UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OSWER Directive 9283.1-09
OFFICE OF
SOLID WASTE AND EMERGENCY
RESPONSE
MEMORANDUM
SUBJECT: The Role of CSGWPPJi
FROM:
TO:
PURPOSE
Timothy Fields, Jr.
Acting Assistant Ad
Regional Administrators
Regions I-X
This Directive recommends that EPA remediation programs be familiar with
Comprehensive State Ground Water Protection Programs (CSGWPPs) and utilize them as a
means of giving more flexibility to a State for management of ground-water resources. EPA's
ground-water remediation programs - Superfund, RCRA Subtitle C and D, and Underground
Storage Tanks - have an important stake in the CSGWPP process. More specifically, this
Directive establishes the policy that EPA remediation programs generally should:
t Defer to State determinations of current and future ground-water uses, when based on an
EPA-endorsed CSGWPP that has provisions for site-specific decisions;
• Participate in EPA's review and endorsement of CSGWPPs; and
• Use other CSGWPP provisions, as appropriate, for more effective or efficient program
implementation (e.g., increased program emphasis in geographic areas identified in a
CSGWPP as having highfcl&Sfl&e value or priority).
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For the Superfund program the policy, stated above, is intended to revise and supersede
guidance provided in the Preamble to National Contingency Plan (NCP),’ as discussed under
Implementation (Section A) of this Directive.
Background information on CSGWPPs is provided below. More detailed discussion of
when EPA should defer to State determinations of future ground-water use is provided under
Implementation, Section A. Discussion of EPA involvement in the CSGWPH review and
endorsement process is provided in Section B, and the role of other CSGWPP provisions in EPA
remediation programs is discussed in Section C.
BA CKGROUND
One of the primary purposes of a CSGWPP is to provide a framework for EPA to give
greater flexibility to a State for management and protection of its ground-water resources. Such a
program was first envisioned in EPA’s Ground-Water Strategy for the 1990s,2 which states that:
“To the extent authorized by EPA statute and consistent with Agency program
implementation objectives, EPA will defer to State policies, priorities, and standards once
a State has developed an ‘adequate’ program.”
EPA’s CSGWPP Guidance
Guidance describing what the Agency meant by an “adequate” ground-water program
was issued in 1992. This document, entitled Final Comprehensive State Ground Water
Protection Program, 3 identified six Strategic Activities that should be included in a
Comprehensive State Ground Water Protection Program to be considered “adequate” by EPA.
(Readers of this Directive are strongly advised to read the 1992 Final CSGWPP guidance to gain
a more complete understanding of the CSGWPP approach.) The Strategic Activities identified in
the 1992 Final CSGWPP Guidance are listed in Attachment 1.
The 1992 Final CSGWPP Guidance describes how developing a CSGWPP is a three.1
stage process. First, a State develops a Core CSGWPP and submits it to the EPA Regional office
for review and endorsement. (The review and endorsement process is discussed under
Implementation, Section B.) The Core Program need include only one around-water
protection or remediatior program to demonstrate whether the State’s CSGWP? approach is
‘Thc “N onn1 oil and Hazardous Substances Pollution Contingency Plan, Final Rule” (NCP) provides the
regulatory framework for the Superfiznd program The NCI was published in 1990 in Volume 55, No. 46, March 8,
1990 of the Federal Regiszer and is included in the Code of Federal Regulations (CFR) as 40 CFR Part 300.
“Protecting the Nations Ground Water: EPA’s Strategy for the 1990s,” Publication 2 IZ- 1020, Office of
the Administrator, July 1991.
‘EPA publication: EPA lOO-R-93-OO1, Office of the Administrator, December 1992.
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consistent with the guidance. Several States have already developed or are developing a Core
CSGWPPJ as indicated in Attachment 2. Second, after the Core Program is endorsed by EPA,
joint State-EPA discussions should result in a “multi-year planning agreement” for incorporating
additional State and EPA programs into the CSGWPP, leading to a “Fully Integrating
CSGWPP.” The Core CSGWPP provides the basis for multi-year planning discussions.
Third, at the completion of the multi-year planning and implementation processes, a “Fully
Integrating” CSGWPR occurs when the six previously mentioned Strategic Activities
fundamentally influence and are supported by the day-to-day operations of J1 federal, state and
local ground-water related protection and remediatioll programs. Adequacy criteria, which
describe what EPA expects from a State for both a Core and Fully Integrating CSGWPP. are
described in the 1992 Final CSGWPP guidance.
EPA Commitments Supporting CSGWPPs
In the 1992 Guidance, EPA recognized that fundamental changes within its own
programs were just as much a prerequisite to achieving a Fully Integrating CSGWPP as the
Strategic Activities that a State needs to undertake. EPA documented its willingness to change
its own programs in a document entitled, EPA ‘.s Commitments to Support Comprehensive State
Ground- Water Protection Programs. 4 This document identified specific actions, that EPA has
already taken, will take, or will evaluate for future action to support CSGWPPs. The primary
focus of the commitments is to provide the States enhanced flexibility for setting their own
priorities and promoting greater State- and community-based decision making. The 1995
commitments reflect only the first set of EPA actions to support States developing CSGWPPs.
EPA will continue to review proposals for futuref actions and program changes that could
improve comprehensive ground-water protection.
CSGWPPS and Performance Partnership Agreements
A Performance Partnership Agreement (PPA) is a broad strategic document containing a
joint statement of priorities and goals negotiated between a State and an EPA Region. It is also
called an Environmental Performance Agreement. States that have negotiated or are in the
process of negotiating PPAs may have accomplished some of the critical activities needed for a
CSGWPP. For States that have an EPA-endorsed CSGWPP, the CSGWPP can become part of a
PPA and would constitute the State’s priority setting policy for ground-water protection and
remediation. For further’ information concerning PPAs, refer to the EPA fact sheet entitled
State/EPA Pe fonnance Partnerships’.
‘EPA Publication EPA lOO-R-95-002, Office of the AdministlBlorJ June 1995.
3 Publication lOO-F-96-024, Office of Regional Operations and State/Local Operations, October 1996.
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CSGWPPS and EPA Remediatioi Programs
The overall goal of EPA remediation programs is to protect human health and the
environment. With respect to ground water, this goal includes taking actions to prevent ground-
water resources from becoming contaminated in the first place, preventing unacceptable
exposures of humai and ecologic receptors to contaminated ground water, and remediating
contaminated aquifers to beneficial uses where practicable. EPA recognizes the limited
resources available for ground-water protection and remediation, the need to prioritize these
activities, and the central role of the States in making ground-water protection and remediation
decisions. EPA anticipates that the CSGWPP process will be the vehicle by which EPA and the
States can come to a mutual understanding of regulatory requirements, policies and priorities that
influence ground-water protection and remediation decision making.
In developing a Core CSGWPP, EPA generally expects a State to devise guidelines to
classify and/oil prioritize ground waters based upon their current use, expected future use,
vulnerability to contamination, resource value, or similar factors. Such resource-based
classifications or priorities can then be used by the State and EPA for a variety of purposes,
including:
• Program planning, so that protection and remediation efforts can be emphasized in
geographic areas with high priority ground waters (see Implementation, Section C); and
• Program decision-making, in which current and expected future uses (or other factors
such as resource value) are an important factor in decisions regarding remediation of
contaminated sites.
However, the Agency’s experience with Core CSGWPPS developed to date is that they
generally cannot be used for the site-specific decisions made by EPA remediation programs,
because they either:
• Define broad scale (e.g., basin-wide) classifications or priorities that cannot be applied to
ground waters at specific sites; or
• Do not define a basis for distinguishing among ground-water resources within the State
(i.e. all ground waters have the same expected use or priority).
Implementation of EPA remediation programs requires that assessments and remediation
decisions be made at specific sites or facilities. Thus, if a CSGWPP is expected to provide
comprehensive guidance to EPA concerning remediation decisions, it should have provisions
which allow ground-water classifications or priorities to be determined at a specific site
anywhere in the State. For example, if a Core CSGWPP defines high value ground waters
(and/oi those of low value) and is expected to be utilized in remediation decisions, the definition
should include criteria which allow the resource value of ground water to be determined at a
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specific site anywhere in the State. Also, for this example, EPA and the State should have
reached agreement on how the resource value of ground water is to be utilized in remediation
assessments or decisions. Further discussion of CSGWPTh provisions that support site-specific
determination of ground-water classification or priority is provided under Implementation,
Section A, of this Directive.
In general, a Core CSGWPPI that provides no mechanism for distinguishing among
ground waters of the State provides less usefu! information for site-specific remediation
decisions than a CSGWPP that does draw distinctions among different ground-water resources.
Further, such a CSGWPP does not meet the intent of EPA’s 1992 CSGWPP guidance which
expects a Core CSGWPP to provide some method for establishing priorities among ground-water
resources based on ground-water characteristics and/or other factors. 6 For a CSGWP? that
defines all ground waters as a source of drinking water or as high priority, EPA remediation
programs should work with other EPA and State programs during the CSGWPP review process
(see Implementation, Section B) to develop criteria which can be used to fuithef distinguish
among the State’s ground waters at specific sites (see Implementation, Section A).
EPA recognizes that not all States plan to develop a ground-water classification system as
part of their Core CSGWPP. As an alternative approach, a CSGWPP may define the relative
value, priority or vulnerability of ground-water resources rather than current and expected future
uses. For a CSGWPP that does not define current and future ground-water uses, EPA
remediation programs should work with other EPA and State programs during the CSGWPP
review process to cIarif r how the relative value, priority or vulnerability will be used to make
assessment or remediation decisions at specific sites.
IMPLEMI NTATION
A. F PA Deferral to State Determinations of Future Use
Current Practice
Determining current and future uses of contaminated ground waters at a particular site or
facility is important for all EPA remediation programs. These programs consider ground-water
uses when assessing the risks posed by the contamination, determining appropriate remedial
objectives, and in setting appropriate cleanup levels when ground-water restoration is an
objective. In the Underground Storage Tank piogram, site-specific cleanup requirements
generally are established based on the current and fiiture risks posed by the site, including risk-
based cleanup levels for specific ground-water contaminants. In Superfiind and the RCRA
‘Tbi is called for by Core Adequacy Criterion 2 under Strategic Activity 2 (page 2-7) of the 1992 Final
cSGWPJ’ Guidance: “A State’s ground water priority-setting process is based primarily on consideration of varying
ground water characteristics such as those listed on Figure 2-1 on Page 2-18 [ of the 1992 guidance].”
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Subtitle C and D programs, drinking water standards 7 generally are used as cleanup levels for
ground waters that are determined to be a current or potential future source of drinking water.
Conversely, these programs generally do not use drinking water standards as cleanup levels for
ground waters that are not a potential source of drinking water; and for this case, cleanup levels
generally are determined from a site-specific evaluation of risk and receptors. For example,
appropriate cleanup levels for contaminated ground water flowing into surface water could be
based on ensuring protection of ecologic receptors, rather than direct ingestion of the ground
water by humans. Also, ground-water uses could include support of surface water ecosystems.
Thus, determining current and future ground-water uses Is necessary to determine the
potential risks posed by the contamination, and as a result, the remedlation objectives
and/or cleanup levels needed to protect human health and the environment.
Current practice in determining ground-water uses at a particular site or facility varies
somewhat among EPA remediation programs. EPA programs generally consider State ground.j
water classifications or similar State designations for determining current and futurd ground
water uses. For the Superfund’ program, guidance on this issue is provided in the NCP Preamble,
which recommends that the Agency’s 1984 Ground-Water Protection Srra1egy and .1986
Guidelines for Ground-Water Class qflcarion be used as guidelines for determining future use of
ground waters at a particular site. (These documents defined Class I, H and III ground waters.)
The Superfund program also considers State ground-water classifications in determining futurd
use, but the NCP Preamble advises that where State and EPA classifications result in different
ground-water use scenarios, the classification leading to the more “stringent” remediation goals
should be used. Thus, ground waters at a given site are generally assumed to be a future source
of drinking water if designated as such by the State or if considered to be a potential source of
drinking water under the 1986 Classification Guidelines. For any use scenario, Superflind
remedies must be protective of human health and the environment.
Policy Change for Superfund
For the Superfund program the policy of deferring to a State’s ground-water use
determination (discussed below) supersedes the guidance provided in the NCP Preamble
(discussed above). This policy change is necessary to make the Superfund program consistent
with EPA’s Strategy for the 1990s and the 1992 Final CSGWPP guidance. Although the NCP
Preamble is not part of the rule, it is used as program guidance. At the time it was written the
NCP Preamble was consistent with the Agency’s 1984 Ground-Water Protection Strategy and
‘DrinkinS water standards include maximum contaminant levels (MCLs) or nonzero Maximum
Contaminant Level Goals (MCLGs) promulgated under the Safe Drinking Water Act, more stringent State drinking
water standards, or risk-based levels for contaminants that do not have federal or State MCLs.
UwGrour*d..Wate11 Protection Strategy,” Office of Ground-Water Protection, August 1984.
9 ”Guidelines for Ground-Water Classification Under the [ 1984] EPA Ground-Water Protection Strategy,
Final Draft,” Oflicd of Ground-Water Protection, November, 1986.
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the 1986 Classification Guidelines, which have since been superseded by EPA ’s Strategj4 for the
1990..V and the 1992 Final CSGWPP guidance. The NCP Preamble states:
“If a state classification would lead to a less stringent solution than the EPA classification
scheme, then the remediation goals will generally be based on EPA classification.”O
For States that have a CSGWPP that has been endorsed by EPA and has provisions for
site-specific decisions, EPA will generally defer to State determinations of current and future
ground-water uses, as discussed below. For States that do not have an EPA-endorsed CSGWPP
or for CSGWPPs that do not have provisions for making site-specific determinations of ground
water use (or resource value, priority or vulnerability), the Superfund program will continue to
follow guidance provided in the NCP Preamble, as stated above. No policy change is needed for
the RCRA Subtitle C and D and Underground Storage Tank programs because these programs
already have the flexibility to defer, where appropriate, to State determinations of ground-water
use under a wide range of circumstances.
Deferral to EPA-endorsed CSGWPPs
Under this Directive, Superftind and other EPA remediation programs should generally
defer to a State’s determination of current and future ground-water uses, when based on criteria
or methodology that I) are specified in an EPA-endorsed Core CSGWPPJ and 2) can be applied
at specific sites or facilities. Under such a CSGWPP and except as noted below, EPA
remediation programs generally should defer to a State’s determination of ground-water
use even when it differs from the use that would otherwise have been determined by EPA
using the 1986 Classification Guidelines. As a result, EPA rcmcdiatioz programs should
generally assess site risks (e.g., the Baseline Risk Assessment for Superfund sites) and
establish remediation objectives and/or cleanup levels consistent with the CSGWPP-
determined ground-water uses.
Ground-water use determinations in previous remediation decisions, including Superfund
Records of Decision and permits or orders issued under RCRA Subtitle C or D authority, are
unaffected by this Directive or by EPA endorsement of a State’s CSGWPP.I EPA would follow
applicable requirements of the relevant remediation program in determining whether to change
any existing decision document, based on new information concerning the site or facility.
Exceptions to the above policy of EPA generally deferring to State ground-water use
determinations may be appropriate under certain circumstances. These exceptions are expected
to be rare for CSGWPPS that have been reviewed and endorsed by EPA remediation programs.
‘°NCi Preamble at page 8733.
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In general, it may be appropriate to depart from a State’s determination of current and future
ground-water use if the State’s determination:
• Is not consistent with the EPA-endorsed CSGWPP;
• Is not consistent with an existing, applicable State or federal statute or promulgated
regulation;
• Is based on technically incorrect or erroneous information;
• Affects an interstate aquifer and is not consistent with the use determination for this
aquifer in an adjacent State; or
• Would lead to selection of a remedy that EPA considers not sufficiently protective of
human health and the environment.
States have been authorized to implement some EPA remediation programs, such as the
RCRA Subtitle C and D and Underground Storage Tank programs. For States with an EPA -
endorsed CSGWPP, EPA expects that State determinations of ground-water use at specific
facilities to be assessed or remediated under these authorized or approved programs will
generally be consistent with the CSGWPP.
Provisions Supporting Site-specific Decisions
If a CSGWPP is expected to provide comprehensive guidance to EPA concerning
remediation decisions, the CSGWPP should have provisions which allow ground-water
classifications or priorities to be determined at a specific site or facility anywhere in the State, as
discussed above. In this Directive, CSGWPP provisions supporting site-specific decisions are
defined as factors, criteria or a methodology included in the CSGWPP for determining ground-
watet classifications or priorities at a specific site. Including these provisions in a CSGWPP will
ensure that these factors, criteria or methodology are consistently applied throughout the State.
Examples of physical characteristics and other factors that can be used to define the use, or
relative value or priority of ground-water resources at specific sites are provided in Figure 2-1
(page 2-1 8) of the 1992 CSGWPP Guidance. Also, EPA Region I has completed a regional
guidanc& 2 which identifies factors for determining ground-water “use and value” at a specific
site and explains how these determinations will generally be used by EPA remediation programs
11 Foê example the Safe Drinking Water Act and 40 CFR, Sections 144.3, and 146.3, define an
“underground source of drinking water.”
12 ”F(nal Groundwatei’ Use and Value Determination Guidance, A Resource-Based Approach to Decision
Making,” U.S. EPA Region 1, April 4, 1996. (For copies of this Region P guidance, contact Gloria Humd at (617)
573-5700.)
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in that Region. The Region I guidance provides a good example of an approach to site-specific
determination of ground-water resource priorities that can be included in a Core CSGV1PP or
developed as a separate EPA-State agreement subsequent to EPA endorsement of a Core
CSGWPP.
As discussed above, some Core CSCWPPs do not provide a basis for distinguishing
among ground-water resources within the State (Led all ground waters have the same expected
future use or priority). Although some States have statutes or regulations designating all ground
waters as potential drinking waters, the CSGWPP should include some method for setting
ground-water resource priorities within the State. Examples of factors or criteria which can be
used to distinguish among potential drinking waters on a site-specific basis are:
• Expected time frame of future use;
• Likelthood of use within a certain time period (e.g., 30 years);
• Relative priority or value; or
• Relative vulnerability of ground waters.
The types of site-specific provisions listed above are useful to EPA remediation programs
because, in addition to assessing risks and establishing cleanup levels based on expected ground.
water uses, these programs must evaluate alternative remedial measures and select those most
appropriate for a given site or facility. Different remedial measures often require substantially
different time periods to attain the remedial objectives. For example, remedial measures that
require a relatively long period of time to attain drinking water standards may be appropriate for
contaminated ground waters that are not expected to be used for this purpose in the near future.
A longer remediation time frame may also be appropriate for ground waters of lower priority or
resource value.
‘To support remediation under the Underground Storage Tank program, the CSGWPP
should also have a mechanism for providing site-specific flexibility in setting risk-based
remediation requirements, including cleanup levels for specific ground-water contaminants,
based on the current and future risks posed by the site.
Provisions that support site-specific remediation activities should be part of a Core
CSGWPP prior to EPA-endorsement when it includes an EPA remediation program (i.e., the
six Strategic Activities have been demonstrated using this program). When an EPA remediation
program is not part of the Core CSGWPP, additional provisions for site-specific decision-
making should be established in State-EPA negotiations during the subsequent “multi-year
planning” stage. When provisions specific to one or more EPA remediation programs are added
subsequent to EPA endorsement of the Core CSGWPP, these provisions can either be included
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as a separate agreement (e.g. a Memorandum of Agreement) or as an update or attachment to the
Core CSGWPPJ
B. EPA Involvement in CSGWPP Review and Endorsement
Review Process
After developing their Core CSGWPPS, States submit them to EPA regional offices for
cross-program review. Regional staff from all EPA remediation programs, including RCRA
Subtitle C and D, Superfund and Underground Storage Tanks, or cross-program
representatives should be involved In the review of a Core CSGWPP. In this review, EPA
Regional staff should assess the implications for and useability of the principles developed in the
Core CSGWPP’ by their respective programs. Regional staff should also make sure that
program-specific issues will be resolved, either:
• In the Core CSGWPP, or
• During the “multi-year planning” stage, after the Core CSGWPP has been endorsed.
In the current review process, multiple program offices are part of the review team from
both the respective Region and Headquarters, although Headquarters program offices review
only the first Core CSGWPP submitted to each Region. Regional ground-water protection
programs generally have the lead for the EPA review process.
Focus of Review
When reviewing a Core CSGWPP, EPA remediation program staff should pay particular
attention to the following sections of a Core CSGWPP
01 The State’s method for establishing ground-water priorities, based on “varying
ground-water characteristics;”’ 3 and
• Discussion of how ground-water characteristics are to be used to “support rational
decision-making” for site-specific remediation activities.’ 4
These two Adequacy Criteria are closely linked. A Core CSGWPP should define and
demonstrate use of a priority setting mechanism in at least one ground-water program. It should
also discuss how this priority setting mechanism would be applied to other programs not profiled
in the Core CSGWPP, including facility siting and remediation programs. EPA remediation
‘ 3 Adequacy Criterion 2 under Strategic Activity 2, defined in EPA’s 1992 CSGWP Guidance, page 2-7.
‘ 4 Adequacy Criterion 6 under Strategic Activity 4, defined in EPA’s 1992 CSGWPP Guidance, page 2-12.
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program staff should determine whether the sections of the Core CSGWPP noted above,
adequately support types of site-specific assessments and decisions made by their specific
remediation prOgrams. If not, EPA remediation programs should request that provisions
supporting site-specific decisions be added either to the Core CSGWPP prior to EPA
endorsement or added in subsequent CSGWPP agreements, as appropriate. (See above
discussion under “Provisions Supporting Site-specific Decisions.”)
C. Role of Other CSCWPP Provisions In EPA Remediation Prn r ms
In addition to current and expected futur& ground-water uses, a CSGWPP may provide
additional information that can be used by EPA programs for program planning, so that
protection and remediation efforts can be emphasized in areas where ground waters have a high
resource value or priority. EPA remediation programs should utilize the resource value or
priority defined in an EPA-endorsed C. SGWPPII as appropriate, for more effective or efficient
implementation of program activities. For example, an EPA remediatior program could set
priorities for sites requiring initial assessments based in part on the resource value or priority
defined in an EPA-endorsed CSGWPP A more specific example would be where an EPA
remediation program schedules initial site assessments in well head protection areas (i.e., high
priority) prior to assessments in other areas.
For further information concerning the role of CSGWPPs in EPA remediation programs,
contact Ken Lovelace of EPA’s Office of Emergency and Remedial Response at (703) 603-8787,
Guy Tomassoni of the Office of Solid Waste at (703) 308-8622, orJohn Heffelfinger of the
Office of Underground Storage Tanks at (703) 603-7157. For more information about
CSGWPPs in general, contact the ground-wateil program representative in your Region.
Attachments
cc: Mike Shapiro, OSWER Linda Boornazian, OECAJOSRE
Barbara Hostage, OSWER Larry Starfiçld, OGC
Steve Luftigj OSWERJOERR Lisa K. Friedman, OGC
Elizabeth Co1sworth OSWER/OSW Cynthia Dougherty, OW.
Anna VirbickJOSWER/OUST KrisHoe1len j ASTSWMO
Jim Woolford, OSWERIFFRRO . Mark Giesfeldt, ASTSWMO/
Linda Garczinski, OSWER/OSPS CERCLA Subcommittee Chair
Barry Breen, OECA/OSRE
NOTICE: Thi document provides guidance to EPA staff. It also provides guidance to the public and to the
regulated community on how EPA intends to exercise it discretion in implementing its regulations. The guidance
is designed to implement national policy on these issues. The document does not, however, substitute for EPA’s
statutes or regulations, nor is it a regulation itself. Thus, it cannot impose legally-binding requirements on EPA,
States, or the regulated community, and may not apply tQ a particular situation based upon the circumstances. EPA
may change this guidance in the future, as appropriate.
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1 2
Attachment
STRATEGIC ACTIVITIES OF A
COMPREHENSIVE STATE GROUND WATER PROTECTION PROGRAM’
I. “Establishing a ground water protection goal to guide all relevant federal, State,
and local programs operating within the State;
2. Establishing priorities, based on characterization of the resource, identification of
sources of contamination, and programmatic needs, to guide all relevant federal,
State, and local programs and activities in the State toward the most efficient and
effective means of achieving the State’s common ground water protection goal;
3. Defining authorities, roles, responsibilities, resources, and coordinating
mechanisms across relevant federal, State, tribal, and local programs for
addressing identified ground water protection priorities;
4. Implementing all necessary efforts to accomplish the State’s ground water
protection goal consistent with the State’s priorities and schedules;
5. Coordinating information collection and management to measure progress, re-
evaluate priorities, and support all ground water-related programs; and
6. Improving public education and participation in all aspects of ground water
protection to achieve support of the State’s protection goal, priorities, and
p r 0 g r a m S .
From 1992 Final CSGWPP Guidance, pages 1-19 and 1-20.
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Attachment 2*
STATUS OF COMPREHENSIVE STATE GROUND WATER PROTECTION
PROGRAMS
EPA Region
States uiith Core
CSGWPP
Endorsed by
-
States with Core
CSGWPP
Submitted to
EPA
Region 1
Connecticut,
Massachusetts,
New Hampshire
Region 2
New Jersey,
New York
Regiofl 3
Region 4
Alabama
Georgia,
Florida
Rei ion 5
Wisconsin
Illinois
Region 6
Oklahoma
Arkansas,
Louisiana
Re ion7 I I____________
Region 8
I Montana
Region
Nevada
Region 10
Washingtoi
Total No. States
6 States
110 States
TOTAL OF 16 STATES HAVE SUBMITTED CSGWPPS TO EPA
Based on information provided by EPA’s Office of Ground Water and Drinking Water, Ground Water Protection
Division, as of March, 1997.
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