APPENDIX D:

ACP:
ADID:
ARAR:
ARS:
ASCS:
BIA:
BLM:
BMP:

CERCLA:

CSRS:
CWA:
CZM:
CZMA:
DASD (E):
DERP:

" DNAPLs:
DoD:
DOE:
DOI:
DOT:

DSMOA:

Poe -

GLOSSARY OF ACRONYMS

USDA Agricultural Conservation Program
Advanced Identification (under CWA §404)
Applicable or relevant and appropriate requirement
USDA Agricultural Research Service

Agricultural Stabilization and Conservation Act

DOI Bureau of Indian Affairs

DOI Bureau of Land Management

Best management practice

Comprehensive Environmental Response, Compensation, and
Liability Act

USDA Cooperative State Research Service
Clean Water Act

Coastal Zone Management

Coastal Zone Management Act

DoD Deputy Assistant Secretary of Defense
DoD Defense Environmenta! Restoration Program
Dense non-aqueous phase liquids

US Department of Defense

US Department of Energy

US Department of the Interior

US Department of Transportation

DoD Defense and State Memoranda of Agreement


B-5
- Cost of prevention and remediation; and

- Inter-jurisdictional considerations (Tribes, federal government,
other States).

(3) EPA's Definition of "Reasonably Expected Uses of Ground Water."

In the absence of State definitions, EPA’s definitions of "Ground Water
Supporting Surface Water Ecosystems" and "A Reasonably Expected Source of
Drinking Water" will apply.

(a) | Ground Water Supporting Surface Water Ecosystems: EPA's
definition for ground water closely hydrologically connected to surface
water and supporting its ecosystems is ground water which, if its
availability or quality are affected, would result in surface water not
meeting the water quality standards required to support its designated
use. (This definition reflects the current state of information on ground
water - surface water interaction. This definition may change as more
information becomes available.)

(b) A Reasonably Expected Source of Drinking Water: EPA's definition
for a reasonably expected source of drinking water is ground water that
is available in sufficient quantity for its intended use and contains fewer
than 10,000 mg/l total dissolved solids. This definition derives from the
Safe Drinking Water Act, Part C - Protection of Underground Sources of
Drinking Water, Section 1421. EPA has developed this definition to be
as protective as possible of future ground water uses; however, EPA
recognizes that this definition may be more comprehensive than a State
may wish to be.

EPA's Assistance to States. EPA realizes that a State may find it useful to have
the benefit of EPA's views on how best to define ground water supporting surface
water ecosystems and ground water that is a reasonably expected source of drinking
water. To provide this guidance, EPA is developing a technical assistance document
on resource assessment.


A4

determine if their own protection goal is at least as stringent as EPA's -- as required
by CSGWPP adequacy criteria.

EPA's goa! also states that "in determining appropriate prevention and
protection strategies, EPA will also consider the use, value and vulnerability of the
resource, as well as social and economic values." Given the lessons learned over the
last several years (see Section 1.3) regarding the extensive use and high value of
ground water, its vulnerability to contamination, and the social and economic
consequences of such contamination, EPA will pursue the following three-tiered
hierarchy of preferred ground water protection objectives:

° Prevention of contamination whenever possible. In order to meet the
Agency's goal of preventing adverse effects to human health and the
environment and protecting environmental integrity, prevention of
contamination must be the first priority of the CSGWPP approach.

e Prevention of contamination based on the relative vulnerability of the
resource, and where necessary the ground water’s use and value.
While prevention of contamination whenever possible must be the first
priority of a CSGWPP, EPA also recognizes that basic human activity has
impacts on ground water. Prevention of all discharges to all ground
water is not possible. This should not be construed as allowing ground
waters to be "written-off." Rather, EPA believes that some level of
protection should be considered for all ground water resources.

Other factors may need to be taken into account when making ground
water protection decisions. The relative vulnerability! of the ground
water should help determine the level of source control measures
necessary to prevent contamination. As an additional preventive
measure, the relative use, value, and vulnerability of ground waters at
different locations should be considered in decisions regarding the siting
of facilities or activities. Also, due to limited government personnel and
financial resources, the relative use, value, and vulnerability of ground
waters should be key factors in setting priorities for day-to-day
operations of relevant programs (e.g. which permits to write first, which
inspections to do first, which clean-ups to begin first).

Finally, in some cases, EPA is required by statute to base regulation on
consideration of the risks and the benefits of activities that may pose

‘EPA defines ground water vulnerability as the relative ease with which a contaminant introduced into
the environment can migrate to an aquifer under a given set of management practices, contaminant
characteristics, and aquifer sensitivity conditions, Ground water vulnerability assessment methods assess

hydrogeologic characteristics, contaminant characteristics, and management practices related to
contaminants.


D-2
DSMOA: DoD Defense and State Memoranda of Agreement
ECAP: DoD Environmental Compliance Achievement Program
EM: DOE Office of Environmental Restoration and Waste Management
EPA: US Environmental Protection Agency
ERS: USDA Economic Research Service
ES: USDA Extension Service
FIFRA: Federal Insecticide, Fungicide and Rodenticide Act
FS: United States Forest Service
GOA: US General Accounting Office
GIS: Geographic Information System
HRS: Hazard Ranking System
HSWA: Hazardous and Solid Waste Amendments of 1984 to RCRA
|AGs: interagency Agreements
IHS: DO! Indian Health Service
IRP: DoD Installation Restoration Program
MCL: Maximum Contaminant Level
NAPLs: Non-aqueous phase liquids
NASS: USDA Agricultural Statistic Service
NEPA: National Environmental Protection Act
NOAA: National Oceanic and Atmospheric Administration
NPDES: National Pollutant Discharge Elimination System

NPL: National Priority List

NPS: Nonpoint Source


D-4

RFA: RCRA Facility Assessment

SARA: Superfund Amendments and Reauthorization Act

scs: USDA Soil Conservation Service

SDWA: Safe Drinking Water Act

SMCRA: Surface Mining Contro! and Reclamation Act of 1977

SMP: State Management Plan to prevent ground water contamination

from pesticides

SRPA: Smail Reclamation Projects Act

SNC: Significant noncompliance

SSA: Sole Source Aquifer

TDP: Technology Development Program
TSCA: Toxic Substances Control Act

UIC: Underground Injection Control
UMTRCA: Uranium Mill Tailings Radiation Control Act
USDA: United States Department of Agriculture
USGS: United States Geological Survey

UST: Underground Storage Tank

VOCs: Volatile Organic Compounds

WHP: Wellhead Protection

WAQIP: Water Quality Incentive Practices


C-3

As of October 15, 1992, a total of 96 comments had been received on the draft
guidance, primarily from the following groups:

e

State Agencies (64 from 44 States)
- Environmental (30)

- Health (9)

~ Agriculture (12)

- Natural Resources (13)
Business and Trade Groups (8)
Environmental Groups (2)

Local Governments (4)

Citizen Groups (1)

Federal Agencies (6)
Universities (1)

National Organizations of
State and Local
Governments (4)

EPA HQ Offices (4)

EPA Regions (13 from 8
Regions)

This guidance document represents a significant reexamination of the concepts
and approaches outlined in the draft guidance based on the numerous comments

received.


we cen,

APPENDIX B: DEFINING VALUES AND REASONABLY EXPECTED USES OF
GROUND WATER

B.1. GROUND WATER VALUES

As described in Appendix A, a State's perception of the value of its ground
water is a key factor in determining remediation objectives or in siting facilities that
have a potential to contaminate. Value, as discussed in Strategic Activity 2, is a key
factor in assigning priorities for ground water protection or remediation activities. The
States are given the flexibility to define their own ground water values through the
CSGWPP.

Recent studies indicate that people value ground water for many different
reasons, each of which should be considered by States. EPA held a Ground Water
Valuation Conference on October 20, 1992, to provide a common base of knowledge
on the types of ground water values. Experts were invited to discuss their recent
studies on this topic. The description of values described below was derived from this
conference and previous EPA reports.

Ground water is valued in three ways:

e For its current uses;
e For its future or reasonably expected uses; and
e For its intrinsic values.

B.1.1 Current Use Value -

Persons most commonly value ground water for its many uses, and pay a price
to use it -- the use value of ground water. The value of the ground water depends on
its use. However, not all of the uses of ground water are easily quantifiable. For
example, ground water has great value for maintenance of streamflow and lake levels
and their associated ecosystems, particularly during dry seasons. Also, the value of
the ground water may vary depending on the availability of alternate sources and
vulnerability to contamination. In locations where many competing uses are
withdrawing ground water faster than it is recharged, the cost to produce, and
therefore the value of ground water, may be rising as the resource becomes scarce.

B,1.2 Future or Reasonably Expected Use Value

There is also a value given to the future use of ground water, known as option
value. Option value is the value people place on ground water that they don't
currently use, but want to have the option to use in the future. Reasonably expected
use is a subset of this option use value -- it is ground water that not only has the


we on,

A-6

requires national resources (@.g., research, expertise for technically complex
environmental problems); :c) when State-by-State efforts would create unwarranted
and inefficient duplication; and d) when national security is involved (e.g., disposal of
high-level radioactive waste).

A3

EPA’s POLICY TOWARD ENDORSING CSGWPP GOALS

Under Strategic Activity 1, a State’s goal must be no less protective than EPA’s
goal. Therefore, for:

Prevention. A State’s goal must, at least, be based on preventing
ground water contamination whenever possible. A state is encouraged
to determine what is "possible" explicitly and through adequate public
participation -- State legislation may often be the best vehicle for such
policy determinations. Where appropriate, the State should also allow
local governments, which are closest to those most affected, to make
these decisions. States and local governments will, however, need to
follow federal laws where they prescribe what is "possible."

A State’s goal must be just as, or more stringent than, EPA’s goal for
prevention. A State's goal could, therefore, be based on "non-
degradation" or “anti-degradation" as well as prevention whenever
possible. However, EPA recognizes the need will arise to balance the
economic and social costs of prevention with the underlying ground
water’s use and value. Therefore, while a State is encouraged to pursue
prevention whenever possible, a State or its localities may have statutes,
regulations, or ordinances that operate under a less stringent standard.
State and local approaches must, however, be in compliance with any
applicable federal statute or regulation.

Remediation. A State’s goal must, at least, be based on protecting
ground water currently used, or reasonably expected to be used, as a
source of drinking water as well as ground waters that are closely
hydrologically connected to surface waters. For drinking waters, the
attainment of Maximum Contaminant.Levels (MCLs) established under
the Safe Drinking Water Act (SDWA) should be the remediation goal.

For ground waters closely hydrologically connected to surface waters,
the goal should be to reduce contamination so that its discharges to
surface water does not exceed water quality standards established under
the Clean Water Act (CWA).

A State's goal can be more stringent than EPA's goal for remediation. A
State's goal could, therefore, be based on "non-degradation." A State's
goal could also be based on either "remediation to the extent possible"
or "differential protection based on relative risks to human health and the


A-5

health or environmental concerns. Such consideration could result in
targeting prevention measures to those areas where ground waters are
considered to have certain uses and values that, if not protected and
conserved, would pose an unreasonable risk to human health and the
environment now or for future generations. While under these federal
statutes EPA and the States will need to ensure protection of ground
waters with certain uses and values, States are encouraged to pursue
prevention whenever possible.

e Remediation based on relative use and value of ground water.
Although the focus of ground water protection should be on the
prevention of contamination, remediation must be pursued as a final
option when prevention fails or where contamination already exists.
EPA's goal is to remediate all aquifers to meet their designated uses.
Given the expense of cleaning up ground water contamination and the
need to focus more effort and resources on prevention, EPA and the
States must take a realistic approach to restoration based upon the
actual and reasonably expected uses of the resource as well as on
social and economic values. EPA, the States, and other federal agencies
must work together to ensure consistent approaches to determining
clean-up objectives.

As noted above in Section A.1, certain social/economic as well as technologic
factors can be considerations in determining what are "possible" measures for
preventing ground water contamination. Similar factors can come into play in
determining what level of remediation should be achieved for ground water
considered to have a particular use or value. It is EPA’s position that determinations
of what factors will be employed should be explicit and done through considerable
public education and participation --- often perhaps through representative
governmental processes. Furthermore, such decisions should be made, to the extent
possible, at the governmental level closest to the people most affected.

In general, States and local governments should play the prominent role in
such decision-making. This is especially appropriate when: a). the activities of concern
are numerous (e.g., 23 million septic tanks) or highly localized (e.g., vary in impact
and number from State to State) and nationally present a low to medium risk potential;
b) when land-use management is the principal protection approach; and c) when
technologies currently exist or are easily developed to address the problem.

The federal government may need to take the primary role in these decisions
when: a) there is a need to establish national regulatory consistency (@.g., to limit
significant adverse impacts on interstate commerce); b) when the scope of the effort


C-4


AB

pte




(a)

(b)

B-3

The State should utilize a public participation process with objectives as
defined in 40 CFR Part 25. State laws designating ground water uses
are considered adequate for this purpose. States are encouraged to
keep their ground water use designations current. The objectives of 40
CFR Part 25 are to:

- Ensure that the public has the opportunity to understand official
programs and proposed actions;

- Ensure that the government decision defining reasonably
expected uses includes consulting interested and affected
segments of the public;

- Ensure that the government action is as responsive as Possible to
public concerns;

- Encourage public involvement in implementing environmental
laws;

- Keep the public informed about significant issues and proposed
project or program changes as they arise;

- Foster a spirit of openness. and mutual trust among EPA, States,
sub-state agencies, and the public; and

- Use all feasible means to create opportunities for public
participation and to stimulate and support participation.

The State should consistently apply its definitions of ground water uses
across all prevention and remediation decisions over which the State has
control. For example, (i) the State should use a consistent definition
regardless of waste type (e.g., sewage sludge or municipal solid waste)
in determining facility requirements, and (ii) a State’s definition would
apply similarly to State and Federally funded remediation. As another
example, application of a State's definition, which would require
remediation programs to create an "island of clean" within a larger region
of previously contaminated ground water, could be considered an
inconsistent application.

Defining Reasonably Expected Uses for Ecological Support and Drinking Water

While States are expected to consider all uses, this section focuses on support

of ecological systems and drinking water, because most laws that EPA implements
focus on human health and the environment.


B-2

potential for use. in the future, but is expected to be used. The value will depend on
the expected use.

B.1.3 Intrinsic Value

Society places an intrinsic value on ground water, separate from any thought of
using the resource, called non-use value (value other than for its specific uses).
Studies have shown that Americans are willing to pay for the knowledge that clean
ground water exists. Existence value is the value that individuals place on simply
knowing that clean ground water exists independent of any use. Bequest value is the
value the current generation places on the ability to pass clean ground water on to
future generations. These values are difficult to quantity, and require the use of survey
data. EPA’s draft report "Methods for Measuring Non-Use Values: A Contingent
Valuation Study of Ground Water Cleanup" also indicated that individuals are willing to
pay just to know that clean ground water exists. This willingness to pay becomes a
significant amount when added up over the population of a city, county, or State.

B.2 DEFINING REASONABLY EXPECTED USES OF GROUND
WATER

EPA recommends that States use the process described in this Appendix to
define reasonably expected uses of ground water. The priority-setting and program
impiementation components of a CSGWPP (i.e., Strategic Activities 2 and 4) both rely
on a State’s resource characterization efforts. This characterization could be done
through an interactive process. An important application of State resource
characterizations will be to identify reasonably expected uses of ground water so that
those uses which have particular value or benefit to the State can be afforded greater
attention using a differential management approach. These uses may include
ecological support and drinking water, as well as other purposes. States may. also
want to consider other principal uses and factors, such as for agriculture and industry.
It is left to States to determine relative priorities among the uses.

The approach described below allows each State to tailor resource based
priority-setting to its own institutions. First, a public process is described for defining
the reasonably expected uses of ground water. Second, factors are identified for
States to consider in defining ground waters reasonably expected to be used for
ecological purposes and drinking water. Third, an EPA default definition for Federal
program purposes will be applied to the extent needed to implement regulatory
programs in States choosing not to define these uses.

(1) Public Process. To obtain the operational flexibility through the CSGWPP, the
State’s public process to determine reasonably expected uses should (a)
maximize public input, and (b) have its results consistently applied across
programs.


A-7

environment." However, the resulting State clean-up objectives need to
at least as stringent, and consistently applied, as the standards
described above.


D-3

NRC: Nuclear Regulatory Commission

OAR: EPA Office of Air and Radiation

OE: EPA Office of Enforcement

OERR: EPA Office of Emergency and Remedial Response
OHWP: DoD Other Hazardous Waste Program

OPA: Oil Pollution Act of 1990

OPPTS: , EPA Office Prevention, Pesticides, and Toxic Substances
OsbD: Office of the Secretary of Defense

OSM: DO! Office of Surface Mining

OSWER: EPA Office of Solid Waste and Emergency Response
Ow: EPA Office of Water

PA/SI: Preliminary Assessment and Site Investigation
PCBs: Polychlorinated biphenyls

POTW: Publicly owned treatment works

PWS: Public water supply

PWSs: Public water supply system

QA/QC: Quality assurance/quality control

RAD: Radiation

RASA: Regional Aquifer-System Analysis

RCRA: Resource Conservation and Recovery Act

RCRA C: Resource Conservation and Recovery Act Subtitle C
RCRA D: Resource Conservation and Recovery Act Subtitle D

Reclamation: DOI Bureau of Reclamation


A.2

A:3

As described above in the previous goal discussion, these other social,

economic, and technical factors can be incorporated, either explicitly or
implicitly, in legislation or ordinances at the federal, State or local levels.
For example, FIFRA requires EPA to weigh the risks against the benefits
of a pesticide’s use before taking regulatory measures, including those

aimed at ground water protection.

Critics of this goal claim that it is often difficult to determine accurately all
risks associated with ground water contamination and, therefore, the total
impact of contamination will not be factored into protection decisions.
Critics are concerned that such a goal can often lead to ground water
degradation where decisions attempt to balance ground water protection
against the social and economic impacts of such protection.
Furthermore, the approach raises the issues of who decides what "risks"
are acceptable and whether these decisions represent an informed
societal choice.

Differential Protection Based on Relative Use and Value of the
Ground Water. Because it is usually difficult to ascertain actual risks,
this goal relies on information about the relative use and value (See
Appendix B) as well as the vulnerability of underlying ground water in
determining the degree of protection to be afforded. The decision-
maker is still faced with determining what benchmark will be used to
determine the level of protection afforded to a particular use. Such a
benchmark can be set as a particular concentration of a contaminant for
a particular ground water use or value (e.g., the MCL for current or
reasonably expected drinking water) or can vary according to social and
economic factors as described above for previous goals.

Critics of this goal claim that it leads to "writing-off' of ground water
resources where the use and value of the resource are not clear or are
not considered significant relative to the social and economic costs of
remediation or prevention. Furthermore, this approach also raises the
issues of who decides the beneficial use and value of ground water
resources and whether these decisions reflect informed societal choice.

EPA’s GROUND WATER PROTECTION GOAL

EPA's ground water goal is to prevent adverse effects to human health and the
environment and protect the environmental integrity of the nation's ground water
resources, Several reviewers of an early draft of this Guidance commented that this
goal does not, by itself, provide sufficient operational direction. In part, this is a result
of the EPA goal not fitting into any one of the five traditional goals described above.
They recommended that the Agency provide clarification of its goal so States can


B-6


C-2

reduced and revised to six Strategic Activities to reflect views expressed in the
Roundtables; specific adequacy criteria were included or excluded based on State
and Tribal arguments; and certain procedures associated with the CSGWPP process
were revised. In particular, EPA initially planned on providing a State with increased
flexibility only when the State had a fully implemented, EPA-concurred-upon CSGWPP.
However, Roundtable participants suggested instead that increased program-specific .
flexibility should occur as specific milestones are met in the progressive
implementation of each State's CSGWPP. This Guidance adopts that approach.

In July 1992, EPA published the draft CSGWPP guidance and carried out a
broad range of outreach activities to ensure that the draft CSGWPP guidance
document was reviewed by all States’ agencies involved in ground water protection,
numerous federal agencies, tribes, national organizations of State and local
governments, national environmental organizations, business groups, EPA Regions
and other entities committed to adequately protecting ground water resources. EPA
published a notice on July 7, 1992, in the Federal Register that the draft guidance was
available for distribution to the public. Simultaneously, EPA distributed copies of the
draft guidance, accompanied by a letter from EPA’s Deputy Administrator, F. Henry
Habicht Il, that requested commenters to address specific questions concerning the
guidance and the Comprehensive State Ground Water Protection Program (CSGWPP)
approach, to a large number of State officials. EPA supplied about 4,000 copies of
the draft guidance to the public.

During the 60-day comment period, EPA’s Office of Ground Water and Drinking
Water, Office of Pesticide Programs, Office of Radiation Programs, and Office of Solid
Waste and Emergency Response met with national associations of State and local
governments, environmental organizations, States, local government officials, and five
federal agencies (Department of Defense, Department of Energy, Department of
Interior, U.S. Department of Agriculture, and the Nuclear Regulatory Commission) to
obtain additional views.

EPA Headquarters, in an effort to build a new partnership with its sister federal
agencies, held a Federal Interagency Roundtable in March 1992. In addition, EPA
held meetings with other involved federal agencies this summer to discuss the draft
guidance and to develop plans for more active efforts at programs coordination. As a
follow-up to these meetings, EPA Headquarters, at a staff level, has approached the
other federal agencies with several ideas to forge ahead into this new partnership,
which has resulted in the descriptions of these efforts in Part Il, Section Il.


A-2

Social or economic considerations may also enter into determinations of
what is "possible." For specific source controls, these other factors are
often considered and balanced, either explicitly or implicitly, in a context
of competing interests. Legislation at the federal or State levels or
ordinances at local levels may specify explicitly that a regulatory agency
must take into account certain social or economic factors in determining
appropriate ground water protection measures. For example,
prevention measures established by EPA under RCRA Subtitle D are to
“take into account the practicable capability of a municipal solid waste
landfill (MSWLF)." EPA, therefore, considers the cost impacts to
MSWLEFs in determining which measures to prevent ground water
contamination are "possible,"

Legislation at the federal and State levels and ordinances at local levels
can also implicitly incorporate social and economic considerations into
what protection measures are "possible". Society’s preference for what
is "possible" can be revealed where the processes of representative
government have resulted in prescribing performance, design,
operational or zoning requirements for ground water protection. For
example, a local zoning ordinance allowing one residential dwelling per
ten acres in order to limit ground water contamination from septic
systems has implicitly incorporated social and economic development
considerations in what is "possible" in protecting ground water.

Critics of this goal suggest that it is "source-specific’ and, therefore, does
not provide a unifying approach to protecting the ground water resource.
Other critics are concerned that such a goal can often lead to ground
water degradation where determination of what is "possible" in ground
water protection is bounded by social and economic considerations.
Furthermore, the approach raises the issues of who decides what is
"possible" and of whether these decisions reflect an informed societal
choice.

Differential Protection Based on Relative Risks to Human Health or
the Environment. This goal takes into account the relative risks to
human heaith or the environment posed by ground water contamination.
Under this goal, a decision-maker must first determine what risks to
human health and the environment would result if ground water
contamination takes place. The decision maker must then weigh these
tisks against some benchmark to determine appropriate prevention or
remediation measures. Such benchmarks can be set at a particular level
of risk (e.g., a one in a million chance of cancer incidence over a 70-year
life-span) or vary according to other factors such as technological
feasibility and social/economic impacts.



APPENDIX A: DEFINING GROUND WATER PROTECTION GOALS

Ad

HISTORICAL TYPES OF GROUND WATER PROTECTION GOALS

Under Strategic Activity 1, a State is asked to establish an averarching ground
water protection goal, Historically, ground water protection goals have fallen into five
general types:

Non-Degradation. This goal is considered the most stringent of
possible ground water protection goals because it defines all
contamination as unacceptable. To achieve such a goal, all activities that
would potentially contaminate ground water would need to be eliminated
or controlled. Furthermore, all presently contaminated ground water
would need to be restored. While the relative vulnerability of ground
water could be a factor in determining needed prevention measures, the
relative use and value of the ground water would not be factors in
determining either prevention or remediation measures.

Critics argue that from a prevention standpoint, a non-degradation goal
is impossible to enforce because many basic human activities (e.g. crop
production, resource extractions, septic systems, etc.) would require
unrealistic prohibitions to eliminate their potential to cause some level of
ground water pollution. And, from a remediation standpoint, a non-
degradation goal would often be economically, if not technologically,
beyond our society's reach. Critics further contend that technological
advances in water quality monitoring can now reveal minute levels of
substances -- the presence of which in ground water would constitute
degradation but whose environmental health impact may be minimal or
non-existent.

As a practical matter, non-degradation is viewed more often as a general
policy aim rather than as a day-to-day operational criterion or objective.

Anti-Degradation. For the purposes of this document, this goal applies
the above non-degradation objective to only the prevention side of the
ground water protection issue; i.e., its intent is to avoid making ground
water contamination worse. The goal does not provide a reference for
remediation activities other than to avoid further degradation of ground
waters that are already contaminated.

Prevention, Reduction or Remediation of Contamination to the Extent
Possible. This goal requires the consideration of certain pragmatic
factors in determining what ground water protection measures are
"possible." In determining what is "possible", technological feasibility or
the availability of technology would need to be considered.


B-4

For Ground Water Supporting Surface Water Ecosystems: EPA's
1991 Ground Water Protection Strategy emphasizes protection of ground
water closely hydrologically connected to surface waters to ensure
ecosystem integrity. EPA considers the following factors important
indicators of ground water hydrologically connected to surface water. A
State may choose to use other factors. States should negotiate with the
EPA Regions which factors are most appropriate for their respective
circumstances.

- Relative ground water travel time from potential contaminant
sources;

- Relative contribution of ground water to quantity and quality
(chemical and physical) of surface water;

~ Biota living in or dependent on ground water/surface water
ecosystems;

- Climatic or seasonal variations; and
oo Attainment of water quality standards to support designated use

of surface water.

For A Reasonably Expected Source of Drinking Water: EPA
considers the following factors to be important in evaluating the future
use of ground water. EPA expects States to consider or dismiss, with a
sound rationale, from consideration these factors when determining a
reasonably expected drinking water source. The State may also use
other factors. States should negotiate with EPA Regions which factors
are most relevant to their respective circumstances.

- Hydrologic characteristics, including water quality and quantity;

- Availability and cost of alternative water supplies;

- Demographics, including future growth and population patterns;
- Remoteness from likely areas of residential or other development;
- Land use planning;

- Remediation technology for, and practicality of, remediation;


APPENDIX C: HOW THIS GUIDANCE WAS DEVELOPED

This Comprehensive State Ground Water Protection Program Guidance was
developed using a deliberative process involving federal and State agencies as well as
the public. Development began in the Summer of 1989, when EPA Administrator
Reilly formed a Ground Water Task Force to review and coordinate EPA's policy on
ground water protection. The Task Force, which consisted of senior Agency
managers from all offices with ground water-related responsibilities, issued its final
report in July 1991. The report, Protecting the Nation's Ground Water: EPA’s Strategy
for the 1990s, describes the Agency’s policy of engaging in an aggressive and
comprehensive approach to protecting the nation’s ground water resources, The
Strategy:

. Sets forth principles to ensure the protection of ground water resources;

. Identifies States as having primary responsibility for ground water
protection; and

. Introduces methods for improving EPA's coordination of ground water-
related activities. :

The Strategy outlines the CSGWPP approach that is the primary vehicle through which
many of the Strategy’s policies and objectives will be met. During the preparation of
the Strategy, the Task Force sought comment and input from States, other federal
agencies, and numerous public and private organizations on all facets of the initial
development of the CSGWPP approach.

Preparation of this guidance on implementation of the CSGWPP approach
followed the release of the Strategy and also involved a high level of State and public
input. Between December 1991 and February 1992 a series of Roundtable
discussions involving EPA and State and Tribal officials from agencies with ground
water responsibilities were held throughout the country. The Roundtables were
organized to provide a forum for State and Tribal views on four key subjects: (1) what
are the necessary elements of a successful CSGWPP; (2) what are the criteria for
determining the adequacy of each CSGWPP element; (3) what can prevent
successful implementation of a CSGWPP; and (4) what EPA can do to help the States
and Tribes implement CSGWPPs successfully.

The Roundtable Discussion. approach introduced a new and innovative
dimension to program guidance development. Thirteen separate Roundtables, with a
total of over 700 State and Tribal participants, were held around the country.
Comments, opinions, and questions from the Roundtables have been used to inform
EPA decision making and have influenced the development of the draft CSGWPP.
Guidance in many ways. For example, the number of CSGWPP elements was
reduced and revised to six Strategic Activities to reflect views expressed in the
Roundtables; specific adequacy criteria were included or excluded based on State