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Region I
Regional Assessment
Criteria Questionnaire
Strategic Activity 2
priority setting would benefit from this program's
prioritization processes.
Indicate programs at EPA or the states who might use
information generated by this program in their respective
program prioritization processes.
k. Indicate whether program could benefit from other EPA or
State prioritization processes?
1. Indicate coordination mechanisms used to discuss program
prioritization w/in the program Regional and state programs.
m. Describe any barriers to prioritizing program activity that
support ground water protection.
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Region I
Regional Assessment
Criteria Questionnaire
Strategic Activity 2
2. Determine if EPA Region I Program uses ground water
priority-setting process that is based on sufficient
consideration of varied ground water characteristics.
Note: In New England the program should assume all GW is
intrinsically vulnerable to contamination, and the threat is
related to land-use activities over the GW.
a. Describe prioritization approach(es) used.
b. Indicate if program priority setting process considers
ground water resource characteristics, or resource related
factors, such as:
flow patterns: yes( primary, minor), no
flow rate (transmiss.): yes( primary, minor) , no
water quality: yes( primary, minor), no
availability (access/yield): yes( primary/ minor), no
sand & gravel aquifer: yes( primary, minor), no
bedrock aquifer: yes( primary, minor), no
wellhead protection: yes( primary, minor), no
State GW classification: yes( primary, minor), no
Fed. GW classification: yes( primary, minor), no
local aquifer prot. zone: yes( primary, minor), no
land-use activity: yes( primary, minor), no
current use: yes( primary, minor), no;
reasonably expected future use: yes( primary, minor),
no;
watershed protection effort: yes( primary, minor), no
c. List any other water resource characteristics considered.
d. Describe any barriers to utilizing ground water
characteristics in program activity prioritization
processes.
e. Describe where program obtains information relating to
ground water characteristics or related factors listed
above.
f. Does the program encourage or require state to include the
above types of factors in setting priorities?
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Region I
Regional Assessment
Criteria Questionnaire
Strategic Activity 2
3. Determine if EPA Region I Program has sufficient
contamination source inventories and assessments to support its
process for identifying all significant potential sources of
contamination and to consistently determine its around water
protection priorities based on the relative threats of these
sources to the resources.
a. Does the program have contaminant sources inventoried?
b. Indicate which significant contaminant sources are
inventoried.
c. Has the program characterized or have sufficient information
on the nature of the threat(s) that each significant
contaminant poses to ground water resources to prioritize
program activity?
d. Does the program set priorities based on relative threats to
ground water?
e. When setting priorities, does the program need contaminant
source information from:
another EPA program? yes, no
a state program? yes, no
local sources? yes, no
another federal agency? yes, no
[Criteria #4 asks "from who", and "how" the information is
obtained?]
f. Describe any barriers to utilizing the contaminant source
inventory information in the program's prioritization
process.
g. Does the program encourage or require state programs to
obtain contaminant source information suitable for use in
priority setting? (Is latitude/longitude info suggested)?
4. Determine if EPA Region I Program has sufficient technical
capabilities to support its priority-setting process and
determinations.
a. Indicate the technical needs of the priority process.
Indicate:
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Region I
Regional Assessment
criteria Questionnaire
Strategic Activity 2
- priority setting criteria (i.e.; pws wells w/in 1/2 mi.)
- types of information needed (GW resource characteristics,
contaminant source inventory, population size, number
of facilities, etc.)
- sources of information needed/used ("who" has the
information and how is it obtained)
- support needed from other programs, federal and state (to
develop data, etc.)
- information management systems that support process
- information formats necessary
- minimum set of data elements necessary
- latitude and longitude w/accuracy to support priority
setting (one second,")
b. Does the program priority setting processes :
use automated information management systems
use Regional GIS
have sufficient trained staff
have mechanism to interact with state data
systems
c. Indicate technical barriers that impede or preclude
prioritization of program activity that can result in better
ground water resource protection.
d. As a routine, how does the program obtain state data
information to support priority setting ?
e. Is the program encouraging or requiring the state to support
detailed mapping and assessment to address the state's
highest priority needs ?
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Region I
Regional Assessment
Criteria Questionnaire
Strategic Activity 2
5. Determine if EPA Region I program has formally adopted
measures of around water protection (e.g.. performance standards.
quality standards, etc), which are sufficient to support
consistent program priority setting and the measurement of
progress toward protection of around water resources.
a. Is your program aware of formal EPA or state adopted
measures of ground water protection, such as:
water quality standards
pollutant discharge standards
soil clean-up standards
contamination mitigation standards
classification standards
reference points
other
b. Indicate which of these ground water protection measures are
used to support prioritization of program activity.
c. Does the program estimate public health and environmental
risk from exposure to contaminated GW ? How is it factored
into priority setting ?
6. Determine if protecting public water supplies is among EPA
Region I's highest priorities and whether controlling contaminant
sources in wellhead protection and recharge areas and basins of
drinking water reservoirs and aquifers is a priority.
a. When prioritizing program activities, does the program
routinely consider the following resource protection areas
as program priorities for controlling contaminant sources:
wellhead protection areas, yes, no
sole source aquifers, yes, no
public water supply sources intakes or points of
withdrawal, yes, no
aquifer recharge areas, yes, no
potential high yield aquifer areas, yes, no
surface water basins draining to public water supply
reservoirs and aquifers, yes, no
public water supply contamination source assessment
areas, yes, no
local aquifer protection overlay districts (zones)
others resource based factors ?
b. Obtaining locations (latitude/longitude) of resource areas
and contaminant sources is crucial to priority setting. How
does the program currently obtain information related to
above resource areas, and for contaminant source activities?
c. Does the program encourage or require state programs to
define and use wellhead protection, or other resource based
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Region I
Regional Assessment
criteria Questionnaire
Strategic Activity 2
areas, as being high priority areas for controlling
contaminant source activities ?
d. How is information for protecting public water supplies
factored into the program's priority setting ?
e. Does the program encourage or require state programs to
obtain locational information (latitude/longitude) in the
state's resource assessment and contaminant source
activities ?
7. Determine if EPA Region I program is sufficiently
coordinating its ground water protection with its surface water
quality and other environmental priorities.
This criteria will be addressed in Strategic Activity #3.
8. Determine if EPA Region I program's priorities sufficiently
incorporate and support a process of on-aoina review and
improvement of the six Strategic Activities supporting Regional
comprehensive ground water protection.
It is assumed that the Region's GW Policy Committee will oversee
an on-going review and improvement of GW activities internally
and with the States.
Addressing this criteria calls for the compilation of all
programs input to the Regional Assessment and is best left to the
end when all data is in.
WRAP UP QUESTIONS
EPA's GW Strategy and states have stressed there is need for
improved state/EPA partnership with states having the primary
responsibility, and that states should have increased flexibility
and EPA support.
What flexibility is there in EPA - State interaction in
implementing program prioritization schemes ?
How can the program better support states' programs toward
comprehensively protecting ground water resources ? (States
will identify specific recommendations important to them).
How could states make your job easier in the area of
priority setting?
How can the program better interact/integrate to support
Regional comprehensive ground water protection in the area
of priority setting ?
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COMPREHENSIVE GROUND WATER PROTECTION PROGRAM
REGIONAL ASSESSMENT
STRATEGIC ACTIVITY 3
DEFINING AUTHORITIES, ROLES, RESPONSIBILITIES, RESOURCES, AND
COORDINATING MECHANISMS ACROSS RELEVANT EPA, STATE, AND LOCAL
PROGRAMS FOR ADDRESSING IDENTIFIED GROUND WATER PROTECTION
PRIORITIES
GROUND WATER POLICY COMMITTEE
Implementation Subcommittee
Data Management Committee
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Region I Page 2
Regional Assessment
Criteria Questionnaire
Strategic Activity 3
I. PROGRAM BASELINE DATA
1. Determine that all EPA around water-related programs
responsible for addressing the Region's and states7 around
water protection priorities are identified. A lead contact
fRA. DRA/coordinating committee, or program director) is
established for coordinating and assisting states7 development
and implementation of their Comprehensive State Ground Water
Protection Programs, and to oversee development of Region I's
Regional Assessment and subsequent implementation.
a. Does the program impact or have a role ground water
protection. If yes, briefly identify.
b. Is the program aware of any Regional coordinating
committee(s) or programs responsible for overseeing
ground water protection in the Region? Identify them.
c. What are the perceived benefits gained by the program
through their participation in comprehensive ground water
protection efforts in the Region and state program?
d. Do the following program guidances include elements or
commitments on ground water protection through developing
and implementing states' Comprehensive Ground Water
Protection Programs, and for developing the Regional
Assessment?
Guidance Yes/No '93 Yes/No '94
Agency Oper. Guidance(STARS)
HQ Grant Guidance to States
HQ FY 93/94 Grant Guidance
Regional FY 93/94 Guidance
Program Strategic Plan (HQ/Reg.)
Other
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Region I Page 3
Regional Assessment
Criteria Questionnaire
Strategic Activity 3
2. Determine if a coordinating mechanism(s) operates that
fa) includes all EPA programs with around water-related
responsibilities, fbl brings all programs' expertise to bear
on EPA/s ground water protection priorities, and (c) supports
development and implementation of states7 Comprehensive State
Ground Water Protection Programs.
a. Is the program represented on the Region I Ground Water
Policy Committee? Is she/he an active participant? Who
is it and what's their title?
b. Is there a designated point of contact between the
program and Region I's ground water program? Who is it?
What is the role and activity of the ground water program
in coordinating and supporting programmatic activities?
Reply: Yes, No, or describe if not included below below) .
Review of the program's annual guidance
Review of the state work plans
Participation in, and review of, program's priority
setting
Participation identifying data needs and supporting
its development
Discussion of program issues for potential Ground
Water Policy Committee attention
Liaison with state ground water programs
Other
c. Has the program participated in any cross program ground
water-related protection activities? What are they
(please be specific)?
Workaday and routine program activities
KPA activities...
Pollution prevention programmatic activity, or on
P2 Taskforce...
Light industry pollution prevention program
material development - dry cleaning, auto services,
pit stops...
Geographic targeted initiatives, Merrimack River
Initiative, Nashua River project, Chesprecot Water
District...
Data management efforts...
Locating water wells or resource assessment...
Other
d. Has the program participated in activities associated
with CSGWPPs? What are they?
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Region I Page 4
Regional Assessment
Criteria Questionnaire
Strategic Activity 3
e. What barriers could limit the program's participation in
coordination efforts?
• across EPA ground water-related programs?
• between the program and states' program?
• between the program and states' ground water
protection program managers?
f. Identify topics and presentations for improving the
coordination mechanism's (Ground Water Policy Committee,
Implementation Subcommittee, and Data Management
Committee) knowledge of Agency issues and functions
(i.e.: priority setting, data management/needs, etc.).
g. Identify internal Regional issues (see "consider" list
below) with potential cross-program implications which
could be raised to the Ground Water Policy Committee (or
Ground Water Management Section) for coordination and
direction.
h. Identify possible state issues (see "consider" list
below) with potential cross-program implications which
could be raised to the Ground Water Policy Committee (or
GW Management Section) for coordination and/or direction.
i. Identify significant program issues or cross-program
matters (see "consider" list below) raised by states that
might be addressed or coordinated through the Ground
Water Policy Committee, or GW Management Section.
Consider:
1) Participation on internal cross-program state work
group for knowledge, coordinating activities
2) State's capability of having lead role and
responsibility for ground water protection
3) Building state and local capacity
4) Conferring more Regional EPA flexibility (if states
do not already have them)
5) Conflicts when programs attempt using resource
oriented approaches (for planning, issuing grants,
prioritizing activities, conducting resource
assessment, and conducting inspections, compliance,
and enforcement)
6) Needing to satisfy "beans" rather than protection
7) States requesting Regional program support,
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Region I Page 5
Regional Assessment
Criteria Questionnaire
Strategic Activity 3
technical assistance, etc.
8) Changing grant / work plan approval process
9) Appropriate use of grants across traditional
program lines
10) Other
OPTIONAL QUESTION
What does the program believe states would ask of the Region
that would support the states' program?
3. Determine if sufficient resources are available to address
EPA's Regional around water protection needs, requirements.
and priorities, and to support Comprehensive State Ground
Water Protection planning and implementation efforts.
a. How has the program made a commitment of staff time and
financial resources directly related to ground water
protection, or to activities and issues having a surface
water - ground water relationship?
b. In what way(s) will the program continue to support
(funding, internal resources, technical assistance) the
development and implementation of the states'
Comprehensive State Ground Water Protection Programs?
c. What improvements could be made on the program's ability
to provide quality service or technical assistance to the
Region's programs, states or the public which would
require additional staff and funding resources?
Consider:
Data collection
Data display and distribution
Resource assessment
Prioritizing resource areas for program attention
Contaminant source locations
Providing technical assistance/expertise to
programs, states, locals and public
Providing technical assistance to states, locals
and public
Conduct public education and outreach
Conducting inspections in critical ground water
resource areas
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Regional Assessment
Criteria Questionnaire
Strategic Activity 3
Taking compliance and enforcement actions in
critical resource areas, as well as by
referrals and special initiatives
Determining use, value and vulnerability of ground
water resource
Other
d. What areas/activities would the program like to focus
allocation of resources (prevention, priority setting,
data management, etc.)? Briefly describe this for states
in general, and for the Region's program).
4. Determine if relevant federal agencies within Region I are
sufficiently informed and consulted in support of Region I's
ground water protection efforts, and in support of states'
development and implementation of CSGWPPs.
Identify the federal agencies with whom the program
interacts, or should interact with, and the typical level
of interaction with each? (Levels include: "routinely,"
"occasionally," "rarely," "never, but should").
Agency Level of Interaction
b. What has been the nature or types of ground water issues
discussed with these agencies and how comprehensive have
been the discussions?
c. Has the program ever had any formal agreement (MOA, MOU,
data exchange agreement, etc.) with another federal
agency? If yes, what was its purpose?
d. How could the program benefit from ground water
protection discussions with another federal agency?
e. How could the program's input benefit another federal
agency?
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Regional Assessment
Criteria Questionnaire
Strategic Activity 3
f. ' Has the program discussed CSGWPP with another federal
agency?
g. Is the program aware of any state agency which has
identified another federal agency regarding a ground
water issue? If yes, identify agencies and issues.
h. Has the state agency asked for the program's/EPA's
involvement? (Briefly describe).
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Region I Page 8
Regional Assessment
Criteria Questionnaire
Strategic Activity 3
5. Determine if EPA has a role in assisting states on interstate
matters, and should initiate coordination efforts / mechanisms
for substantive around water protection issues.
a. Is the program aware of any ground water protection or
management issues that have interstate implications?
If yes, briefly describe the issue(s).
b. Has the program discussed interstate coordination issues
regarding ground water: (briefly, identify agency/issue)?
• within its program or with another Regional
program?
• with any state agency?
• with any federal agency?
c. Has any state(s) requested the program's/Region's
participation or technical assistance in coordinating or
resolving issues between states? If yes, briefly
identify the states and the program's response.
d. Does the program believe the Region should arrange and
facilitate interstate dialog in support of state
activities? Yes, no.
e. Are there any established interstate coordinating
mechanisms that can be used to discuss interstate ground
water protection issues? If yes, identify them, such as
the following:
• New England Interstate Water Pollution Control
Commission
• Northeast Waste Management Officials Association
• New England Water Works Association
• Others
Do interstate issues warrant establishing a new
interstate coordinating mechanism for ground water-
related issues? Yes, no. If yes, what suggestions can
the program make on its nature, structure, and future
agenda.
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Region I Page 9
Regional Assessment
Criteria Questionnaire
Strategic Activity 3
6. Determine if EPA is sufficiently considering local government
(communities, regional planning agencies, etc.) needs and is
encouraging/requiring states to engage and closely coordinate
with local governments on ground water-related issues and
CSGWPPs.
a. Is there a component to the program's mission, Agency
Operating Guidelines / STARS measures, or program
objectives for working directly with local governments or
interest groups? If yes, briefly identify.
b. How does the program involve, if at all, community/local
government (local's role) in the program's planning or
activities?
c. How could the program, further and appropriately, involve
community/local government in the program's planning and
activities?
d. How has the program considered the needs of community /
local government in the program's ground water protection
planning (strategic, annual, etc.) and efforts? Such as
local needs for: (yes, no, not applicable
where the hazards/contamination (RCRA C & D,
Superfund, nonpoint, UIC...) sources exist in
their communities, from EPA/state contaminant
source inventories
where program conducts inspections / and
provides results back to locals
where program takes enforcement actions / and
provides results back to locals
technical assistance for "science" and
facilitation
technical assistance to train local inspectors
development of quality educational materials
for public outreach, and curriculum
emergency response reaction should involve
local officials, and follow-up communication
management options necessary for preventing
and controlling contamination sources
developing advocacy to propel local efforts
developing models, pilots or other initiatives
engaging states to improve state and local
partnerships / connections
other
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Region I Page 10
Regional Assessment
Criteria Questionnaire
Strategic Activity 3
e. How does the program seek to provide necessary tools for
improving local capacity/capability for preventing
contamination to ground water resources?
For instance, the program:
issues grants to communities; yes , no
provides mapped resources; yes , no
provides inventories/addresses/locations of
contaminating sources; yes , no
distributes technical assistance documents;
yes , no
involves locals in program strategic planning;
yes , no
conducts outreach efforts on program and
technical matters; yes , no
provides pollution prevention materials;
yes , no
conducts training for local inspection
officials; yes , no
certifying private inspectors; yes , no
other
Would active local efforts/information directly benefit
or improve the program's ability and effectiveness to
protect the ground water resources? If yes, identify
local efforts/information. (Yes, no, not applicable, or
briefly describe if not listed below).
The following local efforts could benefit the Region's or
states' ground water protection program:
targeting inspections for Region/state visits
conducting inspections
verifying contaminant source information, status
and location (address, lat/long)
identifying critical or significant ground water
resources
identifying land uses, sensitive receptors
verifying new public water supply locations
(lat/long)
identification of local management controls
availability of state or local management documents
others
Does, and how does, the program encourage or require
states to engage and work closely with local governments
and to consider local government needs for ground water
protection and resource management?
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Regional Assessment
Criteria Questionnaire
Strategic Activity 3
h. Is the program willing to use grant guidance, grant
conditions, input to geotargeted initiatives or resource
management plans, to engage and improve state-local
commitments and efforts? If not, why not.
i. Does the program perceive any benefit (in strategic
planning, day-to-day operation, priority setting,
developing technical assistance, etc.) in having
discussions with state and local governments about local
ground water protection?
j. Identify any barriers to considering local ground water
protection needs in the programs activities?
WRAP UP QUESTIONS
This effort and questionnaire is structured for developing the
Regional Assessment with three primary sections, current Baseline
Data (Section I), State Flexibilities (Section II) which can be
conferred upon states by the Region, and Program Recommendations
(Section III) to improve coordination and integration of ground
water-related programs and to assist states in developing and
implementing CSGWPPs
II. STATE FLEXIBILITY
EPA's GW Strategy and states have stressed there is need for
improved state/EPA partnership with states having the primary
responsibility, and that states should have increased
flexibility and EPA support.
To what degree does the program feel the state's program
already has substantial flexibility in administering their
program?
Where are areas of greater state flexibility relating to
defining authorities, roles, responsibilities, resources, and
coordinating mechanisms for supporting ground water protection
activities?
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COMPREHENSIVE GROUND WATER PROTECTION PROGRAM
REGIONAL ASSESSMENT
STRATEGIC ACTIVITY 4
IMPLEMENTING ALL NECESSARY EFFORTS TO ACCOMPLISH
THE REGION'S GROUND WATER PROTECTION MISSION
CONSISTENT WITH THE AGENCY'S POLICIES AND
IN SUPPORT OF THE STATES' PRIORITIES
GROUND WATER POLICY COMMITTEE
Implementation Subcommittee
Data Management Committee
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Region I
Regional Assessment
Criteria Questionnaire
Strategic Activity 4
Page 2
STRATEGIC ACTIVITY 4
I. PROGRAM BASELINE DATA
1. Determine if the Region's programs are being implemented to
attain EPA's objectives and to support the states' CSGWPPs.
Do programs have objective measures such as standards,
criteria or others, which are directed at prevention and
control of contamination?
a. Determine if the program, or program components, is
delegated (approved, issued primacy, or is managed by a
multi-program or multi-agency team, etc.) to states for
primary implementation responsibility.
b. Briefly, describe what your program is all about.
Identify the different components or facets of the
program. And, identify the types of activities occurring
or being encouraged in the Regional and States' programs.
(The list of activities below might be helpful).
c. Does the program use any of the following activities for
prevention/remedial efforts, or support similar state or
local activities? Identify measurable objectives
(standards, criteria...) aimed at reducing or preventing
potential releases of contamination. (Indicate "yes"
below under column).
Regional State Local
Program Program Activity
• Controls through / /
permitting
• Enforcement/compliance / /
and inspection activity
• Other regulatory activity, / /
limits, goals
• Development of management / /
plans
• Development of surface water/ / /
GW water resource assessments
• Development of local action / /
agreements
• Other non-regulatory / /
activity, mgt. controls for
resource protect., monitoring
activities
Performance standards / /
Facility siting criteria / /
Maximum loading criteria / /
BMPs / /
State GW classification / /
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Region I
Regional Assessment
Criteria Questionnaire
Strategic Activity 4
State GW quality standards /
Drinking water MCLs, or health /
advisories
Remediation clean-up levels /
Assessment of health risk levels /
Contamination "threat" associated /
with land-use
Other criteria for decision /
making, (identify)
Page 3
d. Identify standards or criteria in program to reduce or
prevent contamination, or establish remedial action. And,
are they different generally from state criteria?
e. Explain the use of ground water classification in the
program activities and decisions.
f. Do remedial/clean-up programs consider the use and value
of ground water in decision making? (Remedial programs).
Explain the use of 'time' as a management option for
remedial clean-up. (Remedial programs).
h. How does the program decide what is a "reasonable" time
frame for ground water restoration? And, is this
generally different from states approach?
Under what conditions would the program decide to "walk
away from a ground water clean-up (eg: natural
attenuation, or technical impracticability)? Are they
different generally from what states consider?
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Regional Assessment
Criteria Questionnaire
Strategic Activity 4
k. Consider the following programs and activities, and
indicate the type of activity (see list) and the degree
of coordination or involvement the program has with the
other programs listed below:
Is it Adequate?
Program Interviewed Activity & Coordination Yes/no/needs
Level (see lists below) improvement.
1. PESTICIDES
2. NONPOINT SOURCE
3. RCRA C
4. UST
5. RCRA D
6. SUPERFUND
7. INFO/DATA MGT.- CIS
8. UIC
9. PWSS
10. POLLUTION PREVENTION _
11. STORM WATER
12. NPDES
13. REGIONAL COUNSEL
14. GW/WELLHEAD PROTECTION
15. BAYS/NEAR COASTAL ~
16. FEDERAL FACILITIES
Levels of Coordination / Involvement;
Often (routinely), 4; Occasionally, 3; Rarely, 2; Never, 1
Program Activity
A. Annual Grant or Other Program Guidance Development
B. State Work Plan Review
C. State Program Mgt. Plans (NPS, PEST..)
D. Mid-year Evaluation
E . Grants timing and coordination
F. Setting Priorities (State, Regional)
G. Strategic Planning
H. Unilateral or Multi-Media Inspections
I. Compliance / Enforcement
J. Resource Characterization (Wellhead areas, critical
aquifers, sole source aquifers, hydraulic factors, etc.)
K. Coordinating and Intergrating among programs for
considering critical GW resources into programs'
activities and decisions
L. Identifying Contaminant Sources
M. Data Development and Use; obtaining latitude/longitude
N. Surface water - Ground water Interaction
O. Resource Mgt. Plans (Bays/Coastal/Wetlands)
P. Technical Assistance / Expertise
Q. Special GeoTarget Initiatives
R. Public Education / Outreach States & Public
S. Other (Specify)
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Region I Page 5
Regional Assessment
Criteria Questionnaire
Strategic Activity 4
1. How would the program characterize the support between
the Regional GW Management Section and the program? How
can it be improved?
m. Identify Regional programs that could be useful or
beneficial to the program and where support should be
improved.
n. Identify which other Regional programs which could
benefit from the program's activities? (i.e. targetting
geographic and resource areas, conducting inspections,
managing information, obtaining locational data,
reviewing program guidance or work plans, etc.).
o. Participation in a state's GW Coordination Mechanism and
with the Ground Water Protection program is paramount to
the success of states' CSGWPPs.
Does the program encourage or instruct the state's
program to contact and coordinate with the state's....
• Ground Water Program ?
• Another state program ?
• "Ground Water Coordination Mechanism"?
p. Indicate the available opportunities in the program to
encourage / require the state program's participation in
the state's ground water coordination mechanism and with
the ground water program. Indicate the program's
willingness to use these opportunities. (Yes, No, NA)
Consider:
A. Annual national guidance
B. Annual regional guidance
C. Workplan negotiation
D. Grant conditions
E. Mid-year evaluation
F. State-Regional directors meetings
G. NEIWPCC coordination meetings
H. NEMOA coordination meetings
I. Cooperative agreements, MOUs
J. Special initiatives
K. Development of state, resource, or area-wide
management plans (NPS, Pest. SMP, Bays...)
L. Other suggestions (please indicate)
How are the states meaningfully involved in the program's
activities or functions now (where they have input or
participation)? How can these be improved?
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Regional Assessment
Criteria Questionnaire
Strategic Activity 4
r. Are other Regional or state programs, local officials or
public being made aware of the ground water-related
products being prepared, or have been recently prepared,
by the states or other EPA funded recipients? (Yes, no,
and if yes-how)
s. Would the program participate in Regional cross-program
state-specific coordinating committees (similar to those
being established in the Water Management Division? (Yes,
no, if not-why not)
t. Should the GW Management Section consider developing a
low-tech ground water "newsletter" for providing greater
awareness of each others' ground water-related matters?
(Program emphasis, technical assistance documents
received, data base coverages acquired, etc).
u. Does the program, or related geographic or resource
initiative, have a current newsletter? Please identify
it.
v. Does the state's program or related geographic
initiatives have newsletters? What are their names?
w States have identified EPA as a "barrier" to improving
coordination, priority setting and implementation among
their programs. They have asked EPA for coordinated
grant timing across ground water-related programs.
Identify the program's grant process timing (transmittal
of national &/or regional guidance, receipt of draft
workplans, and issue of grant).
Identify any constraints or limitations the program may
have towards improving the Region's coordination (and
possible timing) of grants to states, thereby allowing
states to improve their cross-program coordination.
In what areas could the program provide flexibiliy to
address program priorities of their choice, use funding
across normal grant program lines, support more
"prevention" oriented type activities, direct activities
to significant resource areas, geographic emphasis, etc?
For permit programs, how are ground water concerns
factored into permit activities and decisions?
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Region I Page 7
Regional Assessment
Criteria Questionnaire
Strategic Activity 4
Determine if characterization or assessment of around water
vulnerability, and where appropriate the around water's use
and value, fused in prevention measures) support decisions
affecting around water protection and management in the
Regional program and under states' CSGWPPs.
Note 1. Preventing contamination wherever possible is the
principal objective of the Agency's Ground Water Protection
Strategy and states' CSGWPPs. They emphasize an approach for
identifying critical resources (resource assessment)
vulnerable to potential threats, and for identifying and
locating potential contamination sources (source inventories)
to be controlled and managed.
Note 2. Regarding vulnerability, Region I states' ground
water protection program managers and other programs, have
indicated that ground waters in New England are vulnerable to
potential releases of contamination in nearly all settings.
a. How, and for what purpose, does the program use
information about ground water resource characterization,
(e.g.: flow patterns), and its vulnerability to
contamination?
b. What types of resource-related information are used in
program activities (other than prioritizing- covered
previously), and decision making? (See below).
A. Resource sensitivity
B. Geological/hydraulic parameters
C. Potential yield
D. Aquifer type (bedrock, sand & gravel...)
E. Contamination sources, inventory and locations
F. Ground water quality
G. Current water use
H. Reasonably expected future water use
I. Water resource value
J. Surface - Ground water interaction
K. Public or private well water monitoring
L. State water resource information (explain)
M. Local aquifer protection zones
N. State or EPA GW classification (which)?
0. Others (specify)
c. If resource characterization is not used now, which ones
could benefit the program in planning, activities, and
decision making? Is the program willing to assist
generating and/or obtaining this information? (May wish
to seek Section Chief's thoughts).
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Regional Assessment
Criteria Questionnaire
Strategic Activity 4
d. Is the resource characterization information available
and from whom?
e. Is the program aware of, or using, state resource
information and data coverages? Briefly identify.
f. How, and for what purpose, does the program utilize
information on ground water use. value. and
vulnerability? How are these obtained or determined?
Is the program aware of the Agency's April 8, 1991,
Locational Data Policy? Identify activities using
latitude / longitude.
h. Lat/long has utility in resource assessment and in
contaminant sources inventories. In addition to priority
setting, where could the program benefit from using
lat/long (inspections, monitoring wells, etc)?
i. How is the program moving toward latitude/longitude
collection and use?
How is the lat/long generated by EPA, or shared with
states? Does Region obtain this data from states?
k. Identify barriers to routinely collecting lat/long (one
second accuracy) in the program from now/into the future.
1. Is the program encouraging or requiring state programs to
collect and use locational data?
m. Generally, how well are states' programs or initiatives
collecting lat/long? How could the program assist or
engage the state program for collecting it routinely?
n. Does the program have sufficient technical capabilities
to evaluate, use and integrate ground water
characterization into program activities and decisions?
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Region I Page 9
Regional Assessment
Criteria Questionnaire
Strategic Activity 4
3. Determine if Region is sufficiently considering state Wellhead
Protection Program fWHPl programs and EPA goals when
conducting program activities.
Note: The Agency acknowledges the WHP program as a primary
resource based, prevention oriented program, addressing the
protection of health of public water supply users.
a. Is the program knowledgeable of State Wellhead Protection
programs and their goals? (All states but Maine are
implementing EPA approved programs). (Yes/no/must improve)
b. Does the program or initiative, consider WHP areas
(developed according to state regulation and guidance) in
its activities and decision making? (Yes,no; if no, why
not) .
c. Describe current activities being focused on WHP areas,
such as conducting inspections and enforcement,
inventoring contamination sources, providing outreach to
state programs or local activity.
d. List any specific program activity or decision making
that could consider WHP areas and protection measures,
protecting them directly, or as a secondary outcome
(i.e.; management controls to reduce contaminants to
coastal bays).
e. Many localities protect aquifers through aquifer
protection zones/overlay districts instead of WHP areas.
Has the program/state progrm considered these locally
derived areas? (Yes, no)
f. Identify barriers to using WHP areas in program planning,
activities and decisions?
Does state program consider WHP in their planning,
activities and decisions?
Does, and how does, the program encourage states'
programs to consider wellhead protection in its
activities and decision process?
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Region I Page 10
Regional Assessment
Criteria Questionnaire
Strategic Activity 4
4. Determine if other aspects of around water protection
activities are being implemented.
a. Does the program : (Yes, no).
1. Conduct inspections ?
2. Participate in multi-media inspections ?
3. Coordinate inspection results back to all relevant
ground water-related Regional programs?
What is Region/state relationship on who conducts
inspections and who takes enforcement actions where
authorities overlap? And, is there a formal agreement?
(Attach any inspection forms currently used).
b. What areas does the program believe need additional
implementation (current efforts may not be sufficient-
regardless of cause) - which could reduce or eliminate
potential environmental releases to ground water?
c. Identify improvements the Regional program could make
that would support state programs and improve their
operating effectiveness for protecting ground water
resources? And, have states inquired about this?
d. Generally, and as representing the program, what do you
think states need to do to gain the program's confidence
in states' capacity to "direct" ground water protection
efforts in the state? (May wish to have Section chief's
thoughts).
e. In what way(s) does your program include GW - sw
interaction into its activities and decisions?
WRAP-UP QUESTIONS
This effort and questionnaire is structured for developing the
Regional Assessment with three primary sections, current Baseline
Data (Section I), State Flexibilities (Section II) which can be
conferred upon states by the Region, and Program Recommendations
(Section III) to improve coordination and integration of ground
water-related programs and to assist states in developing and
implementing CSGWPPs
II. STATE FLEXIBILITY
EPA's GW Strategy and states have stressed there is need for
improved state/EPA partnership with states having the primary
responsibility, and that states should have increased
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Region I Page 11
Regional Assessment
Criteria Questionnaire
Strategic Activity 4
flexibility and EPA support.
To what degree does the program feel the state's program
already has substantial flexibility in administering their
program?
Where are areas of greater state flexibility relating to
defining authorities, roles, responsibilities, resources, and
coordinating mechanisms for supporting ground water protection
activities?
III. RECOMMENDATIONS
What are the recommendations for greater integration of all
ground water-related programs with respect to defining
authorities, roles-, responsibilities, resources, and
coordinating mechanisms for supporting ground water protection
activities?
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COMPREHENSIVE GROUND WATER PROTECTION PROGRAM
REGIONAL ASSESSMENT
STRATEGIC ACTIVITY 5
COORDINATING INFORMATION COLLECTION AND MANAGEMENT
TO MEASURE PROGRESS, RE-EVALUATE PRIORITIES, AND
SUPPORT ALL GROUND WATER-RELATED PROGRAMS
GROUND WATER POLICY COMMITTEE
Implementation Subcommittee
Data Management Committee
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Region I Page 2
Regional Assessment
Criteria Questionnaire
Strategic Activity 5
I. PROGRAM BASELINE DATA
1. Determine if Region collects, coordinates, and manages
information, including record-keeping, monitoring, and other
necessary information, within and across all programs to re-
evaluate priorities, measure progress toward meeting EPA
ground water protection goals and priorities, and support
all program activities related to comprehensive state ground
water resource protection.
a. Identify any information that the program currently
collects, manages and/or coordinates, that could be
used by the program, or other Regional or state
programs to protect ground water. (Names of data
bases, types of information, status of inspections and
their results, etc., that can be used for ground water
resource protection). (Provide characteristic print-
out) .
b. What program information is currently provided to, or
requested by:
1. Other Regional programs?
2. States' programs?
3. Local officials and public?
c. How could the information generated, collected and
managed by the program be useful (information exchange)
to ground water protection efforts of: (THINK
CREATIVELY)
1. Another Regional program ?
2. State programs ?
3. Local officials/boards ?
(E.g., providing results of inspections to local
officials - such as Boards of Health; zoning officials)
d. What generally are the complications in acquiring and
using information the program collects and applying it
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Region I Page 3
Regional Assessment
Criteria Questionnaire
Strategic Activity 5
to the program's ground water protection or remedial
efforts?
1. What types of data base problems or shortcomings
currently exist?
2. Can the program extract the data it needs in an
appropriate format to support its ground water-related
activities? If not, briefly explain.
3. Are paper results not routinely converted to
electronic storage and retrieval systems? (i.e.; are
multi-media inspection results being electronically
entered for cross-program, state and local purposes?)
e. Is information which is controlled by the program
readily accessible (available and extractable) to other
programs, state agencies and locals? (Yes, no; if no
briefly explain).
f. Does the program have a plan to assure that program
controlled information can be made available to ground
water related programs? (Yes, no). And, identify any
barriers that hinder acquistion of information / data.
"Environmental Indicators" - What information is
currently collected by the program, other programs or
state programs, that can be used for measuring progress
in ground water protection, and for remedial
improvement?
Can the program suggest any indicators for showing
progress being made on protecting ground water
resources (preventing contamination) in the Region I?
(Whether from Region/state/or local agencies). (Yes,
no; if yes please describe your suggestion).
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Region I Page 4
Regional Assessment
Criteria Questionnaire
Strategic Activity 5
i. What program issues regarding information and data
collection, management and use, would the program like
addressed, or otherwise clarified or brought to the
awareness of the Ground Water Policy Committee?
2. Determine whether Region uses, and otherwise encourages
states to use relevant data from local governments and other
state and federal programs (i.e., Wellhead, Public Water
Supply, etc.) to re-evaluate priorities, measure progress
toward meeting EPA/State ground water protection goals and
priorities, and support all program activities related to
Comprehensive State Ground Water Resource Protection.
a. Does the program use ground water related information
/data from other Regional, federal, states or local
programs to support their ground water resource
protection and remedial activities? (Yes, no; if yes,
identify source and information type).
Current Information Type of Information /
Sources Data
b. What critical information does the program need now,
but does not have, for setting and re-evaluating
priorities, measuring progress, assessing ground water
resources, etc.? Who has it, and are there barriers to
obtaining it and using it (i.e., incompatible computer
formats, information is not qualified, staff time and
resources are insufficient to extract it from paper or
electronic files, etc.)?
c. Is the program aware of, and uses, state developed
information from state management and assessment
reports? (Such as those below, to assist in setting
priorities, issuing grant guidance, developing
pollution prevention information, identifying
prevention activities to be supported, measuring
progress toward protecting ground water resources,
etc.). (Yes, no; previously unaware of state reports)
1. Nonpoint Source, Section 319 State Management
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Region I Page 5
Regional Assessment
Criteria Questionnaire
Strategic Activity 5
Program reports identifying activities, practices
and watersheds for improving NFS contamination to
surface and ground waters.
2. Wellhead Protection Program reports
3. Comprehensive Coastal Management Plan reports
4. Section 305 (b) Water Quality Assessment Reports
5. State Clean Water Strategies
6. State Ground Water Protection Strategies
7. others ?
d. Does the program specify to the state program what
information/data to collect, manage and/or use? (Yes,
no; if yes, identify the information).
e. How does the program encourage and support state
programs to collect and use relevant information from
other state, local and federal programs?
f. What would the program like to see the state's program
do to: (So that the program and state's program can
re-evaluate priorities, support activities, and measure
progress towards protection goals):
1. Improve on the information currently collected and
managed; and, how the information can be put to other
uses?
2. Improve on how the information is collected and
managed.
3. Have states requested assistance from the Region?
4. How can the Region support state efforts?
g. Is the program willing to use grant guidance, grant
conditions, work plan negotiations, program delegations
(mid-year evaluations, directors meetings, etc.)* to
encourage or require state programs to improve on their
collection, management and use of information/data?
(Yes, no; if no, why not)
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Region I Page 6
Regional Assessment
Criteria Questionnaire
.Strategic Activity 5
3. Determine if Region has defined a sufficient set of data
elements to facilitate efficient data sharing and cross
media analyses, and determine if Region is providing data
users with constant comparable data that is suitable for use
in all ground water related programs.
a. Has the program identified a specific set of ground
water related data elements that would support efforts
by the program or others to protect ground water?
b. Is the program and state's program aware of EPA's
minimum set of data elements? (Yes, no).
c. Indicate any specific program data elements that may be
important to other programs with responsibility to
protect ground water.
d. Indicate if the program has been part of discussions
about development of or use of data to support ground
water protection.
(1) cross program use of data
(2) data quality standard
(3) minimum sets of data elements
(4) data automation
(5) data management system enhancement to
facilitate data access or data transfer.
(6) program use of CIS to display data and make
decisions
(7) facility, site, data point locational
standards
(8) program information needs assessments
(9) other
NOTE; Nearly all programs recognize the importance for obtaining
and using accurate locational data (re: latitude and longitude,
"lat/long"). There is agreement that lat/long is paramount for
identifying areas where human health and ecology are at risk from
potential ground water contamination. Lat/long serves:
• To chart critical ground water resources (through related
aquifer/watershed hydrogeologic characteristics, etc.)
• To map human activities as sources of potential
contamination
• As a major factor in Regional/state strategic planning and
program activities (i.e.; directing inspections and
enforcement activities, directing remedial activities,
adding to ground water resource characterization and
understanding, etc.)
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Region I Page 7
Regional Assessment
Criteria Questionnaire
Strategic Activity 5
• To facilitate cross-program, cross-jurisdiction pollution
prevention through coordinated federal, state, and local
efforts.
Address the following questions regarding LAT/LONG: (Many of the
responses may have been previously given in other places, but,
please bear with us to coalesce the information in this section).
e. Is the program aware of the Agency's national
locational data policy and its requirements for
implementation? (Yes, no; if no, why not)?
f. What program functions now collect information
including lat/long? And, what purpose does location
information currently serve? If it is collected, but
not used, explain why. Identify barriers: (i.e.,..
• there is no purpose for it's use
• the information is imprecise, unqualified, and cannot
be used for charting or mapping purposes
• in paper format, not useful in strategic planning or
other program activities
• not included in HQ or Regional data base
• not accessible or retrievable in any useful format
• site assessment and monitoring locations at remedial
sites
• other (explain)
g. Does the program now use locational data from another
program, or from states? If yes, identify the program,
type of information, and whether the information is
adequate.
h. What additional locational data does the program most
have need for, and for what purpose would it be used?
i. How would the program like to see improvements in
locational data collection and management in its
program or other Regional program?
j. What improvements would the program like to see in
locational data collection and management in its
state's program or other state program? Briefly
summarize relevant discussions conducted.
k. How can the program support state efforts, and identify
any barriers to obtaining locational data.
1. Obtaining locational data now for all Regional
facilities, permits, monitoring wells, contaminant
generators, public water supply inlets, nonpoint
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Region I Page 8
Regional Assessment
Criteria Questionnaire
Strategic Activity 5
sources, etc., is expensive and resource limited.
Identify any means (opportunities) for collecting
accurate locational data on existing and new points
from this time forward.
THINK CREATIVELY.
• (i.e., all inspectors at Regional and State programs
carry GPS units to obtain accurate fixes
• all applications (instructions to filing forms) at
Regional and state programs could require certified
location fixes
m. Is the program willing to use grant guidance, grant
conditions, work plan negotiations, program delegations
(mid-year evaluations, directors meetings, etc.), to
encourage or require state programs to improve on their
collection, management and use of locational
information / data? (Yes, no; if no, why not).
4. Determine if EPA monitoring program scope and design reflect
EPA and State ground water protection priorities and goals.
a. Does program perform or influence any monitoring
program with impact on ground water quality or quantity
or ground water resource management.
b. Does the program use or have need for information from
monitoring programs that have impact on ground water
that are managed by other EPA or State programs? (Yes,
no; if yes what information from whom?)
c. Has program discussed the scope and nature of any
monitoring programs and their support of ground water
protection with other EPA or State programs? Briefly
describe status of discussions.
d. Identify any types of monitoring that the program has
interest in.
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Region I Page 9
Regional Assessment
Criteria Questionnaire
Strategic Activity 5
WRAP-UP QUESTIONS
This effort and questionnaire is structured for developing the
Regional Assessment with three primary sections, current Baseline
Data (Section I), State Flexibilities (Section II) which can be
conferred upon states by the Region, and Program Recommendations
(Section III) to improve coordination and integration of ground
water-related programs and to assist states in developing and
implementing CSGWPPs
II. STATE FLEXIBILITY
EPA's GW Strategy and states have stressed there is need for
improved state/EPA partnership with states having the
primary responsibility, and that states should have
increased flexibility and EPA support.
To what degree does the program feel the state's program
already has substantial flexibility in administering their
program?
Where are areas of greater state flexibility relating to
coordinating information collection and management to
measure progress, re-evaluate priorities, and support all
ground water-related programs?
III. RECOMMENDATIONS
What are the recommendations for greater integration of all
ground water-related programs with respect to coordinating
information collection and management to measure progress,
re-evaluate priorities, and support all ground water-related
programs?
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COMPREHENSIVE GROUND WATER PROTECTION PROGRAM
REGIONAL ASSESSMENT
STRATEGIC ACTIVITY 6
IMPROVING PUBLIC EDUCATION AND PARTICIPATION
IN ALL ASPECTS OF GROUND WATER PROTECTION
TO ACHIEVE SUPPORT OF THE
STATE'S PROTECTION GOAL, PRIORITIES, AND PROGRAMS
GROUND WATER POLICY COMMITTEE
Implementation Subcommittee
Data Management Committee
-------
I. PROGRAM BASELINE DATA
1. Determine if an active public education program exists that
addresses the key issues in decisions on the goal,
objectives, priorities, and progress of the Region's and
states7 comprehensive ground water programs.
a. Is there a public education / outreach / or involvement
component in the program's mission, strategic planning
objectives, Agency Operating guidance - STARS measures,
HQ or Regional annual guidance, etc? (If yes, identify
where it is included).
Briefly describe the program's current public education
and outreach to the states and the public. (For
instance, what types of "technical assistance
documents11, fact sheets, pamphlets, etc., are developed
for state and local distribution?).
c. Describe how, if at all, states' or local programs are
involved in the program's strategic planning,
establishing objectives of the program, or in
identifying the needs for public education and
outreach?
d. Briefly describe how the program encourages or requires
the states' programs to include an active public
education, outreach and participation component to its
activities.
Identify ways the program could improve its public
education and outreach efforts, particularly in support
of improving local capacity and awareness (advocacy)
for preventing ground water contamination, and for
addressing the use and value of ground waters involved
in remedial activities.
-------
f. Identify technical assistance the program could provide
to states' programs to support and improve states
public education and outreach efforts. Have states
asked the program for any assistance?
Identify ways the states' programs could improve their
public education and outreach activities.
h. Are there any public education or outreach issues at
the Regional, state, or local levels that should be
presented to the Region's Ground Water Policy Committee
for consideration at the Regional level?
WRAP-UP QUESTIONS
This effort and questionnaire is structured for developing the
Regional Assessment with three primary sections, current Baseline
Data (Section I), State Flexibilities (Section II) which can be
conferred upon states by the Region, and Program Recommendations
(Section III) to improve coordination and integration of ground
water-related programs and to assist states in developing and
implementing CSGWPPs
II. STATE FLEXIBILITY
EPA's GW Strategy and states have stressed there is need for
improved state/EPA partnership with states having the
primary responsibility, and that states should have
increased flexibility and EPA support.
To what degree does the program feel the state's program
already has substantial flexibility in administering their
program?
Where are areas of greater state flexibility relating to
improving public education and participation in all aspects
-------
of ground water protection to achieve support of the state's
ground water protection goal, priorities, and programs.
III. RECOMMENDATIONS
What are the recommendations for greater integration of all
ground water-related programs with respect to improving
public education and participation in all aspects of ground
water protection to achieve support of the state's ground
water protection goal, priorities, and programs.
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Appendix B
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REGION I - PROGRAM REPRESENTATIVES FOR REGIONAL ASSESSMENTS
Ground Water Manager Assignment for Regional Assessment
September 1993
REGIONAL PROGRAM PHONE
GROUND WATER MGR.
Rob Koethe
Bob Morehouse
Frank Battaglia
Bill Torrey
Myra Schwartz
John Hackler
Aaron Gilben
Chuck Franks
Dennis Huebner
Greg Charest
Dave Delaney
Ralph Abele
Chris Ryan
Abby Swaine
Jay Brolin
Shelly Puleo
Jerry Potamis
Janet Labonte
Steve Silva
Steve Couto
Brain Rohan
Rob Adler
Matt Liebman
Dave Turin
PESTICIDES *
NONPOINT SOURCE *
RCRAC*
UST*
UST
RCRA D (Waste CIS)
RCRAD *
RCRAD
SUPERFUND *
DATA MGT/GIS *
UIC *
WETLANDS
PWSS-WATER SUPPLY *
POLLUTION PREVENT.
STORMWATER
NPDES/PERMJTS
NPDES/PERMJTS
NPDES/ENFORCEMENT
NPDES/ENFORCEMENT
REGIONAL COUNSEL
GW/WHP/SSA *
BAYS/NEAR COASTAL
WATER QUALITY
565-3702
565-3513
573-9643
573-9604
573-5743
573-9670
223-5529
573-9678
573-9610
565-4528
565-3615
565-4438
565-3609
565-4523
565-3590
565-3528
565-3575
565-3566
565-2489
565-3499
565-4972
565-3601
565-4866
565-3543
Tara Tracy
Tara Tracy
Rob Adler
John Haederle
(Same)
Michele Notarianni
(Same)
(Same)
Jane Downing
Dave Delaney
Dave Delaney
John Haederle
Chris Ryan (PWS)
Michele Notarianni
Dave Delaney
(Same)
Irish Garrigan
Irish Garriagn
Jane Downing
Jane Downing
Jane Downing
Rob Adler
Doug Heath
Doug Heath
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Appendix C
-------
WASTE
MANAGEMENT
DIVISION
\
UJ
o
-------
PROGRAM: SUPERFUND
STRATEGIC ACTIVITY 1 - GW PROTECTION GOAL
CRITERIAVS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
Regional Programs are aware of and promote consistent ground water
protection strategy goals.
* The goal of EPA's Superfund approach to ground water remediation is to
return usable ground waters to their beneficial uses within a
timeframe that is reasonable given the particular circumstances of the
site.
* The Ground Water Protection Strategy provides overarching guidance
that the program considers in deciding how best to protect human
health and critical systems threatened by contaminated ground water.
The "Guidelines for Ground Water Classification" is used as guidance
to help make decisions on the level of ground water cleanup at
Superfund sites (see Strategic Activity #4 below). [Note: These
guidelines are in draft form and have not been consistently and widely
used throughout the Agency.] The Strategy and the Guidelines are not
used as strict criteria (e.g.ARARs) but rather to set goals for ground
water cleanup (e.g.remediation approaches).
* Although the program has communicated with their state programs
regarding CSGWPP goals and activities, instructions from Superfund's
national program has been vague.
* Program believes that existing state classification schemes may not
have realistic goals and therefore may limit the ability of the
federal program to fully endorse a state directed resource-based
approach to ground water remediation at Superfund sites.
* Existing federal laws and regulations may limit ability of program to
embrace CSGWPP.
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PROGRAM: SUPERFUND
STRATEGIC ACTIVITY 2 - PRIORITIES
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program has established approaches for its priority-setting process to
protect GW resources.
* The CERCLIS data base includes over 2500 potential contaminated sites.
The progression of a site may include the conduct of a Preliminary
Assessment (PA), Site Inspection (SI), Worst First? Site Screening
(WFSS), Hazardous Ranking System (HRS), Superfund Accelerated Cleanup
Model (SACM), Remedial Investigation (RI), and Feasibility Study (FS).
Prioritization occurs to various degrees throughout to determine: 1)
which sites are listed on NPL; 2) potential early action; 3)
assignment of resources.
* There is no prioritization for Pas. A PA is performed for all sites
referred to EPA for investigation (60 Pas/year) within one year of
entry of CERCLIS. The PA is scored by using a modified version of the
HRS (40 CFR Part 300).
* All sites are not screened out after a PA is completed and must
proceed to the next step (SI) by law. The large backlog of sites
needing an SI or SIP are assigned as resources become available,
selecting candidates for Sis could be based in part on CSGWPP.
* All sites with both a completed SI and a preliminary HRS score greater
than 28.5 are subject to the WFSS process to determine relative
priorities for further federal action. HRS is utilized to determine
whether sites are eligible for proposal on the National Priority List
(NPL).
* SACM screening is performed on pre-NPL and NPL sites for
identification of potential early actions, including Time Critical and
Non-Time Critical Removal Actions.
* Unstarted RIs are prioritized to determine which NPL sites should be
actively worked on.
* The regions give monies to the states to conduct PA/Sis; for sites
near NPL proposal, the Region discusses their priorities with the
states. The state prioritization scheme for state waste sites is not
widely known and is conducted independent from EPA's priority scheme.
Criterion #2
The Program demonstrates consideration of varied GW characteristics in its
priority-setting process.
* A high priority is placed on sites with significant GW contamination;
When determining threats posed by GW contamination for priority
setting, all GW is assumed to be drinkable.
* The above priority schemes incorporate knowledge of the following GW
Characteristics:
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GROUND WATER
CHARACTERISTICS
Flow Patterns
Flow Rate
Water Quality
Availability
Aquifer Type
Wellhead Prot.
State GW Class.
Fed.GW Class.
Local Prot.
Current Land
Use
Future Land Use
Watershed Prot.
Efforts
Nature of Cts.
(ONAPLS)
PA/ SI
X
X
X
X
X
WFSS/
HRS
X
X
X
X
X
SACM
X
X
X
X
X
X
X
X
X
X
X
RI/FS
X
X
X
X
X
X
X
X
X
X
X
* The nature and extent to which GW characteristics are factored into
the above priority setting reflect the availability of such
information at various points in the Superfund pipeline (see Strategic
Activity #4 below).
* In addition to the above GW characteristics, all priority schemes use
information about ecological endangerment, impacts to wetlands and
distance to private or public water supplies.
Criterion #3
Regional Programs have contamination source information available to
identify potential threats to GW and to set priorities based on the
relative threats to ground water resources.
* All sites (non-NPL, pre-NPL, NPL) which come into the federal door is
inventoried in the CERCLIS data base. There are over 2500 sites
currently in CERCLIS, 700 with completed Sis.
* The states have separate overlapping lists of state sites and
generally do not share their information for the purpose of compiling
one universe (federal and state) of contaminated sites.
* When setting priorities, the program receives information on
contaminant sources from EPA-Environmental Services Division, State
Waste Programs, local government (zoning etc.) and the public.
Lack of state-wide contaminant source mapping of >700 potential HRS
-------
sites limit the program's ability to compare such locations against
resource characteristics on a broad scale in order to accomplish
priority setting based on the value of the resources.
Criterion #4
The Program has technical capabilities to support its GW protection
priorities and decisions.
* The ability to incorporate resource characteristics into priority
setting is restricted by the availability of such data (e.g. resource
mapping), particularly in the early stages of the pipeline prior to
site-specific studies.
* The program.."does the best we can with what we have." The priority
schemes (WFSS vs. HRS vs. SACM vs. RI/FS) are designed to fit the
capabilities of the program and each reflects the appropriate level of
available data.
* In order to conduct resource-based priority setting, the program needs
the following types of information: 1) contaminant source inventories;
2) affected population size; 3) GW resource characteristics (see
criterion — above); 4) locational site data; and 5) perceived
threats. The inability to obtain such information will limit the
quality of the priority setting.
* For pre-remedial sites, contractors use available background data,
including USGS topographical maps; state and local contacts are
surveyed for existing data relating to the site, including distance to
water supplies and land use activities. For SACM sites and sites where
RI/FSs have been conducted, ground water characteristics are derived
from field-generated data (e.g. well logs, water level measurements,
permeability tests); state and federal GW classification information
is provided by state/federal contacts.
* Barriers that impede prioritization include: 1) lack of GIS
capability; 2) lack of consistent GW classification; 3) lack of
understanding of use, value, vulnerability. GIS was used for mapping
contaminant sources and ground water resources in CT. "It's a dream
do it for all others." There are also priority screens which may
complete with resource preference for example environmental justice,
economic impact, community interest, enforcement appeal etc.
Criterion #5
The Program has included measurement objectives for GW protection priority-
setting and methods for assessing the Program's progress in the protection
of GW resources.
* Drinking water standards, GW classification standards, population
served and preliminary risk assessments are used to support
prioritization of program activities.
* Sites which pose significant threats to human health from exposure to
contaminated GW, as defined by preliminary risk assessments, are
assigned a greater priority at the SACM and RI/FS stages. For example,
sites which pose an imminent threat to drinking water supplies are
likely to be candidates for early actions, including time-critical
removal actions. Exposure pathways (e.g. # of receptors) are factored
into the HRS prioritization.
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Criterion #6
The Program's activities give high priority to managing contamination
sources in wellhead protection areas and other public water supply source
areas.
* The program considers the following resource protection areas as
program priorities for controlling contaminant sources:
RESOURCE PROTECTION AREAS
Wellhead Protection Areas
Sole Source Aquifers
Publ. Water Supply Intakes
Aquifer Recharge Areas
High Yield Aquifer Areas
Watershed basins assoc. w/
Surface/GW Water Supplies
Local aquifer protection
overlay districts
Private GW supply recharge
areas
Other
YES
X
X
X
X
NO
X
X
X
X
HRS evaluates the proximity of public water supplies to hazardous
waste sites. For new sites, highest priority for assigning resources
would generally be given to sites whose GW contamination threatens
public water supplies. However, the ability of the program to assess
such high priority sites is sometimes limited by the ability to
accurately locate sites against critical resource areas (e.g. wellhead
protection areas).
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PROGRAM: SUPERFUND
STRATEGIC ACTIVITY 3 - RESPONSIBILITIES
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program has been identified as GW related and lead contact named to
support Regional GW & CSGWPP matters.
* Prioritization for identifying NPL sites and early actions are based
on perceived threats to human health and the environment from exposure
to contaminated ground water. Removal/remedial decisions relating to
cleanup technology, restoration time frame, and cleanup levels are
guided by state and federal laws, regulations and GW classification
schemes.
* Perceived benefits gained by the program through participation in
CSGWPP include: 1) support of states as trustees of GW; 2) consistency
across state/federal programs (e.g.one site list). Core state grants
could include a push for states to participate in comprehensive
strategy.
* Dennis Huebner (NH&RI Waste Management Branch) is Superfund lead
contact - Overall GW Policy Issues for Waste; GW Policy Steering
Committee GW Implementation Subcommittee.
Criterion #2
The Program is involved with the Regional GW coordinating committee and
supports cross-program activities & CSGWPPs.
* Program is represented on the GW Policy Committee by Mel Hohman (GW
Strategy Advocate) and Dennis Huebner (Superfund lead contact).
* Federal GW program supports program activities by conducting selected
risk assessments and providing policy input on GW-related issues.
* Program has participated in cross program activities (Merrimack River,
Nashua River, locating public water wells) and CSGWPP state round
tables.
* The following barriers impact the ability of the program to
participate in coordination and CSGWPP efforts: 1) resources; 2) NCP-
federal statutes and regulations that establish EPA response actions;
3) state GW contacts not known; 4) lack of direction by national
programs to convince the regional programs that EPA is serious about a
state directed-resource based approach to GW management.
Criterion /3
The Program has staff and resources allocated for GW protection concerns
and support of CSGWPPs.
* Resources, both funding and staff time, are directed at identifying,
prioritizing, assessing and remediating hazardous waste sites. The
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vast majority of such sites have ground water contamination problems.
Therefore, Super fund commits significant resources towards ground
water management.
* Program will support implementation of a state directed resource-based
approach to the extent allowed under federal laws, regulations and
guidance. Further clarification on potential conflicts between NCP and
CSGWPP guidance needs to be provided by the national programs.
* Program expects to continue support for CSGWPP through staff review
time and input.
* Improvements should be made in the following areas to improve the
program's ability to support CSGWPP: 1) funding; 2) resource
assessments; 3) priority setting; 4) contaminant source locations; 5)
targeting activities in critical resource areas; 6) determining use,
value, vulnerability.
Criterion #4
Relevant Federal Agencies are informed & consulted by the Program in
support of Regional GW protection efforts and state development of CSGWPPs.
* The program interacts routinely and has formal agreements with Federal
Facilities (GW Assessment & Remediation) , ATSDR (Health Assessment) ,
NOAA (Environmental Assessment, Army Corps of Engineers (GW
Remediation) , USGS (GW Assessment) , US Fish & Wildlife (Environmental
Assessment) .
* The program has not discussed CSGWPP with other federal agencies and
does not believe Super fund's CSGWPP efforts could benefit from input
from such agencies at this time.
Criterion #5
The Program coordinates with the states to assess interstate matters, and
assists and encourages interstate cooperation.
* Interstate coordination may be necessary if a site encompasses ground
water contamination that crosses state boundaries (none to-date) .
* In such cases, New England Interstate Water Pollution Control
Commission and Northeast Waste Management Officials Association are
established mechanisms that could be used for discussion of interstate
GW protection issues.
Criterion #6
The Program considers local needs and encourages/requires States to closely
involve and assist locals.
* Every removal and remedial action must comply with specific public
participation requirements including: 1) community relation plans; 2)
public repositories; 3) public meetings/hearings; 4) public comment
periods.
* Due to resource constraints, .. "the program is doing as much as it can
to involve town and local governments" in the program's planning and
activities.
-------
Local needs of educational materials, technical assistance (TAG
grants) and emergency response capabilities are factored into
program's planning.
The following local efforts could benefit the program's ability to
support CSGWPP:
LOCAL EFFORTS
TARGETING INSPECTIONS
CONDUCTING INSPECTIONS
VERIFYING CONTAMINANT SOURCE INFORMATION
IDENTIFYING CRITICAL RESOURCES
IDENTIFYING LAND USES
VERIFYING PUBLIC WATER SUPPLY LOCATIONS
IDENTIFICATION LOCAL MANAGEMENT CONTROLS
AVAILABILITY OF MANAGEMENT DOCUMENTS
YES
X
X
X
X
X
X
NO
X
X
1
1
1
There could be an additional complication if local GW classification
are different from either state or federal.
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PROGRAM: SUPERFUND
STRATEGIC ACTIVITY 4 - IMPLEMENTATION
CRITERIAVS. PROGRAMINFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program coordinates, integrates, and prioritizes resource-based
efforts, and evaluates them to improve the Region's and State's GW
protection efforts.
* Superfund program is managed by EPA, with input from states. States
have parallel but distinct waste programs which are responsible for
overseeing state hazardous waste sites. The program does not know how
the state waste programs function, including priority setting and
cleanup decision making. Remediation goals may be similar for state
and federal sites because they form the basis for State ARARs, but the
technical means to cleanup state sites may be different.
* The Superfund program has multiple components each directed at
the assessment and control of ground water contamination:
SITE ASSESSMENT
REMOVAL/REMEDIAL
COST RECOVERY/ENFORCE.
This program is
responsible for:
management of the
CERCLIS data base;
oversight and conduct
of Preliminary
Assessments (Pas),
Site Investigations
(Sis) of pre-remedial
sites; screening and
listing of sites on
the National Priority
List (NPL).
This program is
responsible for: the
assessment of the
nature and threats of
contaminated sites;
selection, design and
performance of removal
and remedial actions.
This component of the
Superfund program is
responsible for the
documentation of costs
incurred at sites, and
enforcement actions,
including responsible
party searches,
negotiations, and
settlements or
referrals.
Performance standards for remedial action can be health-based (e.g.
MCLs, toxicity standards, health advisories), ecologically-based
(e.g.AWQCs), or technology-based (e.g. mass reduction of pollutants).
The ground water classification influences the decisions relating to
cleanup levels and remedial activities. Typically for ground water
classified as potable, the cleanup levels shall be MCLs or other
health-based standards. As described in the preamble to the National
Contingency Plan (NCP), the Ground Water Protection Strategy and the
"Guidelines for Ground Water Classification are not ARARs but help
define situations for which standards may be ARARs and help set goals
for ground water remediation. "EPA will make use of state
classification when determining appropriate remediation approaches for
ground water. Classification of ground waters by EPA is only done to
the extent it guides remedy selection. If the use of state
classification would result in the selection of a nonprotective
remedy, EPA would not follow the state scheme." Region I's Office of
Regional Counsel (ORC) has determined that the above wording of the
NCP provides flexibility for EPA to defer to the state classification
-------
schemes in cases where use of such classifications would result in a
protective remedy.
As described in the CSGWPP guidance, EPA's goal is to remediate all
aquifers to meet their designated uses. Decisions relating to what the
program considers what a reasonable restoration time frame may greatly
influence the nature and extent of the remedial action selected for
the site. For example, a selected restoration time frame of 10 years
vs. 30 years may result in a more aggressive remedial action (e.g.
pump and treat vs. natural attenuation).
The decision on what is a reasonable time frame for GW restoration
generally is determined through a site-specific analysis of
alternatives and by a balance of nine criteria, including protection
of human health, cost, effectiveness and implementability. Such
factors such as location, proximity to population and likelihood of
exposure shall be used when determining remediation timeframes. In
addition, Superfund regulations specify that "EPA's preference is for
rapid restoration, when practicable, of Class I ground waters and
contaminated ground waters that are currently, or likely in the near
term to be, the source of a drinking water supply" and where
institutional controls are not clearly effective or reliable.
Reasonable restoration time periods may range from very rapid (one to
five years) to relatively extended (perhaps several decades)." The
Preamble to the NCP further specifies that "if there are other readily
available drinking water sources of sufficient quality and yield that
may be used as an alternative water supply, the necessity for rapid
restoration of the contaminated ground water may be reduced." The
program is not aware of how the states determine what is a
"reasonable" time frame for restoration for state sites.
The decision on the type of remedial action, including natural
attenuation, is determined by a balance of nine criteria, including
protection of human health, cost, effectiveness and implementability.
Technological impracticability may be used as a justification to
choose a less aggressive cleanup strategy although still protective.
As described in the Preamble to the NCP, "natural attenuation is
generally recommended only when active restoration is not practicable,
cost-effective or warranted because of site-specific conditions or
where natural attenuation is expected to reduce the concentration of
contaminants in the ground water to the remediation goals - levels
determined to be protective of human health and sensitive ecological
environments - in a reasonable timeframe." The program is not aware of,
how the states determine whether to "walk away from a ground water
cleanup" for cleanups at state sites governed by state law.
The program has described the following areas where the Ground Water
Management Section can better support their GW-related activities: 1)
coordinate information of locations of Wellhead Protection Areas
(WHPAs), Sole Source Aquifers (SSAs) and location of other critical
resources; 2) facilitate site-specific dialogue with state GW programs
on use and value of GW; 3) consultation on site-specific GW issues,
including GW reclassification; 4) GW policy discussions.
Program does not encourage or instruct state's program to contact and
coordinate with the state's GW Coordination Mechanism and GW program
(coordination between state waste and GW programs is assumed). The
program is willing to use the following opportunities to promote state
internal coordination: 1) annual national guidance; 2) grant
conditions; 3) Program Directors meeting; 4) NEMOA meetings; 5)
-------
cooperative meetings; 5) special initiatives.
* In accordance with the regulations, the program gives the state a
reasonable opportunity for comment on site documents and coordinates
with them on a routine basis. EPA gives money to the states to
participate in all program activities.
* Cooperative agreements with the states to perform Pas/Sis are
negotiated at the end of the fiscal year. Core multi-site cooperative
agreements are finalized throughout the year.
Criterion #2
The Program obtains/uses information to assess resource vulnerability for
remedial/prevention actions; and considers resource use and value in
remedial efforts and in prevention efforts where appropriate.
* Use and value of the ground water is considered in the remedial
decision making to the extent the state ground water classification
systems have factored such parameters into its classification scheme.
The program asks for clarification on methodologies on measuring the
use and value of ground water. In particular, the CSGWPP guidance
states that EPA must take a realistic approach to restoration based
upon the actual and reasonably expected uses of the resource as well
as on social and economic values, but does not explain how to measure
such use and value.
* As part of the Remedial Investigation conducted to assess the nature
and extent of contamination, the following resource-related
information may be compiled and evaluated: geological parameters,
yield, aquifer type, contaminant sources, water quality, use, value,
GW/SW interaction, GW classification. The program generates
significant resource-related information. In addition, it obtains some
information from the states and USGS to the extent to which the
information is readily available.
* The program does not routinely compile accurate longitude/latitude on
contaminant sources and does not require state programs to collect and
use locational data. The program has financially supported some state
mapping efforts.
Criterion #3
The Program considers wellhead protection areas as high priority resources
in prevention and remediation efforts in Region and State programs.
* There are no current program activities which are focused on WHP
areas. Barriers to using WHP information include: lack of cross-
program education, limited accessibility and availability of WHP
delineation, inaccurate longitude/latitude on sites, no formal cross-
program (Superfund/GWMS) coordination mechanism.
Criterion #4
The program implements other aspects of Ground Water protection.
* Ground Water/Surface Water interaction is evaluated during the
Remedial Investigation in assessing the threat to surface water posed
-------
by contaminant plume migration.
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PROGRAM: SUPERFUND
STRATEGIC ACTIVITY 5 - INFORMATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Regional Program collects, coordinates and manages information to
assess priorities, measure progress and support CSGWPPs.
* Ground water monitoring data (hydrogeological and chemical) is
collected at every site.
* Site data is generally kept on hard copies in site files and is not
routinely converted to electronic storage and retrieval systems.
Ground water data is accessible to other programs, state agencies and
locals to the extent such programs/agencies are able to review site
files and extract relevant data.
* "Environmental Indicators" collected by the program could include
population within specified distance to the site (number of people
protected as a result of site removal/remedial activities).
Criterion #2
The Program uses and encourages states to use data from local, state and
other federal programs, to assess priorities, measure progress and support
CSGWPPs.
* Program obtains ground water-related information/data from USGS and
state waste programs.
* In order to perform resource-based priority setting, the program needs
accurate longitude/latitude information on ground water contaminant
sources (sites) and critical resources (Wellhead Protection Areas).
* The program does not direct state programs to collect, manage and/or
use ground water data and locational information. States manage their
sites (state sites), including data gathering, separate from the
federal Superfund program. The program has however encouraged this
and has financially supported some state efforts.
Criterion #3
The Program has a defined set of data elements and is providing data users
with comparable qualified data.
* The program has not identified a specified set of ground water related
elements that support ground water protection.
* In general, program and state programs are not aware of EPA's minimum
set of data elements.
* The program is not aware of the Agency's national locational data
policy and its requirements for implementation.
-------
Criterion
The Program collects and facilitates the use and sharing of accurate
locational data (lat./long.) among other Regional Programs, Locals and
the State's CSGWPPs.
* Locational data on sites are generally developed from topographical
maps, stored in paper format (reports), and therefore not useful in
strategic planning or other program activities. The exception is the
locational mapping of sites and resource characteristics which was
performed through a joint effort by EPA and the state of Connecticut.
* The program provided significant financial resources to support
efforts to locate public water supplies within the Region.
* Obtaining locational data for all pre-remedial, removal and NPL sites
would require significant investment of resources and effort, using
Connecticut as a model.
Criterion #4
The scope and design of regional ground water monitoring programs reflect
EPA and State priorities and goals.
* Superfund is the prime keeper and generator of ground water monitoring
data, as obtained through site assessment and remedial activities.
* The scope of ground water monitoring performed at sites adequately
reflects the goal of remedial investigations - to determine the nature
and extent of contamination.
* A universal data storage system does not exist in Superfund. This
limits the practical use of the data generated for strategic planning.
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PROGRAM: SUPERFUND
STRATEGIC ACTIVITY 6 - PUBLIC PARTICIPATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #\
The Program's goals, priorities and progress are addressed through a public
education/involvement process.
* As required by statute and guidance, the program has specific and
extensive public involvement requirements. Such education/outreach
efforts include: 1) community relations plans; 2) community Technical
Assistance Grants; 3) public hearings/meetings; 4) information
repositories; 5) public comment periods.
* Fact sheets on sites are periodically developed for state and local
distribution.
* State programs have not asked program for technical assistance.
* To improve outreach activities, state programs could articulate in
writing what they are doing now and what their future directions are.
Similarly, the Region needs to clearly articulate what we expect the
states to do across all media programs and what we and Headquarters
are doing to remove barriers, including statute changes where
necessary.
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PROGRAM RCRA C
STRATEGIC ACTIVITY 1 - GOALS
CRITERIA VS"! PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
Regional Programs are aware of and promote consistent
ground water protection strategy goals.
* Outside of the Ground Water Protection Strategy, the program was not
aware of a common or single GW protection goal.
* The Agency's Grant Guidance and Agency Operating Guidance for RCRA C
does include reference to supporting CSGWPP's and comprehensive ground
water protection approach.
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PROGRAM RCRA C
STRATEGIC ACTIVITY 2 - PRIORITIES
CRITERIAVS~.PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program has established approaches for its priority-setting process to
protect GW resources.
* Overall, there is minor, or no, prioritization (in program/state
program) in compliance, inspection/enforcement, that include GW
consideration (not resource-based). Priorities are set by contaminant
or industry-based initiatives.
* Currently, there is little need to prioritize permitting activities
(TSDs, closures). State programs have the lead, and these activities
are usually handled on a first come basis.
* Corrective Action (CA) is the only RCRA C program to formally
prioritize activities for site clean-ups. The name of CA priority
setting approach is the National Corrective Action Priority System
(NCAPS). It ranks sites through calculation of general risk-based
factors at each site, and minimally considers ground water. NCAPS is
Regionally supplemented by an informal forum of Section/Branch Chiefs
and is referred to as the Environmental Benefits Review. The review
is, for the most part, open to considering other issues
(institutional, environmental, site ownership, etc.) including ground
water ones which go beyond the couple of factors in NCAPS. In
practice, the Review has not resulted in resource-based priority
setting.
* Other Regional/state programs had limited input in priority setting
formulation and rationale.
* Program grant guidance to the states has not requested state
inspection and enforcement with a focus on resource-based priority
setting. CA program is EPA operated, so the states have no CA •
activities to prioritize.
* The program does not use, in any appreciable or routine way, GIS or
supporting files on contaminant sources, and water and ground water
resources, to assist in priority setting. Obtaining state information
and data is generally not routine for supporting priority setting.
Criterion #2
The program demonstrates consideration of varied GW characteristics in its
priority-setting process.
* Generally, GW characteristics are not factored significantly into
priority setting.
* See #1 above. GW resource considerations are not included in
inspection and enforcement priority setting in the program, or state's
program.
-------
Consideration of GW resources is limited in NCAPS prioritization.
NCAPS GW considerations include "current /future use" (i.e. drinking
. water), and distance to any type of well.
Environmental Benefits Review does not routinely involve consideration
of further GW factors beyond the NCAPS ranking.
Prioritization does not actively involve obtaining data or input from
other Regional or state programs. State programs are contacted
proforma about the ranking.
The program understood that other programs could benefit from an
effective prioritization process and listing from RCRA C.
RCRA C does not encourage state program to set resource-based
priorities. But, grants can be used to do that.
#2
jgional programs have contamination source information available to
lent if y potential threats to GW and to set priorities based on the
relative threats to ground water resources.
RCRA C upgrading database w/ RCRIS. Contaminant codes identified for
many handlers (TSDs, LQG, SQGs (inputted by the state)).
Region and state programs have not used the Region's or state's
contaminant source information to focus inspection and enforcement,
and corrective action in most threatened resource areas.
* Region and state contamination source data not consistently available
or conveniently accessible.
* Region and state resources data is not consistently available or
conveniently accessible
* Program has not sought or used existing Regional and state GW resource
information for identifying critical resources for prioritizing
inspections and enforcement, and permitting. NCAPS uses few resource
characteristics, thereby not requiring greater resource information
from Region and state data.
* Program was not familiar with State available data for NCAPS.
* Generally, program feels state resource data not consistently
available or accessible for determining resource use/value to set
corrective action priorities or clean-up levels.
* RCRA C does not seek local resource information, its "use" and
"value," or contaminant sources, in setting priorities.
Criterion #4
The Program has technical capabilities to support its GW protection
priorities and decisions.
* Program has limited technical staff to undertake complete resource and
contaminant source data gathering to improve priority setting.
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Criterion 15
The Program has included measurement objectives for GW protection priority-
setting and methods for assessing the Program's progress in the protection
of GW resources.
* Program does not use various standards (measures) in NCAPS Corrective
Action priority setting; nor in prioritizing inspections/enforcement.
Standards can be used in the Regional Environmental Benefits Review.
* Various standards and protection measures are considered in
establishing clean-up objectives in corrective action.
* Risk to public health is not directly considered in priority setting
for inspections and enforcement. For corrective action, there are two
factors in the NCAPS ranking calculation, including general toxicity
of the contaminants and public use or proximity.
* Assigning a toxicological "risk" to public health is considered in
establishing clean-up levels after priority sites have been selected
and site investigations conducted.
t
Criterion #6
The Program's activities give high priority to managing contamination
sources in wellhead protection areas and other public water supply source
areas.
* Regional and state inspection and enforcement and enforcement
activities do not consider wellhead protection areas (WHPAs) in
setting priorities.
* NCAPS considers distance from wells in calculating corrective action
priorities; it does not distinguish between public or private water
wells, nor consider WHPAs. Environmental Benefits Review can consider
this but has not to date.
Criterion #~l
The Program coordinates its GW priorities with other environmental
priorities.
* "Other environmental" priorities are not defined. But, the program is
involved in other Regional priorities such as Environmental Equity,
Pollution Prevention, Investment/Disinvestment, etc.
Criterion #8
The Program's priorities include on-going reviews and improvements of
Strategic Activities supporting the CSGWPPs.
* This criterion is too general in most ways. Whenever there is
opportunity to review the program to make improvements, the Branch
Chiefs meet weekly and can address issues and activities. Many of the
issues in the waste programs, however, are nationally oriented and can
only be resolved at that level.
This Regional Assessment will result in many issues for the program to
think about. Its recommendations will suggest improvements in our
-------
program that will have to be discussed; and, state submitted CSGWPPs
will identify areas that the program should think over.
-------
ROGRAM RCRA C
STRATEGIC ACTIVITY 3 - RESPONSIBILITIES
-•RITERIA VS~. PROGRAM INFORMATION FROM SURVEY RESPONSES
:riterion #1
The Regional Program has been identified as GW related and lead contact
named to support Regional GW & CSGWPP matters.
* Program recognizes it has a role in ground water protection, in the
•Region's comprehensive protection efforts and in support of CSGWPP
efforts with the states.
* RCRA C program does not specifically have a lead program contact; it
has a representative on Implementation Subcommittee, and is generally
represented by a Superfund branch chief who represents the Waste
Division on the GW Policy Committee. Waste Management Division
Director is also the Leadership Team advocate for comprehensive GW
efforts and co-chair of the GW Policy Committee.
* Currently there is no point-of-contact for RCRA C and the GW programs.
Criterion #2
The Program is involved with the Regional GW coordinating committee and
supports cross-program activities & GSGWPPs.
* RCRA C has a member on Implementation Subcommittee, but not the GW
Policy Committee. Waste Management Division is represented on the GW
Policy Committee by a Superfund Branch Chief, and the Waste Management
Division Director.
* RCRA C understands GW Management Section provides primary support for
the Implementation Subcommittee (ISC) and the GW Policy Committee and
has a pivotal role in communication.
* There are no assigned program contacts between RCRA C (or any of the
Waste Management Division programs) and the GW Management program.
* Program expects to benefit from comprehensive program coordination
among Regional programs by gaining greater knowledge of resource
values, classification and other GW related factors, and expects state
programs will receive the same benefit from their state ground water
program.
* Annual guidance/workplans for the last two years required state
programs to coordinate and participate in state CSGWPP activities and
the state's coordination mechanism.
* There is specific staff for conducting the NCAPS calculations and
addressing other issues for Environmental Benefits Review, for setting
priorities. Some other programs may become involved, but that hasn't
been the case to date. There could be better resource-based priority
setting if the GW Policy Committee understood the need for
ng GW reiated resource factors and information, and
-------
assessed the need for inter-program and state coordination.
Criterion #3
The Program has staff and resources allocated for GW protection concerns
and support of CSGWPPs.
* There are limited resources to provide "quality" service or technical
assistance to Region's programs, or to states and locals.
* No program and no state programs' efforts (in most states) are being
made to improve local capacity for managing hazardous waste, or for
obtaining feedback from local oversight. Locals could possibly assist
program with verification of RCRIS facility and generator locations.
* No program or state programs' efforts in public outreach and
education.
* Program has not developed a role for, nor involved, the GW Management
program as an additional resource for review of annual guidance,
workplans, or grant conditions; there have not been discussions of
critical GW resources, data needs, state issues, etc.
* Additional resources would be needed by the program and state program
to improve awareness and outreach to elevate local capacity for
managing local hazardous waste efforts; additional tools needed could
include inspector training, description of legal authorities, develop-
ment of model health ordinances or by-laws, providing demonstration
projects, distribution of literature and local data, etc.
Criterion #4
Relevant Federal Agencies are informed & consulted by the Program in
support of Regional GW protection efforts and state development of CSGWPPs.
* RCRA C has had little coordination or routine contact with Federal
resource agencies like USGS, SCS, Dept. of Agriculture, etc., or of
RCRA C issues at Federal facilities.
Criterion #5
The Program coordinates with the states to assess interstate matters, and
assists and encourages interstate cooperation.
* The program was not aware of any current significant inter-state
issues which need the program's intervention or resolution.
* One area for future concern may involve the transport of other states'
hazardous wastes over roads through critical resource areas; a second
issue concerns hazardous wastes brought in for treatment from another
state which has only limited capacity to handle waste generated in its
own state.
-------
Criterion #6
The Program considers local needs and encourages/requires States to closely
involve and assist locals.
* The program and state program have public notice and comment process
for all permitting functions in the program (for TSDs, closures, and
corrective action permits and orders).
* Generally, RCRA C and state programs do not include a local role in
priority setting, coordination, inspection and enforcement, strategic
planning, outreach, technical assistance, etc.
* Generally, RCRA C and state program have not traditionally considered
needs of local governments and communities for local prevention
efforts to control the threat of contamination from hazardous waste
generators and facilities. Building state and local capacity could
provide improved overview of potential threats.
* There is an opportunity for a productive local role. Program and
state programs' inspection results are not routinely presented to or
discussed with local governments who could provide another appropri?^-
level of interest and provide local follow-up.
* Program recognized that improved local efforts could directly benefit
the program and states' programs, with such efforts as:
• targetting inspections for Region/state inspections
• verifying locational information on contaminant source activities
• identifying critical ground water resources for priority setting
• identifying land uses and sensitive receptors
Local needs could include:
. technical assistance and "science"
local inspector training
development of quality outreach/educational materials
distribution of quality P2 information
developing local advocacy
developing model ordinances, or demonstration projects
providing useful resource information and contaminant source
inventories
Occasionally, press releases are issued on results of multi-media
inspection/enforcement action. Locals have input in the development
of emergency response plans and are notified of emergencies. Locals
are notified of corrective actions being undertaken.
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PROGRAM RCRA C
STRATEGIC ACTIVITY 4 - IMPLEMENTATION
CRITERIA VS~IPROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #\
The Program coordinates, integrates, and prioritizes resource-based
efforts, and evaluates them to improve the Region's and State's GW
protection efforts.
* Program is chiefly delegated to the states for issuing TSD permits,
receiving notifications for small and large quantity generators,
regulating very small quantity generators, administering manifest
system and regulating transporters; states regulate closures.
* State and Region cooperatively conduct inspections and enforcement.
* Only EPA administers Corrective Action program for past releases,
(similar to the Superfund clean-up activity)
* Inspections are often carried out in joint state-Region visits.
Setting priorities for conducting inspections/enforcement is not
resource-based. Often set by initiative, focusing on certain
contaminant use or industry.
* Generally, Region's corrective action program is only RCRA C program
setting priorities, and it is used for determining what sites will be
addressed first. NCAPS and Environment Benefits Review are the
priority setting mechanisms. NCAPS is minimumly resource-based taking
into account the distance to any type of well and GW's current/future
use; it is national and institutionally derived within the EPA.
Environmental Benefits Review is more flexible to address further
issues including other ground water and health based factors, but
generally this has not been the practice.
* Local and public comment in permitting process is principally the only
local involvement in program/state program. Locals are notified of
corrective action activities when such activity occurs, and in the
case of an emergency event.
* The program and states' programs do not support improving local
capacity to manage and control hazardous waste activities in the
community. The program has not encouraged the state program to assess
and conduct local outreach and support the development of "tools" to
improve local capacity. Occassional assistance is provided through
state ground water and wellhead protection programs.
* Some tools are provided in regulation and practice by the public water
supply and GW programs before issuing approvals for new GW sources of
drinking water which require wellhead protection efforts in the
community.
* Corrective action activities in developing clean-up levels, threat to
health and the environment consider federal and state surface and
ground water and drinking water standards/classification, health
advisories, etc.
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For establishing corrective action priorities, particularly in the
Environmental Benefits Review, and for establishing cleanup-up levels,
the program has great need for resourced-based information and
contaminant source inventories. There is also need for land-use
activities to distinguish between industrial and residential uses in
establishing clean-up and health risk levels. Determining the
resource "use" and "value" is significant here.
Corrective action program has not defined or judged how "time" may be
a management option, nor what may be a "reasonable" time frame in
which a clean-up action would have to be taken or completed (except in
a priority or emergency situation). Program might consider "time"
options if ground water use is low and clean-up costs are "very high."
Unlike, Superfund, the site owners are known and responsible.
Coordination is routine and adequate with Regional Counsel and the
Pollution Prevention program; and occasional, but needing improvement,
with the Water Supply program (particularly with respect to risk
assessment); generally adequate though occasional with most of the
Waste programs; and low to inadequate with most of the Water,
Infor/Data, and Pesticides programs.
The table below approximates the degree of interaction between the
progam and the other Regional programs.
PROGRAM
PESTICIDES
PWSS
UIC
STORMWATER
NPDES
•. '/WHP
BAYS /COASTAL
NONPOINT SRC
INFO /DATA
FED FACILITY
P2
ORC
SUPERFUND
UST
RCRA D
OPERATIONAL
*
*
*
*
*
*
*
LOW /
INADEQUATE
*
*
*
*
*
*
*
*
-------
* The program identified several other programs that would be especially
"useful" to seek coordination improvements, including:
• PWSS, GW/WHP, UIC, WATER QUALITY/ BAYS (TMDLS) , and INFO/DATA
These program could provide resource information, important to
inspections/compliance priority setting, and to corrective action
priority setting and clean-up level determinations.
* At the state level these connections are probably improved since many
considerations involving water resource information exchange is
necessary to the permitting process the states administers.
* Inspection/compliance at state level has not employed water resource
information to set resource-based priorities, but should be required
to do so under grant guidance and grant conditions.
* The program believes improved cross-program communication is needed,
and participation in cross-program state coordinators meetings and a
Regional newsletter would be useful ways of doing it.
* Grants timing is generally as follows:
National Guidance in April - May
Regional Guidance in May - June
Draft Grants in July
Final Grants in mid-August - Fall
* Waste program grants are not consolidated or uniformally distributed
and could serve as a barrier to any state wishing to improve and
establish cross-program coordination and annual objectives.
Criterion #2
The Program obtains and uses information to assess resource
vulnerability for remedial/prevention actions; and considers resource "use"
and "value" in remedial efforts and in prevention efforts where
appropriate.
* Overall, GW vulnerability is not factored into prioritizing
(inspection/enforcement, NCAPS - corrective action, permitting) but
could be included to some degree in review of permits (TSD, Corrective
Action, and closures) in Regional or state programs.
* "Use and value" are factors when considering,
• NCAPS ranking of corrective actions - only if GW is used as a
drinking water source
• determining corrective action clean-up levels
• land use - considering commercial vs. residential use
• determining "time" as a factor on how soon, if at all, a
corrective action will be taken
* Comprehensive resource-related information is used in corrective
action site reviews and decisions, and the state programs probably use
much of the same comprehensive data in considering permits for TSDs,
closures. Generally, much of the information is site specific, and
off-site to the degree contamination migrates.
* Generally, the RCRA C site managers is not aware of the EPA
"locational" policy for obtaining latitude/longitude. Essentially,
program managers and site managers have little direct use of latitude
and longitude in locating a site, or facitity features. However, the
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program recognized the substantial need for quality locational (and
CIS) information on GW resource conditions/quality, other
environmental attributes and its use, and for assessing human use and
the risks associated with it.
*• Quality latitude and longitude for facilities and resources (TSDs,
LQG, SQG, conditionally exempt SQGs, corrective action) is needed for
prioritizing inspection / enforcement, ranking and decisions on
corrective actions based on the use and quality of the resource and on
land and human use, etc.
*• Because much of RCRA C is delegated (permitting, closures, LQG, SQG
notification, inspection, etc.), states have substantial need for
quality latitude and longitude for ranking, identifying resources and
human use, strategic planning, etc.
*• RCRA C is not moving forward with specific activity or policy in
obtaining quality latitude and longitude, nor encouraging and
requiring state programs to obtaining quality latitude and longitude.
For the Region/state programs, barriers appear to be low "awareness"
and "staff and program resources."
Criterion #3
The Program considers wellhead protection areas as high priority resources
in prevention and remediation efforts in Region and State programs.
*• RCRA C does not specifically address or focus any part of the program
on protecting wellhead protection areas (WHPAs). Regional NCAPS
ranking for corrective action does not consider WHPAs (relative NCAPS
factors include: distance to any well, and GW use for drinking water),
though the Environmental Benefits Review may consider WHPA protection,
but, has not been the practice or awareness to do so.
*• For the most part, priority setting for Regional and state
inspections/enforcement does not consider WHPAs. Future permitting
and closures ranking will likely use NCAPS as a priority setting
mechanism, which does not include WHPA factors.
*• The program does not encourage or require state programs to address or
focus activities in WHPAs, though many state environmental/hazardous
waste regulations require attention to WHPAs. Such as, new public
water supply wells will not be approved if a TSD facility is in a
WHPA. New permits for TSD will not be approved if in a WHPA.
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PROGRAM RCRA C
STRATEGIC ACTIVITY 5 - INFORMATION
CRITERIAVlTPROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Regional Program collects, coordinates and manages information to
assess priorities, measure progress and support CSGWPPs.
* The primary RCRA C data base is Resource Conservation Recovery
Information System (RCRIS). It contains information from RCRA C
Notification forms from all handlers and Permit Application.
Notification submittal includes common address and contact
information, ownership, and description of wastes; an EPA facility ID
number is assigned, but latitude and longitude is not required.
The Hazardous Waste Permit Application Parts A and B requesting a TSD
permit, requests more detailed information and the facilitiy location
in latitude and longitude among other facility and waste information.
* RCRIS contains activity type (LQG, SQG, TSD, etc); location
addressing, mailing address, contacts and owners, past and present
operators, accessibility - bankruptcy (current status or filing for),
litigation status, owner/operator access/left country/or under
prosecution, off-site waste receipt, violations and inspection report
findings, river basin (not required), etc.
Latitude and longitude is also indicated for TSDs and LQGs, but is
applicant provided and its quality is uncertain, and for most purposes
unreliable.
* Multiple data bases exist with the states, since most states also have
further hazardous waste program information, particularly for the
conditionally exempt facilities small quantity generators (= VSQGs).
*• The principle data base problem is the random and low quality of the
latitude and longitude information, since it is obtained from
applicants without requirements for accuracy.
*• Information from RCRIS is accessible to other programs, state programs
and other entities and the public, upon request. It is not user
friendly and requires querying the right information.
Criterion #2
The Program uses and encourages states to use data from local, state and
other federal programs, to assess priorities, measure progress and support
CSGWPPs.
* Available ground water related data from various sources (state,
local, etc.) are not used by the program and state program for
prioritizing inspections and enforcement activities. Ground water
resource information would be most useful if obtained.
* Available ground water related data from various sources (state,
local, etc.) are not used by the program to prioritize corrective
-------
actions. Priority setting for corrective action utilizes limited GW
related information.
* Broardly available information from state and other sources is
obtained and used during corrective action investigation and remedial
planning.
Criterion #3
The Program has a defined set of data elements and is providing data users
with comparable qualified data.
* The program has not identified a minimum set of data elements, but is
willing to participate in discussions regarding them for the RCRA C
program. Currently, the only elements included in their data
collection is the latitude and longitude, as it is obtained from the
applicant.
Criterion #3A
The Program collects and facilitates the use and sharing of accurate
locational data (latitude and longitude) among other Regional Programs,
Locals and the State's CSGWPPs.
* Accurate locational data, according to EPA's one second (1")
locational data policy, is not collected. Latitude and longitude is
is submitted by the applicant without quality control or
certification.
Criterion #4
(Responses: a-c)
The scope and design of regional ground water monitoring programs reflect
EPA and State priorities and goals.
* Currently, there are no regional ground water monitoring programs in
which RCRA C program participates. When state and EPA data management
systems can handle large volumes of on-site monitoring results, the
information could help characterize ground water on a regional basis.
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PROGRAM RCRA C
STRATEGIC ACTIVITY 6 - PUBLIC PARTICIPATION
CRITERIAVJTPROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program's' goals, priorities and progress are addressed through a public
education/involvement process.
* Generally, the program does not have a public education and
involvement component. Public comments are sought during the
administrative processes of permitting for TSDs, and closure and
Corrective Action activities.
* Also, see the above section on Strategic Activity 4 - "Implementation"
under Criterion #1
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PROGRAM RCRA 0
STRATEGIC ACTIVITY 1 - GW PROTECTION GOAL
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
Regional Programs are aware of and promote consistent
ground water protection strategy goals.
* The goal of the national RCRA D Program for improving the safety of
solid waste management facilities is to protect ground water and
prevent pollution from poorly designed and operated landfills. EPA
intends to achieve this goal via recently promulgated Municipal Solid
Waste Landfill (MSWLF) regulations.
* Region I RCRA D staff are aware of the Agency's ground water
protection strategy via: final CSGWPP guidance, Municipal Solid Waste
Landfill Regulations (MSWLF), Implementation Subcommittee (ISC)
meetings.
* The Program has not discussed CSGWPPs with the Region I States because
the RCRA D Program: 1) does not provide continuing program grants
with annual guidance to States and 2) is currently taxing States to
submit Solid Waste Permitting Program (SWPP) applications without
providing any funds. It is difficult to ask the States to do more at
this present time.
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PROGRAM RCRA D
STRATEGIC ACTIVITY 2 - PRIORITIES
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program has established approaches for its priority-setting process to
protect GW resources.
* The MSWLF regulations establish minimum criteria for ground water
monitoring, landfill siting, design, and operation, and corrective
action to ensure protection of ground water resources.
* The States, rather than the Region, establish priority-setting
processes pertaining to MSWLFs as part of the State Solid Waste
Permitting Program (SWPP) applications. States are encouraged to use
state ground water classification systems, State Wellhead Protection
Programs (WHPPs) , and other differential protection mechanisms to
prioritize activities (siting, closure, corrective action) for MSWLFs.
* The Program's current priorities are driven by the effective date of
the MSWLF regulations. The Program's highest priority is to assist
the New England State with developing SWPPs for Region I's review and
approval. However, the Program has no enforcement mechanism to
require the States to submit SWPP applications.
Criterion #2
The Program demonstrates consideration of varied GW characteristics in its
priority-setting process.
* Although the Program does not have a resource-based priority-setting
process, Program staff have expertise with DRASTIC, NCAPS, and a
Region I DRASTIC version to assist States with setting priorities
based on ground water characteristics.
• ^ *m ^ ^ ^ ^^ ^ ^ ^^ ^ ^ ^^ ^ ^ ^ ^ ^ ^^ ^ ^^ • ^^m^ ^^ ^ ^m ^ ^m^ ^^^^^ ^ ^ ^ ^ ^ •» ^ ^ ^ ^^^ ^ ^ ^^ ^ ^ ^ ^ ^ •• ^ ^ ^ ^ ^ ^^ ^ ^ ^ •
criterion /3
Regional Programs have contamination source . information available to
identify potential threats to GW and to set priorities base on the relative
threats to ground water resources.
* Contaminant source information is not needed by the Program for SWPP
reviews.
* State Solid Waste Program have varying amounts and types of data on
existing landfills. The RCRA D Program has no oversight role and does
not collect landfill data from the States.
Criterion #4
The Program has technical capabilities to support its GW protection
priorities and decisions.
-------
The States currently make the decisions for MSWLFs. It is anticipated
States will continue to do so with approved SWPPs.
The RCRA D Program does not presently need technical capabilities for
making decisions on MSWLFs, as MSWLFs are covered by State Solid Waste
Programs. Should a State decide not to submit a SWPP or does not
receive approval, the Program will need to consider data collection
and information management.
Criterion #5
The Program has included measurement objectives for GW protection priority-
setting and methods for assessing the Program's progress in the protection
of GW resources.
* The MSWLF regulations require the use of reference points such as
Maximum Contaminant Levels (MCLs) and, when MCLs are not available,
other health-based standards established by the State.
* The MSWLF regulations encourage consideration and use of
classification standards for ground water and water quality.
Criterion #6
The Program's activities give high priority to managing contamination
sources in wellhead protection areas and other public water supply source
areas.
* The Program does not encourage States to use State WHPPs as management
tools for landfills; rather, States propose in SWPP applications an
integrated application of their ground water programs to set
priorities.
* The MSWLF regulations reference local WHPPs for MSWLF owners/operators
as additional requirements they should be in compliance with.
Criterion £7
The Program coordinates its GW priorities with other environmental
priorities.
* Five main areas of the MSWLF regulations (location, operation, design,
ground water monitoring & corrective action, closure and post-closure
care) consider ground water impacts in concert with other applicable
concerns.
* The Program considers impacts to other natural resources such as
wetlands and floodplains when evaluating State SWPP siting criteria as
established by the MSWLF regulations.
* The Program considers impacts to surface waters and air when
evaluating state SWPP landfill operating criteria as established by
the MSWLF regulations.
-------
Criterion
The Program's priorities include on-going reviews and improvements of
Strategic Activities supporting the CSGWPPs.
* The Program has no oversight responsibilities for Region I -approved
SWPPs. States must notify EPA only when changes to the SWPP are made
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PROGRAM RCRA 3
STRATEGIC ACTIVITY 3 - RESPONSIBILITIES
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion 11
The Regional Program has been identified as GW related and lead contact
named to support Regional GW & CSGWPP matters.
* A lead contact is identified for the Implementation Subcommittee.
There is a lead person for ground water issues related to RCRA D SWPP
reviews .
* RCRA D's ground water protection role is to ensure safe design and
operation of MSWLFs to prevent ground water contamination.
* The national RCRA D guidance for use by Regions to review SWPP
applications does not reference CSGWPP commitments; however, the MSWLF
regulations do describe EPA's new ground water policy.
Criterion #2
The Program is involved with the Regional GW coordinating committee and
supports cross-program activities & CSGWPPs.
* Support to the GWPC is represented by Advocate from Waste Division.
* RCRA D staff participate in the Merrimack River Initiative,
Chesprocott Initiative, P2 KPA, P2TF, and Locational Policy
development for Region I.
* Barriers to the Program's participation with CSGWPPS: l) Limited
Regional staff with large workloads; 2) Not politically feasible to
ask 'States to support CSGWPPs because RCRA D is not providing any
funds to develop SWPPs.
Criterion #3
The Program has staff and resources allocated for GW protection concerns
and support of CSGWPPs.
* Staff review SWPP applications which ensure protection of ground and
surface waters. Staff are also dedicated to pollution prevention
issues.
Criterion #4
Relevant Federal Agencies are informed & consulted by the Program in
support of Regional GW protection efforts and state development of CSGWPPs.
* No Federal Agencies are involved with the RCRA D Program.
-------
The Program coordinates with the states to assess interstate matters, and
assists and encourages interstate cooperation.
* The Program coordinates with the States via the interstate
organization, NEWMOA, where the Region funds a Solid Waste Manager.
Region I/II Solid Waste Workgroup also collaborates monthly via
conference calls.
* Ground water issues have not been raised in an interstate forum yet.
Criterion #6
The Program considers local needs and encourages/requires States to closely
involve and assist locals.
* The Program funds pilot projects to assist communities with solid
waste management planning.
* The Region I Solid Waste Library is dedicated to responding to public
inquiries.
* SWPPS are reviewed by the public and hearings are held before SWPPs
are finally approved by EPA.
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PROGRAM RCRA 3
STRATEGIC ACTIVITY 4 - IMPLEMENTATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program coordinates, integrates, and prioritizes
resource-based efforts, and evaluates them to improve
the Region's and State's GW protection efforts.
* The MSWLF regulations encourage States to use differential protection
mechanisms. The Program empowers States to prioritize MSWLF
activities using a resource-based approach, encouraging use of state
ground water classification schemes for landfill siting, design,
ground water monitoring, and corrective action.
* Corrective action criteria in the MSWLF regulations consider current
and future uses of ground water (USE) and ground water quality and
quantity (VALUE).
* Time until "full protection is achieved" is one of five evaluation
factors owners/operators must consider in selection of a remedy.
Other factors include the technical and economic capability of the
owner/operator and potential risk reduction.
* Contamination from certain constituents does not require remediation
as decided by the State director of an approved SWPP. The
owner/operator must demonstrate to the State the following:
1) the ground water is contaminated by other substances from non-
MSWLFs and remediation of those substances would not signficantly
reduce risk to actual or potential receptors or;
2) the ground wter is not currently or reasonably expected to be a
source of drinking water and is not hydraulically connected to
waters to which the constituents are or could migrate to at
levels which exceed established ground water protection standards
or;
3) remediation of the release is technically impracticable; or
4) remediation results in unacceptable cross-media impacts.
* The Program coordinates primarily with the Information Management
Program for special projects which might locate landfills.
Criterion #2
The Program obtains/uses information to assess resource
vulnerability for remedial/prevention actions; and
considers resource use and value in remedial efforts and
in prevention efforts where appropriate.
* The Program does not make decisions on resource vulnerability; rather,
the States do once the Program approves of the States' processes for
doing so.
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Cri'erior. »3
The Program considers wellhead protection areas as high
priority resources in prevention and remediation
efforts in Region and State programs.
* The Program emphasizes differential protection, focusing on ground
water classification. States identify in their SWPP applications how
WHPAs will be used to prioritize actions.
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PROGRAM RCRA D
STRATEGIC ACTIVITY 5 - INFORMATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Regional Program collects, coordinates and manages information to
assess priorities, measure progress and support CSGWPPs.
* The Program does not collect information on MSWLFs. There are no
reporting requirements exist for EPA-approved State SWPPs.
* The Program's Information Management liaison participates in Regional
data management issues and conducts studies to promote integrated
environmental management, utilizing locations of RCRA C and D
facilities and Superfund sites.
Criterion #2
The Program uses and encourages states to use data from local, state and
other federal programs, to 'assess priorities, measure progress and support
CSGWPPs .
* No, the Program does not use other data to set priorities. States use
data as deemed necessary to run their particular programs.
Criterion #3
*
The Program has a defined set of data elements and is providing data users
with comparable qualified data.
* The Program does not collects data and therefore provides none.
Criterion
The Program collects and facilitates the use and sharing of accurate
locational data (lat./long.) among other Regional Programs, Locals and
the State's CSGWPPs.
* The Program does not require States to collect locational data of a
specific format.
Criterion #4
The scope and design of regional ground water monitoring programs reflect
EPA and State priorities and goals.
* The MSWLF regulations set forth comprehensive ground water monitoring
program requirements which closely parallel RCRA C ground water
monitoring systems for hazardous waste disposal facilities. The
purpose is to ensure consistent, reliable ground water monitoring data
are collected.
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Monitoring design is flexible, recognizing the hydrogeologic
variability from site to site. The number, location, and depth of
monitoring wells is, thus, not specified.
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PROGRAM RC3A D
STRATEGIC ACTIVITY 6 - PUBLIC PARTICIPATION
CRITERIA US'. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion t1
The Program's goals, priorities and progress are addressed through a public
education/involvement process.
* The public has influenced the catupult of solid waste management
issues into the limelight, moving EPA to develop "The Solid Waste
Dilemma: An Agenda for Action", February 1989.
* The public is given an opportunity to comment upon State SWPP
approvals before finalization.
* The Program maintains a library of information to respond to
information requests by the public.
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PROGRAM: UNDERGROUND STORAGE TANK
STRATEGIC ACTIVITY 1 - GW PROTECTION GOAL
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
Regional Programs are aware of and promote consistent
ground water protection strategy goals.
* The UST program includes reference to the CSGWPP process and ground
water strategy in their guidance and grant activities to the states.
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PROGRAM: UNDERGROUND STORAGE TANK
STRATEGIC ACTIVITY 2 - PRIORITIES
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program has established approaches for its priority-setting process to
protect GW resources.
* Under the UST program, EPA asks the state to develop a prioritization
scheme for cleanup activities, but defers to the state when
establishing definitions and approaches.
* The UST program is a regulatory prevention program that allows states
to identify the location and age of tanks, develop a data base for
inventorying, and encourages the development of regulations. It is
not really a resource-based program; it is more a technically driven
program that focuses on testing for leaks and replacement of
substandard systems.
* The LUST program manages cleanup/remediation of leaking underground
storage tanks. States have their own resource protection based
priority schemes with public and private well supplies considered a
very high priority.
* The UST program is first and foresmost a state program - EPA only
helps run it by providing financial assistance. We provide technical
assistance and grants to the states. UST regulations are
procedurally-based, and defer to state governments.
* The cornerstone coordination mechanism for the UST program is the 1987
requirement for states to produce a Workplan Output for LUST
Cooperative Agreements. This agreement showed that the states had the
ability to manage, adminster, and enforce their own programs.
* Barriers identified include lack of money and staff, too many sites,
GPS data available but not accessible, and legislative pressure to not
"back off" on sites that the state may have prioritized according to
their own needs. Massachusetts was named as a particularly
challenging state: institutional barriers, such as the fact that two
seperate agencies (DEP, Dept. of Public Safety) have overlapping
jurisdiction and responsibilities, make it difficult to prioritize
program activities.
Criterion #2
The Program demonstrates consideration of varied GW characteristics in its
priority-setting process.
* Wellhead protection areas are considered by all six states when doing
remediation work. On the prevention side, Maine considers gw resource
characteristics in their regulations, and Rhode island in their
enforcement policies.
Criterion #3
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Regional Programs have contamination source information available to
identify potential threats to GW and to set priorities base on the relative
threats to ground water resources.
* The states have this information; it is not routinely collected or
used at the Regional level.
Criterion #4
The Program has technical capabilities to support its GW protection
priorities and decisions.
* EPA has the technical capability to support the states in these areas,
but we don't do priority setting, thus, this criteria doesn't really
apply.
Criterion #5
The Program has included measurement objectives for GW protection priority-
setting and methods for assessing the Program's progress in the protection
of GW resources.
* The UST program defers to state standards (performance standards,
quality standards, etc.).
Criterion #6
The Program's activities give high priority to managing contamination
sources in wellhead protection areas and other public water supply source
areas .
N/A
Criterion #7
The Program coordinates its GW priorities with other environmental
priorities.
* There is little or no coordination- with surface water programs (LUST'S
don't usually leak directly into a waterbody) ; only ground water
coordination currently exists.
Criterion #8
The Program's priorities include on-going reviews and improvements of
Strategic Activities supporting the CSGWPPs.
* The UST program is already conferring maximum flexibility upon the
states; as a result, we have no regulatory "club" to hit them with.
* More staff and program dollars to the states and EPA would be welcome.
Also, increased emphasis and dollars for obtaining GPS locational
data. This would greatly assist the states in tracking and
monitoring. Regulatory and targeting activities would also be vastly
improved with better GPS locational data.
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PROGRAM: UNDERGROUND STORAGE TANK
STRATEGIC ACTIVITY 3 - RESPONSIBILITIES
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Regional Program has been identified as GW related and lead contact
named to support Regional GW & CSGWPP matters.
* Proper siting and land use controls for UST's could be a tremendous
benefit to ground water. Pollution prevention is the most cost
efficient method; siting and land use regs could provide more
consistent, focused ground water protection, faciltate enforcement
efforts, etc.
Criterion #2
The Program is involved with the Regional GW coordinating committee and
supports cross-program activities & CSGWPPs.
* One issue that should be addressed is heating oil tanks; UST currently
defers to state-set MCL's for petroleum clean ups. Some states (New
Jersey) have raised MCL's for heating oil spills from 100 to 10,000.
using the argument that the lower MCL level is not commensurate with
the actual human health risk. EPA has never attempted to set cleanup
standards for petroleum - we let states set their own standards.
Perhaps the GWPC might want to look into the question of whether we
want to continue to let states set their own MCLs for petroleum, or
whether it is desirable for EPA to do more facilitating/coordinating
among states for evaluating uniform standards for states (this
question requires state feedback).
Criterion #3
The Program has staff and resources allocated for GW protection concerns
and support of CSGWPPs.
N/A
Criterion #4
Relevant Federal Agencies are informed & consulted by the Program in
support of Regional GW protection efforts and state development of CSGWPPs.
N/A
Criterion #5
The Program coordinates with the states to assess interstate matters, and
assists and encourages interstate cooperation.
* A gasoline station contamination incident on the Rhode
Island/Connecticut border several years ago highlighted good
interstate cooperation between state environmental programs.
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* NEIWPCC meets with the UST program quarterly, and regularly updates
interstate issues with them.
Criterion #6
The Program considers local needs and encourages/requires States to closely
involve and assist locals.
* The UST program only allocates $162,000 per state, which essentially
funds three FTEs; there are not adequate resources at the present time
to do outreach activities.
* Being a federally-funded state-run program, EPAs UST program feels
that EPA is already administering maximum flexibility.
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PROGRAM: UNDERGROUND STORAGE TANK
STRATEGIC ACTIVITY 4 - IMPLEMENTATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program coordinates, integrates, and prioritizes resource-based
efforts, and evaluates them to improve the Region's and State's GW
protection efforts.
* UST is a federally-financed, state run program. There is a formal
delegation authority presently with NH, VT, ME and RI; MA and CT
should be decided in FY'94.
* The UST program primarily relies upon new UST tank standards and leak
detection requirements, while states usually determine remedial action
levels.
* The ground water classification issue is a state issue only; no EPA
ground water classification standards were in place in 1988 when the
UST program was created. The New England states, which differ widely
in their classification on the use and value of ground water, apply
their own classification systems to remediation standards for UST
cleanups.
* New Hampshire is currently exploring the use of time as a management
option for remedial cleanup actions, specifically the areas of natural
biodegradation, attenuation zones, & when to justify no action levels.
* .UST program feels that the ground water section is doing an excellent
job coordinating and communicating on the CSGWPP process.
* The UST program strongly encourages contact and coordination through
their grant guidance and activities.
* A QAT team was formed to look at coordinated grar; issuance. The
National/Regional guidance goes to states by April 1, draft workplans
area due back by June 14, final workplans by August 2. Theoretically,
completed, approvable workplans are ready by Oct. 1, followed by
release of grant monies.
Criterion #2
The Program obtains/uses information to assess resource
vulnerability for remedial/prevention actions; and
considers resource use and value in remedial efforts and
in prevention efforts where appropriate.
* EPA's UST program is requesting GIS data delivery from states this
year, to support environmental equity and other targeting
considerations. Grant conditions are the mechanism for achieving
this.
* Priority setting, inspections, and environmental equity are the
program benefits which could be realized from the use of lat/long
standards.
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* The UST program is currently using a consultant to assist in GPS data
gathering, address matching, etc. The program is not making lat/long
use a grant condition.
* All states, except MA and ME, have used lat/long to do locational
data, such as tying in facility data base with # of tanks, type of
fuel stored, etc.
* States don't want owners/operators to provide locational data - they
prefer to do it themselves. Issue of quality control.
* The states generally see value in the use of lat/long. UST program
estimates that it will take two years to complete site locations and
tie in to facility data base.
Criterion #3
The Program considers wellhead protection areas as high
priority resources in prevention and remediation efforts in Region and
State programs.
* EPA UST program does not routinely consider WHP areas in its
activities and decision making; states do. National program did not
have the data when UST program was formed in 1988; WHP guidance was in
effect at the time, with no formalized gw classification standards.
Because of this, EPA cannot require that WHP areas be incorporated
into state decision making, only assure that minimum federal standards
will be met.
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PROGRAM: UNDERGROUND STORAGE TANK
STRATEGIC ACTIVITY 5 - INFORMATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Regional Program collects, coordinates and manages information to
assess priorities, measure progress and support CSGWPPs.
* Information is typically gathered and maintained by the state.
Although there is officially a federal notification requirement,
states are the ones who reply to FOIA's, etc. Types of information
the EPA UST program routinely collects are state quarterly reports,
and inspection and compliance info, which resides on LOTUS.
* Generally, the UST program doesn't feel the need to create more work
than necessary. For instance, a 2 IE request that comes to EPA would
be passed on to MA DEP, who would have the specific data needed on
tank locations, etc.
* When the UST program first tried to perform priority setting for doing
UST inspections on PWS wells, they could not get any information on
WHPA's. They wanted to target a ground water-dependent town, but
could not get the info they needed to make the correct decision (this
was in the pre-GPS era) . Generally, the data varies wildly from town
to town. Thirty towns to date have been analyzed for compliance, of
which 50-90% have achieved.
* Lack of ability to target towns based upon vulnerability is a
constraining factor for most state UST/LUST programs in Region I.
* Well data and town water distribution systems would be useful data to
have for the EPA UST/LUST program.
* LUST program uses total number of releases as an environmental
indicator, although it does not distinguish between major and minor
spills.
* In the future, the UST program would like to track tank replacements
as a measure of progress.
Criterion #2
The Program uses and encourages states to use data from local, state and
other federal programs, to assess priorities, measure progress and support
CSGWPPs.
* EPAs UST program is asking states to provide tank data for all six
states at once, so that they can input onto GIS. Tank-specific
attributes will be used with state programs as a targeting tool. The
information is being requested ASCII format.
* Grant guidance is used to improve data collection. Generally, the UST
program at EPA does not dictate data needs, but rather responds to
state-identified needs and gaps. Also, the UST program is providing
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assistance to MA to improve their CIS capability this year.
Criterion #3
The Program has a defined set of data elements and is providing data users
with comparable qualified data.
* Tank locations, attributes, wellhead locations, aquifers, etc. are
specific data elements that are important to the program.
Criterion #3A
The Program collects and facilitates the use and sharing of accurate
locational data (lat./long.) among other Regional Programs, Locals and
the State's CSGWPPs.
N/A
Criterion #4
The scope and design of regional ground water monitoring programs reflect
EPA and State priorities and goals.
* The role of CIS needs to be better defined. The UST program feels
that it should be raised to the level of the Ground Water Policy
Committee and Data Management Subcommittee.
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PROGRAM: UNDERGROUND STORAGE TANK
STRATEGIC ACTIVITY 6 - PUBLIC PARTICIPATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program's goals, priorities and progress are addressed through a public
education/involvement process.
N/A
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WATER
MANAGEMENT
DIVISION
4
Ul
C5
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PROGRAM: Underground Injection Control
STRATEGIC ACTIVITY 1 - GW PROTECTION GOAL
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
Regional Programs are aware of and promote consistent
ground water protection strategy goals.
* Program has received encouragement from EPA HQ to Consider
comprehensive resource protection in programs internal activities and
during their interaction with states.
* The program has communicated with state UIC programs the importance of
CSGWPP.
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PROGRAM: Underground Injection Control
STRATEGIC ACTIVITY 2 - PRIORITIES
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program has established approaches for its priority-setting process to
protect GW resources.
* Program encourages state prioritization of state activity to protect
ground water resources.
* Prioritization can focus state program activity and result in greater
protection of ground water resources.
* EPA UIC program does no prioritization. Program has a major
responsibility to encourage state prioritization of UIC activity to
support state and local resource protection.
* States are encouraged to prioritize outreach education, technical
assistance, inspections, and enforcement to assume more comprehensive
resource protection.
* Successful prioritization of state UIC activities would benefit water
supply, nonpoint source, storm water, and wellhead protection
programs.
* State prioritization of UIC activity would be more possible if
information describing resources was more accessible for program
decisions.
Criterion #2
The Program demonstrates consideration of varied GW characteristics in its
priority-setting process.
* Program encourages state consideration of ground water characteristics
such as groundwater availability, wellhead protection, groundwater
classification, local aquifer protection, watershed protection, sole
source aquifers to support prioritization of program activity.
* The availability and accessibility of information describing
groundwater characteristics is poor and NOT convenient to consider.
CRITERION #3
Regional Programs have contamination source information available to
identify potential threats to GW and to set priorities base on the relative
threats to ground water resources.
* The program does not inventory contaminant sources; however, the
program encourages the states and EPA programs to consider making
contaminant source information more useful to a broad spectrum of
programs that could use this type of information to prioritize program
activity and consequently protect resources.
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* The program encourages state UIC programs to UIC activity of
facilities they are able to prioritize.
* State programs are encouraged to set their priorities and their
program activity based on the relative threat of a facility activity
to water resources.
* State programs could use contaminant source information from EPA
programs, state programs and local resources.
* Contaminant source information is not conveniently available to state
programs.
Criterion #4
The Program has technical capabilities to support its GW protection
priorities and decisions.
* The EPA is not able to support state prioritization of its UIC program
activity because EPA information that the state program would use is
not conveniently accessible to state programs.
* EPA Poor Regional data quality information availability information
accessibility preclude use of EPA information to support state program
priority settings.
* The EPA UIC program encourages state use of facility and resource
information to prioritize their program decisions to protect ground
water.
Criterion #5
The Program has included measurement objectives for GW protection priority-
setting and methods for assessing the Program's progress in the protection
of GW resources.
* The UIC program is aware of many formally adopted state measures to
protect ground water.
* State UIC programs are encouraged to use all applicable state and
federal ground water protection measures to support prioritization of
program activity.
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Criterion #6
The Program's activities give high priority to managing contamination
sources in wellhead protection areas and other public water supply source
areas.
* The program routinely and strongly encourages state UIC programs to
consider wellhead protection, sole source aquifers, public water
supply sources, groundwater availability and local resource protection
when prioritizing program activity.
* The program strongly encourages EPA and states to continue to compile
information identifying and describing resources of critical
environmental concern and to enhance information management system and
Geographic Information System (GIS) tools so that EPA and state
programs can better prioritize program activity to protect resources.
Criterion #7
The Program coordinates its GW priorities with other environmental
priorities.
* Program consistently encourages state and EPA programs to consider a
broad spectrum of resources when considering prioritization of program
activity.
Criterion #8
The Program's priorities include on-going reviews and improvements of
Strategic Activities supporting the CSGWPPs.
* Program continues to encourage EPA and states to make significant
improvement to environmental and facility information management
systems and to encourage enhancement of GIS tools in ways that will
allow consideration of information needed to prioritize program
activity convenient, easy, fast, more automated, more cross program
useful.
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PROGRAM: Underground Injection Control
STRATEGIC ACTIVITY 3 - RESPONSIBILITIES
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Regional Program has been identified as GW related and lead contact
named to support Regional GW & CSGWPP matters.
* Program activity has a direct impact on groundwater resources. The
program oversees state UIC programs that regulate discharge of wastes
into the ground through wells.
* The Program is an active member of the Groundwater Policy Committee
and participates on the Policy Committee implementation and data
management subcommittees.
* Currently Agency, grant, regional guidances and the Regional Strategic
plan does not consider CSGWPP.'
Criterion #2
The Program is involved with the Regional GW coordinating committee and
supports cross-program activities & CSGWPPs.
* The program is represented on the Groundwater Policy Committee.
* The program actively coordinates activity with the groundwater
management program. The groundwater program actively reviews program
guidance, state work plans, participates in discussions about priority
setting and provides liaison with state groundwater programs.
* The program has participated in pollution prevention initiatives, dry
cleaning, industry pollution prevention activities, geographic
initiatives in the Merrimack, Blackstone and Nashua River Basin areas.
* CSGWPP participation has been a major program activity.
* EPA/ state information management needs to support resource protection
is a significant issue that should be addressed by the Groundwater
Policy Committee.
* The following cross program issues have been identified as important
by the New England States:
Criterion
The Program has staff and resources allocated for GW protection concerns
and support of CSGWPPs.
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Program participates in all discussions about groundwater resource
protection within EPA and with states.
Program actively encourages and supports state CSGWPP efforts.
EPA regional support and resources directed at the following world
increase effectiveness of Region State and local resource protection.
Resource assessment
Prioritizing resource areas for program attention
Contaminant source locations
Conduct public education and outreach
Conducting inspections in critical ground water resource areas
Taking compliance and enforcement actions in critical resource
areas, as well as by referrals and special initiatives
Determining use, value and vulnerability of ground water
resources
Criterion #4
Relevant Federal Agencies are informed & consulted by the Program in
support of Regional GW protection efforts and state development of CSGWPPs.
* The program interacts with USGS and other federal agencies conducting
program work associated with National Water Quality Assessments.
* The UIC program coordinated with EPA's federal facilities program and
participates on federal facility multimedia inspections.
Criterion #5
The Program coordinates with the states to assess interstate matters, and
assists and encourages interstate cooperation.
* Ground water protection and well head protection often involve
interstate consideration of resource protection. .
* The program is occasionally involved in discussions about interstate
ground water protection issues with state UIC and ground water
programs.
* Interstate ground water protection issues are discussed with federal
agencies associated with National Water Quality Assessment in the
region.
* Interstate coordination of ground water protection and management
issues is supported by the NEIWPCC, NEWMOA, and the New England Water
Works Association,
Criterion #6
The Program considers local needs and encourages/requires States to closely
involve and assist locals.
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Public education and outreach are an important part of EPA and state
program work.
The states are primarily responsible for coordinating and conducting
education and outreach to the public, local governments and regulated
facilities.
The program encourages through discussion, guidance documents and
state outreach activities in the following areas:
where program conducts inspections
where program takes enforcement actions
technical assistance for 'science7 and facilitation
technical assistance to train local inspectors
development of quality educational materials for public outreach
and curriculum
management options necessary for preventing and controlling
contamination sources
Resources to increase state UIC implementation are the greatest
barriers to increasing program effectiveness to protect groundwater
resources.
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PROGRAM: Underground Injection Control
STRATEGIC ACTIVITY 4 - IMPLEMENTATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program coordinates, integrates, and prioritizes
resource-based efforts, and evaluates them to improve
the Region's and State's GW protection efforts.
* The UIC program is delegated to each of the New England states.
* State UIC programs use permitting, enforcement, management plans, best
management practices, groundvater classification, wellhead protection,
and drinking water standards to reduce or limit waste discharges to
ground water resources.
* The UIC program occasionally coordinates program activities with
Pollution Prevention, nonpoint sources, information management,
stormwater, federal facilities and groundwater protection.
* The program actively and routinely coordinates program activity wit
state and EPA groundwater programs.
* The program encourages state program coordination on groundwater
issues through regional guidance, workplan negotiation, midyear
evaluations, NEIWPCC meetings and special geographic initiatives.
Criterion #2
The Program obtains/uses information to assess resource
vulnerability for remedial/prevention actions; and
considers resource use and value in remedial efforts and
in prevention efforts where appropriate.
* Program encourages state use of information characterizing ground
water resources to support resource protection decisions.
* State UIC programs consider ground water use and value, local aquifer
protection zones, groundwater classification, and water resource
information to support program decisions.
* The program is aware of EPA locational data policies.
* The program actively encourages state and EPA programs regulating
facility activities or overseeing state regulatory programs to
encourage collection of appropriate locational data for regulated
activities.
* State programs are slowly collecting locational data; however,
resources are a barrier to significant data collection.
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Criterion #3
The Program considers wellhead protection areas as high
priority resources in prevention and remediation
efforts in Region and State programs.
* EPA and state programs are very knowledgeable of groundwater
protection and wellhead protection program goals and routinely
consider wellhead protection in program planning and decisions.
* State UIC programs focus program inspection enforcement and outreach
efforts in wellhead protection and drinking water protection areas.
* UIC program activities that focus on groundwater resource protection
includes:
multimedia inspections resulting in identification of UIC
activities
* More effective state UIC program activities to protect resources would
be supported by increased financial resources.
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PROGRAM: Underground Injection Control
STRATEGIC ACTIVITY 5 - INFORMATION
CRITERIA VS. PROGRAM INFORMATION FORM SURVEY RESPONSES
Criterion /I
The Regional Program collects, coordinates and manages information to
assess priorities, measure progress and support CSGWPPs.
* Data collected and managed by EPA UIC program is associated with grant
tracking.
* No regional UIC data is requested by others.
* State UIC programs maintain data on closed UIC facilities and
permitted UIC activities.
* State programs desire greater access to EPA facility and environmental
resource data.
* State UIC information is typically in hard copy and available.
* Typically members of controlled UIC facilities are used as indicators
of program success.
Criterion #2
The Program uses and encourages states to use data from local, state and
other federal programs, to assess priorities, measure progress and support
CSGWPPs.
* EPA UIC program encourages state program use of groundwater related
information to support resource protection. States desire to use
these kinds of information to make decisions; however, data is
typically not readily available.
* The program is aware of state non point source state management plans,
coastal management plans, Water Quality Reports, state clean water and
groundwater protection strategies.
* Program encourages states to use information about critical resources
and contaminant source information from other programs to support
program activity.
Criterion #3
The Program has a defined set of data elements and is providing data users
with comparable qualified data.
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* The UIC program is aware of and reports use of EPA's minimum set of
data elements to describe activity that may impact water resources.
* Consensus and agreement by EPA and states on a minimum set of data
elements is important to facilitate cross program use of program data
to protect critical resources.
* The program is aware of EPA's National Locational Data Policy.
* State UIC programs are encouraged to include locational information
for permitted UIC activity.
* State programs desire and have need for locational data for facilities
regulated by RCRA, TSCA, PWS, and NPDES statutes. •
Criterion
The Program collects and facilitates the use and sharing of accurate
locational data (lat./long.) among other Regional Programs, Locals and
the State's CSGWPPs.
criterion
The scope and design of regional ground water monitoring programs reflect
EPA and State priorities and goals.
* EPA and state UIC programs do not perform monitoring and do not
typically have need for monitoring data.
* State programs may be able to use groundwater quality monitoring data
associated with areas of contaminated groundwater to direct inspection
of UIC activity.
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PROGRAM: Underground Injection Control
STRATEGIC ACTIVITY 6 - PUBLIC PARTICIPATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program's goals, priorities and progress are addressed through a public
education/involvement process.
* There is a public education and outreach component to UIC program
activity and state UIC programs are encouraged to include out reach
activities in their programs.
* New England State UIC programs develop outreach materials directed at
regulated industries, local officials, and the public to keep them
informed about UIC issues and groundwater resource protection.
* State UIC programs in conjunction with their state groundwater program
counterparts determine state UIC program direction and objectives.
* States are encouraged to include active public outreach components in
their programs during discussions about yearly workplans, during
midyear review and occasionally through out the year.
* The program supports public outreach, education, and technical
assistance through contact with EPA HQ, EPA Regions and states.
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PROGRAM: NPDES/Pretreatment
STRATEGIC ACTIVITY 1 - GW PROTECTION GOAL
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
Regional Programs are aware of and promote consistent
ground water protection strategy goals.
* The NPDES and Pretreatment programs are primarily driven by their own
program goals.
* Staff were not familiar with agency groundwater protection goals.
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PROGRAM: NPEDS/Pretreatment
STRATEGIC ACTIVITY 2 - PRIORITIES
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RSPONSES
Criterion #1
The Program has established approaches for its priority-setting process to
protect GW resources.
* The priority setting process for the programs are driven by regulatory
mandates, STARS targets, compliance and reissuance needs, and program
implementation, not protecting ground water resources.
* Recently, more flexibility has been given to states in setting
priorities so long as adequate justiciation/explanation can be
provided.
Criterion #2
The Program demonstrates consideration of varied GW characteristics in its
priority-setting process.
* The programs do not consider GW characteristics.
Criterion #3
Regional Programs have contamination source information available to
identify potential threats to GW and to set priorities base on the relative
threats to ground water resources.
* N/A to these programs
Criterion #4
The Program has technical capabilities to support its GW protection
priorities and decisions.
* The programs do not have specific technical capabilities to support GW
protection- although some staff may be knowledgable in this area.
Criterion #5
The Program has included measurement objectives for GW protection priority-
setting and methods for assessing the Program's progress in the protection
of GW resources.
* The programs do not measure progress in groundwater protection.
Criterion #6
The Program's activities give high priority to managing contamination
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= arces in wellhead protection areas and other public water supply source
c eas.
N/A
~ -iterion #7
Program coordinates its GW priorities with other environmental
-riorities.
The programs do not have GW priorities.
riterion #8
"he Program's priorities include on-going reviews and improvements of
.trategic Activities supporting the CSGWPPs.
* The programs continue to try to improve. In the area of communication
- a recent QAT effort resulted in new fact sheets and permit formats.
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PROGRAM: NPDES / Pretreatment
STRATEGIC ACTIVITY 3 - RESPONSIBILITIES
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Regional Program has been identified as GW related and lead contact
named to support Regional GW & CSGWPP matters.
* Program contacts have been identified and interviewed, but I do not
believe there is a lead contact named to actively support Regional GW
and CSGWPP matters.
Criterion #2
The Program is involved with the Regional GW coordinating committee and
supports cross-program activities & CSGWPPs.
* The programs support cross-program activities. However, because the
programs are not percieved as a "primary" gw program there has not
been much involvement on the GW Coordinating Committee.
Criterion #3
The Program has staff and resources allocated for GW protection concerns
and support of CSGWPPs.
* No, the programs do not have staff allocated for this, but they are
cooperating when needed.
Criterion #4
Relevant Federal Agencies are informed & consulted by the Program in
support of Regional GW protection efforts and state development of CSGWPPs.
* N/A
Criterion #5
The Program coordinates with the states to assess interstate matters, and
assists and encourages interstate cooperation.
* Yes, this is an important aspect of the NPDES program
* The Pretreatment Program is specific to municipalities, so it does not
get into interstate matters.
Criterion #6
The Program considers local needs and encourages/requires States to closely
involve and assist locals.
* Public hearings for NPDES program are required during which local
needs are considered.
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Local needs are considered when setting local limits for the
Pretreatment program.
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PROGRAM: NPDES / Pr et r ea tment
STRATEGIC ACTIVITY 4 - IMPLEMENTATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
^ ^ ^^ ^ ^ ^ ^^^^^ ^ ^ ^ ^ ^ ^^ ^ •• •• ^ ^ ^^ «V ^ ^ •* ^^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^^ ^ ^ ^ ^ ^ ^ ^ ^^ ^ •• ^ •• •• ^^^^^ ^^^^^^
Criterion #1
The Program coordinates, integrates, and prioritizes
resource-based efforts, and evaluates them to improve
the Region's and State's GW protection efforts.
* Both the NPDES and Pretreatment programs are prioritized based on
program compliance and regulatory directives. Occasionally resource
based efforts are considered, including impacts on surface water
drinking supplies, but GW protection is not included.
Criterion #2
The Program obtains/uses information to assess resource
vulnerability for remedial/prevention actions; and
considers resource use and value in remedial efforts and
in prevention efforts where appropriate.
* These are not remedial programs. Programs are regulatory driven and
primarily respond by setting limits to control pollutants, not by
pollution prevention actions.
Criterion #3
The Program considers wellhead protection areas as high
priority resources in prevention and remediation
efforts in Region and State programs.
* Wellhead protection areas are not considered. However, they might be
if the program staff were aware of where they are.
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PROGRAM: NPDES/Pretreatment
STRATEGIC ACTIVITY 5 - INFORMATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
• «»«•»•«•«•»••••••*••••••»••••••*•••«•«»««••••••••••»•«••»«•••••»••»••••••»•••
Criterion #1
The Regional Program collects, coordinates and manages information to
assess priorities, measure progress and support CSGWPPS.
* The NPDES program collects, coordinates and manages information for
it's own program priorities and uses a computerized data base (PCS)
for tracking compliance. Indirectly this supports CSGWPP.
* The Pretreatment program primarily uses audits and inspections to
measure program compliance.
Criterion #2
The Program uses and encourages states to use data from local, state and
other federal programs, to assess priorities, measure progress and support
CSGWPPs.
* The programs primarily use internal data. However, where needed
additional data is sought. Currently not much other data (local,
state, federal) is easliy accessible to program staff.
Criterion #3
The Program has a defined set of data elements and is providing data users
with comparable qualified data.
* Data elements as required by PCS.
* Pretreatment program requires scan of priority pollutants of influent
and effluent to determine local limits.
Criterion #3A
The Program collects and facilitates the use and sharing of accurate
locational data (lat./long.) among other Regional Programs, Locals and
the State's CSGWPPs.
* The accuracy of the program's locational data is not certain.
Sharing of this data is not activley facilitated.
Criterion #4
The scope and design of regional ground water monitoring programs reflect
EPA and State priorities and goals.
* N/A
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PROGRAM: NPDES/Pretreatment
STRATEGIC ACTIVITY 6 - PUBLIC PARTICIPATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program's goals, priorities and progress are addressed through a public
education/involvement process.
* The NPDES program is primarily regulatory. A public hearing process
is the primary tool for public comment. The program does not actively
promote it's goals, priorities and progress through public education
and involvement. The delegated states (CT, RI, and VT) may do more in
this area than the non-delegated state (MA, NH, ME).
* The Pretreatment program - carried out at the local level - relies on
Sewer Use Ordinances and setting of local limits to inform the public
and regulated community.
* Staff members do occasionly get involved in educational events.
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PROGRAM: NPDES/STORMWATER
STRATEGIC ACTIVITY 1 - GW PROTECTION GOAL
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
Regional Programs are aware of and promote consistent
ground water protection strategy goals.
* The program is aware of the Regional efforts to protect ground water.
* The program has received no direction from EPA HQ to support ground
water protection or incorporate comprehensive ground water protection
in program activities.
* The program has had no discussion with states about CSGWPP.
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PROGRAM: NPDES/STORMWATER
STRATEGIC ACTIVITY 2 - PRIORITIES
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program has established approaches for its priority-setting process to
protect GW resources.
* The program currently does not prioritize activities based on
consideration of ground water resources. Permittees are asked about
their proximity to water supplies, however, this information is not
used to prioritize permitting activities.
* Permitting rating worksheet could be used to upgrade a minor permit to-
a major permit.
* Generally permitting prioritization is supported by EPA HQ, Region I
and the program. Prioritization processes however, are informal and
not consistently applied.
* States have influence on EPA region prioritization processes through
305 (B) report processes. Prioritization typically include
consideration of lakes, watersheds, geographic targeting, and coastal
initiatives.
Criterion #2
The Program demonstrates consideration of varied GW characteristics in its
priority-setting process.
* The program is not aware of and does not specifically use ground water
resource characteristics to set program priorities.
* There is a need to clarify for the program the use and significance of
resource characteristics for priority setting.
* There is no program encouragement of state program use of ground water
characteristics for their program activity prioritization.
Criterion #3
Regional Programs have contamination source information available to
identify potential threats to GW and to set priorities base on the relative
threats to ground water resources.
* The program uses SIC codes and Discharge Monitoring Reports to gain
insight into the significance of a facility activity and to support
program prioritization of major permits.
* There is currently no use of contaminant source information to
prioritize minor NPDES and stormwater activities.
* Facilities reguired to report and that are consistently inventoried is
specified in federal regulations. No facilities are inventoried and
prioritized to protect resources.
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* The program does not set priorities based on relative threats to
ground water.
* The program could use contaminant source information from other EPA,
state and federal agencies.
* Barriers to using contaminant source information for prioritizing
program activity are related to resources, information, and
information management utility.
* Permit prioritization typically occurs for major and some minor
permits. Permitting is prioritized according to threat to resources or
people and geographic targeting.
i
* Prioritization does not impact inspections, enforcement and staffing.
* Program encourages state program prioritization to protect resources
that include ground water.
* Program feels it could benefit from program prioritization activity in
RCRA and Super fund programs.
* Barriers to prioritization that would result in program comprehensive
resource protection include narrow institutional focus on surface
water, staff and funding resources and the inability to access
supporting information.
Criterion #4
The Program has technical capabilities to support its GW protection
priorities and decisions.
* The program needs better access to information describing ground water
resources and other critical environments.
* Priority setting would be more possible if there were greater access
to facility locational data, resource characterization and contaminant
source information.
* Information quality, availability, accessibility are seen as
impediments to prioritization of program activities to protect
resources.
* Standards of data format and adoption of a minimum set of facility
data elements would support greater sharing of information.
* The program uses PCS system to mange permit data.
* There is no link of PCS to Regional CIS.
* The program does not have a mechanism to share information or obtain
information from states that would support program activity
prioritization.
* The program uses 106 state work plans to guide program activities.
Criterion #5
The Program has included measurement ob]ectives for GW protection priority-
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setting and methods for assessing the Program's progress in the protection
of GW resources.
* The program is generally aware of EPA and state adopted measures to
protect ground water resources; however, no specific performance
standards, or quality standards associated with ground water are used
to prioritize program activity.
Criterion #6
The Program's activities give high priority to managing contamination
sources in wellhead protection areas and other public water supply source
areas.
* The program routinely considers the relationship of permitted activity
to surface water drainage and to public water supply reservoirs.
* The program does not routinely consider prioritization of activities
using consideration of Wellhead Protection Areas, Sole Source
Aquifers, Water Supply Intakes and wells, high yield aquifers, and
local aquifer protection areas.
* The program does not use information on ground water resource areas to
set program priorities.
* The program encourages state consideration of ground water resource
protection areas through 106 program planning process.
Criterion #7
The Program coordinates its GW priorities with other environmental
priorities.
Criterion #8
(Responses: Any suggestions/observations are welcomed)
The Program's priorities include on-going reviews and improvements of
Strategic Activities supporting the CSGWPPs.
* The program can support state CSGWPP efforts by encouraging consistent
formal incorporation of state ground water protection goals in
stormwater program planning.
* Program activity prioritization would be supported by better access to
information describing areas of critical environmental concern.
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PROGRAM: STORMWATER
STRATEGIC ACTIVITY 3 - RESPONSIBILITIES
CRITERIA VS. PROGRAM INFORMATION FROM RESPONSES
Criterion #1
The Regional Program has been identified as GW related and lead contact
named to support Regional GW & CSGWPP matters.
* Stormwater can impact surface and ground water quality, stormwater
program can encourage use of disposal practices that reduce waste
loading and encourage infiltration best management practices.
* The program is aware and participates on the Region I Ground Water
Policy Committee, the Implementation Subcommittee and state program
coordinating committees.
* The program understands the benefit sharing information about program
activities that impact ground water with Regional and state programs.
* Agency guidance to Regional program and state programs does not
include elements or commitments on ground water protection.
Criterion #2
The Program is involved with the Regional GW coordinating committee and
supports cross-program activities & CSGWPPs.
* The program is represented on Region I Ground Water Policy Committee.
* The program maintains contact with the Ground Water management
program.
* Program views role of Ground water programs supporting identification
of ground water information needs, supporting ground water issued
discussions, liaison with state ground water programs, support for
review of general permit documentation, guidance, and best management
practices that impact ground water.
* Program is actively involved with storm water runoff from highways and
parking plots and their ground water impacts.
* The program has participated in EPA/ State roundtables associated with
CSGWPP and the Regional Assessment of ground water protection
activity.
* Barriers to more effective program coordination include management
support, state priorities, program regulatory limitation, resources,
and conflicting program guidance.
* Issues important to cross program coordination include geographic and
watershed targeting and cross program prioritization to protect ground
water resources.
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•riterion #3
.'he. Program has staff and resources allocated for GW protection concerns
md support of CSGWPPs.
* The program has committed staff resources to coordination efforts
through the Ground Water Policy Committee.
* The program expects to continue to participate in state/Regional
CSGWPP activities.
* Improvements in data quality, availability and accessibility,
prioritization of environments of critical concern, information on
regulated contaminant sources, resources for technical assistance and
outreach to states and the public and more effective targeting on
inspections and enforcement would increase the program ability to
support other Regional programs.
* Increased resources to improve use of EPA and State data to support
pollution prevention and prioritize program activity would improve
ground water and resource protection.
Criterion #4
Relevant Federal Agencies are informed & consulted by the Program in
support of Regional GW protection efforts and state development of CSGWPPs.
* Program has contact with USGS, USFWC, COE, SCS, NOAH occasionally.
* Typically, ground water is never a topic of discussion.
* The program can benefit from discussing concerning design and best
management practices developed through work by other federal agencies.
* Stormwater state programs have worked with the US Postal Service and
various federal facilities.
* State stormwater program interact with the EPA Wastewater and
Stormwater programs and Waste management programs.
Criterion #5
The Program coordinates with the states to assess interstate matters, and
assists and encourages interstate cooperation.
* The program considers downstream impacts of permitted activity on
surface water quality, aquatic biology, wetlands; however, the program
rarely considers impacts on ground water.
* The program has had no interstate discussion about ground water issues
and has received no state requests for assistance to resolve ground
water issues.
* The program is aware of established interstate organizations like
NEIWPCC, NEMOA, and NEWWA that are available mechanisms to discuss
resource protection issues.
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Criterion #6
The Program considers local needs and encourages/requires states to closely
involve and assist locals.
* There are no EPA guidances or program objectives that direct the
program work with local governments to protect ground water.
* These are opportunities for public comment on best management
practices, draft permits and other public notification processes.
There are no other formal efforts to involve the public in program
activities or planning.
* There have been few efforts to consider community ground water
protection needs when permitting stormwater discharge activities.
* States are encouraged to work closely with local communities dealing
with stormwater; however, ground water resource protection is not
emphasized.
* The program can consider use of grant and program guidance to states
to encourage consideration of local ground water resource protection
when specifying stormwater disposal options.
* Lack of information identifying local resource protection needs is a
primary barrier to considering local needs. Program could focus more
effort on consideration of local resource protection needs.
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PROGRAM: STORMWATER
STRATEGIC ACTIVITY 4 - IMPLEMENTATION
CRITERIA VS. PROGRAM INFORMATION FROM RESPONSES
Criterion #1
The Program coordinates, integrates, and prioritizes
resource-based efforts, and evaluates them to improve
the Region's and State's GW protection efforts.
* The stormwater program is delegated in some states and direct
implementation by EPA program in others.
* The program is responsible for implementing the stormwater program
permitting discharges and overseeing state delegated stormwater
programs.
* The program uses Regional permitting enforcement, discharge
guidelines, drinking water standards, effluent quality limits, water
quality goals and best management practices that are directed at
reducing or preventing contamination of resources.
* The program requires similar state activities as condition for primacy
to implement stormwater programs.
* The program can consider local discharge limits, stormwater management
plans, facility siting criteria and best management practices.
* The program does not use ground water classification when considering
stormwater discharges.
* The program coordinates with many EPA programs rarely and sees a
benefit to better communication especially with regard to more
comprehensive resource protection.
* The program does not encourage State program coordination with state
ground water programs.
* The program encourages stormwater programs coordination with State
wetland, 319, 6217 and lake programs.
* The program has opportunity to encourage state coordination through
annual regional program guidance, workplan negotiations, grant
conditions, state/EPA directors meetings, NEIWPCC meetings, special
initiatives.
Criterion #2
The Program obtains/uses information to assess resource vulnerability for
remedial/prevention actions; and considers resource use and value in
remedial efforts and in prevention efforts where appropriate.
* Program uses information about public water supplies to guide setting
discharge limits. Public surface water supplies are considered most
often. The program uses little ground water information to make
decisions.
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* Program could use information about ground water use, wellhead
protection areas, aquifer protection zones, state ground water
classification to support program decisions.
* The program does not use state ground water information.
* Program considers public water supply use, but does not consider
ground water value and vulnerability.
* Programs considering collection of latitude and longitude locational
data for facility discharges they regulate. There is no provision to
collect locational data associated with general permits.
* Locational data is not shared with states.
* Resource and specific institutional requirements to collect locational
data slow inclusion of this type of data in information management
systems .
* The program does not have sufficient technical capabilities to
evaluate and use information about ground water to support decisions.
Criterion #2
The Program considers wellhead protection areas as high
priority resources in prevention and remediation
efforts in Region and State programs.
* Program is aware of but not very knowledgeable about state wellhead
protection programs.
* The program does not routinely consider wellhead protection or local
aquifer protection zones in program decisions.
* The .program and consider ground water resources and wellhead
protection to prioritize program activity.
* State program occasionally consider wellhead protection in program
decisions and Regional program has not encouraged state consideration
of ground water resources to support activities.
* Cross program coordination and poor resource information accessibility
are barriers to greater use of resources to support program decisions.
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PROGRAM: STORMWATER
STRATEGIC ACTIVITY 5 - INFORMATION
CRITERIA VS. PROGRAM INFORMATION FROM RESPONSES
Criterion #1
The Regional Program collects, coordinates and manages information to
assess priorities, measure progress and support CSGWPPs.
* Program manages information about facilities discharge activities,
effluent quality, discharge points. This information is managed in
PCS and stormwater databases.
* Currently, no information from these databases are provided by other
EPA programs. Information could be provided to EPA programs, State,
and local organizations if requested.
* The primary difficulty in applying program managed information if
ground water protection is that data is focused on surface water
concerns. The primary focus of program is to regulated discharges to
surface water environments. Information of use for ground water
resource protection is typically poor, incomplete or not available.
* Discharge monitoring report data, pollution prevention plans, status
of BMP implementation and inspection can be used to gain a sense of
progress toward ground water resource protection.
* Program decisions could be better supported by easier on line access,
PCS data, locational data of discharges, on line access through GIS to
resource information that could be used to prioritize program
activity.
Criterion #2
The Program uses and encourages states to use data from local, state and
other federal programs, to assess priorities, measure progress and support
CSGWPPs.
* Program does not consider or encourage states to consider ground water
related information from local, state, or other federal programs to
support decisions to protect resources and support CSGWPP.
* Program is not aware of the location of means of access to, quality
off, value of, and uses of a broad spectrum of information about
ground water and other resources that could support program.
* This does not use any state developed ground water source information
to set program priorities. The program considers state developed
information available in Section 319 state management reports as
Section 305(b) water quality reports, sate cleanwater strategies and
watershed management plans; however, these sources are not considered
for ground water protection activities.
* Program does not encourage or require states to collect information
that is not specifically required by statute.
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Criterion #3
The Program has a defined set of data elements and is providing data users
with comparable qualified data.
* The program has not formally identified any set of data elements that
would support program efforts to protect ground water.
* The program is not aware of EPA efforts to standardize use of a
minimum set of data elements that can support cross program data use.
* Program information that could be useful to efforts by others to
protect resources include discharge location, facility activity, SIC
codes, facility identification number, monitoring data, discharge
limitations.
* Program is aware of EPA national locational data policy.
* Program is considering collection of locational data describing
permitted discharge locations.
* Program could use locational data for facilities provided by Toxics,
Water Supply, RCRA, and air programs, and the geographic location of
resources of critical concern identified by the Region.
Criterion #4
The scope and design of regional ground water monitoring programs reflect
EPA and State priorities and goals.
* The program maintain monitoring information associated with discharges
of stormwater that can have an impact on ground water resources.
* Program has an interest in monitoring associated with RCRA, public
water supply, Underground tanks to enable better assessment of surface
water impact on ground water degradation.
* The program has had no discussions concerning the scope and nature of
a monitoring programs and their support of ground water resource
protection.
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PROGRAM: STORMWATER
STRATEGIC ACTIVITY 6 - PUBLIC PARTICIPATION
CRITERIA VS. PROGRAM INFORMATION FROM RESPONSES
Criterion #1
The Program's goals, priorities and progress _e addressed through a public
education/involvement process.
* Public outreach and education about stormwater is a component of
program activity. Outreach issues are addressed in grants and
guidance.
* Outreach and education are typically accomplished through hotline call
in, presentations, factsheets, pamphlets.
* Outreach initiatives rarely consider issues of ground water
protection. Program could incorporate ground water protection issues
in outreach efforts.
* State watershed protection initiative offer best opportunity for
program to gain insight to public needs for information.
* Improved EPA internal and EPA/State communicating can facilitate
greater understanding of ground water resource protection.
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PROGRAM: WETLANDS
STRATEGIC ACTIVITY 1 - GW PROTECTION GOAL
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
^ ^mm ^^^ ^ «*^ ^ ^^ ^ ^^ ^ ^^ ^ ^ •• ^ BB^^^MB^^^ ^ ^^^^^^ ^^ ^ ^ ^ ••«•• ^ ^ ^^ ^ ^^ ^ ^^ ^ ^^^ MB^^ «B^ ^ ^ •• MB ^ ^ ^ ^ •• •• •
Criterion i^l
Regional Programs are aware of and promote consistent ground water
protection strategy goals.
* The Ground Water Management Section briefed the New England wetlands
managers at their quarterly meeting on the CSGWPP strategy and goals.
* The wetlands program has not received specific recommendations or
guidance from their HQ counterparts on incorporating the Strategy's
comprehensive approach into the wetlands program.
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PROGRAM: WETLANDS
STRATEGIC ACTIVITY 2 - PRIORITIES
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program has established approaches for its priority-setting process to
protect GW resources.
* The wetlands program does not specifically set priorities after
considering activity impact on ground water resources; EPA wetlands
plays a reactive role by responding to Corps of Engineers public
notice requirements for 404 permit applications. Wetlands does
practice prioritizing in a sense; for example, they would put
"priority" on a permit that proposed to fill 13 acres of wetlands, as
opposed to a permit to put in a pier in Boston Harbor. Also, EPA can
require an applicant to file for an individual permit under the 404
program (difficult, lengthy process) rather than a nationwide permit
(easier, shorter process). This is a form of prioritization.
* Prioritization or categorization schemes involve functional
assessments of wetlands and assignment of relative value bases upon
these assessments. Although the wetlands program does not like to
"rank" wetlands, national policy changes may push categorization. The
result would be greater coordination with the Corps of Engineers in
terms of examining ground water and other values more closely.
* The wetlands program feels that the National Wetlands Forum would be a
good vehicle for integrating CSGWPP concerns.
* Wetlands, as a program, does not generate a lot of information.
Resource mapping is not done by EPA, but funded through NEIWPCC.
* Emergency Wetlands Resource Act, passed by Congress in 1988, is
administered by EPA and the Fish & Wildlife Service, and was formed to
recommend funding for land acquisition (primarily wetlands) that have
outstanding resource values other than wildlife. This program could
be viewed as an opportunity to incorporate CSGWPP concerns, as well as
protect high value aquifers and other ground waters.
* Under Section 404(c) of the Clean Water Act, EPA has the authority to
veto permit applications that will have adverse impacts on municipal
water supplies or recharge areas of supply wells.
Criterion #2
The Program demonstrates consideration of varied GW characteristics in its
priority-setting process.
* The areas where the Wetlands program obtains information relating to
ground water characteristics are: 1.) sole source aquifer program, 2.)
404 applications from the Corps of Engineers, and 3.) the Ground Water
Management Section.
Criterion #3
Regional Programs have contamination source information available to
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identify potential threats to GW and to set priorities base on the relative
threats to ground water resources.
N/A
Criterion #4
The Program has technical capabilities to support its GW protection
priorities and decisions.
* EPA recently funded a permit tracking project in Connecticut and New
Hampshire. The resultant data will be shared with EPA wetlands.
Criterion #5
The Program has included measurement objectives for GW protection priority-
setting and methods for assessing the Program's progress in the protection
of GW resources.
* The Wetlands program is primarily driven by state water quality
standards, which guide the permit process. The Federal 401 permit
program also includes a provision for recognizing Outstanding Resource
Waters, which can be defined (at least in Massachusetts) as 1.)
watersheds of drinking water supplies, 2.) vernal pool habitat, and
3.) coastal Areas of Critical Environmental Concern (ACEC) .
Criterion #6
The Program's activities give high priority to managing contamination
sources in wellhead protection areas and other public water supply source
areas.
* The wetlands program does consider WHPAs, public water supplies, etc.
as important program priorities for controlling contaminant sources,
however clean fill is defined as a pollutant, not a contaminant.
Criterion #7
The Program coordinates its GW priorities with other environmental
priorities.
N/A
Criterion #8
The Program's priorities include on-going reviews and improvements of
Strategic Activities supporting the CSGWPPs.
* The concept of greater flexibility is not really relevant in the
wetlands program, which is primarily regulatory in nature. The
program feels that the only area where "flexibility" could be
introduced would be the grants program.
* State Wetlands Conservation Plans would be an effective mechanism to
introduce CSGWPP concerns. EPA is currently funding an FTE in Vermont
to produce the Plan.
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PROGRAM: WETLANDS
STRATEGIC ACTIVITY 3 - RESPONSIBILITIES
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Regional Program has been identified as GW related and lead contact
named to support Regional GW & CSGWPP matters.
* No program guidances targeted to the wetlands program currently
include elements or commitments on ground water protection through the
CSGWPP process.
Criterion #2
The Program is involved with the Regional GW coordinating committee and
supports cross-program activities & CSGWPPs.
* The wetlands program is represented on the Region I Ground Water
Policy Committee.
* The wetlands program has identified technical assistance on ground
water issues as an area where the ground water and wetlands programs
could improve coordination.
* The Wetlands White Paper, a planning document that was produced wit •
input from all Region I state wetlands programs, contains discussion
of ground water values and protection.
Criterion #3
The Program has staff and resources allocated for GW protection concerns
and support of CSGWPPs.
* The wetlands program has approximately 10 FTEs devoted to wetlands
enforcement, public education/outreach, and grant activities.
* One area where the wetlands program could use more technical analysis
is the area of ground water withdrawal impacts on wetlands.
Criterion #4
Relevant Federal Agencies are informed & consulted by the Program in
support of Regional GW protection efforts and state development of CSGWPPs.
* The federal agencies that the EPA wetlands program continuously
interacts with are the Army Corps of Engineers, the Fish & Wildlife
Service, and the National Marine Fisheries Service. Other agencies
that they coordinate infrequently with are the Soil Conservation
Service, Federal Highway Administration, and Flood Emergency
Management Agency (FEMA).
* The wetlands program has several formal agreements with other federal
agencies: an interagency personnel agreement with the Fish & Wildlife
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Service (Ralph Abele's position), enforcement activities with the
Corps of Engineers, and a BTAG (Biological Technical Assistance Grant)
with the Super fund program.
:riterion #5
The Program coordinates with the states to assess interstate matters, and
assists and encourages interstate cooperation.
* The wetlands program discusses interstate coordination issues
regarding wetlands (ground water included) on a quarterly basis
through the meetings of the New England Wetlands Managers group.
i
:riterion #6
The Program considers local needs and encourages/requires States to closely
involve and assist locals.
* The wetlands program has a full time outreach coordinator devoted to
working closely with locals. Also, 104 (b) (3) grants to the states
encourage local involvement and coordination.
•* The wetlands program would be willing to use the grant guidance
process as a vehicle for improving coordination relative to CSGWPP
issues; they would like the ground water section to provide them with
grant language.
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3ROGRAM: WETLANDS
STRATEGIC ACTIVITY 4 - IMPLEMENTATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program coordinates, integrates, and prioritizes resource-based
efforts, and evaluates them to improve the Region's and State's GW
protection efforts.
* The most promising vehicle for integrating the CSGWPP process to
states is the requirement for states to do State Comprehensive
Management Plans. If states complete these, EPA and the Corps will
consider streamlined permitting as a "carrot".
* Generally, the wetlands program feels that the ground water section
does a good job of keeping them abreast of ground water issues.
* A ground water newsletter -would be of interest to the wetlands program
if it focused on an area of mutual concern, i.e. ground water
withdrawal effects on wetlands ecosystems.
Criterion
The Program obtains/uses information to assess resource
vulnerability for remedial/prevention actions; and
considers resource use and value in remedial efforts and
in prevention efforts where appropriate.
* 404 permits are logged in on lat/long.
^^^ ^ « « • ^^^ ^ ^ ^ •• •• ^ ^ V V ^^^ ^ ^ ^ ^ ^ ^ ^ ^^^^^ ^^«^^^^^v^^^^« ^^ ^^«* ^ • ^M» •» ^ MM^^^M*^ •• •• ^ •• ^^^^ ^«
Criterion ^3
The Program considers wellhead protection areas as high priority resources
in prevention and remediation efforts in Region and State programs.
N/A
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PROGRAM: WETLANDS
STRATEGIC ACTIVITY 5 - INFORMATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Regional Program collects, coordinates and manages information to
assess priorities, measure progress and support CSGWPPs.
N/A
Criterion #2
The Program uses and encourages states to use data from local, state and
other federal programs, to assess priorities, measure progress and support
CSGWPPs .
N/A
Criterion #3
The Program has a defined set of data elements and is providing data users
with comparable qualified data.
N/A
Criterion
The Program collects and facilitates the use and sharing of accurate
locational data (lat./long.) among other Regional Programs, Locals and
the State's CSGWPPs.
N/A
Criterion #4
The scope and design of regional ground water monitoring programs reflect
EPA and State priorities and goals.
N/A
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PROGRAM: WETLANDS
STRATEGIC ACTIVITY 6 - PUBLIC PARTICIPATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program's goals, priorities and progress are addressed through a public
education/involvement process.
* The wetlands section has a non-regulatory component that exclusively
deals with wetlands education and outreach.
* The wetlands section has a vast list of in house publications
available to the public, such as fact sheets, pamphlets,
-------
PROGRAM: WATER QUALITY MANAGEMENT SECTION
STRATEGIC ACTIVITY 1 - GW PROTECTION GOAL
:RITERIA vs. PROGRAM INFORMATION FROM SURVEY RESPONSES
___«_••«_•••»«•_«••••••«»•••««•«•«•«•«•H__«__*w__«_w»w^~w««*M~w«a
Criterion #1
Regional Programs are aware of and promote consistent
ground water protection strategy goals.
* The Water Quality Management Section is mostly program driven.
Currently, there is no program that formally incorporates the GW
protection goals into state water quality standards. This is not to
say that ground water concerns are ignored by this program. These
goals can be incorporated on a case by case basis into program's
activities to the extent that information regarding the connection
between surface water pollution sources and ground water are
identified and brought to the attention of program staff.
-------
PROGRAM: WATER QUALITY MANAGEMENT SECTION
STRATEGIC ACTIVITY 2 - PRIORITIES
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program has established approaches for its priority-setting process to
protect GW resources.
* Program does not prioritize ground water or ground water information.
Criterion #2
The Program demonstrates consideration of varied GW characteristics in its
priority-setting process.
* The Program does not prioritize ground water protection or resource
characteristics.
* The Program can obtain limited ground water information through NPDES
permit review and CWA 305(b) reports.
Criterion #3
Regional Programs have contamination source information available to
identify potential threats to GW and to set priorities base on the relative
threats to ground water resources.
* The Program does not prioritize ground water information. Information
regarding ground water impacts is used on a case by case basis.
Criterion #4
The Program has technical capabilities to support its GW protection
priorities and decisions.
Criterion #5
The Program has included measurement objectives for GW protection priority-
setting and methods for assessing the Program's progress in the protection
of GW resources.
* Measurement objectives for GW are not mandated by Clean Water Act.
Connecticut, however, has incorporated GW classification system into
its WQ standards.
* The Program assesses impacts to surface-water quality from point and
non-point discharges, including NPDES and pump and treat remediation
discharges. GW is not factored into priority setting. Impacts assessed
are 1) human health and 2)organisms in surface water.
Criterion #6
-------
The Program's activities give high priority to managing contamination
sources in wellhead protection areas and other public water supply source
areas.
* • Yes. Resource protection areas considered are public water supplies,
aguifer recharge areas (when examining wetland impacts) , and
contaminant source assessment areas.
Criterion #7
The Program coordinates its GW priorities with other environmental
priorities.
* Ground water information from other programs is sought when necessary.
* Improved coordination can ensure incorporation of GW's six Strategic
Activties into WQ program.
Criterion #8
The Program's priorities include on-going reviews and improvements of
Strategic Activities supporting the CSGWPPs.
* There is some flexibility in the Program for EPA/ State interaction.
But prior it izat ion schemes are not used.
-------
PROGRAM: WATER QUALITY MANAGEMENT SECTION
STRATEGIC ACTIVITY 3 - RESPONSIBILITIES
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Regional Program has been identified as GW related and lead contact
named to support Regional GW & CSGWPP matters.
* The Program has an indirect role in managing non-point source and GW
discharge permits.
Criterion #2
The Program is involved with the Regional GW coordinating committee and
supports cross-program activities & CSGWPPs.
* Eric Hall represents the Program in the Ground Water Policy Committee.
* The Program has participated in CWA 319 grants comprehensive planning.
Criterion #3
The Program has staff and resources allocated for GW protection concerns
and support of CSGWPPs.
* No. The Program does not have staff allocated specifically for ground
water protection activities. If a question or issue arises about
ground water, then we can work with the Ground Water Management
Section.
* However, closer communication between the Program and the GWMS is
recommended .
* The Program would like to focus on priority setting, prevention, and
remediation for the Region's programs.
Criterion #4
Relevant Federal Agencies are informed & consulted by the Program in
support of Regional GW protection efforts and state development of CSGWPPs.
Criterion #5
The Program coordinates with the states to assess interstate matters, and
assists and encourages interstate cooperation.
* Interstate coordination regarding ground water is routinely encouraged
with regard to non-point source programs. This will also likely be a
part of 303 (d) planning activities.
-------
Criterion #6
The Program considers local needs'and encourages/requires States to closely
involve and assist locals.
* Yes, particularly with regard to prioritization for NFS and
development of management plans.
-------
PROGRAM: WATER QUALITY MANAGEMENT SECTION
STRATEGIC ACTIVITY 4 - IMPLEMENTATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program coordinates, integrates, and prioritizes
resource-based efforts, and evaluates them to improve
the Region's and State's GW protection efforts.
* Yes, but only in the context of reviewing GW or non-point source
impacts to surface-water quality. In general, the Program uses State
water quality standards to reduce contamination, with the exception of
when 1) when EPA applies federal criteria and 2) downstream State
criteria. GW classification can be used in the permit process to
protect GW quality.
* The Program coordinates often with the non-point source, stormwater,
NPDES, Regional Counsel and GWMS programs; occasionally with the GIS
and Bays programs; and rarely with the rest (listed in 4.k.).
* Support with the Program and the GWMS is through an informal staff
relationship. This can be improved by educating respective staffs
about their program activities. The Program thinks that RCRA, CERCLA
and Pesticides could benefit from the Program's activities.
* The Program believes that ground water concerns are poorly factored
into permit activities and decisions. This is a result of the
regulatory factors discussed above.
Criterion #2
The Program obtains/uses information to assess resource vulnerability for
remedial/prevention actions; and considers resource use and value in
remedial efforts and in prevention efforts where appropriate.
* On a case by case basis. Generally, the Program only uses resource-
related information such as surface water/ground water interaction
data. GW information alone is rarely used.
* Resource characterization information may come later after the State
TMDL programs mature.
* NPDES outfalls maybe checked occasionally by the Program through topo
map or site visit to confirm location..
Criterion #3
The Program considers wellhead protection areas as high priority resources
in prevention and remediation efforts in Region and State programs.
* The Program's level of protection of high priority resources reflects
the level of protection mandated by federal law (CWA goals) and state
water quality standards.
-------
PROGRAM: WATER QUALITY MANAGEMENT SECTION
STRATEGIC ACTIVITY 5 - INFORMATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Regional Program collects, coordinates and manages information to
assess priorities, measure progress and support CSGWPPs.
* The Program does not collect, coordinate or manage GW information to
make priorities.
Criterion #2
The Program uses and encourages states to use data from local, state and
other federal programs, to assess priorities, measure progress and support
CSGWPPs .
* On a case by case basis, as necessary to protect critical resource
areas and hydrologically linked surface waters.
* The Program is aware of Nonpoint Source, Section 319 State Management
Program reports and any other reports that describe surface water
quality [305(b), 303 (d) ] .
* The Program may assist the States determine what information to
collect, manage and use in 303 (d) and nonpoint source information with
regard to surface water contamination from ground water.
Criterion #3
The Program has a defined set of data elements and is providing data users
with comparable qualified data.
* No. The Program is also unaware of the Minimum Set of Data Elements
for Water Quality and EPA's Locational Data Policy.
Criterion #3A
The Program collects and facilitates the use and sharing of accurate
locational data (lat./long.) among other Regional Programs, Locals and
the State's CSGWPPs.
* No.
Criterion #4
The scope and design of regional ground water monitoring programs reflect
EPA and State priorities and goals.
* The Program does not monitor ground water quality.
-------
PROGRAM: WATER QUALITY MANAGEMENT SECTION
STRATEGIC ACTIVITY 6 - PUBLIC PARTICIPATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program's goals, priorities and progress are addressed through a public
education/involvement process.
* Yes, but ground water information is not addressed through the
Program.
-------
PROGRAM: NONPOINT SOURCE
STRATEGIC ACTIVITY 1 - GW PROTECTION GOAL
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
Regional Programs are aware of and promote consistent ground water
protection strategy goals.
* Yes. Using cross-program efforts, as well as guidance issued to and
communication with states, consistent application of federal and state
ground water protection goals is promoted through the development and
implementation of §319 work plans and Nonpoint Source Management
Plans.
-------
PROGRAM: NONPOINT SOURCE
STRATEGIC ACTIVITY 2 - PRIORITIES
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program has established approaches for its priority-setting process to
protect GW resources.
* Not yet, but will with development and implementation of GW
prioritization component of NFS Management Plans by states.
Prioritization "guidance" is forthcoming.
Criterion #2
The Program demonstrates consideration of varied GW characteristics in its
priority-setting process.
* Not yet, but possible with development and implementation of GW
prioritization component of NPS Management Plans by states.
Criterion #3
Regional Programs have contamination source information available to
identify potential threats to GW and to set priorities base on the relative
threats to ground water resources.
* No contaminant sources are inventoried by the program; states
undertake this work and use the results in-state. As noted above,
states will be encouraged to set priorities under the GW
prioritization "guidance".
Criterion #4
The Program has technical capabilities to support its GW protection
priorities and decisions.
* Unknown until prioritization "guidance" is developed and implemented.
Criterion #5
The Program has included measurement objectives for GW protection priority
setting and methods for assessing the Program's progress in the protection
of GW resources.
* Unknown until prioritization "guidance" is developed and implemented.
Criterion #6
The Program's activities give high priority to managing contamination
sources in wellhead protection areas and other public water supply source
areas.
-------
* Informally now; should improve with development and implementation of
the prioritization "guidance" which will include high priority public
water supply areas such as WHPA's. Lat/long is not required for
location of contamination sources, and would only be funded if it were
part of an implementation project.
Criterion #1
The Program coordinates its GW priorities with other environmental
priorities.
* See previous answers.
Criterion #8
The Program's priorities include on-going reviews and improvements of
Strategic Activities supporting the CSGWPPs.
* Need to continue seeking state input on guidance development.
-------
PROGRAM: NONPOINT SOURCE
STRATEGIC ACTIVITY 3 - RESPONSIBILITIES
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Regional Program has been identified as GW related and lead contact
named to support Regional GW & CSGWPP matters.
* Yes. Bob Morehouse.
Criterion #2
The Program is involved with the Regional GW coordinating committee and
supports cross-program activities & CSGWPPs.
* Yes, through GWPC and annual ad-hoc §319 review teams.
Criterion #3
The Program has staff and resources allocated for GW protection concerns
and support of CSGWPPs.
* Yes, to the extent that NPS staff oversee and coordinate GW components
of state work plans.
Criterion #4
Relevant Federal Agencies are informed & consulted by the Program in
support of Regional GW protection efforts and state development of CSGWPPs.
* Yes.
Criterion #5
The Program coordinates with the states to assess interstate matters, and
assists and encourages interstate cooperation.
* Yes through NEIWPCC, although no situations to date.
Criterion #6
The Program considers local needs and encourages/requires States to closely
involve and assist locals.
* Yes, guidance requires public participation.
-------
PROGRAM: NONPOINT SOURCE
STRATEGIC ACTIVITY 4 - IMPLEMENTATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
• __••»•••••»»•••••«_•_••»••_«__••__«*•»•.______•_••_••«••••««•»«««««••«•»
Criterion #1
The Program coordinates, integrates, and prioritizes resource-based
efforts, and evaluates them to improve the Region's and State's GW
protection efforts.
* Some efforts already exists (e.g., CSGWPP/WHPP and P2 as required by
NPS guidance; coordination with GWMS) , but will be improved with
development and implementation of the prioritization "guidance".
^ •• ^ «• ^^ •• ^^ ^ ^ ^m ^ ^ ^ ^ ^ MB ^ ^ ^^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ flW^ ^ MB ^ ^ ^ •• ^ ^^ ^ ^«B^ ^ ^ ^^ ^ ^^^ ^ ^ •• ^ ^ ^ ^^ ^ ^ ^^ ^^
Criterion #2
The Program obtains/uses information to assess resource vulnerability for
remedial/prevention actions; and considers resource use and value in
remedial efforts and in prevention efforts where appropriate.
* See above relative to prevention; little remediation under §319.
^ ^ ^ ^ ^^ ^ ^^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ (^ W •• ^ ^ •• ^ ^ ^ ^ ^ ^ ^^ ^ ^ ^ ^ ^ ^ ^ •• ^ ^ ^ •• ^ ^ ^ ^ ^ •• ^ ^ •• M»^ ^ ^ ^^^^^ •
Criterion #3
The Program considers wellhead protection areas as high priority resources
in prevention and remediation efforts in Region and State programs.
* See above.
-------
PROGRAM: NONPOINT SOURCE
STRATEGIC ACTIVITY 5 - INFORMATION
CRITERIA VS. PROGRAM IFORMATION FROM SURVEY RESPONSES
«»__»•»•«*•«•••••••««••««_••••••_•»••«««••••••«•»•••»»«•••«•««»•»«••»«••
criterion #1
The Regional Program collects, coordinates and manages information to
assess priorities, measure progress and support CSGWPPs.
* Unknown regarding specific data bases managed by NPS programs (state
and federal); however, forthcoming ground water prioritization
"guidance" will likely encourage use of existing data bases (e.g.,
WHPP, Public Water Supply) for prioritization, at a minimum.
Criterion #2
The Program uses and encourages states to use data from local, state and
other federal programs, to assess priorities, measure progress and support
CSGWPPs.
* See above.
Criterion #3
The Program has a defined set of data elements and is providing data users
with comparable qualified data.
* Unknown.
Criterion #3A
The Program collects and facilitates the use and sharing of accurate
locational data (lat./long.) among other Regional Programs, Locals and the
State's CSGWPPs.
* Lat/long is not required for location of contamination sources, and
would only be funded if it were part of an implementation project.
Criterion #4
The scope and design of regional ground water monitoring programs reflect
EPA and State priorities and goals.
* Yes.
-------
PROGRAM: NONPOINT SOURCE
STRATEGIC ACTIVITY 6 - PUBLIC PARTICIPATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program's goals, priorities and progress are addressed through a public
education/involvement process.
* Yes; §319 guidance requires public participation/education.
-------
PROGRAM: MARINE AND ESTUARINE PROTECTION SECTION
STRATEGIC. ACTIVITY 1 - GW PROTECTION GOAL
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
Regional Programs are aware of and promote consistent
ground water protection strategy goals.
* The Program has not received encouragement from HQ's to incorporate
the CSGWPP strategy into its own internal activities and priorities or
with State program activities.
-------
PROGRAM: MARINE & ESTUARINE PROTECTION SECTION
STRATEGIC ACTIVITY 2 - PRIORITIES
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program has established approaches for its priority-setting process to
protect GW resources.
* Program does not prioritize ground water or ground water information.
Criterion #2
The Program demonstrates consideration of varied GW characteristics in its
priority-setting process.
* The Program does not prioritize ground water protection or resource
characteristics .
Criterion #3
Regional Programs have contamination source information available to
identify potential threats to GW and to set priorities base on the relative
threats to ground water resources.
* The following contaminant sources are inventoried: POTW's,
contaminated rivers, atmospheric deposition, dredging material,
stormwater drainage, CERCLA sites, RCRA sites, landfills.
* The major threats to surface water are sources of nitrate and
phosphate .
* Ground water may be prioritized only when it may contribute
nitrate/phosphates to surface water at unacceptable levels.
* Barriers consist of access difficulties, hard copy data, missing data,
and suspect quality of data.
* The Program encourages the collection of lat/long coordinates of
sources.
Criterion #4
The Program has technical capabilities to support its GW protection
priorities and decisions.
* The program has sufficient technical capability but not enough money.
It needs more GPS units.
Criterion #5
The Program has included measurement objectives for GW protection priority-
setting and methods for assessing the Program's progress in the protection
of GW resources.
-------
* Measurement objectives are contained in water quality standards.
Criterion #6
The Program's activities give high priority to managing contamination
sources in wellhead protection areas and other public water supply source
areas.
* Resource areas (such as ground water recharge zones) and contaminant
sources are mapped and digitized. GPS is also used, when available.
Criterion #7
The Program coordinates its GW priorities with other environmental
priorities.
N/A
Criterion #B
The Program's priorities include on-going reviews and improvements of
Strategic Activities supporting the CSGWPPs.
N/A
-------
PROGRAM: MARINE & ESTUARINE PROTECTION SECTION
STRATEGIC ACTIVITY 3 - RESPONSIBILITIES
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Regional Program has been identified as GW related and lead contact
named to support Regional GW & CSGWPP matters.
* The Program is not aware of any Regional coordinating committee for
ground water protection.
Criterion #2
The Program is involved with the Regional GW coordinating committee and
supports cross-program activities & CSGWPPs.
* The Program has participated only in the Merrimack River Initiative.
Criterion #3
The Program has staff and resources allocated for GW protection concerns
and support of CSGWPPs.
* No. The Program does not have staff allocated specifically for ground
water protection activities. If a question or issue arises about
ground water, then we can work with the Ground Water Management
Section.
* However, closer communication between the Program and the GWMS is
recommended.
Criterion #4
Relevant Federal Agencies are informed & consulted by the Program in
support of Regional GW protection efforts and state development of CSGWPPs.
* U.S. Geological Survey - routinely
USDA-SCS - routinely
NOAA - routinely
Corps, of Engineers - routinely
U.S Fish and Wildlife Service - routinely
U.S. Coast Guard - rarely
Criterion #5
The Program coordinates with the states to assess interstate matters, and
assists and encourages interstate cooperation.
* Lake Champlain (NY/Vt) : nitrate and land-use issues
* The Program has not discussed interstate coordination regarding ground
water.
-------
The Program believes that the Region should facilitate interstate
dialog about GW issues, such as with the NEIWPCC.
riterion #6
The Program considers local needs and encourages/requires States to closely
nvolve and assist locals.
* Yes, with local governance committees, demonstration projects, and
attends many meetings with local groups.
The Program heavily involves local government in planning and
decision-making, with respect to septic systems, development of
educational materials for public outreach, BMPs, and establishing
partnerships.
* The Program works with local governance committees to focus on
embayments and minibay projects such as Plum Island Sound, Waquoit
Bay, Wellfleet Harbor, etc.
-------
PROGRAM: MARINE & ESTUARINE PROTECTION SECTION
STRATEGIC ACTIVITY 4 - IMPLEMENTATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program coordinates, integrates, and prioritizes
resource-based efforts, and evaluates them to improve
the Region's and State's GW protection efforts.
* Yes, but only in the context of protecting surface-water quality in
coastal areas.
Criterion #2
The Program obtains/uses information to assess resource.
vulnerability for remedial/prevention actions; and
considers resource use and value in remedial efforts and
in prevention efforts where appropriate.
* The Program only uses resource-related information such as resource
sensitivity, aquifer type, contaminant sources, and surface
water/ground water interaction data from the U.S. Geological Survey,
USDA-SCS, universities, and State agencies. Other information includes
water-quality data, land use data, MASS GIS coverages, bathymetrie
data, and 1:5,000 scale orthophotos of State coastline.
Criterion #3
The Program considers wellhead protection areas as high
priority resources in prevention and remediation
efforts in Region and State programs.
* The Program has little or no awareness of State wellhead protection
programs. Obtaining maps showing WHPAs would be helpful.
-------
PROGRAM; MARINE & ESTUARINE PROTECTION SECTION
STRATEGIC ACTIVITY 5 - INFORMATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Regional Program collects, coordinates and manages information to
assess priorities, measure progress and support CSGWPPs.
* The Program currently compiles information in its Massachusetts Bays
Program database. Information is provided to State and local programs
for research and monitoring studies.
* The Program does not now have a plan to share its data with the GWMS
or other ground water related programs.
* Currently, program emphasis is on nitrate modeling and management in
coastal embayments.
Criterion #2
The Program uses and encourages states to use data from local, state and
other federal programs, to assess priorities, measure progress and support
CSGWPPs .
* The Program uses such information (through its own data management
committee) but does not now actively encourage greater use among
agencies according to CSGWPP guidelines.
•* The Program is aware of and uses CCAMP reports.
Criterion #3
The Program has a defined set of data elements and is providing data users
with comparable qualified data.
* No, the Program does not define or specify particular ground water
data elements. It is not aware of the Minimum Set of Data Elements for
Ground Water Quality.
Criterion #3A
The Program collects and facilitates the use and sharing of accurate
locational data (lat./long.) among other Regional Programs, Locals and
the State's CSGWPPs.
* The Program uses locational data from the USGS, SCS and university
researchers, but not from states. Locational data tends to be limited
to surface water quality monitoring stations.
Criterion
-------
The scope and design of regional ground water monitoring programs reflect
EPA and State priorities and goals.
*' The Program monitors only surface-water quality data.
-------
PROGRAM: MARINE & ESTUARINE PROTECTION SECTION
STRATEGIC ACTIVITY 6 - PUBLIC PARTICIPATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program's goals, priorities and progress are addressed through a public
education/involvement process.
* Yes, but only in the context of managing and characterizing impacts to
surface water quality in coastal and marine environments. Ground
water, per se, is not intrinsic to Program goals.
-------
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-------
?SCGRAM POLLUTION PREVENTION
STRATEGIC ACTIVITY 1 - GW PROTECTION GOAL
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion £1
Regional Programs are aware of and promote consistent
ground water protection strategy goals.
* The goal of the Region I Pollution Prevention (P2) "Program" is to
promote P2 integration into the Region's programs wherever possible
and to assist the New England States with increasing their capacity to
run P2 Programs.
* P2 is more of a theme or concept to institutionalize into the Region's
practices rather than an operating "program".
* The Region's two P2 Coordinators have not discussed CSGWPPs with the
Headquarters Pollution Prevention Division (PPD) nor the Region I
States. The P2 Coordinators are in the process of identifying what
are their roles in the Region I CSGWPP process.
-------
= R :• '•RAM ?C ll'-TI3N PREVENTION
STRATEGIC ACTIVITY 2 - PRIORITIES
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #\
The Program has established approaches for its priority-setting process to
protect GW resources.
* P2 priorities are established by the Region I P2 Task Force
(established in 1989) through consensus-building with final approval
from the Leadership Team.
i
* The Leadership Team has designated P2 a key priority area for FY 1993
and 1994 under the Region's Strategic Planning process.
* Ground water protection priorities may be integrated with P2 via the
annual P2 workplan writing process begun in FY 1993. Each Division
agrees to invest/dis invest in new P2 activities. Currently, ground
water concerns are most effectively addressed through the Water
Division P2 Workplan Writers Workgroup.
* The Region I States have historically targeted activities by industry
that is, the magnitude of the industry's impact on the environment.
The States have just begun to integrate P2 more closely with their
media programs via state P2 task forces. The States are also applying
media grants to do P2 in priority watersheds and ground water resource
areas (FY 1994) .
Criterion #2
The Program demonstrates consideration of varied GW characteristics in its
priority-setting process.
* The P2 Task Force sets priorities with significant input from the
States. Ground water characteristics are not applicable for use in
the Task Force's priority-setting process.
* The focus of the Region I P2 Program is policy development versus
technical determinations.
* Initially, comparative risk studies were used to target activities to
prevent problems which pose the greatest environmental and health
risks; ground water pollution was ranked as having a low potential
risk to human health and the environment.
Criterion #3
Regional Programs have contamination source information available to
identify potential threats to GW and to set priorities base on the relative
threats to ground water resources.
* The Program does not use contaminant source information. However, the
States or Regional media programs may use land use data to implement
specific P2 projects.
-------
Criterion *4
The Program has technical capabilities to support its GW protection
priorities and decisions.
* Although the P2 Program is more policy oriented, more guidance is
needed to write permits (e.g. NPDES) which specifically incorporate
P2. The P2 Task Force has convened a workgroup to organize and
develop P2 training for permit writers.
Criterion 15
The Program has included measurement objectives for GW protection priority-
setting and methods for assessing the Program's progress in the protection
of GW resources.
* Not applicable.
Criterion 16
The Program's activities give high priority to managing contamination
sources in wellhead protection areas and other public water supply source
areas.
* The P2 Program relies on the media programs to integrate resource
protection concerns into P2 projects. For example, the media program
representatives directing the PIT STOPS project developed guidance for
States to target technical assistance in high priority water resource
areas such as WHPAs.
* The P2 Task Force does not currently dictate in its funding criteria
that P2 projects must occur in high priority resource areas.
Criterion #1
The Program coordinates its GW priorities with other environmental
priorities.
* The P2 Task Force seeks to institutionalize P2 into all the Region's
programs. The Task Force, with representatives from every Division,
balances all environmental priorities of the Agency and agrees upon a
roadmap to follow via consensus-building.
Criterion #8
The Program's priorities include on-going reviews and improvements of
Strategic Activities supporting the CSGWPPs.
* The Program currently participates on the GWPC and ISC.
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STRATEGIC ACTIVITY 3 - RESPONSIBILITIES
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
^ ^ ^ ^ ^^ ^ ^^^ ^ ^ ^ ^^^^ ^ ^ ^^ ^ ^ ^^ ^ ^ ^ ^ OM^OM ^ ^^ ^^ ^ ^ ^^ ^ ^ ^ ^ ^ ^ ^ ^^^ «• ^ ^ •
Criterion #1
The Regional Program has been identified as GW related and lead contact
named to support Regional GW & CSGWPP matters.
* The lead contact on CSGWPP and P2 issues also serves as the P2 Task
Force alternate for the Water Division.
Criterion #2
The Program is involved with the Regional GW coordinating committee and
supports cross-program activities & CSGWPFs.
* Each P2 Coordinator is a member of the GWPC and ISC.
* The P2 Coordinators facilitate (at least initially) virtually all
cross-program P2 activities funded with P2 monies (e.g. PIT STOPS) .
The P2 Coordinators also serve on the former P2 KPA and the Region I
Merrimack River Initiative Committee, with their primary role as
facilitators of the Region I P2 Task Force.
Criterion #3
The Program has staff and resources allocated for GW protection concerns
and support of CSGWPPs.
* The Program coordinates with media programs via several committees.
* P2 integration is fairly decentralized in the Region. Each Division
may invest in P2 activities and oversees state implementation of P2
using media grants.
* The P2 Task Force is developing P2 training for permit writers which
should protect all water resources.
Criterion #4
Relevant Federal Agencies are informed & consulted by the Program in
support of Regional GW protection efforts and state development of CSGWPPs.
* The Program has interacted with DOT concerning transportation plans
for which the Air Division is the lead contact. Also, DOE and the
Program interact on water conservation issues. The media programs are
consulted for their technical expertise as necessary.
* Formal agreements between EPA/ DOT and EPA/FHWA have been established
to cooperate better in planning such that environmental impacts will
be considered.
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=?.cc-?AM ?CII.T::N- PREVENTION
STRATEGIC ACTIVITY 4 - IMPLEMENTATION
CRITERIA VS. PROGRAM IMPLEMENTATION FROM SURVEY RESPONSES
Criterion 11
The Program coordinates, integrates, and prioritizes
resource-based efforts, and evaluates then to improve
the Region's and State's GW protection efforts.
* P2 is not a "program" in the traditional sense; rather, P2 is a
concept which is incorporated into operating practices. There is no
distinct, national "P2 Program" per say with requisite legal
authorities.
* The two P2 Coordinators working in the Planning & Management Division
promote P2 integration and coordination formally via facilitation of
the P2 Task Force and informally on a consultation basis. Each
Division performs P2 activities in the Region with decentralized
coordination by the P2 Task Force, which meets monthly to quarterly.
Beyond sharing information and advising with policy development, the
Task Force is now responsible for general oversight and distribution
of Regional P2 funds and providing guidance and training for all
subsequent (from FY 1994) P2 Workplan Writing activities.
* The States all promote P2 in their media programs to various degrees.
The States have had P2 Programs since the beginning of the 1990s. The
Region has typically exercised minimal oversight of the States' P2
Programs, as Headquarters has managed the Pollution Prevention
Incentives for states (PPIS) grants. Now that the Regions will
administer these grants, there are opportunities to ensure resource
protection priorities are integrated into States' efforts. (Note:
PPIS grants do not constitute a "delegated program".)
Criterion #2
The Program obtains/uses information to assess resource
vulnerability for remedial/prevention actions; and
considers resource use and value in remedial efforts and
in prevention efforts where appropriate.
* The Program does not collect resource data. (See SA#5)
Criterion 13
The Program considers wellhead protection areas as high
priority resources in prevention and remediation
efforts in Region and State programs.
* The Program is aware of State Wellhead Programs.
* Priorities set by the P2 Task Force to date do not require or
encourage targeting to wellhead protection areas. The media programs
which implement P2 projects help set the resource protection
priorities.
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= ? : C- RAM FCllwTIS.'.' PREVENTION
STRATEGIC ACTIVITY 5 - INFORMATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion *l
The Regional Program collects, coordinates and manages information to
assess priorities, measure progress and support CSGWPPs.
* The Program does not collect any resource or industry data. Data
collection is done by the States and Regional media programs, which
are represented on the P2 Task Force.
* The Program maintains a P2 Resource Center which consists of EPA P2
documents and miscellaneous P2 materials. The Region I Library
receives only the main EPA P2 documents from the Center. The Waste P:
manager in the Waste Division also maintains a separate collection
focused on waste issues.
* A recent Executive Order requires federal facilities to produce P2
plans which may make federal facility data available to the Regions.
^ ^ ^ ^ ^^ ^ ^ ^ ^ ^ •• ^ ^^ ^ ^ ^«* ^ ^^«K«M ^ •• ^^ ^ ^ ^ ^^ ^ ^ ^^ ^ ^ ^^«B^ ^ ^ •• ^^ ^ •• ^^ ^ ^ ^ ^^«* ^^ ^^ ^ •• ^^ ^^^ ^ ^^^ ^fl
Criterion #2
The Program uses and encourages states to use data from local, state and
other federal programs, to assess priorities, measure progress and support
CSGWPPs .
* States are not encouraged to use ground water data. The States are
given much flexibility with how they set priorities.
Criterion £3
The Program has a defined set of data elements and is providing data users
with comparable qualified data.
* Not applicable.
Criterion 13A
The Program collects and facilitates the use and sharing of accurate
locational data (lat./long.) among other Regional Programs, Locals and
the State's CSGWPPs.
* The Federal and State P2 Programs do not collect facility data.
Criterion 14
The scope and design of regional ground water monitoring programs reflect
EPA and State priorities and goals.
* Not applicable.
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Criterion *5
The Program coordinates with the states to assess interstate matters, and
assists and encourages interstate cooperation.
* The Program coordinates with several interstate organizations via the
P2 Task Force:
• New England Interstate Water Pollution Control Commission
(NEIWPCC)
• Northeast Waste Management Officials Association/North East State
Pollution Prevention Roundtable (NEWMOA/NESPPR)
• North East States for Coordinated Air Management (NESCAUM)
Criterion ^6
The Program considers local needs and encourages/requires States to closely
involve and assist locals.
* The Program rarely works directly with locals except when responding
to occasional requests for information or assistance. States are not
specifically encouraged to involve locals.
* Identifying local needs for P2 materials could help focus Headquarters
in developing technical assistance documents.
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= .= ;:• =_;_•*. .=: ii*. T :::; =R;VZMTIQN
STRATEGIC ACTIVITY 6 - PUBLIC PA3TTCIPATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1.
The Program's goals, priorities and progress are addressed through a publi
education/involvement process.
* The P2 Program responds to local requests for information as needed.
Local outreach is performed by the State P2 Technical Assistance
Programs and Region I media programs.
* Identifying local needs for P2 materials could help focus Headquarter:
PPD in developing technical assistance documents.
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PROGRAM INFORMATION MANAGEMENT
STRATEGIC .ACTIVITY 1 - GW PROTECTION GOAL
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
Regional Programs are aware of and promote consistent
ground water protection strategy goals.
* Program has received no instructions or encouragement from EPA
Headquarters to support Comprehensive Ground Water Resource
Protection.
* The program has not discussed or communicated with State program
counterparts regarding CSGWPP goals or activities.
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PROGRAM INFORMATION MANAGEMENT
STRATEGIC ACTIVITY 2 - PRIORITIES
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program has established approaches for its priority-setting process to
protect Ground Water (GW) resources.
* Program has had no specific discussions regarding program activity
prioritization to support protection of ground water resources.
* Program serves the information management need of programs requesting
support and views prioritization of program activity as a program
specific responsibility.
* Program can work to support program prioritization processes when
requested and routinely encourages secondary use of data for focusing
resource protection.
Criterion #2
The Program demonstrates consideration of varied GW characteristics in its
priority-setting process.
* Program has no program activity process that considers ground water
protection.
Criterion #3
Regional Programs have contamination source information available to
identify potential threats to GW and to set priorities base on the relative
threats to ground water resources.
* Program is not in a position to inventory contaminant sources and,
consequently, does not use this type of information to protect ground
water resources.
* The barriers to utilizing contaminant source inventories that might be
used by EPA programs include: lack of adequate locational data that
can support prioritization based on relative proximity to critical
resources; outdated and error filled contaminant source inventory data
bases; incomplete contaminant source inventories; significant issues
of data quality, data availability, data accessibility; and, issues of
information management utility and integration that can support
substantive resource protection.
Criterion #4
The Program has technical capabilities to support its GW protection
priorities and decisions.
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* Program does not set priorities that are directed at protecting ground
water resources.
* EPA program technical needs could be determined when programs indicate
priority setting processes adopted.
* Programs wishing to prioritize activity can indicate facility,
resource, contaminant source, and environmental monitoring data needs.
Information system enhancements and tools would be identified and
specific enhancements could be made if resources are available.
* Latitude and longitude locational data is not available in EPA data
bases precluding their use to support program prioritization
processes.
* Program has not encouraged state information management counterparts
to support state program prioritization schemes.
Criterion #5
The Program has included measurement objectives for GW protection priority-
setting and methods for assessing the Program's progress in the protection
of GW resources.
* Program is aware of many state and EPA standards adopted to protect
ground water; however, the program does not use this type of
information to prioritize its program activity.
Criterion #6
The Program's activities give high priority to managing contamination
sources in wellhead protection areas and other public water supply source
areas.
* Program does not consider resource protection areas when prioritizing
program activity.
* Program attempts to consider the information needs of all levels of
government and the public but has no specific mandate or authority to
focus on local organizations.
* Latitude and longitude locational data for source of contamination and
resource areas is important to prioritizing EPA program activity to
protect resources. The program obtains locational data from State
programs, EPA contractors, and EPA labs typically on program request.
Criterion #1
The Program coordinates its GW priorities with other environmental
priorities.
Criterion #8
The Program's priorities include on-going reviews and improvements of
Strategic Activities supporting CSGWPPs.
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PROGRAM INFORMATION MANAGEMENT
STRATEGIC ACTIVITY 3 - RESPONSIBILITIES
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #\
The Regional Program has been identified as GW related and lead contact
named to support Regional GW & CSGWPP matters.
* The program supports maintenance of Region information and informatior
management systems. The program has no responsibility for regulatory
activity that impacts ground water and other resources. The program
has responsibility for maintenance of many types of information and
information systems that are important to effective resource
protection.
* The program actively participates on the Ground Water Policy
Committee.
* No EPA guidances to the program includes reference to CSGWPP or
resource protection.
Criterion #2
The Program is involved with the Regional GW coordinating committee and
supports cross-program activities and CSGWPPs.
* The program is represented on the Ground Water Policy Committee. The ...
program maintains contact with State information management programs
and CSGWPP roundtables to assure cross program access to information.
* The program routinely participates in cross program ground water and
resource protection related activity. The program participates in trie
Resource protection, KPA, Light Industry Project, Pollution
Prevention, Geographic Targeting in Merrimack River, Nashua River,
Blackstone River Basins, Chesprocott and Bays Initiatives.
* Barriers to increased program support of resource protection include
resources, information and information system limitations.
Criterion #3
The Program has staff and resources allocated for GW protection concerns
and support of CSGWPPs.
* The program views its role as a service to Regional programs. Work
related to CSGWPP and resource protection occurs with direction and
resources provided by programs needing services.
* The program advocates and supports secondary and cross program uses of
EPA data. Increased regional commitment of resources would enhance
our opportunities to actualize broader use of Regional data to protect
resources.
Criterion #4
Relevant Federal Agencies are informed and consulted by the Program in
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support of Regional GW protection efforts and state development of CSGWPPs.
* The program occasionally has contact with USGS, USFWL, and DOA SCS.
Contact has primarily been related to transfer of information that can
support Regional program data needs.
* Memorandums of Understanding (MOU) with these Federal Agencies have
been developed nationally. There are no specific MOU that are Region
specific. The program is not aware of any Federal Agency/ state MOU
that relates to resource protection.
Criterion #5
The Program coordinates with the states to assess interstate matters, and
assists and encourages interstate cooperation.
* The program is an active participant in the Merrimack River
Initiative.
* Topics of inter-State coordination have focused on issues of
information exchange to support specific Regional program needs. No
discussion of ground water specific interstate issues has occurred;
however, ground water and other resource information transfer does
occur.
* The program participates in discussions about data management and
geographic information coordinated through the NEIWPCC and the
State/ EPA Data Management Coordinating Committee.
Criterion #6
The Program considers local needs and encourages/requires States to closely
involve and assist locals.
* There is no component of programs mission that encourages or directs
program activity with local governments. The program does not
consider the information needs of local resource protection.
* The program has no grants with States and is not in a position to
require State focus on local activities. The program has had no
discussion with States about their support of local resource
protection.
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PROGRAM INFORMATION MANAGEMENT
STRATEGIC ACTIVITY 4 - IMPLEMENTATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program coordinates, integrates, and prioritizes
resource-based efforts, and evaluates then to improve
the Region's and State's GW protection efforts.
* The program does not perform any regulatory activity or oversee any
state regulatory program. The program does not prioritize any of its
activity with ground water or resource protection as an objective.
* Information management functions routinely necessitate contact with
all Regional programs. Related ground water contact is typically rare
with the most common contact regarding CIS services.
* The program has good working relationship with the Ground Water
Management and Water Supply Branch. The program could be part of a
more substantial effort to identify and protect a broader spectrum of
critical resources and to assess information management needs.
* A broad spectrum of programs could benefit from Regional efforts to
improve EPA ability to prioritize activity to protect resources.
* The program discusses information management issues with states and
could discuss issues of resource protection information needs through
State/EPA Data management program processes.
Criterion #2
The Program obtains/uses information to assess resource
vulnerability for remedial/prevention actions; and
considers resource use and value in remedial efforts and
in prevention efforts where appropriate.
* The program obtains and manages resource related information in
response to requests from Regional programs. The program does not use
resource information to make program decisions.
* The program is aware of EPA's latitude/longitude locational data
policy. There is a national EPA effort to standardize
latitude/longitude coding and to assure that all EPA programs include
these data in their databases.
* Few Region I databases contain reliable latitude/longitude information
that is suitable to support prioritization of program activity that
will result in better protection of resources. The principal barrier
to collection of latitude/longitude locational data is a Regional
decision to do so.
* State programs are beginning to collect latitude/longitude information
for appropriate data bases and they use this information to support
resource protection.
Criterion #3
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The Program considers wellhead protection areas as high
priority resources in prevention and remediation
efforts in Region and State programs.
* The program is aware of Wellhead Protection (WHP) program; but not
knowledgeable about program goals. The program does not regulate any
activity or oversee state regulatory activity and, consequently, does
not consider WHP when directing program activity.
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PROGRAM INFORMATION MANAGEMENT
STRATEGIC ACTIVITY 5 - INFORMATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Regional Program collects, coordinates and manages information to
assess priorities, measure progress and support CSGWPPs.
* The program currently collects, manages, and provides many types of
information that can be used by Regional and State programs to protect
resources. The program provides Geographic Systems (GIS) Data
Management, Information transfer, and hardware and software technical
support to Regional programs and States.
* With some notable exceptions, information available in Regional data
management systems, including ground water monitoring data, is of poor
quality, missing key data, and is not conveniently accessible to
support resource protection on a broad scale. There is no Regional
plan to assess information and information system needs that can
support prior itization of program activity to protect resources.
* The program would like to have the Agency's mmonitoring data that is
developed or contracted for in one place that is LAN accessible. In
addition, the program recommends the development of a listing of other
state data sources that would allow the Agency to readily assess their
utility and assessibility.
Criterion #1
The Program uses and encourages states to use data from local, state and
other federal programs, to assess priorities, measure progress and support
CSGWPPs .
* The program does not use Regional or State ground water resource
information to conduct program activities.
* The program regulates no activities or oversee State regulatory
programs and does not direct Regional or State information collection
or management.
* The program supports Regional and State collection and management of
information that supports resource protection.
Criterion #3
The Program has a defined set of data elements and is providing data users
with comparable qualified data.
* The program is aware of EPA latitude/ longitude locational policy.
* The program has no functions that necessitate collection of locational
data. All locational data that program uses to support Regional
activities is provided by Regional programs or the states.
* Locational data in Regional data management systems is typically of
poor quality or non-existent.
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Criterion #3A
The Program collects and facilitates the use and sharing of accurate
locational data among other Regional Programs, Locals and
the State's CSGWPPs.
Criterion #4
The scope and design of regional ground water monitoring programs reflect
EPA and State priorities and goals.
* The program conducts no environmental monitor activity and has little
opportunity to impact the scope of monitoring efforts.
* The program acquires and uses monitoring data developed through
Regional program activities. These data are typically used in the
program's efforts to support other program activity.
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PROGRAM INFORMATION MANAGEMENT
STRATEGIC ACTIVITY 6 - PUBLIC PARTICIPATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program's goals, priorities and progress are addressed through a public
education/involvement process.
* Public and state access to Regional data is a component of program
activity. The program does not have a public outreach component to its
mission. Currently, the program has discussed issues of increased
public access to EPA data. EPA/HQ has indicated that public access is
an issue. The program engages the states to discuss information access
through state/EPA information management processes.
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AIR
MANAGEMENT
DIVISION
ST«K
u
"\ PRC*^
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GENERAL NOTE: The Pesticides programs in Region I have already taken
significant and measurable strides in ground water protection, principally
through state implementation. All the New England states have primary
responsibility for administering various federal programs under the Federal
Insecticide, Fungicide, and Rodenticide Act (FIFRA); these programs include
ground water protection, endangered species, and worker protection.
Specifically, using EPA guidance, states are developing and implementing
Generic State Management Plans and will developing and implementing
Pesticide-Specific Management Plans (collectively known as SMP's).
PROGRAM: PESTICIDES
STRATEGIC ACTIVITY 1 - GW PROTECTION GOAL
i
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
Regional Programs are aware of and promote consistent ground water
protection strategy goals.
* Yes. Guidance issued to states promotes consistent application of
ground water protection goals (at the state level) through the
development and implementation of SMP's.
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PROGRAM: PESTICIDES
STRATEGIC ACTIVITY 2 - PRIORITIES
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program has established approaches for its priority-setting process to
protect GW resources.
* Yes. Guidance issued to states establishes need for priority-setting
(at the state level) through the development and implementation of
SMP's.
Criterion #2
The Program demonstrates consideration of varied GW characteristics in its
priority-setting process.
* Yes, as above. The SMP Guidance component "V. Basis for Assessment and
Planning" includes consideration of how the state identifies "current
or reasonably expected drinking water sources" and "ground water that
can affect ecosystem integrity". Component V also includes emerging
CSGWPP considerations, land use, and determination of use, value and
vulnerability.
Criterion #3
Regional Programs have contamination source information available to
identify potential threats to GW and to set priorities base on the relative
threats to ground water resources.
* Yes, as above. Through the SMP process states are assessing pesticide
threats to ground water resources. Contamination source information
from pesticide use is retained by the states not the regional office.
Criterion #4
The Program has technical capabilities to support its GW protection
priorities and decisions.
* Yes, the Pesticides Program GW protection priorities include technical
and financial support including review of states' SMPs. SMP review
procedures supplement technical expertise in key areas by drawing on
experts from other programs.
Criterion #5
The Program has included measurement objectives for GW protection priority-
setting and methods for assessing the Program's progress in the protection
of GW resources.
* A part of each state's Cooperative Agreement with EPA includes
specific targets and milestones for pesticides and ground water SMP
development.
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Criterion #6
The Program's activities give high priority to managing contamination
sources in wellhead protection areas and other public water supply source
areas.
* Yes. Through the development and implementation of SMP's, the New
England states typically prioritize contamination sources in public
water supply source areas.
Criterion #7
The Program coordinates its GW priorities with other environmental
priorities.
* Yes. Pesticide management and use is undertaken by states relative to
other considerations such as worker protection and endangered species,
through guidance from EPA.
Criterion #3
The Program's priorities include on-going reviews and improvements of
Strategic Activities supporting the CSGWPPs.
* The Program recommends creation of a mechanism for review of and
concurrence with Generic Pesticide State Management Plans or review
and approval of Pesticide-Specific State Management Plans. Ideally,
this organization would be separate from the Region I Ground Water
Policy Committee, but would regularly brief the Policy Committee on
activities related to review/concurrence/approval.
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PROGRAM: PESTICIDES
STRATEGIC ACTIVITY 3 - RESPONSIBILITIES
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Regional Program has been identified as GW related and lead contact
named to support Regional GW & CSGWPP matters.
* Yes; Rob Koethe.
Criterion #2
The Program is involved with the Regional GW coordinating committee and
supports cross-program activities & CSGWPPs.
* Yes, Pamela Ringoff is a member of the GW Policy Committee. Robert
Koethe is a member of both the GW Implementation and Data Management
Subcommittees. The pesticide and ground water SMP development process
encourages cross-program activities at both the Headquarters and
Regional levels.
Criterion #3
1'he Program has staff and resources allocated for GW protection concerns
and support of CSGWPPs.
* Yes, in order to meet its ground water protection responsibilities
especially as they relate to the SMP process, Program FTEs are
allocated for pesticides and ground water protection. Financial
support is provided through FIFRA grants to pesticide regulatory
agencies for protecting ground water from potential pesticide
contamination. Nevertheless, more resources for Region's Pesticide
Program and for state agencies developing SMPs would be helpful.
Criterion #4
Relevant Federal Agencies are informed & consulted by the Program in
support of Regional GW protection efforts and state development of CSGWPPs.
* The Pesticides Section works closely with the USDA Cooperative
Extension Service to deliver pesticide education programs to train
pesticide applicators using Restricted-Use pesticides. Since education
is a key component for protection of ground water resources, CES is
involved in the SMP process in all Region I states. Other federal
agencies with whom the Program has contact include the USDA Soil
Conservation Service, the Agricultural Experiment Station System, and
the U.S. Fish and Wildlife Service.
Criterion #5
The Program coordinates with the states to assess interstate matters, and
assists and encourages interstate cooperation.
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* No, the pesticide SMP process does not specifically address interstate
issues. To date, no potential problems have emerged for Regional
Office attention and no guidance has been provided by Headquarters.
Criterion #6
The Program considers local needs and encourages/ requires States to closely
involve and assist locals.
* The SMP mechanism emphasizes the central role of the state in ground
water protection. SMPs also consider other levels of governments. SMP
Component II addresses Roles and Responsibilities of Agencies,
including federal, state and local agencies. SMP Components III -
Legal Authority, X - Public Awareness and Participation, XI -
Information Dissemination, and possibly some other SMP components may
also address local considerations.
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PROGRAM: PESTICIDES
STRATEGIC ACTIVITY 4 - IMPLEMENTATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program coordinates, integrates, and prioritizes resource-based
efforts, and evaluates them to improve the Region's and State's GW
protection efforts.
* The New England states have primary responsibility for administering
various federal programs under the Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA) ; these programs include ground water
protection, endangered species, and worker protection. Key programs
are pesticide enforcement and applicator certification and training.
Specific GW protection efforts include standard setting in the SMP
process, cross-program coordination at the Federal and state levels,
and consideration of GW in guidance development and implementation.
Criterion #2
The Program obtains/uses information to assess resource vulnerability for
remedial/prevention actions; and considers resource use and value in
remedial efforts and in prevention efforts where appropriate.
* GW resource vulnerability, typically developed using information such
as current and expected use, is a key consideration in the development
and implementation of SMP's.
* Lat/long is obtained and utilized where possible; additional GPS
access is necessary.
Criterion #3
The Program considers wellhead protection areas as high priority resources
in prevention and remediation efforts in Region and State programs.
* While the state pesticide programs utilize their state WHPP
information to some extent, knowledge of the programs could improve.
As previously noted, SMP's are the primary mechanism for consideration
of WHPA's (e.g., priority area for monitoring).
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PROGRAM: PESTICIDES
STRATEGIC ACTIVITY 5 - INFORMATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Regional Program collects, coordinates and manages information to
assess priorities, measure progress and support CSGWPPs.
* Principally through SMPs, GW data is collected and managed by the
states; data typically stays with the states. The Program supports
the Merrimack River Initiative and has facilitated the inclusion of
pesticide use information collected by the New Hampshire pesticide
lead regulatory agency.
criterion #2
The Program uses and encourages states to use data from local, state and
other federal programs, to assess priorities, measure progress and support
CSGWPPs.
* See above.
Criterion #3
The Program has a defined set of data elements and is providing data users
with comparable qualified data.
* Although the Program does not collect its own ground water data, SMP
Component VI - Monitoring recommends use of EPA's MSDE. As previously
noted,, lat/long and other descriptors may not always be available and
a defined set of data elements is not specified in SMP draft guidance.
Criterion #3A
The Program collects and facilitates the use and sharing of accurate
locational data (lat./long.) among other Regional Programs, Locals and
the State's CSGWPPs.
* See above.
Criterion #4
The scope and design of regional ground water monitoring programs reflect
EPA and State priorities and goals.
* Through SMP's, states design and implement pesticides monitoring
programs, reflecting state priorities and goals, along with EPA
guidance.
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PROGRAM: PESTICIDES
STRATEGIC ACTIVITY 6 - PUBLIC PARTICIPATION
CRITERIA VS. PROGRAM INFORMATION FROM SURVEY RESPONSES
Criterion #1
The Program's goals, priorities and progress are addressed through a public
education/involvement process.
* Public outreach/education regarding pesticides/GW occurs principally
through SMP's.
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Appendix D
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COMPREHENSIVE GROUND WATER PROGRAM - REGIONAL ASSESSMENT
RESOURCE CONSERVATION AND RECOVERY ACT - C (RCRA C)
FINAL RECOMMENDATIONS
I. BARRIER 1 - RESOURCES
1. Provide, and require states to provide, sufficient
resources (after resources are identified) to acquire
adequate numbers of GPS units for obtaining accurate
latitude/longitude during all inspections, complaint
responses and site investigations (excepting on-site
investigations, borings, test pits, monitoring
locations, until coordination logistics, applications
and data repositories are established).
(Region/Program/State) [SA 2;4;5] (Program, Region)
{Lead contact - Frank Battaglia; FY '95 activity}
2. Consider, cooperatively with the state, to direct or
provide resources sufficient for initiatives to inspect
small quantity generators in high priority, critical GW
resource areas. (Program) [SA 2; 4] {Lead contact -
Frank Battaglia; FY 95}
II. BARRIER 2 - INFORMATION
1. Note: There is a critical need for ground water
resource related information for the Regional and state
RCRA C activities, including priority setting
(inspection/ enforcement, NCAPS and Environmental
Benefits Review), remedial investigation, assessment of
risk and determination of clean-up levels, etc.
Remedial assessment utilizes all GW related information
identified in the Survey. Generally, there is critical
need for GW resource related including the following
for attaining a comprehensive GW protection approach:
resource sensitivity
hydro/geologic parameters
aquifer characteristics
ground water quality and yield
current uses and value
reasonably expected future use and value
location of public and private wells
wellhead protection areas
local aquifer protection zones
Sole Source Aquifers
population statistics
etc.
2. Use available information in resource based approach,
including all prioritizing for inspections,
enforcement, corrective action (NCAPS) and
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Environmental Benefits Review; and use in risk and
clean-up level determinations, etc.; and site
investigation and remedial planning. Promote and
require state program to do the same. (Program) [SA
2;4;5] (Lead contact - Frank Battaglia, Pat Mickey; FY
95}
3. Integrate contaminant-based inspection initiatives with
the resource-based approach (i.e.: dry cleaners in
WHPAs). (Program) [SA 2] {Lead contact - Pat Hickey;
FY1 94/95}
4. Participate with other Regional and state programs in
identifying the program's/state program's data needs
for GW related resource information, contamination,
demographics, source information, etc., not currently
in existing state and Regional data bases. (Program/
Region) [SA 2;4;5] {Lead contact - Frank Battaglia; FY
•94/95}
5. Acquire/obtain, and similarly reguire state program
under grant workplans or conditions, to collect quality
accurate latitude/longitude information now and in the
future, including obtaining it in all opportunities,
including notifications, applications, inspections,
etc. for all LQGs, SQGs, VSQGs (state), TSDs, etc.
Encourage state program to obtain accurate data on
VSQGs (conditionally exempt). (Region/Program) [SA
2;5] {Lead contact - Frank Battaglia; FY ' 94/95}
6. Encourage states to continue to make program
information more accessible to local governments and
organizations directing resource protection.
•(Including mapped resources, source inventories,
technical assistance documents, fact sheets, pilot
projects, etc.). (Program) [SA 3,4;6] {Lead contact -
Frank Battaglia; FY '95}
III. BARRIER 3 - COORDINATION
1. Time and staff constraints could limit coordination
with other programs. Identify coordination needs and
roles and discuss with other Regional and state
programs how best to improve coordination. Similarly
encourage state program. (Program) [SA 3] {Lead contact
- Frank Battaglia; FY '94/95}
2. Improve program staff knowledge of state, Regional and
locally available data and information. Cooperatively
identify with state and Regional program and data
managers, the water resource-related information,
demographic and user information and contaminant source
information currently available that can be applied to
RCRA C uses. (Region/Program/State). [SA 2;4;5] {Lead
-------
contact - Frank Battaglia; FY '94/95}
3. Coordinate with Regional and state program and data
managers, and institutionalize data sharing, cataloging
and inventorying, to maintain knowledge of available
information/data, CIS data layers, critical resources,
etc. (Region/Program) {Lead contact - Frank
Battaglia; FY '94/95} [SA 4;5]
4. Assign coordinating contacts between RCRA C and GW
Management Section programs. Define any roles in
reviewing annual guidance or grant conditions,
participation in information management discussions and
in prioritizing activities in critical resource areas,
etc. (RCRA C Program/GWM Program) [SA 3] {Lead
contact - Frank Battaglia (RCRA C); Rob Adler (GWM) ;
FY '94/95}
5. Continue to encourage state program to closely
coordinate with state GW program on resource and
contaminant source issues and data/information efforts.
(Program) [SA 3] {Lead contact - Frank Battaglia; FY
•94/95}
6. Continue to require, in grant guidance and grant
conditions, the state program's participation (with the
state GW office) in state efforts for developing and
implementing the Comprehensive State GW Protection
Program (CSGWPP) and other resource related program.
(Program) [SA 3;4] {Lead contact - Frank Battaglia;
FY '95}
7. Continue to require state program's participation on
the states' "GW Coordination Mechanism" (committee) .
(Program) [SA 3] {Lead contact - Frank Battaglia; FY
•95}
8. Participate in cross-program coordinator teams, such as
in teams recently initiated in the Water Division; team
forums (for Region's state coordinators) are being held
for program coordinators to discuss cross-program
issues, priorities, resource information, etc.
(Region/Program) [SA 3;4] {Lead contact - Frank
Battaglia; FY '94/95}
9. Attempt coordinating and involving local data, land
use, resource use and characteristics, etc., into
priorities for corrective action, and inspections.
(Region/Program) [SA 2] {Lead contact - Frank
Battaglia, Ernie Waterman; FY '94/95}
10. Share priority determination and results of
inspections/enforcement with other programs (UIC, NFS,
WHP, PWS...) for their prioritization.
-------
(Region/Program) [SA 2;4] {Lead contact - Frank
Battaglia, Ernie Waterman; FY '94/95}
11. Coordinate (encourage state program to coordinate) with
P2 for outreach materials for inspections. (Region/
Program/ State) [SA 2;4] {Lead contact - Pat Hickey;
FY '94/95}
12. Coordinate with state and GWM to utilize state resource
documents. (Region/Program) [SA 2;5] {Lead contact -
Frank Battaglia (RCRA C), Rob Adler (GWM); FY '94/95}
13. Improve coordination with the Water Management programs
and Toxic and Pesticides program. (Program) [SA 3]
{Lead contact - Frank Battaglia; FY '94/95}
IV. BARRIER 4 - GROUND WATER RESOURCE / SOURCE IDENTIFICATION
l. Encourage state program to participate in resource
assessment and mapping critical resources for setting
priorities, undertaking corrective action, etc.
(Program) [SA 5] {Lead contact - Frank Battaglia; FY
•95}
7. BARRIER 5 - GROUND WATER ISSUES AWARENESS
1. Improve GW Policy Committee's understanding of the
limited GW resource considerations in current priority
setting approaches, and obtain support for cross-
program improvements in information/locational and GW
resource data. Role of GW Policy Committee is needed
to improve resource-based priority setting.
(Region/Program) [SA 3] {Lead contact - Frank
Battaglia, Dennis Huebner; FY '94/95}
2. Improve NCAPS - consider supplemental GW resource
information. (Program/HQ/Region) [SA 2] {Lead contact
- Frank Battaglia, Ernie Waterman; FY '95}
3. Program/state program put high priority for inspections
at federal, state and local municipal facilities (DPWs,
post offices, town halls, fire stations, etc.).
(Region/Program/ State) [SA 2;4] {Lead contact - Pat
Hickey; FY '94/95}
VI. BARRIER 6 - GRANTS
1. Provide flexibility to traditional grant program
funding lines to support cross-program priorities.
(Region/Program) [SA 2;4] {Lead contact - Frank
Battaglia; FY '95}
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VII. BARRIER 7 - INSTITUTIONAL
1. Institute resource-based priority setting. (Program)
{Lead contact - Frank Battaglia, Pat Hickey; FY 94/95})
2. Improve NCAPS - RCRA C corrective action priority
methodology calculation to include additional resource
based factors; and/or improve Environmental Benefits
Review for considerations GW and water resource
factors. (Headquarters/Program) [SA 2] {Lead contact -
Frank Battaglia, Ernie Waterman; FY '95}
3. Initiate defining "use" and "value" as related to the
program, and participate with other programs to arrive
at consistent definitions; related to setting
corrective action clean-up limits and priority setting
(under NCAPS). Identify the type of information needed
for their determination, and cooperatively initiate
data collection. (Program) (Headquarters/ Region)
[SA 2,4] {Lead contact - Frank Battaglia; FY '95}
4. Promote with state programs to require accurate and
certified (by engineer, surveyor, etc.)
latitude/longitude locational information (one second
accuracy). Make appropriate changes in the instructions
for filing the forms. (Headquarters/Program) [SA 5]
{Lead contact - Frank Battaglia; FY 95}
5. Promote institutionalizing collection of accurate
latitude/longitude in service industries such as
banking, insurance, realtors and mortgage industries.
(Headquarters/Region/Program) [SA 4;5] {Lead contact -
Frank Battaglia; FY '94/95}
VIII.BARRIER 8 - OUTREACH / EDUCATION
1. Identify and participate in identifying ways to enhance
public access to EPA/RCRA C information related to
sources of contamination, pollution prevention and
regulated activities. (Region/Program) [SA 3;4;6]
{Lead contact - Frank Battaglia; FY '95)
2. Provide local government Boards of Health, or other
Board with results of inspections conducted in their
towns, to support local resource protection efforts.
(Program) [SA 4;5;6] {Lead contact - Pat Hickey,
Frank Battaglia; FY 94/95}
3. Undertake, and encourage the state program, assessing
the needs and assistance necessary for improving the
locals capacity to manage hazardous waste activities;
prioritize development of these types of assistance.
Support "local tools." Tools include:
• technical assistance and "science"
-------
local inspector training
development of quality outreach/educational
materials
distribution of quality P2 information
developing local advocacy
developing model ordinances, or demonstration
projects
• providing useful resource information and
contaminant source inventories
(Program/State) [SA 3;4]
{Lead contact - Frank Battaglia; FY '95)
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COMPREHENSIVE GROUND WATER PROGRAM - REGIONAL ASSESSMENT
RCRA D PROGRAM
FINAL RECOMMENDATIONS
III. BARRIER 3 - COORDINATION
1. Continue close coordination with State Ground Water
Protection Program Managers to assist with developing
State Solid Waste Permitting Program (SWPP)
applications. Region I RCRA D staff may seek GWMS
assistance on an as-needed basis to understand state
operations prior to state discussions and raise and/or
resolve controversial issues. [SA 4; 1] (P)
{Lead contact- Aaron Gilbert; FY'94 activity}
2. Inform Region I State Ground Water Managers of SWPP
efforts and encourage coordination with State RCRA D
staff. [SA 4; 1] (P)
{Lead contact- Michele Notarianni; FY'94 activity}
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COMPREHENSIVE GROUND WATER PROGRAM - REGIONAL ASSESSMENT
SDPERFUND PROGRAM
FINAL RECOMMENDATIONS
I. BARRIER 1 - RESOURCES
II. BARRIER 2 - INFORMATION
1. Support development and utilize information on
locational mapping of priority or critical resources
(e.g. wetlands, WHPAs) for priority setting of sites
(e.g. Sis, MRS), and for determining appropriate
remediation approaches. (Region/Program/GWMS)
[SA 2; 4; 5]
{Lead contact- Lynn Gilleland; ongoing activity}
2. Support development and share information with states
and regional programs on accurate locational data and
mapping of sites, for use in priority setting and for
determining appropriate remediation approaches. Site
inventories are compiled on the CERCLIS list, but not
locationally mapped (e.g.CIS). (Region/Program)
[SA 2; 4; 5]
{Lead contact- Lynn Gilleland; ongoing activity}
3. For identifying potential CERCLIS listing and providing
site-specific background, establish mechanism to obtain
information obtained from sanitary surveys conducted at
local level, and conversely provide locational site
data to local ground water managers. Local contacts
could also provide information on verifying site
locations (e.g. lat/long.) and identifying land uses
and local management controls. (Region/Program) [SA 3;
4; 5]
{Lead contacts- Lynn Gilleland/Don Smith; ongoing
activity}
III. BARRIER 3 - COORDINATION
1. Provide specific vision/direction, funding and
encouragement to the regions, to support and
incorporate comprehensive ground water planning into
programs' activities and priorities. (Headquarters)
[SA 1]
2. Initiate discussions with states to cooperatively
understand state/federal differences between programs,
support consistent approaches to priority setting and
determining cleanup objectives, and determine areas for
mutual support and improvement. Fully comprehensive
-------
programs may include 1 list of hazardous waste sites,
where states and EPA in partnership determine
strategies for all sites, including designation of lead
agency. [SA 2; 4; 6]
{Lead contact- Dennis Huebner; ongoing activity}
3. Work with GWMS to formalize procedures to coordinate on
significant site-specific ground water issues (e.g. GW
reclassification, Technical Impracticability Waivers).
(Program/GWMS) [SA 3; 4]
{Lead contact- Dick Willey; ongoing activity}
4. Continue to support a communication channel between
federal and state Superfund and Ground Water programs,
to discuss ways to further support a state directed
resource-based approach to ground water remediation.
GWMS shall facilitate discussions with state Ground
Water Programs on assessing use, value and
vulnerability of ground water, based on a comprehensive
state strategy. (Program/GWMS) [SA 3; 4]
{Lead contact- Dennis Huebner; ongoing activity}
5. Promote state internal coordination including: annual
national guidance; Program Directors Meeting: NEMOA
Meeting; state/EPA meetings; special initiatives. [SA
3; 4] {Lead contact- Dennis Huebner; ongoing activity}
IV. BARRIER 4 - GROUND WATER RESOURCE SOURCE IDENTIFICATION
Upon establishment of realistic and consistent state
classification schemes, establish a mechanism to use state
classification in setting program priorities and determining
• appropriate remediation approaches. (Program/GWMS) [SA 2; 4]
{Lead contact- Dennis Huebner; ongoing activity}
V. BARRIER 5 - GROUND WATER ISSUES AWARENESS
1. Encourage the consistent incorporation of the new
comprehensive approach into agency operating guidance
and strategic planning. (Headquarters/Program) [SA 3]
{Lead contact- Dennis Huebner; ongoing activity}
2. Clearly articulate what EPA expects the states to do in
support of CSGWPP across all programs and what regional
and national programs are doing to remove barriers,
including changes in statutes and guidances where
necessary. (Headquarters/Region/Program) [SA 4; 6]
{Lead contact- Dennis Huebner; ongoing activity}
VI. BARRIER 6 - GRANTS
1. Require the states and EPA contractors through
grant/contract conditions, to acquire accurate
locational mapping of sites in their site assessments
-------
activities (e.g. PA/SI). [SA 2]
{Lead contact- Don Smith; ongoing activity}
2. Incorporate into core state grants to the extent
possible a requirement to participate in the
comprehensive ground water strategy. [SA 3]
{Lead contact- Carl Deloi; ongoing activity}
VII. BARRIER 7 - INSTITUTIONAL
1. With facilitation by Ground Water Management Section,
encourage and initiate dialogue with states to define
realistic goals and objectives for ground water
remediation, which includes use, value and
vulnerability. (Program/GWMS) [SA 1]
{Lead contacts- Dennis Huebner/Dick Willey; ongoing
activity}
2. CERCLA/NCP specify methods for determining cleanup
approaches which may restrict flexibility in promoting
a state directed resource-based approach to
remediation. During reauthorization of CERCLA,
national programs should recommend changes for
consistency with CSGWPP Guidance. Such changes may
include deletion of reference to federal ground water
classification system (in deference to state
classifications), and clarification for preference for
rapid restoration where warranted based on the use and
value of the resource. (Headquarters/Program) [SA 4]
{Lead contact- Dennis Huebner; FY'94 activity}
3. Encourage creative use of Supplemental Environmental
Projects (SEPs) in settlement of Superfund liabilities.
For example, can we get PRPs to finance local Wellhead
Protection Programs in areas in close proximity to the
sites? The outcome of such efforts would be to further
protect the existing water supplies so that the need
for additional sources, including ground water at the
site, shall be minimized. By financing local prevention
activities, PRPs would be providing the regulatory
agencies greater comfort in allowing less aggressive
approaches, including technical impracticability
waivers, while minimizing their potential future
liability. (Headquarters/Region/Program) [SA 4]
{Lead contact- Ira Leighton; ongoing activity}
VIII.BARRIER 8 - OUTREACH/EDUCATION
Conduct cross-program training with GWMS on State Wellhead
Protection Programs and goals. (Program/GWMS) [SA 4]
{Lead contact- Nancy Smith; ongoing activity}
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COMPREHENSIVE GROUND WATER PROGRAM - REGIONAL ASSESSMENT
UNDERGROUND STORAGE TANK (UST) PROGRAM
FINAL RECOMMENDATIONS
I. BARRIER 1 - RESOURCES
Increase resources to UST program for increased leak
detection activities and for obtaining GPS locational data
(HQ/Region/state). [SA 2, SA 4,4b].
{Lead contact- Myra Schwartz; FY'94 activity}
II. BARRIER 2 - INFORMATION
1. Encourage increased data sharing between state and
federal programs (state/Region) [SA 5].
{Lead contact- Myra Schwartz; FY'94 activity}
2. Encourage states to institute the use of lat/long
standards for use in priority setting, inspections,
monitoring, and compliance. [SA 4,2g-n, SA 5,3hj.
{Lead contact- Myra Schwartz; FY'94 activity}
3. Consider the use of more relevant environmental
indicators to monitor progress in ground water
protection, such as tracking tank replacements (state).
[SA 5,1k]. {Lead contact- Myra Schwartz; FY'94
activity}
III. BARRIER 3 - COORDINATION
1. Encourage increased communication and coordination
between LUST program and ground water/wellhead
protection program at the state level [SA 3].
{Lead contact- Myra Schwartz; FY'94 activity}
2. Communicate the status of each state's wellhead
protection program to the UST program. Provide
mapping, where available, of communities with
designated wellhead protection areas for use in
targeting enforcement and remediation decisions (GWMS)
[SA 5,le]. {Lead contact- Myra Schwartz; FY'94
activity}
3. Provide the UST program with information on well data
and water distribution systems within WHPAs (GWMS/PWSS)
[SA 5,If]. {Lead contact- Myra Schwartz; FY'94
activity}
4. Coordinate and share inspection results between EPA UST
-------
staff and ground water management staff [SA 3]
{Lead contact- Myra Schwartz; FY'94 activity}
IV. BARRIER 4 - GROUND WATER RESOURCE IDENTIFICATION
N/A
V. BARRIER 5 - GROUND WATER ISSUES AWARENESS
N/A
VI. BARRIER 6 - GRANTS
VII. BARRIER 7 - INSTITUTIONAL
Evaluate the desirability of increased information sharing
with states on health-based risk issues relating to heating
oil petroleum spills, and whether state standards are the
most appropriate and effective means of ensuring the
protection of public health (HQ/Region/state) [SA 3,2h].
{Lead contact- Myra Schwartz; FY'94 activity}
VIII.BARRIER 8 - OUTREACH/EDUCATION
N/A
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COMPREHENSIVE GROUND WATER PROGRAM - REGIONAL ASSESSMENT
MARINE AND ESTDARINE PROTECTION SECTION
FINAL RECOMMENDATIONS
I. BARRIER 1 - RESOURCES
The Program needs more Global Positioning System units
for locational data. (Region)
II. BARRIER 2 - INFORMATION
The program shall encourage information gathering on local
conditions affecting nitrogen loading rates, including soil
types. (Program)
{Lead contact- Matt Liebman; FY'94 activity}
III. BARRIER 3 - COORDINATION
1. The Program shall encourage greater involvement with
ground-water related activities and technical staff,
including coordination with the Nonpoint Source Program,
especially for coastal areas. (Program)
{Lead contact- Matt Liebman; FY'94 activity}
2. The Region and the States should improve growth
management strategies.
IV. BARRIER 4 - GROUND WATER RESOURCE IDENTIFICATION
V. BARRIER 5 - GROUND WATER ISSUES AWARENESS
VI. BARRIER 6 - GRANTS
VII. BARRIER 7 - INSTITUTIONAL
1. Program shall support program planning on a regional,
embayment or watershed basis.
{Lead contact- Matt Liebman; FY'94 activity}
2. Improve Massachusetts Title 5 regulations.
{Lead contact- Matt Liebman; FY'94 activity}
3. Program shall encourage giving more authority to regional
planning agencies and county governments.
{Lead contact- Matt Liebman; FY'94 activity}
VIII.BARRIER 8 - OUTREACH/EDUCATION
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COMPREHENSIVE GROUND WATER PROGRAM - REGIONAL ASSESSMENT
NON POINT SOURCE PROGRAM
FINAL RECOMMENDATIONS
I. BARRIER 1 - RESOURCES
Generate awareness at the state level of opportunities for
§319 and §320 Estuaries Program expenditures allowed for the
state revolving fund under the Clean Water Act. Source;
SA#3. {Lead contact- Robert Morehouse; FY'94 activity}
II. BARRIER 2 - INFORMATION
No recommendations developed.
III. BARRIER 3 - COORDINATION
1. Increase involvement and communication with regional
and state NFS staff regarding regional CSGWPP
activities. Source; SA#2.
{L.ead contact- Robert Morehouse; FY'94 activity}
2. Provide support for ground water product reviews and
i-formation exchange of materials developed under Clean
hater Act §604 (b) water quality planning projects.
Responsible; Ground Water Management Section/Non Point
Source Program. Source; SA#5.
{Lead contact- Robert Morehouse; FY'94 activity}
IV. BARRIER 4 - GROUND WATER RESOURCE IDENTIFICATION
Continue to recognize and support flexibility for Clean
Water Act §319 ground water projects to conduct assessment
and planning activities which will result in implementation.
Responsible; Ground Water Management Section/Non Point
Source Program. Source; SA#3. *This recommendation is also
applicable to Barrier #7.*
{Lead contact- Robert Morehouse; FY'94 activity}
V. BARRIER 5 - GROUND WATER ISSUES AWARENESS
Continue to identify ground water priorities for region and
states and provide as part of Regional §319 guidance.
Responsible; Ground Water Management Section/Non Point
Source Program. Source: SA#2.
{Lead contact- Robert Morehouse; FY'94 activity}
-------
VI. BARRIER 6 - GRANTS
No recommendations identified.
VII. BARRIER 7 - INSTITUTIONAL
1. Continue to emphasize an holistic water resource
approach to state programs to ensure maximization of
funding. Source; SA#2.
{Lead contact- Robert Morehouse; FY'94 activity}
2. Refer also to Barrier 4.
VIII.BARRIER 8 - ODTREACH/EDUCATION
No recommendations identified.
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COMPREHENSIVE GROUND WATER PROGRAM - REGIONAL ASSESSMENT
NPDES/PRETREATMENT PROGRAM
FINAL RECOMMENDATIONS
I. BARRIER 1 - RESOURCES
II. BARRIER 2 -INFORMATION
1. Make information on the location of all-public water
supplies accessible to permit writers and Pretreatment
staff. Have them include relevant information in the
permit fact sheet. (Program) [SA# 5]
{Lead contacts- Kevin McSweeney/Jane Downing; FY'94
activity}
2. Prepare fact sheet for permit writers on what is
important to consider to determine groundwater/drinking
water impacts. (Program) [SA# 3]
{Lead contacts- Kevin McSweeney/Jane Downing; FY'94
activity}
3. Give a basic hydrogeology presentation to permit
writers and Pretreatment program personnel. (Program)
[SA# 4] {Lead contact- Jane Downing/Division Training
Team; FY'95 activity}
III. BARRIER 3 - COORDINATION
1. Examine water quality standards/criteria as potential
permit limits in consideration of drinking
water/groundwater concerns. (Program) [SA# 4]
{Lead contact- Bill Butler; ongoing activity}
2. When deciding where to do inspections or audits for the
NPDES or Pretreatment programs consider proximity to
WHPA and/or SSA, in addition to considering program
compliance and implementation. (Program) [SA# 2]
{Lead contact- Larry Brill; FY'95 activity}
3. Provide information to the Pretreatment staff about
state UIC and Groundwater discharge permit programs and
contacts for possible referrals. Specifically, for
instances where they know of industrial uses in
unsewered areas. (Program) [SA# 5]
{Lead contact- Dave Delaney; FY'94 activity}
4. Examine Regional policies (CSO, Sludge, Toxicity,
Stormwater, Pretreatment) for consistency regarding
groundwater concerns. (Region) [SA# 1]
{Lead contact- Kevin McSweeney; 1QFY'94 activity}
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IV. BARRIER 4 - GRODNDWATER RESOURCE SOURCE IDENTIFICATION
Examine the potential for groundwater contamination from
Exfiltration in critical groundwater areas. (Program)
[SA# 4]; {Lead contact- Tony Depalma; FY'95 activity}
V. BARRIER 5 - GROUNDWATER ISSUES AWARENESS
Factor groundwater concerns in when developing BMP's as part
of a NPDES permit. (Program) [SA# 4]
{Lead contact- Kevin McSweeney; 1QFY'94}
VI. BARRIER 6 - GRANTS
VII. BARRIER 7 - INSTITUTIONAL
1. Include groundwater considerations when determining if
a discharge is a "major" or a "minor" discharge.
(Program) [SA# 2]
{Lead contact- Kevin McSweeney; ongoing activity}
2. Amend Supplemental Environmental Project guidance to
make it less restrictive and allow for more creative
solutions including pollution prevention and wellhead
protection. (Program) [SA# 4]
{Lead contact- Larry Brill/ORC; FY'95 activity}
VIII.BARRIER 8- OUTREACH/EDUCATION
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COMPREHENSIVE GROUND WATER PROGRAMS - REGIONAL ASSESSMENT
PUBLIC WATER SUPPLY SUPERVISION PROGRAM
RECOMMENDATIONS
I. BARRIER I - RESOURCES
N/A
II. BARRIER 2 - INFORMATION
1. Encourage HQ to include mandatory data fields for
latitude and longitude data into HQ's PWSS modernized
system that will replace FRDS. (Headquarters/Program)
{Lead contact - Bob Mendoza; FY '94/95 activity}
2. Promote with HQ's that latitude and longitude be a
mandatory reporting requirement under future SDWA
regulations. (It is not currently required).
(Headquarters/Program) {Lead contact - Bob Mendoza; FY
•94/95 activity}
3. Promote with HQ's that the new PWSS modernization program
be able to link with CIS systems for integrated data
management. (Headquarters/Program) {Lead contact - Bob
Mendoza; FY '94 activity}
4. Coordinate with state programs to determine whether they
require latitude and longitude of new PWS sources being
approved. Strongly promote with states' programs.
(Program) {Lead contact - Bob Mendoza; FY '94 activity}
5. Promote with RCRA C, GW, SF, and other programs, the
important need for centralized data management or
compatibility of multi-program data integrated data
systems which allow data base access and utilization by
all programs; promote real-time, on-line automated work
stations. (Program/Region) {Lead contact - Bob
Mendoza; FY '94/95 activity}
III. BARRIER 3 - COORDINATION
1. PWSS and GW will seek to establish coordination mechanism
for the source control programs (RCRA C, UST, SF, etc.)
to provide information regarding their facilities and
generators or other threatening activities to PWS wells.
(Program/Region) {Lead contacts - Chris Ryan (PWSS) and
Rob Adier (GWM); FY '94/95 activity}
2. Participate with cross-program teams for identifying
available information and for identifying other
information and data needs. Continue participation on
cross-program state coordinator teams established in the
-------
Water Management Division. (Program/Region) {Lead contact
- Chris Ryan and other PWSS state coordinators; FY '94/95
activity}
3. Exchange guidance between PWSS and GW for review; annual
guidance for s.106 national/Regional ground water, UIC
(national), and PWSS (national/Regional) guidance.
(Program) {Lead contacts - Bob Mendoza (PWSS) and Jane
Downing (GWM); FY '95 activity}
4. Improve coordination between PWSS and GW by exchanging a
staff participant to attend each others section meetings.
(Program) {Lead contacts - Bob Mendoza (PWSS) and Jane
Downing (GWM); FY '94/'95 activity}
5. Coordinate with Regional Counsel to determine the utility
of ORC's enforcement tracking database to prioritize
inspection and state and EPA enforcement in the PWSS
programs. (Program) {Lead contact - Chris Ryan; FY "94/95
activity}
6. Strongly encourage the states' PWSS programs make
available information and latitude and longitude on
public water supplies to their other state programs.
(Program) {Lead contact - Bob Mendoza; FY '94/'95
activity}
7. Promote with states' PWSS programs the utility of sharing
findings of sanitary surveys (conducted by the state and
Region I) with local Boards of Health, or other local
boards. (Program) {Lead contact - Bob Mendoza; FY
•94/'95 activity}
8. Continue to encourage, through grant guidance and
conditions, state programs participate in the states'
ground water coordination mechanisms, and support the
states' ground water programs in developing and
implementing states' CSGWPPs. (Program) {Lead contact -
Chris Ryan; FY '94/95 activity}
IV. BARRIER 4 - GROUND WATER RESOURCE IDENTIFICATION
N/A
V. BARRIER 5 - GROUND WATER ISSUES AWARENESS
N/A
VI. BARRIER 6 - GRANTS
N/A
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VIZ. BARRIER 7 - INSTITUTIONAL
1. Within the context of SDWA reauthorization, will continue
to promote need for and likelihood that small and medium
systems should demonstrate their ability to comply with
the SDWA requirements, including planning and prevention
activities for source water protection.
(Headquarters/Program) {Lead contact - Bob Mendoza; FY
•94/'95 activity}
2. Promote with HQs to develop the PWS modernization system
with the capability of providing system upgrades (for
state PWSS data systems) as new regulations are issued.
(Headquarters/Program) {Lead contact - Chris Ryan; FY
'94/95 activity}
VIII. BARRIER 8 - OUTREACH / EDUCATIONAL
N/A
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COMPREHENSIVE GROUND WATER PROGRAM - REGIONAL ASSESSMENT
STORMWATER (NPDES) PROGRAM
FINAL RECOMMENDATIONS
I. BARRIER 1 - RESOURCES
Provide resources and tools that can support program
priority setting and pollution prevention that supports
broad resource protection. (Region/Program) [SA 2; 3; 4]
{Lead contact- Kevin McSweeney}
II. BARRIER 2 - INFORMATION
1. Require quality longitude and latitude data for major
facilities regulated by EPA. (Region/Program) [SA 2;
4; 5] {Lead contact- Ronnie Harrington; FY'95
activity}
2. Improve the quality, availability and on-line
accessibility of PCS data to program and others.
(Headquarters/Region/Program) [SA 2; 3; 5]
{Lead contact- Ronnie Harrington; FY'95 activity}
3. Encourage EPA and state programs to adopt EPA's minimum
set of data elements to facilitate cross program data
utility and sharing. (Region/Program) [SA 5]
{Lead contact- Ronnie Harrington; FY'95 activity}
4. Provide on-line work station access to GIS tools that
can display critical resources and program activity to
support program decisions. (Region) [SA 2; 4; 5]
{Lead contact- Ronnie Harrington; FY'94 activity}
III. BARRIER 3 - COORDINATION
1. Encourage discussion of CSGWPP with federal and state
programs. [SA 1; 3]
{Lead contact- Kevin McSweeney; FY'94 activity}
2. Establish a coordination mechanism within the Region
and with the states that support efforts to prioritize
activities. [SA 2; 4]
{Lead contact- Steve Silva; FY'94 activity}
3. Promote state cooperation with state ground water
program and encourage communication of ground water
resource protection priorities and strategies. [SA
2; 3] {Lead contact- Kevin McSweeney; FY'94 activity}
IV. BARRIER 4 - GROUND WATER RESOURCE SOURCE IDENTIFICATION
1. Provide cross-program education about the types and
-------
sources of resource information that can support
program activity. (Region/Program) [SA 2; 5]
{Lead contact- Jane Downing/Division Training Team;
FY'95 activity}
2. Encourage formal EPA identification of critical
resources that can be used by EPA and state programs to
better direct program activity that will result in
resource protection. (Region/Program) [SA 4]
{Lead contact- Steve Silva; FY'94 activity}
V. BARRIER 5 - GW ISSUES AWARENESS
l. Continue interprogram communication about CSGWPP and
ground water protection. [SA 1; 2; 6]
{Lead contact- Kevin McSweeney; FY'94 activity}
2. Participate in improved communication between EPA
programs to facilitate identification of program issues
impacting ground water. [SA 4]
{Lead contact- Kevin McSweeney; FY'94 activity}
3. Improve CSGWPP education outreach within program and to
state program. [SA 4]
{Lead contact- Kevin McSweeney; FY'94 activity}
VI. BARRIER 6 - GRANTS
Consider grant guidance which encourages states to improve
their collection, management and use of latitude and
longitude to locate regulated facilities. (Region/Program)
[SA 3; 4; 5]
{Lead contact- Bill Nuzzo; FY'95 activity}
VII. BARRIER 7 - INSTITUTIONAL
1. Support program consideration of a broad spectrum of
resources when setting priorities. [SA 2]
{Lead contact- Steve Silva; FY'94 activity}
2. Develop formal standardized approach to prioritizing
program activity that supports water supply and ground
water protection. [SA 2]
{Lead contact- Larry Brill; FY'95 activity}
3. Support development of technical ability to use ground
water resource characterization to prioritize program
activities. (Region) [SA 2; 4]
4. Support greater consideration of ground water
protection through discussion within EPA and with
states, local and other appropriate federal agencies.
[SA 3] {Lead contact- Kevin McSweeney; FY'94 activity}
-------
5. Promote use of GIS tools to support program
prioritization processes. (Region/Program) [SA 2;4]
{Lead contact- Kevin McSweeney; FY'94 activity}
6. Institute formal process for considering ground water
protection into permits. [SA 4]
{Lead contact- Kevin McSweeney; 2QFY'94 activity}
7. Formalize introduction of CSGWPP into regional guidance
to states. [SA 1; 3; 4; 5]
{Lead contact- Bill Nuzzo; ongoing activity}
VIII.BARRIER 8 - OUTREACH/EDUCATION
1. Encourage inclusion of CSGWPP and WHP information in
program outreach efforts to states and permittees.
[SA 4] {Lead contact- Kevin McSweeney; FY'94 activity}
2. Use inspection opportunities to provide education and
outreach materials to permittees describing Pollution
Prevention, BMPs, and ground water protection.
[SA 5; 6] {Lead contact- Tony Depalma; FY'95 activity}
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COMPREHENSIVE GROUND WATER PROGRAM - REGIONAL ASSESSMENT
UNDERGROUND INJECTION CONTROL (UIC) PROGRAM
FINAL RECOMMENDATIONS
I. BARRIER 1 - RESOURCES
Encourage EPA/HQ to change Class V funding formulas for
calculating allocations to states that will increase
resources available to protect water supplies.
(Headquarters/Region/Program) [SA 1; 2; 4]
{Lead contact- Dave Delaney; FY'94 activity}
II. BARRIER 2 - INFORMATION
1. Encourage states to include appropriate quality
latitude and longitude locational data for facilities
with permitted UIC wells. (Region/Program) [SA 2; 4; 5]
{Lead contact- Dave Delaney; FY'94 activity}
2. Encourage states to include a minimum set of data
elements in program information management systems to
facilitate cross-program environmental analysis and
information sharing that can support comprehensive
resource protection. (Region/Program) [SA 5]
{Lead contact- Dave Delaney; FY'94 activity}
3. Encourage states to use automated information
management systems to manage permitted UIC activity.
[SA 2; 3; 5]
{Lead contact- Dave Delaney; FY'94 activity}
4. Encourage states to enhance program information and
information management systems so that they can support
comprehensive resource protection. [SA 2; 3; 5]
{Lead contact- Dave Delaney; FY'94 activity}
5. Encourage states to make program information more
accessible to local governments and organizations
directing resource protection. [SA 2; 3; 5]
{Lead contact- Dave Delaney; FY'94 activity}
6. Encourage EPA to improve availability, accessibility
and quality of EPA information and information
management systems sufficiently to support broad cross
program use by state, EPA and local programs to protect
environmental resources. (Headquarters/Region/Program)
[SA 2; 3; 5]
{Lead contact- Dave Delaney; FY'94 activity}
III. BARRIER 3 - COORDINATION
-------
1. Increase coordination of program activity with Federal
Facility program. [SA 1; 3]
{Lead contact- Dave Delaney; FY'94 activity}
2. Encourage state program to participate in state
multimedia inspection processes and to increase efforts
to inform state inspectors about UIC issues. [SA 3; 4]
{Lead contact- Dave Delaney; FY'94 activity}
3. Encourage EPA/HQ to promote more inter-Regional
transfer of information regarding pollution prevention,
BMPs, and outreach educational materials appropriate to
UIC and related programs. (Headquarters/Region/Program)
[SA 3] {Lead contact- Dave Delaney; FY'94 activity}
IV. BARRIER 4 - GROUND WATER RESOURCE SOURCE IDENTIFICATION
Encourage formal EPA identification of critical resources
that can be used by EPA and state programs to better direct
program activity that will result in resource protection.
(Region/Program) [SA 4]
{Lead contact- Dave Delaney; FY'94 activity}
V. BARRIER 5 - GROUND WATER ISSUES AWARENESS
Improve communication within EPA and with states to ensure
better transfer of information about pollution prevention,
BMPs, technology transfer that will increase resource
protection. (Region/Program) [SA 2; 4; 6]
{Lead contact- Dave Delaney; FY'94 activity}
VI. BARRIER 7 - INSTITUTIONAL
Formalize inclusion of CSGWPP reference in UIC grant
guidance. [SA 1; 3; 4; 5]
{Lead contact- Dave Delaney; FY'94 activity}
VII. BARRIER 8 - OUTREACH/EDUCATION
1. Encourage inclusion of CSGWPP and WHP information in
program outreach efforts to states and permittees.
[SA 4] {Lead contact- Dave Delaney; FY'94 activity}
2. Use inspection opportunities to provide education and
outreach materials to permittees describing Pollution
Prevention, BMPs, and ground water protection.
[SA 5; 6] {Lead contact- Dave Delaney; FY'94 activity}
3. Encourage more extensive outreach targeting to state,
local and private organizations that can support
implementation of BMPs, bylaws, permits and pollution
prevention that can support more comprehensive resource
protection. (Region/Program) [SA 3]
{Lead contact- Dave Delaney; FY'94 activity}
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COMPREHENSIVE GROUND WATER PROGRAM - REGIONAL ASSESSMENT
WATER QUALITY MANAGEMENT SECTION
FINAL RECOMMENDATIONS
I. BARRIER 1 - RESOURCES
II. BARRIER 2 - INFORMATION
III. BARRIER 3 - COORDINATION
1. Provide better communication of cross-program needs. The
GWMS staff should be more aware of my Program's
activities and vice versa. Education of our respective
staffs will help open channels of communication.
{Lead contact- Dave Turin; FY'94 activity}
2. The GWMS should coordinate Technical Impracticability
proposals and issues between my Program and the Waste
Management Division for CERCLA/RCRA sites that currently
impact or will impact surface-water quality.
{Lead contacts- Dave Turin/Doug Heath; FY'94 activity}
3. GWMS staff should work with the TMDL staff and
investigate opportunities to control those sources.
{Lead contacts- Dave Turin/Doug Heath; FY'94 activity}
IV. BARRIER 4 - GROUND WATER RESOURCE IDENTIFICATION
V. BARRIER 5 - GROUND WATER ISSUES AWARENESS
The Program can better support State efforts in protecting
ground water resources by improved communications at the
EPA/State level through the CSGWPP process.
{Lead contact- Dave Turin; FY'94 activity}
VI. BARRIER 6 - GRANTS
VII. BARRIER 7 - INSTITUTIONAL
VIII.BARRIER 8 - OUTREACH/EDUCATION
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COMPREHENSIVE GROUND WATER PROGRAM - REGIONAL ASSESSMENT
WETLANDS PROGRAM
FINAL RECOMMENDATIONS
I. BARRIER 1 - RESOURCES
N/A
II. BARRIER 2 - INFORMATION
N/A
III. BARRIER 3 - COORDINATION
1. Provide New England State Sole Source Aquifer (SSA) and
Wellhead Protection Area (WHPA) maps to Region I
Wetlands program to assist in identification of
wetlands projects with potential for adverse impact to
ground water (GWMS) [SA 3].
{Lead contacts- Ralph Abele/John Haederle; FY'94
activity}
2. Encourage State Drinking Water and Wetlands programs to
consider impacts of new water supply wells on wetlands
ecosystems (Region/State) [SA 3].
{Lead contact- Ralph Abele; FY'94 activity}
IV. BARRIER 4 - GROUND WATER RESOURCE IDENTIFICATION
N/A
V. BARRIER 5 - GROUND WATER ISSUES AWARENESS
N/A
VI. BARRIER 6 - GRANTS
1. Integrate ground water issues into grants guidance to
states (HQ/Region) [SA 4,lw].
VII. BARRIER 7 - INSTITUTIONAL
N/A
VIII.BARRIER 8 - OUTREACH/EDUCATION
1. Coordinate EPA and U.S. Army Corps of Engineers public
education and outreach efforts relative to ground water
issues (HQ/Region) [SA 4,lw].
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COMPREHENSIVE GROUND WATER PROGRAM - REGIONAL ASSESSMENT
INFORMATION MANAGEMENT PROGRAM
FINAL RECOMMENDATIONS
I. BARRIER 1 - RESOURCES
1. Provide adequate resources (Region) and support
activities (Program) to assure continued
program participation in efforts to protect ground
water resources. (Region)(Program) [SA2;3]
{Lead contact- Chris Diehl; FY'94 activity}
2. Provide sufficient resources (Region) and support
activities (Program) to increase the availability,
assessability and quality of information in EPA
information management systems. (Region/Headquarters)
(Program) [SA2;3;5]
{Lead contact- Chris Diehl; FY'94 activity}
3. Provide adequate resources (Region) and support
activities (Program) to support enhancement of EPA
information and information management systems so that
they can more effectively support resource protection.
(Region/Headquarters) (Program) [SA3;5]
{Lead contact- Chris Diehl; FY'94 activity}
4. Provide resources (Region) and support activities
(Program) to determine EPA program information and
information system needs to support prioritization
activities necessary for comprehensive resource
protection. (Region)(Program) [SA3]
{Lead contact- Chris Diehl; FY'94 activity}
II. BARRIER 2 - INFORMATION
1. Facilitate Identification of EPA programs' information
and information system needs that can support
prioritization of program activity to protect
resources. (Region) (Program) [SA2]
{Lead contact- Chris Diehl; FY'94 activity}
2. Facilitate Identification of information that EPA
programs need to characterize and assess the threat of
contaminants and regulated activity to environmental
resources. (Region) (Program) [SA2]
{Lead contact- Chris Diehl; FY'94 activity}
3. Improve accessibility, availability, and quality of
information that programs can use to prioritized
program activity and that will support efficient,
-------
comprehensive EPA and State protection of environmental
resources. (Region/Headquarters) (Program) [SA2;4;5]
{Lead contact- Chris Diehl; FY'94 activity}
4. Promote acquisition of quality, appropriate latitude
and longitude locational data for all EPA regulated
facilities. (Region)(Program) [SA2;4]
{Lead contact- Greg Charest; FY'94 activity}
5. Provide information and encourage EPA and State
programs to use a minimum set of data elements in data
management systems to facilitate efficient data
sharing, cross program analysis and comprehensive
environmental resource protection. (Region)(Program)
[SA5] {Lead contact- Chris Diehl; FY'94 activity}
6. Facilitate identification of ways that EPA information
and information management systems can better support
State and EPA efforts to consider environmental
vulnerability and value when making program decisions.
(Region)(Program) [SA3;4]
{Lead contact- Chris Diehl; FY'94 activity}
7. Facilitate Determination of whether there are
information management issues related to acquisition,
management, use of EPA and State monitoring data that
make these data difficult to use to support
comprehensive protection of water resources.
(Region)(Program) [SA5]
{Lead contact- Chris Diehl; FY'94 activity}
III. BARRIER 3 - COORDINATION
1. Promote EPA, State and interstate dialogue on mutual
uses of information to protect environmental resources.
(Region)(Program) [SA3]
{Lead contacts- Chris Diehl/Greg Charest; FY'94
activity}
2. Promote increased access and information exchange
between federal agencies. [SA3]
{Lead contact- Chris Diehl; FY'94 activity}
3. Promote regional program support to enhance EPA
information and information management systems that
will result in their broader use to protect the
environment and resources. [SA3]
{Lead contact- Chris Diehl; FY'94 activity}
IV. BARRIER 4 - GROUND WATER RESOURCE IDENTIFICATION
1. Facilitate Identification of resource related
-------
information needed by programs to make environmental
decisions that will result in better resource
protection. (Region)(Program) [SA2;4]
{Lead contact- Chris Diehl; FY'94 activity}
2. Facilitate Identification of EPA programs' need for
contaminant source and regulated activity data
necessary to prioritized program activity that can
result in resource protection. (Region)(Program) [SA2]
{Lead contact- Chris Diehl; FY'94 activity}
3. Facilitate Determination of EPA programs' need for
information from State and federal agencies that can
support resource protection. (Region)(Program) [SA5]
{Lead contact- Chris Diehl; FY'94 activity}
V. BARRIER 5 - GROUND WATER ISSUE AWARENESS
Encourage discussion with States and within EPA
about the importance of information and information
management to CSGWPP. (Region) (Program) [SA1;2;6]
{Lead contact- Chris Diehl; Fy'94 activity}
VII. BARRIER 7 - INSTITUTIONAL ISSUES
Promote discussion about use of EPA information to support
prioritization of program activity. (Region) [SA2]
VIII. BARRIER - 8 EDUCATION/OUTREACH
1. Facilitate Identification of ways to enhance public
access to EPA information related to pollution
prevention, environmental resources, sources of
contamination and regulated activity that place the
environment at risk and to environmental monitoring
data that can support State and local resource
protection. (Region) [SA6]
2. Facilitate identification of EPA information that local
governments need access to that can support their
resource protection efforts. (Region) [SA6]
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COMPREHENSIVE GROUND WATER PROGRAM - REGIONAL ASSESSMENT
POLLUTION PREVENTION (P2)
FINAL RECOMMENDATIONS
I. BARRIER 3 - COORDINATION
1. Re-evaluate P2 Program Managers' roles on Region's CSGWPP
committees. The Region's P2 Coordinators should consult
with the CSGWPP committee on specific issues rather than
as regular participants. (Program) [SA 2]
{Lead contact- Abby Swaine; ongoing activity}
2. Continue participation by the Ground Water Management
Section on Region I Pollution Prevention Task Force
(P2TF) as support to lead P2TF Water representative to
maintain communication and ensure integration. (GWMS)
[SA 2; 3} {Lead contact- Michele Notarianni; ongoing
activity}
II. BARRIER 4 - GROUND WATER RESOURCE & SOURCE IDENTIFICATION
Decide whether geographic targeting within critical water
resource areas makes sense for Region I Pollution Prevention
Incentives for States (PPIS) grants and P2 AC&C funds, with
close consultation of P2 Program Managers and Water Lead on
P2TF. (Region) [SA 1; 2]
{Lead contact- Mark Mahoney; 2&3QFY'94 activity}
III. BARRIER 5 - GROUND WATER ISSUES AWARENESS
Present emerging issues and concerns related to ground water
in a P2 forum, highlighting documented threats to ground water
and the importance and role of P2 in ground water protection.
(Program) [SA 1; 3]
{Lead contacts- Mark Mahoney/Abby Swaine; ongoing activity}
IV. BARRIER 7 - INSTITUTIONAL
Clarify what specific components of resource protection
activities are P2 by Region I's interpretation to assist both
EPA and States with identification and implementation of P2
activities. (Program) [SA 2; 3]
{Lead contacts- Mark Mahoney/Abby Swaine; 1QFY'94 activity}
V. BARRIER 8 - OUTREACH/EDUCATION
Coordinate development and distribution of related ground
water and P2 outreach materials, based on identified needs, to
address requests for P2 information by state ground water
managers and local officials. (Program) [SA 1: 6]
{Lead contact- Abby Swaine; ongoing activity}
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COMPREHENSIVE GROUND WATER PROGRAM - REGIONAL ASSESSMENT
PESTICIDES PROGRAM
FINAL RECOMMENDATIONS
I. BARRIER 1 - RESOURCES
1. Provide additional resources to influence the states in
program development and implementation (e.g.,
collection of baseline and targeted monitoring
activities) consistent with CSGWPP, since the
components of the Pesticides Program which result in
ground water protection are largely implemented by the
Region I states. Responsible: Region I. Source; SA#5.
2. Provide additional resources to the Region I Pesticides
Program to support Regional CSGWPP activities.
Responsible: Region I. Source: SA#3.
II. BARRIER 2 - INFORMATION
Increase the availability and use of GPS to obtain latitude
and longitude data. Responsible: Headquarters/Region I.
Source: SA#4.
III. BARRIER 3 - COORDINATION
Improve support and coordination between Pesticides Program
. and Nonpoint Source, Bays/Near Coastal, and Public Water
Supply Programs. Responsible; Ground Water Management
Section/Pesticides Program. Source: SA#4. {Lead contact-
Rob Koethe; FY'94 activity}
IV. BARRIER 4 - GROUND WATER RESOURCE IDENTIFICATION
No recommendations developed.
V. BARRIER 5 - GROUND WATER ISSUES AWARENESS
Improve awareness of state wellhead protection programs by
state pesticides program. Responsible; Ground Water
Management Section/Pesticides Program. Source; SA#4.
{Lead contact- Rob Kpethe; FY'94 activity}
-------
VI. BARRIER 6 - GRANTS
Search for opportunities to improve timing with other grant
program(s) in order to improve coordination of mid-year and
end-of-year reviews. Responsible: Headquarters/Region I.
Source; SA#4.
VII. BARRIER 7 - INSTITUTIONAL
Create a mechanism for review of and concurrence with
Generic Pesticide State Management Plans or review and
approval of Pesticide-Specific State Management Plans.
Ideally, this organization would be separate from the Region
I Ground Water Policy Committee, but would regularly brief
the Policy Committee on activities related to
review/concurrence/approval. Responsible; Region I.
Source; SA#2.
{Lead contact- Rob Koethe; FY'94 activity}
VIII.BARRIER 8 - OUTREACH/EDUCATION
No recommendations developed.
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Appendix E
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COMPREHENSIVE GROUND WATER PROGRAM - REGIONAL ASSESSMENT
LIST OF HEADQUARTERS RECOMMENDATIONS
I. WASTE MANAGEMENT DIVISION
A. RESOURCE CONSERVATION AND RECOVERY ACT - C (RCRA C)
BARRIER 7 - INSTITUTIONAL
1. Improve NCAPS - RCRA C corrective action priority
methodology calculation to include additional resource
based factors; and/or improve Environmental Benefits
Review for considerations GW and water resource
factors. (Headquarters/Program) [SA 2] {Lead contact -
Frank Battaglia, Ernie Waterman; FY '95}
2. Initiate defining "use" and "value" as related to the
program, and participate with other programs to arrive
at consistent definitions; related to setting
corrective action clean-up limits and priority setting
(under NCAPS). Identify the type of information needed
for their determination, and cooperatively initiate
data collection. (Program) (Headquarters/ Region)
[SA 2,4] {Lead contact - Frank Battaglia; FY '95}
3. Promote with state programs to require accurate and
certified (by engineer, surveyor, etc.)
latitude/longitude locational information (one second
accuracy). Make appropriate changes in the instructions
for filing the forms. (Headquarters/Program) [SA 5]
{Lead contact - Frank Battaglia; FY 95}
4. Promote institutionalizing collection of accurate
latitude/longitude in service industries such as
banking, insurance, realtors and mortgage industries.
(Headquarters/Region/Program) [SA 4;5] {Lead contact -
Frank Battaglia; FY '94/95}
B. SUPERFUND PROGRAM
BARRIER 3 - COORDINATION
Provide specific vision/direction, funding and encouragement
to the regions, to support and incorporate comprehensive
ground water planning into programs' activities and
priorities. (Headquarters) [SA 1]
BARRIER 5 - GROUND WATER ISSUES AWARENESS
1. Encourage the consistent incorporation of the new
comprehensive approach into agency operating guidance
-------
and strategic planning. (Headquarters/Program) [SA 3]
{Lead contact- Dennis Huebner; ongoing activity}
2. Clearly articulate what EPA expects the states to do in
support of CSGWPP across all programs and what regional
and national programs are doing to remove barriers,
including changes in statutes and guidances where
necessary. (Headquarters/Region/Program) [SA 4; 6]
{Lead contact- Dennis Huebner; ongoing activity}
BARRIER 7 - INSTITUTIONAL
1. CERCLA/NCP specify methods for determining cleanup
approaches which may restrict flexibility in promoting
a state directed resource-based approach to
remediation. During reauthorization of CERCLA,
national programs should recommend changes for
consistency with CSGWPP Guidance. Such changes may
include deletion of reference to federal ground water
classification system (in deference to state
classifications), and clarification for preference for
rapid restoration where warranted based on the use and
value of the resource. (Headquarters/Program) [SA 4]
{Lead contact- Dennis Huebner; FY'94 activity}
2. Encourage creative use of Supplemental Environmental
Projects (SEPs) in settlement of Superfund liabilities.
For example, can we get PRPs to finance local Wellhead
Protection Programs in areas in close proximity to the
sites? The outcome of such efforts would be to further
protect the existing water supplies so that the need
for additional sources, including ground water at the
site, shall be minimized. By financing local prevention
activities, PRPs would be providing the regulatory
agencies greater comfort in allowing less aggressive
approaches, including technical impracticability
waivers, while minimizing their potential future
liability. (Headquarters/Region/Program) [SA 4]
{Lead contact- Ira Leighton; ongoing activity}
C. UNDERGROUND STORAGE TANK (UST) PROGRAM
BARRIER 1 - RESOURCES
Increase resources to UST program for increased leak
detection activities and for obtaining GPS locational data
(HQ/Region/state). [SA 2, SA 4,4b].
{Lead contact- Myra Schwartz; FY'94 activity}
BARRIER 7 - INSTITUTIONAL
Evaluate the desirability of increased information sharing
with states on health-based risk issues relating to heating
-------
oil petroleum spills, and whether state standards are the
most appropriate and effective means of ensuring the
protection of public health (HQ/Region/state) [SA 3,2h].
{Lead contact- Myra Schwartz; FY'94 activity}
II. WATER MANAGEMENT DIVISION
A. PUBLIC WATER SUPPLY SUPERVISION PROGRAM
BARRIER 2 - INFORMATION
1. Encourage HQ to include mandatory data fields for
latitude and longitude data into HQ's PWSS modernized
system that will replace FRDS. (Headquarters/Program)
{Lead contact - Bob Mendoza; FY '94/95 activity}
2. Promote with HQ's that latitude and longitude be a
mandatory reporting requirement under future SDWA
regulations. (It is not currently required).
(Headquarters/Program) {Lead contact - Bob Mendoza; FY
'94/95 activity}
3. Promote with HQ's that the new PWSS modernization
program be able to link with GIS systems for integrated
data management. (Headquarters/Program) {Lead contact
- Bob Mendoza; FY '94 activity}
BARRIER 3 - COORDINATION
Exchange guidance between PWSS and GW for review; annual
guidance for s.106 national/Regional ground water, UIC
(national), and PWSS (national/Regional) guidance. (Program)
{Lead contacts - Bob Mendoza (PWSS) and Jane Downing (GWM);
FY '95 activity}
BARRIER 7 - INSTITUTIONAL
1. Within the context of SDWA reauthorization, will
continue to promote need for and likelihood that small
and medium systems should demonstrate their ability to
comply with the SDWA requirements, including planning
and prevention activities for source water protection.
(Headquarters/Program) {Lead contact - Bob Mendoza; FY
'94/'95 activity}
2. Promote with HQs to develop the PWS modernization
system with the capability of providing system upgrades
(for state PWSS data systems) as new regulations are
issued. (Headquarters/Program) {Lead contact - Chris
Ryan; FY '94/95 activity}
-------
B. STORMWATER (NPDES) PROGRAM
BARRIER 2 - INFORMATION
Improve the quality, availability and on-line accessibility
of PCS data to program and others.
(Headquarters/Region/Program) [SA2; 3; 5]
{Lead contact- Ronnie Harrington; FY'95 activity}
C. WETLANDS PROGRAM
BARRIER 6 - GRANTS
Integrate ground water issues into grants guidance to states
(HQ/Region) [SA4,lw].
BARRIER 8 - OUTREACH/EDUCATION
Coordinate EPA and U.S. Army Corps of Engineers public
education and outreach efforts relative to ground water
issues (HQ/Region) [SA 4,lw].
D. UNDERGROUND INJECTION CONTROL (UIC) PROGRAM
BARRIER 1 - RESOURCES
Encourage EPA/HQ to change Class V funding formulas for
calculating allocations to states that will increase
resources available to protect water supplies.
(Headquarters/Region/Program) [SA 1; 2; 4]
{Lead contact- Dave Delaney; FY'94 activity}
BARRIER 2 - INFORMATION
Encourage EPA to improve availability, accessibility and
quality of EPA information and information management
systems sufficiently to support broad cross program use by
state, EPA and local programs to protect environmental
resources. (Headquarters/Region/Program)
[SA 2; 3; 5] {Lead contact- Dave Delaney; FY'94 activity}
BARRIER 3 - COORDINATION
Encourage EPA/HQ to promote more inter-Regional transfer of
information regarding pollution prevention, BMPs, and
outreach educational materials appropriate to UIC and
related programs. (Headquarters/Region/Program)
[SA 3] {Lead contact- Dave Delaney; FY'94 activity}
III. AIR MANAGEMENT DIVISION
-------
A. PESTICIDES PROGRAM
BARRIER 2 - INFORMATION
Increase the availability and use of GPS to obtain latitude
and longitude data. Responsible; Headquarters/Region I.
Source; SA#4.
BARRIER 6 - GRANTS
Search for opportunities to improve timing with other grant
program(s) in order to improve coordination of mid-year and
end-of-year reviews. Responsible; Headquarters/Region I.
Source; SA#4.
IV. PLANNING AND MANAGEMENT DIVISION
A. INFORMATION MANAGEMENT PROGRAM
BARRIER 1 - RESOURCES
1. Provide sufficient resources (Region) and support
activities (Program) to increase the availability,
assessability and quality of information in EPA
information management systems. (Region/Headquarters)
(Program) [SA2;3;5]
{Lead contact- Chris Diehl; FY'94 activity}
2. Provide adequate resources (Region) and support
activities (Program) to support enhancement of EPA
information and information management systems so that
they can more effectively support resource protection.
(Region/Headquarters) (Program) [SA3;5]
{Lead contact- Chris Diehl; FY'94 activity}
BARRIER 2 - INFORMATION
Improve accessibility, availability, and quality of
information that programs can use to prioritized program
activity and that will support efficient, comprehensive EPA
and State protection of environmental resources.
(Region/Headquarters) (Program) [SA2;4;5]
{Lead contact- Chris Diehl; FY'94 activity}
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