Office of Solid Waste and
Emergency Response
5204G
EPA 500-R-07-001
December 2007
Recommendations from the
EPA Ground Water Task Force
A Report by the
Ground Water Task Force
December 2007
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';
/ £ WASHINGTON, D.C,
;', . OFFICE OF
" ' SOLID WASTE AND EMERGENCY
RESPONSE
DEC 21 2007
MEMORANDUM
SUBJECT: Recommendations from the EPA Ground Water Task Force
CJ p fl i
₯^T» nii it n (Xm^'i- , * \&f*J V - ^
FROM: Susas^aricer Bomne,
Assistant Administrator
TO: OSWER Office and Staff Directors
Superfund, RCRA, Tanks, and Brownfields Regional Directors
Susan Bromm, OECA Office of Site Remediation and Enforcement
Dave Kling, OECA Federal Facilities Enforcement Office
Elizabeth Cotsworth, OAR Office of Radiation and Indoor Air
Cynthia Dougherty, OW Office of Ground Water and Drinking Water
Sally Gutierrez, ORD/NRMRL
Debbie Edwards, OPPTS Office of Pesticide Programs
Roger Martella, Office of General Counsel
The attached report, "Recornmendations from the EPA Ground Water Task Force," is a
result of a three-year effort, which was established under OSWER's One Cleanup Program. This
group was asked to identify and prioritize ground water issues that will benefit multiple cleanup
and protection programs, and to recommend potential activities for EPA to consider in its
planning. The Task Force was staffed by senior representatives from EPA program offices that
have a role in cleaning up or protecting ground water resources and included OSWER programs,
OW, OECA, OAR, and OPPTS. Other participants included the EPA Ground Water Forum,
ORD, lead RCRA and Superfund regions, and the states of Georgia, Nebraska, and New York. I
would like to thank the Task Force members for preparing this thoughtful report as well as your
offices for the support that you have provided to the Task Force.
OSWER is currently working on the following projects in response to recommendations
included in this report: an update to the 1993 guidance on technical impracticability; new
guidance on data needs and procedures for tracing dense non-aqueous phase liquid (DNAPL)
source zone cleanup efforts; a DNAPL web-based resource center; and approaches for drinking
water and cleanup program collaboration at Source Water Areas delineated by the states.
OSWER will consider additional recommendations and ideas in this report when designing
future projects to promote both ground water protection and ground water cleanup.
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Questions concerning aspects of this report pertaining to DNAPLs should be directed to
either Matthew Charsky (charsky.matthew@epa.gov) or Linda Fiedler (fiedler.linda@ei3a.ggv)
of OSWER's Superfund program, and questions concerning aspects of the report pertaining to
ground water use, value and vulnerability should be directed to Guy Tomassoni
(tomassoni.gu> a cpa.gov) of OSWER's Center for Program Analysis.
Attachment
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A Special Acknowledgement
A special thanks and recognition goes to Kenneth Lovelace who served as the Chair of
the Ground Water Task Force that produced this report. Ken was an expert and advocate
of ground water protection and remediation, and
friend to many who miss him.
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Acknowledgments
This report would not have been possible without the contribution of the many individuals
listed below who participated in EPA's Ground Water Task Force. The Task Force was
organized by the Office of Solid Waste and Emergency Response, and chaired by Kenneth
Lovelace formerly of EPA's Office of Superfund Remediation and Technology Innovation.
These names and affiliations of individual Task Force members listed below were accurate at
the time the Task Force was convening, and may not reflect their current positions.
Harold Ball, Region 9, Superfund Division
Felicia Barnett, OSWER, Region 4, Office of Brownfields Cleanup and Redevelopment
Betsy Behl, OPPTS, Office of Pesticide Programs
Arnold Bierschenk, Region 6, Water Quality Protection Division
Matt Charsky, OSWER, Office of Superfund Remediation Technology Innovation
Kathy Davies, Region 3, Hazardous Site Cleanup Division
Chuck Evans, OPPTS, Office of Pesticide Programs
Linda Fiedler, OSWER, Office of Superfund Remediation Technology Innovation
Elisabeth Freed, OECA, Office of Site Remediation Enforcement
JoAnn Griffith, OSWER, Office of Superfund Remediation Technology Innovation
Stephen Hammond, New York State Department of Environmental Conservation
Joel Hennessy, Region 3, Waste and Chemicals Management Division
Ruth Izraeli, Region 2, Division of Environmental Planning and Protection
Jennifer Kaduck, ASTSWMO and Georgia Environmental Protection Division
Marty Link, Nebraska Department of Environmental Quality
Ken Lovelace, OSWER, Office of Superfund Remediation Technology Innovation
Steve Mangion, Region 1, Hazardous Substances Technical Liaison Program
Tim Mott, OSWER, Federal Facilities Restoration and Reuse Office
Kevin McCormack, OW, Office of Ground Water and Drinking Water
Peter Neves, OECA, Office of Site Remediation Enforcement
Howard Orlean, Region 10, Office of Waste and Chemical Management
Robert Pierce, Georgia Environmental Protection Division
Nancy-M Porter, OSWER, Office of Brownfields Cleanup and Redevelopment
Bob Puls, ORD, National Risk Management Research Laboratory
Roy Simon, OW, Office of Ground Water and Drinking Water
Guy Tomassoni, OSWER, Land Revitalization Office
Hal White, OSWER, Office of Underground Storage Tanks
Ron Wilhelm, OAR, Office of Radiation and Indoor Air
Dick Willey, Region 1, Office of Site Remediation and Restoration
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Disclaimer
This report is a work product of the Ground Water Task Force. The report is intended to provide
information to EPA management, program staff, and other stakeholders for their consideration
and to inform and encourage discussion on the topic. The statements in this document do not
constitute official Agency policy, do not represent an Agency-wide position, and are not binding
on EPA or any other party.
IV
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Table of Contents
Acronyms and Abbreviations 1
Executive Summary 3
DNAPL Source Zone 3
Ground Water Use, Value, and Vulnerability (UVV) 4
Introduction 7
Purpose of Ground Water Task Force 7
Methodology for Developing Recommendations 9
Stakeholder Input on DNAPL Paper and Options 11
Comments on Options Presented in DNAPL Paper 11
Option 1: Develop a fact sheet describing the potential benefits of DNAPL
mass removal from the source zone, as well as the potential disadvantages 11
Option 2: Develop a fact sheet describing program flexibilities and alternative
cleanup goals that may be applied to the DNAPL source zone other than
attainment of Maximum Contaminant Levels (MCLs) 11
Program flexibilities (e.g., technical impracticability decisions, containment zones, or similar
alternatives) would be those allowed under federal or state cleanup programs.
The alternative goals would typically apply only to the DNAPL source zone rather than the entire
plume, in accordance with existing policy.
Option 3: Develop a supplemental EPA guidance on technical impracticability (Tl)
that clarifies some or all of the following questions for Superfund and other EPA
cleanup programs:(see page 11 for questions) 11
Option 4: Develop a policy memorandum re-emphasizing the existing EPA policy
that program flexibilities are to be used for DNAPL source zones as a means of
setting cleanup goals that are achievable in a reasonable time frame 12
Such program flexibilities may include Tl determinations, containment zones, ground water
classification exemptions, or similar flexibilities that are available at a particular site from
either the federal or state cleanup program overseeing the cleanup at that site.
The memorandum would reiterate EPA's current policy that cleanup goals for DNAPL source
zones should not include restoration of ground water to drinking water standards, if this goal
cannot be achieved in a "reasonable time frame" based on site conditions.
Option 5: Develop guidance on recommended methods and approaches for
delineating the extent of the DNAPL source zone 12
Option 6: Develop guidance providing a qualitative approach for determining
when source depletion technologies should or should not be implemented 13
VI
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Option 7: Develop guidance on performance measures for the effectiveness of
DNAPL mass removal, and on how to determine when active DNAPL removal
efforts should be discontinued 13
Such measures could include trend analysis for mass removal rates, mass flux data, or other
parameters for gauging remedy performance.
Option 8: Develop guidance describing improved methods for comparing long-
term remedies 13
The guidance would allow a more realistic accounting of the costs and other disadvantages of
long-term custodial care. This would include long-term costs of maintaining containment
systems, equipment replacement, monitoring and enforcing institutional controls, and site
monitoring.
Additional Options Suggested by Commenters on the DNAPL Paper 13
General Themes in Comments on DNAPL Paper 15
Stakeholder Input on Ground Water Use, Value, and Vulnerability as Factors in
Setting Cleanup Goals Paper and Options 17
Comments on Ground Water Use, Value, and Vulnerability Paper Options 17
Option 1: Develop a series of educational fact sheets and Internet training
seminars 17
Material would be, targeted primarily to government officials and members of the regulated
community to raise awareness of ground water UVV; interconnection between ground water and
surface water systems and health impacts from contaminants most commonly found in ground
water.
This effort would include summaries of the findings from the 2004 Ground Water Report to
Congress.
Option 2: Conduct research on the impacts on other developed nations that have
resulted from either the presence or lack of strong ground water protection
programs 18
Option 3: Develop summaries of how individual EPA and state cleanup programs
consider ground water UVV in setting cleanup goals (e.g., ground water
classification and classification exception systems, ground water management
zone-type approaches) 18
These summaries would be written with Internet links to more detailed resources. EPA would
provide access to these summaries via its One Cleanup Program website. This option could also
involve low-cost Internet training to raise awareness of the range of approaches being used by
EPA and states.
Option 4: Takes option 3 one step further by developing an EPA policy memo that
explains how EPA cleanup programs acknowledge the various approaches used by
states in setting ground water cleanup goals based on ground water UVV 18
For example, the policy statement would clarify how state ground water management zone
policy could influence goals established under EPA's cleanup programs. Internet training could
also be used to increase awareness and understanding of the policy statement.
VI1
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Option 5: Using information from federal and state cleanup programs, develop a
general framework that describes how to prioritize sites according to problem
severity and ground water UVV 19
This framework would clearly describe how ground water UW as well as specific problem
magnitude (e.g., risk) can be used to prioritize sites and influence remedial decisions.
This framework would describe how a prioritization system directed at site-specific ground water
problems can work within statewide general classification systems and how, for example, ground
water management zone policy could influence goals established under EPA's cleanup programs.
Option 6: Use defined Source Water Assessment Program (SWAP) areas (required
by the 1996 amendments to the Safe Drinking Water Act) to promote consistency
in ground water cleanup decision making 19
The option would involve establishing a means to encourage stakeholders to become more aware
of and involved with various ground water cleanups taking place within or near an individual
Source Water Assessment Area.
The objective would be that cleanups could be selected to maximize efficiencies and benefits
within a particular source water area.
Option 7: Promote and provide funding assistance for regular meetings within an
individual state or watershed that brings together the various programs and
stakeholders involved with ground water cleanup and protection 19
One of the objectives of these meetings would be to help prioritize cleanup actions based on
factors, such as magnitude and extent of ground water contamination, as well as ground water
UW.
Additional Options Suggested by Commenters on the Ground Water Use, Value,
and Vulnerability Paper 19
General Themes In Comments on Ground Water UVV Paper 20
Task Force Recommendations 23
Recommendations Concerning DNAPL Issues 23
Recommendation 1. Develop guidance on how to acknowledge technical
limitations posed by DNAPLs in EPA cleanup decisions 23
This would include updated guidance on the use of technical impracticability (Tl) decisions in the
Superfund program.
The guidance should also discuss mechanisms for acknowledging technical limitations posed by
site complexities other than DNAPLs.
Ground Water Use, Value, and Vulnerability Recommendations 26
Recommendation A. Develop a new web-based resource center for information
related to the potential role of ground water UVV in cleanup decisions 26
The resource center would address items such as:
interconnection between ground water and surface-water systems;
importance of ground water to ecosystems;
health impacts from contaminants most commonly found in ground water;
vm
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potential for drinking water shortages and their effects on current ground water use
classifications;
federal protection policies, and exemplary state policies
Recommendation B. Request that the U.S. Census Bureau update the 1990
census information on sources of drinking water, and develop tools to facilitate
access to this information 27
Recommendation C. Develop approaches for using source water areas (SWA),
delineated by state drinking water programs, to promote collaboration among
cleanup programs, drinking water programs, and stakeholders concerned with
cleanup and protection of ground water resources 28
Summary 29
Attachment A. Discussion Paper: Cleanup Goals Appropriate for DNAPL
Source Zones A-1
Attachment B. Discussion Paper: Ground Water Use, Value, and Vulnerability as
Factors in Setting Cleanup Goals B-1
Attachment C. GWTF Web Page C-1
Attachment D. Individuals and Organizations that Submitted Comments on One or
Both Discussion Papers D-1
IX
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Acronyms and Abbreviations
ARAR Applicable or Relevant and Appropriate Requirements
ASTSWMO Association of State and Territorial Solid Waste Management Officials
DNAPL Dense Non-Aqueous Phase Liquid
EPA Environmental Protection Agency
GWTF Ground Water Task Force
MCL Maximum Contaminant Level
MOU Memorandum of Understanding
NCP Superfund National Oil and Hazardous Substances Pollution Contingency Plan
NGWA National Ground Water Association
OSWER Office of Solid Waste and Emergency Response
RBCA Risk-Based Corrective Action
RCRA Resource Conservation and Recovery Act
SWA Source Water Area
Tl Technical Impracticability
UST Underground Storage Tank
UVV Use, Value, and Vulnerability
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Executive Summary
In recognizing the importance of ground water to the nation's drinking water supply and its
critical role in maintaining the health of ecosystems, EPA established the Ground Water Task
Force (GWTF) in the fall of 2002 as part of the Agency's One Cleanup Program. The mission of
the task force was to identify and prioritize ground water issues that will benefit multiple
cleanup programs (e.g., RCRA, Superfund, Brownfields, Underground Storage Tanks, etc.),
and make recommendations to EPA senior management on the best course of action. The
GWTF was staffed by senior representatives from various EPA program offices (cleanup and
non-cleanup), and representatives from the Ground Water Forum, lead RCRA and Superfund
regions, and some state cleanup programs.
Task force members identified two topic areas for initial evaluation and developed
"discussion papers" for each area. The papers are: "Cleanup Goals Appropriate for DNAPL1
Source Zones" and "Ground Water Use, Value, and Vulnerability as Factors in Setting Cleanup
Goals" (UVV). EPA undertook an extensive outreach effort to obtain the views of the general
public, environmental advocacy groups as well as state officials, tribal leaders, and industry.
The papers provide a series of problem statements that reflect the views of EPA as well as
various stakeholder groups who responded and proposed options (not necessarily mutually
exclusive)that may be used to address the problem statements. The task force reviewed
cleanup policies associated with these topic areas, but did not review overall Agency policies
concerning the cleanup of contaminated ground water.
The task force placed the papers on the GWTF webpage on May 10, 2004 and solicited
comments on the options. The task force also invited commenters to submit any other
suggestions they might have on the two issues. To advertise the solicitation of comments,
notices were placed in several newsletters, two EPA internet seminars were held to explain
the papers, and direct email requests were sent to over 100 stakeholder groups. Comments
were received from industry, government agencies, and environmental consultants. No
comments were received from environmental advocacy groups.2 The task force considered
the comments received in light of the original options, evaluated additional suggestions, and
developed the following series of recommendations for consideration by senior EPA
management.
DNAPL Source Zone
The decision-making process involved in determining cleanup goals appropriate for a DNAPL
source zone, and whether remediation efforts should be undertaken to remove or treat the
DNAPL source zone was a common theme in the comments received. Most task force members
agreed that the current Superfund guidance on technical impracticability (Tl) should be
1 A nonaqueous phase liquid (NAPL) is a chemical compound that is a liquid in its pure form, does not
readily mix with water, but does slowly dissolve in water. A dense nonaqueous phase liquid (DNAPL)
sinks in water, while a light nonaqueous phase liquid (LNAPL) floats on water. When released to the
environment, DNAPLs and LNAPLs are sources of contamination to ground water.
2 These papers are included in this report as Attachments A and B. Comments can be viewed from the
Ground Water Task Force website at: http://gwtf.clu-in.org/papers/.
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updated. Also, there was support for identifying mechanisms for acknowledging complex site
conditions that would be useful in the decision-making process for cleanup programs other
than Superfund.
Recommendation. Develop guidance on how to acknowledge technical limitations posed
by DNAPLs in EPA cleanup decisions, including updated guidance on the use of technical
impracticability (Tl) decisions in the Superfund program. The guidance should also discuss
mechanisms for acknowledging technical limitations posed by site complexities other than
DNAPLs.
While not a universal opinion, there was common concern that several of the options could
not be implemented because of a lack of scientific consensus, and industry commenters in
particular made the point that the benefits of source reduction had not been conclusively
demonstrated. The task force agreed that there is a need to better assess and document
results achieved by DNAPL source reduction efforts.
Recommendation. Develop recommended data needs and procedures for documenting and
tracking DNAPL source zone cleanup efforts so that technology performance can be
adequately assessed. Procedures are needed to better assess field research and testing
(conducted by EPA and others) to develop promising technologies for remediation and
characterization of DNAPL source zones.
Several of the options involved educational and informational activities, and analysis of the
comments showed a need for better access to the research, guidance, and policy documents
that are currently available on DNAPL issues. Such access could be provided through a website
and would be a useful source of information for EPA and state site managers, cleanup
contractors, community groups, and other stakeholders. There is no current EPA website
specific to DNAPLs that serves this purpose.
Recommendation. Develop a web-based resource center for information related to
cleanup and characterization of sites with DNAPLs, including links to existing policy,
guidance, technology descriptions, and case studies.
The GWTF believes that implementation of these recommendations will greatly aid
practitioners in making decisions on the cleanup of DNAPL source zones. Updated guidance on
ways to acknowledge complex site conditions in cleanup decisions (e.g., Tl decisions in
Superfund) combined with an EPA website that provides current information on remediation
technologies and EPA guidance related to DNAPLs will provide tools to help meet near-term
needs of cleanup programs. In addition, continuing to support technology demonstrations,
while providing a mechanism for properly evaluating field application of DNAPL source
cleanups, will develop the scientific basis for evaluating the likely benefits of source
cleanups, and provide the basis for future Agency guidance.
Ground Water Use, Value, and Vulnerability (UW)
One key factor in determining human health risk from contaminated ground water is whether
an aquifer is currently used as a drinking water supply, or is expected to be used in the future
as a source of drinking water. Also, the economic and/or ecological value of an aquifer, or
the relative vulnerability of an aquifer to contamination may be considered in setting cleanup
goals. Consideration of ground water use, value, and vulnerability may be helpful in other
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remedy decisions, such as desired cleanup time frame or priority of cleanup compared to
other sites.
Most of the options presented in the UVV paper contain an element of information transfer
and education, and several of the comments received emphasized the importance of
education in understanding the importance of the use, value, and vulnerability of surface and
ground waters in making cleanup decisions. The GWTF concluded that information on ground
water UVV and its potential role in cleanup decisions should be more readily available to
government officials (particularly cleanup managers) and interested members of the public.
Furthermore, an information and education effort could help address many of the issues
identified in the GWTF option paper (e.g., educate interested stakeholders about the many
state approaches used to account for ground water UVV in site-specific cleanup decisions).
Educational tools would address the importance of protecting ground waters that currently
support ecosystems, and ground waters that may be needed as a future source of drinking
water whether they are currently considered suitable for drinking water or not.
Recommendation. Develop a new web-based resource center for information related to
the potential role of ground water UVV in cleanup decisions. The resource center would
address items, such as the interconnection between ground water and surface-water
systems; health impacts from contaminants most commonly found in ground water;
federal protection policies, and exemplary state policies.
Most states, through the source water assessment program, have identified aquifers that
supply public drinking water wells; however, information on private drinking water wells in a
given area is sometimes inaccurate, difficult to obtain, or unavailable. In the 1990 Census,
the U.S. Census Bureau collected information on the source of drinking water to a household-
private well or public supply. This question was included in the "long form" of the 1990
Census, but was omitted from the long form in the 2000 Census.3 The task force agreed that
the information collected by the Census Bureau in 1990 was a valuable source of information
on sources of drinking water, because location-specific information was collected for all 50
states, and this is the only national data base with information concerning private wells. The
task force agreed that easily accessible information on drinking water sources would be very
helpful to EPA programs involved with protection and cleanup of ground water. It would be
most helpful if the Census Bureau would reinstate the question on source of drinking water.
Recommendation. Request that the U.S. Census Bureau update the 1990 census
information on sources of drinking water, and develop tools to facilitate access to this
information.
Option 6 in the UW paper involved source water areas (SWAs) delineated by state drinking
water programs. Ground water source areas are portions of an aquifer that supply drinking
water to public wells.4 This option suggested that mechanisms to facilitate collaboration
3 For the 2010 Census, the long form is being replaced by the ongoing American Community Survey
(ACS), which also does not have questions concerning source of drinking water.
4 Delineation of the source water is typically based on estimated travel time for water in the aquifer to
reach the public supply well (e.g., 10 years). A more simplified approach used by some states is to
delineate the source based on a radial distance from the well. See
http://cfpub.epa.gov/safewater/sourcewater/ for more information about source water, source water
assessments, and source water protection.
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among ground water cleanup and protection programs within specific (i.e., "pilot") source
water areas should be explored. This option was well received by both the regulated
community and government commenters. It would promote consistency in ground water
cleanup decision making and encourage stakeholders to become more aware of and involved
with various ground water cleanups taking place within or near an individual Source Water
Assessment Area. A further objective would be to maximize efficiencies and benefits within a
particular source area.
Recommendation. Develop approaches for using source water areas (SWA) delineated by
state drinking water programs to promote collaboration among cleanup programs, drinking
water programs, and stakeholders concerned with cleanup and protection of ground water
resources.
By implementing these recommendations on ground water use, value, and vulnerability, the
GWTF believes the Agency will attain more consistency within its ground water cleanup
programs and promote a better understanding among all stakeholders of the role that
evaluation of aquifer use, value, and vulnerability plays in making cleanup decisions. The
recommendations reflect the fact that other than educational efforts, which are represented
in the recommendations, there was little consensus among stakeholders on how these issues
should be approached. The regulated community for the most part advocated a risk-based
present use approach, while the government commenters preferred to evaluate an aquifer for
its present and future uses as well as how it fits into the overall ecosystem.
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Introduction
The Ground Water Task Force (GWTF) was
established in the fall of 2002 as part of
the Environmental Protection Agency's
(EPA) One Cleanup Program. The One
Cleanup Program is a long term effort
designed to improve the planning and
quality of EPA cleanup programs dealing
with brownfields, federal facilities, leaking
underground storage tanks, Resource
Conservation and Recovery Act (RCRA)
Corrective Action and Superfund. The
Office of Solid Waste and Emergency
Response (OSWER) established the One
Cleanup Program in 2002 in response to
issues raised by the regulated community,
other governmental agencies, and citizens
impacted by contaminated properties. The
One Cleanup Program's goal is to improve
the coordination, speed, and effectiveness
of cleanups at the nation's contaminated
sites without new legislation or program
restructuring. It represents EPA's vision for
how different cleanup programs at all
levels of government can work together to
meet this goaland ensure that resources,
activities, and results are effectively
coordinated and communicated to the
public. More information concerning the
One Cleanup Program can be obtained
from the Agency's website
(http://www.epa.gov/oswer/onecleanuppr
ogram/J.
The One Cleanup Program encourages
coordination among EPA programs and
state, tribal, local, and other federal
agency programs and stakeholders that
lead to:
More consistent and effective cleanups
among cleanup programs
Clearer and more useful information
about cleanups
Better cross-program performance
measures
The results of the One Cleanup Program
are evaluated on a regular basis and
considered in annual planning processes.
Purpose of Ground Water Task Force
The GWTF served as the main technical,
policy, communication, and networking
resource for OSWER on ground water
issues. As such, it promoted cross-program
(state and federal) coordination and
communication on technical and policy
issues related to the cleanup of
contaminated ground water. The GWTF
sought to identify, prioritize, and solve
and/or provide guidance on ground water
issues and projects that will benefit
multiple cleanup programs. It was staffed
by senior representatives from various EPA
program offices (both cleanup and non-
cleanup), and representatives from the
Ground Water Forum, lead RCRA and
Superfund regions, and the states.
Ground water is an essential national
resourceover half of the U.S. population
relies on it for drinking water.5
Unfortunately many of the nation's
contaminated sites impact ground water,
and ground water contamination is usually
very difficult to characterize and clean up,
often requiring decades of treatment and
monitoring. Consequently, almost every
cleanup program devotes a significant level
of attention and resources to ground water
issues.
5 "Safe Drinking Water Act, Section 1429
Ground Water Report to Congress," October
1999, Office of Water Publication
EPA-816-R-99-016.
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While each ground water contamination
problem is uniquely complex, there are
many common issues related to the
management and cleanup of these
problems. Thus, it is important that the
nation's cleanup programs share their
knowledge and work together to ensure
consistent, effective, efficient, and
protective ground water cleanups.
The GWTF created a website
(http://gwtf.cluin.org) to aid in outreach
efforts. The website contains a ground
water resource center that has hyperlinks
to various Agency policy and guidance
documents, ground water characterization
and monitoring guidance and modeling
documents from across government
agencies, treatment technology
descriptions and guidance, and hyperlinks
to information on dense non-aqueous phase
liquids (DNAPLs). Also on the website are
examples of various ground water cleanup
approaches and "success stories" from the
RCRA and Superfund programs.
GWTF members identified two high priority
areas to focus on and have developed a
"discussion paper" for each of them:
"Cleanup Goals Appropriate for DNAPL
Source Zones" and "Ground Water Use,
Value and Vulnerability as Factors in
Setting Cleanup Goals" (Attachments A and
B). Both discussion papers were written to
improve the processes for setting cleanup
goals at ground water contamination sites.
These papers outline the background of the
issues involved in DNAPL cleanup decisions
and in assessing ground water use, value,
and vulnerability to aid in making cleanup
decisions. They lay out a series of problem
statements that were designed to reflect
the views of various stakeholders (e.g.,
state and federal project managers, the
public, industry, and environmental
advocacy groups). They also contain a
series of potential options (not necessarily
mutually exclusive options)that EPA could
undertake to address some or all of the
issues raised in the problem statements.
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Methodology for Developing
Recommendations
Two GWTF subgroups developed the
papers, which were reviewed and revised
before being sent to OSWER office
directors, and regional division directors,
for any major comments. After these
comments were addressed, the papers
were posted on the GWTF website on May
10, 2004. The website announcement
invited public comments on the options
and invited the submission of additional
problem statements as well as other
options for the GWTF to use to refine the
recommendation choices.
The specific means by which the GWTF
solicited comments on the papers included
the following:
RCRA Corrective Action National
Meeting, May 11, 2004. Presentations
on the options papers were given
during a two-hour session that was held
at the end of the RCRA Corrective
Action National Meeting. The session
was well attended (100+) by a broad
range of interest group representatives.
Ground Water News and Views. A short
article on the GWTF and the options
papers was written for the National
Ground Water Association's (NGWA)
June issue of Ground Water News and
Views ( Lovelace, K. EPA Task Force
Seeks Comment from NGWA, Ground
Water News and Views, Volume 1, Issue
1, June 2004). This on-line publication
reaches ground water professionals
from industry, government, and
consulting. The NGWA also sent a
direct request for comment to its
members.
TechDirect Newsletter. A one-
paragraph description of GWTF
activities and the options papers was
placed in EPA's TechDirect email
newsletter (June 2004, message 88),
which at that time had over 20,000
subscribers.
Internet Seminar. Two Internet
seminars were held June 8 and June
23, 2004 to discuss the GWTF and the
options papers. The seminars were
announced in TechDirect (see above)
and attracted over 100 attendees each.
Direct Email Notices. Direct email
notices requesting review of the
options papers were sent to EPA
Superfund regional branch chiefs, EPA
Ground Water Forum, EPA Engineering
Forum, EPA Federal Facilities Forum,
and EPA Office Directors for programs
represented on the GWTF. The
Association of State and Territorial
Solid Waste Management Officials
(ASTSWMO) forwarded their email
notice to their state remediation
managers for RCRA, Superfund, Federal
Facilities, and Underground Storage
Tank programs. Emails were sent
directly to cleanup program managers
in other federal agencies (forwarded by
the Federal Facilities Restoration and
Reuse Office). Direct email notices
were also sent to over 100 stakeholder
groups, including trade associations
(industries and their attorneys),
associations of waste management
officials, water pollution prevention
officials, drinking water supply
associations, state or tribal
environmental officials, public interest
groups, environmental groups, and
other stakeholder groups having a
national perspective on issues related
to cleanup and protection of
contaminated ground water.
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Stakeholder Input on DNAPL Paper
and Options
This section summarizes review comments
on the options provided in the DNAPL
paper, lists new options recommended by
reviewers, summarizes general comment
themes that did not specifically address
the original options, and presents the
recommendations of the GWTF.
Comments on Options Presented in
DNAPL Paper
The final deadline for submitting
comments was September 24, 2004. As of
that date, 37 comments on the DNAPL
options paper had been received. Of the 37
comments, 20 came from government
agencies (6 states and 14 federal
headquarters and regional offices), and 17
came from the private sector/regulated
community (6 industry associations or
companies, 8 consultants, and 3 federal
facilities). No comments were received
from environmental advocacy groups or
from public interest groups. Comments
from non-EPA reviewers are available on
the task force website at:
http://gwtf.cluin.org.
The DNAPL paper evaluated eight problem
statements and offered eight potential
options that might be adopted to help
solve them, and commenters were invited
to propose additional options.
The options were intended to address at
least one problem statement, but they may
address several.
Option 1: Develop a fact sheet describing
the potential benefits of DNAPL mass
removal from the source zone, as well as
the potential disadvantages.
Private sector/regulated community:
These commenters thought that this
option was unnecessary since it would be
repetitive of what is already available and
even if it were completed, it would not
affect decision making, which is done on a
site by site basis.
Government agencies: These commenters
thought that such a fact sheet might be
useful, but did not indicate strong support
for it.
Option 2: Develop a fact sheet describing
program flexibilities and alternative
cleanup goals that may be applied to the
DNAPL source zone other than attainment
of Maximum Contaminant Levels (MCLs).
Program flexibilities (e.g., technical
impracticability decisions, containment
zones, or similar alternatives) would be
those allowed under federal or state
cleanup programs. The alternative goals
would typically apply only to the DNAPL
source zone rather than the entire plume,
in accordance with existing policy.
Private sector/regulated community:
Comments were generally favorable, and
in some cases commenters wanted the
scope expanded.
Government agencies: Commenters
discussed technical issues related to this
option and in general did not think it
would be particularly useful.
Option 3: Develop a supplemental EPA
guidance on technical impracticability (Tl)6
6 Technical impracticability (Tl) for
contaminated ground water refers to a
situation where a remedy is not expected to
achieve ground water cleanup levels that would
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that clarifies some or all of the following
questions for Superfund and other EPA
cleanup programs:
Circumstances that would warrant
revisiting a Tl decision
Content and/or format of a Tl
evaluation report
How the Tl decision process can be
used to encourage delineation of
DNAPL source zones
When a simplified (or streamlined) Tl
decision process can be applied to
operating remedies
How the Tl decision process can be
used to encourage use of innovative
source removal technologies
General: There was general agreement
that the current guidance is dated, and
most of the commenters supported the
development of supplemental Tl guidance;
however, opinions differed on what it
should cover.
Government agencies: While not opposing
a guidance update, multiple state
commenters pointed out that Tl as a
concept is not always well received in
states with antidegradation policies and is
normally be required, because achieving such
levels is not practicable from an engineering
perspective. This definition for Tl was included
in the Superfund statute. EPA's "Guidance for
Evaluating the Technical Impracticability of
Ground Water Restoration" was completed in
1993. A Tl determination is part of a site-
specific remedy decision and is made by the
lead decision-maker for the site (e.g., EPA or
state). The supporting rationale for such a
decision is provided in the decision document
(e.g., a Superfund Record of Decision). The
term "engineering perspective" refers to
factors, such as feasibility, reliability, scale or
magnitude of a project.
often perceived as a no-action option by
the public.
Option 4: Develop a policy memorandum
re-emphasizing the existing EPA policy that
program flexibilities are to be used for
DNAPL source zones as a means of setting
cleanup goals that are achievable in a
reasonable time frame. Such program
flexibilities may include Tl determinations,
containment zones, ground water
classification exemptions, or similar
flexibilities that are available at a
particular site from either the federal or
state cleanup program overseeing the
cleanup at that site. The memorandum
would reiterate EPA's current policy that
cleanup goals for DNAPL source zones
should not include restoration of ground
water to drinking water standards, if this
goal cannot be achieved in a "reasonable
time frame" based on site conditions.
General: A number of commenters did not
express an opinion on implementing this
option, but did provide technical
observations.
Private sector/regulated community:
Option 4 was generally supported (with
caveats) by those commenting.
Government agencies: There were few
direct government comments, and they
were generally not supportive of the
recommendation
Option 5: Develop guidance on
recommended methods and approaches for
delineating the extent of the DNAPL source
zone.
General: Option 5 had no clear trends
among commenter groups or commenters.
Some thought a delineation guidance
would be useful and should include topics,
such as how much delineation is necessary.
Others thought that there are a sufficient
number of guidance documents already
available to develop an appropriate
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approach for any given site. Still others
did not think that source zone delineation
is an issue.
Option 6: Develop guidance providing a
qualitative approach for determining when
source depletion technologies should or
should not be implemented. This guidance
would attempt to identify types of site
conditions where:
MCLs are potentially achievable in the
DNAPL source zone
MCLs are not likely to be achieved
Benefits of source depletion efforts
tend to outweigh disadvantages
Source depletions should be included as
a remediation goal (regardless of
whether or not MCLs are likely to be
achieved within the DNAPL source zone
Private sector/regulated community:
Though potential difficulties were
acknowledged, this option was generally
supported.
Government agencies: The states that
commented on it were not supportive and
thought the information needed to
accomplish it is not available. EPA
comments tended to be technical in nature
and neutral on whether or not to move
forward with this option.
Option 7: Develop guidance on
performance measures for the
effectiveness of DNAPL mass removal, and
on how to determine when active DNAPL
removal efforts should be discontinued.
Such measures could include trend analysis
for mass removal rates, mass flux data, or
other parameters for gauging remedy
performance.
Private sector/regulated community:
Option 7 had strong support from the
private sector/ regulated community.
Dissenters either believed it was
premature to write a guidance, given the
state of the art, or existing guidance
already addresses this issue.
Government agencies: EPA comments
tended to be technical in nature and
neutral on whether or not to move
forward with this option. The Interstate
Technology Regulatory Council (ITRC, a
state workgroup) has developed a
technical guide on this issue.
Option 8: Develop guidance describing
improved methods for comparing long-term
remedies. The guidance would allow a
more realistic accounting of the costs and
other disadvantages of long-term custodial
care. This would include long-term costs of
maintaining containment systems,
equipment replacement, monitoring and
enforcing institutional controls, and site
monitoring.
Private sector/regulated community: Most
of the comments on this option were from
the private sector/regulated community
and either supported developing the
guidance or provided technical input that
was neutral on implementation. The
dissenting comments questioned its
usefulness.
Government agencies: EPA comments
tended to be technical in nature and
neutral on whether or not to move
forward with this option.
Additional Options Suggested by
Commenters on the DNAPL Paper
In addition to thoughts on the options
presented in the DNAPL paper, many
commenters offered other ideas for EPA to
consider. Some of these suggestions were
unclear or overly broad (e.g., EPA should
change its entire approach to cleanup).
From these suggestions, the task force
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found that the following nine were worthy
of further consideration.
/. AH Records of Decision (RODs) should
have required language to indicate
whether DNAPLs are present at a
ground water remedy site and whether
remedial actions will have significant
benefit based on conditions at the site.
Ground water RODs with pump and
treat as the selected remedy should be
subjected to external scientific peer
review.
2. Set up a system of rewarding mass
removal of DNAPL regardless of the
fraction of total mass that it
represents. This suggestion pertains to
Problem Statements 1 & 2, in
particular. Site owners and regulators
are more likely to collaborate if
success can be envisioned. A
quantitative value can be attached to a
pound of DNAPL removed from the
subsurface environment with a simple
economic analysis. Each site's
regulator and owner would be tasked
with achieving a covenant as to how
the value of the DNAPL removed would
be applied to offsetting the present or
future cost of compliance. Examples of
these offsets include monitoring
reduction and reporting relief.
3. EPA should standardize the use of
indicators that identify decreasing
effectiveness of pump-and- treat
systems (e.g., declining mass removal
rates) and provide an agreed upon
metric for determining when further
reductions are not technically feasible.
4. EPA should compile a comprehensive
DNAPL annotated bibliography (for
Internet access) of references,
research, organizations (e.g.,
academic, industry, and government),
and their respective web
links/addresses.
5. EPA should establish a more consistent
framework for setting site-specific
goals for ground water remediation.
Such a framework should take into
account the priority of public health
protection, use, and value of the
ground water unit in question, and a
realistic approach to ground water
remediation.
6. EPA should produce a guidance that
provides site owners and
regulators/site managers with more
information with which to make
decisions (e.g., DNAPL source zone
definition, mass flux, risks impacted,
site cleanup difficulty ranking, aquifer
value and vulnerability, site value).
This type of site information must be
developed first before a decision is
made about whether a Tl is
appropriate or not.
7. EPA should develop new guidance
explicitly on how to assess the remedy
for DNAPL sites under the remedy
selection criteria provided in the
Superfund National Oil and Hazardous
Substances Pollution Contingency Plan
(NCP).7
8. EPA should fund the research areas
suggested in the Kavanaugh-Rao
report. (M. Kavanaugh and S. Rao, co-
chairs, 2004. The DNAPL Remediation
Challenge: Is There a Case for Source
Depletion? EPA/600/R-03/143. Office
of Research and Development, EPA.)
9. EPA should sponsor a team of experts
that will go to a variety of sites across
the country that have undergone or are
about to undergo a source depletion
remediation. The EPA experts (along
7 National Oil and Hazardous Substances
Pollution Contingency Plan (NCP); Final Rule,
Federal Register 55, no. 46:8706 and 8733-34,
March 8, 1990. The NCP provides the regulatory
framework for the Superfund program.
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with those from other agencies or from
industry, as appropriate for a
particular site) will determine if site
conditions are properly characterized
and will ensure that performance
monitoring instrumentation is in place
to determine the short- and long-term
effects of the source depletion. The
ensuing data set will provide hard
evidence that is acceptable to both
sides (EPA/states and industry) on the
benefits, if any, of source depletion in
different hydrogeologic settings.
General Themes in Comments on DNAPL
Paper
In addition to specific comments on the
options themselves there were several
overarching themes within the comments
submitted for the DNAPL paper by the
different groups.
Private sector/regulated community
Commenters from the regulated
community felt that EPA could exercise a
great deal of flexibility in setting goals for
the cleanup of DNAPL sites, but rarely did.
There was some concern about an overly
rigid interpretation or lack of
consideration of what constitutes a
"reasonable time frame" for achieving
cleanup goals.
It was suggested that EPA change its
overall approach to site cleanup and adopt
a risk- based one, limiting the
interpretation of "risk-based" to current
use and exposure of a contaminated
resource (e.g., ground water) and
excluding future uses for purposes of
setting current cleanup goals.
Many commenters also cited as an issue a
lack of data to support source removal
decisions.
There was far more uncertainty in
predicting the success and cost of source
removal technologies, which some felt are
experimental, than with more proven
technological approaches, such as
containment.
In addition, they believe that given the
current state of knowledge, the benefits
of source removal are at best conjectural.
Government agencies
There was considerable support for
keeping MCLs as the cleanup goals for
source zones for the following reasons:
they encourage source zone cleanup; they
encourage development of innovative
technologies; and they may, by forcing
source zone depletion actions, allow MCLs
to be achieved at the property line.
Several commenters voiced the opinion
that waiving stringent goals, such as MCLs
undervalued the resource in order to
justify short-term cost savings that may
very well result in higher costs in the
future.
A state commenter, taking a different
tack, said that several states had
embraced risk-based corrective action
(RBCA) and were applying it to set cleanup
goals at DNAPL sites.
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Stakeholder Input on Ground Water
Use, Value, and Vulnerability as
Factors in Setting Cleanup Goals
Paper and Options
This section summarizes review comments
on the options provided in the UVV paper,
lists new options recommended by
reviewers, summarizes general comment
themes that did not specifically address
the original options, and presents the
GWTF's recommendations.
Comments on Ground Water Use, Value,
and Vulnerability Paper Options
The final deadline for submitting
comments was September 24, 2004. As of
that date, 33 comments on the UVV
options paper had been received. Of the 33
comments, 24 were from government
agencies (9 states and 15 federal
headquarters and regional offices), and 9
were from the private sector/regulated
community (5 industry associations or
companies, 3 consultants, and 1 federal
facility). No comments were received from
environmental advocacy groups or public
interest groups. Comments from non-EPA
reviewers are available on the task force
website at: http://gwtf.cluin.org.
The UVV paper evaluated four problem
statements and offered seven potential
options that might be adopted to help
solve them. Although the options were
intended to address at least one problem
statement, overlap exists. The paper
invited commenters to propose additional
options if they so desired.
Option 1: Develop a series of educational
fact sheets and Internet training seminars,
targeted primarily to government officials
and members of the regulated community
to raise awareness of ground water UW;
interconnection between ground water and
surface water systems; and health impacts
from contaminants most commonly found
in ground water. This effort would include
summaries of the findings from the
upcoming Ground Water Report to
Congress.
General: This option received a moderate
number of direct comments, but many
more commenters supported the need for
educational efforts in a variety of areas.
Private section/regulated community:
Positive commenters supported the option
in general with specific suggestions on how
it could be implemented. One commenter,
however, thought that it would not
provide much information beyond what is
already available.
Government agencies: There were both
positive and negative government agency
comments. The positive comments
generally identified specific issues the
commenters thought should be addressed
with education efforts, while the negative
commenters generally thought other
options would be more effective. Some
thought that the description of this option
did not adequately emphasize educating
people on the need to protect ground
waters that currently support ecosystems
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and ground waters that may be needed as
a future source of drinking water.
Option 2: Conduct research on the impacts
on other developed nations that have
resulted from either the presence or lack
of strong ground water protection
programs.
General: While several commenters
thought studying selective foreign ground
water protection policies might prove
useful, the majority of commenters (both
private sector/regulated community and
government agencies) did not think it
would be effective in addressing any of the
problems put forth in the paper, especially
in times of limited resources.
Option 3: Develop summaries of how
individual EPA and state cleanup programs
consider ground water UVV in setting
cleanup goals (e.g., ground water
classification and classification exception
systems, ground water management zone-
type approaches). These summaries would
be written with Internet links to more
detailed resources. EPA would provide
access to these summaries via its One
Cleanup Program website. This option
could also involve low-cost Internet
training to raise awareness of the range of
approaches being used by EPA and states.
Private sector/regulated community:
Option 3 was generally opposed by the
commenters as not providing an
implementable solution. Several
commenters, however, thought it would
be a useful exercise for discussion and
developing guidance and another said they
had already performed a similar exercise
and it pointed out the many
inconsistencies in the various state
programs and the need for guidance to
correct these inconsistencies.
Government agencies: Several regulatory
agencies (both state and federal) were in
favor of this effort. One state commenter
did not think highlighting differences in
state and federal programs was a good
idea, though the commenter did support a
study that examined state and federal
programs with the goal of highlighting
strong points. Some thought that this
option would negatively impact states that
have a conservative approach to protecting
ground water resources.
Option 4: Takes option 3 one step further
by developing an EPA policy memo that
explains how EPA cleanup programs
acknowledge the various approaches used
by states in setting ground water cleanup
goals based on ground water UVV. For
example, the policy statement would
clarify how state ground water
management zone policy could influence
goals established under EPA's cleanup
programs. Internet training could also be
used to increase awareness and
understanding of the policy statement.
Private sector/regulated community:
Regulated community comments on this
option were mixed. Some did not think
that this option would lead to any changes
that they would favor. Others said that
such a policy should be expanded to
promote greater use of existing program
flexibilities, with more emphasis on "risk-
based" cleanup decisions rather than
restoration of ground water in every
situation.
Government agencies: Government agency
comments were also mixed. Some EPA
commenters thought that such a policy
would be very helpful. Others, mainly
state commenters, thought that this
option would somehow hinder state efforts
to protect resources. Others thought that
such a policy should also address the need
to protect ground waters that currently
support ecosystems and ground waters
that may be needed as a future source of
drinking water.
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Option 5: Using information from federal
and state cleanup programs, develop a
general framework that describes how to
prioritize sites according to problem
severity and ground water UVV. This
framework would clearly describe how
ground water UVV as well as specific
problem magnitude (e.g., risk) can be used
to prioritize sites and influence remedial
decisions. This framework would describe
how a prioritization system directed at
site-specific ground water problems can
work within statewide general
classification systems and how, for
example, ground water management zone
policy could influence goals established
under EPA's cleanup programs.
General: This option generated a number
of comments that were equally split
between support and opposition. On the
support side, many commenters thought it
would be a good idea to bring UVV
concepts into a useable framework to aid
in prioritizing site cleanups. Speaking
against this option, other commenters
thought it would be difficult or unwise to
implement, and several pointed out that it
seemed to be similar to the
Comprehensive State Ground Water
Protection Program (CSGWPP) initiative,
which has been implemented by only a few
states.
Option 6: Use defined Source Water
Assessment Program (SWAP) areas
(required by the 1996 amendments to the
Safe Drinking Water Act) to promote
consistency in ground water cleanup
decision making. The option would involve
establishing a means to encourage
stakeholders to become more aware of and
involved with various ground water
cleanups taking place within or near an
individual Source Water Assessment Area.
The objective would be that cleanups
could be selected to maximize efficiencies
and benefits within a particular source
water area.
Private sector/regulated community:
Commenters were generally in support of
this option. One consultant, however,
thought it would be difficult to
implement.
Government agencies: Government
commenters were generally in favor of this
option, with one pointing out the necessity
of including private well locations in the
pool and another cautioning about the
uneven quality of the state SWAP
designated areas. Some thought that this
option ignores the need to protect ground
waters that currently support ecosystems
and ground waters that may be needed as
a future source of drinking water.
Option 7: Promote and provide funding
assistance for regular meetings within an
individual state or watershed that brings
together the various programs and
stakeholders involved with ground water
cleanup and protection. One of the
objectives of these meetings would be to
help prioritize cleanup actions based on
factors, such as magnitude and extent of
ground water contamination, as well as
ground water UW.
General: While Option 7 received some
positive comments, the majority of the
commenters were against implementing
this option, with one pointing out the
potential cost of doing this on a
nationwide scale.
Additional Options Suggested by
Commenters on the Ground Water Use,
Value, and Vulnerability Paper
In addition to thoughts on the options
presented in the DNAPL paper, many
commenters offered other ideas for EPA to
consider. Some of these suggestions were
unclear or overly broad (e.g., EPA should
change its entire approach to cleanup).
From these suggestions, the task force
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found that the following twelve were
worthy of further consideration.
/. A study should be done to assess the
success of current ground water
cleanups in protecting source water
protection zones.
2. EPA needs to clarify or modify its
definition of what constitutes a
potential (future) source of drinking
water under the Superfund program.
3. EPA should develop a guidance that
better defines how the ground water
classification or valuation established
within the current regulatory
framework is used in conjunction with
other factors to establish a
"reasonable time frame" for ground
water restoration. A second
commenter suggested that EPA develop
a guidance document discussing time as
a cleanup parameter.
4. EPA should provide guidance to the
states that would allow more
flexibility in interpreting non-
degradation rules.
5. EPA should develop guidance on
determining cleanup levels for non-
potable ground water pathways, such
as those for irrigation water.
6. EPA should conduct a study on how
many cleanup sites were caused or
exacerbated by shallow injection wells.
7. Establish a forum for sharing CIS
information on the extent of ground
water plumes and source water
assessment areas.
8. EPA should develop a reliable tracking
and mapping system for contaminated
areas that can be used by future
resource developers.
9. EPA should make an effort to get the
U.S. Census Bureau to reinstate a
question about private well use that
was in the 1990 census but not in the
2000 census. These data are very
valuable in evaluating the vulnerability
of private wells from contaminated
sites. Currently the government only
tracks public water systems.
10. Develop an annotated, web-based
bibliography of regulatory and
technical resources.
11. Develop educational materials for use
in public participation programs.
12. Develop a national policy statement
regarding overall ground water goals
for the Agency. This statement should
reflect the overall view that 1) no
aquifer will be degraded, and 2) any
degraded aquifer ultimately needs to
be restored to its natural condition.
General Themes In Comments on Ground
Water Use, Value, and Vulnerability
Paper
In addition to specific comments on the
options themselves, several overarching
themes were identified within the
commenter groups.
Private sector/regulated community
State and federal treatment of ground
water UVV is a patchwork of regulations
and practices.
EPA needs to provide a more consistent
framework for setting site-specific goals
for ground water remediation. Underlying
much of the argument is the concept of
the value of ground water, which is very
subjective, and there are no commonly
acceptable methods for evaluating it.
Any definition of reasonably expected uses
needs to be based on economic (e.g., well
yield and value of property) and risk-
related factors (e.g., water quality and
exposure). EPA needs to adopt a risk based
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approach to site cleanup. The Agency
should limit the interpretation of "risk
based" to current use and exposure of a
contaminated resource (e.g., ground
water) and exclude future uses for
purposes of setting current cleanup goals.
There is a need to prioritize site cleanups
so that limited resources are targeted
towards actions that have the greatest
benefit to human health, the
environment, or ground water resources.
Government agencies
Commenters thought a goal using
"reasonably expected" uses was too vague
and the program should keep the
statement "return to potential future
uses" as its goal.
Too little consideration of future drinking
water demands was given in the paper in
considering future uses. One commenter
suggested the Agency should be involved in
evaluating increasing ground water
demand in various regions of the country
to allow for better decision making.
Most options focus too much on protecting
current sources of drinking water and
ignore the need to protect ground waters
that currently support ecosystems and
ground waters that may be needed as a
future source of drinking water.
Another commenter gave a real-life
example of a brackish aquifer near a city
for which drinking water would not have
been considered a reasonably expected
use, but now it has been designated an
aquifer for drinking water and the city is
constructing a desalinization plant.
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Task Force Recommendations
As discussed in the stakeholder comments
sections, a range of potential options was
included in each of the two discussion
papers prepared by the task force. In its
deliberations, the task force considered
the information presented in the discussion
papers, comments received on the options
presented in each paper, additional
options suggested by commenters, and the
general themes of comments from various
stakeholders.
In developing its recommendations the task
force divided its work into two subgroups,
one for each discussion paper. Initially the
subgroups looked for ways to consider all
of the input received on the papers in
developing recommendations. Each
subgroup decided that recommendations
would not necessarily be based solely on
the paper options, but could include
options suggested by commenters.
Furthermore, when deemed appropriate, a
single recommendation might combine
several options from the papers. In later
discussions each subgroup member was
asked to list their top two or three
recommendations, based on previous
deliberations and their understanding of
the issues. These results were tabulated
and discussed. The discussions led to the
task force making three recommendations
for each paper that were tailored to allow
some flexibility during implementation.
Thus, the task force considered input from
multiple EPA programs and stakeholders
and followed a consensus approach in
developing its recommendations.
The task force did not attempt to review
overall cleanup approaches or policies of
individual EPA cleanup programs, except as
necessary to provide background for issues
presented in the two options papers.
Deliberations of the task force focused on
issues and potential options presented in
the papers. The task force operated under
the assumption that the existing statutory
and regulatory framework governing EPA
cleanup programs would not change.
Recommendations Concerning DNAPL
Issues
The GWTF developed the following
recommendations to address issues
identified in the DNAPL paper. The
recommendations fall under three broad
headings: policy/guidance, technology
research and development, and
information resources.
Policy/Guidance
Recommendation 1. Develop guidance on
how to acknowledge technical limitations
posed by DNAPLs in EPA cleanup decisions,
including updated guidance on the use of
technical impracticability (Tl) decisions in
the Superfund program. The guidance
should also discuss mechanisms for
acknowledging technical limitations posed
by site complexities other than DNAPLs.
Goal: Prepare guidance on mechanisms
for setting cleanup goals that
acknowledge the presence of DNAPL
sources and other types of site
complexities. Answer questions that
have arisen concerning the use of Tl
decisions in Superfund and RCRA
Corrective Action programs, especially
those concerning the decision process.
Rationale: The following issues or
questions concerning Tl decisions were
identified in the DNAPL discussion
paper:
Factors indicating that a Tl decision
is warranted
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Circumstances that would warrant
revisiting a Tl decision
Content and/or format of a Tl
evaluation report
Whether a simplified (or
streamlined) Tl decision process can
be applied to operating remedies
Whether the Tl decision process can
be used to encourage use of
innovative technologies
Mechanisms other than Tl for
recognizing site complexities or
technology limitations and adjusting
cleanup goals in Superfund and
other cleanup programs
Addressing these and other questions
will help clarify EPA expectations
concerning use of Tl decisions and
dispel many misconceptions that were
mentioned by reviewers and GWTF
members. Although state reviewers
indicated a general dislike for Tl
decisions, the GWTF concluded that
many of these concerns can be
addressed by updated guidance.
Tl decisions are an important
component of the Superfund program
because statutory provisions concerning
"applicable or relevant and appropriate
requirements" (ARARs) and ARAR
waivers are unique to the Superfund
program. Cleanups conducted under
Superfund are required to meet ARARs
or waive them using one of the waiver
provisions specified in the statute (such
as, Tl).
Next Steps: Form a cross-program
workgroup to scope out and complete
this guidance project. For example, the
guidance workgroup would determine:
Topics to be addressed in the
updated guidance
Whether it is better to complete a
single document or multiple fact
sheets
Whether guidance should be
expanded to include applicability of
Tl decisions to other types of source
areas, such as LNAPLs or metals
Mechanisms other than Tl for
setting cleanup goals different from
drinking water standards
Project schedule
Other issues concerning this project
Technology Research and Development
Recommendation 2. Develop
recommended data needs and procedures
for documenting and tracking DNAPL
source zone cleanup efforts so that
technology performance can be adequately
assessed. Procedures are needed to better
assess field research and testing
(conducted by EPA and others) to develop
promising technologies for remediation and
characterization of DNAPL source zones.
Goal: Provide a scientific basis to
determine whether DNAPL source
depletion is a reasonable cleanup goal.
Improve our understanding of the
capabilities of source reduction
technologies and long-term impacts of
DNAPL source depletion on the
dissolved contaminant plume (benefits
and detriments).
Rationale: Compilation of improved
data sets from multiple sites are
needed to provide the scientific basis
for future EPA guidance concerning
cleanup of DNAPL source zones. One of
the findings of a recent EPA-sponsored
expert panel report was that even
though numerous field trials (pilot tests
and full-scale remedies) of DNAPL
recovery technologies have been
24
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completed, documentation of the tests
has often been insufficient to quantify
the degree of source reduction
achieved or to assess the long-term
effects on the dissolved contaminant
plume. The expert panel also
concluded that improved data sets
from a variety of hydrogeologic settings
should be compiled to provide insight
on the types of benefits that may be
achieved by partial depletion of DNAPL
sources, including long-term effects on
ground water quality. The panel also
recommended that such data sets be
independently reviewed.
Additional field research and testing
(with well defined monitoring methods)
is needed to further advance promising
technologies for remediation and
characterization of DNAPL source
zones, and to better understand the
effectiveness and appropriate
application of these technologies at
contaminated sites. Improved
mechanisms for documentation and
review of test results will increase the
value of field research and testing for
cleanup programs. Continued research
and improved data sets are needed to
provide the scientific basis for EPA
guidance development on the
remediation of DNAPL source zones.
Comments from reviewers and from
GWTF members indicate that guidance
to assist site managers in determining
the types of sites where DNAPL source
depletion technologies should be
implemented is badly needed.
Next Steps: Form a team or similar
body of EPA technical experts to make
recommendations on how to instrument
and monitor field testing and use of
DNAPL source reduction technologies.
This advisory body would identify a
limited number of sites (e.g., one or
two per EPA region) where DNAPL
source treatment is to be tested or
used as part of a remedy. The team
would make recommendations
concerning:
Sites where DNAPL source reduction
technologies have been tested
previously and further data
collection is warranted (e.g., one
site per EPA region)
The types of additional data to be
collected (including site
characterization and long-term
monitoring data)
Methods for documenting and
tracking long-term performance and
impacts on the plume
Independent review of site data
sets
Compilation of data for multiple
sites
Because of the complexity and cost of
such an approach, partnerships with
other federal agencies, universities, or
other entities could be considered in
establishing such a team (e.g., a
"DNAPL technology advisory team").
The purpose of the data collection
effort is to accumulate the data sets
necessary to develop future EPA
guidance on cleanup of DNAPL source
zones (e.g., types of sites where source
reduction should or should not be
attempted, and cleanup goals for the
source zone).
Information Resources
Recommendation 3. Develop a web-based
resource center for information related to
cleanup and characterization of sites with
DNAPLs, including links to existing policy,
guidance, technology descriptions, and
case studies, as well as resources such as
fate and transport and chemical property
tool calculators.
25
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Goal: A resource center for information
concerning cleanup of DNAPL sites,
including both technical resources and
guidance.
Rationale: There is a need for a
website that serves as the starting
point for finding information
concerning cleanup of DNAPL sites and
related information. Such a site would
be a useful source of information for
EPA and state site managers, cleanup
contractors, community groups, and
other stakeholders. There is no current
EPA website specific to DNAPLs that
serves this purpose.
Existing EPA policies and guidance
related to cleanup and characterization
of sites with DNAPLs would also be
linked to this website. Comments from
reviewers and from the GWTF indicate
that there is still some confusion
regarding existing EPA policy, including
whether EPA expects DNAPL source
zones to be restored to drinking water
standards at sites with such sources.
Technical guidance on DNAPLs
developed by others, such as the
Interstate Technology Regulatory
Council (ITRC), could also be linked to
this website.
Next Steps: Assign a project leader to
develop the web resource center.
Existing information on cleanup
technologies, case studies, and
guidance from EPA and non-EPA sources
should be identified. The project
leader would solicit comments from
other programs in making final
determinations of information to be
linked to the website and the format of
the website.
The web resource center could include
a list of experts available to answer
questions concerning cleanup and
characterization of DNAPL sites. This
list could include experts on particular
technologies, experts on requirements
for EPA cleanup programs, and other
sources of specific types of
information.
Ground Water Use, Value, and
Vulnerability Recommendations
The GWTF found that there is little
consensus at this time among stakeholders
for recommending any significant shift in
current policies to address issues identified
in the Ground Water UVV options paper.
Therefore, the GWTF developed the
following recommendations which focus on
providing educational resources and
improving coordination among ground
water cleanup and protection programs.
Recommendation A. Develop a new web-
based resource center for information
related to the potential role of ground
water UVV in cleanup decisions. The
resource center would address items, such
as interconnection between ground water
and surface-water systems; the importance
of ground water to ecosystems; health
impacts from contaminants most commonly
found in ground water; the potential for
drinking water shortages and their effects
on current ground water use
classifications; federal protection policies,
and exemplary state policies.
Goals: Provide a source of information
and educational materials that lay a
foundation for understanding ground
water UVV issues and give examples of
how some states have used ground
water UVV in making cleanup decisions.
An example of a successful outcome of
this effort would be that an interested
member of the public used materials
from the resource center to better
understand a proposed remedy where
ground water UVV were factors in
setting cleanup goals.
26
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Rationale: This recommendation
evolved from Option 1, which referred
only to educational fact sheets and
Internet training seminars. Based on
the comments supporting Option 1 and
suggestions for other options from
commenters, the GWTF broadened
Option 1 into a web-based resource
center. This recommendation received
the broadest support by GWTF
members. The GWTF concluded that
information on ground water UVV and
its potential role in cleanup decisions
should be more easily available to
government officials (particularly
cleanup managers) and interested
members of the public. Furthermore,
this recommendation could help
address many of the issues identified in
the GWTF discussion paper (e.g.,
educate interested stakeholders about
many state approaches used to account
for ground water UVV in site-specific
cleanup decisions). Educational tools
would include the importance of
protecting ground waters that currently
support ecosystems, and ground waters
that may be needed as a future source
of drinking water. Notably, there were
a number of comments, particularly
from members of the regulated
community, that education alone would
not result in needed policy changes.
Next Steps: Form a cross-program
workgroup to scope out the project,
paying particular attention to resources
currently available through EPA's
Office of Ground Water and Drinking
Water and the EPA Drinking Water
Academy.
Recommendation B. Request that the U.S.
Census Bureau update the 1990 census
information on sources of drinking water8,
8 This information was collected in the 1990
census and earlier but was excluded from the
2000 census. The U.S. Census Bureau web page
and develop tools to facilitate access to
this information.
Goal: Successfully convince the U.S.
Census Bureau to add a question to the
2010 census pertaining to sources of
drinking water, thereby updating
information previously collected in
1990. Information on the locations of
private wells in all 50 states, would
allow ground water cleanup and
protection programs to identify areas
where ground water is currently used
as a source of drinking water for
private homes.
Rationale: Information on private wells
is not easily accessible and in some
cases unavailable from other sources.
This recommendation was offered by
GWTF members after the
issues/options paper was released for
public comment; therefore, the GWTF
did not receive comments for or against
this recommendation. However, the
GWTF did receive comments
emphasizing growing demand on ground
water resources due to population
growth and drought conditions in many
parts of the country. Members of the
GWTF broadly supported this
recommendation because only
information on public drinking water
systems is currently provided to EPA.
Additional information on locations of
private wells (at the census block group
provides the following explanation as to why
the question was removed, "Source of water
and method of sewage disposal were not
required or mandated items. Although many
data users throughout the country found the
information extremely useful, there are other
sources at the state and local level where such
information can be obtained; albeit, not all
areas in the country collect these data
uniformly or disseminate the information in a
manner that is readily accessible to data
users."
27
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level) would serve to further inform
and educate government officials and
other interested stakeholders about the
use and value of ground water
resources, as well as assist cleanup
managers in setting remediation goals
that are protective of both public and
private uses of these resources.
Next steps: Contact the U.S. Census
Bureau to find out why the question on
"source of water" was dropped from
the 2000 census. Draft a letter from
EPA to the U.S. Census Bureau
requesting that this question be added
to the 2010 census. The letter would
explain the value of this information to
ground water cleanup and protection
programs. In addition, the Agency
should develop Internet-based tools to
facilitate access to the existing 1990
census data by EPA program staff and
the public and conduct training on the
availability and utility of the existing
data. These activities should be closely
coordinated with EPA's Office of Water
and Drinking Water.
Recommendation C. Develop approaches
for using source water areas (SWA)9,
delineated by state drinking water
programs, to promote collaboration among
cleanup programs, drinking water
programs, and stakeholders concerned with
cleanup and protection of ground water
resources.
Goals: Increase collaboration among
ground water cleanup and protection
programs within particular source
water areas. Specific examples of
desired outcomes are cleanup
managers would be able to find out
easily if their sites are located in a
9 See
http://cfpub.epa.gov/safewater/sourcewater/
protect/swap, html for more information about
source water, source water assessments, and
source water protection.
designated SWA; and site
characterization, risk assessments, and
other information could be shared
among cleanup managers for sites
located within a particular SWA. This
collaboration would provide an
opportunity to agree on common
cleanup approaches and standards,
where appropriate.
Rationale: Nearly all states have
completed delineation of source water
areas for all public drinking water
systems in their state, including both
ground water and surface water
systems. Ground water within a source
water area is currently used as a source
of drinking water for public supply
wells. Furthermore, the GWTF
supported this recommendation
because it recognized that the
interconnection of ground water within
a source water area makes it possible
for a release from one site to affect
ground water at another site. For these
reasons, this recommendation received
broad support from the GWTF and from
reviewers. Some commenters pointed
out that focusing only on source water
areas would ignore ground water
supplying private wells; combining this
option with the Census
recommendation will help to convey
EPA's interest in ensuring protection of
both public and private drinking water
supplies.
Next Steps: Form a cross-program
workgroup to scope out options for
moving forward. One approach is to
develop a memorandum of
understanding (MOU), such as that
developed between the Office of Water
and the Office of Underground Storage
Tanks (UST). This MOU would
recommend that UST program
managers use source water areas as a
tool to help prioritize their activities
(e.g., inspections, assessments,
removals, final cleanups).
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Summary
In recognizing the importance of ground
water to the nation's drinking water supply
and its critical role in maintaining the
health of ecosystems, EPA established the
Ground Water Task Force (GWTF) in the
fall of 2002 as part of the Agency's One
Cleanup Program. The mission of the task
force was to identify, and prioritize,
ground water issues that will benefit
multiple cleanup programs; and to make
recommendations to EPA senior
management on the best course of action.
Task force members identified two topic
areas for initial evaluation and developed
"options papers" for each area. The
papers are: "Cleanup Goals Appropriate for
DNAPL Source Zones" and "Ground Water
Use, Value and Vulnerability as Factors in
Setting Cleanup Goals." The task force
reviewed cleanup policies associated with
these topic areas, but did not review
overall Agency policies concerning cleanup
of contaminated ground water.
For DNAPL source zones, the issues are
centered around determining cleanup goals
appropriate for the source zone, and
whether remediation should be undertaken
to remove or treat the DNAPL sources.
These decisions are difficult because the
various outcomes may contain a high
degree of uncertainty due to incomplete
information regarding the extent of the
source zone and the effectiveness of the
technologies. The GWTF believed that
implementation of the DNAPL
recommendations will greatly aid
practitioners in making decisions on source
zone cleanup. Providing Agency tools such
as an updated guidance on ways to
acknowledge complex site conditions in
cleanup decisions (e.g., Tl decisions in
Superfund), an EPA website that provides
current information on characterization
and remediation technologies, and EPA
guidance related to DNAPLs, will help meet
near term needs of cleanup programs. In
addition, continuing to support technology
demonstrations, while providing a
mechanism for properly evaluating field
applications of DNAPL source cleanups, will
help expand the scientific basis for
evaluation of the likely benefits of source
cleanups, and provide the foundation for
future Agency guidance.
Ground water use, value and vulnerability
issues are more related to consistent
application of remedies within a watershed
or aquifer system and the philosophic
questions of what needs to be protected
and why. There was little consensus among
stakeholders on how these issues should be
approached. The regulated community for
the most part advocated a risk based
present use approach while the
government commenters preferred to
evaluate an aquifer for its present and
future uses as well as how it fits into the
overall ecosystem. However, by
implementing the recommendations on
ground water use, value, and vulnerability
issues, the GWTF believed the agency will
attain more consistency within its ground
water cleanup programs and promote a
better understanding among all
stakeholders of the part evaluation of
aquifer use, value, and vulnerability play
in making cleanup decisions.
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Attachment A
Discussion Paper:
Cleanup Goals Appropriate
for DNAPL Source Zones
This paper reflects the GWTF's research, analysis and findings as of May 10, 2004 when
it was originally posted at http://gwtf.clu-in.org/papers/. The version of the paper included in
this report has been modified to reflect updates to web links that were available as of December
2007. Note that Kenneth Lovelace is no longer the contact for this issue paper as mentioned on
page A-4. For more current information on the subject, contact either Matthew Charsky
(charsky.matthew@epa.gov) or Linda Fiedler (fiedler.linda@epa.gov) of OSWER's Superfund
program.
A-1
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A-2
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Cleanup Goals Appropriate for
DNAPL Source Zones
Introduction
Notice: It is very important to note that this paper has been prepared by EPA's Ground Water
Task Force for informational purposes only. This paper does contain some discussion
summarizing EPA's statutory authorities and regulations. However, this paper does not
constitute an EPA statute or regulation and does not substitute for such authorities. In
addition, the statements in this paper do not constitute official statements of EPA's views
and are not binding on EPA or any party.
This options paper is being developed by EPA's Ground Water Task Force, a workgroup
established under the "One Cleanup Program" of the Office of Solid Waste and Emergency
Response (OSWER).1 This task force is comprised of EPA and state regulatory officials, and was
formed to:
serve as the main technical/policy/communication/networking resource for OSWER on
ground water issues;
promote cross-program coordination and communication on technical and policy issues
related to the cleanup of contaminated ground water;
identify and prioritize and work to solve and/or provide guidance on ground water issues
and projects that will benefit multiple programs; and
assign subgroups to work on priority issues, and/or make recommendations to EPA senior
management on the best course of actions for such issues.
In carrying out its purpose, Ground Water Task Force representatives discussed with Senior
EPA and state program managers a variety of implementation challenges cleanup programs
face with respect to setting ground water cleanup goals.2 One of those challenges, which was
identified as a priority issue, is differing perspectives on what cleanup goals are appropriate
for that portion of the contaminant plume where dense non-aqueous phase liquids (DNAPLs)
are present in the subsurface (the DNAPL source zone). The purpose of this paper is to
promote dialogue on this issue. It provides a brief background on DNAPLs as a source of
contamination, differing stakeholder points of view (based on written or anecdotal input)
with respect to challenges posed by DNAPLs, and potential options for addressing these
problems. Stakeholders include federal and state regulatory officials, and members of the
regulated community, as well as environmental and public interest groups. The Ground Water
1 For more information concerning the EPA's One Cleanup Program, refer to
http://www.epa.gov/oswer/onecleanupprogram/ . For more information concerning the One Cleanup
Program Ground Water Task Force, refer to http://gwtf.cluin.org/ .
2 Oral presentation and discussion on March 4, 2003 before the Cleanup Programs Council, an advisory
group for the OSWER One Cleanup Program.
A-3
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Task Force recognizes that other problems and options may exist, and no decisions have been
made at this point with respect to which option(s) the Agency may pursue. Readers are
encouraged to provide their comments on the paper and to suggest solutions they believe the
Agency should consider to address the problems stated in this paper and/or other problems
not mentioned herein. As conveyed in this document, any additional option submitted should
describe the particular problem(s) it would address, as well as its associated advantages and
disadvantages. These comments will be used in planning future activities of the task force
and in developing recommendations for EPA senior managers on a course of action to address
the issues raised in this paper.
Questions or comments concerning this paper should be directed to Kenneth Lovelace and
sent via email to gwtf@emsus.com by July 31, 2004. Copies of this paper can be obtained
from the Ground Water Task Force website: http://gwtf.cluin.org.
EPA recognizes that some stakeholders are concerned that raising issues addressed in this
paper may generate pressures to change existing approaches, promote debates that slow
down cleanup decisions, and ultimately affect the ability of regulatory programs to impose
and achieve cleanup goals. However, the task force believes that avoiding these issues would
not be responsive to other concerns raised during stakeholder meetings held by the Agency in
2003 concerning the goals of the One Cleanup Program. Additional stakeholder meetings are
planned specifically for this and other options papers developed by the task force. By
including states on the task force and promoting public dialogue on these ground water
issues, the agency is attempting to fairly balance all of these concerns.
Issue Background
DNAPLs as a Source of Contamination
A non-aqueous phase liquid (NAPL) is a chemical or mixture of chemicals that do not readily
mix with water. In water, NAPLs form a separate liquid phase and do not readily dissolve.
Dense NAPLs (DNAPLs) sink while light NAPLs (LNAPLs) float. DNAPLs include chemical
compounds and mixtures with a wide range of chemical properties, including chlorinated
solvents, creosote, coal tar, and polychlorinated biphenyls (PCBs). After a spill, DNAPLs
migrate into the subsurface resulting in disconnected blobs of liquid referred to as "residual
DNAPL," and continuous distributions of DNAPL sometimes referred to as "pools." Residual
and pooled DNAPL occupy pore spaces within granular media (e.g., soil) or fractures in
bedrock. DNAPL pools can be mobile or potentially mobile.
The DNAPL source zone is that portion of the subsurface containing residual and/or pooled
DNAPL. Ground water flowing through the source zone dissolves some of the DNAPL, giving
rise to aqueous phase plumes of contamination hydraulically down-gradient of the source
zone. A plume may also result from precipitation infiltrating through residual DNAPLs (or
LNAPLs) located in the unsaturated zone (above the water table). Since DNAPLs are only
slightly soluble in water, DNAPL source zones can persist for many decades and in some cases
for the foreseeable future. Volatile constituents within the DNAPL may continue to release
vapor phase contamination to the unsaturated zone or the surrounding ground water. Thus,
the nature of the contamination problem at DNAPL sites has two components: 1) the DNAPL
source zone, and 2) the aqueous phase plume (and may also include vapor phase
contamination in the unsaturated zone).
A-4
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Some DNAPLs, such as chlorinated solvents, are much denser than water and very mobile in
the subsurface. A large DNAPL spill can sink below the water table, spreading laterally as it
encounters finer grained layers, and may extend to the base of an aquifer. Pooled DNAPL can
migrate due to gravity along the top of down-ward sloping geologic layers or along fractures,
and the flow path can be in a direction different from the ground water flow. Pooled DNAPL
can also penetrate into deeper aquifers by migrating along fractures in confining layers. For
these reasons, delineating the subsurface extent of the DNAPL source zone can be a
substantial undertaking. At many sites, DNAPLs are suspected but have not been observed in
the subsurface. For other sites, DNAPLs have been observed at some locations but the extent
of the DNAPL source zone has not been distinguished from the overall plume.
The number of CERCLA3 (i.e., Superfund) sites or RCRA4 Corrective Action facilities with
DNAPL source zones is uncertain. However, in the early 1990s, the Superfund program
reviewed existing site investigation data from a sample of 712 sites in order to estimate the
extent of the DNAPL problem. Results were presented in a 1993 report, which concluded that
"...approximately 60% of all NPL sites exhibit a medium to high likelihood of having DNAPLs
present as a source of subsurface contamination" (EPA, 1993a; page x).
EPA Cleanup Goals
The goal for ground water remediation at Superfund sites and RCRA Corrective Action
facilities is to protect human health and the environment, typically using a combination of
short-term measures (e.g., providing alternative water supplies) and long-term measures
intended to return contaminated ground water to quality consistent with its designated
beneficial uses. In general, ground water has been designated by states as current or future
sources of drinking water, although a number of states are looking at other approaches in
designating ground water based on use, value, and vulnerability. (See task force options
paper: Ground Water Use, Value and Vulnerability as Factors in Setting Cleanup Goals.) For
ground water designated as current or future sources of drinking water, long-term (i.e., final)
cleanup goals typically include returning contaminated ground water to drinking water
standards (e.g, federal maximum contaminant levels (MCLs) or state MCLs).5 For Superfund
sites and RCRA Corrective Action facilities where returning the plume to MCLs is a cleanup
goal, MCLs are typically to be attained within the contaminated aquifer and throughout the
plume. Thus, long-term cleanup goals at most Superfund sites and RCRA Corrective Action
facilities include attainment of drinking water standards throughout the plume of
contaminated ground water, which may include the DNAPL source zone (if present) as well as
the aqueous contaminant plume.
Long-term cleanup goals for Superfund sites and RCRA Corrective Action facilities do not
always include attaining MCLs throughout the plume. For ground waters that are not
designated by states as current or future sources of drinking water, drinking water standards
3 The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) was enacted
in 1980, and amended in 1986.
4 The Resource Conservation and Recovery Act (RCRA) was enacted in 1976, and amended in 1984.
5 Federal Maximum Contaminant Levels (MCLs) established under the Safe Drinking Water Act (enacted
in 1974, amended in 1996), and related information are available online at:
http://www.epa.gov/OGWDW/mcl.html .
A-5
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are generally not used as cleanup levels and alternative cleanup goals are typically
established, such as control of sources and containment of the plume. Also, where the
remedy calls for on-site management of waste materials (such as a landfill), cleanup levels
generally do not need to be attained in ground water beneath the waste management area. In
such cases, attaining MCLs throughout the plume applies only to that portion of the plume
outside the waste management area. Furthermore, both the Superfund and RCRA Corrective
Action programs generally allow alternative cleanup goals to be established at sites where
attaining MCLs throughout the plume is determined to be technically impracticable (Tl). Both
of these EPA cleanup programs also establish alternate cleanup limits (ACLs) in lieu of MCLs,
under appropriate circumstances. However, ACLs defined under CERCLA are somewhat
different from those in RCRA Corrective Action.6 Some state cleanup programs have provisions
for establishing contaminated ground water containment or management zones. Within such a
zone, active cleanup of contaminated ground water may be deferred or may not be required.
The specifics of how containment or management zones are defined, and what alternative
cleanup goals are applied, differ from state to state.
Cleanup Technologies
For the reasons discussed above, sites where DNAPLs are present in the subsurface are very
difficult to clean up to drinking water standards. Cleanup technologies applicable to these
sites often include individual approaches or various combinations of approaches intended to
control migration of contaminants (containment), remove contaminants from the subsurface
(extraction), or treat contaminants in place (in-situ treatment). Each of these technology
types have been used (with varying degrees of success) on DNAPLs in the source zone or on
dissolved contaminants in the plume.
Over the past two decades, significant advancement has been made in the development of
these technologies, especially those intended to remove or treat DNAPLs in the source zone.
However, site owners and cleanup managers have been reluctant to implement these
technologies. Potential reasons for the limited application of source-zone depletion
technologies include uncertainties with respect to: 1) actual extent of the DNAPL source-
zone, 2) whether MCLs can be attained in the source zone, 3) predicting benefits and adverse
impacts of DNAPL depletion where MCLs are not likely to be attained, and 4) the acceptability
of cleanup goals other than MCLs (EPA, 2003).
Potential Benefits and Impacts of DNAPL Mass Reduction
Reducing the quantity of DNAPL mass in the source zone can have several potential benefits,
regardless of whether MCLs can be attained in the source zone. A recent national panel report
specifically addresses cleanup of DNAPL source zones. This panel, convened by EPA's Office of
Research and Development, completed a report titled: The DNAPL Remediation Challenge: Is
There A Case For Source Depletion? The Executive Summary of this report provides the
following conclusions regarding the potential benefits of DNAPL mass depletion (EPA, 2003;
pagexi):
6 ACLs used in the Superfund program are defined in CERCLA 121(d)(2)(B)(ii). Guidance for use of ACLs
in RCRA is provided in EPA, 1987.
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Regardless of the site owner, there is a range of benefits, from a risk management
perspective, that may result from DNAPL source-zone depletion. These include explicit
benefits such as: 1) mitigating the future potential for human contact and exposure
through long-term reduction of volume, toxicity, and mobility of the DNAPL, 2) mitigating
the future potential for unacceptable ecological impacts, 3) reducing the duration and
cost of other technologies employed in conjunction with the source removal technology,
and 4) reducing the life-cycle cost of site cleanup. These benefits can be achieved if the
source depletion option can result in the following outcomes: 1) reduction of DNAPL
mobility, if mobile DNAPL is present, 2) reduction in environmental risk to receptors; 3)
reduced longevity of ground water remediation, and 4) reduction of the rate of mass
discharged from the DNAPL source zone. These outcomes could then lead to enhanced
efficiency of complimentary technologies used for ground water remediation as well as
potential reduction in life-cycle costs. Implicit benefits of DNAPL source-zone depletion
include: 1) minimizing risks of failure of long-term containment strategies, 2) mitigating
public stakeholders' concerns, 3) enhancing a company's "green image" as stewards of
the environment, and 4) minimizing future uncertain transaction costs associated with
management of the site.
The 2003 national panel report also summarized the potential adverse impacts of DNAPL mass
depletion as follows (EPA, 2003, page xi):
Adverse impacts of DNAPL source depletion could include: 1) expansion of the DNAPL
source zone due to mobilization of the residual DNAPL, 2) undesirable changes in the
DNAPL distribution (i.e., DNAPL architecture), and 3) undesirable changes in the physical,
geochemical and microbial conditions that may cause long-term aquifer degradation,
and/or may adversely impact subsequent remediation technologies. All of these adverse
impacts could increase life-cycle costs of site cleanup.
Quantitative predictions of these potential benefits and adverse impacts to aid decision
making on whether to implement DNAPL source depletion actions are highly uncertain.
These uncertainties remain as significant barriers to more widespread use of source
depletion options.
Need for Alternative Cleanup Goals
Several national advisory panels have studied the difficulties associated with cleanup of
contaminated ground water, including the particular problems posed by DNAPLs, and have
issued summary reports of their findings. In 1994, the National Research Council (NRC)7
completed the report: Alternatives for Ground Water Cleanup. This report recommended that
sites be categorized according to the "Relative Ease of Cleaning Up Contaminated Aquifers as
a Function of Contaminant Chemistry and Hydrogeology" and gave an example of such a
categorization scheme (Table ES-1), which clearly indicates that DNAPLs are the most difficult
type of contaminant problem to clean up (NRC, 1994; page 5). Among other findings, this
report included the following findings regarding "Setting Cleanup Goals" (NRC, 1994; page 18)
(bold text is from original):
7 The National Research Council (NRC) is the principal operating agency of both the National Academy
of Sciences and the National Academy of Engineering. More information about the NRC can be
obtained from: http://www.nationalacademies.org/nrc/ .
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Conclusion. Existing procedures for setting ground water cleanup goals do not
adequately account for the diversity of contaminated sites and the technical
complexity of ground water cleanup. Whether goals established under existing
procedures adequately protect public health and the environment, or whether they are
overprotective or underprotective, is uncertain, as are the costs to society when these
goals cannot be achieved.
Recommendation 1. Although the committee recognizes that different agencies must
operate under different authorities, all regulatory agencies should recognize that
ground water restoration to health-based goals is impracticable with existing
technologies at a large number of sites.
The Executive Summary of 2003 national panel report provides the following conclusions
regarding "Appropriate Metrics For Performance Assessment" (EPA, 2003; page xi):
The Panel assessed the technical basis for using drinking water standards, such as
Maximum Contaminant Levels (MCLs), as the single performance goal for successful DNAPL
source-zone remediation and the use of chemical analyses in ground water samples from
monitoring wells as the primary metric by which to judge performance of ground water
remediation systems. Although an MCL goal may be consistent with prevailing state and
federal laws for all ground water considered a potential source of drinking water and is a
goal that is easily comprehended by the public, this goal is not likely to be achieved
within a reasonable time frame in source zones at the vast majority of DNAPL sites. Thus,
the exclusive reliance on this goal inhibits the application of source depletion
technologies because achieving MCLs in the source zone is beyond the capabilities of
currently available in-situ technologies in most geologic settings.
Problem Statements
For the purpose of this options paper, the Ground Water Task Force developed generalized
problem statements based on written and anecdotal information. However, the problem
statements listed below do not necessarily represent the position of EPA. Rather, these
problem statements attempt to capture the perspectives of various stakeholders, such as
federal and state regulatory officials, and members of the regulated community, as well as
environmental and public interest groups. Also, individual opinions can vary as much within
these respective groups as between them. Furthermore, these problem statements are not
listed in any order of importance or priority, and do not represent all possible points of view
associated with remediation of a DNAPL source zone.
1. Site owners8 say that cleanup to drinking water standards (e.g., MCLs) is not a realistic
goal for DNAPL source zones, yet they are rarely allowed to use alternative goals.
Federal and state site managers continue to set such stringent goals within the DNAPL
source zone, even though most technical experts agree that attaining MCLs within the
DNAPL source zone is not possible with currently available technologies at most DNAPL
sites. Site managers are not utilizing program flexibilities for setting alternative cleanup
8 In this paper the term "site owners " is used to refer to those parties responsible or potentially
responsible for the release of contaminants to the environment, and therefore, for paying cleanup
costs.
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goals for this portion of the plume (e.g., technical impracticability decisions, containment
zones, or similar).
2. Technology developers say that continued adherence to overly stringent cleanup goals
for DNAPL source zones inhibits the potential use of existing technologies and is
detrimental to development of new methods. Currently available in-situ treatment
methods, such as thermal and oxidation technologies, can remove significant quantities of
DNAPL from the source zone. However, site owners are reluctant to consider using such
technologies in remedies because they feel that attaining MCLs in the source zone is not
likely to be achieved, even with the most promising technologies.
3. Federal and state site managers say that alternative cleanup goals often cannot be
applied because the DNAPL source zone has not been distinguished from the overall
plume. For many sites, the DNAPL source zone has not been delineated. Regulatory
officials are reluctant to use program flexibilities (e.g., technical impracticability
decisions, containment zones, or similar) in these cases, because there is no basis for
defining the portions of the plume where alternative goals are to be applied. Site
managers say that site owners are not interested in delineating the DNAPL zone and
typically want alternative goals to be applied to the entire plume, which would mean that
none of the plume (neither source zones nor aqueous phase plumes) would be cleaned up.
Continued adherence to stringent cleanup goals is the best way to make sure that DNAPL
sites get cleaned up.
4. Federal and state site managers are concerned that alternative cleanup goals have
uncertain reliability and long-term costs. Alternative cleanup goals, such as containment
or exposure control, will require that ground water monitoring and site controls be
maintained throughout the foreseeable future. The long-term reliability of containment
systems and exposure controls is uncertain. Also the effectiveness of such systems and
controls often is not well documented. Containment systems have high capital costs, and
hydraulic (i.e., pumping) containment systems also have high operating costs. Components
used in containment systems have a finite operating life (e.g., pumps, wells, piping, flow
barriers), and replacement costs are not typically considered during remedy selection.
Institutional controls (e.g., deed covenants or well drilling restrictions) also have
long-term costs associated with monitoring and enforcement. Long-term custodial care9 of
sites with DNAPL source zones cannot be maintained if site owners go out of business; or if
federal and state governments decide to eliminate funding for "orphan sites" at some
time in the future. For sites where cleanup to MCLs can be achieved in the DNAPL source
zone and throughout the plume, uncertainties, long-term costs, and other disadvantages
associated with long-term custodial care can be avoided.
5. Federal and state site managers say that although source depletion is sometimes a
cleanup goal, there is currently no accepted performance measures to determine the
effectiveness of DNAPL mass removal. There is no agreement among technical experts
on what performance measures should be used to indicate that DNAPL mass has been
9 Long-term custodial care includes all activities needed to ensure the protectiveness of a remedy into
the foreseeable future, which will likely include multiple generations. These activities include site
monitoring; maintenance of remedy components, replacement of remedy components as needed; and
monitoring and enforcement of institutional controls.
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removed to the extent practicable from the DNAPL source zone. A 1996 EPA guidance says
that long-term objectives for the DNAPL source zone are to (EPA, 1996; page 14):
... control further migration of contaminants from subsurface DNAPLs to the
surrounding ground water and reduce the quantity of DNAPL to the extent
practicable.
Although total DNAPL mass removed by recovery systems is relatively easy to measure,
estimates of total mass present in the subsurface are highly uncertain and are typically
underestimated. This means there is no good way to estimate the fraction of DNAPL mass
removed from the subsurface with an acceptable level of confidence. In some cases, a
sharp decline and leveling off of mass recovery over time has been used to indicate that
DNAPL has been removed to the extent practicable. However, there is no standardized
method for determining when the mass recovery has leveled off. Also, leveling off of mass
recovery can result from a poorly designed recovery system.
6. Site owners say that source depletion should not be a cleanup goal because the
potential benefits of DNAPL mass removal are outweighed by disadvantages. Some site
owners believe that such efforts are unlikely to remove all of the DNAPL from the source
zone, which means that a plume of contaminated ground water will persist and remedies
to contain or otherwise manage the plume will still be required. Site owners also say that
mass removal from the source zone is unnecessary as long as the entire plume is contained
and institutional controls are established. Also, attempts to remove DNAPL mass could
have detrimental effects, such as causing further migration of the DNAPL. Site owners say
that containment of the plume, including the DNAPL source zone, is protective and
consistent with EPA guidance (e.g., the 1993 Tl guidance).
7. Managers of federal and state cleanup programs say that flexibility in setting
appropriate cleanup goals for DNAPL source zones is also a concern when revisiting
operating remedies. Improved decision making approaches will be helpful when selecting
the initial remedy and also when revisiting operating remedies. Many DNAPL sites have
remedies that were selected several years ago, when the state of knowledge concerning
problems posed by DNAPLs was less advanced. Reasons for revisiting cleanup goals during
the operating phase of a remedy could include:
desire to reduce annual operating costs,
desire to change to a more effective cleanup technology,
lack of progress toward existing cleanup goals,
new or previously unrecognized contamination problems, and/or changes in land use.
Those who are paying remedy costs (site owners, federal and state cleanup programs)
generally want to reduce long-term remedy costs. Since annual maintenance costs are
higher for operating systems (e.g., pump and treat, in-situ treatment systems), site
owners and cleanup programs would like to turn off these components of the remedy
sooner rather than later.
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8. Federal and state site managers say that they should be able to revisit technical
impracticability (Tl) decisions. If a Tl decision is made for DNAPL source zones (or for
other site conditions), federal and state site managers want to be able to revisit the Tl
decision at some time in the future when new cleanup technologies become available.
Cleanup of the site is preferable to long-term custodial care for the reasons discussed
above. EPA's 1993 "Guidance for Evaluating the Technical Impracticability of Ground
Water Restoration" states that Tl decisions "...will be subject to future review by EPA"
(EPA, 1993b; page 25). However, this guidance also indicates that Tl decisions can be
permanent for Superfund sites if the remedy continues to be "protective." In contrast,
the 1993 guidance indicates that Tl decisions are not permanent for RCRA facilities (EPA,
1993b; page 25).
EPA DNAPL Related Projects
The projects listed below are technology demonstration projects and multi-year research
efforts intended to address one or more of the problems identified above. All of these
projects were recommended in the findings of a recent national panel report: titled: The
DNAPL Remediation Challenge: Is There A Case For Source Depletion? (EPA, 2003). EPA's
ability to continue and/or initiate these DNAPL-related projects is dependent upon resources
and their relative priority compared to research needs for other issues.
Project A - A review of existing data from sites where sufficient documentation is available to
assess the performance of DNAPL source depletion efforts, including long-term impacts on the
plume (EPA, 2003; Section 5.2, No. 4).
Project B - Develop guidelines for data that should be collected to document field
demonstrations of source depletion technologies, prior to initiation of DNAPL removal, during
operation and after completion of DNAPL removal (EPA, 2003; Section 5.2, No. 3).
Project C - Develop and validate technologies for measurement of mass flux from DNAPL
source zones, and other measures for evaluating the effectiveness of DNAPL mass removal
(EPA, 2003; Section 5.2, No. 5).
Project D - Continue research and demonstration projects to develop, test, and validate the
most promising technologies for DNAPL source zone characterization and mass depletion.
Much of this work is being undertaken in partnership with other federal and state agencies,
and with industry groups (EPA, 2003; Section 5.2, No. 2).
Options for Addressing Problems
The options listed below are intended to address one or more of the problems identified
above. They are listed in approximate order of increasing complexity and time to complete.
For instance, the longer-term projects require the collection of additional supporting data. It
is assumed that the statutory and regulatory framework for EPA cleanup programs will not
change in the near future, so all options fall within the current framework for these
programs. It is also assumed that training and outreach activities are an essential component
of each option. A brief discussion of advantages and disadvantages is included for each
option. A matrix table showing the problems addressed by each option is included as Table 1.
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Option 1 - Develop a fact sheet describing the potential benefits of DNAPL mass removal from
the source zone, as well as the potential disadvantages.
Advantages: No additional studies would be needed to develop such a fact sheet. The
potential benefits of DNAPL source removal are often overlooked. This may encourage
greater consideration and use of DNAPL recovery and/or treatment technologies for site
remedies. May encourage delineation of the DNAPL source zone.
Disadvantages: Simply listing potential benefits and disadvantages without guidance on
the types of sites where source depletion should (or should not) be included as a
remediation goal (Option 6) will not be very helpful. Also, since there are currently no
accepted performance measures to determine the effectiveness of DNAPL mass removal,
it may be difficult to determine whether benefits have been realized at a particular site.
Option 2 - Develop a fact sheet describing program flexibilities and alternative cleanup goals
that may be applied to the DNAPL source zone other than attainment of MCLs. Program
flexibilities (e.g., technical impracticability decisions, containment zones, or similar) would
be those that may be allowed under federal or state cleanup programs. The alternative goals
would typically apply only to the DNAPL source zone rather than the entire plume, in
accordance with existing policy.
Advantages: No additional studies would be needed to develop such a fact sheet. It may
encourage site managers to make greater use of program flexibilities currently available
from federal and state programs for the DNAPL source zone. Tl decisions as well as other
flexibilities would be discussed (e.g., containment zones, or similar designations). It may
encourage delineation of the DNAPL source zone.
Disadvantages: Would only apply to sites where DNAPL source zone has been delineated,
which may be a small minority of sites. May not increase use of program flexibilities. If
examples of program flexibilities are described but not mandated, this fact sheet may not
be very helpful.
Option 3 - Develop a supplemental EPA guidance on technical impracticability (Tl) that
clarifies some or all of the following questions for Superfund and other EPA cleanup programs:
circumstances that would warrant revisiting a Tl decision;
what a Tl evaluation report should look like;
how the Tl decision process can be used to encourage delineation of DNAPL source
zones;
can a simplified (or streamlined) Tl decision process be applied to operating remedies;
and
how the Tl decision process can be used to encourage use of innovative source removal
technologies.
Advantages: No additional studies would be needed to develop such a guidance.
Clarification of when a Tl decision can be revisited may especially help the Superfund
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program (Problem 8). Tl determinations are currently an option in both the Superfund and
RCRA Corrective Action programs. Current guidance would be updated. This guidance
could address several questions or concerns regarding the Tl decision process, such as the
examples given above. Such a guidance could resolve questions that are currently
discouraging Tl determinations.
Disadvantages: Some federal and state cleanup programs may prefer to use program
flexibilities other than Tl for DNAPL source zones. For these programs, a supplemental Tl
guidance would have limited usefulness. Providing guidance on the Tl decision process,
without guidance on the types of sites where source depletion should (or should not) be
included as a remediation goal (Option 6) may not be very helpful in determining when
DNAPL source reduction should (or should not) be attempted.
Option 4 - Develop a policy memorandum re-emphasizing existing EPA policy that program
flexibilities are to be used for DNAPL source zones as a means of setting cleanup goals that
are achievable in a reasonable time frame. Such program flexibilities may include Tl
determinations, containment zones, ground water classification exemptions, or similar
flexibilities that are available at a particular site from either the federal or state cleanup
program overseeing the cleanup at that site. The memorandum would reiterate EPA's current
policy that cleanup goals for DNAPL source zones should not include restoration of ground
water to drinking water standards, if this goal cannot be achieved in a "reasonable time
frame" based on site conditions.
Advantages: No additional studies would be needed to develop such a policy. This is not a
policy change because EPA's cleanup expectations (as stated in the regulations for
Superfund) are to: "... return usable ground waters to their beneficial uses wherever
practicable, within a timeframe that is reasonable given the particular circumstances of
the site" (Federal Register, 1990; §300.430 (a)(1)(F)). This memorandum would clarify
EPA's national policy on cleanup expectations for DNAPL source zones, clarify that
cleanup goals should be scientifically defensible, and apply only to sites where DNAPL
source zones have been delineated.
Disadvantages: Such a policy memorandum would be similar to a policy issued by OSWER
in 1995 (EPA, 1995), which has had little discernable effect on remedy decisions. No
guidance would be provided on the types of sites where source depletion should (or should
not) be included as a remediation goal, and therefore, would not provide much useful
guidance to decision makers. This policy would only apply to sites where the DNAPL source
zone has been delineated, which may be a small minority of sites. It is not clear whether
such a policy memorandum would provide an incentive to delineate such source zones.
Providing guidance on "reasonable time frame" may be difficult. This option does not
address any of the concerns regarding Tl determinations (Problem 8). Since there is
currently insufficient guidance regarding what a "reasonable time frame" is for attaining
cleanup goals, this policy may not be helpful unless this question is also addressed.
Option 5 - Develop guidance on recommended methods and approaches for delineating the
extent of the DNAPL source zone.
Advantages: This guidance would explain which characterization methods, including newly
developed and conventional tools, are most helpful in delineating the spatial extent of the
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DNAPL zone. This would update existing guidance. This may encourage more site
managers to characterize the DNAPL zone.
Disadvantages: There may not be a clear consensus on which characterization methods
are most helpful. If there is no such consensus, then additional research and
demonstration projects will need to be completed before such a guidance can be initiated
(Project D). To be useful this document will need to do more than simply describe field
methods. It will also need to address how field data should be evaluated, level of detail
needed for delineation of the DNAPL source zone as a function of the types of remedies
being considered, value to be placed on direct versus indirect indicators of DNAPL, and
other considerations.
Option 6 - Develop guidance providing a qualitative approach for determining when source
depletion technologies should be implemented, or should not be implemented. This guidance
would attempt to identify types of site conditions where:
MCLs are potentially achievable in the DNAPL source zone;
MCLs are not likely to be achieved;
Benefits of source depletion efforts tend to outweigh disadvantages; and
Types of sites where source depletion should be included as a remediation goal
(regardless of whether or not MCLs are likely to be achieved within the DNAPL source
zone).
Advantages: This would provide a useful decision-making tool. No such guidance currently
exists. This project was included in the recommendations of a recent national panel
report (EPA, 2003). It may encourage delineation of the DNAPL source zone.
Disadvantages: There is currently a lack of well documented case studies, and therefore,
a lack of scientific consensus on these topics. Consequently, this project may not be
feasible at present. A separate project to evaluate existing data from sites where DNAPL
source depletion efforts were undertaken (Project A) would need to be completed before
such a decision making approach could be developed. Also, results of this data evaluation
(Project A) may be inconclusive. If results of Project A are inconclusive, then additional
research and demonstration projects will need to be completed before such a guidance
can be initiated (Project D).
Option 7 - Develop guidance on performance measures for the effectiveness of DNAPL mass
removal, and on how to determine when active DNAPL removal efforts should be
discontinued. Such measures could include trend analysis for mass removal rates, mass flux
data, or other parameters for gauging remedy performance.
Advantages: Currently there is no EPA guidance on this topic. This guidance may
encourage more site managers to include DNAPL depletion as a cleanup goal for the
source zone, and spur wider use of technologies designed to attain this goal. May
encourage delineation of the DNAPL source zone.
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Disadvantages: There may not be a clear consensus on which performance measures are
most helpful. Additional research and field testing of technologies for measurement of
mass flux and other potential performance measures (Project C) are needed before these
methods can be included in such a guidance.
Option 8 - Develop guidance describing improved methods for comparing long-term remedies,
which would allow a more realistic accounting of the costs and other disadvantages of long-
term custodial care. This would include long-term costs of maintaining containment systems,
equipment replacement, monitoring and enforcing institutional controls, and site monitoring.
Advantages: Currently, there is no EPA guidance on this topic. This guidance would allow
EPA to start fresh with new ideas for 1) utilizing the latest technologies; 2) being
responsive to a wide spectrum of stakeholders, including state and local governments,
environmental groups, and the general public; and 3) comparing costs and reliability
issues associated with long-term custodial care.
Disadvantages: Currently there is no consensus on how to do such a comparison.
Therefore, this project may not be feasible at present. No research activities are
currently planned to develop or test potential improved methods for comparing long-term
remedies.
References
EPA, 1987. Alternate Concentration Limit Guidance, Office of Solid Waste and Emergency
Response (OSWER), Publication EPA/530/SW-87/017, July 1987. Available at:
http://www.epa.gov/correctiveaction/resource/guidance/gw/acl.htm.
EPA, 1993a. Evaluation of the Likelihood of DNAPL Presence at NPL Sites, National Results,
Office of Solid Waste and Emergency Response (OSWER), Publication 9355.4-13,
EPA/540-R-93-073, September 1993. Available at:
http://www.epa.gov/superfund/policv/remedy/pdfs/540r-93073-s.pdf.
EPA, 1993b. Guidance for Evaluating the Technical Impracticability of Ground Water
Restoration, Office of Solid Waste and Emergency Response (OSWER), Directive 9234.2-25,
EPA/540-R-93-080, September 1993. Available at:
http://www.epa.gov/superfund/health/conmedia/gwdocs/techimp.htm.
EPA, 1995. Superfund Groundwater RODS: Implementing Change This Fiscal Year, Office of
Solid Waste and Emergency Response (OSWER), Memorandum, Elliott P. Laws to Regional
Administrators and Waste Management Division Directors, OSWER Publication 9335.5-03P,
EPA/540-F-99-005, July 31, 1995. Description available at:
http://www.epa.gov/superfund/policv/remedy/pdfs/540f-99005-s.pdf.
EPA, 1996. Presumptive Response Strategy and Ex-Situ Treatment Technologies for
Contaminated Ground Water at CERCLA Sites, Final Guidance, Office of Solid Waste and
Emergency Response (OSWER), Directive 9283.1-12, EPA/540-R-96-023, October 1996.
Available at: http://www.epa.gov/superfund/health/conmedia/gwdocs/gwguide/index.htm.
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EPA, 2003. The DNAPL Remediation Challenge: Is There A Case For Source Depletion?, Report
Prepared by an Expert Panel to the Environmental Protection Agency, Office of Research and
Development, Publication EPA/600/R-03/143, dated December 2003. Available at:
http://www.epa.gov/ada/download/reports/600R03143/600R03143.pdf.
Federal Register, 1990. Volume 55, No. 46, March 8, 1990; 40 CFR Part 300, National Oil and
Hazardous Substances Pollution Contingency Plan; Final Rule. Available at:
http://www.epa.gov/superfund/policv/remedv/sfremedv/ regenfor.htm.
National Research Council, 1994. Alternatives for Ground Water Cleanup, National Academy
Press, Washington, DC. Available at: http://books.nap.edu/catalog.php7record id=2311.
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Table 1 : Cleanup Goals Appropriate for DNAPL Source Zones:
Matrix Summary of Problems Addressed by Each Option
Options
(primary focus)*
Problem
Statements
1 . Cleanup to MCLs not a realistic
goal for DNAPL zones, yet
alternative goals are rarely used.
2. Overly stringent cleanup goals
inhibit use of existing
technologies.
3. Alternative goals often can't be
applied because DNAPL zone has
not been distinguished from
overall plume.
4. Alternative goals have uncertain
reliability and long-term costs.
5. No accepted performance
measures for effectiveness of
DNAPL mass removal.
6. Potential benefits of DNAPL mass
removal outweighed by
disadvantages.
7. Setting appropriate cleanup
goals for DNAPL zones is also a
concern when revisiting
operating remedies.
8. Should be able to revisit Tl
decisions.
1
P
i| **
1
1
1
1
2
P
2
2
2
2
3
P
2
2
1
2
3
4
P
2
2
1
2
2
5
t
1
1
3
1
6
t
2
2
1
2
2
1
7
t
2
2
2
3
3
1
3
8
t
2
2
3
2
1
3
NOTES:
* Initial/primary focus of option: p=policy; t=technical and/or research study
** 3 = Option provides significant contribution to resolution of problem.
2 = Option provides some help to resolution of problem.
1 = Option may provide help to address problem.
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Attachment B
Discussion Paper:
Ground Water Use, Value,
and Vulnerability as Factors
in Setting Cleanup Goals
This paper reflects the GWTF's research, analysis and findings as of May 10, 2004 when
it was originally posted at http://gwtf.clu-in.org/papers/. The version of the paper included in
this report has been modified to reflect updates to web links that were available as of December
2007. Note that Kenneth Lovelace is no longer the contact for this issue paper as mentioned on
page B-6. For more current information on the subject, contact Guy Tomassoni
(tomassoni.guy@epa.gov) of OSWER's Center for Program Analysis.
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Ground Water Use, Value, and
Vulnerability as Factors in Setting
Cleanup Goals
Issues/Options paper developed by the Cross-Program Ground Water Task Force
Established under EPA's One Cleanup Program
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Introduction
Notice: It is very important to note that this paper has been prepared by EPA's Ground Water
Task Force for informational purposes only. This paper does contain some discussion
summarizing EPA's statutory authorities and regulations. However, this paper does not
constitute an EPA statute or regulation and does not substitute for such authorities. In
addition, the statements in this paper do not constitute official statements of EPA's views
and are not binding on EPA or any party.
This options paper is being developed by EPA's Ground Water Task Force, a workgroup
established under the One Cleanup Program of the Office of Solid Waste and Emergency
Response (OSWER).19 This task force is comprised of EPA and state regulatory officials, and
was formed to:
serve as the main technical / policy / communication / networking resource for
OSWER on ground water issues;
promote cross-program coordination and communication on technical and policy issues
related to the cleanup of contaminated ground water;
identify and prioritize and work to solve and/or provide guidance on ground water
issues and projects that will benefit multiple programs; and
assign subgroups to work on priority issues, and/or making recommendations to EPA
senior management on the best course of actions for such issues.
In carrying out its purpose, Ground Water Task Force representatives discussed with senior
EPA and state managers a variety of implementation challenges cleanup programs face with
respect to setting ground water cleanup goals.20 One of those challenges, which was
identified as a priority issue, is associated with differing perspectives on how ground water
use, value and vulnerability (see Highlight Box on the following page) should influence site-
specific ground water cleanup goals. The purpose of this paper is to promote dialogue by
providing a brief background, followed by differing stakeholder points of view (based on
written or anecdotal input) with respect to problems and/or challenges, and potential options
for addressing these problems. Stakeholders include federal and state regulatory officials,
and members of the regulated community, as well as environmental and public interest
groups.
These points of view do not necessarily represent the position of EPA and are provided to
assist in framing the issues presented. The Ground Water Task Force recognizes that other
problems and options may exist, and no decisions have been made at this point with respect
to which option(s) the Agency may pursue. Readers are encouraged to provide their
comments on the paper and to suggest solutions they believe the Agency should consider to
19 For more information concerning the EPA's One Cleanup Program, refer to
http://www.epa.gov/swerrims/onecleanupprogram/index.htm. For more information concerning the
One Cleanup Program Ground Water Task Force, refer to http://gwtf.cluin.org/.
20 Oral presentation and discussion on March 4, 2003 before the Cleanup Programs Council, an advisory
group for the OSWER One Cleanup Program.
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Ground Water Use, Value and Vulnerability
(Definitions provided for the purpose of this paper)
Ground water use typically refers to the current use(s) and functions of ground water as
well as future reasonably expected use(s). Ground water use can generally be divided into
drinking water, ecological, agricultural, industrial/commercial uses or functions, and
recreational. Drinking water use includes both public supply and individual (household or
domestic) water systems. Ecological use commonly refers to ground water functions, such
as providing base flow to surface water to support habitat; ground water (most notably in
karst settings) may also serve as an ecologic habitat in and of itself. Agricultural use
generally refers to crop irrigation and live-stock watering. Industrial/commercial use
refers to in any industrial process, such as for cooling water in manufacturing, or
commercial uses, such as car wash facilities. Recreational use generally pertains to
impacts on surface water caused by ground water; however, ground water in karst settings
can be used for recreational purposes, such as cave diving. All of these uses and functions
are considered "beneficial uses" of ground water. Furthermore, within a range of
reasonably expected uses and functions, the maximum (or highest) beneficial ground water
use refers to the use or function that warrants the most stringent ground water cleanup
levels, (see Figure 1 reflecting ground water use in the United States.)
Ground water value is typically considered in three ways: for its current uses; for its
future or reasonably expected uses; and for its intrinsic value. Current use value depends
to a large part on need. Ground water is more valuable where it is the only source of
water, where it is less costly than treating and distributing surface water, or where it
supports ecological habitat. Current use value can also consider the "costs" associated
with impacts from contaminated ground water on surrounding media (e.g., underlying
drinking water aquifers, overlying air particularly indoor air, and adjacent surface
water). Future or reasonably expected values refer to the value people place on ground
water they expect to use in the future; the value will depend on the particular expected
use or uses (e.g., drinking water, industrial). Society places an intrinsic value on ground
water, which is distinct from economic value. Intrinsic value refers to the value people
place on just knowing clean ground water exists and will be available for future
generations, irrespective of current or expected uses. While the value of ground water is
often difficult to quantify, it will certainly increase as the expense of treating surface
water increases, and as existing surface water and ground water supplies reach capacity
with continuing development.
Ground water vulnerability refers to the relative ease with which a contaminant
introduced into the environment can negatively impact ground water quality and/or
quantity. Vulnerability depends to a large extent upon local conditions including, for
example, hydrogeology, contaminant properties, size or volume of a release, and location
of the source of contamination. Shallow ground water is generally more vulnerable than
deep ground water. Private (domestic) water supplies can be particularly vulnerable
because (1) they are generally shallower than public water supplies, (2) regulatory
agencies generally require little or no monitoring or testing for these wells, and (3)
homeowners may be unaware of contamination unless there is a taste or odor problem
(EPA, 2003). Furthermore, vulnerability can change over time. For example, anthropogenic
activities, such as mining or construction, can remove or alter protective overburden thus
making underlying aquifers more vulnerable.
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address the problems stated in this paper and/or other problems not mentioned herein. As
conveyed in this document, any additional option submitted should describe the particular
problem(s) it would address, as well as associated advantages and disadvantages. These
comments will be used in planning future activities of the task force and in developing
recommendations for EPA senior managers on a course of action to address the issues raised
in this paper.
Questions or comments concerning this paper should be directed to Ken Lovelace and
sent via email to gwtf@emsus.com by July 31, 2004. Copies of this paper can be obtained
from the Ground Water Task Force website: http://gwtf.cluin.org/.
EPA recognizes that some stakeholders are concerned that raising issues addressed in this
paper may generate pressures to change existing approaches, promote debates that slow
down cleanup decisions, and ultimately affect the ability of regulatory programs to impose
and achieve cleanup goals. However, the task force believes that avoiding these issues would
not be responsive to other concerns raised during stakeholder meetings held by the Agency in
2003 concerning the goals of the One Cleanup Program. Additional stakeholder meetings are
planned specifically for this and other options papers developed by the task force. By
including states on the task force and promoting public dialogue on these ground water
issues, the Agency is attempting to fairly balance all of these concerns.
Background
Since the 1970s, EPA and states have enacted a number of laws and regulations (as well as
supporting initiatives, guidance, and policies) concerning both the protection as well as
cleanup of contaminated ground water. To date, the most concise, cross-programmatic
statements concerning EPA's ground water related policies were provided in the document
titled, "Protecting the Nation's Ground Water: EPA's Ground Water Strategy for the 1990s"
(EPA, 1991). Several of the key principles, findings, and recommendations are presented
below.
Overall Goal:
"The overall goal of EPA's ground water policy is to prevent adverse effects to human
health and the environment and to protect the environmental integrity of the nation's
ground water resources."
With respect to remediation:
"Ground water remediation activities must be prioritized to limit the risk of adverse
effects to human health first, and then to restore currently used and reasonably
expected sources of drinking water and ground water closely hydrogeologically
connected to surface waters, whenever such restorations are practicable and
attainable."
"Given the costs and technical limitations associated with ground water cleanup, a
framework should be established that ensures the environment and public health
benefit from each dollar spent is maximized. Thus in making remedial decisions, EPA
must take a realistic approach to restoration [of contaminated ground water] based
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upon actual and reasonably expected uses of the resource as well as social and
economic values."
With respect to federal, state and local responsibilities:
"The primary responsibility for coordinating and implementing ground water
protection programs has always been and should continue to be vested with the
states. An effective ground water protection program should link federal, state, and
local activities into a coherent and coordinated plan of action."
In the early 1990s, EPA encouraged states to institute Comprehensive Ground Water
Protection Programs (EPA, 1992). The basic goal of the CSGWPP-partnership between the
states and EPA is to achieve a more efficient, coherent, and comprehensive approach to the
nation's ground water resources. More specific goals of an individual State CSGWPP are to
consider ground water use, value, and vulnerability in setting priorities for both prevention
and remediation.
EPA's cleanup programs fully supported CSGWPPs in their directive titled, "The Role of
CSGWPPs in EPA Remediation Programs" (EPA, 1997a). While relatively few states have
pursued CSGWPPs (see http://cfpub.epa.gov/safewater/sourcewater/) many other states
have over the years developed other approaches to designate ground water based on use,
value, and vulnerability. Some of the many approaches, which are often used as factors in
setting ground water cleanup goals, include:
formal state-wide (mapped) classification systems (see for example, Connecticut's
system at
http://www.ct.gov/dep/cwp/view.asp?a=2698&q=323132&depNav_GID=1707 , and
ground water classification exception areas (see for example, New Jersey's provisions
at http://www.state.nj.us/dep/srp/dl/ceaguid2.pdf).
non-degradation policies (e.g., Rhode Island, Maine, Wyoming) that recognize all
ground water as a source of drinking water;
states that presume as a starting point that all ground water is a potential source of
drinking water, but allow for site-specific variations of that classification (see for
example, Michigan waiver provision available at
http://www.michigan.gOV/deq/0,1607,7-135-3311-58095--,00.html and their guidance
on Ground Water Not In An Aquifer (GWNIAA) determinations available at
http://www.deq.state.mi.us/documents/deq-wmd-swp-gwnia-ftp.pdf.
urban use designations as part of voluntary and brownfield cleanup bills (see for
example Ohio's Urban Setting Designations available at
http://www.epa.state.oh.us/derr/vap/docs/fact8.pdf.
ground water management zone approaches that recognize impairment (which allows
for long-term responses like natural attenuation) without changing a ground water
classification (see for example, Illinois' Ground Water Management Zones
(http://www.epa.state.il.us/land/regulatory-programs/permits-and-
management/establishing-groundwater-management-zone.html) and California's
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Containment Zone Policy http://www.swrcb.ca.gov/plnspols/docs/wqplans/res92-
49.html), and
Nebraska's approach to designating and classifying ground water, and their ground
water remediation protocol available Title 118, Chapters 6, 7, and 8 and Appendix A.
(available at http://www.deq.state.ne.us/RuleAndR.nsf/pages/118-TOC).
Later in the 1990s, Congress amended the Safe Drinking Water Act placing a new focus on
assessing and protecting sources of drinking water (see EPA, 2003b). The basic elements of
source water assessment and protection include delineating areas of ground water and
surface water that supply public drinking water systems, assessing those areas with respect to
susceptibility of the drinking water sources to actual or potential sources of contamination,
and developing protection/management strategies and contingency plans. EPA anticipates
that these delineated source water areas will help to focus both protection and remediation
activities.
Regulations and supporting policy and guidance for the three federal cleanup programs
(Superfund, RCRA Corrective Action, Underground Storage Tanks) address the role of ground
water use, among other factors, in setting cleanup goals. For example, the Superfund Rules of
Thumb for Remedy Selection (EPA, 1997b) provides regulatory references and guidance
pertaining to selecting cleanup goals for ground water that is a either a current, potential, or
not anticipated to be a source of drinking water. The Handbook of Ground Water Protection
and Cleanup Policies for RCRA Corrective Action (EPA, 2002) addresses setting cleanup goals
based on various designated uses of ground water. In approving protective corrective action
plans for releases from underground storage tanks, 40 CFR 280.66
(http://www.epa.gov/swerust1/fedlaws/cfr.htm) specifies a number of factors to be
considered. These include the hydrogeologic characteristics of the facility and the
surrounding area, and the proximity, quality and current and future uses of surface water and
ground water in the surrounding area.
Problem Statements
For the purpose of this options paper, the Ground Water Task Force developed generalized
problem statements based on written and anecdotal information. However, the problem
statements listed below do not necessarily represent the position of EPA. Rather, these
problem statements attempt to capture the perspectives of various stakeholders, such as
federal and state regulatory officials, members of the regulated community, and
environmental and public interest groups. Also, individual opinions can vary as much within
these respective groups as between them. Furthermore, these problem statements are not
listed in any order of importance or priority, and do not represent all possible points of view
associated with the role of ground water use, value, and vulnerability in setting cleanup
goals.
1. There does not appear to be enough awareness by the general public, regulated
community, and government officials pertaining to the various ground water functions,
associated values and vulnerability of drinking water supplies to contamination. Adding to
this problem is the lack of awareness and understanding of how aquifers are connected to
other aquifers and to surface water, as well as long-term aspects of contaminant
migration. Furthermore, there is uncertainty with respect to how various contaminants
(individually and cumulatively) affect public health and environmental quality.
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2. There appears to be an increasing demand for reliance on exposure controls rather than
cleaning up contaminated ground water. Decisions not to cleanup may be short-sighted
with regard to increasing future demands for clean drinking water supplies.
3. There is a lack of agreement among stakeholders regarding methods to determine which
ground waters are "reasonably expected" to be a source of drinking water, and how those
decisions should influence cleanup objectives. For example, some programs require
cleanup to drinking water standards only for ground water currently planned to be used as
a drinking water supply rather than considering multi-generational long-term needs. Other
programs require cleanup to drinking water standards for ground water that, in the view
of some stakeholders, would never be used as drinking water supply due to insufficient
quantity and quality. A related problem is the lack of clear direction on determining
appropriate levels or degree of cleanup for ground water not determined to be a
reasonably expected source of drinking water.
4. Ground water cleanup activities and decisions are often not prioritized in a manner that
would result in addressing the most pressing needs or maximizing the public health
benefit of monies spent.
Options for Addressing Problems
The options listed below are intended to address one or more of the problems identified
above. It is assumed that the statutory and regulatory framework for EPA cleanup programs
will not change in the near future, so all options fall within the current framework for these
programs. It is also assumed that training and outreach activities are an essential component
of each option. Furthermore, in evaluating options, the Agency will take into account
resource needs in terms of time, staff and dollars. A brief discussion of advantages and
disadvantages is included for each option. A matrix table showing the problems addressed by
each option is included as Table 1.
Option 1 - Develop a series of educational fact sheets and Internet training seminars
(targeted primarily to government officials and members of the regulated community) to
raise awareness of ground water use, value, and vulnerability, interconnection between
ground water and surface water systems, and health impacts to contaminants most commonly
found in ground water. This effort would include summaries of the findings from the
upcoming 2004 Ground Water report to Congress.
Advantages: This option would help to address problem #1 and would build on EPA's
ground water valuation studies conducted in the early 1990s. It also may also help address
problem #2 by helping people understand the implications of current trends in ground
water cleanups.
Disadvantages: It wouldn't likely provide much benefit with respect to other identified
problems.
Option 2 - Conduct research on the impacts on other developed nations that have resulted
from either the presence or lack of strong ground water protection programs.
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Advantages: This option would help address problem #1 and may also help address
problem #1 by helping people understand the implications of current trends in ground
water cleanups.
Disadvantages: It would only provide information and would not in and of itself promote
any direct changes.
Option 3 - Develop summaries of how individual EPA and state cleanup programs consider
ground water use, value, and vulnerability in setting cleanup goals (e.g., ground water
classification and classification exception systems, ground water management zone type
approaches). These summaries would be written with Internet links to more detailed
resources. EPA would provide access to these summaries via its One Cleanup Program
website. This option could also involve low-cost Internet training to raise awareness of the
range of approaches being used by EPA and states.
Advantages: This option would address, to various degrees, most of the identified
problems. For example, providing access to these summaries could address problems 1
and 2 by raising awareness of EPA and state efforts to protect valuable ground water
resources. Also, it could potentially lead to broader acceptance of successful approaches
that respond to problems 3 and 4. In particular, it would highlight approaches used by
states to distinguish between situations where a drinking water pathway should or should
not be considered in site-specific risk evaluations. Additionally, these summaries and the
associated resource links would help ensure that interested stakeholders were more fully
aware of the flexibilities within a particular program. Lastly, the training element of this
option would increase the visibility and understanding of the various approaches being
used.
Disadvantages: One of the key disadvantages of this option is keeping current the needed
information. Another disadvantage is that it would highlight programmatic differences
that may result in unwanted pressure on some programs to adopt changes to the way in
which they currently set ground water cleanup goals.
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Option 4 - Takes option 3 one step further by developing an EPA policy memo that explains
how EPA cleanup programs acknowledge the various approaches used by states in setting
ground water cleanup goals based on ground water use, value, and vulnerability. For example,
the policy statement would clarify how state ground water management zone policy could
influence goals established under EPA's cleanup programs. Internet training could also be used
to increase awareness and understanding of the policy statement.
Advantages: This option offers the same advantages as Options 3 with the added benefit of
clarifying EPA's policies on the subject.
Disadvantages: This option is associated with same disadvantages posed by Options 3. An
additional disadvantage would be a clear statement of policy on the subject, which may in
some circumstances limit flexibility desired by some stakeholders.
Option 5 - Using information from federal and state cleanup programs, develop a general
framework that describes how to prioritize sites according to problem severity and ground
water use, value, and vulnerability. This framework would clearly describe how ground water
use, value, and vulnerability as well as specific problem magnitude (e.g., risk) can be used to
prioritize sites and influence remedial decisions. This framework would describe how a
prioritization system directed at site-specific ground water problems can work within
statewide general classification systems and how, for example, ground water management
zone policy could influence goals established under EPA's cleanup programs.
Advantages: This option would address many of the problems identified by encouraging
consistency across programs, and by defining the key variables (use, value, and
vulnerability) that should be considered in remedial decisions.
Disadvantages: This option would be fairly resource intensive in terms of federal and state
staff and contractor support needed to develop the framework. The objective of this option
would be similar in many ways to EPA's Office of Water initiative in the early 1990s to
promote Comprehensive State Ground Water Protection Programs (CSGWPPs). Therefore,
this option may be associated with many of the challenges realized in the CSGWPP
initiative.
Option 6 - Use defined Source Water Assessment Program (SWAP) areas (required by the 1996
amendments to the Safe Drinking Water Act) to promote consistency in ground water cleanup
decision making. The option would involve establishing a means that would encourage
stakeholders to become more aware of and involved with various ground water cleanups taking
place within or near an individual Source Water Assessment Area. The objective would be that
cleanups could be selected to maximize efficiencies and benefits within a particular source
water area.
Advantages: This option would specifically address most of the identified problems. States
have completed their SWAP delineations. These areas, which include both ground and
surface water and ground water-surface water interaction, could be used to help address
ground water cleanup and other ground water management related issues. This option
could promote greater consistency in cleanup goals, at least within source SWAP areas.
Additionally, Source Water Assessments are based on a relatively new program that has
significant public interest.
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Disadvantages: Reluctance of states to release detailed SWAP information. It does not
address private water supplies. Additionally, coordination among cleanup projects within a
Source Water Area could be viewed by some as an additional hurdle that could cause
delays.
Option 7 - Promote and provide funding assistance for regular meetings within an individual
state or watershed that brings together the various programs and stakeholders involved with
ground water cleanup and protection. One of the objectives of these meetings would be to
help prioritize cleanup actions based on factors, such as magnitude and extent of ground
water contamination, as well as ground water use, value, and vulnerability.
Advantages: Depending on the planning and agenda, these meetings could help address
most of the stated problems. Topics could include, for example: trends in ground water use,
progress of ground water cleanups; coordination of success stories; training on new
technologies, guidance, policy, etc.
Disadvantages: As noted in the opening paragraph to these options, the ability to support
and implement these meetings may be limited by available resources.
References
EPA, 2003a. One Cleanup Program - Working in Concert to Make Our Cleanups Better. Fact
Sheet available at http://www.epa.gov/swerrims/onecleanupprogram/index.htm.
EPA, 2003b. Memorandum from Assistant Administrator Tracy Mehan III describing source water
assessment and protection (February). Available at
http://www.epa. gov/safewater/sourcewater/pubs/fs_statusbyregion_mehan2003.pdf.
EPA, 2002. Handbook of Ground Water Protection and Cleanup Policies for RCRA Corrective
Action (EPA/530/R-01/015). Available at
http://www.epa.gov/correctiveaction/resource/guidance/gw/gwhandbk/gwhndbk.htm.
EPA, 1997a. The Role of Comprehensive State Ground Water Protection Programs (CSGWPPS) in
OSWER Remediation Programs. OSWER Directive 9283.1-09. Available at
http://epa.gov/superfund/health/conmedia/gwdocs/csgwpp.htm.
EPA, 1997b. Rules of Thumb for Superfund Remedy Selection (EPA/540/R-97/013). Available at
http://www.epa.gov/superfund/policv/remedy/rules/.
EPA, 1992. Final Comprehensive State Ground Water Protection Program Guidance
(EPA/1 OO/R-93/001). Available at
http://www.epa.gov/correctiveaction/resource/guidance/gw/csgwpp.htm.
EPA, 1991. Protecting the Nation's Ground Water: EPA's Strategy for the 1990s. Available at
http://www.epa.gov/superfund/resources/remedy/pdf/21z-1020-s.pdf.
Solley, W.B., R.R. Pierce, and H.A. Perlman, 1998. Estimated Use of Water in the United
States in 1995. USGS Circular 1200. U.S. Geological Survey, Reston, VA. Available at
http://water.usgs.gov/watuse/pdf1995/html/.
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Figure 1
Ground Water Use by States
(Solleyet. al, 1998)
D.C.
0.0%.
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The Role of Ground Water Use, Value, and Vulnerability (UW) in Setting Cleanup Goals:
Matrix of Options Addressing Identified Problems
Option #1 : Fact sheets and
education on ground water
UW.
Option #2: Research other
countries' ground water
programs.
Option #3: Summaries and
education on how programs
consider ground water UW in
setting goals.
Option #4: New policy and
training on ground water UW
in setting cleanup goals.
Option #5: Create framework
for prioritizing cleanups based
on ground water UW.
Option #6: Use SWAP areas to
promote greater consistency
in ground water cleanups.
Option #7: Promote ground
water cleanup coordination
meetings.
Problem
#1:
Insufficient
recognition
of ground
water UW.
3
2
2
1
1
1
2
Problem
#2: Trend
toward
exposure
controls
over
cleanup.
1
2
2
3
3
3
2
Problem #3: Lack
of agreement on
identifying future
ground water use
decisions and how
UW should
influence cleanups.
1
1
3
3
3
3
2
Problem #4: Ground
water cleanup
activities/decisions
often not prioritized
to maximize
benefits.
1
1
3
3
3
3
2
3 = Option provides significant contribution to resolution of problem.
2 = Option provides some help to resolve the problem.
1 = Option may provide help to address problem.
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Attachment C
GWTF Web Page
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= C-2
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S-CDA Unit«l Slale*
Environmental Protection Agency
Ground Water Task Force
News
Upcoming Events
Discussion Papers
Examples of Cleanup
Approaches
Cross-Program
Resources
Task Force Meeting
Summaries
Task Force Members
Member Program
Descriptions
Contact
the Task Force
Ground water is an essential national resource - over half of Ihe U.S. population relies on it for drinking water. However a large percentage of the
nation's contaminated sites impacts ground water. And ground water contamination is usually very difficult to characterize and clean up, often
requiring decades of treatment and monitoring. Almost every cleanup program must devote a significant level of attention and resources to
ground water issues,
Each ground water contamination problem is uniquely complex, yet there are many common issues related to the management and cleanup of
these problems. It is important that the nation's cleanup programs share the knowledge of their unique ground water problems and work together
to ensure the most effective, efficient and protective ground water cleanups.
Task Force Purpose:
* The task force will serve as the main technical / policy / communication I networking resource for OSWER on ground water issues.
The task force will promote cross-program coordination and communication on technical and policy issues related to the cleanup of
contaminated ground water.
* The task force will identify, prioritize and work to solve and/or provide guidance on ground water issues and projects that will benefit
multiple cleanup programs.
* For priority issues and projects, the task force will either assign a subgroup to work on the issue, or make recommendations to EPA
senior management on the best course of action.
The Ground Water Task Force is one component of EPA's One Cleanup Program, which is integrating the
assessment and cleanup efforts of solid and hazardous waste cleanup programs to increase the speed and
efficiency of environmental cleanups and improve the sharing of information with affected citizens. Task Force
efforts are conducted under Initiative I: More Effective and Consistent Cleanups of the One Cleanup Program,
and general Task Force information is also available within this portion of the One Cleanup Program web site.
0
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Attachment D
Individuals and Organizations that
Submitted Comments on One or
Both Discussion Papers
"D-1
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"D-2
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Individuals and Organizations that
Submitted Comments on One or
Both Discussion Papers
EPA
Robin Anderson, OSRTI
Philip Berger, OW
Andy Grassland, Region 2
Richard Freitas, Region 9
Rene Fuentes, Region 10
Elizabeth Janes, Water Office Region 9
Marcella Hutchinson, Region 8
Dave Jenkins, Region 4
Jeff Johnson, RCRA Region 7
Mitch Kaplan, Region 9
Steve Mangion, ORD Region 1
Kevin McCormack, OW
Carol Monell, Region 4
Wayne Naylor, RCRA Region 3
Howard Orlean, Region 10
Lisa Price, RCRA Region 6
Roy Simon, OW
Other
Pierre Sargent, United States Geological Survey
Private Sector/Regulated Community
Richard Kapuscinski, ENVIRON International Corporation for General Motors
Kimberly Gates, NAVFAC
Jim Hatton, Earthtech
Harley Hopkins, American Petroleum Institute
Richard Jackson, Intera Inc.
Donald Koch, C.C. Johnson & Malhotra
Lorraine Krupa-Gershman, American Chemistry Council
W. Caffey Norman, (Patton Boggs) TCE Issues Group
PatO'Hara, Cummings/Riter
John Quarles & Michael Steinberg, Morgan, Lewis & Bockius LLP
Chris Reimer, NGWA
Greg Rucker, Westinghouse Savannah River Company
Bob Schreiber, Camp, Dresser, & McGhee (COM)
Hans Stroo, Retec
Superfund Settlements Project and RCRA Corrective Action Project
Andre Tartre, Ecoremediation
Laura Yeh, Naval Facilities Engineering Service Center
"D-3
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States
Walter Avramenko, State of Colorado
Dale Bridgford, State of Michigan
Daniel Burke, State of Texas
Judy Canova, State of South Carolina
Tom Gallagher, State of Nevada
John Gelting, State of South Carolina
Ed Jones, State of Washington
Jennifer Kaduck, ASTSWMO
David Larsen, State of Utah
Bob Pierce, State of Georgia
Bruce Stuart, State of Missouri
"D-4
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