1-17

SUPERFUND PROGRAM
Resource-Based Priority Setting in Decision Making

The Superfund program was created by the Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA) of 1980, as amended by the
Superfund Amendments and Reauthorization Act (SARA) of 1986. The Superfund
program is designed to respond to contamination at sites with uncontrolied hazardous
substances. Sites that are candidates for Superfund response action first undergo a
Preliminary Assessment and Site Investigation (PA/SI) in order to quantify the human
health and environmental risk posed by the site. Sites are then evaluated under a
number of risk related and other factors set out in the Hazard Ranking System (HRS)
to determine if the site is a priority for possible remedial action and inclusion on the
National Priority.List (NPL). A CSGWPP may influence this process in the following
areas.

Priorities for conducting HRS assessments and for taking short-term removal
actions are determined by the threat that potential contamination may pose. A State's
ability to demonstrate, through a CSGWPP, that it understands the use, value, and
vulnerability of its ground water could be an important factor in setting priorities for
PA/SI and HRS listing evaluations or other actions. By helping to establish high
priority candidate sites, the State can influence which of its sites ultimately get on the
NPL, and become eligible for longer term remedial action.

Once on the NPL, the Superfund policy is to address the worst sites and worst
problems at sites first, based on an assessment of risk to human health and the
environment. Thus, a CSGWPP can assist in determining which studies and sites will
receive priority Superfund attention.

EPA's goal for long-term cleanup of NPL sites includes returning usable ground
waters to their beneficial uses within a reasonable period of time, wherever practicable.
When selecting a remedy and determining remediation requirements for long-term
cleanup at a site, EPA considers both the anticipated uses of ground water and
established State standards. A clear understanding of ground water resources in the
State, demonstrated through consistent application of a CSGWPP, can help inform
these site-specific decisions.

The Superfund Program is currently working to develop a more integrated
approach for its site remediation program, and to identify opportunities for adopting
innovative approaches to restoration and management of hazardous waste sites.
Superfund will also be looking for ways to increase State participation in the remedial
decision process, where allowed by statute.


1-38

RADIATION PROGRAM (continued)

requirements more completely and efficiently by ensuring that they address a
consistent ground water:goal and priorities and share a common assessment of the
resource.


1-34


1-43

POLLUTION PREVENTION PROGRAM
Resource-Based Priority Setting in Decision-Making

Priority setting within the CSGWPP will provide a means for targeting specific
geographic environments for the implementation of pollution prevention techniques,
technologies and work practices. Focusing pollution prevention efforts in high risk,
high value areas will yield the greatest benefits to States as they work to protect their
ground water resources.

Coordination with Other Programs

The Ground Water Protection Strategy and the CSGWPP focus on protecting
ground water from contamination. One of the most effective means of protecting
ground water supplies is through pollution prevention. EPA's Pollution Prevention
program has an vital role to play in the CSGWPP as States establish priorities and
begin to integrate various ground water protection efforts.

Pollution Prevention programs focus primarily on preventing risks rather than -
addressing pollutants after they have been created and emitted to the environment.
While some large industries have been quick to seize upon the pollution prevention
concept, many smail, local businesses are still relatively unaware of how pollution
prevention practices can benefit them. The CSGWPP will encourage broader industry
and public participation in pollution prevention activities through State priorities that
emphasize the role of pollution prevention in protecting ground water quality.

The CSGWPP will foster greater emphasis on pollution prevention at the State
and local levels and will also help Pollution Prevention programs and activities to be
coordinated with other ground water protection programs. As States establish
priorities and goals, they will work to coordinate the efforts of ground water protection
programs and build the pollution prevention concept into them. This process will also
be driven by the on-going interest in promoting pollution prevention in media-specific
grant guidance.

Coordinating Grants

The federal Pollution Prevention grants program "Pollution Prevention Incentives
for States" provides grants to States to support State, Tribal, and local pollution
prevention programs that address the reduction of pollutants across all environmental
media: air, land, surface water, ground water and wetlands. This grant funding could
be used to support the following CSGWPP activities: defining roles and responsibilities
of key participants of proposed projects and promoting coordination with pollution
prevention activities already underway in the State; developing and implementing
prevention programs for reducing or eliminating pollution; collecting and analyzing
data; developing mechanisms to measure progress in pollution prevention; and


1-11

RCRA SUBTITLE C PROGRAM
Resource-Based Priority Setting in Decision Making

The FY 1992 RCRA Implementation Plan indicates that the RCRA program is
implementing a cooperative strategic framework with the States which is designed to:
(1) identify regional and State-wide environmental priorities among all facilities in the
RCRA universe, and (2) use these priorities to select the most appropriate allocation of
resources for RCRA permitting and cleanup activities. One factor in setting these
priorities will be the use, value, and vulnerability of the ground water. Since
CSGWPPs encourage States to develop systems that allow resource-based priority
setting, the CSGWPP approach should serve as an integral part of the efforts the
States and RCRA are undertaking to implement this strategy for setting RCRA
priorities.

An adequate characterization of a State’s ground water resources developed as
part of the implementation of a CSGWPP could supply much useful information that
may be useful in implementing current and future RCRA-related activities. RCRA
corrective actions to cleanup releases of hazardous waste and constituents are
conducted on a site-specific basis, and take into account ground water protection as
a major factor in selecting cleanup remedies. The information generated as part of a
CSGWPP will help to ensure that site-specific decision making will be conducted in the
context of the regional ground water resources. In addition, future regulation on
location standards for RCRA facilities is likely to be integrated with regional ground
water resources identified and characterized as part of a State's CSGWPP.

Coordination with Other Programs

Subtitle C permits should be coordinated with UIC, NPDES, and Wetlands
(§404) permits. When these and other ground water-related programs are ail
implemented within the CSGWPP framework, consistency among priorities and
pollution prevention measures will be significantly enhanced. Overall implementation
will be more efficient and effective.

Some commentators noted that RCRA's requirements on the handling of
pesticide wastes were burdensome. The Office of Solid Waste will explore this
problem with the Office of Pesticide Programs.

Coordinating Grants

RCRA implementation grants can be used, in part, to support general
assessment and infrastructure building, as long as the activities funded demonstrably
aid in implementing RCRA. Because of RCRA's emphasis on State-led, priority-based
decision making, activities such as assessment, mapping, and characterization of
ground water resources would fit this criterion. These activities are also key in other
programs and are essential to developing and implementing a CSGWPP. As such,


1-21

UNDERGROUND INJECTION CONTROL PROGRAM
Resource-Based Priority Setting in Decision Making

CSGWPP resource-based priority setting will help make permitting, inspection,
and enforcement actions for all classes of underground injection wells more effective
and efficient. The overall CSGWPP framework will supply the States with an important
understanding of the use, value and vulnerability of their ground water resources that
will be useful in UIC programs involving all classes of wells.

UIC Class | hazardous waste injection wells (deep industrial disposal wells), for
example, are permitted under the SDWA and by rule under RCRA Subtitle C. Before
operation such wells must be determined not to endanger human health or the
environment. . Comprehensive assessment of the ground water resource will expedite
the identification of all potentially threatened ground waters and confining layers, and
will help to ensure complete and accurate monitoring and identification of potential
migration in the subsurface. The requirements currently being developed for UIC.
Class V wells (shallow drainage and miscellaneous wells) also demonstrate how
CSGWPPs will support resource-based decision making. Under the regulations and
guidance being developed by the UIC program, the most environmentally harmful
Class V wells (e.g., service station drains, industrial waste disposal wells, etc.) will be
controlled by permits; other Class V wells will be controlled by general rules
supplemented by guidance or proper practices to comply with those rules. Although
the controls placed on these wells will be tied to the level of contamination being
injected, the use and value of the underlying ground water resources could be a key
consideration in the setting of priorities under this approach.

Coordination with Other Programs

The UIC program, and particularly the Class V component, will benefit from
being linked to other ground water programs within the CSGWPP. Other programs,
such as the WHP program, will assist in identifying Class V wells that have not been
inventoried. Under the WHP program, sources of contamination within WHP areas
must be identified. Any Class V wells identified during the WHPP inventory can be
added to the Class V inventory. Similarly, any Class V wells identified during RCRA
Facility Assessments (RFAs) or CERCLA Preliminary Assessments and Site
Investigations (PA/SIs) could be added to the Class V inventory.

Efficiencies involving the UIC program and other programs will also be created
through the CSGWPP. The UST program, for example, will be able to benefit from
joint inspections at gasoline stations that address both Class V wells and underground
storage tanks. Pesticide SMPs can include UIC Class V measures to avoid ground
water contamination caused by disposal of residues from mixing or washing in shallow
drainage wells. UIC Class V inventories will be useful sources of information in RFAs
and PA/SIs.


1-39

WETLANDS PROGRAM
Resource-Based Priority Setting in Decision Making

Because wetlands act as natural pollutant filters and as a source of aquifer .
recharge, they often are closely linked to the quality and quantity of ground water
resources. Wetlands occurring along rivers and streams probably are the most
important types of wetlands for ground water recharge. This recharge occurs most
often in the wet portions of the year during overbank flooding. Ground water, in turn,
may be discharged back to the wetlands and river bed during dry years. The
Everglades are a good example of the linkage between a river and a wetlands system
and its underlying ground water, the Biscayne aquifer. Florida is acquiring
approximately 41,000 acres of partially drained wetlands in the Everglades and
restoring them to regain their water quality and recharge benefits.

Several EPA programs. are aimed at protecting and restoring wetlands. In
some cases, ground water resources are considered when establishing wetland
program priorities. For example, EPA is assisting States with the development of
water quality standards for wetlands which include methods for designating wetlands
uses based on function and value. Currently the State of Michigan is considering
designating wetlands as Outstanding Natural Resource Waters if the wetlands are
connected to a municipal ground water supply.

Knowledge of State ground water resource priorities would be useful to the
wetlands program in administering its responsibilities under CWA §404. For example,
under §404, EPA has regulatory responsibility for reviewing permits for the discharge
of dredge or fill materials into waters of the United States, including wetlands. The
presence of high-priority ground water resources could be a consideration in review of
these permits. Also under §404, EPA participates in Advance Identification (ADID)
studies to identify waters as possible disposal sites and to identify areas that are likely
to be unsuitable for disposal. The results of these studies provide the public and
regulated community with an indication of whether a §404 permit will likely be
received. Recently, in Bucks County, Pennsylvania, ground water withdrawal and its
impact on local water quality was identified as one of the key factors that prompted an
ADID.

Ground water protection also can be enhanced by identification and protection
of wetlands that recharge and protect ground water. For example, if such wetlands
are identified as part of the CSGWPP, their characteristics will-be known for wellhead
protection programs.




1-32


1-18

SUPERFUND PROGRAM (continued)
Coordination with Other Programs

Superfund remedial actions are required to comply with (or justify a waiver of)
applicable or relevant and appropriate requirements (ARARs) of State environmental
laws that are promulgated, timely identified, and consistently applied in similar
situations. ARARs pertinent to ground water remedial actions include standards
established by various State and Federal environmental statutes. Ground water
cleanup levels are determined for each Superfund site based on ARARs and/or on
acceptable human health and environmental risk levels for all potential exposure
pathways. ARARs and risk levels are determined for both current and reasonably
expected future use of the ground water. Other EPA programs, such as RCRA
Corrective Action, use a similar approach for setting cleanup levels for contaminated
ground water, Under the CSGWPP approach, current and reasonably expected uses
would be determined by a State and would be consistently applied to all State and
Federal programs. Where a CSGWPP is in place, the Superfund program may
provide flexibility to focus more intensive long-term remedial efforts at sites where
ground water is more highly valued by the State and less intensive efforts (i.e., longer

- restoration time periods) in other areas.

Coordinating Grants

A State or Indian Tribe may enter into a Core Program Cooperative Agreement
to build and enhance its capabilities to respond to uncontrolled hazardous substance
sites and to promote more effective State participation in the Superfund program, The
Core Program focuses on assisting a State to develop its ability to support or
implement emergency and long-term response under the Superfund program. The
Core Program Cooperative Agreement may enable EPA Regional Offices to fund
appropriate ground water tasks that contribute to the recipients ability to implement
Superfund and also are useful to comprehensive ground water management in a
State. Examples might include development of ground water sampling protocols or
design of risk assessment criteria and procedures, and other similar components that
also could support a framework for a CSGWPP.


1-24

PUBLIC WATER SUPPLY SUPERVISION PROGRAM (continued)
Coordination with Other Programs

Given the high priority of protecting PWS under a CSGWPP, a State's PWSS
Program will benefit significantly from the CSGWPP's objective of coordinating and
targeting the numerous ground water protection efforts of federal, State, and local
programs. Coupled with Wellhead Protection Programs, the source inventory and
characterization efforts of numerous source-specific programs (e.g., UIC, UST,
Pesticides SMPs, NPS, etc.) should assist the PWSS Program in determining the
"vulnerability" or susceptibility of water supply systems to different potential
contaminants. Furthermore, these programs should significantly assist the PWSS
Program in achieving permanent solutions to contamination by focusing on preventing
or mitigating source water contamination rather than often costly treatment by
individual PWS systems.

_ In addition to receiving benefits from the CSGWPP approach, the PWSS
Program has much to add. For example, the ability of the PWSS Program to take civil
action on an emergency basis to address contamination of underground sources of
drinking water (Section 1431 of SDWA) should be integrated under the :
Comprehensive Program approach with other programs’ regulatory and non-
regulatory efforts to provide a broader array of tools to address ground water
concerns.

Also, under a CSGWPP coordination objective, the monitoring data collected by
PWS systems should be integrated with other programs’ information (e.g., source
inventory and characterization data) to derive better understanding of the
environmental fate and movement of contaminants. Greater accessibility of
environmental data across programs also would allow vuinerability assessments to be
done by automated processes rather than-solely by expensive field investigations,
facilitating the issuance of monitoring waivers. In addition, some States would not be
able to support a waiver program without a coordinated information program
mechanism in place to increase confidence in waivers.

Finally, the PWSS laboratory certification programs should be better
coordinated, under the CSGWPP approach, with other programs’ monitoring efforts to
help ensure more accurate information across all ground water-related programs.


1-20


1-33

COASTAL ZONE MANAGEMENT PROGRAM
Resource-Based Priority Setting In Decision Making

The Costal Zone Management Act (CZMA) authorizes and supports State
programs for protecting the Nation’s coastal waters. Amendments to the CZMA in
1990 established a significant initiative to control non-point source pollution to coastal
areas. Each State with a federally approved Coastal Zone Management Program
must submit a Coastal Nonpoint Program containing the following: 1) provisions for
implementing management measures to protect coastal waters; 2) identification of
land uses which may cause or contribute significantly to coastal waters degradation;
3) identification of critical coastal areas adjacent to coastal waters which. are impaired
or threatened by NPS pollution; 4) provisions for implementing additional management
measures for land uses or critical coastal areas as necessary to achieve and maintain
water quality standards; 5) programs to provide technical assistance to local
governments and the public; 6) public participation opportunities in all aspects of the
program; 7) modification of coastal zone boundaries as necessary to implement
NOAA's recommendations; .and 8) enforceable policies and mechanisms to implement
the management measures. EPA plays a critical role in this initiative by having the
‘responsibility to develop guidance specifying management measures for controlling
the various nonpoint sources in coastal areas. In addition, both EPA and the National
Oceanic and Atmospheric Administration (NOAA) must approve State Coastal
Nonpoint Programs.

CSGWPPs have a primary function of identifying ground waters of high use,
value, and vulnerability, which would include those ground waters that are closely
hydrogeologicaily linked to coastal waters and which are capable of carrying
contaminants to sensitive coastal waters. The Comprehensive Program can assist
State Coastal Nonpoint Programs by identifying where ground waters play a
significant role in coastal waters protection.

Coordination with Other Programs

Strong potential linkage exists between State Coastal Nonpoint Programs and
CSGWPPs. For exampie, in many coastal areas, which include estuaries, ground
water nutrient contribution (especially nitrogen) is contributing significantly to
eutrophication problems of coastal waters. Sources of this ground water
contamination can include septic tanks from coastal developments or fertilizer use in
agricultural areas adjacent to coastal land. .

The CSGWPP can also assist in coordinating a number of other EPA programs
(e.g., RCRA, CERCLA, Pesticides) to reduce coastal water impacts from toxic
chemicals by protecting, as a priority, ground water closely linked to coastal waters.


1-15

UNDERGROUND STORAGE TANK PROGRAM
Resource-Based Priority Setting in Decision-Making

Under EPA’s UST Program, minimum federal standards are set and a State is
allowed to be more stringent or different if the State’s program is no less stringent and
provides for adequate enforcement of compliance. Because the program’s size often
overwhelms the. ability of the States to staff the program, EPA encourages States to
implement UST programs and achieve compliance through a variety of State-specific
management measures and mechanisms.

The UST program offers States flexibility in the following ways:

e The UST program encourages States to set enforcement priorities and
do multimedia enforcement.

e The federal UST program defines minimum standards and allows States
to set more stringent or different (but no less stringent) standards for
prevention and detection of releases from USTs, for site
characterizations, soil and ground water cleanup investigations, and
remedial action for releases from USTs. :

Maximum flexibility is realized when a State is authorized to implement its UST
in lieu of the federal program. To be approved, the State must demonstrate that it has
additional funding sources, adequate staff, authorities that are no less stringent than
the federal UST program in scope and regulation, and capacity and willingness to
enforce the program.

The ground water assessment and characterization efforts carried out under the
priority setting Strategic Activity of a CSGWPP will help a State better determine its
UST program priorities in regard to inspection and enforcement actions and program
resource allocations. Information provided by the CSGWPP approach on the relative
use and value of ground water resources also will assist in UST program decision-
making regarding cleanup investigations and corrective actions.

Coordination with Other Programs

Because the UST program seeks to regulate potential sources of ground water
contamination (i.e., underground storage tanks), there are several specific links
between a State’s UST program and its CSGWPP. For example, the UST program
requires all UST owners to notify the State of existing underground storage tanks.
This inventory will assist the States in cataloging and assessing one potential source
of contamination. :


1-7

PESTICIDES STATE MANAGEMENT PLAN (SMP) PROGRAM (continued)
Coordination with Other Programs

Examples of how CSGWPPs will contribute to coordinating or promoting
consistency between key activities of SMPs and other ground water-related programs
include:

e Coordination and priority-setting under CSGWPPs will promote better
integration of the regulatory and non-regulatory prevention measures
called for by an SMP, such as those available under FIFRA and the
CWA's Nonpoint Source Program, as well as needed monitoring
information, available from a number of programs.

e CSGWPP efforts to define roles, responsibilities, and coordinating
mechanisms will further clarify and build on foundations laid under SMPs
to define roles, and promote coordination between agricultural agencies
with primary pesticides management responsibilities and water,
environmental, or health agencies with primary ground water resource
responsibilities.

e Efforts under CSGWPPs to promote State legal authorities and to form
coordinated enforcement strategies for ground water protection will also
strengthen legal and enforcement capacity to protect ground water from
pesticides.

e Coordination mechanisms developed under CSGWPPs should establish
links at the State level to other federal agencies with ground water
protection responsibilities. These links should facilitate the targeting of
non-EPA federal water quality projects to address a State’s SMP
priorities.

Coordinating Grants

CSGWPPs will help coordinate CWA, SDWA, CERCLA, and RCRA, as well as
FIFRA funding for activities that will help meet the adequacy criteria of both CSGWPPs
and SMPs. For example, money from §106 of the CWA could support State efforts to
assess and identify the areas most vulnerable to ground water contamination by
pesticides as a basis for establishing priorities for protection. FIFRA funding would be
available for tailoring pesticides management practices to certain critical areas and for


1-30


1-27

NPDES AND INDUSTRIAL PRETREATMENT PROGRAM
Resource-Based Priority Setting in Decision Making

Under the Clean Water Act, EPA and the States regulate facilities that either
discharge wastewaters directly to surface waters or discharge to municipal wastewater
treatment systems. Direct discharges are covered under the National Pollutant
Discharge Elimination System (NPDES), whereas industrial discharges to municipal
treatment systems are covered by pretreatment requirements. The primary objective
of these regulatory programs is to ensure the attainment of the "designated uses"
(e.g., fishable, swimable) of receiving surface waters.

While a number of States have incorporated ground water discharges into their
NPDES permits and pretreatment requirements, there is no national requirement to do
so. States might consider surface water recharge to valuable ground waters as a
designated use for surface water and issue specific NPDES permit requirements
designed to assure attainment of that designated use and, thereby, indirectly protect
inter-connected high priority ground waters. States could use the resource
assessment, source evaluation and priority setting mechanism of CSGWPPs to identify
high-priority ground waters that are subject to contamination from closely
hydrologically connected surface waters.

Coordination with Other Programs

CSGWPPs can provide a central coordination point for surface water regulators
to coordinate with ground water officials from a wide variety of ground water-related
programs. For example, a number of facilities with required NPDES or pretreatment
permits for surface water protection are also likely to be subject to future RCRA D and
SDWA Underground Injection Control Class V Well requirements. The CSGWPP can
help a State make integrated environmental management decisions across both
ground and: surface waters. in other words, States can use their ground water
protection authorities in conjunction with the NPDES permitting process to ensure that
specific requirements in NPDES permits do not result in unintended contamination of
sensitive ground water from practices such as the use of surface impoundments.




1-3

WELLHEAD PROTECTION PROGRAM
Resource-Based Priority Setting in Decision-Making

An EPA-approved State Wellhead Protection (WHP) Program will be a required
and integral part of the Fully-Integrating CSGWPP. A CSGWPP will emphasize that
wellhead protection areas, recharge areas, and basins of drinking water aquifers are
to be afforded extra management focus across all programs within the CSGWPP
framework.

In addition to being an integral part of the priority-setting portion of the
CSGWPP, wellhead protection programs will benefit by other activities that make up a
CSGWPP. For.example, characterization and mapping will aid in delineating actual
wellhead protection areas and recharge zones.

Coordination with Other Programs

Many programs use the wellhead protection areas to identify areas of priority
concern. USDA's Conservation Reserve Program, for example, provides incentives to
farmers not to conduct practices that may impact ground water in sensitive areas.
Other programs use wellhead protection areas as a tool in program management
schemes, such as the Public Water Supply (PWS) Supervision Program for
vulnerability assessments and sanitary surveys. The vulnerability assessment
completed under a WHP Program will meet the requirement of the PWS Program as a
first step for a PWS to apply to the State to waive monitoring. The CSGWPP will
become the vehicle to further demonstrate the utility of State WHP Programs and
ensure that WHP-related activities are carried out consistently across programs.

Coordinating Grants

To date, grant funding under the Safe Drinking Water Act for State Wellhead
Protection Programs has not been appropriated. However, State ground water
assessment and characterization activities and other wellhead protection activities are
supported by EPA with CWA §106 grants, and wallhead protection is referenced as a
viable and valuable activity in the grant guidances of other EPA ground water-related
programs (e.g., CWA §319 and RCRA). Within the CSGWPP framework, all of these
grants would be coordinated so that the maximum number of wellhead protection
areas are established.


1-16

UNDERGROUND STORAGE TANK PROGRAM (continued)

A number of facilities and operations with underground storage tanks may also
be subject to requirements by other ground water-related programs, such as SDWA
underground injection controls or RCRA hazardous waste or solid waste management.
The CSGWPP will provide a management focal point for a State to establish more
coordinated inspections and enforcement schemes across ground water-related
programs. Presently many States’ UST programs barely have enough personnel to
meet their enforcement needs. Through the integration provided by the CSGWPP,
State personne! from other programs may be trained to look for UST violations or to
take enforcement actions.

Facilities with underground storage tanks often are located in an area where
ground water remediation efforts are being considered. Knowledge of the presence of
underground storage tanks in such areas may be crucial information in determining
the source and responsibility for an area’s contamination and means for successful
remediation. Under the UST program, owners are required to notify the State of
existing underground storage tanks. Inclusion of such information in the CSGWPP.
strategic activity of coordinated ground water data bases within the State could greatly
assist other programs’ field personnel in determining appropriate actions.

Coordinating Grants

The federal UST program provides grants to States to prevent, detect, and
correct leaks from underground storage tanks containing petroleum and other
hazardous substances. As a result, UST grant funding, which supports the
development and implementation of an UST regulatory program, also can support the
following corresponding CSGWPP activities: identifying sources of contamination;
establishing a comprehensive remediation program that sets priorities according to
risk; defining federal, State, and local enforcement authorities; conducting monitoring,
data collection, and data analysis; and improving public participation.


CSGWPP Strategic Activities

Establish a Common Ground Water

Protaction Goal Across
ail Relevant Programs

SMP Components

Establish Priorities, Based on
Characterization of the Resource,
Identification of Sources of Contamination,
and Programmatic Needs to Direct

State's Philosophy and Goal

all Relevant Programs and Activities

Define Roies, Authorities, Responsibilites,
Resources, and Coordinating Mechanisms
for Addressing Identified Priorities |

Implement Necessary Activities to
Accomplish the State's Goal
Consistent with State Priorities
and Schedules

Conduct Information Collection and
Management to Measure Progress,

Re-evaluate Priorities, and Support
all Related Programs

Improve Public Education and

Participation in all Aspects of
Ground Water Protection

Basis for Assessment and Planning

Roles and Responsibilities of State Agencies

Logal Authority

Prevention Actions

Response to Detections

Enforcement Mechanisms.

Records and Reporting

Information Dissemination

Public Awareness and Participation

Figure ll-1. Relation of the Six Strategic Activities of a CSGWPP to the
12 Components of a Pesticides State Management Plan.



1-22

4

UNDERGROUND INJECTION CONTROL PROGRAM (continued)
Coordinating Grants

States can use UIC grants for activities such as mapping, inventorying, and
data management. For these activities, grant guidances among all programs allowing
funds to be used for these purposes could be coordinated to insure synergies and to
reduce unnecessary duplication among programs.




1-9

SOLE SOURCE AQUIFER PROTECTION PROGRAM
Resource-Based Priority Setting In Decision-Making

The Sole Source Aquifer (SSA) Protection Program is a resource-oriented
ground water contamination prevention program. It is one of many tools that should
be utilized in a CSGWPP to increase public awareness of the value of ground water as
a resource and to prevent contamination from federal financially-assisted projects.

The SSA Protection Program's objectives and activities correspond to the
Strategic Activities of a Comprehensive Program. Common management measures in
both programs include resource assessment, identification of important resources for
setting priorities, development of management options, and involvement of State and
local governments.

The CSGWPP approach should provide the framework for increased State
participation and improved EPA decision-making in determining priority SSA
designations and project reviews. State and local prevention, control, and remediation
efforts within SSA designated areas should be prioritized and managed through a
~CSGWPP.

Coordination with Other Programs

Under coordination efforts of a CSGWPP, SSA protection activities should
significantly support the development and implementation of other ground water-
related programs in the following ways:

e Contributes valuable aquifer characterization and assessment information
to assist States in setting priorities;

e Assists States in establishing priority ground water protection areas
based on use and value of the resource;

e Implements a pollution prevention program for reducing or eliminating
pollution in SSA areas;

e Uses a broad range of education, voluntary, and regulatory techniques
to protect the resource; and

e Provides opportunities for monitoring, data collection and data analysis
of the nature and quality of ground water.


1-8

PESTICIDES STATE MANAGEMENT PLAN (SMP) PROGRAM (continued)

outreach to the agricultural community. State agriculture agencies would work with
State water quality agencies to utilize their expertise and facilities for monitoring,
assessments of aquifer sensitivity, data management, and other activities necessary
for SMP development. Under the CSGWPP approach, SDWA funding of PWSS
monitoring, enforcement, and vuinerability assessments could also be coordinated to
provide significant information to a State for developing and improving its SMP.
Finally, the coordination mechanisms developed under CSGWPPs also have the
potential to facilitate the targeting of grants from other federal agencies, such as
USDA, to support SMP activities or to get the State agencies involved in SMP
implementation in the selection of federally-funded water quality projects.


1-44

WATERSHED PROTECTION APPROACH
Resource-Based Priority Setting in Decision Making

The Watershed Protection Approach is a resource-oriented framework
supported by EPA for focusing and integrating current efforts and for exploring
innovative methods to achieve miaximum efficiency and effectiveness in water quality
protection. The term watershed refers to a geographic area in whith water,
sediments, and dissolved materials drain to a common outlet -- a point on a larger
stream, a lake, an underlying aquifer, an estuary, or an ocean. An aquifer or part of
an aquifer, such as a wellhead protection area, can be a watershed. The Watershed
Protection Approach is not a new "program," but an effort to target appropriate tools
and resources from existing programs to the needs within a particular watershed. The
Watershed Protection Approach is built on three main principles: risk-based
geographic targeting, stakeholder involvement, and integrated solutions. Presently a
number of state projects and programs using the Watershed Protection Approach
have been implemented.

The ground water assessment and characterization efforts carried out under the
priority setting Strategic Activity of a CSGWPP provide a framework for States to target
aquifers or portions of aquifers for the Watershed Protection Approach. In addition,
watershed efforts aimed at surface water protection can benefit from information
developed under a CSGWPP on those ground waters that are closely :
hydrogeologically linked to the targeted surface waters. Such information will assist in
determining the influence of ground waters on these watershed protection areas.

Coordination with Other Programs

Both the Watershed Protection Approach and CSGWPP are intended to focus
the efforts of several programs on protection of high-priority water bodies. CSGWPPs
should be considered as an important tool in the Watershed Protection Approach.
CSGWPPs will focus those programs with primary ground water protection
responsibilities on protection of important watershed areas, whether they are aquifers, ©
portions of aquifers, or surface water bodies that are closely hydrologically linked to
ground waters.

The 1992 Agency Operating Guidance states that EPA will focus actual
protection and restoration activities in specific watersheds, and several programs have
recognized the importance of a watershed approach in their guidance documents.
This emphasis will be compatible with and supportive of CSGWPP implementation
efforts. For example, in the Region 3 Mill Creek Pequea Creek Watershed, nonpoint
source resources have been made available to farmers to implement BMPs to reduce
nutrient, bacteria, and pesticide contamination of surface waters.and ground water.


1-29

STORM WATER PROGRAM
Resource-Based Priority Setting in Decision Making

Industiral storm water discharges to surface waters and discharges from
municipal separate storm sewer systems serving populations greater than 250,000,
are regulated through National Pollutant Discharge Elimination System (NPDES)
permits. Storm water management can affect ground water in a number of ways --
some storm water management practices may be designed to recharge ground water
in urban areas as an important means for water supply storage; other storm water
controls focus on pollution prevention controls which reduce risks to both surface and
ground water; and in some industrial and agricultural situations, storm water collection
devices or best management practices (BMPs) may transfer contaminants to
underlying ground waters. In any of these cases, this water may eventually re-enter
the surface water again as ground water discharges to streams and lakes.

Given the possible inter-connection between storm water management and
ground water, it is important to consider potential ground water impacts, particularly
where this underlying resource is highly valuable or closely hydrogeologically linked to
surface water quality. To address the potential for ground water contamination, storm
water BMPs should be developed to reflect States’ CSGWPP resource protection
objectives and.priorities.

Coordination with Other Programs

Coordination within the CSGWPP framework among the NPDES program, UIC
Class V program, the NPS program, and the Wellhead Protection Program will help
focus efforts to manage cross-media impacts and avoid having major national
programs working at cross-purposes within the State.


1-28


1-5

PESTICIDES STATE MANAGEMENT PLAN (SMP) PROGRAM
Resource-Based Priority Setting In Decision-Making

EPA's Pesticides and Ground-Water Strategy released in October 1991 offers
States the flexibility to continue the use of a pesticide that EPA would otherwise cancel
due to ground water contamination concerns. States will gain this flexibility by
developing and implementing State Management Plans (SMPs), which are designed to
ensure that each State can sufficiently manage, control, and enforce pesticide use to
protect valuable and vuinerable ground water. EPA will coordinate its efforts with
USDA and with State agricultural agencies to alleviate redundancies and ensure
consistent regulatory requirements.

Figure Il-1 demonstrates that the specific components and adequacy criteria of
a Pesticide SMP are closely aligned with those of a CSGWPP. This close alignment
means that implementation of a Generic Pesticide SMP" will meet the general
condition of many of the adequacy criteria for a Core CSGWPP that the State’s
intended comprehensive approach be adopted or implemented by at least one
operating program within the State.” Obviously, however, a Pesticide SMP, even at
the Generic level, will require more specificity on pesticide management measures
than would be found in a CSGWPP. An SMP should be viewed as a more program-
specific version of the more general, but broader scope CSGWPP.

The Pesticide SMP approach fully adopts the Agency's overall ground water
protection goal and the tiered hierarchy of preferred protection objectives outlined in
this CSGWPP Guidance. Under an SMP, States are encouraged to pursue prevention
of ground water contamination whenever possible. However, protection of the
nation’s currently and reasonably expected sources of drinking water supplies, both
public and private, is a required SMP priority. Further, ground water that is closely
hydrologically connected to surface water must receive priority protection to ensure
the integrity of associated ecosystems.

‘According to EPA's draft Pesticide SMP Guidance, a Generic SMP is the State's primary source
document which provides the overarching policies and approaches from which Pesticide-Specific
SMPs will be derived, if necessary, to address unique concerns for individuals pesticides.

2A State needs to demonstrate, however, that its comprehensive approaches are intended to
eventually encompass ali ground water protection programs within the State.


1-19

OIL POLLUTION ACT
Resource-Based Priority Setting in Decision Making

The Oil Pollution Act of 1990 (OPA) provides EPA (and the Coast Guard) with
expanded authorities to address discharges of oil that pose substantial threats to
public health or welfare and natural resources. Section 311 of the Clean Water Act,
which is implemented through the National Contingency Plan like CERCLA, empowers
EPA to arrange for the removal of oil discharges or to mitigate or prevent the
substantial threat of the discharge that threatens public health or welfare.

A comprehensive assessment of a State's ground water resource carried out as
part of a CSGWPP will support speedy and effective actions under Section 311 by
better identifying the ground waters, and surface waters closely hydrogeologically
connected to ground waters, that could be affected by a discharge of oil, and by
identifying reasonably expected sources of drinking water that could be threatened.
This will help to determine when removal actions are necessary.

Coordination with Other Programs

The ARARs pertinent to removal actions involving oil discharges into ground
water that threaten surface waters will, under the CSGWPP approach, be based on an
understanding of the ground water resource and its use, value, and vulnerability that is
common to all programs in the State.


1-36


1-37

RADIATION PROGRAM
Resource-Based Priority Setting in Decision Making

EPA is responsible for development of federal guidance on radiation protection
and promulgates standards and regulations for exposure to radionuclides. In
particular, EPA provides support to States in radiation monitoring, research, training,
and other forms of technical assistance; develops standards for cleanup,
management, and disposal of uranium and thorium mill tailings and high-level, low-
tevel, and transuranic radioactive wastes; and assists in the promulgation of standards
for the control of radionuclides in drinking waters and in all types of wastes. EPA's
standards cover activities of other federal agencies, including DOE and DoD, and
activities regulated by NRC.

Resource assessment, source evaluation, and priority setting mechanisms
developed through CSGWPPs should be used by States and other federal agencies
to implement the ground water protection and remediation standards contained in
EPA regulations involving radionuclides. For example, EPA regulations in 40 CFR Part
192 on uranium tailings management at active uranium processing facilities call for
evaluation of the hydrogeology of the site, including determination of background

" ground water quality, rate and direction of migration of contaminated ground water,
and extent of the contamination. The regulation calls for remedial action decisions to
be made on a case-by-case basis, taking into account, among other things, present
and future use of the aquifer and the degree to which human exposure is likely to
occur. NRC implements requirements for active uranium processing sites that
incorporate ground water protection standards that are comparable to requirements
developed under RCRA Subtitle C. A comprehensive characterization and
assessment of the resource will facilitate decision-making affecting ground water for
such sites.

Coordination with Other Programs

Regulatory authority over some possession and use of radionuclides, with
some exceptions, such as commercial nuclear power reactors and high level
radioactive waste disposal facilities, has been relinquished by agreement between the
Nuclear Regulatory Commission and the States to over half the States (Agreement
States). In such States, siting of facilities involving radionuclides and design and
operational requirements established by facility licenses are controlled and directed by
the States. In States where NRC retains primacy, regulatory limits for some types of
licensed nuclear facilities (e.g., uranium mill tailings impoundments) set specific design
and operational criteria for licensed facilities to protect ground water and maximum
limits are established for ground water contamination. Facilities in Agreement and
non-Agreement States are subject to standards issued by EPA under the Uranium Mill
Tailings Radiation Control Act and the Atomic Energy Act and implemented by
Agreement States or by NRC in non-Agreement States. Implementation of a CSGWPP
will enable States to begin to coordinate implementation of such standards and


1-25

NONPOINT SOURCE PROGRAM
Resource-Based Priority Setting in Decision Making

Authorized under §319 of the CWA, the Nonpoint Source (NPS) Program
provides grant funds for implementing control activities and institution-building
activities based on a State's federally-approved NPS Assessment and Management
Program. The program focuses on both ground water and surface water, with a
minimum of 10 percent of the grants going for ground water-related activities. On
average, the States devote more than 10 percent, with 30 percent going towards
ground water-related funding in FY 91.

A State must have an EPA-approved NPS Management Program to be eligible
to receive NPS grants. Section 319 requires State NPS Management Programs to
identify, among other things, best management practices and measures to be
implemented to reduce NPS pollutant loadings, to set up a schedule for implementing
the measures, and to define authorities. Only priority ground water protection
activities identified in an approved management plan are eligible for §319 grant
funding, either by direct identification in the NPS Management Plan or by reference to
the CSGWPP. Therefore, the ground water protection priorities established by a
CSGWPP should have a direct link to the priorities of the State's NPS Program. This
link should focus §319 NPS efforts on the most valuable and vulnerable ground
waters.

Coordination with Other Programs

Because CSGWPPs require that States define roles and coordination points
between and among ground water-related programs, the CSGWPP will provide a
means by which the NPS program will have information about all of the other ground
water-related programs. This should decrease unnecessary duplication and increase
efficiency in the §319 program. For example, coordination afforded by a CSGWPP
should promote better integration of NPS prevention activities and prevention
measures under EPA's Pesticide State Management Plan (SMP) approach for
protecting ground water from pesticides contamination. Integration between the NPS
Management Program's requirements and those of upcoming Underground Injection
Control (UIC) Class V regulations and guidance, particularly for agricultural drainage
wells, can also be facilitated by the CSGWPP approach. At a minimum, a CSGWPP
should ensure that these major national programs are not working at cross-purposes
within the State.

Coordinating Grants
The bulk of §319 grants must be used for implementing NPS control activities

for either surface water or ground water quality concerns. Considerable and wide-
ranging ground water protection efforts have been undertaken through these NPS


1. LINKAGE TO EPA PROGRAMS

This section provides a program-by-program discussion of the linkages
between the CSGWPP approach and each EPA program that potentially affects
ground water. For each program, a brief description of how CSGWPP-supported
resource-based decision-making would benefit the program is provided. For most
programs, this is followed by a discussion of how the CSGWPP affords greater
beneficial coordination to the program. Finally, for programs that provide grants to
States, a brief discussion of how those grants can be used in a coordinated fashion to
support the development and implementation of CSGWPP follows. The material
described below is not meant to take the place of any specific program guidance or
regulation, and, where seeming discrepancies might exist, the information in the most
current program-specific guidance or regulation must prevail. EPA is in an on-going
process to align and update all of its programs related to ground water protection with
the CSGWPP approach.


1-44

POLLUTION PREVENTION PROGRAM (continued)

conducting public education and outreach. Grants may also be used to initiate
demonstration projects that test and support innovative pollution prevention
approaches and methodologies which may eventually be integrated into prevention
programs.


1-42


1-12

RCRA SUBTITLE C PROGRAM (continued)

the RCRA grants should be coordinated with funds from a variety of programs. The
CSGWPP supplies the coordinating framework which ensures that no unnecessary
duplication of effort exists across programs, thus assuring that grants from RCRA and
all other programs provide maximum overall benefit.


1-14

RCRA SUBTITLE D PROGRAM (continued)

Coordinating Grants

Grants given to States to develop an understanding of the characteristics of
their ground water will be coordinated with grants from other programs so that
duplication is avoided when a State implements certain functions such as monitoring.
(See also the discussion under RCRA Subtitle C.) ‘


PART II:

SECTION 1:

SECTION 2:

TABLE OF CONTENTS

Page
LINKAGE TO EPA AND OTHER FEDERAL PROGRAMS
LINKAGE TO EPA PROGRAMS .......... sence eens 1-1
Wellhead Protection Program ...........0. cece eeeeee 1-3
Pesticides State Management Plan (SMP) Program . see e eee 1-5
Sole Source Aquifer Protection Program ................ 1-9
RCRA Subtitle C Program ........ 0... cece ee eee eee 1-11
RCRA Subtitle D Program .......... 00 cece eee eee 1-13
Underground Storage Tank Program ............0-.-005 1-15
Superfund Program ......... 00 cee reece cece eee ennnes 1-17
Oil Pollution Act 0.0... ccc cece te eee e reece nnes 1-19
Underground Injection Control Program ............000. 1-21
Public Water Supply Supervision Program .............. 1-23
Nonpoint Source Program .......... 0c cece eee eens 1-25
NPDES and Industrial Pretreatment Program........... 1-27
Storm Water Program .........0. 0c cece erect e ee eeee 1-29
Sewage Sludge Program ........ ccc een eee e rere eens 1-31
Coastal Zone Management Program ...........:en eens 1-33
Toxic Substances Control Program ........... 2002 e eens 1-35
Radiation Program ........ 0. cece eee eee tenes 1-37
Wetlands Program ........ 0 eee e ete e eect tere ttnees 1-39
Watershed Protection Approach seen e ee eee etre tees 1-41
Pollution Prevention Program .............0seeeneeeee 1-43
LINKAGE TO OTHER FEDERAL AGENCY
PROGRAMS .......... 2c eee eens cece eee eens 2-1
United States Department of Agriculture ................ 2-3
United States Department of Defense .................. 2-9
United States Department of Energy ..............000ee 2-13
United States Department of the Interior ................ _ 2-17
United States Department of Transportation ............. 2-23

United States Nuclear Regulatory Commission ........... 2-27


1-35

TOXIC SUBSTANCES CONTROL PROGRAM

Resource-Based Priority Setting in Decision Making

EPA is interested in applying its capabilities and authorities under the Toxic
Substances Control Act to address local environmental needs and problems.
CSGWPP priorities provide an immediate context in which EPA and States can test the
geographically-specific applications of certain TSCA authorities. Presently, a number
of TSCA authorities can support the Strategic. Activities of a CSGWPP, including:

EPA toxicity determinations, exposure determinations, and risk
assessment capabilities under TSCA could support CSGWPP priority-
setting. For example, various EPA capabilities, such as testing
authorities, Graphic Exposure Modeling Systems, and others, could
provide information to assist States in identifying risk-based geographic
priorities for ground water protection and in establishing ground water
protection priorities across contamination sources.

EPA risk reduction decision-making capabilities could.support the
pollution prevention components of a CSGWPP. EPA could perform
Substitute Analyses, Cost/Benefit Analyses, and Pollution Prevention
Technical assessments to assist with States’ efforts to reduce or
eliminate potential environmental! releases that may adversely affect
ground water quality. These EPA capabilities could be directed towards
differential management of ground water under a State’s CSGWPP by
focusing on activities that are located in geographic proximity to the
State's most valuable and vulnerable ground waters. These capabilities
could also be used to assist a State in implementing pollution prevention
priorities across sources.

EPA risk management capabilities could also be used to support
CSGWPP contaminant control efforts. TSCA Section 6(a) provides EPA
with the authority to regulate chemicals that present an unreasonable risk
of injury to human health or the environment. EPA could use this
authority to address chemicals of concern in targeted geographic areas
which encompass a State's high priority ground waters. TSCA Section
6(a) offers a wide range of possible actions to prevent pollution from
prohibiting the manufacture, sale, or use of a chemical to recordkeeping
and labeling requirements which could be selectively applied in specific
geographic areas to protect high priority ground waters.

At this time, EPA's efforts to apply TSCA capabilities to local problems will take
the form of pilot projects. States need to work with EPA Regional Offices to identify
opportunities within the CSGWPP framework which would test the TSCA approach.


1-23

PUBLIC WATER SUPPLY SUPERVISION PROGRAM

Resource-Based Priority Setting In Decision-Making

The protection of public water supplies (PWS) is a high priority for
Comprehensive Programs. This is evident by the CSGWPP adequacy criteria requiring:
implementation of an EPA-approved State Wellhead Protection Program (WHP) for a
Fully-Integrating CSGWPP. A State's WHP, coupled with other CSGWPP efforts, will
provide information on the “vuinerability" or susceptibility of source waters of individual
PWS systems to contamination. Under the Public Water Supply System Program,
States have the flexibility within the Program to:

(1)

(2)

(3)

(4)

(5)

(6)

Work toward flexible federal monitoring requirements for individual water
supply systems with less burdensome PWS monitoring requirements;

Offer water suppliers opportunities for obtaining waivers from monitoring
requirements for certain contaminants, if their systems are not vulnerable
to contamination;

Use PWSS enforcement actions to support development and
implementation of local wellhead protection programs. CSGWPPs can
provide data and information upon which to initiate enforcement actions,
(i.e, SDWA §1431 emergency orders);

Allow more flexibility in the application of the “timely and appropriate"
enforcement criteria for violations of the SDWA, particularly PWSs that
are in significant noncompliance SNC, if a State can demonstrate that an
enforcement action, based on data fram a wellhead protection program
or other ground water activities, can appropriately address and mitigate
the violations; ~

Set the phase in schedule (beginning in 1993) for monitoring under the
new "standardized monitoring framework," implementing a three year
compliance period. Setting priorities for targeting wnen systems would
be phased in may be based in part on the use, value, vulnerability of
ground waters and extent of data available. Making determinations
using these factors would be greatly enhanced by the coordination —
achieved and data developed under a CSGWPP; and

Enhance Sanitary surveys where use of wellhead protection area
delineations and contaminant source surveys, pesticide application
information and a pesticide management plan, and other information
could be used.


Part Il:
LINKAGE TO EPA AND OTHER FEDERAL
AGENCY PROGRAMS



1-31

SEWAGE SLUDGE PROGRAM
Resource-Based Priority Setting In Decision Making

Requirements to: protect public health and the environment from the adverse
effects of pollutants that may be contained in sewage sludge are authorized by
Section 405 of the Clean Water Act. The CWA Sewage Sludge Program has :
proposed regulations for the final use and disposal of sewage sludge. Requirements
already exist under RCRA for sewage sludge that is determined to be hazardous.
Sludge determined to be hazardous under RCRA must be managed in RCRA Subtitle
C facilities. Sludge disposed in municipal solid waste landfills, which frequently receive
sludge from POTWs, must be managed in facilities that satisfy the RCRA Subtitle D
regulatory requirements. Both the Subtitle C and D requirements include location
standards and ground water monitoring and remediation, if necessary. Some
commentators were concerned about possible duplicative regulation. The Sewage
Sludge Program and the RCRA Program will coordinate their efforts to alleviate
excessive duplication.

; Proposed rules on management of sludge under the CWA Sewage Sludge
Program in landfills limited to sewage sludge monofills are expected to set limits on
concentrations of certain pollutants in sludge placed in monofills so as not to exceed
ground water MCLs or contaminate an aquifer with nitrogen. Proposed rules on land
application of sludge are expected to include both management practices and national
pollutant limits, including pathogen requirements and limitations on the concentrations
of certain metals, Sludge application rates also should minimize the amount of
nitrogen that passes below the root zone to the ground water. A comprehensive
ground water assessment carried out under a CSGWPP will assist the implementation
of these requirements by ensuring accurate and timely information about the condition
of the ground water resources.

Coordination with Other Programs

The development of priorities through the CSGWPP process will help to
coordinate the sewage sludge program with other programs in the State in several
ways. Decisions about capacity and siting of RCRA Subtitle D facilities, for example,
will affect how sludge is managed. Similarly, decisions concerning discharges into
POTWs may affect whether sludge can be used in land application or must be
managed in RCRA Subtitle C facilities.


1-40


1-26

NONPOINT SOURCE PROGRAM (continued)

grants, including abandoned well plugging, agricultural drainage well siting and
closure, installment of best management practices in the field, and improved septic
tank maintenance. Many of these activities would meet the objectives of other EPA
programs (e.g., Coastal Nonpoint Programs, UIC, UST, Pesticides, RCRA). CSGWPP
coordination of the NPS efforts with the control efforts supported by other programs
will provide a vehicle for establishing and focusing joint efforts on highest ground

water priority concerns.

EPA's Section 319 grant guidance requires that at least 10% of a State's work
program be devoted to addressing priority ground water nonpoint source activities.
However, where the requisite information to establish State implementation priorities is
lacking, the State is encouraged to use Section 319 grants to further its assessment
and characterization of ground water resources and to establish a basis for identifying

. priority protection needs prior to undertaking any site-specific measures.




1-13

RCRA SUBTITLE D PROGRAM
Resource-Based Priority Setting in Decision Making

Under the Subtitle D program regulations on municipal landfill criteria, States
have the opportunity to adjust certain aspects of the EPA-promuigated standards
concerning landfill design, monitoring, siting and corrective action. To gain this
flexibility, States must have EPA-approved municipal solid waste landfill permitting
programs. When an approved State makes a site-specific permit decision on landfill
design or monitoring requirements, it may do so based, in part, on the relative
vulnerability of the ground water. For corrective action requirements, decisions can
be based, in part, on the underlying ground water's use, value, and vulnerability.
Assessment and characterization carried out under the strategic activities of the
CSGWPP can be used to help demonstrate to the EPA Regional Administrator that
their Municipal Waste Programs adequately incorporate Subtitle D federal guidelines.

Other Subtitle D programs for solid waste (e.g., mining, oil and gas, and
industrial wastes) are just beginning to be developed at this time. EPA expects these
Subtitle D industrial programs to incorporate the CSGWPP approach and allow States
to make decisions on aspects of landfill design, monitoring requirements, or corrective
action requirements based, in part, on the use, value, and vulnerability of the ground
water. ‘

Coordination with Other Programs

The RCRA Subtitle D program already has developed ground water monitoring
requirements for municipal solid waste landfills. These requirements allow the use of a
sampling and analysis program that accurately represents the ground water quality at
a particular site. A CSGWPP could ensure the development of a consistent monitoring
program applicable to both Subtitle D facilities and to other programs such as the
UST program that may affect ground water.

A number of industrial facilities and operations likely to be covered under future
RCRA Subtitle D regulations for industrial solid waste also will require NPDES permits
for surface water discharges, for sewage sludge facilities, or for industrial pretreatment
permits from POTWs and also may be subject to the SDWA Underground injection
Control Program, particularly Class V regulations. The CSGWPP will provide a
framework for better coordination of these programs to avoid cross-purposes in
objectives and approaches. EPA will also work to coordinate these regulatory
activities through the Agency's Ground Water Cluster.