iii

Office of Solid Waste and EPA 500-R-07-001 

Emergency Response December 2007 

5204G 

Recommendations from the 

EPA Ground Water Task Force 

A Report by the 

Ground Water Task Force

 December 2007
i

A Special Acknowledgement 

A special thanks and recognition goes to Kenneth Lovelace who served as the Chair of 

the Ground Water Task Force that produced this report. Ken was an expert and advocate 

of ground water protection and remediation, and 

 friend to many who miss him. 
ii

Acknowledgments

This report would not have been possible without the contribution of the many individuals 

listed below who participated in EPA’s Ground Water Task Force. The Task Force was 

organized by the Office of Solid Waste and Emergency Response, and chaired by Kenneth 

Lovelace formerly of EPA’s Office of Superfund Remediation and Technology Innovation. 

These names and affiliations of individual Task Force members listed below were accurate at 

the time the Task Force was convening, and may not reflect their current positions. 

Harold Ball, Region 9, Superfund Division 

Felicia Barnett, OSWER, Region 4, Office of Brownfields Cleanup and Redevelopment 

Betsy Behl, OPPTS, Office of Pesticide Programs 

Arnold Bierschenk, Region 6, Water Quality Protection Division 

Matt Charsky, OSWER, Office of Superfund Remediation Technology Innovation 

Kathy Davies, Region 3, Hazardous Site Cleanup Division 

Chuck Evans, OPPTS, Office of Pesticide Programs 

Linda Fiedler, OSWER, Office of Superfund Remediation Technology Innovation 

Elisabeth Freed, OECA, Office of Site Remediation Enforcement 

JoAnn Griffith, OSWER, Office of Superfund Remediation Technology Innovation 

Stephen Hammond, New York State Department of Environmental Conservation 

Joel Hennessy, Region 3, Waste and Chemicals Management Division 

Ruth Izraeli, Region 2, Division of Environmental Planning and Protection 

Jennifer Kaduck, ASTSWMO and Georgia Environmental Protection Division 

Marty Link, Nebraska Department of Environmental Quality 

Ken Lovelace, OSWER, Office of Superfund Remediation Technology Innovation 

Steve Mangion, Region 1, Hazardous Substances Technical Liaison Program 

Tim Mott, OSWER, Federal Facilities Restoration and Reuse Office 

Kevin McCormack, OW, Office of Ground Water and Drinking Water 

Peter Neves, OECA, Office of Site Remediation Enforcement 

Howard Orlean, Region 10, Office of Waste and Chemical Management 

Robert Pierce, Georgia Environmental Protection Division 

Nancy-M Porter, OSWER, Office of Brownfields Cleanup and Redevelopment 

Bob Puls, ORD, National Risk Management Research Laboratory 

Roy Simon, OW, Office of Ground Water and Drinking Water 

Guy Tomassoni, OSWER, Land Revitalization Office 

Hal White, OSWER, Office of Underground Storage Tanks 

Ron Wilhelm, OAR, Office of Radiation and Indoor Air 

Dick Willey, Region 1, Office of Site Remediation and Restoration
iii

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iv

Disclaimer

This report is a work product of the Ground Water Task Force. The report is intended to provide 

information to EPA management, program staff, and other stakeholders for their consideration 

and to inform and encourage discussion on the topic. The statements in this document do not 

constitute official Agency policy, do not represent an Agency-wide position, and are not binding 

on EPA or any other party. 
v

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vi

Table of Contents

Acronyms and Abbreviations.................................................................... 1

Executive Summary............................................................................... 3

DNAPL Source Zone.............................................................................. 3

Ground Water Use, Value, and Vulnerability (UVV)........................................ 4

Introduction ........................................................................................ 7

Purpose of Ground Water Task Force ........................................................ 7

Methodology for Developing Recommendations ............................................ 9

Stakeholder Input on DNAPL Paper and Options...........................................11

Comments on Options Presented in DNAPL Paper.........................................11

Option 1: Develop a fact sheet describing the potential benefits of DNAPL 

mass removal from the source zone, as well as the potential disadvantages. ....11

Option 2: Develop a fact sheet describing program flexibilities and alternative 

cleanup goals that may be applied to the DNAPL source zone other than 

attainment of Maximum Contaminant Levels (MCLs). ...............................................11 

Program flexibilities (e.g., technical impracticability decisions, containment zones, or similar 

alternatives) would be those allowed under federal or state cleanup programs. 

The alternative goals would typically apply only to the DNAPL source zone rather than the entire 

plume, in accordance with existing policy. 

Option 3: Develop a supplemental EPA guidance on technical impracticability (TI)

that clarifies some or all of the following questions for Superfund and other EPA 

cleanup programs:(see page 11 for questions)..........................................11

Option 4: Develop a policy memorandum re-emphasizing the existing EPA policy 

that program flexibilities are to be used for DNAPL source zones as a means of 

setting cleanup goals that are achievable in a reasonable time frame. ................12 

Such program flexibilities may include TI determinations, containment zones, ground water 

classification exemptions, or similar flexibilities that are available at a particular site from 

either the federal or state cleanup program overseeing the cleanup at that site. 

The memorandum would reiterate EPA’s current policy that cleanup goals for DNAPL source 

zones should not include restoration of ground water to drinking water standards, if this goal 

cannot be achieved in a “reasonable time frame” based on site conditions.

Option 5: Develop guidance on recommended methods and approaches for 

delineating the extent of the DNAPL source zone. ....................................12

Option 6: Develop guidance providing a qualitative approach for determining 

when source depletion technologies should or should not be implemented. . ....13
vii

Option 7: Develop guidance on performance measures for the effectiveness of 

DNAPL mass removal, and on how to determine when active DNAPL removal 

efforts should be discontinued. ........................................................................................13 

Such measures could include trend analysis for mass removal rates, mass flux data, or other 

parameters for gauging remedy performance.

Option 8: Develop guidance describing improved methods for comparing longterm remedies. .............................................................................13 

The guidance would allow a more realistic accounting of the costs and other disadvantages of 

long-term custodial care. This would include long-term costs of maintaining containment 

systems, equipment replacement, monitoring and enforcing institutional controls, and site 

monitoring. 

Additional Options Suggested by Commenters on the DNAPL Paper ...................13

General Themes in Comments on DNAPL Paper ...........................................15

Stakeholder Input on Ground Water Use, Value, and Vulnerability as Factors in 

Setting Cleanup Goals Paper and Options ...................................................17

Comments on Ground Water Use, Value, and Vulnerability Paper Options ...........17

Option 1: Develop a series of educational fact sheets and Internet training 

seminars. ...............................................................................................................................17 

Material would be, targeted primarily to government officials and members of the regulated 

community to raise awareness of ground water UVV; interconnection between ground water and 

surface water systems and health impacts from contaminants most commonly found in ground 

water. 

This effort would include summaries of the findings from the 2004 Ground Water Report to 

Congress.

Option 2: Conduct research on the impacts on other developed nations that have 

resulted from either the presence or lack of strong ground water protection 

programs. .....................................................................................18

Option 3: Develop summaries of how individual EPA and state cleanup programs 

consider ground water UVV in setting cleanup goals (e.g., ground water 

classification and classification exception systems, ground water management 

zone-type approaches). .....................................................................................................18 

These summaries would be written with Internet links to more detailed resources. EPA would 

provide access to these summaries via its One Cleanup Program website. This option could also 

involve low-cost Internet training to raise awareness of the range of approaches being used by 

EPA and states.

Option 4: Takes option 3 one step further by developing an EPA policy memo that 

explains how EPA cleanup programs acknowledge the various approaches used by 

states in setting ground water cleanup goals based on ground water UVV. .........18 

For example, the policy statement would clarify how state ground water management zone 

policy could influence goals established under EPA’s cleanup programs. Internet training could 

also be used to increase awareness and understanding of the policy statement. 
viii

Option 5: Using information from federal and state cleanup programs, develop a 

general framework that describes how to prioritize sites according to problem 

severity and ground water UVV. .....................................................................................19 

This framework would clearly describe how ground water UVV as well as specific problem 

magnitude (e.g., risk) can be used to prioritize sites and influence remedial decisions. 

This framework would describe how a prioritization system directed at site-specific ground water 

problems can work within statewide general classification systems and how, for example, ground 

water management zone policy could influence goals established under EPA’s cleanup programs. 

Option 6: Use defined Source Water Assessment Program (SWAP) areas (required 

by the 1996 amendments to the Safe Drinking Water Act) to promote consistency 

in ground water cleanup decision making. ...................................................................19 

The option would involve establishing a means to encourage stakeholders to become more aware 

of and involved with various ground water cleanups taking place within or near an individual 

Source Water Assessment Area. 

The objective would be that cleanups could be selected to maximize efficiencies and benefits 

within a particular source water area.

Option 7: Promote and provide funding assistance for regular meetings within an 

individual state or watershed that brings together the various programs and 

stakeholders involved with ground water cleanup and protection. ................19 

One of the objectives of these meetings would be to help prioritize cleanup actions based on 

factors, such as magnitude and extent of ground water contamination, as well as ground water 

UVV.

Additional Options Suggested by Commenters on the Ground Water Use, Value, 

and Vulnerability Paper .......................................................................19

General Themes In Comments on Ground Water UVV Paper.........................................20

Task Force Recommendations .................................................................23

Recommendations Concerning DNAPL Issues...............................................23

Recommendation 1. Develop guidance on how to acknowledge technical 

limitations posed by DNAPLs in EPA cleanup decisions. ............................................23 

This would include updated guidance on the use of technical impracticability (TI) decisions in the 

Superfund program. 

The guidance should also discuss mechanisms for acknowledging technical limitations posed by 

site complexities other than DNAPLs.

Ground Water Use, Value, and Vulnerability Recommendations .......................26

Recommendation A. Develop a new web-based resource center for information 

related to the potential role of ground water UVV in cleanup decisions. ............26 

The resource center would address items such as: 

• interconnection between ground water and surface-water systems; 

• importance of ground water to ecosystems; 

• health impacts from contaminants most commonly found in ground water; 
ix

• potential for drinking water shortages and their effects on current ground water use 

classifications; 

• federal protection policies, and exemplary state policies 

Recommendation B. Request that the U.S. Census Bureau update the 1990 

census information on sources of drinking water, and develop tools to facilitate 

access to this information..................................................................27

Recommendation C. Develop approaches for using source water areas (SWA), 

delineated by state drinking water programs, to promote collaboration among 

cleanup programs, drinking water programs, and stakeholders concerned with 

cleanup and protection of ground water resources. ...................................28

Summary ...........................................................................................29

Attachment A. Discussion Paper: Cleanup Goals Appropriate for DNAPL 

Source Zones .....................................................................................A-1

Attachment B. Discussion Paper: Ground Water Use, Value, and Vulnerability as 

Factors in Setting Cleanup Goals.............................................................B-1

Attachment C. GWTF Web Page................................................................C-1

Attachment D. Individuals and Organizations that Submitted Comments on One or 

Both Discussion Papers .........................................................................D-1
 1

Acronyms and Abbreviations 

ARAR Applicable or Relevant and Appropriate Requirements 

ASTSWMO Association of State and Territorial Solid Waste Management Officials 

DNAPL Dense Non-Aqueous Phase Liquid 

EPA Environmental Protection Agency 

GWTF Ground Water Task Force 

MCL Maximum Contaminant Level 

MOU Memorandum of Understanding 

NCP Superfund National Oil and Hazardous Substances Pollution Contingency Plan 

NGWA National Ground Water Association 

OSWER Office of Solid Waste and Emergency Response 

RBCA Risk-Based Corrective Action 

RCRA Resource Conservation and Recovery Act 

SWA Source Water Area 

TI Technical Impracticability 

UST Underground Storage Tank 

UVV Use, Value, and Vulnerability
 2

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Executive Summary 

In recognizing the importance of ground water to the nation’s drinking water supply and its 

critical role in maintaining the health of ecosystems, EPA established the Ground Water Task 

Force (GWTF) in the fall of 2002 as part of the Agency’s One Cleanup Program. The mission of 

the task force was to identify and prioritize ground water issues that will benefit multiple 

cleanup programs (e.g., RCRA, Superfund, Brownfields, Underground Storage Tanks, etc.), 

and make recommendations to EPA senior management on the best course of action. The 

GWTF was staffed by senior representatives from various EPA program offices (cleanup and 

non-cleanup), and representatives from the Ground Water Forum, lead RCRA and Superfund 

regions, and some state cleanup programs. 

Task force members identified two topic areas for initial evaluation and developed 

“discussion papers” for each area. The papers are: “Cleanup Goals Appropriate for DNAPL1

Source Zones” and “Ground Water Use, Value, and Vulnerability as Factors in Setting Cleanup 

Goals” (UVV). EPA undertook an extensive outreach effort to obtain the views of the general 

public, environmental advocacy groups as well as state officials, tribal leaders, and industry. 

The papers provide a series of problem statements that reflect the views of EPA as well as 

various stakeholder groups who responded and proposed options (not necessarily mutually 

exclusive)that may be used to address the problem statements. The task force reviewed 

cleanup policies associated with these topic areas, but did not review overall Agency policies 

concerning the cleanup of contaminated ground water. 

The task force placed the papers on the GWTF webpage on May 10, 2004 and solicited 

comments on the options. The task force also invited commenters to submit any other 

suggestions they might have on the two issues. To advertise the solicitation of comments, 

notices were placed in several newsletters, two EPA internet seminars were held to explain 

the papers, and direct email requests were sent to over 100 stakeholder groups. Comments 

were received from industry, government agencies, and environmental consultants. No 

comments were received from environmental advocacy groups.2

 The task force considered 

the comments received in light of the original options, evaluated additional suggestions, and 

developed the following series of recommendations for consideration by senior EPA 

management. 

DNAPL Source Zone 

The decision-making process involved in determining cleanup goals appropriate for a DNAPL 

source zone, and whether remediation efforts should be undertaken to remove or treat the 

DNAPL source zone was a common theme in the comments received. Most task force members 

agreed that the current Superfund guidance on technical impracticability (TI) should be 

 

1

 A nonaqueous phase liquid (NAPL) is a chemical compound that is a liquid in its pure form, does not 

readily mix with water, but does slowly dissolve in water. A dense nonaqueous phase liquid (DNAPL) 

sinks in water, while a light nonaqueous phase liquid (LNAPL) floats on water. When released to the 

environment, DNAPLs and LNAPLs are sources of contamination to ground water. 

2

 These papers are included in this report as Attachments A and B. Comments can be viewed from the 

Ground Water Task Force website at: http://gwtf.clu-in.org/papers/.
 4

updated. Also, there was support for identifying mechanisms for acknowledging complex site 

conditions that would be useful in the decision-making process for cleanup programs other 

than Superfund. 

Recommendation. Develop guidance on how to acknowledge technical limitations posed 

by DNAPLs in EPA cleanup decisions, including updated guidance on the use of technical 

impracticability (TI) decisions in the Superfund program. The guidance should also discuss 

mechanisms for acknowledging technical limitations posed by site complexities other than 

DNAPLs. 

While not a universal opinion, there was common concern that several of the options could 

not be implemented because of a lack of scientific consensus, and industry commenters in 

particular made the point that the benefits of source reduction had not been conclusively 

demonstrated. The task force agreed that there is a need to better assess and document 

results achieved by DNAPL source reduction efforts. 

Recommendation. Develop recommended data needs and procedures for documenting and 

tracking DNAPL source zone cleanup efforts so that technology performance can be 

adequately assessed. Procedures are needed to better assess field research and testing 

(conducted by EPA and others) to develop promising technologies for remediation and 

characterization of DNAPL source zones. 

 

Several of the options involved educational and informational activities, and analysis of the 

comments showed a need for better access to the research, guidance, and policy documents 

that are currently available on DNAPL issues. Such access could be provided through a website 

and would be a useful source of information for EPA and state site managers, cleanup 

contractors, community groups, and other stakeholders. There is no current EPA website 

specific to DNAPLs that serves this purpose. 

 

Recommendation. Develop a web-based resource center for information related to 

cleanup and characterization of sites with DNAPLs, including links to existing policy, 

guidance, technology descriptions, and case studies. 

The GWTF believes that implementation of these recommendations will greatly aid 

practitioners in making decisions on the cleanup of DNAPL source zones. Updated guidance on 

ways to acknowledge complex site conditions in cleanup decisions (e.g., TI decisions in 

Superfund) combined with an EPA website that provides current information on remediation 

technologies and EPA guidance related to DNAPLs will provide tools to help meet near-term 

needs of cleanup programs. In addition, continuing to support technology demonstrations, 

while providing a mechanism for properly evaluating field application of DNAPL source 

cleanups, will develop the scientific basis for evaluating the likely benefits of source 

cleanups, and provide the basis for future Agency guidance. 

Ground Water Use, Value, and Vulnerability (UVV) 

One key factor in determining human health risk from contaminated ground water is whether 

an aquifer is currently used as a drinking water supply, or is expected to be used in the future 

as a source of drinking water. Also, the economic and/or ecological value of an aquifer, or 

the relative vulnerability of an aquifer to contamination may be considered in setting cleanup 

goals. Consideration of ground water use, value, and vulnerability may be helpful in other 
 5

remedy decisions, such as desired cleanup time frame or priority of cleanup compared to 

other sites. 

Most of the options presented in the UVV paper contain an element of information transfer 

and education, and several of the comments received emphasized the importance of 

education in understanding the importance of the use, value, and vulnerability of surface and 

ground waters in making cleanup decisions. The GWTF concluded that information on ground 

water UVV and its potential role in cleanup decisions should be more readily available to 

government officials (particularly cleanup managers) and interested members of the public. 

Furthermore, an information and education effort could help address many of the issues 

identified in the GWTF option paper (e.g., educate interested stakeholders about the many 

state approaches used to account for ground water UVV in site-specific cleanup decisions). 

Educational tools would address the importance of protecting ground waters that currently 

support ecosystems, and ground waters that may be needed as a future source of drinking 

water whether they are currently considered suitable for drinking water or not. 

Recommendation. Develop a new web-based resource center for information related to 

the potential role of ground water UVV in cleanup decisions. The resource center would 

address items, such as the interconnection between ground water and surface-water 

systems; health impacts from contaminants most commonly found in ground water; 

federal protection policies, and exemplary state policies. 

Most states, through the source water assessment program, have identified aquifers that 

supply public drinking water wells; however, information on private drinking water wells in a 

given area is sometimes inaccurate, difficult to obtain, or unavailable. In the 1990 Census, 

the U.S. Census Bureau collected information on the source of drinking water to a household—

private well or public supply. This question was included in the “long form” of the 1990 

Census, but was omitted from the long form in the 2000 Census.3

 The task force agreed that 

the information collected by the Census Bureau in 1990 was a valuable source of information 

on sources of drinking water, because location-specific information was collected for all 50 

states, and this is the only national data base with information concerning private wells. The 

task force agreed that easily accessible information on drinking water sources would be very 

helpful to EPA programs involved with protection and cleanup of ground water. It would be 

most helpful if the Census Bureau would reinstate the question on source of drinking water. 

Recommendation. Request that the U.S. Census Bureau update the 1990 census 

information on sources of drinking water, and develop tools to facilitate access to this 

information. 

Option 6 in the UVV paper involved source water areas (SWAs) delineated by state drinking 

water programs. Ground water source areas are portions of an aquifer that supply drinking 

water to public wells.4

 This option suggested that mechanisms to facilitate collaboration 

 

3 For the 2010 Census, the long form is being replaced by the ongoing American Community Survey 

(ACS), which also does not have questions concerning source of drinking water. 

4

 Delineation of the source water is typically based on estimated travel time for water in the aquifer to 

reach the public supply well (e.g., 10 years). A more simplified approach used by some states is to 

delineate the source based on a radial distance from the well. See 

http://cfpub.epa.gov/safewater/sourcewater/ for more information about source water, source water 

assessments, and source water protection. 
 6

among ground water cleanup and protection programs within specific (i.e., “pilot”) source 

water areas should be explored. This option was well received by both the regulated 

community and government commenters. It would promote consistency in ground water 

cleanup decision making and encourage stakeholders to become more aware of and involved 

with various ground water cleanups taking place within or near an individual Source Water 

Assessment Area. A further objective would be to maximize efficiencies and benefits within a 

particular source area. 

Recommendation. Develop approaches for using source water areas (SWA) delineated by 

state drinking water programs to promote collaboration among cleanup programs, drinking 

water programs, and stakeholders concerned with cleanup and protection of ground water 

resources. 

By implementing these recommendations on ground water use, value, and vulnerability, the 

GWTF believes the Agency will attain more consistency within its ground water cleanup 

programs and promote a better understanding among all stakeholders of the role that 

evaluation of aquifer use, value, and vulnerability plays in making cleanup decisions. The 

recommendations reflect the fact that other than educational efforts, which are represented 

in the recommendations, there was little consensus among stakeholders on how these issues 

should be approached. The regulated community for the most part advocated a risk-based 

present use approach, while the government commenters preferred to evaluate an aquifer for 

its present and future uses as well as how it fits into the overall ecosystem. 
 7

Introduction

The Ground Water Task Force (GWTF) was 

established in the fall of 2002 as part of 

the Environmental Protection Agency’s 

(EPA) One Cleanup Program. The One 

Cleanup Program is a long term effort 

designed to improve the planning and 

quality of EPA cleanup programs dealing 

with brownfields, federal facilities, leaking 

underground storage tanks, Resource 

Conservation and Recovery Act (RCRA) 

Corrective Action and Superfund. The 

Office of Solid Waste and Emergency 

Response (OSWER) established the One 

Cleanup Program in 2002 in response to 

issues raised by the regulated community, 

other governmental agencies, and citizens 

impacted by contaminated properties. The 

One Cleanup Program’s goal is to improve 

the coordination, speed, and effectiveness 

of cleanups at the nation’s contaminated 

sites without new legislation or program 

restructuring. It represents EPA’s vision for 

how different cleanup programs at all 

levels of government can work together to 

meet this goal—and ensure that resources, 

activities, and results are effectively 

coordinated and communicated to the 

public. More information concerning the 

One Cleanup Program can be obtained 

from the Agency’s website 

(http://www.epa.gov/oswer/onecleanuppr

ogram/). 

The One Cleanup Program encourages 

coordination among EPA programs and 

state, tribal, local, and other federal 

agency programs and stakeholders that 

lead to: 

■ More consistent and effective cleanups 

among cleanup programs 

■ Clearer and more useful information 

about cleanups 

■ Better cross-program performance 

measures 

The results of the One Cleanup Program 

are evaluated on a regular basis and 

considered in annual planning processes. 

Purpose of Ground Water Task Force 

The GWTF served as the main technical, 

policy, communication, and networking 

resource for OSWER on ground water 

issues. As such, it promoted cross-program 

(state and federal) coordination and 

communication on technical and policy 

issues related to the cleanup of 

contaminated ground water. The GWTF 

sought to identify, prioritize, and solve 

and/or provide guidance on ground water 

issues and projects that will benefit 

multiple cleanup programs. It was staffed 

by senior representatives from various EPA 

program offices (both cleanup and noncleanup), and representatives from the 

Ground Water Forum, lead RCRA and 

Superfund regions, and the states. 

Ground water is an essential national 

resource—over half of the U.S. population 

relies on it for drinking water.5

Unfortunately many of the nation’s 

contaminated sites impact ground water, 

and ground water contamination is usually 

very difficult to characterize and clean up, 

often requiring decades of treatment and 

monitoring. Consequently, almost every 

cleanup program devotes a significant level 

of attention and resources to ground water 

issues. 

 

5

 “Safe Drinking Water Act, Section 1429 

Ground Water Report to Congress,” October 

1999, Office of Water Publication 

EPA-816-R-99-016. 
 8

While each ground water contamination 

problem is uniquely complex, there are 

many common issues related to the 

management and cleanup of these 

problems. Thus, it is important that the 

nation’s cleanup programs share their 

knowledge and work together to ensure 

consistent, effective, efficient, and 

protective ground water cleanups. 

The GWTF created a website 

(http://gwtf.cluin.org) to aid in outreach 

efforts. The website contains a ground 

water resource center that has hyperlinks 

to various Agency policy and guidance 

documents, ground water characterization 

and monitoring guidance and modeling 

documents from across government 

agencies, treatment technology 

descriptions and guidance, and hyperlinks 

to information on dense non-aqueous phase 

liquids (DNAPLs). Also on the website are 

examples of various ground water cleanup 

approaches and “success stories” from the 

RCRA and Superfund programs. 

GWTF members identified two high priority 

areas to focus on and have developed a 

“discussion paper” for each of them: 

“Cleanup Goals Appropriate for DNAPL 

Source Zones” and “Ground Water Use, 

Value and Vulnerability as Factors in 

Setting Cleanup Goals” (Attachments A and 

B). Both discussion papers were written to 

improve the processes for setting cleanup 

goals at ground water contamination sites. 

These papers outline the background of the 

issues involved in DNAPL cleanup decisions 

and in assessing ground water use, value, 

and vulnerability to aid in making cleanup 

decisions. They lay out a series of problem 

statements that were designed to reflect 

the views of various stakeholders (e.g., 

state and federal project managers, the 

public, industry, and environmental 

advocacy groups). They also contain a 

series of potential options (not necessarily 

mutually exclusive options)that EPA could 

undertake to address some or all of the 

issues raised in the problem statements.
 9

Methodology for Developing 

Recommendations 

Two GWTF subgroups developed the 

papers, which were reviewed and revised 

before being sent to OSWER office 

directors, and regional division directors, 

for any major comments. After these 

comments were addressed, the papers 

were posted on the GWTF website on May 

10, 2004. The website announcement 

invited public comments on the options 

and invited the submission of additional 

problem statements as well as other 

options for the GWTF to use to refine the 

recommendation choices. 

The specific means by which the GWTF 

solicited comments on the papers included 

the following: 

■ RCRA Corrective Action National 

Meeting, May 11, 2004. Presentations 

on the options papers were given 

during a two-hour session that was held 

at the end of the RCRA Corrective 

Action National Meeting. The session 

was well attended (100+) by a broad 

range of interest group representatives. 

■ Ground Water News and Views. A short 

article on the GWTF and the options 

papers was written for the National 

Ground Water Association’s (NGWA) 

June issue of Ground Water News and 

Views ( Lovelace, K. EPA Task Force 

Seeks Comment from NGWA, Ground 

Water News and Views, Volume 1, Issue 

1, June 2004). This on-line publication 

reaches ground water professionals 

from industry, government, and 

consulting. The NGWA also sent a 

direct request for comment to its 

members. 

■ TechDirect Newsletter. A oneparagraph description of GWTF 

activities and the options papers was 

placed in EPA’s TechDirect email 

newsletter (June 2004, message 88), 

which at that time had over 20,000 

subscribers. 

■ Internet Seminar. Two Internet 

seminars were held June 8 and June 

23, 2004 to discuss the GWTF and the 

options papers. The seminars were 

announced in TechDirect (see above) 

and attracted over 100 attendees each. 

■ Direct Email Notices. Direct email 

notices requesting review of the 

options papers were sent to EPA 

Superfund regional branch chiefs, EPA 

Ground Water Forum, EPA Engineering 

Forum, EPA Federal Facilities Forum, 

and EPA Office Directors for programs 

represented on the GWTF. The 

Association of State and Territorial 

Solid Waste Management Officials 

(ASTSWMO) forwarded their email 

notice to their state remediation 

managers for RCRA, Superfund, Federal 

Facilities, and Underground Storage 

Tank programs. Emails were sent 

directly to cleanup program managers 

in other federal agencies (forwarded by 

the Federal Facilities Restoration and 

Reuse Office). Direct email notices 

were also sent to over 100 stakeholder 

groups, including trade associations 

(industries and their attorneys), 

associations of waste management 

officials, water pollution prevention 

officials, drinking water supply 

associations, state or tribal 

environmental officials, public interest 

groups, environmental groups, and 

other stakeholder groups having a 

national perspective on issues related 

to cleanup and protection of 

contaminated ground water.
 10

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 11

Stakeholder Input on DNAPL Paper 

and Options 

This section summarizes review comments 

on the options provided in the DNAPL 

paper, lists new options recommended by 

reviewers, summarizes general comment 

themes that did not specifically address 

the original options, and presents the 

recommendations of the GWTF. 

* * * * * 

Comments on Options Presented in 

DNAPL Paper 

The final deadline for submitting 

comments was September 24, 2004. As of 

that date, 37 comments on the DNAPL 

options paper had been received. Of the 37 

comments, 20 came from government 

agencies (6 states and 14 federal 

headquarters and regional offices), and 17 

came from the private sector/regulated 

community (6 industry associations or 

companies, 8 consultants, and 3 federal 

facilities). No comments were received 

from environmental advocacy groups or 

from public interest groups. Comments 

from non-EPA reviewers are available on 

the task force website at: 

http://gwtf.cluin.org. 

The DNAPL paper evaluated eight problem 

statements and offered eight potential 

options that might be adopted to help 

solve them, and commenters were invited 

to propose additional options. 

The options were intended to address at 

least one problem statement, but they may 

address several. 

Option 1: Develop a fact sheet describing 

the potential benefits of DNAPL mass 

removal from the source zone, as well as 

the potential disadvantages. 

Private sector/regulated community: 

These commenters thought that this 

option was unnecessary since it would be 

repetitive of what is already available and 

even if it were completed, it would not 

affect decision making, which is done on a 

site by site basis. 

Government agencies: These commenters 

thought that such a fact sheet might be 

useful, but did not indicate strong support 

for it. 

Option 2: Develop a fact sheet describing 

program flexibilities and alternative 

cleanup goals that may be applied to the 

DNAPL source zone other than attainment 

of Maximum Contaminant Levels (MCLs). 

Program flexibilities (e.g., technical 

impracticability decisions, containment 

zones, or similar alternatives) would be 

those allowed under federal or state 

cleanup programs. The alternative goals 

would typically apply only to the DNAPL 

source zone rather than the entire plume, 

in accordance with existing policy.

Private sector/regulated community: 

Comments were generally favorable, and 

in some cases commenters wanted the 

scope expanded. 

Government agencies: Commenters 

discussed technical issues related to this 

option and in general did not think it 

would be particularly useful. 

Option 3: Develop a supplemental EPA 

guidance on technical impracticability (TI)6 

 

6

 Technical impracticability (TI) for 

contaminated ground water refers to a 

situation where a remedy is not expected to 

achieve ground water cleanup levels that would 
 12

that clarifies some or all of the following 

questions for Superfund and other EPA 

cleanup programs:

■ Circumstances that would warrant 

revisiting a TI decision 

■ Content and/or format of a TI 

evaluation report 

■ How the TI decision process can be 

used to encourage delineation of 

DNAPL source zones 

■ When a simplified (or streamlined) TI 

decision process can be applied to 

operating remedies 

■ How the TI decision process can be 

used to encourage use of innovative 

source removal technologies 

General: There was general agreement 

that the current guidance is dated, and 

most of the commenters supported the 

development of supplemental TI guidance; 

however, opinions differed on what it 

should cover. 

Government agencies: While not opposing 

a guidance update, multiple state 

commenters pointed out that TI as a 

concept is not always well received in 

states with antidegradation policies and is 

 

normally be required, because achieving such 

levels is not practicable from an engineering 

perspective. This definition for TI was included 

in the Superfund statute. EPA’s “Guidance for 

Evaluating the Technical Impracticability of 

Ground Water Restoration” was completed in 

1993. A TI determination is part of a sitespecific remedy decision and is made by the 

lead decision-maker for the site (e.g., EPA or 

state). The supporting rationale for such a 

decision is provided in the decision document 

(e.g., a Superfund Record of Decision). The 

term “engineering perspective” refers to 

factors, such as feasibility, reliability, scale or 

magnitude of a project. 

often perceived as a no-action option by 

the public. 

Option 4: Develop a policy memorandum 

re-emphasizing the existing EPA policy that 

program flexibilities are to be used for 

DNAPL source zones as a means of setting 

cleanup goals that are achievable in a 

reasonable time frame. Such program 

flexibilities may include TI determinations, 

containment zones, ground water 

classification exemptions, or similar 

flexibilities that are available at a 

particular site from either the federal or 

state cleanup program overseeing the 

cleanup at that site. The memorandum 

would reiterate EPA’s current policy that 

cleanup goals for DNAPL source zones 

should not include restoration of ground 

water to drinking water standards, if this 

goal cannot be achieved in a “reasonable 

time frame” based on site conditions. 

General: A number of commenters did not 

express an opinion on implementing this 

option, but did provide technical 

observations. 

Private sector/regulated community: 

Option 4 was generally supported (with 

caveats) by those commenting. 

Government agencies: There were few 

direct government comments, and they 

were generally not supportive of the 

recommendation 

Option 5: Develop guidance on 

recommended methods and approaches for 

delineating the extent of the DNAPL source 

zone. 

General: Option 5 had no clear trends 

among commenter groups or commenters. 

Some thought a delineation guidance 

would be useful and should include topics, 

such as how much delineation is necessary. 

Others thought that there are a sufficient 

number of guidance documents already 

available to develop an appropriate 
 13

approach for any given site. Still others 

did not think that source zone delineation 

is an issue. 

Option 6: Develop guidance providing a 

qualitative approach for determining when 

source depletion technologies should or 

should not be implemented. This guidance 

would attempt to identify types of site 

conditions where: 

■ MCLs are potentially achievable in the 

DNAPL source zone 

■ MCLs are not likely to be achieved 

■ Benefits of source depletion efforts 

tend to outweigh disadvantages 

■ Source depletions should be included as 

a remediation goal (regardless of 

whether or not MCLs are likely to be 

achieved within the DNAPL source zone 

Private sector/regulated community: 

Though potential difficulties were 

acknowledged, this option was generally 

supported. 

Government agencies: The states that 

commented on it were not supportive and 

thought the information needed to 

accomplish it is not available. EPA 

comments tended to be technical in nature 

and neutral on whether or not to move 

forward with this option. 

Option 7: Develop guidance on 

performance measures for the 

effectiveness of DNAPL mass removal, and 

on how to determine when active DNAPL 

removal efforts should be discontinued. 

Such measures could include trend analysis 

for mass removal rates, mass flux data, or 

other parameters for gauging remedy 

performance. 

Private sector/regulated community: 

Option 7 had strong support from the 

private sector/ regulated community. 

Dissenters either believed it was 

premature to write a guidance, given the 

state of the art, or existing guidance 

already addresses this issue. 

Government agencies: EPA comments 

tended to be technical in nature and 

neutral on whether or not to move 

forward with this option. The Interstate 

Technology Regulatory Council (ITRC, a 

state workgroup) has developed a 

technical guide on this issue.

Option 8: Develop guidance describing 

improved methods for comparing long-term 

remedies. The guidance would allow a 

more realistic accounting of the costs and 

other disadvantages of long-term custodial 

care. This would include long-term costs of 

maintaining containment systems, 

equipment replacement, monitoring and 

enforcing institutional controls, and site 

monitoring. 

Private sector/regulated community: Most 

of the comments on this option were from 

the private sector/regulated community 

and either supported developing the 

guidance or provided technical input that 

was neutral on implementation. The 

dissenting comments questioned its 

usefulness. 

Government agencies: EPA comments 

tended to be technical in nature and 

neutral on whether or not to move 

forward with this option. 

* * * * * 

Additional Options Suggested by 

Commenters on the DNAPL Paper 

In addition to thoughts on the options 

presented in the DNAPL paper, many 

commenters offered other ideas for EPA to 

consider. Some of these suggestions were 

unclear or overly broad (e.g., EPA should 

change its entire approach to cleanup). 

From these suggestions, the task force 
 14

found that the following nine were worthy 

of further consideration. 

1. All Records of Decision (RODs) should 

have required language to indicate 

whether DNAPLs are present at a 

ground water remedy site and whether 

remedial actions will have significant 

benefit based on conditions at the site. 

Ground water RODs with pump and 

treat as the selected remedy should be 

subjected to external scientific peer 

review. 

2. Set up a system of rewarding mass 

removal of DNAPL regardless of the 

fraction of total mass that it 

represents. This suggestion pertains to 

Problem Statements 1 & 2, in 

particular. Site owners and regulators 

are more likely to collaborate if 

success can be envisioned. A 

quantitative value can be attached to a 

pound of DNAPL removed from the 

subsurface environment with a simple 

economic analysis. Each site’s 

regulator and owner would be tasked 

with achieving a covenant as to how 

the value of the DNAPL removed would 

be applied to offsetting the present or 

future cost of compliance. Examples of 

these offsets include monitoring 

reduction and reporting relief. 

3. EPA should standardize the use of 

indicators that identify decreasing 

effectiveness of pump-and-treat 

systems (e.g., declining mass removal 

rates) and provide an agreed upon 

metric for determining when further 

reductions are not technically feasible. 

4. EPA should compile a comprehensive 

DNAPL annotated bibliography (for 

Internet access) of references, 

research, organizations (e.g., 

academic, industry, and government), 

and their respective web 

links/addresses. 

5. EPA should establish a more consistent 

framework for setting site-specific 

goals for ground water remediation. 

Such a framework should take into 

account the priority of public health 

protection, use, and value of the 

ground water unit in question, and a 

realistic approach to ground water 

remediation. 

6. EPA should produce a guidance that 

provides site owners and 

regulators/site managers with more 

information with which to make 

decisions (e.g., DNAPL source zone 

definition, mass flux, risks impacted, 

site cleanup difficulty ranking, aquifer 

value and vulnerability, site value). 

This type of site information must be 

developed first before a decision is 

made about whether a TI is 

appropriate or not. 

7. EPA should develop new guidance 

explicitly on how to assess the remedy 

for DNAPL sites under the remedy 

selection criteria provided in the 

Superfund National Oil and Hazardous 

Substances Pollution Contingency Plan 

(NCP).7

8. EPA should fund the research areas 

suggested in the Kavanaugh-Rao 

report. (M. Kavanaugh and S. Rao, cochairs, 2004. The DNAPL Remediation 

Challenge: Is There a Case for Source 

Depletion? EPA/600/R-03/143. Office 

of Research and Development, EPA.) 

9. EPA should sponsor a team of experts 

that will go to a variety of sites across 

the country that have undergone or are 

about to undergo a source depletion 

remediation. The EPA experts (along 

 

7

 National Oil and Hazardous Substances 

Pollution Contingency Plan (NCP); Final Rule, 

Federal Register 55, no. 46:8706 and 8733-34, 

March 8, 1990. The NCP provides the regulatory 

framework for the Superfund program. 
 15

with those from other agencies or from 

industry, as appropriate for a 

particular site) will determine if site 

conditions are properly characterized 

and will ensure that performance 

monitoring instrumentation is in place 

to determine the short- and long-term 

effects of the source depletion. The 

ensuing data set will provide hard 

evidence that is acceptable to both 

sides (EPA/states and industry) on the 

benefits, if any, of source depletion in 

different hydrogeologic settings. 

* * * * * 

General Themes in Comments on DNAPL 

Paper 

In addition to specific comments on the 

options themselves there were several 

overarching themes within the comments 

submitted for the DNAPL paper by the 

different groups. 

Private sector/regulated community 

Commenters from the regulated 

community felt that EPA could exercise a 

great deal of flexibility in setting goals for 

the cleanup of DNAPL sites, but rarely did. 

There was some concern about an overly 

rigid interpretation or lack of 

consideration of what constitutes a 

“reasonable time frame” for achieving 

cleanup goals. 

It was suggested that EPA change its 

overall approach to site cleanup and adopt 

a risk- based one, limiting the 

interpretation of “risk-based” to current 

use and exposure of a contaminated 

resource (e.g., ground water) and 

excluding future uses for purposes of 

setting current cleanup goals. 

Many commenters also cited as an issue a 

lack of data to support source removal 

decisions. 

There was far more uncertainty in 

predicting the success and cost of source 

removal technologies, which some felt are 

experimental, than with more proven 

technological approaches, such as 

containment. 

In addition, they believe that given the 

current state of knowledge, the benefits 

of source removal are at best conjectural.

Government agencies 

There was considerable support for 

keeping MCLs as the cleanup goals for 

source zones for the following reasons: 

they encourage source zone cleanup; they 

encourage development of innovative 

technologies; and they may, by forcing 

source zone depletion actions, allow MCLs 

to be achieved at the property line. 

Several commenters voiced the opinion 

that waiving stringent goals, such as MCLs 

undervalued the resource in order to 

justify short-term cost savings that may 

very well result in higher costs in the 

future. 

A state commenter, taking a different 

tack, said that several states had 

embraced risk-based corrective action 

(RBCA) and were applying it to set cleanup 

goals at DNAPL sites.
 16

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 17

Stakeholder Input on Ground Water 

Use, Value, and Vulnerability as 

Factors in Setting Cleanup Goals 

Paper and Options

This section summarizes review comments 

on the options provided in the UVV paper, 

lists new options recommended by 

reviewers, summarizes general comment 

themes that did not specifically address 

the original options, and presents the 

GWTF’s recommendations. 

* * * * * 

Comments on Ground Water Use, Value, 

and Vulnerability Paper Options 

The final deadline for submitting 

comments was September 24, 2004. As of 

that date, 33 comments on the UVV 

options paper had been received. Of the 33 

comments, 24 were from government 

agencies (9 states and 15 federal 

headquarters and regional offices), and 9 

were from the private sector/regulated 

community (5 industry associations or 

companies, 3 consultants, and 1 federal 

facility). No comments were received from 

environmental advocacy groups or public 

interest groups. Comments from non-EPA 

reviewers are available on the task force 

website at: http://gwtf.cluin.org. 

The UVV paper evaluated four problem 

statements and offered seven potential 

options that might be adopted to help 

solve them. Although the options were 

intended to address at least one problem 

statement, overlap exists. The paper 

invited commenters to propose additional 

options if they so desired. 

Option 1: Develop a series of educational 

fact sheets and Internet training seminars, 

targeted primarily to government officials 

and members of the regulated community 

to raise awareness of ground water UVV; 

interconnection between ground water and 

surface water systems; and health impacts 

from contaminants most commonly found 

in ground water. This effort would include 

summaries of the findings from the 

upcoming Ground Water Report to 

Congress.

General: This option received a moderate 

number of direct comments, but many 

more commenters supported the need for 

educational efforts in a variety of areas. 

Private section/regulated community: 

Positive commenters supported the option 

in general with specific suggestions on how 

it could be implemented. One commenter, 

however, thought that it would not 

provide much information beyond what is 

already available. 

Government agencies: There were both 

positive and negative government agency 

comments. The positive comments 

generally identified specific issues the 

commenters thought should be addressed 

with education efforts, while the negative 

commenters generally thought other 

options would be more effective. Some 

thought that the description of this option 

did not adequately emphasize educating 

people on the need to protect ground 

waters that currently support ecosystems 
 18

and ground waters that may be needed as 

a future source of drinking water. 

Option 2: Conduct research on the impacts 

on other developed nations that have 

resulted from either the presence or lack 

of strong ground water protection 

programs. 

General: While several commenters 

thought studying selective foreign ground 

water protection policies might prove 

useful, the majority of commenters (both 

private sector/regulated community and 

government agencies) did not think it 

would be effective in addressing any of the 

problems put forth in the paper, especially 

in times of limited resources. 

Option 3: Develop summaries of how 

individual EPA and state cleanup programs 

consider ground water UVV in setting 

cleanup goals (e.g., ground water 

classification and classification exception 

systems, ground water management zonetype approaches). These summaries would 

be written with Internet links to more 

detailed resources. EPA would provide 

access to these summaries via its One 

Cleanup Program website. This option 

could also involve low-cost Internet 

training to raise awareness of the range of 

approaches being used by EPA and states. 

Private sector/regulated community: 

Option 3 was generally opposed by the 

commenters as not providing an 

implementable solution. Several 

commenters, however, thought it would 

be a useful exercise for discussion and 

developing guidance and another said they 

had already performed a similar exercise 

and it pointed out the many 

inconsistencies in the various state 

programs and the need for guidance to 

correct these inconsistencies. 

Government agencies: Several regulatory 

agencies (both state and federal) were in 

favor of this effort. One state commenter 

did not think highlighting differences in 

state and federal programs was a good 

idea, though the commenter did support a 

study that examined state and federal 

programs with the goal of highlighting 

strong points. Some thought that this 

option would negatively impact states that 

have a conservative approach to protecting 

ground water resources. 

Option 4: Takes option 3 one step further 

by developing an EPA policy memo that 

explains how EPA cleanup programs 

acknowledge the various approaches used 

by states in setting ground water cleanup 

goals based on ground water UVV. For 

example, the policy statement would 

clarify how state ground water 

management zone policy could influence 

goals established under EPA’s cleanup 

programs. Internet training could also be 

used to increase awareness and 

understanding of the policy statement. 

Private sector/regulated community: 

Regulated community comments on this 

option were mixed. Some did not think 

that this option would lead to any changes 

that they would favor. Others said that 

such a policy should be expanded to 

promote greater use of existing program 

flexibilities, with more emphasis on “riskbased” cleanup decisions rather than 

restoration of ground water in every 

situation. 

Government agencies: Government agency 

comments were also mixed. Some EPA 

commenters thought that such a policy 

would be very helpful. Others, mainly 

state commenters, thought that this 

option would somehow hinder state efforts 

to protect resources. Others thought that 

such a policy should also address the need 

to protect ground waters that currently 

support ecosystems and ground waters 

that may be needed as a future source of 

drinking water. 
 19

Option 5: Using information from federal 

and state cleanup programs, develop a 

general framework that describes how to 

prioritize sites according to problem 

severity and ground water UVV. This 

framework would clearly describe how 

ground water UVV as well as specific 

problem magnitude (e.g., risk) can be used 

to prioritize sites and influence remedial 

decisions. This framework would describe 

how a prioritization system directed at 

site-specific ground water problems can 

work within statewide general 

classification systems and how, for 

example, ground water management zone 

policy could influence goals established 

under EPA’s cleanup programs. 

General: This option generated a number 

of comments that were equally split 

between support and opposition. On the 

support side, many commenters thought it 

would be a good idea to bring UVV 

concepts into a useable framework to aid 

in prioritizing site cleanups. Speaking 

against this option, other commenters 

thought it would be difficult or unwise to 

implement, and several pointed out that it 

seemed to be similar to the 

Comprehensive State Ground Water 

Protection Program (CSGWPP) initiative, 

which has been implemented by only a few 

states. 

Option 6: Use defined Source Water 

Assessment Program (SWAP) areas 

(required by the 1996 amendments to the 

Safe Drinking Water Act) to promote 

consistency in ground water cleanup 

decision making. The option would involve 

establishing a means to encourage 

stakeholders to become more aware of and 

involved with various ground water 

cleanups taking place within or near an 

individual Source Water Assessment Area. 

The objective would be that cleanups 

could be selected to maximize efficiencies 

and benefits within a particular source 

water area. 

Private sector/regulated community: 

Commenters were generally in support of 

this option. One consultant, however, 

thought it would be difficult to 

implement. 

Government agencies: Government 

commenters were generally in favor of this 

option, with one pointing out the necessity 

of including private well locations in the 

pool and another cautioning about the 

uneven quality of the state SWAP 

designated areas. Some thought that this 

option ignores the need to protect ground 

waters that currently support ecosystems 

and ground waters that may be needed as 

a future source of drinking water.

Option 7: Promote and provide funding 

assistance for regular meetings within an 

individual state or watershed that brings 

together the various programs and 

stakeholders involved with ground water 

cleanup and protection. One of the 

objectives of these meetings would be to 

help prioritize cleanup actions based on 

factors, such as magnitude and extent of 

ground water contamination, as well as 

ground water UVV. 

General: While Option 7 received some 

positive comments, the majority of the 

commenters were against implementing 

this option, with one pointing out the 

potential cost of doing this on a 

nationwide scale. 

* * * * * 

Additional Options Suggested by 

Commenters on the Ground Water Use, 

Value, and Vulnerability Paper 

In addition to thoughts on the options 

presented in the DNAPL paper, many 

commenters offered other ideas for EPA to 

consider. Some of these suggestions were 

unclear or overly broad (e.g., EPA should 

change its entire approach to cleanup). 

From these suggestions, the task force 
 20

found that the following twelve were 

worthy of further consideration.

1. A study should be done to assess the 

success of current ground water 

cleanups in protecting source water 

protection zones. 

2. EPA needs to clarify or modify its 

definition of what constitutes a 

potential (future) source of drinking 

water under the Superfund program. 

3. EPA should develop a guidance that 

better defines how the ground water 

classification or valuation established 

within the current regulatory 

framework is used in conjunction with 

other factors to establish a 

“reasonable time frame” for ground 

water restoration. A second 

commenter suggested that EPA develop 

a guidance document discussing time as 

a cleanup parameter. 

4. EPA should provide guidance to the 

states that would allow more 

flexibility in interpreting nondegradation rules. 

5. EPA should develop guidance on 

determining cleanup levels for nonpotable ground water pathways, such 

as those for irrigation water. 

6. EPA should conduct a study on how 

many cleanup sites were caused or 

exacerbated by shallow injection wells. 

7. Establish a forum for sharing GIS 

information on the extent of ground 

water plumes and source water 

assessment areas. 

8. EPA should develop a reliable tracking 

and mapping system for contaminated 

areas that can be used by future 

resource developers. 

9. EPA should make an effort to get the 

U.S. Census Bureau to reinstate a 

question about private well use that 

was in the 1990 census but not in the 

2000 census. These data are very 

valuable in evaluating the vulnerability 

of private wells from contaminated 

sites. Currently the government only 

tracks public water systems. 

10. Develop an annotated, web-based 

bibliography of regulatory and 

technical resources. 

11. Develop educational materials for use 

in public participation programs. 

12. Develop a national policy statement 

regarding overall ground water goals 

for the Agency. This statement should 

reflect the overall view that 1) no 

aquifer will be degraded, and 2) any 

degraded aquifer ultimately needs to 

be restored to its natural condition. 

* * * * * 

General Themes In Comments on Ground 

Water Use, Value, and Vulnerability 

Paper 

In addition to specific comments on the 

options themselves, several overarching 

themes were identified within the 

commenter groups. 

Private sector/regulated community 

State and federal treatment of ground 

water UVV is a patchwork of regulations 

and practices. 

EPA needs to provide a more consistent 

framework for setting site-specific goals 

for ground water remediation. Underlying 

much of the argument is the concept of 

the value of ground water, which is very 

subjective, and there are no commonly 

acceptable methods for evaluating it. 

Any definition of reasonably expected uses 

needs to be based on economic (e.g., well 

yield and value of property) and riskrelated factors (e.g., water quality and 

exposure). EPA needs to adopt a risk based 
 21

approach to site cleanup. The Agency 

should limit the interpretation of “risk 

based” to current use and exposure of a 

contaminated resource (e.g., ground 

water) and exclude future uses for 

purposes of setting current cleanup goals. 

There is a need to prioritize site cleanups 

so that limited resources are targeted 

towards actions that have the greatest 

benefit to human health, the 

environment, or ground water resources. 

Government agencies 

Commenters thought a goal using 

“reasonably expected” uses was too vague 

and the program should keep the 

statement “return to potential future 

uses” as its goal. 

Too little consideration of future drinking 

water demands was given in the paper in 

considering future uses. One commenter 

suggested the Agency should be involved in 

evaluating increasing ground water 

demand in various regions of the country 

to allow for better decision making. 

Most options focus too much on protecting 

current sources of drinking water and 

ignore the need to protect ground waters 

that currently support ecosystems and 

ground waters that may be needed as a 

future source of drinking water. 

Another commenter gave a real-life 

example of a brackish aquifer near a city 

for which drinking water would not have 

been considered a reasonably expected 

use, but now it has been designated an 

aquifer for drinking water and the city is 

constructing a desalinization plant.
 22

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 23

Task Force Recommendations

As discussed in the stakeholder comments 

sections, a range of potential options was 

included in each of the two discussion 

papers prepared by the task force. In its 

deliberations, the task force considered 

the information presented in the discussion 

papers, comments received on the options 

presented in each paper, additional 

options suggested by commenters, and the 

general themes of comments from various 

stakeholders. 

 

In developing its recommendations the task 

force divided its work into two subgroups, 

one for each discussion paper. Initially the 

subgroups looked for ways to consider all 

of the input received on the papers in 

developing recommendations. Each 

subgroup decided that recommendations 

would not necessarily be based solely on 

the paper options, but could include 

options suggested by commenters. 

Furthermore, when deemed appropriate, a 

single recommendation might combine 

several options from the papers. In later 

discussions each subgroup member was 

asked to list their top two or three 

recommendations, based on previous 

deliberations and their understanding of 

the issues. These results were tabulated 

and discussed. The discussions led to the 

task force making three recommendations 

for each paper that were tailored to allow 

some flexibility during implementation. 

Thus, the task force considered input from 

multiple EPA programs and stakeholders 

and followed a consensus approach in 

developing its recommendations. 

The task force did not attempt to review 

overall cleanup approaches or policies of 

individual EPA cleanup programs, except as 

necessary to provide background for issues 

presented in the two options papers. 

Deliberations of the task force focused on 

issues and potential options presented in 

the papers. The task force operated under 

the assumption that the existing statutory 

and regulatory framework governing EPA 

cleanup programs would not change. 

* * * * * 

Recommendations Concerning DNAPL 

Issues 

The GWTF developed the following 

recommendations to address issues 

identified in the DNAPL paper. The 

recommendations fall under three broad 

headings: policy/guidance, technology 

research and development, and 

information resources. 

Policy/Guidance

Recommendation 1. Develop guidance on 

how to acknowledge technical limitations 

posed by DNAPLs in EPA cleanup decisions, 

including updated guidance on the use of 

technical impracticability (TI) decisions in 

the Superfund program. The guidance 

should also discuss mechanisms for 

acknowledging technical limitations posed 

by site complexities other than DNAPLs. 

Goal: Prepare guidance on mechanisms 

for setting cleanup goals that 

acknowledge the presence of DNAPL 

sources and other types of site 

complexities. Answer questions that 

have arisen concerning the use of TI 

decisions in Superfund and RCRA 

Corrective Action programs, especially 

those concerning the decision process. 

Rationale: The following issues or 

questions concerning TI decisions were 

identified in the DNAPL discussion 

paper: 

■ Factors indicating that a TI decision 

is warranted 
 24

■ Circumstances that would warrant 

revisiting a TI decision 

■ Content and/or format of a TI 

evaluation report 

■ Whether a simplified (or 

streamlined) TI decision process can 

be applied to operating remedies 

■ Whether the TI decision process can 

be used to encourage use of 

innovative technologies 

■ Mechanisms other than TI for 

recognizing site complexities or 

technology limitations and adjusting 

cleanup goals in Superfund and 

other cleanup programs 

Addressing these and other questions 

will help clarify EPA expectations 

concerning use of TI decisions and 

dispel many misconceptions that were 

mentioned by reviewers and GWTF 

members. Although state reviewers 

indicated a general dislike for TI 

decisions, the GWTF concluded that 

many of these concerns can be 

addressed by updated guidance. 

TI decisions are an important 

component of the Superfund program 

because statutory provisions concerning 

“applicable or relevant and appropriate 

requirements” (ARARs) and ARAR 

waivers are unique to the Superfund 

program. Cleanups conducted under 

Superfund are required to meet ARARs 

or waive them using one of the waiver 

provisions specified in the statute (such 

as, TI). 

Next Steps: Form a cross-program 

workgroup to scope out and complete 

this guidance project. For example, the 

guidance workgroup would determine: 

■ Topics to be addressed in the 

updated guidance 

■ Whether it is better to complete a 

single document or multiple fact 

sheets 

■ Whether guidance should be 

expanded to include applicability of 

TI decisions to other types of source 

areas, such as LNAPLs or metals 

■ Mechanisms other than TI for 

setting cleanup goals different from 

drinking water standards 

■ Project schedule 

■ Other issues concerning this project

Technology Research and Development

Recommendation 2. Develop 

recommended data needs and procedures 

for documenting and tracking DNAPL 

source zone cleanup efforts so that 

technology performance can be adequately 

assessed. Procedures are needed to better 

assess field research and testing 

(conducted by EPA and others) to develop 

promising technologies for remediation and 

characterization of DNAPL source zones.

Goal: Provide a scientific basis to 

determine whether DNAPL source 

depletion is a reasonable cleanup goal. 

Improve our understanding of the 

capabilities of source reduction 

technologies and long-term impacts of 

DNAPL source depletion on the 

dissolved contaminant plume (benefits 

and detriments). 

Rationale: Compilation of improved 

data sets from multiple sites are 

needed to provide the scientific basis 

for future EPA guidance concerning 

cleanup of DNAPL source zones. One of 

the findings of a recent EPA-sponsored 

expert panel report was that even 

though numerous field trials (pilot tests 

and full-scale remedies) of DNAPL 

recovery technologies have been 
 25

completed, documentation of the tests 

has often been insufficient to quantify 

the degree of source reduction 

achieved or to assess the long-term 

effects on the dissolved contaminant 

plume. The expert panel also 

concluded that improved data sets 

from a variety of hydrogeologic settings 

should be compiled to provide insight 

on the types of benefits that may be 

achieved by partial depletion of DNAPL 

sources, including long-term effects on 

ground water quality. The panel also 

recommended that such data sets be 

independently reviewed. 

Additional field research and testing 

(with well defined monitoring methods) 

is needed to further advance promising 

technologies for remediation and 

characterization of DNAPL source 

zones, and to better understand the 

effectiveness and appropriate 

application of these technologies at 

contaminated sites. Improved 

mechanisms for documentation and 

review of test results will increase the 

value of field research and testing for 

cleanup programs. Continued research 

and improved data sets are needed to 

provide the scientific basis for EPA 

guidance development on the 

remediation of DNAPL source zones. 

Comments from reviewers and from 

GWTF members indicate that guidance 

to assist site managers in determining 

the types of sites where DNAPL source 

depletion technologies should be 

implemented is badly needed. 

Next Steps: Form a team or similar 

body of EPA technical experts to make 

recommendations on how to instrument 

and monitor field testing and use of 

DNAPL source reduction technologies. 

This advisory body would identify a 

limited number of sites (e.g., one or 

two per EPA region) where DNAPL 

source treatment is to be tested or 

used as part of a remedy. The team 

would make recommendations 

concerning:

■ Sites where DNAPL source reduction 

technologies have been tested 

previously and further data 

collection is warranted (e.g., one 

site per EPA region) 

■ The types of additional data to be 

collected (including site 

characterization and long-term 

monitoring data) 

■ Methods for documenting and 

tracking long-term performance and 

impacts on the plume 

■ Independent review of site data 

sets 

■ Compilation of data for multiple 

sites 

Because of the complexity and cost of 

such an approach, partnerships with 

other federal agencies, universities, or 

other entities could be considered in 

establishing such a team (e.g., a 

“DNAPL technology advisory team”). 

The purpose of the data collection 

effort is to accumulate the data sets 

necessary to develop future EPA 

guidance on cleanup of DNAPL source 

zones (e.g., types of sites where source 

reduction should or should not be 

attempted, and cleanup goals for the 

source zone). 

Information Resources

Recommendation 3. Develop a web-based 

resource center for information related to 

cleanup and characterization of sites with 

DNAPLs, including links to existing policy, 

guidance, technology descriptions, and 

case studies, as well as resources such as 

fate and transport and chemical property 

tool calculators.
 26

Goal: A resource center for information 

concerning cleanup of DNAPL sites, 

including both technical resources and 

guidance. 

Rationale: There is a need for a 

website that serves as the starting 

point for finding information 

concerning cleanup of DNAPL sites and 

related information. Such a site would 

be a useful source of information for 

EPA and state site managers, cleanup 

contractors, community groups, and 

other stakeholders. There is no current 

EPA website specific to DNAPLs that 

serves this purpose. 

Existing EPA policies and guidance 

related to cleanup and characterization 

of sites with DNAPLs would also be 

linked to this website. Comments from 

reviewers and from the GWTF indicate 

that there is still some confusion 

regarding existing EPA policy, including 

whether EPA expects DNAPL source 

zones to be restored to drinking water 

standards at sites with such sources. 

Technical guidance on DNAPLs 

developed by others, such as the 

Interstate Technology Regulatory 

Council (ITRC), could also be linked to 

this website. 

Next Steps: Assign a project leader to 

develop the web resource center. 

Existing information on cleanup 

technologies, case studies, and 

guidance from EPA and non-EPA sources 

should be identified. The project 

leader would solicit comments from 

other programs in making final 

determinations of information to be 

linked to the website and the format of 

the website. 

The web resource center could include 

a list of experts available to answer 

questions concerning cleanup and 

characterization of DNAPL sites. This 

list could include experts on particular 

technologies, experts on requirements 

for EPA cleanup programs, and other 

sources of specific types of 

information. 

* * * * * 

Ground Water Use, Value, and 

Vulnerability Recommendations 

The GWTF found that there is little 

consensus at this time among stakeholders 

for recommending any significant shift in 

current policies to address issues identified 

in the Ground Water UVV options paper. 

Therefore, the GWTF developed the 

following recommendations which focus on 

providing educational resources and 

improving coordination among ground 

water cleanup and protection programs. 

Recommendation A. Develop a new webbased resource center for information 

related to the potential role of ground 

water UVV in cleanup decisions. The 

resource center would address items, such 

as interconnection between ground water 

and surface-water systems; the importance 

of ground water to ecosystems; health 

impacts from contaminants most commonly 

found in ground water; the potential for 

drinking water shortages and their effects 

on current ground water use 

classifications; federal protection policies, 

and exemplary state policies. 

Goals: Provide a source of information 

and educational materials that lay a 

foundation for understanding ground 

water UVV issues and give examples of 

how some states have used ground 

water UVV in making cleanup decisions. 

An example of a successful outcome of 

this effort would be that an interested 

member of the public used materials 

from the resource center to better 

understand a proposed remedy where 

ground water UVV were factors in 

setting cleanup goals. 
 27

Rationale: This recommendation 

evolved from Option 1, which referred 

only to educational fact sheets and 

Internet training seminars. Based on 

the comments supporting Option 1 and 

suggestions for other options from 

commenters, the GWTF broadened 

Option 1 into a web-based resource 

center. This recommendation received 

the broadest support by GWTF 

members. The GWTF concluded that 

information on ground water UVV and 

its potential role in cleanup decisions 

should be more easily available to 

government officials (particularly 

cleanup managers) and interested 

members of the public. Furthermore, 

this recommendation could help 

address many of the issues identified in 

the GWTF discussion paper (e.g., 

educate interested stakeholders about 

many state approaches used to account 

for ground water UVV in site-specific 

cleanup decisions). Educational tools 

would include the importance of 

protecting ground waters that currently 

support ecosystems, and ground waters 

that may be needed as a future source 

of drinking water. Notably, there were 

a number of comments, particularly 

from members of the regulated 

community, that education alone would 

not result in needed policy changes. 

Next Steps: Form a cross-program 

workgroup to scope out the project, 

paying particular attention to resources 

currently available through EPA’s 

Office of Ground Water and Drinking 

Water and the EPA Drinking Water 

Academy. 

Recommendation B. Request that the U.S. 

Census Bureau update the 1990 census 

information on sources of drinking water8

, 

 

8

 This information was collected in the 1990 

census and earlier but was excluded from the 

2000 census. The U.S. Census Bureau web page 

and develop tools to facilitate access to 

this information.

Goal: Successfully convince the U.S. 

Census Bureau to add a question to the 

2010 census pertaining to sources of 

drinking water, thereby updating 

information previously collected in 

1990. Information on the locations of 

private wells in all 50 states, would 

allow ground water cleanup and 

protection programs to identify areas 

where ground water is currently used 

as a source of drinking water for 

private homes.

Rationale: Information on private wells 

is not easily accessible and in some 

cases unavailable from other sources. 

This recommendation was offered by 

GWTF members after the 

issues/options paper was released for 

public comment; therefore, the GWTF 

did not receive comments for or against 

this recommendation. However, the 

GWTF did receive comments 

emphasizing growing demand on ground 

water resources due to population 

growth and drought conditions in many 

parts of the country. Members of the 

GWTF broadly supported this 

recommendation because only 

information on public drinking water 

systems is currently provided to EPA. 

Additional information on locations of 

private wells (at the census block group 

 

provides the following explanation as to why 

the question was removed, “Source of water 

and method of sewage disposal were not 

required or mandated items. Although many 

data users throughout the country found the 

information extremely useful, there are other 

sources at the state and local level where such 

information can be obtained; albeit, not all 

areas in the country collect these data 

uniformly or disseminate the information in a 

manner that is readily accessible to data 

users.” 
 28

level) would serve to further inform 

and educate government officials and 

other interested stakeholders about the 

use and value of ground water 

resources, as well as assist cleanup 

managers in setting remediation goals 

that are protective of both public and 

private uses of these resources. 

Next steps: Contact the U.S. Census 

Bureau to find out why the question on 

“source of water” was dropped from 

the 2000 census. Draft a letter from 

EPA to the U.S. Census Bureau 

requesting that this question be added 

to the 2010 census. The letter would 

explain the value of this information to 

ground water cleanup and protection 

programs. In addition, the Agency 

should develop Internet-based tools to 

facilitate access to the existing 1990 

census data by EPA program staff and 

the public and conduct training on the 

availability and utility of the existing 

data. These activities should be closely 

coordinated with EPA’s Office of Water 

and Drinking Water. 

Recommendation C. Develop approaches 

for using source water areas (SWA)9

, 

delineated by state drinking water 

programs, to promote collaboration among 

cleanup programs, drinking water 

programs, and stakeholders concerned with 

cleanup and protection of ground water 

resources. 

Goals: Increase collaboration among 

ground water cleanup and protection 

programs within particular source 

water areas. Specific examples of 

desired outcomes are cleanup 

managers would be able to find out 

easily if their sites are located in a 

 

9

 See 

http://cfpub.epa.gov/safewater/sourcewater/

protect/swap.html for more information about 

source water, source water assessments, and 

source water protection. 

designated SWA; and site 

characterization, risk assessments, and 

other information could be shared 

among cleanup managers for sites 

located within a particular SWA. This 

collaboration would provide an 

opportunity to agree on common 

cleanup approaches and standards, 

where appropriate. 

Rationale: Nearly all states have 

completed delineation of source water 

areas for all public drinking water 

systems in their state, including both 

ground water and surface water 

systems. Ground water within a source 

water area is currently used as a source 

of drinking water for public supply 

wells. Furthermore, the GWTF 

supported this recommendation 

because it recognized that the 

interconnection of ground water within 

a source water area makes it possible 

for a release from one site to affect 

ground water at another site. For these 

reasons, this recommendation received 

broad support from the GWTF and from 

reviewers. Some commenters pointed 

out that focusing only on source water 

areas would ignore ground water 

supplying private wells; combining this 

option with the Census 

recommendation will help to convey 

EPA’s interest in ensuring protection of 

both public and private drinking water 

supplies. 

Next Steps: Form a cross-program 

workgroup to scope out options for 

moving forward. One approach is to 

develop a memorandum of 

understanding (MOU), such as that 

developed between the Office of Water 

and the Office of Underground Storage 

Tanks (UST). This MOU would 

recommend that UST program 

managers use source water areas as a 

tool to help prioritize their activities 

(e.g., inspections, assessments, 

removals, final cleanups).
 29

Summary

In recognizing the importance of ground 

water to the nation’s drinking water supply 

and its critical role in maintaining the 

health of ecosystems, EPA established the 

Ground Water Task Force (GWTF) in the 

fall of 2002 as part of the Agency’s One 

Cleanup Program. The mission of the task 

force was to identify, and prioritize, 

ground water issues that will benefit 

multiple cleanup programs; and to make 

recommendations to EPA senior 

management on the best course of action. 

Task force members identified two topic 

areas for initial evaluation and developed 

“options papers” for each area. The 

papers are: “Cleanup Goals Appropriate for 

DNAPL Source Zones” and “Ground Water 

Use, Value and Vulnerability as Factors in 

Setting Cleanup Goals.” The task force 

reviewed cleanup policies associated with 

these topic areas, but did not review 

overall Agency policies concerning cleanup 

of contaminated ground water. 

For DNAPL source zones, the issues are 

centered around determining cleanup goals 

appropriate for the source zone, and 

whether remediation should be undertaken 

to remove or treat the DNAPL sources. 

These decisions are difficult because the 

various outcomes may contain a high 

degree of uncertainty due to incomplete 

information regarding the extent of the 

source zone and the effectiveness of the 

technologies. The GWTF believed that 

implementation of the DNAPL 

recommendations will greatly aid 

practitioners in making decisions on source 

zone cleanup. Providing Agency tools such 

as an updated guidance on ways to 

acknowledge complex site conditions in 

cleanup decisions (e.g., TI decisions in 

Superfund), an EPA website that provides 

current information on characterization 

and remediation technologies, and EPA 

guidance related to DNAPLs, will help meet 

near term needs of cleanup programs. In 

addition, continuing to support technology 

demonstrations, while providing a 

mechanism for properly evaluating field 

applications of DNAPL source cleanups, will 

help expand the scientific basis for 

evaluation of the likely benefits of source 

cleanups, and provide the foundation for 

future Agency guidance. 

Ground water use, value and vulnerability 

issues are more related to consistent 

application of remedies within a watershed 

or aquifer system and the philosophic 

questions of what needs to be protected 

and why. There was little consensus among 

stakeholders on how these issues should be 

approached. The regulated community for 

the most part advocated a risk based 

present use approach while the 

government commenters preferred to 

evaluate an aquifer for its present and 

future uses as well as how it fits into the 

overall ecosystem. However, by 

implementing the recommendations on 

ground water use, value, and vulnerability 

issues, the GWTF believed the agency will 

attain more consistency within its ground 

water cleanup programs and promote a 

better understanding among all 

stakeholders of the part evaluation of 

aquifer use, value, and vulnerability play 

in making cleanup decisions. 
 30

Page intentionally left blank 
 

 A-1

Attachment A 

Discussion Paper: 

Cleanup Goals Appropriate 

for DNAPL Source Zones 

This paper reflects the GWTF’s research, analysis and findings as of May 10, 2004 when 

it was originally posted at http://gwtf.clu-in.org/papers/. The version of the paper included in 

this report has been modified to reflect updates to web links that were available as of December 

2007. Note that Kenneth Lovelace is no longer the contact for this issue paper as mentioned on 

page A-4. For more current information on the subject, contact either Matthew Charsky 

(charsky.matthew@epa.gov) or Linda Fiedler (fiedler.linda@epa.gov) of OSWER’s Superfund 

program. 
 

 A-2

Page intentionally left blank 
 

 A-3

Cleanup Goals Appropriate for 

DNAPL Source Zones 

Introduction 

Notice: It is very important to note that this paper has been prepared by EPA’s Ground Water 

Task Force for informational purposes only. This paper does contain some discussion 

summarizing EPA’s statutory authorities and regulations. However, this paper does not 

constitute an EPA statute or regulation and does not substitute for such authorities. In 

addition, the statements in this paper do not constitute official statements of EPA’s views 

and are not binding on EPA or any party. 

This options paper is being developed by EPA’s Ground Water Task Force, a workgroup 

established under the “One Cleanup Program” of the Office of Solid Waste and Emergency 

Response (OSWER).1

 This task force is comprised of EPA and state regulatory officials, and was 

formed to: 

■ serve as the main technical/policy/communication/networking resource for OSWER on 

ground water issues; 

■ promote cross-program coordination and communication on technical and policy issues 

related to the cleanup of contaminated ground water; 

■ identify and prioritize and work to solve and/or provide guidance on ground water issues 

and projects that will benefit multiple programs; and 

■ assign subgroups to work on priority issues, and/or make recommendations to EPA senior 

management on the best course of actions for such issues. 

In carrying out its purpose, Ground Water Task Force representatives discussed with Senior 

EPA and state program managers a variety of implementation challenges cleanup programs 

face with respect to setting ground water cleanup goals.2

 One of those challenges, which was 

identified as a priority issue, is differing perspectives on what cleanup goals are appropriate 

for that portion of the contaminant plume where dense non-aqueous phase liquids (DNAPLs) 

are present in the subsurface (the DNAPL source zone). The purpose of this paper is to 

promote dialogue on this issue. It provides a brief background on DNAPLs as a source of 

contamination, differing stakeholder points of view (based on written or anecdotal input) 

with respect to challenges posed by DNAPLs, and potential options for addressing these 

problems. Stakeholders include federal and state regulatory officials, and members of the 

regulated community, as well as environmental and public interest groups. The Ground Water 

 

1

 For more information concerning the EPA’s One Cleanup Program, refer to 

http://www.epa.gov/oswer/onecleanupprogram/ . For more information concerning the One Cleanup 

Program Ground Water Task Force, refer to http://gwtf.cluin.org/ . 

2

 Oral presentation and discussion on March 4, 2003 before the Cleanup Programs Council, an advisory 

group for the OSWER One Cleanup Program.
 

 A-4

Task Force recognizes that other problems and options may exist, and no decisions have been 

made at this point with respect to which option(s) the Agency may pursue. Readers are 

encouraged to provide their comments on the paper and to suggest solutions they believe the 

Agency should consider to address the problems stated in this paper and/or other problems 

not mentioned herein. As conveyed in this document, any additional option submitted should 

describe the particular problem(s) it would address, as well as its associated advantages and 

disadvantages. These comments will be used in planning future activities of the task force 

and in developing recommendations for EPA senior managers on a course of action to address 

the issues raised in this paper. 

Questions or comments concerning this paper should be directed to Kenneth Lovelace and 

sent via email to gwtf@emsus.com by July 31, 2004. Copies of this paper can be obtained 

from the Ground Water Task Force website: http://gwtf.cluin.org. 

EPA recognizes that some stakeholders are concerned that raising issues addressed in this 

paper may generate pressures to change existing approaches, promote debates that slow 

down cleanup decisions, and ultimately affect the ability of regulatory programs to impose 

and achieve cleanup goals. However, the task force believes that avoiding these issues would 

not be responsive to other concerns raised during stakeholder meetings held by the Agency in 

2003 concerning the goals of the One Cleanup Program. Additional stakeholder meetings are 

planned specifically for this and other options papers developed by the task force. By 

including states on the task force and promoting public dialogue on these ground water 

issues, the agency is attempting to fairly balance all of these concerns. 

Issue Background 

DNAPLs as a Source of Contamination 

A non-aqueous phase liquid (NAPL) is a chemical or mixture of chemicals that do not readily 

mix with water. In water, NAPLs form a separate liquid phase and do not readily dissolve. 

Dense NAPLs (DNAPLs) sink while light NAPLs (LNAPLs) float. DNAPLs include chemical 

compounds and mixtures with a wide range of chemical properties, including chlorinated 

solvents, creosote, coal tar, and polychlorinated biphenyls (PCBs). After a spill, DNAPLs 

migrate into the subsurface resulting in disconnected blobs of liquid referred to as “residual 

DNAPL,” and continuous distributions of DNAPL sometimes referred to as “pools.” Residual 

and pooled DNAPL occupy pore spaces within granular media (e.g., soil) or fractures in 

bedrock. DNAPL pools can be mobile or potentially mobile. 

The DNAPL source zone is that portion of the subsurface containing residual and/or pooled 

DNAPL. Ground water flowing through the source zone dissolves some of the DNAPL, giving 

rise to aqueous phase plumes of contamination hydraulically down-gradient of the source 

zone. A plume may also result from precipitation infiltrating through residual DNAPLs (or 

LNAPLs) located in the unsaturated zone (above the water table). Since DNAPLs are only 

slightly soluble in water, DNAPL source zones can persist for many decades and in some cases 

for the foreseeable future. Volatile constituents within the DNAPL may continue to release 

vapor phase contamination to the unsaturated zone or the surrounding ground water. Thus, 

the nature of the contamination problem at DNAPL sites has two components: 1) the DNAPL 

source zone, and 2) the aqueous phase plume (and may also include vapor phase 

contamination in the unsaturated zone). 
 

 A-5

Some DNAPLs, such as chlorinated solvents, are much denser than water and very mobile in 

the subsurface. A large DNAPL spill can sink below the water table, spreading laterally as it 

encounters finer grained layers, and may extend to the base of an aquifer. Pooled DNAPL can 

migrate due to gravity along the top of down-ward sloping geologic layers or along fractures, 

and the flow path can be in a direction different from the ground water flow. Pooled DNAPL 

can also penetrate into deeper aquifers by migrating along fractures in confining layers. For 

these reasons, delineating the subsurface extent of the DNAPL source zone can be a 

substantial undertaking. At many sites, DNAPLs are suspected but have not been observed in 

the subsurface. For other sites, DNAPLs have been observed at some locations but the extent 

of the DNAPL source zone has not been distinguished from the overall plume. 

The number of CERCLA3

 (i.e., Superfund) sites or RCRA4 Corrective Action facilities with 

DNAPL source zones is uncertain. However, in the early 1990s, the Superfund program 

reviewed existing site investigation data from a sample of 712 sites in order to estimate the 

extent of the DNAPL problem. Results were presented in a 1993 report, which concluded that 

“...approximately 60% of all NPL sites exhibit a medium to high likelihood of having DNAPLs 

present as a source of subsurface contamination” (EPA, 1993a; page x). 

EPA Cleanup Goals 

The goal for ground water remediation at Superfund sites and RCRA Corrective Action 

facilities is to protect human health and the environment, typically using a combination of 

short-term measures (e.g., providing alternative water supplies) and long-term measures 

intended to return contaminated ground water to quality consistent with its designated 

beneficial uses. In general, ground water has been designated by states as current or future 

sources of drinking water, although a number of states are looking at other approaches in 

designating ground water based on use, value, and vulnerability. (See task force options 

paper: Ground Water Use, Value and Vulnerability as Factors in Setting Cleanup Goals.) For 

ground water designated as current or future sources of drinking water, long-term (i.e., final) 

cleanup goals typically include returning contaminated ground water to drinking water 

standards (e.g, federal maximum contaminant levels (MCLs) or state MCLs).5

 For Superfund 

sites and RCRA Corrective Action facilities where returning the plume to MCLs is a cleanup 

goal, MCLs are typically to be attained within the contaminated aquifer and throughout the 

plume. Thus, long-term cleanup goals at most Superfund sites and RCRA Corrective Action 

facilities include attainment of drinking water standards throughout the plume of 

contaminated ground water, which may include the DNAPL source zone (if present) as well as 

the aqueous contaminant plume. 

Long-term cleanup goals for Superfund sites and RCRA Corrective Action facilities do not 

always include attaining MCLs throughout the plume. For ground waters that are not 

designated by states as current or future sources of drinking water, drinking water standards 

 

3

 The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) was enacted 

in 1980, and amended in 1986. 

4

 The Resource Conservation and Recovery Act (RCRA) was enacted in 1976, and amended in 1984. 

5

 Federal Maximum Contaminant Levels (MCLs) established under the Safe Drinking Water Act (enacted 

in 1974, amended in 1996), and related information are available online at: 

http://www.epa.gov/OGWDW/mcl.html .
 

 A-6

are generally not used as cleanup levels and alternative cleanup goals are typically 

established, such as control of sources and containment of the plume. Also, where the 

remedy calls for on-site management of waste materials (such as a landfill), cleanup levels 

generally do not need to be attained in ground water beneath the waste management area. In 

such cases, attaining MCLs throughout the plume applies only to that portion of the plume 

outside the waste management area. Furthermore, both the Superfund and RCRA Corrective 

Action programs generally allow alternative cleanup goals to be established at sites where 

attaining MCLs throughout the plume is determined to be technically impracticable (TI). Both 

of these EPA cleanup programs also establish alternate cleanup limits (ACLs) in lieu of MCLs, 

under appropriate circumstances. However, ACLs defined under CERCLA are somewhat 

different from those in RCRA Corrective Action.6

 Some state cleanup programs have provisions 

for establishing contaminated ground water containment or management zones. Within such a 

zone, active cleanup of contaminated ground water may be deferred or may not be required. 

The specifics of how containment or management zones are defined, and what alternative 

cleanup goals are applied, differ from state to state. 

Cleanup Technologies 

For the reasons discussed above, sites where DNAPLs are present in the subsurface are very 

difficult to clean up to drinking water standards. Cleanup technologies applicable to these 

sites often include individual approaches or various combinations of approaches intended to 

control migration of contaminants (containment), remove contaminants from the subsurface 

(extraction), or treat contaminants in place (in-situ treatment). Each of these technology 

types have been used (with varying degrees of success) on DNAPLs in the source zone or on 

dissolved contaminants in the plume. 

Over the past two decades, significant advancement has been made in the development of 

these technologies, especially those intended to remove or treat DNAPLs in the source zone. 

However, site owners and cleanup managers have been reluctant to implement these 

technologies. Potential reasons for the limited application of source-zone depletion 

technologies include uncertainties with respect to: 1) actual extent of the DNAPL sourcezone, 2) whether MCLs can be attained in the source zone, 3) predicting benefits and adverse 

impacts of DNAPL depletion where MCLs are not likely to be attained, and 4) the acceptability 

of cleanup goals other than MCLs (EPA, 2003). 

Potential Benefits and Impacts of DNAPL Mass Reduction 

Reducing the quantity of DNAPL mass in the source zone can have several potential benefits, 

regardless of whether MCLs can be attained in the source zone. A recent national panel report 

specifically addresses cleanup of DNAPL source zones. This panel, convened by EPA’s Office of 

Research and Development, completed a report titled: The DNAPL Remediation Challenge: Is 

There A Case For Source Depletion? The Executive Summary of this report provides the 

following conclusions regarding the potential benefits of DNAPL mass depletion (EPA, 2003; 

page xi): 

 

6

 ACLs used in the Superfund program are defined in CERCLA 121(d)(2)(B)(ii). Guidance for use of ACLs 

in RCRA is provided in EPA, 1987. 
 

 A-7

Regardless of the site owner, there is a range of benefits, from a risk management 

perspective, that may result from DNAPL source-zone depletion. These include explicit 

benefits such as: 1) mitigating the future potential for human contact and exposure 

through long-term reduction of volume, toxicity, and mobility of the DNAPL, 2) mitigating 

the future potential for unacceptable ecological impacts, 3) reducing the duration and 

cost of other technologies employed in conjunction with the source removal technology, 

and 4) reducing the life-cycle cost of site cleanup. These benefits can be achieved if the 

source depletion option can result in the following outcomes: 1) reduction of DNAPL 

mobility, if mobile DNAPL is present, 2) reduction in environmental risk to receptors; 3) 

reduced longevity of ground water remediation, and 4) reduction of the rate of mass 

discharged from the DNAPL source zone. These outcomes could then lead to enhanced 

efficiency of complimentary technologies used for ground water remediation as well as 

potential reduction in life-cycle costs. Implicit benefits of DNAPL source-zone depletion 

include: 1) minimizing risks of failure of long-term containment strategies, 2) mitigating 

public stakeholders’ concerns, 3) enhancing a company’s “green image” as stewards of 

the environment, and 4) minimizing future uncertain transaction costs associated with 

management of the site. 

The 2003 national panel report also summarized the potential adverse impacts of DNAPL mass 

depletion as follows (EPA, 2003, page xi): 

Adverse impacts of DNAPL source depletion could include: 1) expansion of the DNAPL 

source zone due to mobilization of the residual DNAPL, 2) undesirable changes in the 

DNAPL distribution (i.e., DNAPL architecture), and 3) undesirable changes in the physical, 

geochemical and microbial conditions that may cause long-term aquifer degradation, 

and/or may adversely impact subsequent remediation technologies. All of these adverse 

impacts could increase life-cycle costs of site cleanup. 

Quantitative predictions of these potential benefits and adverse impacts to aid decision 

making on whether to implement DNAPL source depletion actions are highly uncertain. 

These uncertainties remain as significant barriers to more widespread use of source 

depletion options. 

Need for Alternative Cleanup Goals 

Several national advisory panels have studied the difficulties associated with cleanup of 

contaminated ground water, including the particular problems posed by DNAPLs, and have 

issued summary reports of their findings. In 1994, the National Research Council (NRC)7

completed the report: Alternatives for Ground Water Cleanup. This report recommended that 

sites be categorized according to the “Relative Ease of Cleaning Up Contaminated Aquifers as 

a Function of Contaminant Chemistry and Hydrogeology” and gave an example of such a 

categorization scheme (Table ES-1), which clearly indicates that DNAPLs are the most difficult 

type of contaminant problem to clean up (NRC, 1994; page 5). Among other findings, this 

report included the following findings regarding “Setting Cleanup Goals” (NRC, 1994; page 18) 

(bold text is from original): 

 

7

 The National Research Council (NRC) is the principal operating agency of both the National Academy 

of Sciences and the National Academy of Engineering. More information about the NRC can be 

obtained from: http://www.nationalacademies.org/nrc/ . 
 

 A-8

Conclusion. Existing procedures for setting ground water cleanup goals do not 

adequately account for the diversity of contaminated sites and the technical 

complexity of ground water cleanup. Whether goals established under existing 

procedures adequately protect public health and the environment, or whether they are 

overprotective or underprotective, is uncertain, as are the costs to society when these 

goals cannot be achieved. 

Recommendation 1. Although the committee recognizes that different agencies must 

operate under different authorities, all regulatory agencies should recognize that 

ground water restoration to health-based goals is impracticable with existing 

technologies at a large number of sites. 

The Executive Summary of 2003 national panel report provides the following conclusions 

regarding “Appropriate Metrics For Performance Assessment” (EPA, 2003; page xi): 

The Panel assessed the technical basis for using drinking water standards, such as 

Maximum Contaminant Levels (MCLs), as the single performance goal for successful DNAPL 

source-zone remediation and the use of chemical analyses in ground water samples from 

monitoring wells as the primary metric by which to judge performance of ground water 

remediation systems. Although an MCL goal may be consistent with prevailing state and 

federal laws for all ground water considered a potential source of drinking water and is a 

goal that is easily comprehended by the public, this goal is not likely to be achieved 

within a reasonable time frame in source zones at the vast majority of DNAPL sites. Thus, 

the exclusive reliance on this goal inhibits the application of source depletion 

technologies because achieving MCLs in the source zone is beyond the capabilities of 

currently available in-situ technologies in most geologic settings. 

Problem Statements 

For the purpose of this options paper, the Ground Water Task Force developed generalized 

problem statements based on written and anecdotal information. However, the problem 

statements listed below do not necessarily represent the position of EPA. Rather, these 

problem statements attempt to capture the perspectives of various stakeholders, such as 

federal and state regulatory officials, and members of the regulated community, as well as 

environmental and public interest groups. Also, individual opinions can vary as much within 

these respective groups as between them. Furthermore, these problem statements are not 

listed in any order of importance or priority, and do not represent all possible points of view 

associated with remediation of a DNAPL source zone. 

1. Site owners8

 say that cleanup to drinking water standards (e.g., MCLs) is not a realistic 

goal for DNAPL source zones, yet they are rarely allowed to use alternative goals. 

Federal and state site managers continue to set such stringent goals within the DNAPL 

source zone, even though most technical experts agree that attaining MCLs within the 

DNAPL source zone is not possible with currently available technologies at most DNAPL 

sites. Site managers are not utilizing program flexibilities for setting alternative cleanup 

 

8

 In this paper the term “site owners ” is used to refer to those parties responsible or potentially 

responsible for the release of contaminants to the environment, and therefore, for paying cleanup 

costs. 
 

 A-9

goals for this portion of the plume (e.g., technical impracticability decisions, containment 

zones, or similar). 

2. Technology developers say that continued adherence to overly stringent cleanup goals 

for DNAPL source zones inhibits the potential use of existing technologies and is 

detrimental to development of new methods. Currently available in-situ treatment 

methods, such as thermal and oxidation technologies, can remove significant quantities of 

DNAPL from the source zone. However, site owners are reluctant to consider using such 

technologies in remedies because they feel that attaining MCLs in the source zone is not 

likely to be achieved, even with the most promising technologies. 

3. Federal and state site managers say that alternative cleanup goals often cannot be 

applied because the DNAPL source zone has not been distinguished from the overall 

plume. For many sites, the DNAPL source zone has not been delineated. Regulatory 

officials are reluctant to use program flexibilities (e.g., technical impracticability 

decisions, containment zones, or similar) in these cases, because there is no basis for 

defining the portions of the plume where alternative goals are to be applied. Site 

managers say that site owners are not interested in delineating the DNAPL zone and 

typically want alternative goals to be applied to the entire plume, which would mean that 

none of the plume (neither source zones nor aqueous phase plumes) would be cleaned up. 

Continued adherence to stringent cleanup goals is the best way to make sure that DNAPL 

sites get cleaned up. 

4. Federal and state site managers are concerned that alternative cleanup goals have 

uncertain reliability and long-term costs. Alternative cleanup goals, such as containment 

or exposure control, will require that ground water monitoring and site controls be 

maintained throughout the foreseeable future. The long-term reliability of containment 

systems and exposure controls is uncertain. Also the effectiveness of such systems and 

controls often is not well documented. Containment systems have high capital costs, and 

hydraulic (i.e., pumping) containment systems also have high operating costs. Components 

used in containment systems have a finite operating life (e.g., pumps, wells, piping, flow 

barriers), and replacement costs are not typically considered during remedy selection. 

Institutional controls (e.g., deed covenants or well drilling restrictions) also have 

long-term costs associated with monitoring and enforcement. Long-term custodial care9

 of 

sites with DNAPL source zones cannot be maintained if site owners go out of business; or if 

federal and state governments decide to eliminate funding for “orphan sites” at some 

time in the future. For sites where cleanup to MCLs can be achieved in the DNAPL source 

zone and throughout the plume, uncertainties, long-term costs, and other disadvantages 

associated with long-term custodial care can be avoided. 

5. Federal and state site managers say that although source depletion is sometimes a 

cleanup goal, there is currently no accepted performance measures to determine the 

effectiveness of DNAPL mass removal. There is no agreement among technical experts 

on what performance measures should be used to indicate that DNAPL mass has been 

 

9

 Long-term custodial care includes all activities needed to ensure the protectiveness of a remedy into 

the foreseeable future, which will likely include multiple generations. These activities include site 

monitoring; maintenance of remedy components, replacement of remedy components as needed; and 

monitoring and enforcement of institutional controls. 
 

 A-10

removed to the extent practicable from the DNAPL source zone. A 1996 EPA guidance says 

that long-term objectives for the DNAPL source zone are to (EPA, 1996; page 14): 

... control further migration of contaminants from subsurface DNAPLs to the 

surrounding ground water and reduce the quantity of DNAPL to the extent 

practicable. 

Although total DNAPL mass removed by recovery systems is relatively easy to measure, 

estimates of total mass present in the subsurface are highly uncertain and are typically 

underestimated. This means there is no good way to estimate the fraction of DNAPL mass 

removed from the subsurface with an acceptable level of confidence. In some cases, a 

sharp decline and leveling off of mass recovery over time has been used to indicate that 

DNAPL has been removed to the extent practicable. However, there is no standardized 

method for determining when the mass recovery has leveled off. Also, leveling off of mass 

recovery can result from a poorly designed recovery system. 

6. Site owners say that source depletion should not be a cleanup goal because the 

potential benefits of DNAPL mass removal are outweighed by disadvantages. Some site 

owners believe that such efforts are unlikely to remove all of the DNAPL from the source 

zone, which means that a plume of contaminated ground water will persist and remedies 

to contain or otherwise manage the plume will still be required. Site owners also say that 

mass removal from the source zone is unnecessary as long as the entire plume is contained 

and institutional controls are established. Also, attempts to remove DNAPL mass could 

have detrimental effects, such as causing further migration of the DNAPL. Site owners say 

that containment of the plume, including the DNAPL source zone, is protective and 

consistent with EPA guidance (e.g., the 1993 TI guidance). 

7. Managers of federal and state cleanup programs say that flexibility in setting 

appropriate cleanup goals for DNAPL source zones is also a concern when revisiting 

operating remedies. Improved decision making approaches will be helpful when selecting 

the initial remedy and also when revisiting operating remedies. Many DNAPL sites have 

remedies that were selected several years ago, when the state of knowledge concerning 

problems posed by DNAPLs was less advanced. Reasons for revisiting cleanup goals during 

the operating phase of a remedy could include: 

■ desire to reduce annual operating costs, 

■ desire to change to a more effective cleanup technology, 

■ lack of progress toward existing cleanup goals, 

■ new or previously unrecognized contamination problems, and/or changes in land use. 

Those who are paying remedy costs (site owners, federal and state cleanup programs) 

generally want to reduce long-term remedy costs. Since annual maintenance costs are 

higher for operating systems (e.g., pump and treat, in-situ treatment systems), site 

owners and cleanup programs would like to turn off these components of the remedy 

sooner rather than later. 
 

 A-11

8. Federal and state site managers say that they should be able to revisit technical 

impracticability (TI) decisions. If a TI decision is made for DNAPL source zones (or for 

other site conditions), federal and state site managers want to be able to revisit the TI 

decision at some time in the future when new cleanup technologies become available. 

Cleanup of the site is preferable to long-term custodial care for the reasons discussed 

above. EPA’s 1993 “Guidance for Evaluating the Technical Impracticability of Ground 

Water Restoration” states that TI decisions “...will be subject to future review by EPA” 

(EPA, 1993b; page 25). However, this guidance also indicates that TI decisions can be 

permanent for Superfund sites if the remedy continues to be “protective.” In contrast, 

the 1993 guidance indicates that TI decisions are not permanent for RCRA facilities (EPA, 

1993b; page 25). 

EPA DNAPL Related Projects 

The projects listed below are technology demonstration projects and multi-year research 

efforts intended to address one or more of the problems identified above. All of these 

projects were recommended in the findings of a recent national panel report: titled: The 

DNAPL Remediation Challenge: Is There A Case For Source Depletion? (EPA, 2003). EPA’s 

ability to continue and/or initiate these DNAPL-related projects is dependent upon resources 

and their relative priority compared to research needs for other issues. 

Project A - A review of existing data from sites where sufficient documentation is available to 

assess the performance of DNAPL source depletion efforts, including long-term impacts on the 

plume (EPA, 2003; Section 5.2, No. 4). 

Project B - Develop guidelines for data that should be collected to document field 

demonstrations of source depletion technologies, prior to initiation of DNAPL removal, during 

operation and after completion of DNAPL removal (EPA, 2003; Section 5.2, No. 3). 

Project C - Develop and validate technologies for measurement of mass flux from DNAPL 

source zones, and other measures for evaluating the effectiveness of DNAPL mass removal 

(EPA, 2003; Section 5.2, No. 5). 

Project D - Continue research and demonstration projects to develop, test, and validate the 

most promising technologies for DNAPL source zone characterization and mass depletion. 

Much of this work is being undertaken in partnership with other federal and state agencies, 

and with industry groups (EPA, 2003; Section 5.2, No. 2). 

Options for Addressing Problems 

The options listed below are intended to address one or more of the problems identified 

above. They are listed in approximate order of increasing complexity and time to complete. 

For instance, the longer-term projects require the collection of additional supporting data. It 

is assumed that the statutory and regulatory framework for EPA cleanup programs will not 

change in the near future, so all options fall within the current framework for these 

programs. It is also assumed that training and outreach activities are an essential component 

of each option. A brief discussion of advantages and disadvantages is included for each 

option. A matrix table showing the problems addressed by each option is included as Table 1. 
 

 A-12

Option 1 - Develop a fact sheet describing the potential benefits of DNAPL mass removal from 

the source zone, as well as the potential disadvantages. 

Advantages: No additional studies would be needed to develop such a fact sheet. The 

potential benefits of DNAPL source removal are often overlooked. This may encourage 

greater consideration and use of DNAPL recovery and/or treatment technologies for site 

remedies. May encourage delineation of the DNAPL source zone. 

Disadvantages: Simply listing potential benefits and disadvantages without guidance on 

the types of sites where source depletion should (or should not) be included as a 

remediation goal (Option 6) will not be very helpful. Also, since there are currently no 

accepted performance measures to determine the effectiveness of DNAPL mass removal, 

it may be difficult to determine whether benefits have been realized at a particular site. 

Option 2 - Develop a fact sheet describing program flexibilities and alternative cleanup goals 

that may be applied to the DNAPL source zone other than attainment of MCLs. Program 

flexibilities (e.g., technical impracticability decisions, containment zones, or similar) would 

be those that may be allowed under federal or state cleanup programs. The alternative goals 

would typically apply only to the DNAPL source zone rather than the entire plume, in 

accordance with existing policy. 

Advantages: No additional studies would be needed to develop such a fact sheet. It may 

encourage site managers to make greater use of program flexibilities currently available 

from federal and state programs for the DNAPL source zone. TI decisions as well as other 

flexibilities would be discussed (e.g., containment zones, or similar designations). It may 

encourage delineation of the DNAPL source zone. 

Disadvantages: Would only apply to sites where DNAPL source zone has been delineated, 

which may be a small minority of sites. May not increase use of program flexibilities. If 

examples of program flexibilities are described but not mandated, this fact sheet may not 

be very helpful. 

Option 3 - Develop a supplemental EPA guidance on technical impracticability (TI) that 

clarifies some or all of the following questions for Superfund and other EPA cleanup programs: 

■ circumstances that would warrant revisiting a TI decision; 

■ what a TI evaluation report should look like; 

■ how the TI decision process can be used to encourage delineation of DNAPL source 

zones; 

■ can a simplified (or streamlined) TI decision process be applied to operating remedies; 

and 

■ how the TI decision process can be used to encourage use of innovative source removal 

technologies. 

Advantages: No additional studies would be needed to develop such a guidance. 

Clarification of when a TI decision can be revisited may especially help the Superfund 
 

 A-13

program (Problem 8). TI determinations are currently an option in both the Superfund and 

RCRA Corrective Action programs. Current guidance would be updated. This guidance 

could address several questions or concerns regarding the TI decision process, such as the 

examples given above. Such a guidance could resolve questions that are currently 

discouraging TI determinations. 

Disadvantages: Some federal and state cleanup programs may prefer to use program 

flexibilities other than TI for DNAPL source zones. For these programs, a supplemental TI 

guidance would have limited usefulness. Providing guidance on the TI decision process, 

without guidance on the types of sites where source depletion should (or should not) be 

included as a remediation goal (Option 6) may not be very helpful in determining when 

DNAPL source reduction should (or should not) be attempted. 

Option 4 - Develop a policy memorandum re-emphasizing existing EPA policy that program 

flexibilities are to be used for DNAPL source zones as a means of setting cleanup goals that 

are achievable in a reasonable time frame. Such program flexibilities may include TI 

determinations, containment zones, ground water classification exemptions, or similar 

flexibilities that are available at a particular site from either the federal or state cleanup 

program overseeing the cleanup at that site. The memorandum would reiterate EPA’s current 

policy that cleanup goals for DNAPL source zones should not include restoration of ground 

water to drinking water standards, if this goal cannot be achieved in a “reasonable time 

frame” based on site conditions. 

Advantages: No additional studies would be needed to develop such a policy. This is not a 

policy change because EPA’s cleanup expectations (as stated in the regulations for 

Superfund) are to: “... return usable ground waters to their beneficial uses wherever 

practicable, within a timeframe that is reasonable given the particular circumstances of 

the site” (Federal Register, 1990; §300.430 (a)(1)(F)). This memorandum would clarify 

EPA’s national policy on cleanup expectations for DNAPL source zones, clarify that 

cleanup goals should be scientifically defensible, and apply only to sites where DNAPL 

source zones have been delineated. 

Disadvantages: Such a policy memorandum would be similar to a policy issued by OSWER 

in 1995 (EPA, 1995), which has had little discernable effect on remedy decisions. No 

guidance would be provided on the types of sites where source depletion should (or should 

not) be included as a remediation goal, and therefore, would not provide much useful 

guidance to decision makers. This policy would only apply to sites where the DNAPL source 

zone has been delineated, which may be a small minority of sites. It is not clear whether 

such a policy memorandum would provide an incentive to delineate such source zones. 

Providing guidance on “reasonable time frame” may be difficult. This option does not 

address any of the concerns regarding TI determinations (Problem 8). Since there is 

currently insufficient guidance regarding what a “reasonable time frame” is for attaining 

cleanup goals, this policy may not be helpful unless this question is also addressed. 

Option 5 - Develop guidance on recommended methods and approaches for delineating the 

extent of the DNAPL source zone. 

Advantages: This guidance would explain which characterization methods, including newly 

developed and conventional tools, are most helpful in delineating the spatial extent of the 
 

 A-14

DNAPL zone. This would update existing guidance. This may encourage more site 

managers to characterize the DNAPL zone. 

Disadvantages: There may not be a clear consensus on which characterization methods 

are most helpful. If there is no such consensus, then additional research and 

demonstration projects will need to be completed before such a guidance can be initiated 

(Project D). To be useful this document will need to do more than simply describe field 

methods. It will also need to address how field data should be evaluated, level of detail 

needed for delineation of the DNAPL source zone as a function of the types of remedies 

being considered, value to be placed on direct versus indirect indicators of DNAPL, and 

other considerations. 

Option 6 - Develop guidance providing a qualitative approach for determining when source 

depletion technologies should be implemented, or should not be implemented. This guidance 

would attempt to identify types of site conditions where: 

■ MCLs are potentially achievable in the DNAPL source zone; 

■ MCLs are not likely to be achieved; 

■ Benefits of source depletion efforts tend to outweigh disadvantages; and 

■ Types of sites where source depletion should be included as a remediation goal 

(regardless of whether or not MCLs are likely to be achieved within the DNAPL source 

zone). 

 Advantages: This would provide a useful decision-making tool. No such guidance currently 

exists. This project was included in the recommendations of a recent national panel 

report (EPA, 2003). It may encourage delineation of the DNAPL source zone. 

Disadvantages: There is currently a lack of well documented case studies, and therefore, 

a lack of scientific consensus on these topics. Consequently, this project may not be 

feasible at present. A separate project to evaluate existing data from sites where DNAPL 

source depletion efforts were undertaken (Project A) would need to be completed before 

such a decision making approach could be developed. Also, results of this data evaluation 

(Project A) may be inconclusive. If results of Project A are inconclusive, then additional 

research and demonstration projects will need to be completed before such a guidance 

can be initiated (Project D). 

Option 7 - Develop guidance on performance measures for the effectiveness of DNAPL mass 

removal, and on how to determine when active DNAPL removal efforts should be 

discontinued. Such measures could include trend analysis for mass removal rates, mass flux 

data, or other parameters for gauging remedy performance. 

Advantages: Currently there is no EPA guidance on this topic. This guidance may 

encourage more site managers to include DNAPL depletion as a cleanup goal for the 

source zone, and spur wider use of technologies designed to attain this goal. May 

encourage delineation of the DNAPL source zone. 
 

 A-15

Disadvantages: There may not be a clear consensus on which performance measures are 

most helpful. Additional research and field testing of technologies for measurement of 

mass flux and other potential performance measures (Project C) are needed before these 

methods can be included in such a guidance. 

Option 8 - Develop guidance describing improved methods for comparing long-term remedies, 

which would allow a more realistic accounting of the costs and other disadvantages of longterm custodial care. This would include long-term costs of maintaining containment systems, 

equipment replacement, monitoring and enforcing institutional controls, and site monitoring. 

 Advantages: Currently, there is no EPA guidance on this topic. This guidance would allow 

EPA to start fresh with new ideas for 1) utilizing the latest technologies; 2) being 

responsive to a wide spectrum of stakeholders, including state and local governments, 

environmental groups, and the general public; and 3) comparing costs and reliability 

issues associated with long-term custodial care. 

Disadvantages: Currently there is no consensus on how to do such a comparison. 

Therefore, this project may not be feasible at present. No research activities are 

currently planned to develop or test potential improved methods for comparing long-term 

remedies. 

References 

EPA, 1987. Alternate Concentration Limit Guidance, Office of Solid Waste and Emergency 

Response (OSWER), Publication EPA/530/SW-87/017, July 1987. Available at: 

http://www.epa.gov/correctiveaction/resource/guidance/gw/acl.htm. 

EPA, 1993a. Evaluation of the Likelihood of DNAPL Presence at NPL Sites, National Results, 

Office of Solid Waste and Emergency Response (OSWER), Publication 9355.4-13, 

EPA/540-R-93-073, September 1993. Available at: 

http://www.epa.gov/superfund/policy/remedy/pdfs/540r-93073-s.pdf. 

EPA, 1993b. Guidance for Evaluating the Technical Impracticability of Ground Water 

Restoration, Office of Solid Waste and Emergency Response (OSWER), Directive 9234.2-25, 

EPA/540-R-93-080, September 1993. Available at: 

http://www.epa.gov/superfund/health/conmedia/gwdocs/techimp.htm. 

EPA, 1995. Superfund Groundwater RODS: Implementing Change This Fiscal Year, Office of 

Solid Waste and Emergency Response (OSWER), Memorandum, Elliott P. Laws to Regional 

Administrators and Waste Management Division Directors, OSWER Publication 9335.5-03P, 

EPA/540-F-99-005, July 31, 1995. Description available at: 

http://www.epa.gov/superfund/policy/remedy/pdfs/540f-99005-s.pdf. 

EPA, 1996. Presumptive Response Strategy and Ex-Situ Treatment Technologies for 

Contaminated Ground Water at CERCLA Sites, Final Guidance, Office of Solid Waste and 

Emergency Response (OSWER), Directive 9283.1-12, EPA/540-R-96-023, October 1996. 

Available at: http://www.epa.gov/superfund/health/conmedia/gwdocs/gwguide/index.htm. 

 
 

 A-16

EPA, 2003. The DNAPL Remediation Challenge: Is There A Case For Source Depletion?, Report 

Prepared by an Expert Panel to the Environmental Protection Agency, Office of Research and 

Development, Publication EPA/600/R-03/143, dated December 2003. Available at: 

http://www.epa.gov/ada/download/reports/600R03143/600R03143.pdf. 

Federal Register, 1990. Volume 55, No. 46, March 8, 1990; 40 CFR Part 300, National Oil and 

Hazardous Substances Pollution Contingency Plan; Final Rule. Available at: 

http://www.epa.gov/superfund/policy/remedy/sfremedy/regenfor.htm. 

National Research Council, 1994. Alternatives for Ground Water Cleanup, National Academy 

Press, Washington, DC. Available at: http://books.nap.edu/catalog.php?record_id=2311. 
 

 A-17

Table 1: Cleanup Goals Appropriate for DNAPL Source Zones: 

Matrix Summary of Problems Addressed by Each Option

Options 

(primary focus)* 

Problem 

Statements 

1 

p 

2 

p 

3 

p 

4 

p 

5 

t 

6 

t 

7 

t 

8 

t 

1. Cleanup to MCLs not a realistic 

goal for DNAPL zones, yet 

alternative goals are rarely used. 

1** 2 2 2 1 2 2 2 

2. Overly stringent cleanup goals 

inhibit use of existing 

technologies. 

1 2 2 2 1 2 2 2 

3. Alternative goals often can’t be 

applied because DNAPL zone has 

not been distinguished from 

overall plume. 

1 2 1 1 3 1 2 

4. Alternative goals have uncertain 

reliability and long-term costs. 3 3 

5. No accepted performance 

measures for effectiveness of 

DNAPL mass removal. 

 3 2 

6. Potential benefits of DNAPL mass 

removal outweighed by 

disadvantages. 

1 2 1 1 

7. Setting appropriate cleanup 

goals for DNAPL zones is also a 

concern when revisiting 

operating remedies. 

1 2 2 2 1 2 3 3 

8. Should be able to revisit TI 

decisions. 3 2 1 

NOTES: 

* Initial/primary focus of option: p=policy; t=technical and/or research study 

** 3 = Option provides significant contribution to resolution of problem. 

 2 = Option provides some help to resolution of problem. 

 1 = Option may provide help to address problem.
 

 A-18

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 B-1

Attachment B 

Discussion Paper: 

Ground Water Use, Value, 

and Vulnerability as Factors 

in Setting Cleanup Goals 

This paper reflects the GWTF’s research, analysis and findings as of May 10, 2004 when 

it was originally posted at http://gwtf.clu-in.org/papers/. The version of the paper included in 

this report has been modified to reflect updates to web links that were available as of December 

2007. Note that Kenneth Lovelace is no longer the contact for this issue paper as mentioned on 

page B-6. For more current information on the subject, contact Guy Tomassoni 

(tomassoni.guy@epa.gov) of OSWER’s Center for Program Analysis. 
 

 B-2

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 B-3

Ground Water Use, Value, and 

Vulnerability as Factors in Setting 

Cleanup Goals 

Issues/Options paper developed by the Cross-Program Ground Water Task Force 

Established under EPA’s One Cleanup Program 
 

 B-4

Introduction 

Notice: It is very important to note that this paper has been prepared by EPA’s Ground Water 

Task Force for informational purposes only. This paper does contain some discussion 

summarizing EPA’s statutory authorities and regulations. However, this paper does not 

constitute an EPA statute or regulation and does not substitute for such authorities. In 

addition, the statements in this paper do not constitute official statements of EPA’s views 

and are not binding on EPA or any party. 

This options paper is being developed by EPA’s Ground Water Task Force, a workgroup 

established under the One Cleanup Program of the Office of Solid Waste and Emergency 

Response (OSWER).19 This task force is comprised of EPA and state regulatory officials, and 

was formed to: 

■ serve as the main technical / policy / communication / networking resource for 

OSWER on ground water issues; 

■ promote cross-program coordination and communication on technical and policy issues 

related to the cleanup of contaminated ground water; 

■ identify and prioritize and work to solve and/or provide guidance on ground water 

issues and projects that will benefit multiple programs; and 

■ assign subgroups to work on priority issues, and/or making recommendations to EPA 

senior management on the best course of actions for such issues. 

In carrying out its purpose, Ground Water Task Force representatives discussed with senior 

EPA and state managers a variety of implementation challenges cleanup programs face with 

respect to setting ground water cleanup goals.20 One of those challenges, which was 

identified as a priority issue, is associated with differing perspectives on how ground water 

use, value and vulnerability (see Highlight Box on the following page) should influence sitespecific ground water cleanup goals. The purpose of this paper is to promote dialogue by 

providing a brief background, followed by differing stakeholder points of view (based on 

written or anecdotal input) with respect to problems and/or challenges, and potential options 

for addressing these problems. Stakeholders include federal and state regulatory officials, 

and members of the regulated community, as well as environmental and public interest 

groups. 

These points of view do not necessarily represent the position of EPA and are provided to 

assist in framing the issues presented. The Ground Water Task Force recognizes that other 

problems and options may exist, and no decisions have been made at this point with respect 

to which option(s) the Agency may pursue. Readers are encouraged to provide their 

comments on the paper and to suggest solutions they believe the Agency should consider to 

 

19 For more information concerning the EPA’s One Cleanup Program, refer to 

http://www.epa.gov/swerrims/onecleanupprogram/index.htm. For more information concerning the 

One Cleanup Program Ground Water Task Force, refer to http://gwtf.cluin.org/. 

20 Oral presentation and discussion on March 4, 2003 before the Cleanup Programs Council, an advisory 

group for the OSWER One Cleanup Program.
 

 B-5

Ground Water Use, Value and Vulnerability

(Definitions provided for the purpose of this paper) 

Ground water use typically refers to the current use(s) and functions of ground water as 

well as future reasonably expected use(s). Ground water use can generally be divided into 

drinking water, ecological, agricultural, industrial/commercial uses or functions, and 

recreational. Drinking water use includes both public supply and individual (household or 

domestic) water systems. Ecological use commonly refers to ground water functions, such 

as providing base flow to surface water to support habitat; ground water (most notably in 

karst settings) may also serve as an ecologic habitat in and of itself. Agricultural use 

generally refers to crop irrigation and live-stock watering. Industrial/commercial use 

refers to in any industrial process, such as for cooling water in manufacturing, or 

commercial uses, such as car wash facilities. Recreational use generally pertains to 

impacts on surface water caused by ground water; however, ground water in karst settings 

can be used for recreational purposes, such as cave diving. All of these uses and functions 

are considered “beneficial uses” of ground water. Furthermore, within a range of 

reasonably expected uses and functions, the maximum (or highest) beneficial ground water 

use refers to the use or function that warrants the most stringent ground water cleanup 

levels. (see Figure 1 reflecting ground water use in the United States.) 

Ground water value is typically considered in three ways: for its current uses; for its 

future or reasonably expected uses; and for its intrinsic value. Current use value depends 

to a large part on need. Ground water is more valuable where it is the only source of 

water, where it is less costly than treating and distributing surface water, or where it 

supports ecological habitat. Current use value can also consider the “costs” associated 

with impacts from contaminated ground water on surrounding media (e.g., underlying 

drinking water aquifers, overlying air— particularly indoor air, and adjacent surface 

water). Future or reasonably expected values refer to the value people place on ground 

water they expect to use in the future; the value will depend on the particular expected 

use or uses (e.g., drinking water, industrial). Society places an intrinsic value on ground 

water, which is distinct from economic value. Intrinsic value refers to the value people 

place on just knowing clean ground water exists and will be available for future 

generations, irrespective of current or expected uses. While the value of ground water is 

often difficult to quantify, it will certainly increase as the expense of treating surface 

water increases, and as existing surface water and ground water supplies reach capacity 

with continuing development. 

Ground water vulnerability refers to the relative ease with which a contaminant 

introduced into the environment can negatively impact ground water quality and/or 

quantity. Vulnerability depends to a large extent upon local conditions including, for 

example, hydrogeology, contaminant properties, size or volume of a release, and location 

of the source of contamination. Shallow ground water is generally more vulnerable than 

deep ground water. Private (domestic) water supplies can be particularly vulnerable 

because (1) they are generally shallower than public water supplies, (2) regulatory 

agencies generally require little or no monitoring or testing for these wells, and (3) 

homeowners may be unaware of contamination unless there is a taste or odor problem 

(EPA, 2003). Furthermore, vulnerability can change over time. For example, anthropogenic 

activities, such as mining or construction, can remove or alter protective overburden thus 

making underlying aquifers more vulnerable. 
 

 B-6

address the problems stated in this paper and/or other problems not mentioned herein. As 

conveyed in this document, any additional option submitted should describe the particular 

problem(s) it would address, as well as associated advantages and disadvantages. These 

comments will be used in planning future activities of the task force and in developing 

recommendations for EPA senior managers on a course of action to address the issues raised 

in this paper. 

Questions or comments concerning this paper should be directed to Ken Lovelace and 

sent via email to gwtf@emsus.com by July 31, 2004. Copies of this paper can be obtained 

from the Ground Water Task Force website: http://gwtf.cluin.org/. 

EPA recognizes that some stakeholders are concerned that raising issues addressed in this 

paper may generate pressures to change existing approaches, promote debates that slow 

down cleanup decisions, and ultimately affect the ability of regulatory programs to impose 

and achieve cleanup goals. However, the task force believes that avoiding these issues would 

not be responsive to other concerns raised during stakeholder meetings held by the Agency in 

2003 concerning the goals of the One Cleanup Program. Additional stakeholder meetings are 

planned specifically for this and other options papers developed by the task force. By 

including states on the task force and promoting public dialogue on these ground water 

issues, the Agency is attempting to fairly balance all of these concerns. 

Background 

Since the 1970s, EPA and states have enacted a number of laws and regulations (as well as 

supporting initiatives, guidance, and policies) concerning both the protection as well as 

cleanup of contaminated ground water. To date, the most concise, cross-programmatic 

statements concerning EPA’s ground water related policies were provided in the document 

titled, “Protecting the Nation’s Ground Water: EPA’s Ground Water Strategy for the 1990s” 

(EPA, 1991). Several of the key principles, findings, and recommendations are presented 

below. 

Overall Goal: 

■ “The overall goal of EPA’s ground water policy is to prevent adverse effects to human 

health and the environment and to protect the environmental integrity of the nation’s 

ground water resources.” 

 With respect to remediation: 

■ “Ground water remediation activities must be prioritized to limit the risk of adverse 

effects to human health first, and then to restore currently used and reasonably 

expected sources of drinking water and ground water closely hydrogeologically 

connected to surface waters, whenever such restorations are practicable and 

attainable.” 

■ “Given the costs and technical limitations associated with ground water cleanup, a 

framework should be established that ensures the environment and public health 

benefit from each dollar spent is maximized. Thus in making remedial decisions, EPA 

must take a realistic approach to restoration [of contaminated ground water] based 
 

 B-7

upon actual and reasonably expected uses of the resource as well as social and 

economic values.” 

With respect to federal, state and local responsibilities: 

■ “The primary responsibility for coordinating and implementing ground water 

protection programs has always been and should continue to be vested with the 

states. An effective ground water protection program should link federal, state, and 

local activities into a coherent and coordinated plan of action.” 

In the early 1990s, EPA encouraged states to institute Comprehensive Ground Water 

Protection Programs (EPA, 1992). The basic goal of the CSGWPP-partnership between the 

states and EPA is to achieve a more efficient, coherent, and comprehensive approach to the 

nation’s ground water resources. More specific goals of an individual State CSGWPP are to 

consider ground water use, value, and vulnerability in setting priorities for both prevention 

and remediation. 

EPA’s cleanup programs fully supported CSGWPPs in their directive titled, “The Role of 

CSGWPPs in EPA Remediation Programs” (EPA, 1997a). While relatively few states have 

pursued CSGWPPs (see http://cfpub.epa.gov/safewater/sourcewater/) many other states 

have over the years developed other approaches to designate ground water based on use, 

value, and vulnerability. Some of the many approaches, which are often used as factors in 

setting ground water cleanup goals, include: 

■ formal state-wide (mapped) classification systems (see for example, Connecticut’s 

system at 

http://www.ct.gov/dep/cwp/view.asp?a=2698&q=323132&depNav_GID=1707 , and 

ground water classification exception areas (see for example, New Jersey’s provisions 

at http://www.state.nj.us/dep/srp/dl/ceaguid2.pdf). 

■ non-degradation policies (e.g., Rhode Island, Maine, Wyoming) that recognize all 

ground water as a source of drinking water; 

■ states that presume as a starting point that all ground water is a potential source of 

drinking water, but allow for site-specific variations of that classification (see for 

example, Michigan waiver provision available at 

http://www.michigan.gov/deq/0,1607,7-135-3311-58095--,00.html and their guidance 

on Ground Water Not In An Aquifer (GWNIAA) determinations available at 

http://www.deq.state.mi.us/documents/deq-wmd-swp-gwnia-ftp.pdf. 

■ urban use designations as part of voluntary and brownfield cleanup bills (see for 

example Ohio’s Urban Setting Designations available at 

http://www.epa.state.oh.us/derr/vap/docs/fact8.pdf. 

■ ground water management zone approaches that recognize impairment (which allows 

for long-term responses like natural attenuation) without changing a ground water 

classification (see for example, Illinois’ Ground Water Management Zones 

(http://www.epa.state.il.us/land/regulatory-programs/permits-andmanagement/establishing-groundwater-management-zone.html) and California’s 
 

 B-8

Containment Zone Policy http://www.swrcb.ca.gov/plnspols/docs/wqplans/res92-

49.html), and 

■ Nebraska’s approach to designating and classifying ground water, and their ground 

water remediation protocol available Title 118, Chapters 6, 7, and 8 and Appendix A. 

(available at http://www.deq.state.ne.us/RuleAndR.nsf/pages/118-TOC). 

Later in the 1990s, Congress amended the Safe Drinking Water Act placing a new focus on 

assessing and protecting sources of drinking water (see EPA, 2003b). The basic elements of 

source water assessment and protection include delineating areas of ground water and 

surface water that supply public drinking water systems, assessing those areas with respect to 

susceptibility of the drinking water sources to actual or potential sources of contamination, 

and developing protection/management strategies and contingency plans. EPA anticipates 

that these delineated source water areas will help to focus both protection and remediation 

activities. 

Regulations and supporting policy and guidance for the three federal cleanup programs 

(Superfund, RCRA Corrective Action, Underground Storage Tanks) address the role of ground 

water use, among other factors, in setting cleanup goals. For example, the Superfund Rules of 

Thumb for Remedy Selection (EPA, 1997b) provides regulatory references and guidance 

pertaining to selecting cleanup goals for ground water that is a either a current, potential, or 

not anticipated to be a source of drinking water. The Handbook of Ground Water Protection 

and Cleanup Policies for RCRA Corrective Action (EPA, 2002) addresses setting cleanup goals 

based on various designated uses of ground water. In approving protective corrective action 

plans for releases from underground storage tanks, 40 CFR 280.66 

(http://www.epa.gov/swerust1/fedlaws/cfr.htm) specifies a number of factors to be 

considered. These include the hydrogeologic characteristics of the facility and the 

surrounding area, and the proximity, quality and current and future uses of surface water and 

ground water in the surrounding area. 

Problem Statements 

For the purpose of this options paper, the Ground Water Task Force developed generalized 

problem statements based on written and anecdotal information. However, the problem 

statements listed below do not necessarily represent the position of EPA. Rather, these 

problem statements attempt to capture the perspectives of various stakeholders, such as 

federal and state regulatory officials, members of the regulated community, and 

environmental and public interest groups. Also, individual opinions can vary as much within 

these respective groups as between them. Furthermore, these problem statements are not 

listed in any order of importance or priority, and do not represent all possible points of view 

associated with the role of ground water use, value, and vulnerability in setting cleanup 

goals. 

1. There does not appear to be enough awareness by the general public, regulated 

community, and government officials pertaining to the various ground water functions, 

associated values and vulnerability of drinking water supplies to contamination. Adding to 

this problem is the lack of awareness and understanding of how aquifers are connected to 

other aquifers and to surface water, as well as long-term aspects of contaminant 

migration. Furthermore, there is uncertainty with respect to how various contaminants 

(individually and cumulatively) affect public health and environmental quality. 
 

 B-9

2. There appears to be an increasing demand for reliance on exposure controls rather than 

cleaning up contaminated ground water. Decisions not to cleanup may be short-sighted 

with regard to increasing future demands for clean drinking water supplies. 

3. There is a lack of agreement among stakeholders regarding methods to determine which 

ground waters are “reasonably expected” to be a source of drinking water, and how those 

decisions should influence cleanup objectives. For example, some programs require 

cleanup to drinking water standards only for ground water currently planned to be used as 

a drinking water supply rather than considering multi-generational long-term needs. Other 

programs require cleanup to drinking water standards for ground water that, in the view 

of some stakeholders, would never be used as drinking water supply due to insufficient 

quantity and quality. A related problem is the lack of clear direction on determining 

appropriate levels or degree of cleanup for ground water not determined to be a 

reasonably expected source of drinking water. 

4. Ground water cleanup activities and decisions are often not prioritized in a manner that 

would result in addressing the most pressing needs or maximizing the public health 

benefit of monies spent. 

Options for Addressing Problems 

The options listed below are intended to address one or more of the problems identified 

above. It is assumed that the statutory and regulatory framework for EPA cleanup programs 

will not change in the near future, so all options fall within the current framework for these 

programs. It is also assumed that training and outreach activities are an essential component 

of each option. Furthermore, in evaluating options, the Agency will take into account 

resource needs in terms of time, staff and dollars. A brief discussion of advantages and 

disadvantages is included for each option. A matrix table showing the problems addressed by 

each option is included as Table 1. 

 

Option 1 - Develop a series of educational fact sheets and Internet training seminars 

(targeted primarily to government officials and members of the regulated community) to 

raise awareness of ground water use, value, and vulnerability, interconnection between 

ground water and surface water systems, and health impacts to contaminants most commonly 

found in ground water. This effort would include summaries of the findings from the 

upcoming 2004 Ground Water report to Congress. 

Advantages: This option would help to address problem #1 and would build on EPA’s 

ground water valuation studies conducted in the early 1990s. It also may also help address 

problem #2 by helping people understand the implications of current trends in ground 

water cleanups. 

Disadvantages: It wouldn’t likely provide much benefit with respect to other identified 

problems. 

Option 2 - Conduct research on the impacts on other developed nations that have resulted 

from either the presence or lack of strong ground water protection programs. 
 

 B-10

Advantages: This option would help address problem #1 and may also help address 

problem #2 by helping people understand the implications of current trends in ground 

water cleanups. 

Disadvantages: It would only provide information and would not in and of itself promote 

any direct changes. 

Option 3 - Develop summaries of how individual EPA and state cleanup programs consider 

ground water use, value, and vulnerability in setting cleanup goals (e.g., ground water 

classification and classification exception systems, ground water management zone type 

approaches). These summaries would be written with Internet links to more detailed 

resources. EPA would provide access to these summaries via its One Cleanup Program 

website. This option could also involve low-cost Internet training to raise awareness of the 

range of approaches being used by EPA and states. 

Advantages: This option would address, to various degrees, most of the identified 

problems. For example, providing access to these summaries could address problems 1 

and 2 by raising awareness of EPA and state efforts to protect valuable ground water 

resources. Also, it could potentially lead to broader acceptance of successful approaches 

that respond to problems 3 and 4. In particular, it would highlight approaches used by 

states to distinguish between situations where a drinking water pathway should or should 

not be considered in site-specific risk evaluations. Additionally, these summaries and the 

associated resource links would help ensure that interested stakeholders were more fully 

aware of the flexibilities within a particular program. Lastly, the training element of this 

option would increase the visibility and understanding of the various approaches being 

used. 

Disadvantages: One of the key disadvantages of this option is keeping current the needed 

information. Another disadvantage is that it would highlight programmatic differences 

that may result in unwanted pressure on some programs to adopt changes to the way in 

which they currently set ground water cleanup goals. 
 

 B-11

Option 4 - Takes option 3 one step further by developing an EPA policy memo that explains 

how EPA cleanup programs acknowledge the various approaches used by states in setting 

ground water cleanup goals based on ground water use, value, and vulnerability. For example, 

the policy statement would clarify how state ground water management zone policy could 

influence goals established under EPA’s cleanup programs. Internet training could also be used 

to increase awareness and understanding of the policy statement. 

Advantages: This option offers the same advantages as Options 3 with the added benefit of 

clarifying EPA’s policies on the subject. 

Disadvantages: This option is associated with same disadvantages posed by Options 3. An 

additional disadvantage would be a clear statement of policy on the subject, which may in 

some circumstances limit flexibility desired by some stakeholders. 

Option 5 - Using information from federal and state cleanup programs, develop a general 

framework that describes how to prioritize sites according to problem severity and ground 

water use, value, and vulnerability. This framework would clearly describe how ground water 

use, value, and vulnerability as well as specific problem magnitude (e.g., risk) can be used to 

prioritize sites and influence remedial decisions. This framework would describe how a 

prioritization system directed at site-specific ground water problems can work within 

statewide general classification systems and how, for example, ground water management 

zone policy could influence goals established under EPA’s cleanup programs. 

 Advantages: This option would address many of the problems identified by encouraging 

consistency across programs, and by defining the key variables (use, value, and 

vulnerability) that should be considered in remedial decisions. 

Disadvantages: This option would be fairly resource intensive in terms of federal and state 

staff and contractor support needed to develop the framework. The objective of this option 

would be similar in many ways to EPA’s Office of Water initiative in the early 1990s to 

promote Comprehensive State Ground Water Protection Programs (CSGWPPs). Therefore, 

this option may be associated with many of the challenges realized in the CSGWPP 

initiative. 

Option 6 - Use defined Source Water Assessment Program (SWAP) areas (required by the 1996 

amendments to the Safe Drinking Water Act) to promote consistency in ground water cleanup 

decision making. The option would involve establishing a means that would encourage 

stakeholders to become more aware of and involved with various ground water cleanups taking 

place within or near an individual Source Water Assessment Area. The objective would be that 

cleanups could be selected to maximize efficiencies and benefits within a particular source 

water area. 

Advantages: This option would specifically address most of the identified problems. States 

have completed their SWAP delineations. These areas, which include both ground and 

surface water and ground water-surface water interaction, could be used to help address 

ground water cleanup and other ground water management related issues. This option 

could promote greater consistency in cleanup goals, at least within source SWAP areas. 

Additionally, Source Water Assessments are based on a relatively new program that has 

significant public interest. 
 

 B-12

Disadvantages: Reluctance of states to release detailed SWAP information. It does not 

address private water supplies. Additionally, coordination among cleanup projects within a 

Source Water Area could be viewed by some as an additional hurdle that could cause 

delays. 

Option 7 - Promote and provide funding assistance for regular meetings within an individual 

state or watershed that brings together the various programs and stakeholders involved with 

ground water cleanup and protection. One of the objectives of these meetings would be to 

help prioritize cleanup actions based on factors, such as magnitude and extent of ground 

water contamination, as well as ground water use, value, and vulnerability. 

Advantages: Depending on the planning and agenda, these meetings could help address 

most of the stated problems. Topics could include, for example: trends in ground water use, 

progress of ground water cleanups; coordination of success stories; training on new 

technologies, guidance, policy, etc. 

Disadvantages: As noted in the opening paragraph to these options, the ability to support 

and implement these meetings may be limited by available resources. 

References 

EPA, 2003a. One Cleanup Program - Working in Concert to Make Our Cleanups Better. Fact 

Sheet available at http://www.epa.gov/swerrims/onecleanupprogram/index.htm. 

EPA, 2003b. Memorandum from Assistant Administrator Tracy Mehan III describing source water 

assessment and protection (February). Available at 

http://www.epa.gov/safewater/sourcewater/pubs/fs_statusbyregion_mehan2003.pdf. 

EPA, 2002. Handbook of Ground Water Protection and Cleanup Policies for RCRA Corrective 

Action (EPA/530/R-01/015). Available at 

http://www.epa.gov/correctiveaction/resource/guidance/gw/gwhandbk/gwhndbk.htm. 

EPA, 1997a. The Role of Comprehensive State Ground Water Protection Programs (CSGWPPS) in 

OSWER Remediation Programs. OSWER Directive 9283.1-09. Available at 

http://epa.gov/superfund/health/conmedia/gwdocs/csgwpp.htm. 

EPA, 1997b. Rules of Thumb for Superfund Remedy Selection (EPA/540/R-97/013). Available at 

http://www.epa.gov/superfund/policy/remedy/rules/. 

EPA, 1992. Final Comprehensive State Ground Water Protection Program Guidance 

(EPA/100/R-93/001). Available at 

http://www.epa.gov/correctiveaction/resource/guidance/gw/csgwpp.htm. 

EPA, 1991. Protecting the Nation’s Ground Water: EPA’s Strategy for the 1990s. Available at 

http://www.epa.gov/superfund/resources/remedy/pdf/21z-1020-s.pdf. 

 

Solley, W.B., R.R. Pierce, and H.A. Perlman, 1998. Estimated Use of Water in the United 

States in 1995. USGS Circular 1200. U.S. Geological Survey, Reston, VA. Available at 

http://water.usgs.gov/watuse/pdf1995/html/.
 

 B-13

Figure 1 

Ground Water Use by States 

(Solley et. al, 1998) 
 

 B-14

The Role of Ground Water Use, Value, and Vulnerability (UVV) in Setting Cleanup Goals: 

Matrix of Options Addressing Identified Problems

Problem 

#1: 

Insufficient 

recognition 

of ground 

water UVV. 

Problem 

#2: Trend 

toward 

exposure 

controls 

over 

cleanup. 

Problem #3: Lack 

of agreement on 

identifying future 

ground water use 

decisions and how 

UVV should 

influence cleanups. 

Problem #4: Ground 

water cleanup 

activities/decisions 

often not prioritized 

to maximize 

benefits. 

Option #1: Fact sheets and 

education on ground water 

UVV. 3 1 1 1 

Option #2: Research other 

countries’ ground water 

programs. 

2 2 1 1 

Option #3: Summaries and 

education on how programs 

consider ground water UVV in 

setting goals. 2 2 3 3 

Option #4: New policy and 

training on ground water UVV 

in setting cleanup goals. 1 3 3 3 

Option #5: Create framework 

for prioritizing cleanups based 

on ground water UVV. 1 3 3 3 

Option #6: Use SWAP areas to 

promote greater consistency 

in ground water cleanups. 1 3 3 3 

Option #7: Promote ground 

water cleanup coordination 

meetings. 2 2 2 2 

3 = Option provides significant contribution to resolution of problem. 

2 = Option provides some help to resolve the problem. 

1 = Option may provide help to address problem.
 

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Attachment C 

GWTF Web Page
 

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 C-3
 

 C-4

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 D-1

Attachment D 

Individuals and Organizations that 

Submitted Comments on One or 

Both Discussion Papers
 

 D-2

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 D-3

Individuals and Organizations that 

Submitted Comments on One or 

Both Discussion Papers 

EPA 

Robin Anderson, OSRTI 

Philip Berger, OW 

Andy Crossland, Region 2 

Richard Freitas, Region 9 

Rene Fuentes, Region 10 

Elizabeth Janes, Water Office Region 9 

Marcella Hutchinson, Region 8 

Dave Jenkins, Region 4 

Jeff Johnson, RCRA Region 7 

Mitch Kaplan, Region 9 

Steve Mangion, ORD Region 1 

Kevin McCormack, OW 

Carol Monell, Region 4 

Wayne Naylor, RCRA Region 3 

Howard Orlean, Region 10 

Lisa Price, RCRA Region 6 

Roy Simon, OW 

Other 

Pierre Sargent, United States Geological Survey 

Private Sector/Regulated Community 

Richard Kapuscinski, ENVIRON International Corporation for General Motors 

Kimberly Gates, NAVFAC 

Jim Hatton, Earthtech 

Harley Hopkins, American Petroleum Institute 

Richard Jackson, Intera Inc. 

Donald Koch, C.C. Johnson & Malhotra 

Lorraine Krupa-Gershman, American Chemistry Council 

W. Caffey Norman, (Patton Boggs) TCE Issues Group 

Pat O’Hara, Cummings/Riter 

John Quarles & Michael Steinberg, Morgan, Lewis & Bockius LLP 

Chris Reimer, NGWA 

Greg Rucker, Westinghouse Savannah River Company 

Bob Schreiber, Camp, Dresser, & McGhee (CDM) 

Hans Stroo, Retec 

Superfund Settlements Project and RCRA Corrective Action Project 

Andre Tartre, Ecoremediation 

Laura Yeh, Naval Facilities Engineering Service Center 
 

 D-4

States 

Walter Avramenko, State of Colorado 

Dale Bridgford, State of Michigan 

Daniel Burke, State of Texas 

Judy Canova, State of South Carolina 

Tom Gallagher, State of Nevada 

John Gelting, State of South Carolina 

Ed Jones, State of Washington 

Jennifer Kaduck, ASTSWMO 

David Larsen, State of Utah 

Bob Pierce, State of Georgia 

Bruce Stuart, State of Missouri