REGIONAL POLLUTION PREVENTION PROJECT
TO DEVELOP AN EARLY WARNING SYSTEM
TO PREVENT IRRETRIEVABLE LOSS OF AQUIFER RESOURCES
PHASE I
PROJECT SUMMARY REPORT
JULY 14, 1994
PREPARED BY:
Derek I. Sandison
Adolfson Associates, Inc.
(509-674-5215)
(503-226-8018)
Gregory L. Glass
Environmental Consultant
(206-523-1858)
John D. Littler
Littler Environmental Consulting
(206-486-3861)
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SECTION I
PROJECT SUMMARY
PROJECT NARRATIVE
The EPA Region 10 Pollution Prevention Project is intended to result in the
development of a conceptual analytical tool to assist in early identification of ground
water contamination problems. Such an early warning mechanism should facilitate
prompt and effective responses to minimize or limit pollution before potentially
catastrophic impacts occur to large portions or all of an aquifer system.
The project was prompted by the significant number of costly ground water
contamination incidents that have occurred within Region 10 during the past two
decades; problems that may have limited in their severity had early action been taken in
response to initial warnings. Among these incidents are the following:
Coeur d'Alene Wellfield (Waho),
Garden City (Idaho),
Lakewood/Ponders Corner (Washington),
Milwaukee (Oregon),
Portland South Shore (Oregon),
Tacoma Landfill (Washington),
Tacoma Well 12A (Washington),
Tumwater Wellfield (Washington), and
Vancouver Wellfield (Washington).
The project is divided into two phases. Phase I is primarily oriented towards an
assessment of existing mechanisms for ground water data evaluation and response; while
Phase n will involve the actual development of the conceptual analytical tool and
validation of the tool by applying it to data from an historic case study and to a set of
current ground water quality data.
EPA Region 10 determined that the project would focus on the State of Oregon.
Oregon was selected from among the four states in Region 10 in recognition of its
ongoing efforts to develop a Comprehensive State Ground Water Protection Program
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and because of the expressed willingness of state agency personnel to participate in and
contribute to this project.
The Pollution Prevention Project will attempt to provide a conceptual analytical tool and
decision making framework that will assist the State of Oregon in the implementation of
its Comprehensive State Ground Water Protection Program. The conceptual analytical
tool will be developed within the context of the institutional system for ground water
resource protection and management in the State of Oregon. However, the tool will be
designed in a manner that will allow adaptation to institutional systems in the other
Region 10 states.
In Phase I, the project team conducted workshops and interviews with EPA Region 10
staff, State of Oregon agency personnel, and representatives of public water utilities
within the State of Oregon in order to gain insight into existing protocols for evaluations
of ground water data and selection of response actions linked to those evaluations.
The workshops and interviews were intended to obtain information that will be vital to
the design of the conceptual analytical tool including:
The nature of available ground water quality data;
The manner in which ground water data are collected, analyzed, and shared;
The specific criteria that trigger response actions to further investigate or
remediate identified problems; and
The range of possible response actions.
The workshops and interviews also provided an opportunity for identification of actual
ground water contamination incidents, case studies, where resource damages could have
been substantially limited had early action been taken.
The first workshop was held in Portland, Oregon, on November 18, 1993. It was
attended by representatives of the Oregon Department of Environmental Quality,
Oregon Health Division, Oregon Water Resources Department, Oregon Department of
Agriculture, Oregon Department of Parks and Recreation, Oregon Association of Water
Utilities, City of Boardman, City of Portland, and the City of Springfield.
The second workshop was held at EPA Region 10 Headquarters in Seattle, Washington,
on November 30, 1993. In attendance were representatives of the Drinking Water,
Ground Water, and Air and Toxics Programs as well as the Environmental Services
Division.
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In addition to participation in the workshops, attendees were asked to complete a
questionnaire designed to elicit specific information regarding the role of their agency or
program in ground water protection and management. Of the 28 total attendees at the
two workshops, 17 completed and returned questionnaires. Summaries of the workshops
and questionnaires are contained in Section II of this document.
Follow-up interviews were conducted with eight EPA Region 10 representatives, nine
Oregon agency personnel, and three public water system managers. Summaries of these
interviews are contained in Section ffi of the document.
Results of the interviews and workshops have led to the development of specific findings
and recommendations provided below. These findings and recommendations served as
the basis for development of guiding principles for project and the design of the Phase II
effort.
FINDINGS AND RECOMMENDATIONS
Based on the workshops and interviews conducted as part of the Phase I effort, the
following findings and recommendations are offered by the project team. The findings
summarize the most significant information obtained from the interviews and workshops
conducted as part of the project, as well as from review of the Profile of Ground Water
Protection Programs 1993, State of Oregon (Keenan and Helferty, 1993).
Assistance of interviewees and workshop attendees was sought in characterizing the day-
to-day, operational processes of the agencies involved in ground water protection in the
State of Oregon. Information concerning data evaluation procedures, data transfer
mechanisms, and response activities is critical to identifying the niche for the analytical
tool and decision making framework envisioned by this project.
The findings are not intended as criticisms of State of Oregon agencies or programs, but
rather to serve as indicators of how the analytical tool and decision making framework
could provide tangible benefit to the existing institutional system. Financial resource
constraints and agency coordination difficulties discussed below are ubiquitous, not only
within Region 10, but across the nation as a whole. Further, it is recognized that many
of the institutional limitations discussed below are being addressed by the State of
Oregon and EPA Region 10 through the Comprehensive State Ground Water Protection
Program planning effort.
1) Financial Resource Limitations. State of Oregon agency personnel interviewed as
part of this project are dedicated individuals who are attempting to operate ground water
protection programs without adequate levels of financial resources. Unfortunately, it
appears that there is little prospect for any increase in resource levels in the foreseeable
future. Financial resource limitations have severely restricted the ability of state health,
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environmental, and resource agencies in the State of Oregon to operate a
comprehensive, forward-looking resource protection program. Important cornerstones of
an effective, comprehensive resource protection program, such as vulnerability mapping,
statewide ambient monitoring, coordinated data management and analysis, and
contaminant source control, have not been advanced to a desired level due to funding
restrictions. In general, state agencies are in a mode of primarily reacting to emergent
problems rather than engaging in proactive planning and management.
RECOMMENDATION: Phase n of the project should be designed to provide tools to
help maximize efficient use of existing personnel by improving the ability to identify
potentially serious ground water contamination problems at an incipient stage. The
conceptual analytical tool and communication and response protocols developed for the
project must be compatible with the current operations of the departments and divisions
involved with their implementation. Should they be viewed as adding additional burdens
to those departments and divisions without providing tangible short term benefits, the
tool and protocols will likely be rejected as impractical.
However, while recognizing that financial limitations will greatly influence the design of
the conceptual analytical tool and institutional protocols, Phase n should also highlight
the differences in approach that might be taken if the conceptual analytical tool was not
constrained financially and was wholly oriented towards long-term resource protection.
2) Confusion Over Role of Project in Pollution Prevention. The project's standing within
EPA's pollution prevention program initially created confusion among some of the State
of Oregon agency representatives. That confusion stemmed from questions as to
whether pollution minimization, which is the principal thrust of this project, fits the
definition of pollution prevention, or whether pollution prevention is confined to source
reduction activities. This semantic issue appears to have initially created some problem
with acceptance of the project's concepts.
RECOMMENDATION: Phase D should attempt to further clarify this semantic issue.
This project seeks to achieve pollution prevention within the broader context of that
term; however, it is concerned with a very specific role in pollution prevention. While it
is recognized that pollution prevention typically focuses on source reduction, pollution
minimization should also be considered an important element as well.
3) Drinking Water VOC Data as Early Warning Indicator. Personnel of both the
Department of Environmental Quality and the Oregon Health Division expressed
concern over the use of drinking water volatile organic compound (VOC) data as the
primary data bases for use with the conceptual analytical tool to provide early warning of
ground water contamination problems. Some are concerned that once VOC
contamination has reached a public water supply well, it may be too late for early
intervention; a problem already exists. Additionally, public water supply wells are usually
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not designed, constructed, or sampled in a manner that provides data which are
representative of specific conditions in an aquifer system.
Further, the practice of some public water utilities of removing wells from service at the
first indication of a problem, either a contaminant hit or unpleasant taste and odor, has
created "dead ends" in the drinking water data base. While the Oregon Health Division
is aware of this problem and is taking steps to rectify it, the practice may have cost the
state opportunities to identify and respond to emerging problems before broader
resource damages occurred.
RECOMMENDATION: It was evident from the interview process that considerable
misunderstanding resulted from the decision by EPA Region 10 to select the Oregon
drinking water VOC data as the primary data source for the limited purposes of this
project That data set will be used strictly to test and illustrate the conceptual analytical
tool developed as part of this project. However, at a point in the future when the
analytical tool and early warning system are fully developed as a result of subsequent
EPA and/or state sponsored efforts, it is recognized that a much broader data base
would need to be incorporated and utilized.
The broader data base would include information from monitoring programs at solid
waste landfills, RCRA sites, and hazardous waste cleanup sites; pesticide data; and
ground water vulnerability assessments. In addition, a comprehensive data base for a
fully developed early warning system would need to consider drinking water monitoring
parameters other than VOCs. Parameters such as bacteria, nitrate, and metals could be
used in conjunction with the aforementioned data as potential triggers for the processes
of priority setting and determination of response actions.
While such a comprehensive data base is under development by the State of Oregon, it
will not be available for use within the time frame of this project.
4) Data Base Coordination Issues. Many data bases related to ground water quality exist
within the departments and divisions of state government; however, the organization of
those data bases has not been well coordinated. Many of these data bases lack common
formats and locators and are not configured in a manner that would facilitate access by
potential users in other departments and divisions.
Data management tools are available (ARC/INFO and ARC/VIEW) to create a
comprehensive, relational data base management system; however, financial resources to
provide for programming, data entry, and data analysis are lacking.
RECOMMENDATION: Efforts by the state's health, environment, and water resource
agencies to develop a comprehensive ground water data base management system that
will allow free flow of information between departments and divisions should be
expedited. This will ultimately result in the development of multiple, interactive linkages
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that will facilitate early identification of and coordinated response to emerging ground
water quality problems.
Progress towards completion of a comprehensive data management system has been
hindered by financial resource limitations. Such a system is not likely to be brought on-
line within the time frame of this project. Thus, interim mechanisms for interagency
data coordination will need to be developed in Phase n as part of the decision making
framework if the conceptual analytical tool is to be useful. The interim mechanism may
be a modification of the Oregon Health Division's drinking water data "alerts" system.
5) Protocols for Data Transfers and Response Actions. There is agreement among many
of those interviewed that a "process" or "protocol" is needed to help determine when and
with whom data should be shared. There is currently no formal system for data
transfers, and there are no mutually agreed upon criteria to trigger transfer of data or
response actions.
RECOMMENDATION: Phase n of the project should provide assistance to departments
and divisions in improving intra- and interagency communication and coordination. In
development of the conceptual analytical tool, it should be recognized that data analysis
and response generally is a two tier process. Typically, an initial threshold determination
is made as to whether a piece or a group of data is significant enough to warrant
notification of others and collection of additional information. After additional data
have been collected and analyzed, a second, response action oriented determination is
made. In concert with the health, environmental, and resource agencies, a framework
for decision making should be developed which links specific analytical outputs to
commensurate response actions.
Because of differences in the goals and missions of health, environmental, and resource
management agencies, it may be necessary to develop more than one system for
assigning priority to identified contamination incidents and for selecting appropriate
responses actions.
6) Wellhead Protection Program Interface! There is a potential interrelationship
between this project and the Wellhead Protection (WHP) Program. Contaminant source
inventories conducted by public water utilities as part of their WHP Programs will
correlate individual wells to specific data sources, improving the ability of health,
environmental, and resource agencies to assess the significance of monitoring data from
water supply wells.
The state WHP program should also provide impetus for centralizing management of
contaminant source data. In order to complete contaminant source inventories for their
WHP Areas, public water utilities will be requesting data from the Department of
Environmental Quality concerning underground storage tanks, leaking underground
storage tanks, RCRA facilities, solid waste landfills, and facilities included in the state's
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Pollution Prevention Program. These data are not currently contained within a single
data base, but are held separately in various divisions of the department.
The Department of Environmental Quality intends to either combine these data bases or
to facilitate coordination of and access to the various data bases. This will ultimately
assist in streamlining the analysis of ground water quality data.
RECOMMENDATION: The Phase H effort should explore the potential role of WHP
Programs in providing linkage between wells and contaminant sources as well as in
facilitating contaminant source data transactions. However, it is premature to speculate
concerning the degree to which this project might benefit from WHP Program related
activities. There is significant political pressure to make the WHP Program voluntary.
Whether it will be entirely or partially voluntary depends on a number of factors to be
decided by state agencies, Oregon's legislature, and EPA.
Other special management programs such as pesticide monitoring and management plan
development efforts may be of greater utility in certain portions of the state where few
major public water systems exist
7) Definition of Agency and Utility Roles. The roles of agencies in ground water
protection appear to be fairly well understood by some individuals at the state level;
however, when the horizon is expanded to include local governments and public water
utilities, the distinction in roles become somewhat unclear. The roles or potential roles
of local governments and public water systems in ground water protection are recognized
by state agencies, but are not fully developed as an adjunct to state water resources
programs.
RECOMMENDATION: When defining the function of the conceptual analytical tool
within the existing institutional system for ground water protection, the role of local
governments and public water utilities in an expanded partnership with state agencies for
protection of ground water resources should be addressed. This should include
establishing mechanisms for accessing data that may be collected and managed at a local
level.
GUIDING PRINCIPLES
EPA Region 10 directed the project team to identify the principals which will guide the
Phase n effort. Those guiding principles are as follows:
1) An effective, comprehensive ground water resource protection program should be
based on proactive planning and management involving state-wide monitoring, accurate
assessments of vulnerability, coordinated data management, and pollution prevention.
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The concept of pollution minimization, as advocated by this project, is an important
element of pollution prevention.
2) A wide-variety of land use and water quality data should considered in data
evaluations, priority setting, and selection of response actions. A single piece of data
may not individually provide an indication of a problem, but, when evaluated in the
context of other available data, may signal the need for response actions.
3) Effective management of and interagency access to data is essential. Investment in
the development of mechanisms for interagency data transfers should have significant
pay offs.
4) To be most effective, ground water data management efforts should facilitate easy
access to more data and provide relatively simple analytical tools to evaluate that data.
5) Interagency "processes" or "protocols" to help determine when and with whom data
should be shared make significant contributions to effective resource management,
particularly when they include formal mechanisms for data transfers and mutually agreed
upon criteria to trigger transfers of data or response actions.
6) Analysis of ground water contamination incidents should include some form of
ranking based upon frequency (number of wells affected), magnitude (what percent of
the MCL), proximity to uses, flow directions, and time trends.
7) A framework for decision making should link specific analytical outputs to
commensurate levels of response.
PROPOSED PHASE H SCOPE OF WORK
Based on the information compiled in Phase I of the ground water protection project,
the following Phase n are proposed:
TASK1: INSTITUTIONAL ISSUES
A number of related institutional issues affecting the realization of the early warning
system ground water protection model were identified in Phase I. Those institutional
issues will be enumerated and discussed; protocols for addressing those issues will then
be developed to support adoption of improved ground water protection practices. The
developed protocols will focus on practical, achievable steps within the existing ground
water protection activities of appropriate agencies.
The roles and responsibilities of the agencies/programs will be addressed, with
consideration of local/state/federal agency interactions and issues related to "handoffs"
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of ground water problems from one agency/program to another. Protocol development
will focus on data collection (types, frequencies, and formats); database management and
data quality issues; communications and data transfers among the agencies; coordination
in integrating relevant data sets (e.g., chemistry and source inventory data); and similar
issues. A list of key contacts in each of the agencies/programs will be provided
identifying areas of responsibility, addresses, and phone numbers.
TASK 2: DEVELOPMENT OF ILLUSTRATIVE ANALYTICAL TOOL FOR
PRIORmZATION
The Phase I interviews confirmed that ground water monitoring data sets have more
detected chemical concentrations than can be effectively dealt with by the agencies
within the constraints of their current level of resources. Therefore, a short-term need
exists to establish some priorities and resource allocation decisions to address potential
ground water contamination issues. An analytical tool to achieve useful prioritization
among ground water "hits" will be developed. That analytical tool may need to consider
the different roles and responsibilities of various agencies (i.e., different prioritization
objectives), yet maintain an overall focus on protection of ground water resources.
Ground water chemistry results and other data types may be included in this analytical
tool. The resulting rankings or priority classifications of potential ground water problems
will likely be used not only for intra-program decisions on allocations of staff resources,
but also for coordinating interagency communications and data transfers,
TASK 3: DEVELOPMENT OF ILLUSTRATIVE ANALYTICAL TOOL TO SUPPORT
SELECTION OF APPROPRIATE RESPONSE ACTIONS
Once a potential ground water contamination problem has been given a priority ranking,
the second problem is the selection of appropriate actions in response to a "hit" in
ground water monitoring data. An analytical tool, consisting of specific evaluations or
displays of chemical and other types of data, will be developed to support informed
decisions on the selection of response actions. The practical limitations in available data
will be considered in designing this analytical tool. To the extent feasible, coordination
of the effort under this task with other ongoing work (e.g., development of Wellhead
Protection Programs or State Management Plans for pesticides) will be pursued. The
data requirements, data characterization, and data display outputs for the analytical tool
will be identified.
TASK 4: DRAFT OUTLINES OF INSTITUTIONAL PROTOCOLS AND ANALYTICAL
TOOLS
The protocols and analytical tools developed in this project need to be both practical and
useful within the existing agency ground water programs. Based on the products of
Tasks 1, 2, and 3 of this scope of work, and prior to testing the developed tools on case
studies and illustrative data sets or preparing project report materials, an outline of
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protocols and analytical tools will be prepared for review by EPA and state agency staff.
A working meeting to discuss review comments and possible revisions may be convened
at EPA's discretion based on the extent of comments and identified issues. Following
any necessary revisions, the subsequent "proof of concept" and report preparation tasks
will be completed.
TASK 5: ILLUSTRATIVE DATA EVALUATIONS USING ANALYTICAL TOOL
SUBTASK 5A - ILLUSTRATIVE DATA ANALYSIS USING CASE STUDIES
The potential benefits of this project's conceptual approach to early warning of ground
water contamination problems and appropriate early actions to prevent loss of ground
water resources will be examined in one or more (retrospective) case studies. While
many sites were mentioned during Phase I interviews as possibilities for case studies,
most appeared to have limitations for full case study application. The most promising
options appear to include the Shoshone-Bannock reservation site in Idaho; the Tacoma
Landfill site in Washington; and LaPine, Oregon.
Data for one or more case study sites will be obtained and evaluated retrospectively,
using the analytical tools developed in Tasks 2 and 3 of this scope of work to illustrate
the benefits of an early detection/early response scenario. A narrative discussion of the
results will be prepared and briefly compared with the actual site histories.
If none of the candidate case study sites effectively illustrate the overall benefits of the
early warning system framework for aquifer protection, a "constructed case study"
approach will be used. Actual site histories and information may still be useful under
this approach to provide specific, real-world examples of particular benefits (such as
protection of human health through early provision of alternate water supplies, or
additional ground water monitoring requirements).
SUBTASK 5B ILLUSTRATIVE DATA ANALYSIS USING CURRENT
GROUND WATER MONITORING DATA
A selected set of current ground water monitoring data will be used to illustrate
applications of the analytical tools developed in Tasks 2 and 3 of this scope of work.
The presumptive ground water chemistry data set for this task will be a subset of the
Oregon VOC data from drinking water supply wells. The analytical tools may use other
types of data in addition to ground water chemistry data; such additional data will be
included in the illustrative analyses to the extent they are readily available. The main
purpose of this task will be to provide clear examples to potential users of the
application and usefulness of the analytical tools. Various data characterization products
(analytical tool outputs) will be provided.
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TASK 6; FINAL REPORT
A Draft Report will be prepared to document the objectives, approach, and results of the
ground water protection project. The report will describe how the conceptual framework
for this project relates to pollution prevention, including case study summaries. The
protocols developed for addressing institutional issues, as well as the analytical tools
developed for prioritization and response action selection, will be described and
illustrated.
The preliminary draft outline reviewed with EPA in December, 1993, will be used as a
starting point for report organization. Modifications in that outline, based on Phase n
work, will be discussed with EPA prior to preparing the draft report
A Final Report will be prepared with revisions based on review comments from EPA
and other designated reviewers. The project report should not exceed 50 pages in
length.
TASK 7: RECOMMENDATIONS.
Recommendations for further development, adaptation, and application of the concept
will be provided to EPA Region 10 in a memo separate from the final report.
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PRELIMINARY DRAFT
REGIONAL POLLUTION PREVENTION PROJECT
TO DEVELOP AN EARLY WARNING SYSTEM TO PREVENT
IRRETRIEVABLE LOSS OF AQUIFER RESOURCES
PHASE I AND PHASE II FINAL REPORT OUTLINE
1. BACKGROUND
A. PROBLEM STATEMENT
B. PROJECT OBJECTIVE
The objective of the framework is to document the conceptual
structure and guiding principles for the use of water monitoring data
in pollution prevention.
The objective of the analytical tool is to provide risk-based
information which characterizes the data in ways useful for
identifying priorities and approaches compatible with existing state
and federal programs for reducing or preventing pollution at the
source.
The objective of the recommendations is to utilize the findings of
the case study and interviews to identify ways in which local, state,
and/or federal program staff can work together to promote early
awareness of water contamination and early initiation of pollution
prevention activities.
C. PROJECT APPROACH
Development of early warning concept with EPA
Interviews
Oregon
EPA
Selection of data for review
Case study
Conceptual development of analytical tool and framework
Evaluation of institutional issues
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PRELIMINARYDRAFT
2. SUMMARY OF CURRENT SITUATION
A. EXISTING INSTITUTIONAL SYSTEMS
EPA
Oregon
Regional
Short-term objectives for early warning system (ranking)
Long-term objectives for early warning system (source detection and
appropriate actions)
B. EXISTING IMPEDIMENTS TO EFFECTIVE EARLY DETECTION
AND ACTION
Extent of current knowledge/understanding
Lack of communication
Lack of coordination
Absence of systems
Inadequate resources
Expanding need
3. ANALYTICAL TOOL
A. PURPOSE
B. IDENTIFICATION OF USEFUL DATA CHARACTERIZATION
PRODUCTS
Short-term (ranking)
Long-term (source detection)
C INPUT/OUTPUT MODEL FOR ANALYTICAL TOOL
D. TYPES OF DATA INPUTS/SOURCES OF DATA
E. DEVELOPMENT OF ANALYTICAL TOOL
F. ILLUSTRATIVE APPLICATIONS
Selected Oregon VOC data
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PRELIMINARY DRAFT
4. APPLICATION OF TOOL WITHIN INSTITUTIONAL SETTING
A, ROLES AND RESPONSIBILITIES
B. RESOURCE DECISIONS (PRIORTTIZATION)
C. SOURCE IDENTIFICATION
D. HIERARCHY OF RESPONSE ACTIONS/SELECTION
5. SELECTION AND REVIEW OF CASE STUDY
A, DESIRABLE CHARACTERISTICS FOR CASE STUDY
B. CANDIDATE CASES
C. CONSTRUCTED CASE SCENARIOS
D. SELECTION OF CASE STUDY(S)
E. DESCRIPTION OF CASE(s)
F. RETROSPECTIVE DATA EVALUATIONS
G. ILLUSTRATION OF OPPORTUNITIES FOR EARLY DETECTION
6. SUMMARY, CONCLUSIONS, AND GUIDING PRINCIPLES
7. REFERENCES
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SECTION II
WORKSHOP AND QUESTIONNAIRE SUMMARIES
The following are summaries of the two workshops conducted as part of the Regional
Pollution Prevention Project. The first workshop was conducted on November 18, 1993,
in Portland, Oregon, with representatives of the State of Oregon; the second was held on
November 30, 1993, in Seattle, Washington, with staff of EPA Region 10. Individuals
who were invited to attend the workshops were also requested to complete a
questionnaire that was developed by the project team. Questionnaire responses are also
summarized below. Some workshop findings* were expanded upon by incorporating
information obtained from the questionnaires. Information so incorporated is generally
not repeated under the summary of the questionnaires. The questionnaire form is
included as an attachment to this section of the Phase I Project Report.
STATE OF OREGON
WORKSHOP FINDINGS - NOVEMBER 18. 1993
GENERAL CONSIDERATIONS
The lack of adequate financial resources severely impairs data collection, management,
transfer, and analysis efforts by Oregon resource management and public health agencies
and limits early response capability.
The selection of terminology for the project is important in clearly defining its
objectives. For instance, the term "source reduction" has specific meaning to those in the
pollution prevention field; it is not synonymous with limiting the migration of pollutants
once they are in ground water.
L DATA COLLECTION AND MANAGEMENT
Sources of ground water data include: OHD public water system compliance data,
DEQ Oregon Water Quality Data Base, individual well certification testing, the free
NO3-N sampling program, the Fire Marshal's hazardous substances surveys, ODA and
DEQ pesticide surveys, USGS, RCRA and CERCLA/SARA enforcement programs,
Environmental Impact Statements for major projects potentially affecting ground water,
and possibly ODOT, BLM, and COE. Other data are potentially available in the private
sector (e.g., data generated through site assessments for property transfers); however,
they are frequently not shared with government agencies due to fear of regulatory
consequences.
The utility of some data sets are limited due to differences in testing objectives.
Consideration of objectives may influence testing methods, well construction practices,
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and selection of detection limits. For example, public water system compliance
monitoring may involve different parameters and detection limits than testing done as
part of a site assessment.
There are many undocumented wells for which data is either never generated or never
provided to public agencies. In addition, there are many public water supply wells within
Oregon that have been removed from service but not properly abandoned. Resource
management agencies sometimes do not know the motivation behind removal of these
wells from service (e.g., were wells taken out of service due to contamination problems
that were never reported?),
II. DATA TRANSACTIONS
The current system for interdepartmental exchange of data is informal; although, a
more formal process is currently under development by an interagency committee. The
interagency committee is also addressing problems in linking data bases such as the lack
of a common location designator (e.g., latitude/longitude; state plane coordinates; and
Township, Range, and Section).
The Oregon Ground Water Protection Act of 1989 addressed the issue of multiple
agency access to data and the creation of a data repository; however, implementation has
not been adequately funded.
OWRD is developing an on-line data base (water levels, well logs, etc.) with well
identifier numbers. This system is not yet fully operational.
Problems noted with the current system for transferring data include:
* Some data sets consist of paper files which are difficult to handle, transfer, and
analyze;
* Data transfers have typically not been considered early enough in various
planning efforts to facilitate effective resource protection;
* Data from "special studies" are often not distributed to other agencies;
Data are not always readily available to those that want to use it (e.g., the City
of Springfield experience); and
* Some local jurisdictions do not properly utilize available data in making land
use decisions (e.g., allowing construction of a subdivision and a community well
over an abandoned landfill).
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The current system for informing other agencies of "detects" or "hits" is human
dependent. Creation of a system that automates the notification system or reduces the
dependence on subjective human judgement would be helpful.
III. DATA ANALYSIS
Currently, OHD conducts an analysis of data when a VOC hit is detected. In
conducting the analysis, OHD considers the type and quantity of the contaminant, the
presence of potential sources, land use information, and the location of other wells that
might be affected.
A general form is used in the evaluation that addresses the following:
* Latitude/longitude of well,
* Number of samples,
* Facilities, (air quality permits, water quality permits, stormwater quality
permits), and
' Fire Marshal MSDS information.
Concern was expressed over the notion of centralizing responsibility for data analysis
within a single department or division. Making one agency (or person) responsible for
data analysis might preclude valuable insight that may be provided by those not
participating in the analysis. Additionally, departments differ with respect to their legal
mandates, priorities, and objectives. Thus, some redundancy in the analysis of data is is
probably desirable.
Triggers" are obviously needed in data analysis, but the trigger should not be the
MCL for a compound. Possible triggers mentioned include: multiple hits versus single
hits, occurrence in residential areas versus industrial areas, relative contaminant levels
such as half the MCL, and the number of potential sources in the area of concern. (See
also discussion of yellow light/red light system in section IV.)
Concerns were expressed over the reliability of data, QA/QC, and well identifiers
when comparing historical data to current data.
Maps of Wellhead Protection Areas may be helpful in alerting agencies and
department as to when outreach to other agencies, especially potentially affected public
water systems, may be appropriate.
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IV. ACTIONS IN RESPONSE TO DATA ANALYSIS
Any detection of VOCs in a drinking water well signifies a problem that needs to be
evaluated and resolved.
Factors that need to be considered in determining appropriate actions include: number
of hits, confirmation, concentration, spatial frequency, and exposure (population
affected).
Responses at cleanup sites should be coordinated with public water system Wellhead
Protection Program activities.
There are a number of hits that have already been discovered; however, state agencies
lack the necessary resources to effectively deal with them. Finding hits is relatively easy;
unfortunately, finding the source of those hits is time consuming and expensive.
Resource limitations have forced departments to make judgements as to when action is
justified. For example, a hit in an industrial area may not be a high priority; whereas,
the same hit in a residential area may raise a red flag.
There is, in practice, a yellow light/red light system for response to identified inorganic
contaminants in ground water. Under this system, if levels of a contaminant, such as
nitrate, remain static within a geographic region, no action is taken. If levels begin
increasing, the yellow light threshold is reached and the region may be designated an
Area of Concern. If levels reach 1/2 the MCL, the red light threshold is reached and a
Ground Water Management Area should be formed. There are 37 areas in the state
that could be designated Ground Water Management Areas; however, there isn't enough
staff in DEQ and OHD to pursue official designation in all areas.
State government agencies, particularly DEQ, lack the ability to institute meaningful
controls at an incipient stage due to lack of jurisdictional authority and the lack of
adequate resources.
Local governments could be more prudent in land use planning decisions concerning
industrial uses. Cities are anxious to attract new industries to expand their tax base.
Some tools are available to minimize impacts of industrial development such as Business
Toxic Use Reduction Plans and Stormwater Containment Plans; however, in areas where
ground water is highly susceptible, industrial zoning may simply be incompatible with the
goal of protecting underlying ground water. Many cities are unwilling to even conduct
inventories of potential contaminant sources.
GIS appears to represent a potentially valuable tool for prioritizing special studies and
enforcement actions through identification of areas with vulnerable ground water.
II-4
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V. CASE STUDIES
Potential case studies identified in the November 1993 interview include:
Montezuma (Medford) (PCE problem in domestic wells),
8 East Multnomah County,
8 Springfield,
8 Lakewood, and
Milwaukie.
II-5
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ADDITIONAL INFORMATION FROM QUESTIONNAIRES:
OREGON RESPONDENTS
Information was provided concerning the mission and the legal jurisdiction of the
following departments: Oregon Water Resources Department, Oregon Department of
Environmental Quality, Oregon State Parks and Recreation Department, Oregon Health
Division, and Oregon Department of Agriculture.
In reviewing individual responses concerning data bases and data transfers, there does
not appear to be a sense of a need for a common data base.
Current processes for data sharing are not fully developed. Some data is shared on a
"by request" basis only.
Respondents were about equally split concerning whether or not agency roles are
currently well defined.
Impediments to prompt response to early warnings include:
Lack of response agency resources,
* Crisis driven mode of operation, and
* Lack of jurisdiction to deal with potential problems before an MCL is violated.
Responses to "let your mind wander question" include:
* Establish a system for regular notification of other agencies,
* Use CIS mapping to identify populations at risk,
" Notify businesses in the area of potential violation that a release appears to be
occurring,
Halt further ground water development and conduct a detailed hydrogeologic
study, and
Initiate enhanced monitoring and surveillance of potential sources within the
possible zone of contribution to the affected well(s).
II-6
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EPA REGION 10
WORKSHOP FINDINGS - NOVEMBER 30. 1993
GENERAL CONSIDERATIONS
Other states in Region 10 may be worse off than Oregon in the implementation of a
coordinated system for collection, transfer, and analysis of data.
There are many efforts in progress to manage, transfer, and analyze data. EPA needs
to get a handle on all of these efforts.
Regardless of the nature of the analytical tool developed as part of this project, we
must focus on a manageable data base such as drinking water data.
The desire to protect ground water resources in general, irrespective of beneficial use,
must be reconciled with the expediency, and arguably the congressional mandate, to
focus on protection of specific water supply wells.
The lack of adequate resources prevents EPA from doing everything it should do in
terms of data transaction, data analysis, and undertaking actions to protect ground water.
I. DATA COLLECTION AND MANAGEMENT
Data sources that might be useful in conducting this project include: Oregon
Vulnerability Map (GIS), Oregon Ground Water Data Base, and the mass nitrate testing
data base.
Concern was expressed that, although EPA Region 10 provides funding to DEQ for a
number of data collection and management projects, it does not have access to the
Oregon Ground Water Data Base.
While there are extensive site investigation data (RCRA, LUST, CERCLA/SARA),
there is a general lack of ambient ground water monitoring of aquifers within Region 10.
Typically, a crisis needs to arise before the EPA or the states recognize the need for
data management.
There are a number of emerging technologies that may significantly improve future
data collection and management efforts, for instance, use of the Global Positioning
System to pinpoint locations of wellheads.
H-7
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II. DATA TRANSACTIONS
EPA does not collect or is unable to obtain all ground water data:
* USGS collects a great deal of ground water data (e.g., monitors 1,000 wells per
year in Idaho) that are not routinely shared with EPA; and
Proprietary data, for example pesticide registration information, are commonly
not available.
Data formats used by the states are typically different than those used by EPA creating
difficulties in data transactions.
EPA data bases are not routinely or globally shared. Transfers of data are generally
viewed as a low priority activity within the agency. There is a need for the upper
management of EPA to promote such activities.
There is some question as to how useful the STORET data base is in facilitating
ground water protection efforts. The principal concerns revolve around the completeness
and accessibility of the data base (See page n-10 for further discussion of STORET).
EPA is in the process of developing a "roadmap" for ground water data sources within
the agency. This document is intended to facilitate exchange of information between
sections within the agency.
III. DATA ANALYSIS
Analysis of ground water contamination incidents should include some form of ranking
based on frequency (number of wells affected), magnitude (what % of the MCL),
proximity to uses, flow direction, and time trends.
IV. ACTIONS IN RESPONSE TO DATA ANALYSIS
Generally, actions to protect ground water quality are left to the states. Federal laws
are not sufficient to protect ground water through preventative action. The
implementation of the WHP Program will help, but its effectiveness is dependent upon
implementation of successful state programs and enactment of state and local enabling
legislation. Assisting in the development of state capability represents the greatest need.
Sole Source Aquifer designation represents another federal tool; however, it is of limited
effectiveness in resource protection because:
Designation requires petition from an agency or citizen group outside of EPA,
II-8
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The designation criteria are not oriented towards aquifers that demonstrate
susceptibility or vulnerability, and
0 The enabling federal legislation (SWDA) provides authority to address only
federally financially assisted activities.
The UIC section of the SDWA allows EPA to abate any underground injection well that
represents an immediate threat to an underground source of drinking water.
The states within Region 10 are in the process of developing Comprehensive State
Ground Water Protection Programs under guidance developed by EPA. Under these
programs, goals will be defined, priorities identified, responsibilities assigned, and
implementation actions specified. Such programs represent a vehicle for improvement of
data collection, transfer, and analysis processes.
The determination of what constitutes an "appropriate" response may necessarily differ
from state to state because the underlying tenets of water law vary. For example, a state
with water laws based on a non-degradation policy may view ground water contamination
differently than a state with laws based on an antidegradation policy.
Some local governments are acting unilaterally to investigate and/or address incipient
problems and are not necessarily informing EPA or the states as to what they are doing
or sharing relevant data.
II-9
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ADDITIONAL INFORMATION FROM QUESTIONNAIRES - EPA RESPONDENTS
EPA Assists the states in preparation of State Management Plans for pesticides. EPA
identifies those chemicals for which SMPs must be developed and determines if the
SMPs prepared by a state are adequate to protect ground water. If they are not, EPA
can eliminate the sale and use of the specific pesticide(s) that is the object of the SMP.
A risk/benefit analysis is a required portion of the SMP. (FIFRA 3(d)(l)(c)(ii))
The STORET data base is the most significant EPA data base concerning ground
water. A portion, but by no means all, of the state data is incorporated into STORET.
Apparently, not enough is done with the STORET data in terms of either data analysis
or transfer of data to other entities.
Impediments to prompt response to early warnings include:
* Laws in some states allow contamination up to the MCL, and
* There is no ambient monitoring system for early detection.
Responses to "let your mind wander question" include:
* Place ambient monitoring wells in appropriate locations,
* Obtain historical water quality data and look for time trends, and
* Properly utilize the data that is already available.
11-10
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DEVELOPMENT OF AN EARLY WARNING SYSTEM TO PREVENT IRRETRIEVABLE
LOSS OF AQUIFERS
WORKSHOP
November 18, 1993
USEPA Region 10
Portland, Oregon
Ranei Nomura
Rick-' Kepler
Jan Koehler
Barbara Priest
Ron Polvi
David Priebe
Cathy Neumann
Dennis. Nelson
Barry C Beyeler
Chuck Davis
Sheree Stewart
Dan DeMoss
Jeff Jenkins
.Heather Schijf
Curt Ireland
ATTENDEES
Wastewater Control, WQ, DEQ
Groundwater, DEQ
OR Water Resources Dept.
DEQ Standards & Assessment
OR Parks & Rec
OR Dept. of Agriculture
OR Health Division
OR ""Health Division
City of Boardman
Springfield Utility Board
Waste Mgmnt & Clnup, DEQ
OAWLL/Program Manager
OSU Dept. of Ag Chemistry
Site Assessment Prgm, DEQ
Portland Water Bureau
Marianne Fitzgerald Cross-Media Project, DEQ
Mary Alvey Oregon Health Division
EPA Project Managers:
Rene Fuentes Region 10 EPA, Seattle
Roseanne Lorenzana Region 10 EPA, Seattle
Consultants:
229-5256
229-6804
378-8455
229-5943
378-6821 x263
378-3776
731-4015
731-4010
481-9252
726-2396
229-5413
364-8269
737-5993
229-5657
823-7598
229-5946
731-4387
(206) 553-1599
(206) 553-8002
Adolfson Associates, Inc. Derek Sandison (206) 789-9658
Littler Environmental Consulting John Littler (206) 486-3861
Environmental Consultant Greg Glass (206) 523-1858
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DEVELOPMENT OF AN EARLY WARNING SYSTEM TO PREVENT
IRRETRIEVABLE LOSS OF AQUIFERS
WORKSHOP
November 30, 1993
USEPA Region 10
Seattle, Washington
Matt Gubitosa
Scott Downey
Garrett Wright
David Frank
Maryann Helferty
Rene Fuentes
Jerry Opatz
Ray Peterson
Martha Sabol
Consultants:
Derek Sandison
John Littler
Greg Glass
ATTENDEES
ESD/Data Management 553-4059
WD/Ground Water Section 553-0682
PTSB/Pesticides Section 553-1495
ESD/Risk Evaluation Branch 553-4019
WD/Ground Water Section 553-1901
ESD/Risk Evaluation Branch 553-1599
Drinking Water Section 553-4039
ESD/Data Management 553-1682
Ground Water Section 553-1593
Adolfson Associates, Inc. 789-9658
Littler Environmental Consulting 486-3861
Environmental Consultant 523-1858
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QUESTIONNAIRE RESPONDENTS
ENVIRONMENTAL PROTECTION AGENCY
Maryann Helferty - Oregon liaison
Martha Sabol - Water Division
Garrett Wright - Air and Toxics
Matt Gubitosa - Environmental Services
Ray Peterson - Environmental Services
OREGON HEALTH DIVISION
Mary Alvey -Drinking Water
Dennis Nelson - Drinking Water
Cathy Neumann - Toxicology
DEPARTMENT OF ENVIRONMENTAL OTTAT.TTY
Rick Kepler - Groundwater
Ranei Nomura - Wastewater Control
Sheree Stewart - Waste Management and Cleanup
Barbara Priest - Standards and Assessment
OTHER STATE AGENCIES
Jan Koehler - Water Resources
Ron Polvi - Parks and Recreation
David Priebe - Dept. of Agriculture
PUBLIC WATER UTILITIES
Barry Beyeler - City of Boardman
Chuck Davis - City of Springfield
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
\ REGION 10
3 REGIONAL POLLUTION PREVENTION PROJECT
DEVELOPMENT OF AN EARLY WARNING SYSTEM TO PREVENT
IRRETRIEVABLE LOSS OF AQUIFER RESOURCES
QUESTIONNAIRE
NAME: ;
TITLE/POSITION:
DIVISION:
DEPARTMENT/AGENCY:.
PHONE NUMBER:
Please complete the following questionnaire prior to the upcoming workshop, and bring it with you to the
workshop.
Respond "not applicable" or "N/A" where appropriate.
A. ABOUT YOURSELF AND YOUR AGENCY
1. Describe your individual role and also your agency's involvement with the use or protection of water
resources.
B. EXISTING GROUND WATER DATA COLLECTION EFFORTS
1. What specific ground water data sets do you collect and manage (including water chemistry data,
hydrogeologic data, aquifer resource data, contaminant source data, and land use data}?
For water quality data sets, estimate the number of sampling locations. What are the frequencies of
monitoring?
2. Are data maintained in computer (electronic) files or as hard copy (paper) records?
If kept in computer files, please specify hardware and software.
Pagel
Workshop - November 1993
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3. What types of ground water monitoring information are kept (what are the fields in the data records)?
What are the data formats?
4. Where are the data stored?
Are the data readily accessible? Who has access? What portion of data is archived?
NOTE: Please provide examples of data records (demonstrating format and fields) that you maintain.
C. DATA TRANSFER MECHANISMS
1. Do you share ground water data with other divisions of your own agency or other agencies?
With who?
As a regular procedure, or only upon specific request?
2. How frequently is data shared?
How long after initial data collection?
3. For what purposes are data shared with other divisions or agencies?
4. What criteria are used to determine who gets data and how often?
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Workshop - November 1993
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5. In what manner and in what format are data transferred?
How are data compatibility issues addressed?
6. After data is shared, is there any feedback from the agency receiving the data concerning how the data was
used?
7. Does everyone receive ground water data that should?
If not, why?
D. DATA EVALUATION
1. What types and/methods of data evaluation do you perform?
2. Who within your department or agency performs the evaluations?
3. How are data evaluations documented (e.g., tables, figures, written memoranda or reports, or computer
files)?
4. For what purpose are data evaluations performed?
5. What criteria is used for evaluation?
6. Who receives the results of the data evaluations?
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Workshop November 1993
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7. If evaluating water chemistry data, what other data, in addition to the chemical data, are incorporated into
the evaluation?
8. In what way is data quality/reliability considered in performing evaluations?
E. LINKING DATA EVALUATIONS TO RESOURCE PROTECTION ACTIONS
1. What types of ground water protection actions are currently available to your department or agency?
2. What are the thresholds used by your department or agency in deciding whether to undertake a response
action (e.g., violation of an MCL)?
3. Under what existing legal authority is your department or agency able to or required to undertake actions
to protect ground water resources? Please cite specific laws, regulations, or policies.
Are there limitations in the scope or applicability of that authority?
4. Are the roles of departments and agencies which are responsible for ground water protection clearly
defined?
5. Why have ground water quality problems historically been addressed "later" rather than "sooner"?
6. What are the greatest impediments to early and effective action to protect ground water resources?
7. Let your mind wander....If data were available to convince you that an aquifer (or portion of) was
threatened, what steps could happen to prevent the loss? What kind of data would it be? What would you do
with the data?
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Workshop - November 1993
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SECTION HI - INTERVIEW SUMMARIES
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TASK 2 - EXPANDED INTERVIEWS
LIST OF INTERVIEWEES
ENVIRONMENTAL PROTECTION AGENCY
Maryann Helferty, Oregon Liaison - Field interviews March 29th and May 12th
Scott Downey, Washington liaison - Field interview March 29th
Grover Partee, Alaska Liaison - Field interview May 12th
Craig Paulson - Tribal Liaison - Field interview May 4th and May 12th
Matt Gubitosa, GIS - Field Interview April 28th
Garrett Wright, Pesticides - Field interview May 4th
Bill Mullen, Office of Groundwater - Field interview May 13th
OREGON STAFF
Mary Alvey, Drinking Water, OHD - Phone interview pending
Dennis Nelson, Drinking Water, OHD - Field interview May 4th
Cathy Neumann, Toxicology, OHD - Phone interview May 19th
Rick Kepler, Groundwater, DEQ - Field interview May 4th
Sheree Stewart - Waste Management and Cleanup, DEQ - Field Interview May 4th
Marianne Fitzgerald - Cross Media Project, DEQ - Phone interview pending
Barbara Priest - Standards and Assessment, DEQ - Field interview May 3rd
Sandy Gurkewitz - Toxics Use Reduction, DEQ - Field Interview May 3rd
Jeff Jenkins - OSU Department of Ag Chemistry - Phone interview May 16th
PUBLIC WATER SYSTEM OPERATORS
Chuck Davis, Springfield Utility - Field interview May 14th, Phone interview May 16th
Denny Klingbile, Damascus Water District - Field interview May 14th
John Thomas, Mt. Scott Water District - Field Interview May 14th
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REGION 10 POLLUTION PREVENTION PROJECT
INTERVIEWEE: Matt Gubitosa
AFFILIATION: U.S. Environmental Protection Agency, Region 10
INTERVIEWER: Greg Glass
DATE: April 28, 1994
Matt attended the November 1993 workshop in Seattle. He manages EPA Region 10's
ground water database and GLS software project.
The original idea behind EPA's regional ground water database project was to compile data
across programs (e.g., RCRA and Superfund) so that site managers could easily access
information relevant to a given site vicinity. (Prior to this project, it was difficult and time
consuming for individual EPA site managers to track down data from other nearby sites or
other EPA programs). While Matt is in contact with state database coordinators and
periodically gets some data files from them, he readily acknowledges that he does not have
"all the ground water data". Additional data sets are worked into the EPA database system
as time and resources allow.
A standard ground water data submittal format was established in 1989. (Pre-1989 data
from EPA files are being added to the database over time, a process now largely
completed). It is being used, for example, as an attachment to EPA orders or consent
decrees at Superfund sites (e.g., where PRPs or their contractors will be producing the data).
EPA can be somewhat flexible about details of data formats for submittals, as long as entry
into the database system can be assured. (There are a lot of options for the software
platform that can be used to submit data). EPA project managers provide data submittals
to Matt, with about 2/3 of the data coming from Superfund and about 1/3 from RCRA
programs. No data from the underground injection control program have been incorporated
yet; UIC is more prevalent in Alaska and Idaho, according to Matt. In a few cases, NPDES
program sites may also produce ground water data.
Matt provided a written copy of EPA Region 10's ground water data submittal requirements,
as well as files on disk with standard formats. Specific data elements are identified and
described. A review of these specific database fields may be useful in thinking about the
types of data evaluations that could be included within the analytical tool. It may also be
useful to compare state database formats against EPA Region 10's format to identify
common and disparate elements.
Matt discussed data sets that he knew existed but that were not included in his regional
database. None of the normal monitoring data for drinking water supply wells are being
compiled in his project. Research studies are likewise not included. Pesticides data are also
largely omitted from the database so far (a lot of the pesticides data exist at the state level).
Matt noted that USGS is doing a substantial amount of ground water monitoring work,
often in cooperation with the states (e.g., Yakima area, Whidbey Island). USGS maintains
its own databases and submits data to the STORET system, which Matt characterized as
"antiquated" (having been developed before the PC revolution). Matt can access STORET,
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or the local PC-based version of STORET used for local data, on request by EPA project
managers, but he does not regularly review or incorporate STORET data.
Matt noted that there were about 8,000 ground water well locations in the 4 state region.
(That obviously does not count small domestic drinking water wells). The states have begun
projects to develop statewide databases; they are reportedly being designed to be compatible
with the EPA database. Some state agencies are doing the database development
themselves; others (e.g., Idaho) are using contractors.
Matt compiles and uses both chemical data and descriptor data (e.g., well location, well
construction) in his ground water program. For creating GIS maps, he uses a large number
of other spatially-based data files to create GIS layers. Most of the effort in the project so
far has gone into assembling the database, and not data analysis. Matt thought there was
about another year of heavy effort on database compilation.
Matt described his current work as focused on "data displays" rather than "data evaluations".
He does not, for example, do any significant statistical data evaluations (correlations, time
trends, etc.). He said he thought ground water data would typically be exported from his
database to another platform for statistical evaluations. The hydrogeologists and risk
assessors at EPA are more likely to do data evaluations, including statistical evaluations.
Matt noted that kriging was available within ARCINFO, as well as some very limited
statistical capabilities. For one WA site they tried to do the risk analysis within ARCINFO,
but decided that was not a very useful approach.
The EPA GIS group appears to have a broad capability for data mapping. Matt showed me
a number of products from previous or ongoing EPA projects.
I asked Matt if he could identify good candidates for case studies to illustrate missed
opportunities for early detection/response to ground water problems. He mentioned the
Tacoma Landfill site, where there were about 10 years of data. He thought the city of
Fircrest wells were just starting to show impacts last year, even though a ground water
extraction system was in place. (We may have to determine if this reflects a prompt but
ineffective response to ground water contamination, or a deferral of appropriate actions).
Matt mentioned that the Manchester lab maintains a separate laboratory database with
ground water data. There is poor coordination of the lab database with his database. He
sometimes gets data files from Manchester, but there is no systematic program for such
transfers of data.
With respect to Matt doing any GIS work as part of our Phase 2 effort, we would route
requests to him through our EPA project leads and he would then review them along with
other requests to see if he had time and resources to respond. If we needed to add new
information for GIS evaluations for our project, that would be easy for him to accommodate
(working out details of formats with him).
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REGION 10 POLLUTION PREVENTION PROJECT
INTERVIEWEE Garrett Wright
AFFILIATION: U.S. Environmental Protection Agency, Region 10
INTERVIEWER: Greg Glass
DATE May 4, 1994
Garrett has worked in EPA's pesticides program since 1987, and was with the cooperative
extension service before that. He attended the November 1993 workshop in Seattle.
A primary motivation for this interview was to explore how information from the initial
surveys of pesticides in ground water was evaluated, and what actions followed from the
detection of pesticide contamination. There was an initial perception that responses in the
case of pesticide contamination of ground water have been more direct and have progressed
further than has been the case for other types of ground water contamination.
Garrett reviewed the development of EPA's ground water program for pesticides. He also
provided a large number of supporting documents after the interview. (All documents
received are being maintained in the project file). Review of those documents was very
helpful in understanding the development of a strategy for addressing pesticide
contamination in ground water, involving cooperative actions by both EPA and the states.
In some ways, pesticides do offer a useful policy "case study" for some of the ideas that have
motivated the current EPA Region 10 project It also appears that the more advanced
strategy and program for addressing pesticides in ground water is in large part attributable
to existing legislation (FIFRA), large and identifiable affected groups (pesticide
manufacturers and users), EPA's use of the pesticides problem as a first illustration for
development of its overall ground water protection strategy, and other coincidental factors.
From the perspective of agency staff working on pesticide contamination problems, progress
is very slow. There have been reports of substantial pesticide problems in selected locations
(sensitive/vulnerable ground water resources) dating back to at least the early 1980's.
Nevertheless, current activities within the overall strategy for pesticides in ground water do
provide an illustration of actions taken in response to detection of ground water
contamination, even if many of those actions focus on prevention of ground water
contamination in the first place rather than early response to avoid further losses of ground
water resources.
I asked Garrett if he could identify any good "case studies" where opportunities for early
responses to ground water contamination were missed. Garrett immediately noted a
pesticide and nitrate contamination problem on the Shoshone-Bannock tribal lands near
Pocatello, Idaho. He identified the key EPA Region 10 contact as Craig Paulsen; I met with
Craig alter completing the interview with Garrett (a separate summary is provided for
discussions with Craig regarding the Shoshone-Bannock problem). Although retrospective
compilation of ground water monitoring data for the tribal lands showed that pesticide and
nitrate contamination had been detected earlier, the true problem (especially regarding safe
drinking water supplies to several thousand people served by ground water wells) was not
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recognized until late 1993. Substantial actions by several agencies, including an emergency
order by EPA under the Safe Drinking Water Act, followed soon after confirmation of the
scope of the problem. The site is currently the focus of a great deal of attention and
continuing agency actions. Garrett commented that the main pesticide problem in ground
water (but not the only one) related to EDB (ethylene dibromide). Since EPA had already
cancelled the registration for EDB use as a pesticide several years ago, there was nothing
more that the pesticides program could do. This illustrates the importance of appropriate
"handoffs" among programs and agencies if appropriate early response actions are to be
identified and implemented.
EPA actions on pesticide registrations occur under FIFRA, a statute that specifically
requires consideration of costs and benefits of EPA actions (i.e., the context is larger than
just environmental issues). When ground water contamination by agricultural chemicals
began to be recognized in the late 1970's, for example in studies in New York and
California, EPA did take some early actions. Pesticide registrations for certain chemicals
shown to have affected ground water quality were suspended or revoked. Manufacturers
also took voluntary actions, such as agreements not to sell specific chemicals in certain areas
of demonstrated vulnerability, or to withdraw from labeled uses applications to specific
crops. EPA development of an overall strategy for pesticides in ground water has evolved
over more than a decade.
Under FIFRA, pesticide-specific rules are the real focus for EPA actions. Once EPA
identifies a specific pesticide for evaluation (e.g., based on perceptions of possible problems
with its use) and rulemaking, states have to develop State Management Plans for that
pesticide, for review and approval by EPA. That pesticide can then be used only in states
whose management plans have been approved. This process of listing specific pesticides and
approving State Management Plans takes several years for each individual chemical, and is
just starting. This framework is really dictated by the nature of the underlying legislation
(FIFRA). However, EPA has recognized the larger ground water protection issues involved
and has found ways to enhance state capabilities on a broader front, providing supporting
grants for state development of more general programs.
EPA released an overall ground water protection strategy in 1991. A final Pesticides and
Ground Water Strategy was also released in 1991 and is in many ways the test bed for the
overall strategy, focusing on a federal-state cooperative approach and on preventing ground
water contamination rather than remediating already contaminated ground water. EPA is
encouraging, and supporting with grants, the development of State Management Plans for
pesticides; it is the intent that these will form part of larger State Ground Water Protection
Programs. EPA has issued guidance for these State Management Plans for pesticides
(1993). Notably, while under FIFRA plans to manage specific pesticides are required, the
guidance encourages states to develop generic management plans that can address issues
such as philosophy and goals; roles and responsibilities of state agencies; monitoring;
prevention actions; and response to detections of pesticides. (See EPA 735-B-93-005a,
Guidance for Pesticides and Ground Water State Management Plans, Office of Prevention,
Pesticides, and Toxic Substances). Various funding mechanisms under multiple laws and
programs are being used to support these activities at the state level. Garrett commented
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that EPA hopes for a "spillover effect" from the state planning for pesticides (e.g., in
establishing interagency communications and coordination).
The development of the national strategy for pesticides and ground water has taken place
against a 5-year national survey (statistically designed) of pesticides in drinking water wells
(completed in about 1990) and numerous state-level surveys. Garrett provided information
on both Washington and Oregon state surveys and results. Overall, a relatively large
number of agricultural chemicals have been detected in ground water, at times at levels
above health-based reference levels, advisories, or drinking water standards. Garrett noted
the primary role of the states in addressing such detected pesticide problems in ground
water. He felt in many ways they can move faster than EPA due to the limitations inherent
in FIFRA (although resources continue to be a significant problem for the states). Garrett
provided a number of reports and summaries of activities under cooperative agreements
between EPA and Oregon to illustrate how specific components of state responses to the
recognition of ground water pesticide problems are being developed.
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REGION 10 POLLUTION PREVENTION PROJECT
INTERVIEWEE: Craig Paulsen
AFFILIATION: U.S. Environmental Protection Agency, Region 10
INTERVIEWER: Greg Glass
DATE May 4, 1994
Craig works in the EPA ground water program and has specific responsibility for tribal lands
in the region. Based on Garrett Wright's suggestion that the Shoshone-Bannock site might
be a good case study, I met with Craig to get additional information on the ground water
issues and data there. (Note: Craig later participated in a group interview at EPA on May
12th, summarized separately).
Craig identified a key contact at the Shoshone-Bannock site: Charlie Bidondo, telephone
208-238-3733 (FAX 208-237-0797). He is coordinating the tribal response to ground water
contamination, and was described by Craig as being a good communicator. Craig noted that
when the problem was recognized, an attempt was made to pull together all of the relevant
(historical) site data; that report should be available through Charlie Bidondo. Craig
thought that ground water monitoring has been conducted since at least the 1970's.
Craig provided copies of two internal memoranda he wrote in March 1994 that succinctly
described the problem. He also referred to a large map as we talked, showing a lot of the
site ground water information. There is a great deal of current activity related to ground
water problems and response actions at the site, something to which we will need to be
sensitive if we decide to pursue this site. There are also jurisdictional issues among the tribe
and various local, state, and federal agencies.
According to Craig, a Boise consulting firm has been working with the tribe on ground water
studies. A Draft Ground Water Investigation Report has apparently been prepared already.
Tribal lands are located north of Pocatello. Ground water contamination reflects
agricultural land use (pesticide use) and the sensitivity of ground water resources (sandy
soils, shallow uppermost aquifer). EDB and nitrates are among the detected contaminants
of concern. Craig thought the last EDB applications were in 1986 (after EDB registration
had been pulled). General application practices are reported to have been appropriate (at
about one-half the label application rate); the problems seem to relate more to the
sensitivity of local ground water. There is anecdotal evidence of some drum or dump sites
related to pesticide use. Studies to date have shown fluctuating EDB concentrations over
time in some wells, and no general spatial pattern in contamination that can be related to
specific sources.
Current concerns over ground water contamination date to November 1993, when routine
supply system monitoring conducted the previous September under the Safe Drinking Water
Act reported EDB. Two rounds of repeated sampling through December 1993 did not
confirm EDB presence. However, there were some issues related to lab capabilities and
performance. Moreover, EPA looked for historic ground water monitoring data in the area
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and discovered numerous reports of detected pesticides and agricultural-related chemicals
in ground water. One sample in a private water supply well from June 1990 had actually
been reported to contain 4,000 times the drinking water standard for EDB. EPA decided
that it needed to conduct its own confirmatory sampling; when the results were obtained in
February 1994, EDB contamination at up to 300 times the MCL was found. Nitrates also
exceeded the MCL. Those findings precipitated many actions, including an EPA Emergency
Order under Section 1431 of the Safe Drinking Water Act, intensive sampling of water
supply wells throughout tribal lands, an emergency declaration from the Governor of Idaho,
and steps to provide alternate water supplies.
EDB has been detected in ground water to a depth of 300 feet according to Craig, with
generally decreasing concentrations with greater depths. Ground water flows toward
Pocatello. Ground water flows at a high velocity of about 70 feet per day in the porous
materials of the aquifer, with very large flow volumes. This may mitigate the vulnerability
of Pocatello water supplies; any interception or containment of the contaminated ground
water appears impractical. Shallower ground water resources are used for irrigation
throughout the valley. There is some thought that irrigation withdrawals may partially
provide "treatment" for the contamination problem.
After detection of the contamination problem, EPA provided large amounts of clean
drinking water at central distribution points within tribal lands until alternate water supplies
could be provided. Residents in outlying areas with contaminated private supply wells had
to pick up and haul their own water. Consideration is being given to interconnecting with
other available water supply systems and to developing a new tribal water supply upgradient
from the contaminated areas. Granular activated carbon systems are meanwhile in place
and being operated for the contaminated water supply systems. There is also a program to
case existing wells (deeper supplies) to isolate them from contaminated ground water.
Health agencies may be conducting several studies of community health (e.g., blue baby
syndrome from nitrates, anecdotal elevated cancer rates). Health advisories and public
education are also required under the EPA Emergency Order, as are development of Best
Management Practices for pesticide use and a comprehensive ground water monitoring
program.
This situation appears to present a case where early ground water monitoring produced a
record of detected contamination, with no effective actions taken until years later when
"regulatory" (required) monitoring results led to recognition of a problem. In this case,
drinking water supplies for several thousand persons were ultimately found to be affected.
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REGION 10 POLLUTION PREVENTION PROJECT
INTERVIEWEE: Grover Partee, Craig Paulsen, Maryann Helferty
AFFILIATION: U.S. Environmental Protection Agency, Region 10
INTERVIEWERS: Greg Glass and Derek Sandison
DATE: May 12, 1994
(Note: see also the interview summary by Derek Sandison, Adolfson Associates)
Maryann Helferty, coordinator for Oregon ground water programs, had previously attended
the Seattle workshop in November 1993, as well as an additional project meeting. Grover
Partee and Craig Paulsen are the ground water coordinators for Alaska and tribal lands in
Region 10, respectively. Craig had previously met with Greg Glass on May 4th regarding
the Shoshone-Bannock tribe situation (see separate summary).
Discussions in this group interview largely confirmed that institutional framework problems
were generalizable from Oregon to other parts of Region 10. Data transfer and agency
coordination problems were noted with respect to effective early responses to ground water
problems. Grover commented that in Alaska the culture of the agencies was to deal
primarily with their individual responsibilities; they did not see much need to interact. Craig
noted similar issues for the tribes. He thought they showed a lot of variability in their
interactions with the states, but with a dominant theme of preserving tribal sovereignty.
(Jurisdictional issues can be complicated by non-tribal members living on tribal lands).
Most of the tribes were described as significantly behind the states in their attempts to deal
with ground water contamination problems.
Resource issues were highlighted as a continuing problem. The states and tribes were
characterized as having few available resources to do development of analytical tools or
protocols for data transfers or evaluations. A ready-to-use standard protocol was felt to
have a greater potential for application within the region. Maryann suggested the possibility
of building a standard approach into wellhead protection programs. At the same time, it
was noted that some resistance to having to adapt to a new standard protocol could be
expected from the states.
Effective communication and sharing of information on ground water monitoring results was
also thought to be very important to meet the objectives of early recognition and
appropriate response to ground water contamination. Database development was noted as
underway, using EPA grant money, with some beginning work to assess data formats and
data transfer requirements. Existing systems are not effective or sufficiently flexible. Past
problems in EPA changing database requirements over time, after state investments to
develop tools under prior formats, were noted by Craig ("EPA pulling the rug out from
under the states"). Maryann noted that even though grant money was available to fund a
GIS position in Oregon, the state had trouble finding an experienced person willing to take
a short-term position with only temporary funding. She also wondered if there was a
possibility of earmarking some money from collected penalties to fund work on data transfer
problems (as a "Supplemental Environmental Project").
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Grover thought any effective data transfer system among the agencies should have the
following characteristics: 1) "translator" functions to achieve standard formats for database
entry should be transparent to the individual users wherever possible (e.g., among various
well location descriptors); 2) acceptance by various users would be increased if they
perceived added benefits of the new system; and 3) backwards compatibility is necessary (no
loss of records).
The general consensus was that all data should be shared among the agencies. It was
recognized that there were privacy concerns or legal restrictions that could limit the release
of certain data. Data quality issues were noted as important. The precision and accuracy
of various data sets are important facts to preserve; blind mixing of data of different quality
should be avoided. Grover commented that in Alaska there is a great deal of basic
information lacking on ground water quality.
Craig commented that beyond the issue of sharing ground water data, there was a question
of knowing what to do with data once they are shared. He thought in the case of the
Shoshone-Bannock tribe pesticide contamination problem, early data had in fact been
reported but in a way that did not make it clear what the potential problems were. As a
result, no actions were taken for several years. Maryann Helferty thought there were similar
problems with monitoring related to injection wells (e.g., food processing wastewaters).
Some criteria that could be used to set priorities for detected ground water contamination
are comparisons to criteria (e.g., percent of MCL); population served by ground water;
toxicity of detected contaminants; and ground water vulnerability. Information would have
to be available and readily extracted from existing data sets to be useful for ranking
problems.
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REGION 10 POLLUTION PREVENTION PROJECT
INTERVIEWEE: Jeff Jenkins
AFFILIATION: Oregon State University
INTERVIEWER: Greg Glass (telephone)
DATE: May 16, 1994
Jeff attended the November 1993 Oregon workshop. He is in the Extension Environmental
Chemistry and Toxicology Program at OSU, working mainly in the area of pesticides. Jeff
has worked with a lot of the user groups in agriculture, forestry, nurserymen, and similar
occupations using agricultural chemicals. He has worked under numerous grants and
agency-funded projects on database development, vulnerability assessments, risk assessments,
and related ground water contamination issues.
Jeff maintains very close contact in all of his activities with the person responsible for the
State Management Plan for pesticides. The federal process for dealing with pesticide
problems in ground water (listing individual chemicals and requiring management plans for
each one) is very slow. More general activities for addressing pesticide problems are being
pursued under the framework of the State Management Plan for Oregon, allowing progress
to be made outside of the EPA pesticide-by-pesticide approach.
ODEQ has a "detects" database for ground water data. Jeff said a fellow professor, now
retired, has a contract with ODEQ to improve the database. Jeff characterized it as a slow
process and said the database is not really that useful in its current form. The current
database does not really support screening or summary characterizations such as the
frequencies of detection for various contaminants.
Using EPA grant money, Jeff has been developing databases on pesticide properties (e.g.,
solubility, fate and mobility) and soil properties (sensitivity measures for ground water
contamination). He is also working in combining various types of information in ground
water vulnerability assessments for Oregon.
Jeff is applying for additional grant money under the wellhead protection program (ODEQ
"319" funds) to focus on exposure assessment issues, especially how pesticides get into
ground water. He commented that toxicity information would then be useful to prioritize
chemicals with potential exposures based on their risks, as part of a broader evaluation.
Ground water monitoring was identified as an important part of the strategy for minimizing
pesticide problems in ground water (early detection/early response). Jeff expressed the
opinion that the agencies know what an effective monitoring approach would be, given more
resources. With limited resources, the ground water monitoring strategy should be based
on a rationale of looking at locations and for chemicals that are most likely to be found (i.e.,
a biased monitoring strategy, looking for "indicators"). Criteria could include, for example,
the amount of pesticide use, specific pesticide properties (e.g., fate and mobility), soil
properties, ground water vulnerability (depth), and so on. This is the approach he has been
taking in his work, to develop and apply such information.
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An individual working for Jeff has been doing pesticide use surveys for the past 12 years.
The details of survey practices have varied over the years. Data are compiled for all major
crop groupings, for all counties, and for all pesticides. The spatial resolution may not
support detailed GIS-type analyses or vulnerability evaluations, but are nonetheless useful.
Jeff said there was a significant effort underway to improve use reporting for pesticides,
which was running into some privacy concern constraints.
I asked Jeff about factors that should be used to set priorities for further assessment/action
among ground water detects. He commented that the basic state approach is "percent of
MCL". Other criteria could include amount of chemical use (indicator of extent of
problem?), toxicity measures (included in setting MCLs), the properties of chemicals
(sensitivity issues), or the degree of ground water use. Jeff noted that something simple like
nitrate testing (required in Oregon for real estate transactions) could provide good
information on sensitivity of ground water to contamination.
One area where Jeff thought a lot could be accomplished was in education on irrigation
practices. Irrigation and not precipitation may be the biggest factor affecting pesticide
leaching to ground water in Oregon. Jeff works a lot with user groups on education to
prevent or minimize contamination problems. His general opinion seemed to be that there
was concern over a few "bad actors" causing problems for the larger user groups, but that
most individuals were interested in "doing it right". There is no real incentive to
overuse/misapply pesticides (in fact, an economic disincentive). Jeff noted that special
measures are appropriate to protect certain sensitive areas (hence his research focus); in
many areas, pesticides can be used properly without much risk to ground water. (The
problems of vulnerability are site-specific). The kinds of information users need to have
more of is fundamental knowledge about the properties of the chemicals they use and the
soil/ground water sensitivity.
I asked Jeff what evaluations he thought should be done to decide what actions to take in
cases of ground water contamination. He is currently working under a USDA grant on a
three-tiered process to evaluate ground water data. The level of detail and sophistication
increases from one tier to the next; the evaluation would proceed only as far as needed to
make a decision. The nature of the problem and the difficulty or consequences of various
possible actions affect the depth of analysis needed (decision theory framework). Thus, the
availability, cost, and effectiveness (greater crop loss?) of alternative pesticides may
determine whether a simple, conservative analysis or a detailed modeling approach is
required. Jeff is preparing a manuscript on this tool for an American Chemical Society
Symposium; he will send me a copy when available (with information on specific types of
information and evaluations used). At the simplest level, conservative assessments of basic
soil and pesticide properties could give "yes/no/maybe" answers that may be adequate for
simple decisions. At the next tier, screening-level fate and transport models may be used
together with regional data to construct scenarios for evaluation. The most detailed analyses
would constitute site-specific evaluations that might be comparable to Superfund site RI/FS
studies.
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REGION 10 POLLUTION PREVENTION PROJECT
INTERVffiWEE: Cathy Neumann
AFFILIATION: Oregon Health Department
INTERVIEWER: Greg Glass (telephone)
DATE: May 19, 1994
Cathy attended the November 1993 Oregon workshop. She remembered the purpose of the
project; our discussions therefore focused on more specific followup questions.
Cathy does not do regular reviews of ground water databases. She becomes involved when
a specific program, e.g. ODEQ or the DW program, brings her in based on detected
contaminants in ground water (on-call role). She has been in her position for about 15
months.
She has been involved in about 6 sites in the last 15 months. Those sites involved diverse
contaminants (PCP, PCE, BTEX, asbestos) with no one type dominating. She has not had
pesticide or agricultural chemical cases, not is she much involved in bacteriological
problems. Considering those types of problems, the frequency would be somewhat more
than the 6 per year she noted.
We talked about case studies. She could not recall seeing cases where early recognition and
early action opportunities had been missed; her experience has been that agency evaluations
have been pretty fast after first detection in ground water data. The biggest timing concern
has been whether to issue notification or advisories before data validation is complete (i.e.,
based on preliminary, non QA'd data).
Cathy commented that she wishes we were doing this project for fish/shellfish
contamination. She said she thinks Oregon needs to be issuing additional health advisories
for fish consumption, based on the available data she has reviewed. I found this comment
quite interesting; it may indicate that the problem we are addressing re: ground water data
(early and appropriately protective responses to monitoring data) is in fact generalizable to
other areas.
Cathy prepares Fact Sheets or advisories, and works with the agencies on risk
communication, for problem sites. The manner in which she participates depends on which
program has the lead role on the project (e.g., ODEQ or OHD). She identified the main
issues as being problem characterization/source identification; health effects evaluations;
and steps for mitigation. ODEQ typically works on characterization/source issues and
engineering questions (filtering, alternate water supplies); she focuses on health effects
issues.
I asked Cathy to describe how she evaluates the ground water data. She said the process
was "best judgment" (i.e., not formally defined), with SDWA MCLs (or advisories) as the
obvious screening criteria. Cathy said the general policy was to "notify if detected", and then
to assess specific additional recommendations based on concentrations in comparison to
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MCLs. Recommendations could include broader or continued sampling; she noted a case
where initial data showed x2 MCLs, but further sampling showed x20 (Monmouth, OR
asbestos problem from corrosivity and pipe deterioration). I asked whether the whole focus
was on addressing drinking water concerns (i.e., whether the issue of aquifer degradation
was also considered); I understood Cathy to say that working with the other agencies (e.g.,
ODEQ) the broader context of source identification and aquifer protection could be
considered, but I am not sure to what extent there is real followup. In any event, it is a
question that really moves beyond Cathy's direct role at ground water contamination sites.
I asked Cathy whether in her experience supply wells were being turned off after detection
of contamination, with loss of information. She said she did not think that was common.
Often there are capacity problems, or few readily available alternatives that do not have
degraded quality (e.g., naturally high Fe or Mn). She commented, however, that she
probably would not be the person to ask about this issue. Cathy also said that in some cases
the concern was over losing a low cost (private) water supply and having to use a higher cost
(public) water supply, so there was a bias against turning off the well.
I asked Cathy what she thought the agencies needed re: evaluating ground water data, or
what she would want at her desk to help assess a problem. She replied that a chemical
database that was integrated across agencies and readily updated, as well as CIS mapping
capabilities, would be high on her list We only started to identify the kinds of GIS layers
she would want (vulnerability/sensitivity, map of sampling data, public well system locations
and use, demographic information, irrigation water use, source information/chemical use,
soil types...).
Cathy commented that the existing monitoring programs might be missing some problems,
and it might make sense to do more testing in some areas (e.g. private wells in
agricultural/high chemical use areas).
Toxicity data are very important given Cathy's role on ground water problems. She uses a
number of available toxicity databases to obtain information, from standard EPA sources
(IRK, HEAST) to RTECS to specialized agricultural chemicals databases. Cathy did not
feel missing toxicity information had been a significant problem at her sites.
In response to her public notifications and Fact Sheets, Cathy sometimes gets requests for
biomonitoring or health assessment studies. She works out risk issues with affected parties
on a case by case basis.
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REGION 10 POLLUTION PREVENTION PROJECT
INTERVIEWEE: Barbara Priest and Sandy Gurkewitz
AFFILIATION: Department of Environmental Quality
INTERVIEWER: Derek Sandison
DATE: May 3, 1994
Oregon DEQ has adopted a broader view of Pollution Prevention that would encompass
the pollution minimization approach of the EPA project. Front end reduction is still
emphasized; however, mitigation, particularly at existing facilities, is also an accepted
approach. The "trigger" for imposing mitigation requirement is the business license
review process.
Thirty-two areas within Oregon could qualify as Ground Water Management Areas;
however, resources are not available to pursue more than the current two GWMAs.
Regarding OHD data:
- Health data difficult to obtain;
- OHD doesn't track wells that aren't in current production, some public water
system wells haven't been tested since the 1930's;
- Often, wells that test positive for VOCs are removed from service and not
further tested creating dead ends in the data base; and
- Private drinking water wells aren't being tested, except wells tested under the
property transfer program.
Regarding other data sources:
- Various sections within DEQ maintain data concerning spills, UST, LUST, etc.
that isn't routinely circulated to other divisions or departments;
- Landfill monitoring data would be helpful; however, enforcement of monitoring
requirements is lacking;
- Hazardous waste reduction plans for businesses may be a source of information
concerning potential contaminant sources;
- An effort should be made to link hazardous waste generator and other DEQ
data with specific well sites (an argument for WHP tie-in);
- There is a Pollution Prevention Plan Requirement for permitted subsurface
stormwater disposal systems; however, only about 1,000 of the 17,000 potentially
regulated systems are currently under NPDES permit; and
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- Bacteriological test results may be early indicators of vulnerability; however,
great significance is generally not attached to such data
Public Water Utilities need to gain a better understanding of ground and surface water
interaction (used Springfield as an example of a community that has an appropriate
understanding.)
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REGION 10 POLLUTION PREVENTION PROJECT
INTERVIEWEE: Dennis Nelson
AFFILIATION: Oregon Health Division - Drinking Water
INTERVIEWER: Derek Sandison (Also interviewed by John Littler)
DATE: May 4, 1994
Once you are seeing detects in PWS wells, you are past the point of early warning; it is a
pretty strong indication that there is a significant problem. Also, for most public supply
wells, only a single test for organic compounds has been conducted; thus, insufficient
information is available for time trends and other analyses. Whatever analytical tool is
developed, it must be capable of working with single sample data.
A large amount of data is collected by the various state agencies, but that data is
generally not pooled or shared.
There is no current "framework" for automatic data transfers. There are no mutually
accepted "triggers" for data transfers. Currently, the determination of what thresholds
will trigger data transfers or response is made on a case by case basis by individuals
within DEQ and OHD. There is a need for common evaluation criteria and a system or
process for determining who needs to know and when (mentioned the DEM notification
sheet as an example). That system or process should be designed to be compatible with
and implementatable within all agencies. In a time of budgetary and personnel resource
limitations, a mechanism for effectively prioritizing agency activities would be helpful.
The driving force in the decision making process is what is the contaminant (e.g.,
chemical v. microbial) and what is the concentration.
Suggested that hits could be automatically flagged by the computer in a manner similar
to the daily "alerts" system OHD currently utilizes, but noted that the evaluation of alerts
data is still subject to subjective opinion. Additionally, the alerts are not routinely
shared with DEQ because DEQ does not want to see all data, and there is no set criteria
for determining what data they might want to see. Alerts are sent to the appropriate
OHD regional offices and local health departments (those with drinking water
programs).
At present, OHD is able to respond to MCL violations of organic contaminants;
however, this is not true of bacteria and nitrates. OHD knows where major problems
are, but lacks adequate staff for proper follow-through. There is a reluctance on the
divison's part to expand any programs. "Everyone is beaten down."
The primary function of OHD (drinking water) is implementation of the Safe Drinking
Water Act This brings up the issue of differing agency goals in terms of ground water
protection. OHD is primarily responsible for protecting health, specifically, ensuring
public water supplies do not exceed the MCL; while DEQ is responsible for enforcing
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the antidegradation policy, that is, preventing any significant deterioration of the quality
of ground water regardless of beneficial use.
Feels that DEQ see's a lot more ground water quality data than OHD.
Interaction with local health departments and utilities is important. At some point, he
wants to see direct access by local health departments to the OHD computer. Probably
all county governments would respond to a problem should one arise (help in sampling
and contacting people).
OHD is currently assisting DEQ in the promotion of the Wellhead Protection (WHP)
Program. WHP involves making land use management decisions that are appropriately
local decisions. Local decision makers should be involved in WHP Program from day
one. One of the first steps should be public involvement including local and state
agencies; this should help give everyone a sense of ownership in the program. A
guideline document for management strategies is being developed by DEQ and OHD.
Currently, WHP is expected to be a voluntary program. A "club" for inducing PWSs to
prepare WHP programs does not appear to be on the horizon. Potentially, an incentive
program could be developed.
The problem with wells being abandoned after VOC or SOC hits is being rectified, the
well will continue to be carried in the data base and all previous data on the well will
remain accessible. Common scenario: public water system wells are being shut down two
to three times a week for chemical detects, taste and odor, chloride, hydrogen sulfide,
etc. OHD will see a hit, perhaps another hit, then no new data.
Suggested La Pine as a case study (included problems with nitrate, BTEX, and
pesticides).
On a daily basis, OHD processes data from 30 chemical analyses and 100 bacteriological
analyses. They are six to eight months behind processing.
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REGION 10 POLLUTION PREVENTION PROJECT
INTERVIEWEE: Rick Kepler
AFFILIATION: Department of Environmental Quality
INTERVIEWER: Derek Sandison (Also interviewed by John Littler)
DATE: May 4, 1994
Doesn't consider this project pollution prevention. DEQ is never going to be able to
respond effectively after contamination has reached a public water supply well.
A single sample may give you an indication that something is occurring, but it doesn't
tell you much.
Excited about formalizing the process of sharing data and communication between
departments. Need to establish lines of communication, coordinating mechanisms,
perhaps a decision tree, and/or a "roadmap." Currently have problems with system and
file structure compatibility. Location designators are a particularly significant problem.
Also there are no common identifiers for wells.
Where you have existing problems is where the system (for cooperation and sharing) is
working well. Cooperation seems to evolve with any formal prioritization effort.
Currently, on a day-to-day basis, Rick and Dennis Nelson have an informal
communication process.
Eventually will have ARC Info/ARC View capability. A data manager to develop a
ground water data system will be hired in June.
Sees WHP Program as stimulus for coordinating existing data systems (ECD Cleanup
Sites, RCRA facilities, solid waste landfills, UST, and pollution prevention. The new
DEQ data system is envisioned as a one stop point of contact for PWSs to collect CSI
data.
ECD is being (has been) decentralized which may hinder information exchange.
Believes that local health departments have a strong role in ground water protection;
they know where the PWS wells are and can identify many of the contaminant sources.
Believes that 75% of PWS wells are withdrawing ground water under the influence of
surface water, making ground water quality management more problematic.
The vulnerability mapping project will not result in a map with site specific application.
Oregon State University has developed an soil type/crop cover/pesticide overlay.
Project is currently stalled since the staff position for developing the map was cut.
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DEQ hasn't gone far in pursuing arrangement with WRD concerning collecting water
quality data from the water level monitoring well network.
Statewide ambient monitoring program is not being initiated due to lack of funding.
Questioned the adequacy of siting criteria for new wells in areas where contamination
sources might be present
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REGION 10 POLLUTION PREVENTION PROJECT
INTERVIEWEE: Grover Partee, Craig Paulson, Maryann Helferty
AFFILIATION: EPA Region 10
INTERVIEWER: Derek Sandison (Also interviewed by Greg Glass)
DATE: May 11, 1994
Suggested that the first time a state goes through the process of crunching data that they
develop a set of conventions for locators, field names, data collection, etc. Additional
data base development efforts in the state could use those conventions or develop
translation software to bridge between data systems.
Funds could potentially be diverted from Supplemental Environmental Projects or from
cleanup activities to support data base development. It is also possible that EPA could
make funds available to states to convert existing data into compatible formats. EPA
may have supported a similar effort in the State of California.
EPA has "burned a number of bridges" with the states in giving conflicting instructions in
terms of the desired structure for data bases. EPA would tell states to organize their
structures in some manner; the states would comply, then EPA would alter its position
and ask the states to make further changes.
Water quality in Alaska is generally good in deep aquifers; however, the shallow aquifer
is a different matter. Underground injection of hazardous waste is permitted in a
number of areas. Financial resources for water quality agencies in Alaska have not
historically represented a problem, but with oil money "drying up", state agencies are
starting to feel the pinch.
Ranking/prioritization of incipient problems should be based on vulnerability, ground
water use, population served or at risk, single or multiple hit, toxicity and concentration
of contaminants.
Recommendation for Case Study: Shoshone/Bannock EDB contamination problem.
This case is illustrative of problems that are allowed to progressively worsen because of
the lack of an adequate early response protocol.
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REGION 10 POLLUTJON PREVENTION PROJECT
INTERVIEWEE: Dennis Nelson
AFFILIATION: Oregon State Health Division - "Water Supply Program
INTERVIEWERS: Derek Sandison and John Littler
DATE: May 4th 1994
The following summary presents the most significant points resulting from the subject interview:
* Regarding semantics there is a need to clarify that it may be too late to "protect ground water" or
provide early warning, from a contaminated source perspective once a bad sample is collected. This or
similar points have been raised by others, Pollution prevention also has some problems in this regard.
When we do the final write ups we will need to be sensitive to this point.
» Whereas data collection is relatively routine, sharing is not. A tool would be very helpful in the
context of defining a framework for defining: who, when, how, what data is shared and what the triggers
are.
No systematic priority setting or system exists for defining when to act or how to respond. The
exceptions are the DEQ HRS system and the PWS compliance responses.
If a framework or procedure is developed as an automatic, like an emergency notification system, as
a checklist or template, this could help in priority setting and decision making.
The current situation is not satisfactory to Dennis.
Thsre is potential to use or build on to the current ALERTS system to raise the red flags.
Response to observed hits is variable, depending on resources and perceptions. The original policy
required a confirmation sampling and investigation, but this is not always possible. In general they seem
to be able to keep up whh MCL violations for organics, but don't have time to worry much about
inorganics.
Good understandings exist with respect to most of the N03 problem areas.
Politically it is a very bad time for agencies to be perceived as expanding programs. Other forums are
being tried to broaden the understanding of the problems,(5.e. WHP). Politically the agencies are in a low
profile mode.
It is understood that the cheapest methods to address these problems are the most proactive and
politically untimely.
Our project tool could: facilitate identification of problem areas, clarify roles and responsibilities, risk
assessment and perception. At this time DEQ has to wait to hear from Dennis and Vice Versa.
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The basic agency missions arc different: DOB looks at public health, but D1:Q looks at the entire
resource and all the beneficial uses theoretically.
Based on his knowledge of DKQ, it is his feeling that both agencies are overwhelmed with the
workload and inadequate resources.
LHDs arc a potentially important player in several areas of the state in the drinking water program,
and statewide when it comes to protection programs.
It would be appropriate to include the counties in the framework.
Wellhead Protection will be a big related interest in this set of issues. Potentially this could be used
as a spring board in some way. This will probably be a voluntary program in Oregon.
Previous comments on writing off areas were discussed. This is not thought to mean writing them
off per sc, but recognizing they arc a lower priority until new resources are available.
A common problem from a data management perspective was that many systems once they had a hit
would turn off the well. This would result in the well disappearing from the data base. This has now
been fixed so that the data is not lost for review.
Raw water samples arc recommended but not required, so it is not always clear what the data
represent.
* A case study does not jump out with along enough history to help this project. There are plenty of
problem water supplies but the data generally only goes back 4 years maximum (i.e. LaPine, Lakewood
and Portland).
No trends analysis of problem sample results is done except on an occasional basis.
Dennis feels that DOH has the responsibility to share the data, and feels this is not happening
routinely except with the ALERT notifications. There is a concern about sharing the data before
knowing what it means.
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REGION 10POLLUTJON PREVENTION PROJECT
INTERVIEWEE: RickKeppler
AFHLIATJON: Oregon Department of Environmental Quality - Water Quality Program
INTERVIEWERS: Derek Sandison and John I-ittler
DATE: May 4th 1994
The following summary presents the most significant points resulting from the subject interview:
Rick feels this is not a pollution prevention project in its pure sense. His concern is you cannot
respond to something after detection. Dennis had a similar comment in the morning session. This again
highlights the sensitivity of how this is discussed in our documentation because nobody disagrees with
the basic thrust of this effort.
He is concerned about the analytical emphasis up front, based on the lack of quality data on which to
base an analysis. A vulnerability type analysis however is something both he and Dennis seem to feel
more at ease with, due to the ability to look at issues impacting water quality and apply a proactive logic
path..
He is excited about formalizing the process and developing a framework of understanding and
problem resolution. This would define who/ what /how /when.
There is currently no good understanding of roles and responsibilities or the associated
communication needs. This needs to be resolved.
There is a difference in the roles of the agencies.
It is important for local health departments to be a part of the process. They have information others
are not privy to.
Communication is sporadic and not well defined, but Dennis and Rick work welt together and
coordinate on a policy level more than a project or site level. This is falling apart in practice due to the
workload and resource pressures.
Arclnfb and Oracle are currently available «nd he is in the process of hiring a full time data person.
Access will allow them to relate different data bases.
CIS is needed for PWS data.
There arc close ties between this project and WHP, which he agrees will probably be a voluntary
program.
In reality there is some good data snaring in GWMAs, but no real prioritization. When there is, it is
not consistent and is based on the individual investigators experience/int.ercst/ and perceptions. It should
be OK to say no when a good priority setting mechanism is used.
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Some community outreach is being done using grants.
The focus on groundwater is still very much from the state level, and overall things are still focused
on surface water. Awareness of issues like hydraulic continuity is limited.
There is no good definition of the (riggers appropriate for defining when he would like to see the
data,
He is concerned that ECD may be writing off areas and there is no authority under state law to do
thai. Sheree Stewart later clarified that is not the case in a formal sense - (sec interview summary for
Sheree Stewart).
* For case studies one of the best places to look in terms of historical data is landfill sites.
One problem identified with respect to database is the absence of a common identifier for wells.
The vulnerability mapping project is stalled and is not the best tool for addressing she specific
problems.
Regarding case studies and the absence of data, if a bigger picture approach is taken important issues
are: land use, known contaminated sites, agricultural use of chemicals, population, water use, industry
and sewage disposal, and others ?
Looking at the factors identified above in a prospective manner could shift the project into more of a
pollution prevention mode in his mind. Rick liked this approach as a risk based approach to pollution
prevention.
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REGION 10 POLLUTION PREVENTION PROJECT
INTERVIEWEE: Sheree Stewart
AFFILIATION: Oregon State Department of Environmental Quality -
Environmental Cleanup Program
INTERVIEWER: John Littler
DATE: May 4th 1994
The following summary presents the most significant points resulting from the
subject interview:
There needs to be increased communication between the agencies.
The roles and responsibilities of the various agencies need to be clarified.
There is a fairly clear distinction between pollution prevention and early
warning systems.
Sheree feels very strongly that public education and involvement is a
critical part of the solution to these problems. She and other professional
staff spend a lot of time educating the public. Hand out materials etc. would
be very helpful to them. This is one of her highest priorities with respect to
this project.
Similar comments to the above interviews regarding priority setting,
resource constraints and trigger questions.
Writing off of Aquifer resources is not a formal thing and is more in the
context of deferred action or lower priority of actions based on the perception
that an aquifer is unusable, outside the normal priority mechanisms or beyond
help. For example in Lake Oswego a PWS well was taken off line and even
though contamination is there and not addressed, it is not a priority at this
time. The probable source has been found through the PA program.
When an up gradient problem is known to exist in a water supply aquifer
aquifer it is automatically be bumped into a higher priority for action.
Dennis and Rick are perceived to be a focal point for whatever
communication and recommendations for action are happening.
The Site Assessment program could also be a focal point for information
flow regarding early detection of contamination. Heather Schigf is the
contact person at 229-5657.
Wellhead Protection has some good elements but would potentially be of
limited benefit due to scope and it being voluntary.
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Database development needs to focus on being more interactive, the
contact person for ECD is Jean Sloper 229-6490.
The cleanup program has not addressed the cost benefit of their
expenditures, for example spending a little at a lot of sites on source control
could produce great benefit, but spending a lot at a few sites has not always
done so. This is probably politically motivated to some extent. More
emphasis should be given to source control, which again could tie back
directly to pollution prevention.
In phase 2 of this project more direct involvement from the programs will
be necessary.
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REGION 10 POLLUTION PREVENTION PROJECT
INTERVIEWEE: Chuck Davis
AFFILIATION: City of Springfield
INTERVIEWER: John Littler
DATE: May 13th 1994
Chuck basically reinforced a great deal of the input previously received from Dennis Nelson and Rich
Keppler. In addition, he emphasized that he felt there is a lot more data available in the utilities and private
sector that could be usefully applied if it could be accessed. He also agreed with the approach that Rick
described of using a vulnerability type analysis to prioritize rather than a detailed analytical tool. He also felt
that it would be very helpful to have documented case studies to use as demonstrative examples in
communicating with policy makers and the public.
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REGION 10 POLLUTION PREVENTION PROJECT
INTERVIEWEE: Denny KKngbile and John Thomas
AFFILIATION: Damascus Water District and Mt. Scott Water District
INTERVIEWER: John Littler
DATE: May 12th 1994
This was a brief discussion which took place during the AWWA convention but described the project in
general with a very positive response in terms of desire to have a tool like ours available, There was some
considerable concern at the prospect of problems going unaddressed as utilities abandon contaminated
sources without addressing the root of the problem, which in turn could impact downgradient wells.
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APPENDIX A - RELEVANT DOCUMENTS
1) Final Comprehensive State Ground Water Protection Program Guidance, EPA Office of
the Administrator, EPA 100-R-93-001, 161 pp., December 1992.
(Describes process for developing state programs under EPA objectives:
A) Prevention of contamination whenever possible;
B) Prevention of contamination based on the relative vulnerability of the resource and,
where necessary, the ground water's use and value;
C) Remediation based on relative use and value of ground water.)
2) Final Report of the Volunteer Well Water Nitrate Testing Program, Clean Water Act
Section 319 Grant to the Oregon Department of Environmental Quality, Barbara Brahmani,
Program Coordinator, ODEQ, 10 pp. plus attachments, November 1993.
(Indications of significant nitrate problems in a number of areas of the state.)
3) Ground Water Protection Act Implementation Task Force: Recommendations to the
Strategic Water Management Group, 6 pp., February 16, 1993.
4) Guidance for Pesticides and Ground Water State Management Plans, EPA Office of
Prevention, Pesticides, and Toxic Substances, EPA 735-B-93-0, 42 pp., December 1993.
(Implementation document for the EPA Pesticides and Ground Water Strategy)
5) Interpretation of Federal Antidegradation Regulatory Requirement, Memo from Tudor
Davis, Director OST, to Water Management Division Directors, Regions I - X, 6 pp.,
February 22, 1994.
6) Oregon DEQ Work Program for Clean Water Act Section 319 Grants: Project Level
Proposal for Fiscal Year 1994 Funding, Project Number OR-94-21-319, Prepared and
Submitted by ODEQ, Undated.
(Project Name: Utilization of GIS Technology to Map Ground Water Vulnerability)
7) Profile of Ground Water Protection Programs 1993, State of Oregon, (Draft Document),
Prepared by Dm Keenan and Maryann Helferty, EPA Region 10, Ground Water Section,
EPA 910/R-93-019, 77 pp. plus appendices, September 1993.
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8) Pesticides in Ground Water Database, EPA Pesticides and Toxic Substances, H750C, 126
pp. plus appendices listed as follows, November 1991.
Appendix A - Describes data fields for data base in D-Base III plus.
Appendix B - Positive entries sorted by chemical (state identified but geographic
location not further defined).
Appendix C - Positive entries sorted by state.
Appendix D - Summary assessment sorted by chemical (shows numbers of states with
positives, range of values, etc.
Appendix E - Bibliography.
Appendix F - Miscellaneous memos, etc.
(National summary and analysis of all data that Office of Pesticide Programs has available,
both in computerized and hard copy form, regarding pesticides in ground water.)
9) Pesticides in Ground Water Database: Region X, EPA Pesticides and Toxic Substances,
H750C, 38 pp., November 1991.
(Regional Supplement to the national summary and analysis described above.)
10) Pesticides in Ground Water Data Base 1988 Interim Report, EPA Office of Pesticide
Programs, 32 pp., December 1988.
(Preliminary document related to the above referenced pesticide surveys.)
11) Uncovering the Legacy of Pesticide Use: What We Know About Ground Water
Contamination in the Northwest, Neva Hassanein, Northwest Coalition for Alternatives to
Pesticides, P.O. Box 1393, Eugene, OR 97440, 36 pp., August 1992.
(Summarizes EPA and ODEQ pesticide findings.)
12) Summary of the January 10, 1994 Quarterly Groundwater Protection Advisory
Committee (GPAC) Meeting, Memo from Ivan Camacho, ODEQ Groundwater Section, to
GPAC issues interested persons, 9 pp., March 8, 1994.
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MAPS
1) "Sampling Locations and Average Nitrate Concentrations", Data from Oregon DEQ
Volunteer Nitrate Testing Program and Health Division's Real Estate Transaction Testing
Program, Scale 1:3,000,000, November, 1989 to June, 1993, by ODEQ, OHD, and State
GIS Program.
2) "Ground Water Vulnerability", Vulnerability = susceptibility plus pollutant load, no
credits, scale not indicated, undated.
(Ranked low, medium, high, and very nigh.)
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