&EPA
United States
Environmental Protection
Agency
Office of
Ground-Water Protection (WH-550G)
Washington DC 20460
March 1985
Planning Workshop to
Develop Recommendations for
a Ground-Water Monitoring
Strategy
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ç O S ,
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
____ WASHINGTON. D.C. 20460
\PRO t 4A j 3 jg
OFFICE OF
WATER
Dear Participant:
Welcome to this workshop to develop a Ground—Water
Monitoring Strategy. A key element in the protection and
cleanup of our nation’s ground—water resources is the
monitoring data upon which our decisions rest. EPP
administers a number of programs which both rely on and
require the conduct of monitoring such as RCRA, Superfund,
Drinking Water and Pesticides. In addition, the Agency uses
monitoring data to anticipate new problems and determine the
extent to which known problems are being addressed. Ground-
water monitoring data is collected and used by a variety of
government agencies at the Federal, State and local levels.
Yet there is a general perception that little data is avail-
able when a decision on ground—water protection must be
made.
This workshop is designed to help EPA step back and
look broadly at the total picture of ground—water monitoring.
We wish to explore with you the purposes for which ground-
water data is needed. We wish your advice on where EPA goes
from here in improving the collection and availability of
ground—water data for its use and for use by others.
Specifically the purpose of the workshop is two fold:
o To examine the issues of ground—water monitor-
ing relating to the need for and methods of
obtaining ground—water monitoring and related
data with a diverse group of experts represent-
ing government, the regulated community,
environmentalists, universities, consultants,
and others: and
o To recommend for consideration by EPA policy—
makers a strategy for improving the acquisition,
use, and availability of ground—water monitoring
information.
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Further elaboration of the workshop scope and purpose
is provided in Chapter 1.
To the end of fulfilling these purposes, we’ve invited
many knowledgeable people to attend and participate in the
workshop. Each of you will play an important role in help-
ing EPA develop an effective and workable approach to ground-
water monitoring that protects that resource and provides
that data necessary to support those decisions. All the EPA
representatives here are anxious to listen to your views.
I can assure you that the workshop results will play an
important role in helping EPA formulate its Ground—Water
Monitoring Strategy.
Again, welcome, and best wishes for a productive
wor kshop.
Sincerely,
Jack E. avan
Assistant Administrator
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This document was compiled by:
U.S. Environmental Protection Agency
Office of Ground-Water Protection
Marian Mlay, Director
Dr. Norbert Dee, Senior Scientist
with assistance from:
Office of Ground-Water Protection
Ground-Water Monitoring Work Group
and
Temple, Barker & Sloane, Inc.
under contract no. 68-01-7002
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GROUND-WATER MONITORING WORKSHOP
Ramada Inn — Seminary Road
Alexandria, Virginia
April 8-11, 1985
Agenda
April8
6:00 p.m. Reception
7:00 Dinner/Welcome/Orientation
April 9
8:30 — 9:30 a.m. Plenary Session I
Discussion: Objectives
9:30 — 12:00 Work Groups: Introductions and Selection of Key Objectives
12:00 — 1:30 p.m. Lunch
1:30 — 2:30 Plenary Session II
Group Presentations on Objectives
Discussion: Monitoring Approaches to Achieve the Objectives
2:30— 4:30 Work Groups: Discussion on Monitoring Approaches for
Selected Objectives
4:30—5:30 Plenary Session Ill
Group Presentations on Monitoring Approaches to Achieve
Key Objectives
Discussion: All Objectives and Monitoring Approaches
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April 10
8:30 — 10:30 a.m. Work Groups: Discussion on Monitoring Approaches for
All Objectives
10:30 — 11:30 Plenary Session IV
Group Presentations on Monitoring Approaches
Discussion: Roles of Federal, State, and Local Governments
and Others
11:30 — 1:00 p.m. Lunch
1:00 — 3:00 Work Groups: Discussion on Roles
3:00 — 4:00 Plenary Session V
Group Presentations on Roles
Discussion: Integration of Recommendations for Ground-Water
Monitoring Strategy
4:00 — 5:30 Work Groups: Integration of Recommendations
April 11
8:30—9:30 am. Work Groups: Integration of Recommendations
9:30— 12:30 p.m. Plenary Session VI
Group Presentations on Integrated Recommendations for
Ground-Water Monitoring Strategy
12:30 Adjournment
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Attendees of Workshop
to Develop Recoianendations for a
Ground—Water Monitoring Strategy
(as of March 11, 1985)
Mr. Michael Annarummo
Supervisor of Permits and
Planning Section
Division of Water Resources
Rhode Island Department of
Envi ronniental Management
Cannon Building, Room 209
75 Davis Street
Providence, Rhode Island 02904
Mr. Dave Baker
National League of Women Voters
1730 M Street, N.W.
Washington, D.C. 20036
Mr. Walt Barbour, Vice president
Environmental Management, Inc.
3003 Butterfield Road
Oakbrook, Illinois 60521
Mr. Bret Blackwilder
Environmental Policy Institute
21B D Street, S.E.
Washington, D.C. 20003
Ms. Jennie Bridge
New England Interstate Water
Pollution Control
607 Boylston Street
Boston, Massachusetts 02116
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Attendees
Page 2
Dr. Larry Canter
Environmental & Ground Water
Institute
University of Oklahoma
200 Felgar Street, Room 127
Norman, Oklahoma 73019
Dr. Edwin H. Clark, II
Senior Associate
Conservation Foundation
1717 Massachusetts Avenue, N.W.
Suite 300
Washington, D.C. 20036
Mr. Scott Cunningham
Washington Representative
Union Carbide Corporation
1100 15 Street N.W.
Washington, D.C. 20005
Mr. Swep Davis
ETC
do 565 Harwood Road
Harwood, Maryland 20766
Dr. Rodney Defian
Environmental Administration
Ground Water Section
State of Florida
Department of Environmental
Regulation, Room 474
2600 Blair Stone Road
Tallahassee, Florida 32301
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Attendees
Page 3
Mr. Richard H. Dreith
Senior Staff Engineer
Head Office
Environmental Affairs Dept.
Shell Oil Company
One Shell Plaza
Houston, Texas
Mr. Donald A. Duncan, Director
Ground—Water Protection Division
South Carolina Department of Health
and Environmental Control
2600 Bull Street
Columbia, South Carolina 29201
Mr. Alan Egler
Senior Engineer
E.I. Dupont
Engineering Department
Louviers Bldg., Room 13W06
Wilmington, Delaware 19898
Dr. C.W. Fetter
Department of Geology
University of Wisconsin - Oshkosh
Oshkosh, Wisconsin 54901
Mr. William J. Gburek
u.s. Department of Agriculture
Agricultural Research Service
Northeast Watershed Research Center
110 Research Building A
University Park, Pennsylvania 16
Ms. Mary Gearhart
Colorado Department of Health
Water Quality Control Division
4210 East 11th Avenue
Denver, Colorado
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Attendees
Page 4
Mr. James P. Gibb
Bead, Ground Water Section
State Water Survey Division
Illinois Department of Energy
and Natural Resources
605 East Springfield Avenue
P.O. Box 5050, Station A
Champaign, Illinois 61820—9050
Mr. Clint Ball, Director
Robert S. Kerr Environmental
Research Laboratory
P.O. Box 1198
Ada, Oklahoma 74820
Ms. Maurine Hinkel
National Audubon Society
645 Pennsylvania Avenue, S.E.
Washington, D.C. 20003
Mr. William S. Hood, Jr.
Ashland Chemical company
P.O. Box 2219
Columbus, Ohio 43216
Mr. Steve Howards
National Wildlife Federation
1412 16th Street, N.W.
Washington, D.C. 20036
Dr. John Impson
Assistant Commissioner
Louisiana Department of
Agriculture
Box 44153
Baton Rouge, Louisiana 70804
Mr. Charles Kauffman, Jr.
Public Health Coordinator
Ocean County Health Department
CN 2191
Toms River, New Jersey 08754
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Attendees
Page 5
Ms. Susan Keith
State of Arizona
Division of Environmental
Health Services
1740 West Adams Street
Phoenix, Arizona 85007
Mr. Kevin Kessler
Wisconsin Department of Natural
Resources
Bureau of Water Resource Management
Box 7921
Madison, Wisconsin 53707
Dr. Tommy Knowles
Director of Data and Engineering
Services Division
Texas Department of Water Resources
P.O. Box 13807
Austin, Texas 78711
Mr. Daniel F. Kriege
Manager, Operations & Maintenance
Santa Clara Valley Water District
5750 Alamaden Expressway
San Jose, California 95118
Mr. William Kucharski
Manager of Environmental
Engineering
Environmental Services
Pacific Power & Light Co.
920 South West 6th Avenue
Portland, Oregon 97204
Dr. William T. Lawhon, President
International Growers, Inc.
P.O. Box 474
1989 Samada Drive
Worthington, Ohio 43085—0474
Mr. Harry LeGrand
331 Yadkin Drive
Raleigh, North Carolina 27609
Ms. Nancy Lopez
Assistant Chief
Office of Water Data Coordination
U.S. Geological Survey
417 National Center
Reston, Virginia 22092
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Attendees
Page 6
Dr. Thomas Maddock III
Department of Hydrology and
Water Resources
University of Arizona
Tucson, Arizona 85721
Mr. Jack M. McMillian
Director, Division of Solid Waste
Mississippi Bureau of Pollution
Control
P.O. Box 10385
Jackson, Mississippi 39209
Mr. Al Murrey, Chief
Water Quality Bureau
Idaho Department of Health
Boise, Idaho 83720
Mr. Thomas J. Nicholson
U.S. Nuclear Regulatory
Commission
Earth Sciences Branch
Mail Stop 1130 SS
Office of Nuclear Regulatory
Research
Washington, DC 20555
Mr. James E. Norris
Environmental Associate
CIBA-GEIGY
P.O. Box 113
McIntosh, Alabama 36553
Dr. Wade Nutter
School of Forest Resources
University of Georgia
Athens, Georgia 30602
Dr. Ruth Patrick
The National Academy of
Natural Sciences
19th & the Parkway
Philadelphia, Pennsylvania 19103
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Attendees
Page 7
Mr. Harold Reheis
Director
Environmental Protection Division
Department of Natural Resources
270 washington Street, S.W.
Atlanta, Georgia 30334
Dr. Howard Reiquam, Director
Environmental Affairs
El Paso Natural Gas company
P.O. Box 1492
El Paso, Texas 79978
Mr. Arnold Schiffman
New Jersey Department
of Environmental Protection
Water Resources Division
P.O. Box CN 029
Trenton, New Jersey 08625
Ms. Grace Singer
Chief, Community Relations
Hazardous Site Mitigation
Administration
New Jersey Department of
Environmental Protection (CN028)
8 East Hanover Street
Trenton, New Jersey 08625
Mr. Randy Sweet
Sweet Edwards and Associates
P.O. Box 328
Kelso, Washington 98626
Mr. James Tripp
Environmental Defense Fund
444 Park Avenue South
9th Floor
New York, New York 10016
Mr. Lewis B. Walker
Deputy for Environmental, Safety
and Occupational Health
Assistant Secretary of the Army
Pentagon Room 2E-577
Washington, D.C. 20310
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Attendees
Page 8
Dr. James Wallace
Law Engineering Testing Company
2749 Delk Road, S.E.
Marietta, Georgia 30067
Ms. Jackie Warren
Natural Resources Defense Council
122 East 42 Street
New York, New York 10017
Mr. Gary Welch
Vice President, Safety and
Environmental Planning
St. Joe Minerals Corporation
7733 Forsyth Avenue
Suite 500
Clayton, Missouri 63105
Dr. Ira Whitman, President
Princeton Aqua Science
165 Fieldcrest Ave.
CN 7809
Edison, New Jersey 08818
Dr. Doug Yoder, Assistant Director
Dade County Environmental Resource
Management Department
909 S.E. First Avenue
Miami, Florida, 33131
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U.S. Environmental Protection Agency
Off ice of Ground—Water Protection
GROUND-WATER MONITORING WORK GROUP
Mr. Joe DeCola
Region I
Water Supply Branch
Environmental Protection Agency
John F. Kennedy Federal Bldg.
Boston, Massachusetts 02203
Dr. Norbert Dee
Office of Ground—Water Protection
Environmental Protection Agency
WH—550G
401 M Street, S.W.
Washington, D.C. 20460
Mr. Ron Hoffer
Office of Ground—Water Protection
Environmental Protection Agency
WH— 55 OG
401 M Street, S.W.
Washington, D.C. 20460
Mr. Bob Holmes
Office of Research & Development
Environmental Protection Agency
RD 680
401 M Street, S.W.
Washington, D.C. 20460
Mr. Mark Horwitz
Region 5
Office of Ground—Water
Enviromental Protection Agency
5WGTUB
230 S. Dearborn Street
Chicago, Illinois 60604
Ms. Susan Keith
Division of Environmental
Health Services
2005 North Central Avenue
Room 200
Phoenix, Arizona 85004
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Mr. Kevin Kessler
Wisconsin Department of
Natural Resources
Bureau of Water Resource Management
Box 7921
Madison, Wisconsin 53707
Mr. Arnold Kuzmack
Office of Drinking Water
Environmental Protection Agency
WE 550
401 M Street, S.W.
Washington, D.C. 20460
Mr. Robert Landers
Environmental Monitoring Systems
Labo rato ry/ORD
Environmental Protection Agency
P.O. Box 15027
Las Vegas, Nevada 89114
Mr. Phil Lindenstruth
Chief, Client Services Branch
Monitoring and Data Support Division
Environmental Protection Agency
WE 553
401 M Street, S.W.
Washington, D.C. 20460
Ms. Marian Mlay
Director, Office of Ground—Water Protection
Environmental Protection Agency
WE 550G
401 M Street, S.W.
Washington, D.C. 20460
Mr. Bill Mullen
Chief, Ground Water Office
Environmental Protection Agency
Region 10, MS/437
1200 Sixth Street
Seattle, Washington 98101
Mr. Arnold Schiffman
New Jersey Department of
Environmental Protection
Water Resources Division
P.O. Box CN 029
Trenton, New Jersey 08625
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—3—
Mr. Dave Severn
Chief, Exposure Assessment Branch
Office of Pesticides Programs
CM—2 815H
Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Dr. Richard Spear
Environmental Services Branch
Environmental Protection Agency
Raritan Arsenal
Edison, New Jersey 08837
Mr. Lynn Torak
Department of the Interior
U.S. Geological Survey
WGS MS 411
Restofl, Virginia 22092
Mr. Peter Truitt
Management Systems Division
Environmental Systems Branch
Environmental Protection Agency
PM 222 A
401 M Street, S.W.
Washington, D.C. 20460
Mr. Burnell Vincent
RCRA
Environmental Protection Agency
WU 565E
401 M Street, S.W.
Washington, D.C. 20460
Ms. Cheryl Wasserman
Chief, Compliance Policy and
Planning Branch
Environmental Protection Agency
LE 133—B
401 M Street, S.W.
Washington, D.C. 20460
Dr. Charles Whitehurst
Office of Ground—Water Protection
Environmental Protection Agency
WH 550G
401 M Street, S.W.
Washington, D.C. 20460
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CONTENTS
Agenda
List of Workshop Participants
List of Office of Ground-Water Protection Ground-
Water Monitoring Work Group Members
I. Introduction to the Workshop
II. Background on Monitoring
III. WhatisaStrategy?
IV. Objectives to Support the Ground-Water Strategy
V. Monitoring Approaches
VI. Roles and Responsibilities in Support of National
and State Ground-Water Strategies
VII. Integration of Recommendations
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RESOURCE DOCUMENT
(Under Separate Cover)
I. Introduction
II. EPA Guidance on Monitoring
Ill. Federal Ground-Water Monitoring Activities
IV. State Ground-Water Monitoring Activities
V. Case Study: Ground-Water Monitoring in Florida
VI. Case Study: EPA Office of Drinking Water Survey
VII. Ground-Water Resources in the United States
VIII. Costs of Ground-Water Monitoring
IX. Technical Ground-Water Monitoring Issues
X. Office of Technology Assessment: Findings on Ground-Water
Contamination
XI. Selected Bibliography
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I. INTRODUCTION TO THE WORKSHOP
The Office of Ground Water Protection (OGWP) has been estab-
lished as the focus of ground—water policy coordination and plan—
fling for EPA. As such, it assumes a variety of important roles
through which the Agency’s ground—water protection strategy will
be implemented. OGWP is responsible for coordinating EPA ground-
water activities, identifying and directing the development of
ground—water policies and guidelines, enhancing ground—water data
management systems and capabilities, and initiating and conduct-
ing special studies of ground—water contamination, among other
tasks.
Environmental monitoring is an essential part of EPA program
activities——from planning and research to rule making, compliance
and pollution control, and evaluating program effectiveness. In
order to acquire and successfully use information on the broad
range of environmental problems, their causes, their public
health implications, and their potential for control, federal,
state, and local officials must identify the need for and collect
environmental data that relate to these issues. Therefore, the
Deputy Administrator has directed all appropriate EPA offices to
develop environmental monitoring strategies.
The ground—water monitoring strategy is being developed in a
context that is considerably broader than EPA itself. The U.S.
Geological Survey and other federal agencies, as well as many
state and local organizations, are actively involved in ground-
water monitoring. The strategy, therefore, must be broad and
consider the data needs of a wide variety of users of ground-
water monitoring data.
GOAL OF THE WORKSHOP
The purpose of this workshop is to develop recommendations
for a ground—water monitoring strategy for EPA. This strategy
will not only complement the monitoring strategies of other EPA
program offices but will serve as the keystone of the Agency’s
ground—water protection efforts and as a basis for ground—water
program planning and policy coordination within EPA and with the
states.
This strategy will also aim to provide regulatory decision
makers at all levels of government with better information on
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ground water to support their decisions. Toward this end it will
be necessary to consider the following questions:
• Who needs the data?
• For what decisions or purposes are the data needed?
• flow would the data be used?
A full discussion of these questions will be an important part of
the workshop and will be needed to support the choices made by
workshop participants.
A workshop process is being used in order to obtain the best
ideas of the various groups that are affected by, and involved
in, ground—water monitoring. The attendees have been carefully
selected to represent state and local government, public interest
groups, business and industry, technical and academic experts,
and other federal agencies.
The Agency’s Environmental Monitoring Policy Statement (see
Resource Document for the Ground—Water Monitoring Strategy Work-
shop , Chapter II) suggests that some EPA programs have suffered
trom the following: limited coordination, control, or planning
of Agency monitoring activities; uncertain quality of the data
collected; the design of networks and studies that result in data
of limited use; lack of data suitable for trend analyses; diff i—
culty in accessing information; incompatibility of databases; and
limited analysis and use of environmental data for EPA decision
making. To the extent that these problems relate to EPA’s
ground—water programs, it is clear that a ground—water monitoring
strategy is both necessary and appropriate at this time. A moni-
toring strategy will help formalize the Agency’s approach to
ground—water management by identifying and avoiding duplication
of ground-water monitoring strategies and by coordinating common
elements of EPA’s ground—water programs.
THE APPROACH TO DATE
OGWP circulated a draft ground—water monitoring issues paper
in June 1984 for review and comment by EPA headquarters and re-
gional office staff. This paper identified key ground-water
monitoring issues and problems that must be addressed by a moni-
toring strategy. Reviewers’ comments were incorporated into a
revised paper that was distributed to an EPA Work Group on
ground—water monitoring. This group was organized to assist OGWP
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with the development of a ground—water monitoring strategy and
consisted of representatives of state governments, regional EPA
offices, other federal agencies, and other offices within EPA.
The ground—water workshop represents the culmination of this
planning by the EPA Work Group and OGWP. It is intended to in-
corporate wide opinion on ground—water monitoring and carry the
strategy development process beyond EPA to include a diverse
community of monitoring experts.
THE PLAN OF THIS DOCUMENT
This document is organized into two parts. The first part,
Chapter II, describes the nature of ground—water monitoring and
outlines current EPA statutes and programs related to ground-
water monitoring.
The second part, Chapters III through VII, describes a deci-
sion process for arriving at a strategy and analyzes the major
policy issues that must be considered in selecting the best stra-
tegy. The analysis sets forth decision options and briefly ana-
lyzes each. The options cover three sequential topics: objec-
tives; approaches to achieve the objectives; and federal, state,
and other roles.
A set of appendices is included as a Resource Document and
contains further analyses of particular issues for background
reading by workshop participants.
PURPOSE OF THE OPTIONS PRESENTED
The options discussed in Chapters IV, V 1 and VI present a
range of views expressed by different people during the research
for this workshop. These options provide a menu of choices that
could be made in developing a ground-water monitoring strategy.
The options are not exhaustive. They are intended as starting
points for discussion in the workshops and may be modified as
participants feel it appropriate.
The discussion of the options must focus on the purposes of
the information that would be collected by ground—water monitor-
ing and the kinds of decisions that would be supported by these
data. This includes consideration of how, why, and for whom the
monitoring data are being collected, with recognition that data
users include state and local governments, federal agencies in-
cluding EPA, and industry.
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In considering these options, one should remember that
ground—water monitoring is a more complex technology and is often
more expensive than air or surface—water monitoring. It is also
important to note that a general lack of sufficient ground—water
data may handicap efforts to protect ground water from containina—
tion. These issues suggest that developing a strategy will in-
volve difficult decisions which, at times, will be made under
great uncertainty. Nevertheless, it will be important to iden-
tify possible approaches to selecting a ground-water monitoring
strategy as a starting point for future policy development.
WORKSHOP STRUCTURE
The workshop will contain six key elements, listed below.
I. Plenary Sessions——Review
of the working Papers
Plenary sessions will take place in the main meeting room at
several points during the workshop. The purpose of these meet-
ings will be to identify and discuss the principal issues as
indicated in this document and other issues as raised by the
workshop participants in preparation for the more detailed in-
dividual work group discussions.
II. Work Group Discussions
At several points during the workshop, the participants will
break into four work groups. Each work group will be expected to
independently select options and develop a tentative position on
the topic assigned.
III. Brief Work Group Progress Reports
At the conclusion of each of these work group sessions, each
group will present to the full workshop a five—to—ten—minute
report of its tentative position on the given issue. These re-
ports will not be considered binding. Their purpose will be to
provide an indication of each work group’s progress and direc-
tion.
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1—5
IV. Work Group Preparation of
Integrated Recommendations
Beginning in the afternoon of the workshop’s second full
day, each work group will be asked to draw upon its previous work
to prepare an integrated set of recommendations related to the
options defined in this document.
V. Work Group Presentations
On the last morning of the workshop, officials from many EPA
offices will join the group. The individual work groups will be
expected to make a 20—to—30—minute presentation of their recom-
mendations, using appropriate visual aids. Following each pre-
sentation, there will be a brief question—and—answer period.
VI. Final Discussion
After the work group presentations, the participants will
discuss the issues raised and the recommendations made. The
workshop will not attempt to reach a consensus on individual
issues. Its focus will be to obtain a full discussion of issues
and recommendations for EPA’S subsequent use in drafting a pro-
posed ground—water monitoring strategy.
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II. BACKGROUND ON GROUND-WATER MONITORING
Monitoring of the nation’s ground waters is conducted by a
variety of public and private organizations. Federal agencies
such as the U.S. Geological Survey (USGS), U.S. EPA, and the
Department of Agriculture collect a broad range of information on
ground water through monitoring. The types of data collected
vary widely, with USGS efforts more often focused on broad-based
ground—water quality and quantity and U.S. EPA efforts generally
focused on ground—water contamination. In addition, most states
conduct monitoring investigations. They may monitor ground water
to determine whether it is actually contaminated and direct moni-
toring efforts toward various points of concern: potential
sources, water supplies, and ambient conditions.
DEFINITION OF MONITORING
For the purpose of this strategy, “ground—water monitoring”
is broadly defined as the set of activities that provides chemi-
cal, physical, geological, biological, and other environmental
data required by environmental managers. Under this definition,
monitoring includes:
• Planning the collection of ground—water data to meet
program objectives and information needs
• Designing monitoring systems and studies
• Selecting sampling sites
• Well installation
• Collecting and handling samples
• Lab analysis
• Reporting and storing data
• Assuring quality of data
• Analyzing, interpreting, and making data available for
use in decision making and reporting to the public
Monitoring activities take place at hazardous waste facili-
ties, public drinking water wells, and other locations where
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11—2
people need information on ground—water quality, quantity, and
flow. The focus of these activities is, in large measure, a
function of statutory mandates requiring government agencies and
the regulated community to monitor ground—water quality.
FEDERAL MONITORING ACTIVITIES
The federal government conducts a wide variety of programs
that include ground—water monitoring. Many of these activities
are responsive to or required under major environmental statutes,
such as the Atomic Energy Act, Clean Water Act, CERCLA, FIFRA,
RCRA, SDWA, and TSCA. Those statutes that make no explicit pro-
visions for monitoring, such as the Coastal Zone Management Act
and the National Environmental Policy Act, leave monitoring to
the discretion of the appropriate federal or state agency. All
these environmental statutes are summarized in Table 11—1, at the
end of this chapter.
Although the focus of this workshop is on EPA monitoring
activities, other federal agencies play a significant role in
ground—water monitoring investigations. The Department of De-
fense, USGS, Soil Conservation Service, Nuclear Regulatory Com-
mission, Department of Agriculture, and Bureau of Land Management
all conduct ground— water monitoring.
The USGS in particular is engaged in a wide range of moni-
toring activity. For example, the USGS Federal—State Cooperative
Water Resources Program assists states, Guam, Puerto Rico, and
U.S. territories with the identification of key ground—water
issues and problems. As the principal U.S. water data agency,
the USGS also maintains several databases that provide for the
processing, storage, and retrieval of ground—water monitoring
data. These databases are summarized in Chapter VIII of the
Resource Document .
The majority of environmental statutes fall within the re-
sponsibility of EPA and its program offices, including the drink-
ing water, pesticides, solid waste, and toxics program offices.
EPA ground-water monitoring supports a variety of mandates. The
involvement of the Office of Drinking Water (ODW) results primar-
ily from ODW’s mandate to protect drinking water supplies, to
establish drinking water standards, and to evaluate system com-
pliance. Recently reported contamination of ground water by
pesticides in several areas has led to changes in ODW’s regula-
tory and standards development priorities. The participation of
the Office of Solid Waste and Emergency Response results from the
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11—3
need to monitor Superfund sites and hazardous waste facilities.
The prime interest of the Office of Toxic Substances is in as-
sessing exposure of people and the environment to toxic chem-
icals. To date, ground—water monitoring by this office is not of
high priority. Monitoring under these offices is summarized in
Table 11—2 and in Chapter III of the Resource Document.
STATE MONITORING ACTIVITIES
The level and focus of monitoring activity among the fifty
states varies considerably and reflects different approaches to
ground—water investigation. A recent report by the Office of
Technology Assessment (OTA) noted:
• Most states have formalized approaches to collecting
and analyzing ground—water quality samples.
• At least 17 states rely on federal guidelines.
• To determine which parameters to measure at a particu-
lar site, many states also rely on federal guidance
through lists prepared for various regulatory programs
and laws.
• Forty—three states make routine comparisons of monitor-
ing data with quality standards..
• Twenty—two states have formal policies on the confiden-
tiality of ground—water information they collect.
• All but one state detect ground-water contamination by
responding to complaints of suspected contamination.
About half the states have formal policies, guidelines,
or procedures for this purpose.
Through these activities, a large amount of information has
been collected on the quality and character of the nation’s
ground—water supplies. However, as public awareness of potential
ground—water contamination has grown, so have concerns about
coordinating the efforts of government agencies conducting mon-
itoring activities to ensure the adequacy and usefulness of
ground—water data.
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11—4
CURRENT PROBLEMS IN GROUND-WATER
MONITORING
Periodic criticism of ground—water monitoring activities has
focused on limited coordination, control, or planning of moni-
toring activities across programs, agencies, or regions of the
country; uncertain quality of the data collected; the design of
networks and studies that result in data of limited use; lack of
data suitable for trend analyses; difficulty in accessing inf or—
mation; incompatibility of databases; and the limited analysis
and use of environmental data for decision making.
For example, accurate assessments of ground—water quality,
quantity, and movement can only be achieved through extensive
monitoring of ground water. However, many factors can confound
efforts to monitor ground water precisely, including limited
planning for well site selection, inadequate well installation,
and contamination of samples. Current programs do not adequately
ensure the high quality and reliability of data collected by
ground—water monitoring, and there are no uniform guidelines by
which to measure the adequacy of monitoring activities. In some
cases, present activities are being carried out well, but more
monitoring is needed. In other cases, enough monitoring programs
are under way, but sampling is not providing data on the consti-
tuents of concern.
Many users of ground-water information have also identified
the need to improve the management and accessibility of ground-
water data. For example, in Long Island, New York, ground—water
data are collected by as many as 13 state and local agencies and
organizations, many of which have different data requirements and
database designs. These agencies often find it difficult to
share information, given their differences in data format, and
have no canmon database on which to make and coordinate policy
decisions. The problem is not unique to Long Island——there are
many databases that have been developed in response to the par-
ticular needs of government agencies. These databases serve the
needs of individual users but often cannot be integrated with
other ground—water databases.
-------
Table TI —i
Offics of T.chna$ogy Ass.ssmsnt Summary of Fsderai Groundwatsr Monitoring Provisions and Obj.ctlvss
Statutory authority
Atomic Energy Act
Clean Waler Act
—Sections 201 and 405
-Section 208
Coastal Zone Management Act
comprehensive Environmental
Response, Compensation.
and Liability Act
Federal Insecticide, Fungicide.
and Rodeaticide Act—
Section 3
Federal Land Policy and
Management Act (and
Associated Mining Laws)
Hazardous Liquid Pipeline
Safety Act
Hazardous Materials
Transportation Act
National Environmental
Policy Act
Reclamation Act
Resource Conservation and
Recovery Act
Monitoring provislons&
Groundwater monitoring is specified in Federal regulations for low-level radioactIve
waste disposal sites. The tacility license must specify the monitoring requirements
for the source The monitoring program must include:
—Pre .operationai monitoring program conducted over a 12-month period. Param-
eters not specified.
—Monitoring during construction and operation to provide early warning of releases
of ractionuclides from the site Parameters and sampling frequencies not
specified.
—Post-operational monitonng program to provide early warning of releases of radio-
nuctides from the site. Parameters and sampling frequencies not specified.
System design Is based on operating history, closure, and stabilization of the sit.
Groundwater monitoring related to the development of geologic repositories will be
conducted. Measurements will Include the rate and location of water inflow Into
subsurface areas and changes in groundwater conditions.
Groundwater monitoring may be conducted by DOE, as necessary, pail of remedial
action programs at storage and disposal facilities (cx radioactive substances.
Groundwater monitoring requirements are established on a case-by-case basis for the
land application of wastewater and sludge from sewage treatment plants.
No explicit requirements are established; however, groundwater monitqrlng stud(es
are being conducled by SCS under the Rural Clean Water Program to evaluate the
impacts of agricultural practices and to design and determine the effectiveness
of Best Management Practices.
The statute does not authorize development of regulations for sources. Thus, any
groundwater monitoring conducted would be the result of requirements established
by a State plan (e.g., monitoring with respect to sait•water intrusion) authorized and
funded by CZMA
Groundwater monitoring may be conducted by EPA (or a Stale) as necessary to
respond to releases of any hazardous substance, contaminant, or pollutant (as
defined by CERCLA).
No monitoring requirements established for pesticide users. However, monitoring may
be conducted by EPA in instances where certain pesticides are contaminating
groundwater.b
Groundwater monitoring is specified in Federal regulations for geothermal recovery
operations on Federal lands for a period of at least one year prior to production,
Parameters and monitoring frequency are not specified.
Explicit groundwater monitoring requirements for mineral operations on Federal lands
are not established in Federal regulations. Monitoring may be requIred (as a permit
condition) by BLM.
Although the statute authorizes development of regulations for certain pipelines for
public safety purposes, the regulatory requirements focus on design and operation
and do not provide for groundwater monitoring.
Although the statute authorizes development of regulatIons for transportation for
public safety purposes, the regulatory requirements focus on design and operation
and do not provide for groundwater monitoring.
The statute does not authorize development of regulations for sources.
No explicit requirements established; however, monitoring may be conducted, as
necessary, as part of water supply development prolects.
Groundwater monitoring is specified in Federal regulations for all hazardous waste
land disposal lacilities (e.g., landfills, surface Impoundments, waste piles, and
land treatment units). ________________
Monitoring oblectives
To obtain background water quality data and to evaluate
whether groundwater is being contaminated.
To confirm geotechnical arid design parameters and to
ensure that the design of the geologic repository
accommodates actual field conditions.
To characterize a contamination problem and to select and
evaluate the effectiveness of corrective measures.
To evaluate whether groundwater is being contaminated.
To characterize a contamination problem and to select and
evaluate the effectiveness of corrective measures.
To characterize a contamination problem (e.g.. to assess
the Impacts of the situation, to identify or verify the
source(s). and to select and evaluate the effectiveness of
corrective measures).
To characterize a contamInation problem.
To obtain background water quality data.
(Continued)
-------
Table 11—1
000ic. of Tsclmology As...amsnt Summwy of Fadsr Groundwatsr Mo.dto ig Provllons and
Slatulory authority
Resource Conservahon and
Recovery Act (cont’d)
—Subside C
—Subtitle D
Sats Drinking Water Act
—Part C—Underground
ln(ectlon Control Program
Monitoring provisions
interim Status monitoring requlr.ments must be met until a fInal permit Is Issued.
These requirements specify the Installation of at least one upgradlenl well and
three downgradlent wells. Samples must be taken quarterly during the fIrst year and
analyzed for the National Interim Drinking Water Regulations, water quality indicator
parameters (chloride, Iron, manganese, phenols, sodium, and sulfate), and indicator
parameters (pH, specIfic conductance, TOC, and TOX). In subsequent years.
each welt Is sampled and analyzed quarterly for the six background water quality
Indicator parameters and semiannually for the four Indicator parameters.
Groundwater mon,forlng requirements can be watved by an ownerloperator If a
written determination Indicating that there Is low potential for waste migration via
the upper-most aqulter to water supply wells or surface water Ii made and certified
by a qualified geologist or engineer. The determination is not submitted to EPA
for verification or approval.
The monitoring requirements for a fully permitted facility are comprised of a three-part
program:
—Detection Monilodnp — Implemented when a permil Is Issued and there Is no
Indication of leakage from a facility. Parameters are specified In the permit.
Samples must be taken and analyzed at least semiannually. Exemptions from
detection monitoring program may be granted by the regulatory authority
for landfills, surface Impoundments, and waste piles with double liners and
teak detection systems.
—Compliance Monitoring — Implemented when groundwater contamination Is
detected. Monitoring Is conducted to determine whether specified concentration
levels tar certain parameters are being excasded Oevsls are based an background
concentrations, maximum contaminant levels specified by the National Drinking
Waler Regulations )if higher than background), or an alternative concentration
limit (.stMlIshed on a site-specific baslsD. Samples must its taken and analyzed
at least quarterly for parameters specified in the permit. Samples must also
be analyzed for a specific list of 375 hazardous constituents (Appendix VIII,
40 CFR 261) at least annually.
—Corrective Action Monitoring — Implemented If compilanc. monitoring indicates
that specilled concentration levels for specified parameters are being exceeded
(and corrective measures are required). Monitoring must continue until specified
concenlratlon levels are met. Parameters and monitoring frequency not specified.
—Exemption from groundwater monitoring requirements may be granted by the
regulatory authority II there Is no potential for migration of liquid to the
uppermost aquifer during the active life and closure and post-closure periods.
Groundwater monitoring may be required by State solid waste programs. Federal
requirments for State programs recommend the estalllshment of monitoring
requirements.
Groundwater monitoring requirements may be specified in a facility permit for
Infection wells used for in-situ or solution mining of minerals (Class III wells) where
infection Is Into a formation containing less than 10,000 mg I! TOS Parameters and
monitoring frequency not specified except In areas subfect to subsidence or
collapse where monitoring Is required on a quarterly basis.
Groundwater monitoring may also be specified in a permit for wells which Inject
beneath the deepest underground source of drinkIng water (Class I wells).
Parameters and monitoring frequency no! specified In Federal regulations .
Monitoring ob ectlves
To obtain background water quality data and evaluate
whether groundwater Is being contaminated.
To obtain background water quality data or evaluate
whether groundwater Is being contaminated (detection
monitoring), to determine whether groundwater quality
standards are being met (compliance monitoring), and to
evaluate the effectiveness of corrective action measures.
To eveluate whether groundwater Is being contaminated.
(Continued)
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Table I l—I
Of tic. of Tclunology A.....msnt Suninary of F.d .u Groundwstsr Monitoring Provl.lons and Obj.cth
Statutory authority
Surface Mining Control and
Reclamation Mt
bxic Substance Control Act
—Section 6
Uranium Mill Tailings
Radiation Control Act
Water Research and
Development Act
Monitoring provisions
Groundwater monitoring is specilied in Federal regulations for surtace and under
ground coal mining operations to determine the impacts on the hydrologic balance
of the minIng and adlacent areas. A groundwater monitoring plan must be
developed for each mining operation (including reclamation ) At a minimum,
parameters must include total dissolved solids or specilic conductance. p11, total
iron, and total manganese. Samples must be taken and analyzed on a quarterly
basis.
MOVIHO.*tQ of a particular water-bearing stratum may be waived ty the regulatory
authority ii it can be demonstrated that it is not a stratum which serves as an
aquifer that significantly ensures the hydrologic balance of the cumulative
impact area
Groundwater monitoring specified in Federal regulations requires monitoring prior to
commencement of disposal operations for PCB5. Only three wells are required it
underlying earth materials are homogenoue, impermeable and uniformly sloping in
one direction. Parameters include (at a minimum) PCBe, p11, specific conductance,
and chlorinated organics. Monitoring frequency not specified.
No requirements are established for active life or after closure.
Federal regulatory requirements for active mill tailings sites are, for the most part, the
same as those established under Subtitle C 01 RCRA.C
Groundwater monitoring for Inactive sites may be conducted it necessary to deter-
mine the nature ol the problem and (or the selection of an appropriate remedial
action.
The statute does not authorize the development of regulations (or sources.
Groundwater monitoring may be conducted as pail ot projects funded by the act .
Monitoring objectives
To obtain background water quality data and evaluate
whether groundwater is being contaminated.
To obtain background water quality data.
To obtain background water quality data, evaluate whether
groundwater is being contaminated, determine whether
groundwater quality standards are being met, and
evaluate the effectiveness of corrective action measures.
To obtain background water quality data and to characterize
a contamination problem.
•Th. moiutodng provisions presented in this tatte are eitha,: those apecilied by regulations tot existing and new sources; or to, Woundwater monitoring that may be conducted as pan 01 an investigatory study or remedial
ection program
bp 5 4 manulactureri may b. requued by EPA to submit groundwater monitoring data as pad of the registration requirements for a pesticide product to evaluate the potential lot a pesticide to Contaminate groundwater.
C 5 app. E.2 to, a summary ol the dtlleraiic.s between UMTRCA and ACRA monitoring requirements.
SOURCE: Office of Technology Assessment.
-------
Table 11—2
S(N*(ART Of EPA’S GROUND-WATER NONITOMNG PROGRAP
Monitoring QA/QC
Purpose of Point of frequency of Contaninanta Responsi— Guid— Data Storage
Program Monitoring Monitoring Monitoring Monitored bility Coverage ance and Access Remark.
1. DRINKING WATER
a. Regulated Conta..inants
• Niorobiological I to 500 sample. Micro— Quarterly sample.
per month depend— biologioal for systems of less
ing on the syste. than 3,000 people.
size and source.
• Turbidity None Turbidity
• Inorganios Analysis and sampi— Arsenic, Sampling and analysi
ing to be done barium, to be repeated every
every three years. cadmium, Original data three years.
Coupliance Repre.en— Last done in 1983. chromium, reported to
with tative of lead, etc. States. Data
maximum the dis— Public for systems not
• Organic Chemtoals contamin— tribution Analysis to be Certain water National Tea meeting an MCI. Organochlorin.
Other than THI4s ant levels system. done at the pesticides system reported to EPA pesticides and
(NC I .s). discretion of and and stored in chlorophenoxy acid
the State. herbicides FRDS. herbicides covered b
the regulation.
• Radioactivity Compliance based Gross Alpha Sampling and analysi
on quarterly and Beta; to be repeated every
samples. Analysis total radium; four years.
to be done every radium 226;
four years. strontium
89.90, etc.
• Trihalomethanes One to four Trihalo— Regulations applies—
samples per year. methanes ble to systems
serving more than
10,000 people.
(Continued)
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Table 11—2
S(flIARY OF EPA’S GROUND—WATER MONITORING PROGRAMS (Continued)
Monitoring QA/QC
Purpose of Point of Frequency of Contaminants Responsi— Guid- Data Storage
Program Monitoring Monitoring Monitoring Monitored bility Coverage ance and Access Remarks
1. DRINKING WATER
(Continued)
b. Underground Injection Monitoring In accord- Class I: deter— Operators -- Yea Data submitted at Regulations became
Control Program of ambient ance with mined by of Class time of approval. effective in Nay
quality of specific the I, II, Ill, Primaoy States may 1984. Data to be
underground sampling Class II: state/ and V have their own reported to States.
sources of plan for a regional Injection wells, requirements. Class V monitoring
water. In site or an direc— fluids, at the discretion of
general, area. Class V: tore, the directors.
monitoring
is required Class III: semi—
only if monthly.
ground -
water is
or will be
used (or
drinking
water
purposes.
o. Sole—Source Aquifer To assess Depends on Depends on the Depends on Federal Federally -— Reported in £13, EPA assesses the
Program danger to the water water quality the water agency financ— or project impact of a Federal
public quality problem faced. quality whose pro— ially— application, project on a sole-
health as problem problem Sects may assisted source aquifer
part of (aced. faced. affect the projects through the NEPA
£13, or aquifer, that might project, or
individual or project impact individual project
project applicant. recharge review.
area of
designated
aquirers.
d. Support for Standard
Settiog
• Previous Surveysa Sampled
water
Determine Representa— systems.
• National Inorganica whether a tive of the Specified Represen- Data available Survey completed
and Radionuolides standard distribu— One—time surveys, in the EPA/States tative of Yes from the Office recently.
Survey should be tion surveys, all water of Drinking Water.
set. system. systems
and
• Pesticides Survey problems. Survey in planning
stages (see Pesti-
cides Program).
(Continued)
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Table 11—2
SUP9 ARY OF EPA’S GROUNDWATER MONITORING PROGRAMS (Continued)
Monitoring QA/QC
Purpose of Point of Frequency of Contaminants Responsi- Guid- Data Storage
Program Monitoring Monitoring Monitoring Monitored bility Coverage ance and Access Remarks
1. DRINKING WATER
(Continued)
e. Contamination Incidents 1) Define — - Depends on the Those State, Specific Yes None Regional drinking
the scope site requirements. affecting generally mci— water offices help
and magni— public dents, hazardous waste and
tude of health. superfund programs
contami— when public water
nation, systems have been
2) Assess contaminated.
future
expansion.
2. PESTICIDE PROGRAM
a. Nationwide Pesticide Detect ______ Study in the planning stages _____ EPA. State 1,500 - Yes Will be stored in Primary office
Groundwater Contamina— problems (10—50 pesticides). and county 3,000 EPA computers. responsible: ODW.
tion Study of direct governments ground—
exposure. will proba— water
bly partic— samples
ipate. expected.
b. USI Regional Determine ______ Study in the ______ Pesticides USGS Florida, Yes —- Will take four
Assessment Program the nature planning stages. and organice. Kansas, years to complete.
and extent Nebraska, Program supposed to
of contam- Califor- cover organios and
ination in nia, and other pollutants.
agricultur— Louisiana/
al areas. Mississippi
(tens to
thounands
of square
mi1e for
each as—
ses ment).
(Continued)
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Table 11—2
SU)*IARY OF EPA ’S GROUND—WATER MONITORING PROGRAMS (Continued)
Monitoring QA/QC
Purpose of Point of frequency of Contaminants Reaponsi Guid— Data Storage
Program Monitoring Monitoring Monitoring Monitored bility Coverage ance and Access Remarks
2. PESTICIDES PROGRAM
(Continued)
a. Single Chemical Registra— Laboratory studies. Registrant Local Need —— -—
Leaching Studies tion of for a
pesti- moni-
cidea. toring
gu Id —
ance
docu —
ment.
d. Collaboration with Assessment _ Depends on local conditions. States and -- - - -- --
States and/or of ground- USGS
Pesticide Hazard water con—
Assessment Projects taatnation,
e. Dougherty Plains Field Predict pesticide movement and fate. Project involves controlled application of two pesticides, ___________
Validation Study aldicarb and metolachior, Project initiated by OFID to validate a model.
3. SOLID WASTE PROGRAM
a. Superfund Sites Clean-up -- Depends on Those State, -— Yea —— - —
with specific site affecting generally
superfund. requirements, public
heal th/
environment.
Enforce- -- Depends on Those Owner/ -— Yes -- Monitoring require-
ment, specific site affecting Operator ments specified in
requirements, public the consent decree.
health/
environment.
(Continued)
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Table 11—2
StJ fjARy OF EPA’S GROUND-WATER MONITORING PROGRAMS (Continued)
Monitoring QA/QC
Purpose of Point of Frequency of Contaminants Responsi— Guid— Data Storage
Program Monitoring Monitoring Monitoring Monitored bility Coverage ance and Access Remarks
3. SOLID WASTE PROGRAM
(Continued)
b. Active Hazardous Detect con- Uppermost Quarterly to Specified
Waste Facilities tamination. aquifer establish back— indicator
immediate— ground; semiannual parameters
ly beneath for detection. (see reg.).
eoge of
waste.
Assess Uppermost Specified in plan All Appendix
extent of aquifer (minimum VIII of
contamina- immediate- quarterly). 110 CFR 261.
tion ly beneath
(assess- edge of Owner/
ment eon- waste. Operator
itoring).
Monitor Uppermost Specified in plan Specified
compliance aquifer (minimum Appendix VIII
with immediate— quarterly). const tuents
ground- ly beneath quarterly,
water edge of all
protection waste, constituents
standard or annually.
corrective
action
plan.
o. Non—Hazardous Waste Ensure Specified Specified by the In general, Chmer or Facili— No None at the
Facilities guidelines by the State. contaminants operator ties Federal level.
(Subtitle D is a for Sub— State. regulated
state progra.i) title D under the
facilities Safe Drinking
are not Water Act.
exceeded.
(Continued)
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Table 11—2
SIR4ARY OF EPA’S GROUND-WATER MONITORING PROGRA (Continued)
Monitoring QA/QC
Purpose of Point of Frequency of Contaminants Reaponsi— Guid— Data Storage
Program Monitoring Monitoring Monitoring Monitored bility Coverage ance and Access Remarks
. TOXI( PROGRAM No specific ground—water monitoring program mandate. Toxic. program supposed to assess exposure to toxic eubstanoes;
exposure through ground—water is not a major concern of the program.
a i surveys have been conducted in the past:
(1) National Organic Reconnaissance Survey (1975);
(2) National Organic Monitoring Survey (1976—1977);
(3) National Screening Program for Organic. in Drinking Water (done by SRI International between 1976 and 1981);
( ) Cc unity Water Supply Survey (1978, . .
(5) The Rural Water Survey (1978); and
(6) The Ground—water Supply Survey (1980—1981).
-------
III. WHAT IS A STRATEGY?
The EPA ground-water monitoring strategy will be developed
by EPA in the context of a wide variety of federal and state
programs. This implies the need for a general consensus on the
part of all concerned——federal, state, and local governments;
business; industry; and others——as to what problem is to be ad-
dressed, what objectives are to be achieved in alleviating the
problem, and what constitutes the most effective, efficient, and
feasible way of achieving those objectives. Central to develop-
ing strategy is specifying the roles of the participants. The
type and extent of these roles depend on many factors, among them
history, current law, capacity to provide needed resources, and
the degree to which the problems are being addressed through
current efforts.
For a ground—water monitoring strategy, EPA has in mind an
approach that is also relevant to and supportive of related ef-
forts, most particularly the efforts of state and local govern-
ments. The strategy should clearly delineate the larger context
in which EPA works--on the federal level and with state and local
governments-—and provide the framework within which EPA decision
making on ground—water monitoring can take place.
Once developed, the ground—water monitoring strategy will
include a statement of the Agency’s ground—water monitoring
objectives and a description of approaches to achieving those
objectives. It will center on the major decisions that EPA and
state/local counterparts must make concerning ground—water quali-
ty as part of their responsibility for protecting the resource
and on the data that are necessary to support those decisions.
It will also focus on those steps or measures needed to accom-
plish EPA ground—water quality monitoring objectives already
identified and on support that EPA will provide to state and
local governments in accomplishing their objectives. The strat-
egy will identify tasks related to individual program responsi-
bilities for ground—water monitoring (e.g., pesticide program,
RCRA program) and will identify activities that will cut across
program areas (e.g., monitoring methods, training, research, and
program evaluation). Thus, the strategy will address key deci-
sions and data needs for existing EPA programs and identify the
gaps between EPA programs.
A ground—water monitoring strategy, therefore, will help
formalize the Agency’s approach to ground—water protection. With
this approach, individual program monitoring strategies will
continue to focus on their program needs, while the ground—water
-------
111—2
monitoring strategy will focus on the inter—relationships between
programs and on the overall direction of the Agency’s ground-
water monitoring effort.
TEE FRAMEWORK FOR
DEVELOPING A STRATEGY
Strategies imply choices——from the broadest determination of
goals and objectives to implementation of the chosen course
through laws, regulations, and resources.
For the purposes of this workshop, these choices will be
presented as follows. First, the major strategic issues that
emerged in preparation for the workshop will be identified, ana-
lyzed, and discussed. Then, the workshop participants, in four
work groups of approximately a dozen persons each, will be asked
to carefully look at the alternatives, add new ones, discard
those thought unworkable, and recommend the strategy choices
considered most appropriate.
A strategy for ground—water monitoring should include
choices with respect to each of the following elements:
• A general ranking of objectives for the ground—water
monitoring strategy in order to identify those that
deserve the most additional attention;
• A choice of the best monitoring approach or approaches
for the accomplishment of each objective and recommen-
dations on how it would be carried out;
• The roles and responsibilities of federal, state, and
local governments in carrying out aspects of the
strategy.
Each of these elements will be discussed during the work-
shop, in the sequence in which they are listed above. Work
groups will discuss them and make recommendations in each area.
The final strategy recommended by each work group will represent
an integration of the various recommendations into one overall
statement.
Strategic options for each of these elements are detailed in
subsequent chapters. Table 111—1 summarizes those options in
three columns as a decision matrix, corresponding to the three
elements of a strategy as listed above. The various columns in
the decision matrix reflect the sequence of steps that the work-
shop participants will follow to develop their recommendations.
-------
Table Ill-i
9JI44ARY OF I ONITORING OBJECTIVES AM) APPROACHES FOR THE E VELOPP€NT
OF A GROUND—WATER NDNITORDG STRATEGY
1. Monitor to Characterize Ground—Water
Reeource
A. Survey Existing Data
B. Expand Use of Existing Monitoring
C. Drill New Wells on Targeted Basis, Such a.
USGS Basin Surveys
D. Design Broad Fixed Nettmrk of New Wells
A. Do Not Standardize (No Change)
8. Decentralize Databases, Standardize Content,
Type, and Formats
C. Decentralize Oatabs es with Accessibility
and Compatibility
D. Create National Computer Database
2. Federal Government Sets Standards and
Technical Requirements in con iltation with
states; States Conduct Monitoring
3. States Design and Conduct Monitoring with
Federal Approval
4. States Design and Conduct Monitoring with
Federal Guidance and Information
5. States Design and Conduct Monitoring
6. Localities Responsible for Monitoring with
State Assistance
7. localitiea Responaibile for Monitoring
Objectives of
Ground—
Monitoring
Approaches
to
Achieve
Roles
and
Responsibilities in Support
Water
Monitoring
Strategy
the Objectives
of National and State Ground—Water
Strategies
(prioritize)
(Select 1
for each
Objective)
(See
Key Questions Below)
1. Federal Government Conducts Monitoring
2. Monitor to Identify New P ob1ems
A. Target Monitoring by Land/ round—Water Use
B. Scout for Problem Sites or Typee
C. Establish Pobic Hotline with Government
Responae
0. Create Incentives or Requirements for
Private Sector
E. Design Net rk of Wells (National or State)
F. Require Sampling by Ground—Water Users
3. Monitor to Assess Kno Problems to
Support Regulatory and Standard
Setting and Respond to Site—Specific
Problems
A. Conduct Direct Governaent Monitoring
8. Create Incentives or Requirements for
Private Sector
C. Regulate Source Operators and Manufacturers
of Chemicals Such as Pesticides
0. Require Seepling by Ground—Water Users
4. Monitor to Assure Compliance with
Regulations
A. Rely an Design Standards without Monitoring
B. Require Self—Monitoring
C. Create Financial Incentives for Self Moni
toring
D. Conduct Government Monitoring
E. Contract for Third Party Monitoring
5. Monitor to Evaluate Program
Effectiveness
A. Utilize Compliance Monitoring Information
B. Monitor on Complaint-Basis
C. Conduct Audit Sampling
D. Design and Establish Network of Wells
6. Improve Quality Assurance/Quality
Control
A. Mo Change
B. Establish Criteria/Standarda for Labs and
Drillers
C. Regulate Labs and Drillera
D. Establish Guidelines, Provide Informstion/
Education for Drilling, Testing
H
H
7. Improve Data Manegement
8. Private Sector Incentives and Requirements
9. End Users
Key Questions
In general, t ich roles do you prefer for each
monitoring approach?
Which roles are suet appropriate for each
nunitoring approach?
Do roles differ for various ground—water
problems?
-------
111—4
First, work groups will discuss objectives and select those that
they believe are more important for a ground-water monitoring
strategy. This could involve categorizing the objectives in two
or three groups in order of importance.
Next, work groups will review the monitoring approaches
presented for achieving each of the seven objectives. They will
be asked to select one of the monitoring approaches for each of
the objectives. Then, participants will discuss federal, state,
and local roles in implementing the strategy and will select one
or more of the options provided.
It will be important to consider the following criteria in
developing recommendations:
• Economic and technical feasibility of the options
selected
• Relative costs of the options selected
• Relationship of the options to ongoing programs
• Response of the appropriate decision makers to the
options selected
• Information necessary to implement the options
selected
After the work groups have completed their presentations on
each of these three topics (objectives, monitoring approaches,
roles and responsibilities), the groups will be asked to develop
a final and more lengthy presentation of an integrated ground-
water monitoring strategy. In order to accomplish this, each
work group will select options in the columns in Table i l l-i and
define a unique set of recommendations for the ground-water moni-
toring strategy. The choices in various columns must relate to
one another logically, in the context of the strategy. Each set
of monitoring approaches in the second column relates directly to
a single objective in the first column, but there is no predeter-
mined correspondence between the roles shown in the last column
and the previous columns. Any horizontal path through the table,
from an objective in the first column to a related monitoring
approach to a selected role, will define a potential strategy.
For example, a work group might decide that one of the ob-
jectives that deserves a high degree of attention is objective
number 2 in the table, “Monitor to Identify New Problems.” It
might then recommend that the best way to achieve that objective
is option A, to set up a targeted monitoring program on the basis
-------
111—5
of local land and ground—water use patterns. The group may feel
that data collected under this approach would enable state and
local decision makers to develop more accurate ground—water clas-
sification programs. Finally, that group might recommend that
the best division of roles to achieve that would be role op-
tion 2, in which the federal government would establish standard
procedures and an overall program design and the states would be
responsible for actually conducting the monitoring.
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IV. OBJECTIVES TO SUPPORT TEE GROUND-WATER STRATEGY
Current ground—water monitoring activities are carried out
to achieve many different and important objectives. The state-
ment of a ground—water monitoring strategy must necessarily em-
phasize some of these objectives more than others. This chapter
describes seven monitoring objectives and suggests that choices
must be made to determine the emphasis that each will receive in
the ground—water monitoring strategy. The first five objectives
relate to uses of ground—water monitoring data. The last two
relate to support activities consisting of ground—water data
collection and management. All seven are possible objectives for
the ground—water monitoring strategy.
The objectives all involve activities that are important to
support the Ground Water Protection Strategy , published by the
EPA in August 1984. For reference, the Executive Summary of the
strategy is included in the companion volume, Resource Document .
The objectives are not mutually exclusive. For example,
some monitoring activities could support several of the objec-
tives. Many such cross—cutting monitoring activities are cur-
rently under way, along with other activities focused on single
objectives.
In selecting which objectives should receive the greatest
emphasis, workshop participants must consider both the uses and
users of the ground—water monitoring data. In addition, the
participants should recognize that all the objectives will re-
ceive attention to some degree in the final strategy. As a re-
sult, participants will consider only the relative emphasis each
objective should receive.
Chapter III of the Resource Document summarizes monitoring
programs currently under way or planned at EPA and other federal
agencies. Chapter IV describes several state programs. The
workshop discussions are not intended to critique these programs.
Rather, the workshop participants should be familiar with these
programs and should discuss the seven monitoring objectives with
acknowledgment of the status of existing programs.
None of the objectives is specific to a particular EPA pro-
gram. For example, the objective of assessing known problems is
not limited to remedial investigations at Superfund sites. In
most cases, individual objectives cut across virtually all EPA
programs affecting ground water. Assuring compliance, for in-
stance, is an important concern of all these programs.
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IV-2
Table IV—l provides definitions of each of the seven ground-
water monitoring objectives. The last column includes examples
of existing monitoring activities that fit primarily (though not
exclusively) in that objective category.
The objectives should be discussed with the following ques-
tions in mind. The discussion should focus on what new activi-
ties or changes are recouunended given all existing programs and
on what uses would be made of ground—water data collected under
each objective. The questions are:
• On which objectives should the strategy place the
greatest emphasis?
• How would you group the objectives into two or three
categories from most important to least important in
terms of the ground—water monitoring strategy?
• Are the objectives realistic, i.e., could a strategy
accomplish them to a significant degree?
In developing answers to the questions above, the workshop
should consider the data needs implied by each objective and the
uses of these data. Specifically, the discussion of objectives
should consider:
• Who needs the data?
• For what decisions or purposes are the data needed?
• How would the data be used?
Each of the seven objectives, its supporting rationale, and
various opinions concerning the objectives are described in the
pages that follow.
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IV-3
Table IV—l
GROUND—WATER PUNITORING OBJECTIVES
Objective
1. Monitor to Character-
ize the Ground—Water
Resource
Definition
• Collection of background data on
ground water on an area—wide
basis
• Characterization of the ground-
water setting (e.g., soils,
geology)
Examples
• IJSCS basin studies
• State Geologic Surveys
• State efforts to establish ground-
water classification systems
2. Monitor to Identify
New Problems
• Monitoring activities to track
down cases of ground—water contam-
ination (“look for trotble”)
• State efforts to propose sites for
National Priority List under
CERCLA
3. Monitor to Assess
Kno Problems to
Support Regulatory
and Standard Setting
and Respond to Site—
Specific Prob lees
• Support of decisions on the need
to develop standards and regula-
tions
• Determination of the source and
extent of known contamination
(‘how serious is it?”)
• Collection of data to project
movement of contamination plumes
• (IRCIA Remedial Investigations
• Survey of leaking underground
storage tanks
4. Monitor to Assure
Compliance with
Regulations
• Determination of violations of
standards/regulations affecting
ground water
• Support of enforcement activities
• RCRA monitoring
• )WA monitoring for compliance
with standards
5. Monitor to Evaluate
Progr Effective-
ness
• Measurement of iether programs
are accomplishing their objec-
tives
• Support of decisions on allocating
resources to program improvementS
• Monitoring in agricultural land
for pesticides in ground water to
determine if FIFRA regulations are
effective
6. Improve Quality As—
airance/Quality
Control
• Activities that improve quality of
ground—water monitoring data
• Activities that enable users of
such data to determine its accur-
acy and validity
• Activities that improve data
availability and accessibility
• State lab and driller certifica-
tion programs
• Selected state data management
systems
7. Improve Data Manage-
ment
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IV—4
OBJECTIVE 1: MONITOR TO CHARACTERIZE
THE GROUND-WATER RESOURCE
This objective involves broad—based monitoring activities
aimed primarily at collecting background data on the ground-water
resource and its setting. These data would be a baseline against
which to assess ground—water quality and the implications of
contamination. The overall question that this objective would
seek to answer is, What is the nature of the ground—water re-
source ?
The results of these studies would be useful in many ways.
States that have undertaken ground—water classification programs
require such data to make decisions on how to locate the class
zones. Some states may use background data in making siting
decisions for new manufacturing or hazardous waste treatment
plants.
The best examples of ground—water monitoring programs con-
ducted to achieve this objective are the basin studies and water
resources investigations of the USGS and associated state survey
offices. Such studies are conducted over a significant geograph-
ic area (aquifer, valley, portion of a state) and are not focused
on a specific site (e.g., a few acres).
The users of this type of monitoring information will in the
future require data on a large number of water quality parame-
ters. In addition to the measures historically taken, they will
need data on organics, rate and direction of flow, soil type,
depth to ground water, and geologic factors. Data on the rela-
tive vulnerability of ground water to contamination would relate
most logically to data on ground—water quality collected under
this objective.
Supporters of this objective typically say:
The only logical place to begin a ground-water program is to
find out where we are——to establish a detailed baseline of
ground—water quality data against which to measure our prog-
ress. N
NWe have pretty good knowledge of where ground water is, from
existing programs, but we just don’t know nearly enough
about its quality, movement, and vulnerability to manage it
effectively. N
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‘v-s
OBJECTIVE 2: MONITOR TO IDENTIFY
NEW PROBLEMS
Monitoring under this objective involves tracking down new
problems of ground—water contamination. Activities are aimed at
looking for instances of contamination or types of activities
that may be causing such contamination. In contrast to the first
objective, it does not involve broad data of general usefulness
on ground water but focuses specifically on sites where contami-
nation or contamination activities may exist and on types of
contamination sources.
In general, the objective aims to answer the question, Where
are the problems ? In this sense it is forward—looking, with the
intent to provide information on the existence of previously
unidentified threats to ground—water quality.
A number of examples of this type of monitoring illustrate
its coverage. All fifty states have proposed sites for the
National Priority List under CERCLA on the basis of ground-water
monitoring data that identified these new problems. Many c u—
panies have undertaken monitoring studies to determine if one or
more of their plants has caused ground—water contamination.
Similarly, local governments, such as counties, cities, and
towns, have initiated ground—water monitoring to determine if
their activities have led to the contamination of ground water.
Representative comments in favor of this objective include
the following:
“We are only beginning to identify threats to ground-water
quality, and we should expand our work to continue to find
the many unknown sources contaminating this resource.”
“Monitoring should focus on finding new site—specific sources
of contamination and should lead to identifying new catego-
ries of problems.”
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IV-6
OBJECTIVE 3: MONITOR TO ASSESS
KNOWN PROBLEMS TO SUPPORT
REGULATORY AND STANDARD SETTING
AND RESPOND TO SITE-SPECIFIC
PROBLEMS
This objective uses monitoring to assess known problems in
order to support regulatory and standard—setting requirements and
respond to site—specific problems. Known problems are those in
which ground—water contamination has previously been identified.
Monitoring to achieve this objective involves answering the ques-
tion, How serious is the problem? , or determining the source and
extent of contamination.
One of the clearest examples of this type of monitoring is
the collection of data to project the movement of plumes of con-
taminants in ground water. Such monitoring is now under way at
hundreds of sites including most of the CERCLA sites on the
National Priority List.
This type of monitoring is also a common first step in re-
sponse to certain types of ground—water threats and the need for
regulations to address such threats. For example, recent atten-
tion has focused on leaking underground storage tanks, and a new
EPA—sponsored survey is under way to determine the seriousness of
this source of potential contamination as a basis for developing
new regulations under RCRA.
Monitoring to achieve this objective is not necessarily
national or regional in scope. It could include local monitoring
around a municipal solid waste landfill known to be a ground-
water threat. Similarly, it could involve a manufacturing com-
pany tracking a chemical spill or leak by monitoring ground water
to determine the fate and transport of the materials.
Typical comments are:
“Remedial action can’t be planned in a cost—effective way un-
less we know how serious a problem we’re dealing with.”
“EPA and other regulatory agencies need to know more about
ground—water threats to establish appropriate standards and
regulations.”
“We know about most of the types of ground-water problems
that exist, but we don’t have enough detailed data on the
cause and extent of these problems to take effective regu-
latory action.”
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IV-7
OBJECTIVE 4: MONITOR TO ASSURE
COMPLIANCE WITH REGULATIONS
Environmental programs generally require some type of moni-
toring to determine compliance. This objective involves those
ground—water monitoring activities that are undertaken to achieve
this end. The objective is broad in that it encompasses many
different regulatory programs, yet it is narrow in that its def i—
nition is straightforward and there is little overlap with other
monitoring objectives. This objective seeks to answer the ques-
tion, To what extent is compliance being achieved ?
Monitoring under this objective is aimed at determining if
ground—water contamination has been or is being caused by viola-
tions of standards or regulations. It is generally intended to
lead to initiation of enforcement or corrective action at a spe-
cific site.
There are numerous examples of present monitoring to achieve
this objective. One example is the RCRA requirement at all per-
mitted hazardous waste landfills. Current RCRA rules require the
installation and use of ground—water monitoring wells at each
such facility. A second example is the requirement of the Safe
Drinking Water Act that community water systems monitor for vari-
ous contaminants that are listed by the Interim Primary Drinking
Water Regulations.
Representative comments of those who consider this to be a
more important objective are:
“Unless we successfully monitor compliance, no present or
future regulation to protect ground water will be effective.
It has to come first.”
“Compliance monitoring is trickier than it first appears. We
need to devote more resources to see that it is done cor-
rectly.”
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IV-8
OBJECTIVE 5: MONITOR TO EVALUATE
PROGRAM EFFECTIVENESS
Many environmental programs have as one of their goals the
protection or improvement of ground—water quality. These include
RCRA, (JIC, clean-ups under CERCLA, the pesticide programs under
FIFRA, and numerous state or local programs such as road salting
limits and septic tank regulations. In addition, the national
and state ground—water strategies are leading to the introduction
of other actions to protect ground water, such as ground—water
classification systems. Regulatory managers, regulated entities,
and the general public are concerned with the degree to which
each of these programs is achieving the goal of ground-water
protection or improvement.
This objective involves collection of ground—water monitor-
ing data to measure regulatory effectiveness in terms of ground-
water protection. The data would answer the question, Is the
program achieving its objectives and are the program targets
correct ? This review could then be used to set priorities for
changing regulatory programs, rules, standards, and procedures.
One example of such monitoring is under consideration within
the pesticides program of FIFRA. A field survey of agricultural
lands where pesticides have been applied is being planned to
determine the effectiveness of rules/guidelines designed to limit
the transport of pesticides to ground water.
Supporters of this objective say:
Without knowing how well we are doing now, we can’t move
forward logically to be more effective in protecting ground
water.
UToo little effort is applied to evaluating program effec-
tiveness. We may monitor compliance but we need to dig
deeper to learn if we are really accomplishing what we set
out to do,w
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IV-9
OBJECTIVE 6: IMPROVE QUALITY
ASSURANCE/QUALITY CONTROL
This objective involves activities that will improve the
quality of ground—water monitoring data. The objective implies
that improving quality assurance and quality control procedures
would contribute toward the overall improvement of ground—water
monitoring. This objective seeks to answer the question, How
good are the data ?
Many comments about current ground-water monitoring activi-
ties have suggested that steps toward this objective would be
very valuable in both improving the reliability and usefulness of
ground—water monitoring data and in adding new value to future
data collection efforts. A part of this value would be to enable
data users to know the accuracy and validity of the information
with which they are working.
This objective could include, for example, the development
of sampling protocols, standardized well construction and sampl-
ing mechanisms, as well as certain lab analytical procedures and
methods.
Supporters of this objective typically say:
“If only we could have some uniform standards of data quali-
ty, I would be able to use so much more of the data present-
ly collected that many fewer new monitoring efforts would be
necessary.”
“As more ground—water monitoring is performed over the next
few years, we should place top priority on ensuring top
quality control and quality assurance so all of us can use
that information, no matter who initially collected it.”
“Let’s be sure we don’t set procedures in concrete—-the state
of the art is moving too quickly.”
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IV —l U
OBJECTIVE 7: IMPROVE DATA MANAGEMENT
This objective involves activities categorized broadly as
data management improvement. It includes activities such as
determination of data to be collected, protocols on data entry,
and standardized database formats. This objective seeks to
answer the question, Where and how accessible are the data ?
The objective would lead to activities that improve data
availability and accessibility through greater compatibility of
ground—water databases. Examples of these activities include
definitions of terms and procedures, standard data reporting
formats, and other activities that enhance the ability of deci-
sion makers to decide what threats to drinking water exist and
how they should be addressed.
Supporters of this objective typically say:
1 know there is a lot of data out there which would be of
great value to my program if I could access it and then
understand it through the use of some standard formats or
common data systems.”
“Much data never sees the light of day. It is stored in ways
that no one other than its originator can make any sense of
it. Improv uents here would bring big benefits with little
cost •“
“If you can’t get at the data, you can’t use it.”
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V. MONITORING APPROACHES
To carry out the objectives of a ground—water monitoring
strategy, it is necessary to identify the activities that may be
undertaken in support of those objectives. This chapter identi-
fies a range of monitoring approaches that might support the
objectives of a ground—water monitoring strategy. These repre-
sent alternatives to implementing the particular objectives of a
monitoring strategy.
For the purpose of developing a strategy, it is necessary to
select the monitoring approach that is most appropriate to carry
out a particular objective. Therefore, it is important to evalu-
ate all major approaches for each monitoring objective and con-
sider how each objective can be achieved most efficiently and
effectively. Perhaps most important from EPA’S perspective, the
approach that is selected should be consistent with and support-
ive of an agreed—upon ground—water monitoring strategy.
In considering the activities through which monitoring ob-
jectives may be implemented, it will also be important to keep
discussion and debate broadly focused and policy oriented rather
than narrowly focused and program— or problem—specific. These
activities, or monitoring approaches, were summarized in
Table 111-1 and are described in the pages that follow.
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V-2
APPROACHES TO ACHIEVE OBJECTIVE 1:
MONITOR TO CHARACTERIZE GROUND-
WATER RESOURCE
This objective involves broad-based monitoring activities
aimed primarily at collecting background data on the ground—water
resource and its setting. This objective would answer the ques-
tion, What is the nature of the ground—water resource ? The major
approaches that have been suggested for accomplishing that are
listed below.
A. Survey Existing Data
Under this approach, characterizing the ground—water re-
source would be accomplished by reviewing existing data and
literature on ground water in a particular area. Sources of
information would include state and federal agency reports and
surveys, and public water utility reports. This information
would be compiled and summarized to gain the maximum benefit from
all the existing data.
A representative comment on this approach follows:
“There is enough information already collected to enable
us to describe ground—water resources throughout the
United States. All we need to do is gather the inf or—
mation that’s out there and organize it so we can use it.”
B. Expand Use of Existing Monitorir ,g
This approach involves collecting additional information on
the ground—water resource from existing wells and monitoring
programs. This would be done where data do not provide enough
information on the ground-water resource and where additional
information could easily be obtained. Some might be obtained by
redirecting current monitoring efforts, for example, by perform-
ing additional testing or utilizing different monitoring equip-
ment or procedures to collect data. Other efforts might even
include collecting samples at wells that are not presently being
monitored.
A representative comment on this approach follows:
“There is a lot of information on ground water that we
can use, but the incremental value of additional inf or-
mation is large enough to warrant additional monitoring
from wells that may or may not be monitored now.”
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V-3
C. Drill New Wells on Targeted Basis,
Such as USGS Basin Surveys
One approach to collecting background data is a “moving
network,” i.e., the establishment of new wells and of a monitor-
ing program in a particular area over a specified period of time.
The USGS periodically conducts such “basin surveys” to study
aquifer systems, characterize the ground—water resources of a
state or region, and collect new information where existing wells
and monitoring data are insufficient to characterize the ground-
water resource.
A representative comment on this approach follows:
“To do an adequate job of describing the ground-water
resource in a particular area, we should drill enough
new wells to get the information we need.”
D. Design Broad, Fixed Network
of New Wells
Under this approach a “fixed network” of new wells would be
developed to monitor ground water for long periods of time over a
wide geographical area. This approach would depend on the data
requirements of the investigating agency or organization.
A representative comment on this approach follows:
“We don’t know enough about ground—water resources in
many parts of the country. The only way to get the
data is to develop bigger and better networks of moni-
toring wells where monitoring goes on for a long time.
In many areas it would be helpful to monitor ground-
water movement over a long period of time so we can
understand better the characteristics of a region’s
aquifers.
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V-4
APPROACHES TO ACHIEVE OBJECTIVE 2:
MONITOR TO IDENTIFY NEW PROBLEMS
Monitoring under this objective involves identifying new
problems of contamination or types of activities that may be
causing such contamination. In contrast to the first objective,
it does not involve broad data but focuses on specific contamina-
tion sites. The objective aims to answer the question, Where are
the problems ?
A. Target Monitoring by Land/
Ground—Water Use
One option for identifying new problem sites is to target
monitoring in areas that could be identified as “high risk”
areas. These would presumably be areas in which there was a high
likelihood of contamination as well as a high dependence upon
ground water. The targeting could probably best be done on the
basis of land or ground—water use.
A representative comment on this approach follows:
“The best way to identify contamination is to look at
places that are the most likely sources of contamina-
tion——like chemical plants, gas stations, factories,
etc. If you want to look for problems, shouldn’t you
start with the most likely polluters?”
B. Scout for Problem Sites or Types
Rather than conduct extensive land/ground-water use surveys
or investigations, another option is to “scout” for problem sites
or types. This option differs from Option A in that it would
seek to identify areas of contamination on a focused, site—
specific basis rather than on a broad, generic basis. Scouting
would involve field work to identify problem sites, or stated
differently, “patrolling” for problems.
A representative comment on this approach follows:
“It’s too expensive to look for problems on a generic
basis. Why not just look in your own ‘backyard’--look
for pollution where you suspect it is most likely to
occur and do the most damage.”
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V-5
C. Establish Public Hot Line
with Government Response
Another way to identify new problems would be to establish a
government hot line to which ground—water users could phone in
problems with water quality (“bad taste,” “funny odor,” “strange
color,” etc.). In this way, users could identify possible con-
tamination of ground water by monitoring ground water “at the
tap.” A government agency would manage the hot line and develop
procedures for investigating reports of contamination.
A representative comment on this approach follows:
“We need to find a way to let people report problems
with their water and get quick action to investigate
these problems. A hot line——like the one for reporting
spills of hazardous waste——would be an easy way to
identify problems with ground water and would spare us
a lot of unnecessary monitoring. Shouldn’t we focus
our efforts where people need our attention?”
D. Create Incentives or Requirements
for Private Sector
Private industry would be encouraged to conduct ground—water
monitoring investigations on a routine basis at sites or facili-
ties determined to be possible or probable sources of ground-
water contamination. Incentives could include increased or
reduced liability where contamination is detected through govern-
ment or self—monitoring, respectively, or tax credits for
installing monitoring wells. Monetary rewards could also be
offered to anyone discovering new contamination.
A representative comment on this approach follows:
“The private sector needs to carry its share of the
burden of identifying contamination problems. Incen-
tives or rewards might be a good way to get private
industry to do its share of the work.”
E. Desi n Network of Wells
( National or State )
Under this option, new instances of contamination would be
identified by means of a network of wells that monitor ground-
water quality on a continuous basis. This network of new wells
or existing wells not currently monitored would be used to review
regional ground—water problems.
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V-6
A representative comment on this approach follows:
“Since monitoring is often done on a sporadic or site—
specific basis, it is difficult to assess the potential
for new problems on a regional basis. By designing a
network of wells we can collect enough information to
begin to identify contamination problems before they
become serious and widespread and deal with them in an
appropriate manner.”
F. Require Sampling by
Ground—Water Users
Users of ground water would be required to sample well water
at the well and at the tap periodically as a check on water qual-
ity. Well sampling would be conducted by water systems that make
large ground—water withdrawals.
A representative comment on this approach follows:
“Sampling at the well or at the tap is a ‘quick and
dirty’ way of identifying contamination problems. You
don’t need to drill new wells or design new systems to
do this——just monitor wells that are usually never
sampled.”
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V-7
APPROACHES TO ACHIEVE OBJECTIVE 3:
MONITOR TO ASSESS KNOWN PROBLEMS TO
SUPPORT REGULATORY AND STANDARD SETTING
AND RESPOND TO SITE-SPECIFIC PROBLEMS
This objective addresses monitoring to assess known problems
in order to support regulatory and standard-setting requirements
and respond to site—specific problems. Monitoring to achieve
this objective involves answering the question, How serious is
the problem? , or determining the source and extent of contamina-
tion.
A. Conduct Direct Government Monitoring
A government agency or group of agencies would design, in-
plement, and evaluate monitoring programs to assess the extent of
contamination and take appropriate regulatory steps to control
the problem.
A representative comment on this approach follows:
“The government has a responsibility to carry out
ground—water monitoring. It has the experience, the
resources, and the knowledge to conduct monitoring
investigations.”
B. Create Incentives or Regulations
for Private Sector
Private industry would be encouraged to conduct ground—water
monitoring investigations on a routine basis at sites or facili-
ties determined to be sources of ground-water contamination.
Incentives could include increased or reduced liability where
contamination is detected through government or self-monitoring,
respectively, or tax credits for installing monitoring wells.
A representative comment on this approach follows:
“Many contamination problems come from industrial plants
and processes. Private industry should be responsible
for cleaning up the mess it creates. Let’s make it
easy for industry to monitor polluted ground water.”
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V—8
C. Regulate Source Operators and
Manufacturers of Chemicals
Such as Pesticides
The operators of facilities that may be or are known to be
sources of ground—water contamination would be required to con-
duct monitoring investigations on—site and/or change operating
procedures to eliminate the threat to ground water posed by
wastes frau industrial processes.
A representative comment on this approach follows:
“Polluters will only monitor ground water they have
contaminated if we require that they do so.”
D. Require Sampling by
Ground-Water Users
Users of ground water would be required to sample well water
“at the well” and “at the tap” periodically as a check on water
quality.
A representative comment on this approach follows:
“We won’t know how serious and widespread contamination
is until we monitor as many wells as possible. The
easiest way to do this is to require sampling by users
of ground water in the affected area.”
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V-9
APPROACHES TO ACHIEVE OBJECTIVE 4:
MONITOR TO ENS tJRE COMPLIANCE WITH
REGULATIONS
Monitoring under this objective is aimed at determining if
ground—water contamination has been or is being caused by viola-
tions of standards or regulations. It is generally intended to
lead to initiation of enforcement or corrective actions at a
specific site. This objective seeks to answer the question, To
what extent is compliance being achieved ?
A. Rely on Design Standards
Without Monitoring
A government agency or group of agencies would rely on de-
sign standards for activities that could, if not properly de-
signed, cause ground—water contamination. These standards would
apply to landfill liner design, underground injection well de-
sign, pesticide application, and other land use activities that
may have an impact on ground water.
A representative comment on this approach follows:
“It is better to design sites so they don’t leak rather
than monitor after leaks are discovered”
B. Require Self—Monitoring
Private industry would be required to conduct ground—water
monitoring investigations at sites or facilities determined to be
sources of ground—water contamination to ensure compliance with
regulations. Self—monitoring might be extensive at high risk
sites or minimal at low risk sites. Extensive monitoring might
also be required at the first signs of contamination.
A representative comment on this approach follows:
“Due to the high expense of monitoring, these costs
should be borne directly by the regulated community and
not by any governmental agency.”
C. Create Financial Incentives
for Self-Monitoring
Private industry would be encouraged to conduct ground—water
monitoring investigations on a routine basis at sites or facili-
ties determined to be sources of ground—water contamination to
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v-b
ensure compliance with regulations. Incentives would include
increased or reduced liability where contamination is monitored
through government or self—monitoring, respectively, or tax
credits for installing monitoring wells.
A representative comment on this approach follows:
“Financial incentives may be a more effective means of
being certain that monitoring is done to ensure compli-
ance with regulations.”
D. Contract for Third-Party Monitoring
Government agencies would develop and evaluate monitoring
programs, but the private sector would contract with third par-
ties (consulting/engineering/auditing firms) to install and
sample monitoring wells. Under this option, a government agency
would not actually conduct monitoring but would use data supplied
by third—party contractors to make compliance evaluations.
A representative comment on this approach follows:
“Data collected by the regulated community or regulators
will always be suspect. Only certified third parties
can be relied upon for compliance data.”
E. Conduct Government Monitoring
A government agency or its representative would develop,
conduct, and evaluate monitoring programs designed to ensure that
the regulated community is in compliance with regulations per-
taining to ground—water contamination.
A representative comment on this approach follows:
“Just making the rules is not enough. Government has to
take the lead in ensuring compliance with those rules.”
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V-li
APPROACHES TO ACHIEVE OBJECTIVE 5:
MONITOR TO EVALUATE PROGRAM EFFECTIVENESS
This objective involves collection of ground—water monitor-
ing data to measure regulatory effectiveness. The data would
answer the question, Is the program achieving its objectives and
are the program targets correct ?
A. Utilize Compliance Monitoring
Information
Under this option, government agencies would use information
from compliance monitoring activities to evaluate the effective-
ness of their ground—water programs. Even though data are not
collected expressly for this purpose, program managers could make
“reasonable judgments” about whether programs are working based
on compliance records and data.
A representative comment on this approach follows:
“Given the vast amount of compliance monitoring data
currently available, these sources of information
should be used to evaluate program effectiveness.”
B. Monitor on Complaint Basis
Ground—water monitoring to evaluate program effectiveness
would be done only after complaints or inquiries about a particu-
lar program or problem were received from private citizens, pri-
vate organizations, government agencies, or legislators. The
frequency and type of complaints, as well as follow—up investiga-
tions of specific complaints, will provide an indication of how
well programs are working.
A representative comment on this approach follows:
“As with many programs, it’s the squeaky wheel that gets
the grease. Individual observers are in the best posi-
tion to provide information on program effectiveness.”
C. Conduct Audit Sampling
Monitoring would be conducted to measure key ground—water
parameters determined to be important for evaluating ground—water
programs. This monitoring would be done on a routine audit basis
by ground—water program managers as a way to measure trends in
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ground—water quality and, thereby, to evaluate the relative
effectiveness of ground-water programs designed to protect
ground-water quality.
A representative comment on this approach follows:
“Just as certified public accountants verify financial
data by spot checks, those evaluating program effec-
tiveness can achieve their objectives in a similar
fashion . N
D. Design and Establish
Network of Wells
Under this option, a network of monitoring wells would be
established using existing wells not currently used for monitor-
ing and/or new wells installed expressly for monitoring. The
purpose of this network would be to collect data to evaluate
changes in ground—water conditions over time and, thereby, to
measure the relative effectiveness of ground—water programs
designed to improve such conditions.
A representative comment on this approach follows:
“Evaluating many programs requires a broad and extensive
network of wells in order to collect enough data to
make accurate evaluations. For example, monitoring of
croplands is necessary to determine if programs are
successful in reducing the migration of pesticides into
ground water.”
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APPROACHES TO ACHIEVE OBJECTIVE 6:
IMPROVE QUALITY ASSURANCE/QUALITY CONTROL
This objective involves activities that will improve the
quality of ground—water monitoring data, such as the development
of sampling protocols, standardized well construction and instal-
lation techniques, and common analytical procedures. It would
answer the question, How good are the data ?
A. No Change
Current drilling, sampling, and laboratory procedures are
adequate to ensure an acceptable level of data quality. This
status quo approach suggests that differing standards and proce-
dures are appropriate for different purposes.
A representative comment on this approach follows:
“Monitoring programs vary so widely in objectives and
procedures that any attempt to create uniform standards
will reduce the effectiveness of every single
program.”
“No single organization should dictate to the larger
community how to do its work.”
B. Establish Criteria/Standards
for Labs and Drillers
A government agency would determine certification standards
for both individuals and organizations that conduct monitoring.
Criteria for certification would be developed to address the need
for qualified individuals to conduct monitoring and for reputable
organizations to support their activities and provide pertinent
data.
A representative comment on this approach follows:
“Ground—water monitoring data varies in quality so much
that a good deal of it is not useful. If we could only
establish standards or certification for professionals
in this field as other professions have (e.g., P.E.,
C.P.A.), then we would have much greater assurance of
high quality data.”
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C. Regulate Labs and Drillers
A government agency would establish regulations on how to
conduct monitoring. These regulations would specify which proce-
dures to use in conducting monitoring investigations and how to
perform them correctly.
A representative c nment on this approach follows:
“In order for ground-water monitoring to be done cor-
rectly, we must tell those conducting monitoring what
procedures to follow. This would be the most effective
way to ensure higher quality data.”
D. Establish Guidelines, Provide
Information/Education for
Drilling, Testing
A government agency would establish guidelines for conduct-
ing monitoring activities and provide information to help drill-
ers and laboratories operate accordingly. Guidance would be
provided on procedures, materials, and standards for well instal-
lation and construction, sample collection, and lab analysis.
A representative comment on this approach follows:
“People involved with ground—water monitoring data are
responsible enough to improve the quality of monitoring
data if more information or education were available..”
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APPROACHES TO ACHIEVE OBJECTIVE 7:
IMPROVE DATA MANAGEMENT
This objective involves activities that would lead to im-
proved data availability, accessibility, and usefulness through
greater compatibility of ground—water databases. It would answer
the question, Where and how accessible are the data ?
A. Do Not Standardize (No Change )
Given the variety of users and uses of monitoring data, it
is neither necessary nor efficient to standardize current data
management practices.
A representative comment on this approach follows:
“The broad variety of ground—water monitoring activities
requires many different databases and data structures.
No standardization could be achieved without force-
fitting these data.”
B. Decentralized Databases; Standardize
Content, Type, and Formats
States and localities would manage their own databases but
make an effort to standardize at least some of the information to
make it comparable with what other states and federal agencies
collect. Standardization would facilitate the interpretation and
use of data.
A representative comment on this approach follows:
“By acknowledging the differences in data needs but
still seeking the benefits of comparability across
states and programs, this approach may offer the best
of both worlds.”
C. Decentralized Databases with
Accessibility and Compatibility
States would manage their own databases but utilize common
procedures so that, when the need arises, data can be exchanged
easily (electronically) among the states and with the federal
government.
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A representative comment on this approach follows:
The most important advance in data management would be
to let ground—water monitoring data users access each
other’s data. This alone would move the state of the
art forward significantly. TM
D. Create National Computer Database
States would mange their own databases, supplying informa—
tion to a national database that would serve national regulatory
and program management purposes and assist states that need
information beyond their own borders.
A representative comment on this approach follows:
TM On]y a national database would provide sufficient data
compatibility and accessibility. Decentralized systems
will fail to achieve these o bjectives since individual
users will inevitably tailor them to their own needs.
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VI. ROLES AND RESPONSIBILITIES IN SUPPORT OF EPA
AND STATE GROUND-WATER STRATEGIES
This chapter deals with the range of roles and responsibili-
ties that is available for managing the implementation of a
ground-water monitoring strategy. The roles to be played by
federal, state, and local governments and other interested par-
ties should be considered within the context of the EPA ground-
water protection strategy and state ground—water strategies. The
definition of these roles requires balancing significant national
interests on the one hand with state and local interests on the
other hand. Public and private sector interests must also be
measured and balanced.
There are many possible roles for government agencies and
other parties in planning for and conducting ground—water moni-
toring. It may be that different roles are appropriate in dif-
ferent areas. In debating these issues it might be helpful to
consider the following questions:
• In general, which roles do you prefer for each monitor-
ing approach?
• Which roles are most appropriate for each monitoring
approach?
• Do roles differ for various ground—water problems?
The summary below describes the major strategic alternatives
for these roles.
SUMMARY OF ROLES
Option 1: The Federal Government
Conducts Monitoring
The federal government would develop, implement, and carry
out all national monitoring programs. States would have limited
responsibility for additional monitoring to support the national
ground—water strategy. Comments about federal control over
ground—water monitoring activity include the following:
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V I —2
“Only the federal government can bring sufficient re-
sources and experience to bear on ground—water problems
that require investigation through monitoring. The
difficulties in standardizing data collection and anal-
ysis and in utilizing monitoring data are sufficient
reasons for such a federal role.”
“The national dimensions of ground—water contamination
require a national approach to remediation that can
only be implemented through federal action.”
Option 2: The Federal Government
Sets Standards and Technical
Requirements in Consultation
with States While States Conduct
Monitoring
Federal requirements for state monitoring activities would
be developed by the EPA or other appropriate federal agencies in
consultation with state agencies in order to standardize state
approaches to monitoring and make them consistent with the goals
of the EPA ground—water protection strategy. Federal and state
governments would specify sampling protocols, standardized data
forms for recording and reporting information on ground water,
and other monitoring requirements. States would then be respon-
sible for the actual design and installation of wells and well
networks and collection and analysis of data. Comments that
support these roles include:
“States generally desire improved coordination of data-
bases and provisions for standard terms and formats
with a strong federal role.”
“If EPA plans to have an effective long-range ground-
water monitoring program, a minimum standard should be
established and support should be made available to
meet this standard. This would allow the states to
have more intensive monitoring programs if they want
more information in their specific programs.”
Option 3: States Design and Conduct
Monitoring with Federal Approval
This approach would delegate authority to state governments
to develop and implement programs that are designed to meet na-
tional, regional, and local needs. The federal government would
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establish some minimum requirements while the states would devel-
op their own programs and su1 nit program plans to the federal
government for approval. Comments about this view include:
“If the states develop their own monitoring programs to
suit their individual needs, how will we use their
information to develop national measures of ground-
water quality? We must be sure the states develop
monitoring programs that not only address local pro—
grains but also meet the nation’s needs for information
on its ground—water resources.”
Option 4: States Design and Conduct
Monitoring with Federal Guidance
and Information
Under this option, the states would be responsible for all
aspects of planning, implementation, enforcement, and evaluation
of their monitoring programs. EPA and other federal agencies
would be consulted for clarification of federal guidelines, sug-
estions on approaches to monitoring, and information on monitor-
ing based on federal agencies’ experience. Comments about this
framework include:
“The best use of federal resources and experience would
be to have EPA, USGS, and other agencies provide pro-
gram and technical guidance and information as re-
quested by the states.”
“Rather than require agency approval of state programs,
the federal government would provide the states with
information on monitoring technologies and databases
and make non—binding program recommendations to state
agencies. In this sense the state/federal relationship
would be an advisory one with the federal government
acting as consultant to the states.”
OptiOn 5: States Design
and Conduct Monitoring
State governments would be responsible for designing and
implementing ground—water monitoring programs that reflect the
particular needs and problems of a region or locality. The fede-
ra]. government could be consulted but would have no responsibil-
ity for programs or their design. Comments on this option in-
clude:
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“States must have control over their own monitoring programs.
Ground—water supply and contamination problems are too site—
specific to be managed by a federal agency.”
“The states have done a good job of developing ground—water
programs. They should take the lead in ground—water moni-
toring.”
Option 6: Localities Are Responsible
for Monitoring with State Assistance
Local governments would design and implement ground—water
monitoring programs according to local needs. State agencies
would provide technical and other support to localities as re-
quested by local municipalities. Reviewers of this framework
suggest:
“Most ground-water problems are local in nature and
therefore demand local attention and action from local
governments. However, local governments often cannot
design monitoring programs and might require additional
resources in order to conduct monitoring activities.”
“State agencies should provide localities with the as-
sistance necessary to enable local officials to conduct
or contract for monitoring.”
Option 7: Localities Are
Responsible for Monitoring
Local governments would design and implement ground—water
monitoring according to local needs. The state and federal gov-
ernment would not participate in ground—water monitoring investi-
gations. Comments about this framework include:
Local governments should be responsible for identifying
and addressing ground—water problems in their jurisdic—
tion. They should take a more active and aggressive
role in monitoring local sites and operate independ-
ently of state or federal agencies.”
Option 8: Private Sector
Incentives and Requirements
State and federal governments would separately or together
provide incentives to private industry to conduct ground—water
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VI-5
monitoring investigations. Incentives to the private sector
might include reductions in liability where contamination is
detected through self—monitoring rather than through state or
federal monitoring, or alternatively, increases in liability
where contamination is detected through state or federal monitor-
ing; and tax credits to firms that install monitoring wells at
their own expense or with financial assistance from the state or
federal government. Comments on this option include:
“Private firms should assume greater responsibility for
monitoring ground water, and it is incumbent upon gov-
ernment to encourage the private sector to do so.
Private monitoring can be an effective way to monitor
possible or probable sites of contamination.”
Option 9: End—User Monitoring
Federal and/or state environmental agencies would either
require or support ground-water monitoring at the well and at the
tap. The states and/or the federal government may require
point—of-use sampling and/or offer incentives to comply with such
regulations. Comments about this concept include:
“This is a way to monitor existing domestic water wells
on a routine basis without installing new wells or
designing new monitoring networks.”
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VII. INTEGRATION OF RECOMMENDATIONS
After completing the presentations on objectives, monitoring
approaches, and roles and responsibilities, each work group will
consider how to combine its recommendations on these three topics
into a coherent monitoring strategy. Work groups will review
their work to decide whether the options that they have selected
can be integrated into a strategy or must be changed to develop a
more unified and internally consistent monitoring strategy. In
developing final recommendations, it may be useful to review the
discussion in Chapter III on strategy development and, in partic-
ular, Table Il l—i.
It will be important to consider again the following cri-
teria in evaluating and integrating work group recommendations:
• Economic and technical feasibility of the options se-
lected
• Relative costs of the options selected
• Relationship of the options to ongoing programs
• Response of appropriate decision makers to the options
selected
• Information necessary to implement the options selected
In addition, an integrated strategy should consider the uses
of monitoring data and the decisions that may be based on this
information. This focus on decisions will ensure that the
ground—water monitoring strategy identifies useful approaches to
the collection of data and where and how to use data to support
decision making.
Each work group will present its final set of recommenda-
tions to the workshop assembly and invited guests, including EPA
officials and staff. At that time, work groups may be asked to
clarify their recommendations and respond to questions pertaining
to their presentation. The final reports of the work groups will
constitute a major input to EPA ’s ground—water monitoring strat-
egy and serve as a basis for developing a more integrated state
and federal approach to ground—water monitoring.
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