PENNSYLVANIA COMPREHENSIVE STATE GROUNDWATER PROTECTION PROGRAM (CSGWPP) AND SELF-ASSESSMENT ___________________________________________________ Pennsylvania Department of Environmental Protection Harrisburg, Pennsylvania October 1, 1998 DEPARTMENT OF ENVIRONMENTAL PROTECTION BUREAU OF WATER SUPPLY MANAGEMENT DOCUMENT NUMBER: 383-2000-030 EFFECTIVE DATE: October 1, 1998 TITLE: Pennsylvania Comprehensive State Groundwater Protection Program (CSGWPP) and Self-Assessment AUTHORITY: Federal Clean Water Act; Pennsylvania Clean Streams Law, Act of 1937 P.L. 1987 No. 394, as amended POLICY: This guidance defines the Pennsylvania Comprehensive State Groundwater Protection Program (CSGWPP) in accordance with USEPA guidelines. PURPOSE: The Comprehensive State Groundwater Protection Program (CSGWPP) is a stateEPA initiative which provides a mechanism whereby states and EPA can work together to develop a comprehensive and consistent statewide approach to groundwater quality protection. The CSGWPP consists of a set of six Strategic Activities, and each Strategic Activity has two sets of adequacy criteria (Core and Fully-Integrating CSGWPP). This document describes and assesses the Pennsylvania groundwater quality protection program relative to the adequacy criteria for the six strategic CSGWPP activities. APPLICABILITY: This guidance applies to all local, state and federal agencies and programs with groundwater quality protection responsibilities. DISCLAIMER: The policies and procedures outlined in this guidance document are intended to supplement existing requirements. Nothing in the policies or procedures shall affect regulatory requirements. The policies and procedures herein are not an adjudication or a regulation. There is no intent on the part of the Department to give these rules that weight or deference. This document establishes the framework within which DEP will exercise its administrative discretion in the future. DEP reserves the discretion to deviate from this policy statement if circumstances warrant. PAGE LENGTH: 112 pages LOCATION: Volume 26, Tab 01B DEFINITIONS: None 383-2000-030 / October 1, 1998 / Page i TABLE OF CONTENTS EXECUTIVE SUMMARY ....…………..………………..……..…………………………. iv PENNSYLVANIA’S VISION FOR A COMPREHENSIVE STATE GROUNDWATER PROTECTION PROGRAM ……………………..………………… viii INTRODUCTION ...……………………………..………………………………………… ix 1. STRATEGIC ACTIVITY 1: ESTABLISHING A GROUNDWATER PROTECTION GOAL ..............................................................................................................1 1.1 Through Adequate Public Participation.......................................................................................... 1 1.2 No Less Protective than EPA’s Groundwater Protection Goal ...................................................... 1 1.3 Guides at Least One Key State Program......................................................................................... 1 2. STRATEGIC ACTIVITY 2: ESTABLISHING PRIORITIES TO ACHIEVE THE STATE’S PROTECTION GOAL.............................................................................................3 2.1 Definitions and Priority-Setting Processes ..................................................................................... 3 2.2 Priority-Setting Process and Groundwater Characteristics............................................................. 4 2.3 Contamination Source Inventories and Assessments...................................................................... 7 2.4 Technical Capabilities..................................................................................................................... 8 2.5 Measures of Groundwater Protection ............................................................................................. 9 2.6 Public Drinking Water Supplies ..................................................................................................... 9 2.7 Groundwater Protection Priorities .................................................................................................. 9 2.8 Review and Improvement of the Six Strategic Activities............................................................. 10 3. STRATEGIC ACTIVITY 3: DEFINING AUTHORITIES AND RESPONSIBILITIES FOR ADDRESSING PRIORITIES .................................................12 3.1 Responsible Agencies and Programs ............................................................................................ 12 3.2 Coordinating Mechanism.............................................................................................................. 12 3.3 Legal Resources and Authorities .................................................................................................. 12 3.4 Relevant Federal Agencies ........................................................................................................... 12 3.5 Neighboring Tribal Officials ........................................................................................................ 13 3.6 Inter-state Coordination ................................................................................................................ 13 3.7 Local Governments ....................................................................................................................... 13 4. STRATEGIC ACTIVITY 4: EFFORTS TO ACCOMPLISH THE STATE’S GOAL ........................................................................................................................................15 4.1 Programs to Address Priorities ..................................................................................................... 15 4.2 Characterization and Assessment to Support Prevention Decision-Making ................................ 15 4.3 Wellhead Protection Program ....................................................................................................... 16 4.4 Implementation of Prevention Activities ...................................................................................... 16 4.5 Programs with Measurable Objectives for Remediation .............................................................. 18 4.6 Characterization and Assessment Support Remediation Decision-Making ................................. 18 4.7 Provisions to Avoid Cross-Contamination During Remediation.................................................. 18 383-2000-030 / October 1, 1998 / Page ii 5. STRATEGIC ACTIVITY 5: DATA MANAGEMENT...................................................21 5.1 Data Management to Re-evaluate Priorities and Measure Progress............................................. 21 5.2 Using Data from Local, State and Federal Governments ............................................................. 21 5.3 Data Elements Defined ................................................................................................................. 22 5.4 QA/QC for State Monitoring Programs ........................................................................................ 22 6. STRATEGIC ACTIVITY 6: IMPROVING PUBLIC EDUCATION AND PARTICIPATION....................................................................................................................24 6.1 Public Participation is Equivalent to EPA’s in 40 CFR Part 25 ................................................... 24 6.2 Public Education Programs for CSGWPP Issues ......................................................................... 24 6.3 Outreach Mechanisms................................................................................................................... 24 6.4 Public Education Programs........................................................................................................... 24 APPENDIX 1: Pennsylvania Comprehensive State Groundwater Protection Program Profile .……………………………………………………….26 APPENDIX 2: The Six Strategic Activities and Their Adequacy Criteria …..………88 383-2000-030 / October 1, 1998 / Page iii EXECUTIVE SUMMARY The Comprehensive State Groundwater Protection Program (CSGWPP) is a state-EPA initiative that provides a mechanism whereby states and EPA can work together to develop a comprehensive and consistent statewide approach to groundwater quality protection. The Bureau of Water Supply Management, through the CSGWPP Work Group, is serving as the lead state agency in coordinating a consistent groundwater quality protection plan for programs and agencies in the state that have groundwater protection responsibilities. The CSGWPP Work Group is composed of representatives from Department of Environmental Protection and Department of Conservation and Natural Resources programs with groundwater protection responsibilities and the Department of Agriculture. These programs and agencies are listed on page 47 of Appendix 1 to this document. Input to the CSGWPP from other federal, state and local levels will be achieved through the CSGWPP public participation process. CSGWPP development is a dynamic process that consists of a set of six strategic activities; each Strategic Activity has two sets of adequacy criteria. The strategic activities are detailed in Appendix 2. The title and subtitles used in this document and Appendix 1 (which correspond to the adequacy criteria met) have been abbreviated. For a full description of the adequacy criteria, see Appendix 2. These adequacy criteria deal with a Core and Fully-Integrating CSGWPP. A Core program is a means for Pennsylvania to document, and EPA to endorse, the state’s commitment to develop and implement a consistent and comprehensive statewide groundwater quality protection program. Once EPA has endorsed the self assessment and the plans to attain a Core-CSGWPP, Pennsylvania can proceed to the development of a Fully-Integrating CSGWPP. Eventual attainment of a Fully-Integrating CSGWPP means that all groundwater quality protection efforts in the state are focused, coordinated and consistent with Pennsylvania's goal for protection of groundwater resources and the CSGWPP Fully-Integrating adequacy criteria. The criteria for these activities formed the basis for a self-assessment of the current state groundwater protection program and identification of the gaps which need to be addressed to meet the CSGWPP goals. The following is a summary of the CSGWPP and self-assessment for the six strategic activities: STRATEGIC ACTIVITY 1: ESTABLISHING A GROUNDWATER PROTECTION GOAL Pennsylvania has an established goal of groundwater protection which guides all groundwater protection and remediation programs in the state. The goal has undergone public participation and is set forth in DEP’s Principles for Ground Water Pollution Prevention and Remediation, December 1, 1996 (383-0800-001). The goal is consistent with and no less protective than EPA’s goal. The Pennsylvania Clean Streams Law provides the authority for carrying out groundwater protection. There are no identified gaps between the EPA adequacy criteria and Pennsylvania’s program for this activity. Pennsylvania attains Core and Fully Integrating status for this Strategic Activity. 383-2000-030 / October 1, 1998 / Page iv STRATEGIC ACTIVITY 2: ESTABLISHING PRIORITIES TO ACHIEVE THE STATE’S PROTECTION GOAL The 1996 Principles of Ground Water Remediation and Pollution Prevention document binds together programs with groundwater protection and remediation responsibilities by providing the guiding framework for state programs regarding groundwater. The Principles document provides guidance for setting priorities for groundwater related protection plans and programs. The document notes that certain groundwater areas in the state may be determined to be the highest priority for protection. Factors excerpted from the Final Comprehensive State Ground Water Protection Program Guidance, EPA 100-R-93-001, are listed that can be considered when setting groundwater priorities. All programs with groundwater protection and remediation responsibilities have priority-setting procedures that are established through specific program regulations or policies. For the most part, priorities are set based on the excerpted factors, i.e. consideration of the use of the resource, aquifer vulnerability, and potential threat to human health and the environment. Contamination source inventories are maintained and updated and are also used in establishing priorities. Development of technical capabilities, such as computer database systems, models, Geographic Information System (GIS) and Global Positioning System (GPS) technologies, is an ongoing process that also supports priority setting. Groundwater performance measures to support priority setting and measurement of progress in attaining protection and remediation goals are based on Maximum Contaminant Levels (MCLs), Health Advisory Levels (HALs) or other state or federally promulgated standards required to protect human health and the environment. All programs coordinate and integrate groundwater and surface water quality protection and take into consideration public water supply locations in establishing priorities. In addition, a draft state Wellhead Protection Program has been completed and has undergone public participation. Core status is attained for this Strategic Activity. However, Fully Integrating attainment is precluded because at this time, even though all programs have similar priority setting processes, there is no formalized process that guides all programs, and because the state does not have sufficient technical capabilities. Attainment of these criteria could be addressed by developing a formal interprogram priority setting process through the CSGWPP Work Group, and attainment of technical capabilities which are deemed to be sufficient by EPA and the state. STRATEGIC ACTIVITY 3: DEFINING AUTHORITIES AND RESPONSIBILITIES FOR ADDRESSING PRIORITIES The Bureau of Water Supply Management, Pennsylvania Department of Environmental Protection (DEP) serves as the primary point of contact for development and implementation of the CSGWPP and has been successfully coordinating with state agencies and programs with groundwater protection responsibilities. All agencies and programs responsible for addressing the state priorities are identified in the Pennsylvania Comprehensive State Groundwater Protection Program Profile, which is an appendix to the CSGWPP. All of the programs so identified have sufficient legal authority and resources to address groundwater protection and remediation needs, requirements and priorities. Pennsylvania coordinates with relevant federal and interstate agencies operating within the state through mechanisms established by the various 383-2000-030 / October 1, 1998 / Page v regulatory programs and will continue to do so in the continuing development of the CSGWPP. Mechanisms which are in place by the various programs with groundwater protection and remediation responsibilities for local government notification will continue to be utilized, along with additional measures, in the CSGWPP development. Core and Fully-Integrating status are attained for this Strategic Activity. STRATEGIC ACTIVITY 4: EFFORTS TO ACCOMPLISH THE STATE’S GOAL All programs with groundwater protection and remediation responsibilities have in place measurable objectives aimed at prevention of groundwater pollution and for cleanup of groundwater which has been polluted. The programs also have in place procedures for groundwater assessment and characterization for regulated activities which include use and value resource factors. Additionally, all programs (a) have integrated procedures to prevent or minimize contamination, (b) implement additional controls if contamination is increasing toward levels that exceed a criterion or a reference point and (c) take actions to cleanup groundwater that violates human health and environmental protection levels. Those programs with cleanup responsibilities have measurable objectives based on remediation of groundwater resources and conduct comprehensive site assessments for all remediation activities. Remediation focused programs provide for interprogram coordination to avoid cross contamination during cleanup activities. Also, the Office of Pollution Prevention and Compliance Assistance has been formed to assist regulated industries, local governments, homeowners, and others in preventing pollution through increasing efficiencies in energy use, water use, raw materials, and other resources and through protecting natural resources by conservation. All programs are systematically planning to update and improve technical capabilities which include computer hardware/software with statewide application, Geographic Information System (GIS), Global Positioning System (GPS), and integrated database programs. Core status is attained for this Strategic Activity. However, because these capabilities are not sufficient at this time, and the draft Wellhead Protection Program, which was submitted to EPA has not yet been approved, minor gaps exist in fullyattaining this Strategic Activity. These gaps can be satisfied as programs continue to systematically implement plans to develop technical capabilities and it has been determined that these capabilities are sufficient, and EPA provides approval for the Wellhead Protection Program. STRATEGIC ACTIVITY 5: DATA MANAGEMENT All groundwater regulatory programs have a system for collecting and managing data, which are stored in various state and federal databases. Relevant data from local governments and the federal government is utilized to the extent that it is necessary, available and acceptable. All programs have groundwater monitoring requirements for a variety of purposes and all programs have in place approved Quality Assurance/Quality Control protocols. However, the programs’ data management systems are not consistent or compatible which results in cumbersome and time-consuming data sharing across programs. In addition, there is at the present time no formal definition or set of data elements to facilitate data sharing and cross-media analysis. These two 383-2000-030 / October 1, 1998 / Page vi factors preclude Core and Fully Integrating attainment for this Strategic Activity. However, GIS activities in DEP have significantly increased and many programs are beginning to share information across programs through GIS technologies. Attainment is contingent upon DEP’s ability to implement a consistent department wide database management system and develop a formal set or definition of a set of data elements to facilitate data sharing and cross-media analysis. STRATEGIC ACTIVITY 6: IMPROVING PUBLIC EDUCATION AND PARTICIPATION Pennsylvania’s public participation procedures and policies for all programs are consistent with the objectives defined by EPA in 40 CFR Part 25. The development of the CSGWPP adheres to these same objectives. Additionally, all programs have in place public education and outreach activities which make available groundwater monitoring data and other information to the public and those responsible for implementing groundwater protection measures. These education and outreach programs have been effective in educating the public on measures to protect groundwater quality and they will be utilized in the CSGWPP. Pennsylvania increasingly uses the Internet to inform and educate the public on the various programs, publications, and actions of DEP. Many publications and information are now available through DEP’s website. This Strategic Activity is fully-attained. 383-2000-030 / October 1, 1998 / Page vii PENNSYLVANIA’S VISION FOR A COMPREHENSIVE STATE GROUNDWATER PROTECTION PROGRAM Framework Pennsylvania has had pollution control programs in place since 1905. The state’s first comprehensive water pollution control legislation was enacted in 1937, and is known as the Clean Streams Law. This law has been strengthened by amendments a number of times, most recently in 1989. Although Pennsylvania does not have specific groundwater protection statutes, the Clean Streams Law provides an excellent legal framework for managing the groundwater quality in the waters of the Commonwealth. The Act states that “... the waters of the Commonwealth shall be construed to include any and all rivers, streams, creeks, rivulets, impoundments, ditches, and other bodies or channels of conveyance of surface and underground (emphasis added) water, or parts thereof, whether natural or artificial, within or on the boundaries of the Commonwealth.” As listed in Appendix 1, the programs that share responsibility for protection of groundwater quality have used this statutory authority in the development, implementation and enforcement of groundwater quality protection rules, regulations and policies. The proposal for closing the “gaps” that have been identified in this document constitutes the plan for attainment of a Core CSGWPP, and longer-term attainment of a Fully-Integrating CSGWPP. Vision The CSGWPP plan for attainment provides the vision for ground water protection in the Commonwealth and will result in the following: · Full attainment of the State’s groundwater protection goal through effective resource characterization, contamination source identification, and establishment of prerequisite priorities, and increasingly through pollution prevention (source reduction) mechanisms rather than through cross-media transfers and costly pollution control and remediation mechanisms; and · Continuation and improvement of groundwater quality protection by 1) considering current and future uses; 2) improving the cooperation and input with federal agencies, other states and local governments; 3) improving data collection and management; and 4) improving public education and outreach programs on the state’s groundwater resource. 383-2000-030 / October 1, 1998 / Page viii INTRODUCTION In December 1992, EPA issued the Final Comprehensive State Groundwater Protection Program Guidance (EPA 100-R-93-001) to assist states in developing their groundwater protection programs. The Comprehensive State Groundwater Protection Program (CSGWPP) provides a mechanism whereby Pennsylvania and EPA Region III can work together to develop a comprehensive and consistent statewide approach to groundwater quality protection. Under the CSGWPP approach, the Bureau of Water Supply Management, Pennsylvania Department of Environmental Protection, is the lead state agency for coordinating a consistent groundwater quality protection plan for all programs and agencies in the state that have groundwater protection responsibilities. Pennsylvania and EPA will use the CSGWPP approach to focus on a long-term process for improving existing state and federal programs related to groundwater quality protection. The CSGWPP consists of a set of six Strategic Activities, and each Strategic Activity has two sets of adequacy criteria. These adequacy criteria deal with a Core and a Fully-Integrating CSGWPP. The criteria for these activities form the basis for this self-assessment of the current state groundwater protection program and identification of gaps that need to be addressed to meet the CSGWPP goals. The CSGWPP guidance provides initially for self-assessment of the current state groundwater protection program and the development of a Core program. Basically, a Core program is a means for Pennsylvania to document, and EPA to endorse, the state’s commitment to develop and implement a consistent and comprehensive statewide groundwater quality protection program. Once EPA has endorsed the self assessment and the plans to attain a Core-CSGWPP, Pennsylvania can proceed to the development of a Fully-Integrating CSGWPP. Eventual attainment of a Fully-Integrating CSGWPP means that all groundwater quality protection efforts in the state are focused, coordinated and consistent with Pennsylvania's goal for protection of groundwater resources and the CSGWPP Fully-Integrating adequacy criteria. This document represents Pennsylvania's CSGWPP and assessment of the state’s groundwater quality protection programs and activities relative to the CSGWPP adequacy criteria for each Strategic Activity. The assessment identifies and documents those adequacy criteria that are currently being met and those adequacy criteria for which additional work and/or resources are needed in order to achieve conformance with the goals of the CSGWPP initiative. Objectives The objectives of the Pennsylvania Core CSGWPP and self-assessment are to: (1) Identify Pennsylvania groundwater quality protection programs which satisfy the Core and Fully-Integrating CSGWPP adequacy criteria; (2) Identify the "gaps," or areas in the Pennsylvania groundwater quality protection which do not satisfy the Core CSGWPP or Fully-Integrating CSGWPP adequacy criteria; 383-2000-030 / October 1, 1998 / Page ix (3) Identify barriers or obstacles that might prevent Pennsylvania from attaining the Core and Fully-Integrating adequacy criteria; and (4) Identify possible mechanisms such as regulatory approaches, non-regulatory initiatives, and EPA technical assistance, which would aid Pennsylvania in closing the gaps and overcome barriers that would prevent Pennsylvania from attaining EPA endorsement of its Core CSGWPP. The CSGWPP and self-assessment are based on a compilation and evaluation of information on various groundwater quality regulatory requirements and initiatives from programs and agencies in the state with groundwater quality protection responsibilities. A detailed description of the state programs is contained in the Pennsylvania Comprehensive State Groundwater Protection Program Profile (hereafter referred to as the “Groundwater Protection Profile”), which is included as Appendix 1 to this document. Limitations This CSGWPP and self-assessment are as comprehensive and complete as possible given limitations imposed by the dynamics of technical and regulatory considerations and resource constraints. These limitations are influenced by the following: - Dynamics of statutory, regulatory, policy and institutional changes. As these occur, it will necessitate program and policy changes, especially as Pennsylvania continues to develop and implement its Core and Fully-Integrating CSGWPP. - Focus limited to programs with primary or secondary groundwater protection and remediation responsibilities. This CSGWPP and self-assessment cannot, due to resource limitations, be an exhaustive treatment of all of the environmental protection activities in Pennsylvania. It does not address those programs within the state that have limited or no groundwater quality protection components. Content This document describes and assesses the Pennsylvania groundwater quality protection program relative to the adequacy criteria for the six strategic CSGWPP activities. For each adequacy criterion for which gaps have been identified, a discussion is included on the barriers that preclude Pennsylvania from satisfying the adequacy criterion and proposed mechanisms for closing the gaps. Gaps will continue to be assessed and Pennsylvania will work with EPA to close these gaps. Work on a Fully-Integrating CSGWPP will be done concurrently with the work on addressing the gaps identified in the self-assessment and continue until the state and EPA have reached agreement on an endorsable Fully-Integrating CSGWPP. 383-2000-030 / October 1, 1998 / Page x 1. STRATEGIC ACTIVITY 1: ESTABLISHING A GROUNDWATER PROTECTION GOAL 1.1 Through Adequate Public Participation Pennsylvania has revised its 1992 Groundwater Quality Protection Strategy and groundwater protection goal. The revised goal as set forth in the 1996 Principles for Ground Water Pollution Prevention and Remediation is the prevention of groundwater contamination whenever possible and the protection of human health and the environment. This is consistent with EPA’s overall goal of preventing adverse effects to human health and the environment and to protect the environmental integrity of the nation’s groundwater. The Principles also state that the purpose of groundwater remediation is to provide for protection of human health and the environment through the use of appropriate treatment and removal technologies and/or engineering and institutional controls. This goal has undergone public participation through DEP’s established public participation process, which is consistent with federal guidelines. Pennsylvania meets the Core and Fully-Integrating adequacy Criteria. 1.2 No Less Protective than EPA’s Groundwater Protection Goal Pennsylvania’s groundwater quality protection goal is totally consistent with EPA’s overall goal of preventing adverse effects to human health and the environment. The groundwater protection goal is consistent with the provisions of the Pennsylvania Clean Streams Law, Act of 1937, P.L. 1987, as amended in 1989, which provides for preservation and improvement of the waters of the Commonwealth for the protection of public health, animal and aquatic life, and/or industrial consumption and recreation. Through the Clean Streams Law and specific program regulations, the goals and standards are integrated with all other state water quality and environmental goals. Pennsylvania meets the Core and Fully-Integrating Adequacy Criteria. 1.3 Guides at Least One Key State Program Although all programs are consistent with the groundwater protection goal, two programs are presented as examples as being guided by goals that are consistent with the Principles of Ground Water Remediation and Pollution Prevention document. They include the Pesticide Management Program (Department of Agriculture), and the Land Recycling Program (Bureau of Land Recycling and Waste Management). The Pesticide Management Program with the Pennsylvania Department of Agriculture (PDA) is striving for protection of all groundwater sources from degradation, which is consistent with the Principles document. The Land Recycling Program also is consistent with the DEP’s Principles document. Cleanup plans are based on the actual risk that contamination from a site poses to public health and the environment. The State’s groundwater protection goal is consistent with the Pennsylvania Clean Streams Law (which applies to groundwater). The Clean Streams Law provides the legal authority for protection and improvement of the waters of the Commonwealth and guides all state groundwater protection programs. This includes protection of groundwater for human health, 383-2000-030 / October 1, 1998 / Page 1 animal and aquatic life, industrial consumption and recreational uses. The Clean Streams Law guides all federal, state, and local groundwater-related programs operating within the state which address potential sources of contamination, including federally-unregulated sources. The Clean Streams Law is one of the major sources of authority for protecting public health and the environment. Specific program regulations based in whole or in part of the Clean Streams Law for attaining the groundwater protection goal include the following: 25 PA Code Chapters 86, 87, 89, and 90 (coal mining) and Chapter 77 (non-coal mining), Oil and Gas Act, 25 PA Code Chapter 78 (Oil and Gas Regulations), Chapter 6217 Coastal Zone Nonpoint Source Regulations, Nutrient Management Act (Act 6), Pennsylvania Pesticide Control Act of 1973, PA Code Chapter 128 (storage, use and transport of pesticides), 25 PA Code Chapters 260-270 (Hazardous Waste Regulations), 25 PA Code Chapters 271-285 (Municipal Waste Regulations), 25 PA Code Chapters 287-299 (Residual Waste Regulations), Chapter 109 (Wellhead Protection Regulations), and Act 610 (Water Well Drillers License Act). In addition, legislative initiatives mandate groundwater and environmental cleanup standards: Act 2 (Land Recycling and Environmental Remediation Standards Act), Act 32 (Storage Tank and Spill Prevention Act), and Act 108 of 1988 (Hazardous Sites Cleanup Act). Pennsylvania meets the Core and Fully-Integrating Adequacy Criteria. SUMMARY STRATEGIC ACTIVITY 1 Criteria 1.1 1.2 1.3 Core Meet Meet Meet Fully Integrating Meet Meet Meet Gaps None None None Discussion/Identified Gaps Pennsylvania has an established goal of groundwater protection that guides groundwater protection and remediation programs in the state. This goal has undergone public participation, and is set forth in the DEP Principles for Ground Water Pollution Prevention and Remediation.. The Principles document is consistent with the Clean Streams Law. The goal as detailed in the Clean Streams Law and the Principles document is consistent with and no less protective than EPA’s goal. There are no identified gaps; a Core and Fully-Integrating status is attained for this Strategic Activity. Plans to Close Gaps None needed - Core and Fully-Integrating status attained. Barriers to Attaining Core/Fully-Integrating Status None. Core and Fully-Integrating status attained. 383-2000-030 / October 1, 1998 / Page 2 2. STRATEGIC ACTIVITY 2: ESTABLISHING PRIORITIES TO ACHIEVE THE STATE’S PROTECTION GOAL 2.1 Definitions and Priority-Setting Processes Programs with groundwater protection and remediation responsibilities have basic definitions and priority setting procedures and processes. The 1996 Principles of Ground Water Remediation and Pollution Prevention document binds these programs together by providing the guiding framework for state programs regarding groundwater. As noted in the Principles document, “These principles define the framework for establishing program requirements which will provide for careful stewardship of the resource and advance the highest feasible level of ground water protection through the use of control technologies, management practices, and pollution prevention measures at activities which may impact ground water quality.” DEP’s Principles document provides guidance for setting priorities for groundwater related protection plans and programs. The document notes that certain groundwater areas in the state may be determined to be the highest priority for protection. Factors excerpted from the Final Comprehensive State Ground Water Protection Program Guidance, EPA 100-R-93-001, are listed that can be considered when setting groundwater priorities. In addition, DEP’s Groundwater Monitoring Guidance Manual, which is referenced in the Principles document, provides overall guidance across programs on issues of groundwater monitoring. The manual discusses critical points for consideration in groundwater monitoring plans and procedures. The manual is referenced in the Land Recycling Program (Act 2) regulations and is included with the program’s Technical Guidance Manual. The Clean Streams Law provides the legal basis for groundwater protection and basic definitions on pollution and waters of the Commonwealth. Other terms such as wellhead protection areas and groundwater are defined in program regulations and guidances. Consistent definitions cross references are used in program guidances and regulations. For example, the same definition for groundwater is used in the Storage Tank Program, the Land Recycling Program, Residual Waste and Municipal Waste Programs, the Nutrient Management Program, and in the Principles document. Specific priority setting procedures are established through regulations, policies and/or guidances of the programs. Two programs will be described in Section 2.2 to show how Pennsylvania is using the framework priority setting process where groundwater is concerned. These programs include the Land Recycling Program (Bureau of Land Recycling and Waste Management) and the Pesticide Management Program (Department of Agriculture). The groundwater characteristics listed in Section 2.2 are used in setting priorities, determining appropriate remediation methods, and making siting decisions. The primary considerations in setting priorities are protection of human health, safety and the environment. The Groundwater 383-2000-030 / October 1, 1998 / Page 3 Protection Profile (Appendix 1) addresses other specific program considerations for setting priorities. Through the development and implementation of a CSGWPP, Pennsylvania will continue to improve the priority setting process at the regional and program level by improving interprogram coordination and data exchange capabilities. Pennsylvania meets the Core and Fully-Integrating Adequacy Criteria. 2.2 Priority-Setting Process and Groundwater Characteristics Groundwater characteristics used by the various programs to set priorities include those listed in Figure 1 and the following: l l l l Use of the resource (public/private water supplies, agricultural uses, etc.) Aquifer vulnerability Threat to human health and the environment Wellhead protection area delineations FIGURE 1 Groundwater characteristics such as, but not limited to, the following are to be used in setting priorities, determining appropriate remediation methods, and making siting decisions: 1. 2. 3. 4. 5. 6. 7. 8. 9. Intrinsic sensitivity, hydrogeologic regimes and flow patterns (recharge/discharge areas), geologic/hydraulic parameters and local hydrogeologic setting Quantity and potential yield Ambient and/or background groundwater quality as determined by monitoring Potential for remediation where contamination already exists Current use Reasonably expected future use based on demographics, land use, remoteness, quality, and availability of alternative water supplies Values attributed to groundwater resources The interactions and potential contamination impacts between surface and groundwater and the value of groundwater quality to the maintenance of ecosystem integrity Inter-jurisdictional characteristics Many of these types of information (quantity and potential yield, hydrogeologic regimes, flow patterns, local hydrogeologic setting, geologic/hydraulic parameters) are not currently available for the entire state. However, site specific information is often available from site investigations and regional hydrogeologic reports. The Pennsylvania Aquifer Characterization Study, which is being conducted by the Bureau of Topographic and Geologic Survey and is nearly 50 percent completed, will provide a great deal more of this type of information. This will be of additional value in defining groundwater characteristics in the priority setting process. 383-2000-030 / October 1, 1998 / Page 4 The Land Recycling Program and the Pesticide Management Program are detailed here to show how the groundwater characteristics listed in Figure 1 are used in setting priorities, determining appropriate remediation methods, and making siting decisions. The Pennsylvania Department of Agriculture’s generic “Pesticides and Groundwater Strategy” will provide a framework under which PDA can manage specific pesticides required by EPA to have state management plans (SMPs). PDA intends to initiate the strategy through groundwater monitoring and data collection. Priority will be given to areas where special protection is required, such as areas where groundwater is used for public water supply. The strategy also will identify action levels and procedures depending on the extent of contamination. PDA intends to address protection of groundwater through the implementation of Best Management Practices (BMPs) and other prevention activities, and will rely on other state and federal agencies for assistance to promote public awareness and participation. PDA is working with the U.S. Geological Survey to implement a vulnerability assessment plan. The plan will consider the items listed in Figure 1 for setting priorities. The Land Recycling Program as a whole addresses each of the items listed in Figure 1. For each of the possible remediation standards, Background, Statewide Health, and Site Specific standard, conditions at the site must be documented. The site must be characterized including details such as following: l l l l l l the nature, extent, direction, estimated volume, and composition of the contamination source and extent of the releases background concentrations of the constituents of concern affected aquifers existing and potential migration pathways estimated volume of contaminated soil and groundwater The background standard can be chosen that allows the site owner to remediate based on background contamination levels (unrelated to the site). This standard does not allow contamination at a site to remain above the background standard after a cleanup of contaminants that were released at the site. To meet this standard, treatment and removal technologies will generally be used. Institutional controls cannot be used to meet the standard, which is typically applied to areas where there are releases of contaminants that are widespread and are migrating from off-property. Intrinsic hydrogeologic sensitivity For all standards in the Land Recycling Program, and when groundwater is determined to be a media of concern, a hydrogeologic study is required as part of an adequate characterization of the site. For the statewide health standard, one of the steps is to develop the conceptual model of the site by considering (among many other factors) the hydrostratigraphic units and all potential migration pathways. The site specific model also must consider such hydrogeologic factors (Figure 1) in the site investigation and in the development of the risk assessment model for the site. 383-2000-030 / October 1, 1998 / Page 5 For pesticides, the vulnerability assessment will consider the intrinsic hydrogeologic sensitivity in determining priorities for the program. Quantity and potential yield The Statewide Health Standard of the Land Recycling Program considers this aspect of groundwater. All geologic units in Pennsylvania are presumed to be aquifers, and all groundwater in aquifers is presumed to be used or planned to be used (unless groundwater has a background total dissolved solids (TDS) concentration of greater than 2,500 milligrams per liter). Areas that can be shown to be non-use areas for groundwater are provided a different level for cleanup (i.e., alternative medium specific concentrations (MSC) can be used for the cleanup standard). The quantity and potential yield of an aquifer must be considered when developing the site conceptual model and risk assessment under the Site Specific Standard. The Pesticide Management Program will give emphasis to drinking water supplies. Wellhead protection areas will be considered as areas requiring special protection. Ambient/background groundwater quality The Background Standard of the Land Recycling Program uses the background groundwater quality as the basis for cleanup at a site. The Statewide Health Standard and the Site Specific Standard consider the background water quality (using TDS concentrations) for establishing the cleanup levels. PDA’s agricultural vulnerability assessment will include the development of a database with existing pesticide concentrations. Priority will be given to areas where monitoring shows that pesticides have contaminated the groundwater. Potential for remediation The Land Recycling Program considers the potential for remediation by allowing the choice of three main cleanup standards: Background, Statewide Health, and Site Specific standard. Another option is provided for industrial facilities where no financially viable responsible person can be found (or at properties in enterprise zones). Cleanup of such sites is covered under the Special Industrial Areas program. The PDA will consider where continued degradation may exist, and target such areas for pollution prevention management and control activities to protect the groundwater resources. Current use All groundwater is assumed to be used or currently planned to be used unless it can be demonstrated to be a non-use aquifer. Current use of groundwater is considered under the Statewide Health Standard and the Site Specific Standard. Remediation where groundwater is currently used must meet the Statewide Health Standard. The use of groundwater is considered when migration paths are determined under a risk assessment for the Site Specific Standard. 383-2000-030 / October 1, 1998 / Page 6 Current use will be considered by PDA for areas where wellhead protection activities have been established. Priority criteria for monitoring will include population dependence on high quality groundwater supplies. Future use Future use of groundwater is considered under the Statewide Health Standard and the Site Specific Standard. Remediation where groundwater will be used must meet the Statewide Health Standard. Any future use of groundwater is considered when migration paths are determined under a risk assessment for the Site Specific standard. One of the priority concerns for developing the State Management Plans for Pesticides is the use of the aquifer for future needs. Values attributed to groundwater resources For the Land Recycling Program, all saturated geologic units in Pennsylvania are presumed to be aquifers, and all groundwater in aquifers is presumed to be used or planned to be used. Less value is placed on groundwater having a TDS concentration of greater than 2,500 milligrams per liter, or where there is no current or future use of groundwater. The goal of the PDA Pesticides and Ground Water Strategy is to protect all groundwater sources from degradation. Special concern is given to groundwater that is used as a source of drinking water. Groundwater - surface water interactions The Land Recycling Program considers such interactions in the Statewide Health Standard and the Site Specific standard. Point or nonpoint discharges to surface water must meet applicable standards. One of the priority concerns used in the development of the State Management Plan for Pesticides is the contribution of the aquifer to baseflow surface water. Inter-jurisdictional characteristics In the Land Recycling Program, existing applicable state and federal regulations for permitted facilities must be met. This would include sites where other state or federal laws would apply. The Pesticide Management Program also crosses program lines. PDA, DEP, EPA, Natural Resource Conservation Service, Farm Service Agency, USGS, and the Cooperative Extension Service are important participants in the pesticides management program. Pennsylvania meets the Core and Fully-Integrating Adequacy Criteria. 2.3 Contamination Source Inventories and Assessments Programs in Pennsylvania that have groundwater protection and remediation responsibilities have compliance monitoring and reporting requirements, and most programs maintain some type of contamination source inventory. These contamination source inventories are continually being 383-2000-030 / October 1, 1998 / Page 7 updated (i.e. from paper to computerized systems) and are being added to as additional data are generated. DEP is currently conducting a Foundation for Information Exchange (FIX) project that will enhance current computerized data management systems. DEP is moving toward GIS coverages in nearly every program. DEP has developed a GIS 1999 Project with goals and milestones to support permitting, compliance assistance, pollution prevention, emergency response, public education and outreach, resource management, recycling and other land use management decisions. Data on contamination sources are utilized in the establishment of program priorities. For example, for the major groundwater pollution problems, a database of releases from underground storage tanks is maintained on a PC database; a comprehensive inventory of inactive and reclaimed mining activities is maintained on a computerized database; non-coal mining activities since 1972 are maintained on a paper data/mapping system; and information from federal/state programs such as the EPA National Priority List (NPL) listing and Hazardous Sites Cleanup Program (HSCA) are used to add to contamination source inventories. Reports on groundwater activities of programs are published in the biennial EPA Water Quality Inventory (305(b) Report). The state’s WHP program will form the cornerstone of the Source Water Protection Program for groundwater resources serving public water systems. The Source Water Protection program is required to define the boundaries of areas providing source water to public water systems and to identify contaminants in the delineated source areas to determine the susceptibility of public water supplies to contaminants. These assessments are to be completed within two years after EPA approval of the state’s Source Water Protection program. GIS technology will play a crucial role in the development and implementation of these programs. Pennsylvania meets the Core and Fully-Integrating Adequacy Criteria. 2.4 Technical Capabilities Pennsylvania continues to make significant progress in developing technical capabilities that can be used to support a priority-setting process. Several computer database systems are in use (ORACLE/WIMS/ACCESS). The EPA GRITS model is used to predict contamination sources. The CERCLA (Superfund) database is used for site listings and a Geographic Information System (GIS) is beginning to be used in the Hazardous Sites Cleanup Program to identify aspects of a desired study area. GIS capabilities were used for the Nonpoint Source Program to rank state plan watersheds and their potential for agricultural pollution. The Coastal Zone Program is developing GIS for bluff recession analysis, and the Chesapeake Bay Program has purchased GIS equipment for developing a ranking system of the state water plan watersheds according to their agricultural pollution potential. GIS is used by the Safe Drinking Water Program to assess potential threats to drinking water and to track monitoring locations in the Ambient and Fixed Station Network (FSN) monitoring programs. Also, GPS is also being used to more accurately locate sources and facilities. GIS is used by the Bureau of Topographic and Geologic Survey to refine the location of water wells. It is planned that all programs will continue to improve data management systems, develop GPS capabilities and expand and refine GIS. These will be coordinated through GIS and database committees to provide for consistency in the priority setting process. Two GIS committees have been formed within DEP. The GIS Technical Committee is represented by every program with GIS interests. In addition, a GIS Management Committee has 383-2000-030 / October 1, 1998 / Page 8 been formed to track the needs and developments of GIS issues. The Management Committee consists of members from the DEP Deputates, and from the DCNR Conservation and Engineering Services Deputate (includes the Bureau of Topographic and Geologic Survey). Both committees meet approximately bi-monthly. Also, both committees are working in contract with the Pennsylvania State University’s (PSU) Environmental Resources Research Institute (ERRI) to develop DEP’s GIS capabilities. A GIS Support Center has been established at ERRI that will eventually serve as a central repository of GIS information. A comprehensive, integrated system for storing, organizing, and retrieving digital map/image GIS data is being developed. This is the Pennsylvania Spatial Data Access (PASDA) site at PSU. PASDA is an Internet based system that supports search, display, and retrieval of GIS data and imagery related to Pennsylvania’s environment. PASDA is being developed in accordance with guidelines established by the Federal Geographic Data Committee, and is a collaborative effort between DEP and PSU. This GIS Support Center will assist Commonwealth agencies with the application of GIS and associated remote sensing technologies. Training of Commonwealth personnel will also be conducted through the GIS Support Center. Moreover, these GIS developments are allowing greater public sharing of data collected by DEP. Pennsylvania meets the Core Adequacy Criterion. 2.5 Measures of Groundwater Protection At the current time, prevention of groundwater pollution is achieved through program specific regulations and policies which use water quality and performance measures such as background levels, drinking water standards or other appropriate health and environmental protection standards. Act 2 of 1995, the Land Recycling and Environmental Remediation Standards Act, specifies certain levels to be attained for groundwater cleanup and remediation. Section 105 of Act 2 created a Scientific Advisory Board whose duty was to review and develop cleanup and remediation standards. The Principles of Ground Water Pollution Prevention and Remediation specifies that groundwater protection will be based on prevention of contamination whenever possible. Pennsylvania meets the Core and Fully-Integrating Adequacy Criteria. 2.6 Public Drinking Water Supplies One of the state’s highest priorities is protecting public water supplies. Authority for such protection is addressed under the Pennsylvania Clean Streams Law and Safe Drinking Water Program statutes and regulations. All programs consider water supply locations in the implementation of management and protection measures. A state Wellhead Protection Program has been submitted to EPA and is awaiting final approval. Pennsylvania meets the Core and Fully-Integrating Adequacy Criteria. 2.7 Groundwater Protection Priorities Pennsylvania continually coordinates and integrates groundwater quality protection priorities with surface water quality and other environmental priorities. Programs with groundwater quality protection and groundwater remediation responsibilities have elements that consider inter-media 383-2000-030 / October 1, 1998 / Page 9 environmental impacts. The Mining and Reclamation Program assumes a direct coupling between surface and groundwater; the Oil and Gas Program collects information on oil and gas wells for ground and surface water quality assessments; the Nonpoint Source Program collects ground and surface water quality data for watershed assessments; the Land Recycling and Waste Management Program conducts total site assessments which include evaluation of soil, surface water and groundwater; and the Environmental Cleanup Program requires assessment of air, surface and groundwater protection elements during remediation projects. Remediation projects also require permits from appropriate regulatory programs, which take into consideration interactions through the various media. Act 2 of 1995, the Land Recycling and Environmental Remediation Standards Act, and the program regulations specifically require the consideration of surface water quality impacts from contaminated groundwater remediation activities. Pennsylvania is sufficiently coordinating its groundwater protection priorities with surface water quality and other priorities. Pennsylvania meets the Core and Fully-Integrating Adequacy Criteria. 2.8 Review and Improvement of the Six Strategic Activities Pennsylvania views the CSGWPP as a dynamic and ongoing process and intends to regularly review, update and improve it. Statutes, regulations and guidances relating to groundwater quality protection are consistently refined and updated to reflect technological advances and changing state and federal priorities. This provision will allow for Pennsylvania to pursue, to the extent that resources allow, the means for addressing gaps in the Core and Fully-Integrating Criteria. Pennsylvania meets the Core and Fully-Integrating Adequacy Criteria. SUMMARY STRATEGIC ACTIVITY 2 Criteria 2.1 2.2 2.3 2.4 2.5 2.6 2.7 2.8 Core Meet Meet Meet Meet Meet Meet Meet Meet Fully-Integrating Meet Meet Meet Not Met Meet Meet Meet Meet Gaps None None None Fully-Integrating None None None None Discussion/Identified Gaps Programs with groundwater protection and remediation responsibilities have priority-setting procedures that are established through specific program regulations or policies. For the most part, priorities are set based on regional considerations of the use of the resource, aquifer vulnerability, potential threat to human health and the environment and wellhead protection area delineations. Contamination source inventories are maintained and updated and are also used in 383-2000-030 / October 1, 1998 / Page 10 establishing priorities. Development of technical capabilities, such as computer database systems, models, GIS and GPS is an ongoing process that also supports priority setting. Groundwater performance measures to support priority setting and measurement of progress in attaining protection and remediation goals are based on Maximum Contaminant Levels (MCLs), Health Advisory Levels (HALs) or other state or federally promulgated standards required to protect human health and the environment. All programs coordinate and integrate groundwater and surface water quality protection and take into consideration public water supply locations in establishing priorities. In addition, the state Wellhead Protection program should soon be finalized. Adequacy criterion 2.4 satisfies the Core requirements, but does not satisfy the Fully-Integrating requirements because the state does not have sufficient technical capabilities at this time. Plans to Close Gaps Although Pennsylvania does not have a formal statewide priority process, all programs use a priority process to protect Pennsylvania's air, land and water from pollution and to provide for the health and safety of its citizens through a cleaner environment (the DEP mission). All of the programs use priority processes that rely on the items listed in Figure 1 (see Appendix 1 for program specific details). Moreover, through the development of a CSGWPP, DEP will continue to monitor the priority setting process at the regional and program level by improving interprogram coordination and data exchange capabilities. This can be accomplished through the continuation of the existing CSGWPP Work Group, which includes representatives from state programs with groundwater quality protection and remediation responsibilities. The Work Group meets on an as-needed basis. The Fully-Integrating gap identified for criterion 2.4 will eventually be addressed as the technical capabilities are systematically expanded and it is determined that these technical capabilities are sufficient. EPA input on making a sufficiency determination will be necessary. Barriers to Attaining Core/Fully-Integrating Status There are no barriers to attaining Fully-Integrating status for criterion 2.4, assuming that the state and EPA can agree on a determination of sufficiency for technical capabilities. 383-2000-030 / October 1, 1998 / Page 11 3. STRATEGIC ACTIVITY 3: DEFINING AUTHORITIES AND RESPONSIBILITIES FOR ADDRESSING PRIORITIES 3.1 Responsible Agencies and Programs Pennsylvania’s Groundwater Protection Profile provides a list of the agencies in the state with groundwater protection and remediation responsibilities, and a summary of the regulatory programs. The Bureau of Water Supply Management, Pennsylvania Department of Environmental Protection serves as the primary contact point with EPA in the development of the CSGWPP, and has been successfully coordinating with state agencies and programs with groundwater protection responsibilities. Since the Core and Fully-Integrating criteria are synonymous, Pennsylvania meets both. 3.2 Coordinating Mechanism A CSGWPP Work Group, which includes state agencies with groundwater protection and remediation responsibilities, has been established. This Work Group, which meets on an asneeded basis, is described in the Groundwater Protection Profile. The CSGWPP Work Group specifically addresses the CSGWPP activities and criteria for each program with groundwater protection responsibilities. The CSGWPP Work Group serves as the coordinating mechanism to ensure that each program’s expertise is brought to bear on the State’s groundwater protection priorities. Pennsylvania meets the Core and Fully-Integrating Adequacy Criteria. 3.3 Legal Resources and Authorities Programs with groundwater quality protection and remediation responsibilities have sufficient legal authority to address the State’s groundwater protection needs, requirements, and priorities under the CSGWPP. The Pennsylvania Clean Streams Law and Act 2 of 1995, the Land Recycling and Environmental Remediation Standards Act, together with program specific regulations and policies, which are identified in the Groundwater Protection Profile and in the CSGWPP and self-assessment under Strategic Activity 1, provide sufficient legal framework and authority for protection and remediation of groundwater quality. Pennsylvania meets the Core and Fully-Integrating Adequacy Criteria. 3.4 Relevant Federal Agencies Pennsylvania coordinates with federal agencies working within the state within the various environmental and regulatory programs. Specific federal agencies and contacts for the various state regulatory programs with groundwater protection responsibilities include the U.S. Department of the Interior (Office of Surface Mining, United States Geological Survey, United States Fish and Wildlife Service, Bureau of Land Management, and United States Bureau of Mines), EPA (UST/LUST, Nonpoint Source Program, Chesapeake Bay Program, Groundwater Protection Program, and Pesticide Management Program), U.S. Department of Agriculture 383-2000-030 / October 1, 1998 / Page 12 (Natural Resources Conservation Service, Agricultural Research Service, Cooperative State Research Service, Economic Research Service, Extension Service, Farm Service Agency, National Agriculture Library, and United States Forest Service). U.S. Department of Commerce (National Oceanic And Atmospheric Administration), Nuclear Regulatory Commission, Department of Energy, Department of Transportation and Department of Defense. These agencies have been provided opportunity for input and comment on the CSGWPP. Pennsylvania meets the Core and Fully-Integrating Criteria. 3.5 Neighboring Tribal Officials There are no tribal lands or tribal governments in Pennsylvania. The mechanism for consultation with other states is discussed in the following criterion (3.6). 3.6 Inter-state Coordination Pennsylvania works with environmental protection agencies of adjacent states to protect surface and groundwater quality of the major interstate ground and surface waters. The following agencies and organizations are utilized by the various programs in addressing interstate ground and surface water quality protection: Delaware River Basin Commission, Susquehanna River Basin Commission, Ohio River Valley Water Sanitation Commission, Interstate Commission on the Potomac River Basin, Chesapeake Bay Program, Interstate Oil and Gas Commission, Delaware Estuary Program, Christiana Basin Watershed Project, and Conference of Radiation Control Program Directors. These, along with direct coordination with adjacent state environmental agencies and coordination with EPA Region III states through EPA workshops, provide the capabilities to support any needed interstate coordination of ground and surface water issues. They have been provided opportunity for input and comment on the CSGWPP. Pennsylvania meets the Core and Fully-Integrating Criteria. 3.7 Local Governments Each program with groundwater protection and remediation responsibilities utilizes various methods and mechanisms to ensure local notification, involvement and participation. These mechanisms include notification by direct mailing, technical advisory committees, county conservation districts, regional roundtables, workshops, county health departments, Pennsylvania Groundwater Policy Education Project, and Water Resources Education Network. However, because of the large number of municipalities in Pennsylvania (approximately 2600), coordination of this task statewide for the CSGWPP will provide a unique and interesting challenge. The above described mechanisms, and with such organizations as the Pennsylvania State Association of Township Supervisors, Pennsylvania State Association of Boroughs, Pennsylvania State Association of County Commissioners, and the Pennsylvania League of Cities and Municipalities, along with publication in the Pennsylvania Bulletin, will be utilized to notify and provide opportunity for local government involvement in development and implementation of the state Core CSGWPP. The difficulty comes with sharing information at the local levels of government where many of the land use decisions are made that ultimately affect groundwater quality. Many local government bodies do not have the technical capability to 383-2000-030 / October 1, 1998 / Page 13 factor in their activities with groundwater issues. The new emphasis on regional and watershed organizations will also help to bridge this deficiency of knowledge and technical capabilities at some local levels. The draft CSGWPP and Self Assessment and the CSGWPP profile were made available for public comment by a notice in the Pennsylvania Bulletin and the DEP Update. Public comments were accepted during this time. The text of the draft CSGWPP has been posted on DEP’s website. Pennsylvania meets the Core and Fully-Integrating Criteria. SUMMARY STRATEGIC ACTIVITY 3 Criteria 3.1 3.2 3.3 3.4 3.5 3.6 3.7 Core Meet Meet Meet Meet Meet Meet Meet Fully-Integrating Meet Meet Meet Meet Meet Meet Meet Gaps None None None None None None None Discussion/Identified Gaps The Bureau of Water Supply Management, Pennsylvania Department of Environmental Protection serves as the primary point of contact for development and implementation of the CSGWPP, and has been successfully coordinating with state agencies and programs with groundwater protection responsibilities. Agencies and programs responsible for addressing the state priorities have been identified in the Pennsylvania Groundwater Protection Profile. All of the programs so identified have sufficient legal authority and resources to address groundwater protection and remediation needs, requirements and priorities. Pennsylvania coordinates with relevant federal and interstate agencies operating within the state through mechanisms established by the various regulatory programs and will continue to do so in the continuing development of the CSGWPP. Likewise, mechanisms that are in place by the various programs with groundwater protection and remediation responsibilities for local government notification will continue to be utilized, along with additional measures, in the CSGWPP development. Core and Fully-Integrating status are attained for this Strategic Activity. Plans to Close Gaps No gaps have been identified. Core and Fully-Integrating status attained. Barriers to Attaining Core/Fully Integrating Status None. Core and Fully-Integrating status attained for this Strategic Activity. 383-2000-030 / October 1, 1998 / Page 14 4. STRATEGIC ACTIVITY 4: EFFORTS TO ACCOMPLISH THE STATE’S GOAL 4.1 Programs to Address Priorities Programs with groundwater protection and remediation responsibilities have measurable objectives aimed at preventing pollution from reaching groundwater and remediating groundwater that has been polluted. These measures can include permitting requirements, increased efforts to educate the regulated community on pollution prevention through source reduction (i.e. not creating polluting substances to begin with, through process and raw material shifts), technological controls and performance standards, siting of facilities and activities, implementation of best management practices, and compliance and enforcement activities. For example, the Water Supply program is developing a Wellhead Protection Program to ensure protection of public water supplies, the Mining and the Oil and Gas programs issue permits which specify technologies and standards to protect surface and groundwater quality, the Nonpoint Source Program establishes effective best management practices for agricultural related activities, the Storage Tank program establishes siting and construction standards to prevent groundwater pollution, the Land Recycling and Waste Management program issues permits and establishes performance and construction standards for landfills to prevent surface and groundwater pollution, and the Department of Agriculture controls pesticide usage through the State Pesticide Management Plan. Remediation programs such as the Land Recycling program and Environmental Cleanup Program establish standards for environmental cleanup consistent with the mandates of Act 2 of 1995, the Land Recycling and Environmental Remediation Standards Act. Also, the Office of Pollution Prevention and Compliance Assistance (OPPCA) has been formed to assist regulated industries, local governments, homeowners, and others in preventing pollution through increasing efficiencies in energy use, water use, raw materials, and other resources and through protecting natural resources by conservation. OPPCA’s mission will be achieved by providing direct technical assistance and through integration of pollution prevention activities across Departmental programs so that prevention takes precedence over cleanup. OPPCA provides a site visit service that can assist in the prevention of groundwater pollution. During these site visits, OPPCA pollution prevention teams, consisting of Department personnel from across various programs, help to identify ways in which the regulated industries can reduce or eliminate the creation of pollutants through more efficient use of water, raw materials, energy and other resources. Pennsylvania meets the Core and Fully-Integrating Adequacy Criteria. 4.2 Characterization and Assessment to Support Prevention Decision-Making - Definitions and Approaches are Applied in a Consistent Manner - Factors Considered Include Intrinsic Sensitivity, Geologic/Hydrogeologic Settings and Potential Sources of Contamination; When Necessary, Other Groundwater Characteristics, Such as, but not Limited to Those Listed in Figure 1 are Considered - Systematic Implementation to Further Develop Technical Capabilities 383-2000-030 / October 1, 1998 / Page 15 Groundwater related programs have procedures in place for groundwater assessment and characterization for regulated activities, which include use and value resource factors listed in Figure 1. All sites under the Land Recycling program must characterize the nature and extent of any contamination of the groundwater resources; the Mining Program requires that permit applicants submit extensive information on surface and groundwater resources within and adjacent to the mining area; the Storage Tank Program considers factors which relate to vulnerability, use and value of the groundwater resource; the Oil and Gas Program requires predrilling water quality assessments; the Nonpoint Source Program requires site assessments; the residual waste program has specific siting and assessment requirements for groundwater protection; the Water Supply Management Program conducts vulnerability assessments to determine which public water supplies are vulnerable to pesticide and certain industrial contaminants; and Water Quality Protection Program conducts or requires assessments for permitted activities such as land application or on-lot septic systems to determine vulnerability of the resource and effectiveness of the treatment technology. DEP’s Groundwater Monitoring Guidance Manual provides guidance on site evaluations and assessments to provide consistency across all programs for monitoring decisions. Most programs are implementing plans to update and improve technical capabilities. These plans include computer hardware/software that can be used statewide, GIS, GPS, and integrated programming. DEP is moving toward GIS coverages in nearly every program. DEP has developed a GIS 1999 Project with goals and milestones to support permitting, compliance assistance, pollution prevention, emergency response, public education and outreach, resource management, recycling and other land use management decisions. DEP staff will have desktop access to the GIS to conduct daily activities. Pennsylvania meets the Core Adequacy Criterion. 4.3 Wellhead Protection Program A proposed Wellhead Protection Program has been submitted to EPA. Provisions of the program, which are voluntary, are being actively implemented. Pennsylvania meets this Core (optional) Adequacy Criterion. 4.4 Implementation of Prevention Activities - Implement Prevention Measures - Implement Additional Controls if Contamination is Detected or Increasing - Take Immediate Action if Reference Point is exceeded Programs with groundwater protection/remediation responsibilities have integrated procedures to prevent or minimize contamination, implement additional controls if contamination is increasing toward levels that exceed a criterion or reference point and take actions to remediate groundwater that exceeds established human health and environmental protection levels. Monitoring requirements are specified for regulated activities that provide for assessment of effectiveness of treatment or technology and siting requirements in meeting established goals and protection of the groundwater resource. DEP has created a new Office of Pollution Prevention and Compliance 383-2000-030 / October 1, 1998 / Page 16 Assistance. The primary mission of this office is to work in a spirit of cooperation with the regulated community to prevent pollution and strive for excellence in meeting environmental protection and permitting requirements. Program specific procedures for preventing and minimizing contamination, assessing effectiveness of prevention requirements and remediating polluted groundwater are detailed in the Groundwater Protection Profile. The Storage Tank Program has an integrated strategy that addresses prevention, additional controls, and immediate action. Leak detection and upgrade requirements are part of the prevention measures used in this statewide program. Leak detection is required on all regulated underground storage tanks (except for emergency generator tanks). The goal is to detect and stop a leak prior to any impact on groundwater or in time to prevent any widespread groundwater contamination that cannot be effectively remediated. All new regulated underground storage tanks are also required to have corrosion and spill/overfill protection; existing regulated tanks will be required to have corrosion and spill/overfill protection by December 22, 1998. Site specific permitting requirements have been developed for targeted storage tanks including new large aboveground storage tanks, field constructed underground storage tanks, and highly hazardous underground storage tanks. The applicant must provide information on the presence of carbonate bedrock. An environmental assessment must be developed that considers potential impacts to public health and safety, and the environment (including water quality and features such as public water supplies). The administration of the Storage Tank and Spill Prevention Program includes provisions for controls once contamination is suspected or detected. Subchapter D, Chapter 245 of the Pennsylvania Code outlines the corrective action process for responding to releases from regulated aboveground and underground storage tanks. These regulations outline the necessary site characterization work to define any impacts on groundwater and implement remedial actions. In addition, the Corrective Action Regulations (specifically, §246.306) require immediate interim remedial actions upon confirmation of a release. This includes the removal of the regulated substance from the tank, the identification and mitigation of hazards from the free product and vapor, and the prevention of any further migration of a substance released from the storage tank. The Pennsylvania Department of Agriculture is establishing their Pesticides and Ground Water Strategy. The program implements prevention measures through the development of educational materials and Best Management Practices (BMPs). The PDA also is developing a monitoring program for pesticides that will support a vulnerability assessment. A response plan for when pesticides are detected will be used. Maximum contaminant levels (MCLs) will be used as a reference point. Voluntary or mandatory BMPs may be enacted depending on the level of vulnerability and the concentration of the pesticide. When pesticide concentrations exceed the action level reference point, use restrictions or product cancellations may be used to prevent further contamination. Pennsylvania meets the Core and Fully-Integrating Adequacy Criteria. 383-2000-030 / October 1, 1998 / Page 17 4.5 Programs with Measurable Objectives for Remediation Programs with major remediation responsibilities (Land Recycling and Waste Management, Storage Tanks, and Environmental Cleanup Program) all have measurable objectives based on the remediation of groundwater resources. The Land Recycling and Waste Management Program oversees remediation efforts in accordance with the provisions and mandates of Act 2 of 1995 and the CERCLA, HSCA, and hazardous and residual waste regulations. The Storage Tank Program oversees cleanup and remediation efforts in accordance with the provisions of Act 2 of 1995 and the Corrective Action Regulations. The Environmental Cleanup Program oversees remediation activities in accordance with the provisions of Act 2 of 1995. All remediation activities include a comprehensive site characterization and assessment. Programs without direct groundwater remediation responsibilities provide technical support and input as needed and requested. Pennsylvania meets the Core and Fully-Integrating Adequacy Criteria. 4.6 Characterization and Assessment Support Remediation Decision-Making - Consistent Definitions and Approaches - Groundwater Characteristics are Considered - Developing Technical Capabilities to Support Its Decision Making Programs with remediation responsibilities as described above oversee comprehensive site assessments by responsible parties for all cleanup activities. These assessments are conducted in accordance with established procedures in the Land Recycling Technical Guidance Manual, integrated waste management regulations (municipal, residual, and hazardous) which require baseline studies, monitoring and post-closure responsibilities, and Groundwater Monitoring Guidance Manual. These are applied in a consistent manner across all programs and consider the groundwater characteristics listed in Figure 1. The development of GIS capabilities, which are in progress, will be an asset in conducting these evaluations. Pennsylvania meets the Core and Fully Integrating Adequacy Criteria. 4.7 Provisions to Avoid Cross-Contamination During Remediation Programs with remediation responsibilities have provisions in place that provide for interprogram coordination in order to avoid cross-contamination during remediation activities. Specific provisions for consideration on inter-media cross-contamination are contained in Act 2 1995, the Land Recycling and Environmental Remediation Standards Act. Remediation technologies frequently generate air discharges, wastewater, or residual or hazardous solid waste. The appropriate program is contacted if another type of waste will be generated during remediation activities. Act 2 maintains permitting and operational requirements for the disposal or release of by-products generated by remediation activities. These checks are typically done in the DEP regions through interprogram coordination. Programs with environmental cleanup projects (typically includes the Storage Tank Program, Hazardous Sites Cleanup Program, and Land Recycling Program) notify other programs of developments in specific groundwater cases that will require coordination. For example, other programs are informed about remediation sites 383-2000-030 / October 1, 1998 / Page 18 that will likely generate some type of waste, such as wastewater or air discharges. Under the regulations for Act 2, discharges to surface water (including diffuse groundwater) must meet applicable surface water quality standards. Pennsylvania meets the Core and Fully-Integrating Adequacy Criteria. SUMMARY STRATEGIC ACTIVITY 4 Criteria 4.1 4.2 4.3 4.4 4.5 4.6 4.7 Core Meet Meet Meet Meet Meet Meet Meet Fully-Integrating Meet Not Met Not Met Meet Meet Meet Meet Gaps None Fully Integrating Fully Integrating None None None None Discussion/Identified Gaps Programs with groundwater protection and remediation responsibilities have in place measurable objectives aimed at prevention of groundwater pollution and cleanup of groundwater that has been polluted. In addition, the Groundwater Monitoring Guidance Manual provides guidance for monitoring activities, including guidelines for the abandonment of wells. These guidelines were developed in cooperation with the Bureau of Topographic and Geologic Survey, which has responsibility for well abandonment. The programs also have in place procedures for groundwater assessment and characterization for regulated activities which include use and value resource factors listed in Figure 1. Additionally, all programs have integrated procedures to prevent or minimize contamination, implement additional controls if contamination is increasing toward levels that exceed a criterion or reference point and take actions to clean up groundwater that violates human health and environmental levels. Those programs with cleanup responsibilities have measurable objectives based on remediation of groundwater resources and conduct comprehensive site assessments for remediation activities. Remediation focused programs provide for interprogram coordination to avoid cross contamination during cleanup activities. All programs are systematically planning to update and improve technical capabilities that include computer hardware/software with statewide application, GIS, GPS, and integrated database programs. Because these capabilities are not sufficient, the Fully-Integrating criterion for adequacy criterion 2 for this strategic activity is not currently met. A draft Wellhead Protection Program has been submitted to EPA. Because it has not yet been approved, this precludes current attainment of adequacy criterion 3. Plans to Close Gaps The gap identified for Fully-Integrating adequacy criterion 2 will be met as programs continue to systematically implement plans to develop technical capabilities and it has been determined that these capabilities are sufficient to support decision-making. This may ultimately be an 383-2000-030 / October 1, 1998 / Page 19 administrative decision based on effective and efficient use of resources. DEP, with its GIS 1999 Project, is developing its technically capabilities. The Fully-Integrating gap identified for adequacy criterion 3 is transient and will be satisfied upon submittal by Pennsylvania and approval by EPA of the Wellhead Protection Plan. This is anticipated in the near future. Barriers to Attaining Core/Fully Integrating Status Core status is attained. There are no foreseeable barriers to attaining the Fully-Integrating status. 383-2000-030 / October 1, 1998 / Page 20 5. STRATEGIC ACTIVITY 5: DATA MANAGEMENT 5.1 Data Management to Re-evaluate Priorities and Measure Progress All groundwater regulatory programs have a system for collecting and managing data and information. These data are stored in various state and federal databases. The Mining Program maintains a comprehensive computer inventory on active and inactive/reclaimed mining activities on the LUMIS system; the Storage Tank Program uses the Land Recycling Program Database; Oil and Gas Program data is maintained and stored on the LABS database; Land Recycling and Waste Management and Environmental Cleanup programs utilize ORACLE and the Land Recycling Program Database (using ACCESS); Watershed Conservation Program stores information on the STORET system. The data stored on these various systems are utilized for implementing all program responsibilities, including measuring progress in attaining protection and remediation goals, establishing priorities, and developing groundwater quality assessments and trend analyses. In addition, DEP is currently undertaking a Foundation for Information Exchange (FIX) project that will enhance current computerized data management systems. Although all program data management systems are not consistent or compatible, data sharing across all programs is routine; however, at times it can be a somewhat cumbersome and time consuming activity. Department Secretary James Seif, at the Conference on Local Solutions to Pennsylvania’s Pollution held in State College in October 1995, recognized the problems with the current data management systems when he stated that “...there is room for a lot of improvement in DEP’s data system,” and “He would like to increase monies for Conservation Districts, comprehensive data systems and maybe GIS hardware and expertise.” New emphasis is being placed on GIS technologies. DEP is working with PSU to develop its GIS capabilities. A comprehensive, integrated system for storing, organizing, and retrieving digital map/image GIS data is being developed. This is the Pennsylvania Spatial Data Access (PASDA) site at PSU. PASDA is an Internet based system that supports search, display, and retrieval of GIS data and imagery related to Pennsylvania’s environment. PASDA is being developed in accordance with guidelines established by the Federal Geographic Data Committee, and is a collaborative effort between DEP and PSU. All of the DEP Deputates are involved and new abilities to use and exchange data between programs are being developed. Although Pennsylvania meets the basic intent of the Core Adequacy Criterion, this reliance on separate, uncoordinated data systems could be considered a gap at this time. 5.2 Using Data from Local, State and Federal Governments All groundwater regulatory programs coordinate interprogram use of groundwater data as discussed in criterion 5.1 above. Data from local governments and federal programs also are utilized to the extent that it is necessary, available, and meets data quality objectives. Under the Municipalities Planning Code, a local government may undertake environmental studies and water surveys. The State’s Wellhead Protection Program has been the program that has had the 383-2000-030 / October 1, 1998 / Page 21 most contact with local governments regarding the sharing of groundwater quality information. Other local government data are obtained from special projects that are conducted in conjunction with the state, EPA, and USGS. Additional data from other state and federal agencies (i.e. USGS, EPA, USDA, and Pennsylvania Department of Agriculture) are obtained from several ongoing special studies which address impacts of land use on groundwater quality. Data and information obtained from these sources are utilized in conducting groundwater quality site assessments, trend analyses, and setting priorities across programs. Pennsylvania meets the Core and Fully-Integrating Adequacy Criteria. 5.3 Data Elements Defined All groundwater regulatory programs collect, store and manage data that are relevant to the specific program needs and requirements. The use of EPA’s Minimum Set of Data Elements is being promoted, as applicable, for all programs. Data are available for cross program sharing, and are also available to the public or other state, federal or local agencies upon request. As noted in the discussion under criterion 5.1, programs routinely and regularly share data in conducting cross-media analyses and site assessments. The Land Recycling Program Database (Microsoft Access) is being used by the Land Recycling Program, the Environmental Cleanup Program, the Storage Tank Program, and the Hazardous Sites Cleanup Program to monitor soil and groundwater cases. There is no formal definition or set of data elements beyond this new database that would facilitate data sharing and cross-media analyses and provide for consistent and comparable data. However, the Land Recycling Program Database can be considered to meet the basic intent of the Core Adequacy Criterion. Continued improvement in data management and the use of the Minimum Set of Data Elements is anticipated in DEP. Pennsylvania meets the Core Adequacy Criteria; however, this is identified as a gap in meeting criteria for the Fully-Integrating CSGWPP. 5.4 QA/QC for State Monitoring Programs All groundwater regulatory programs have requirements for groundwater quality monitoring for a variety of purposes. All samples that are collected and submitted to the laboratory for analysis must comply with a strict set of QA/QC protocols. All programs have approved QA/QC protocols in place. Pennsylvania meets the Core and Fully-Integrating Adequacy Criteria. SUMMARY STRATEGIC ACTIVITY 5 Criteria 5.1 5.2 5.3 5.4 Core Not met Meet Meet Meet Fully-Integrating Not met Meet Not met Meet Gap Core/Fully-Integrating None Fully-Integrating None 383-2000-030 / October 1, 1998 / Page 22 Discussion/Identified Gaps All groundwater regulatory programs have a system for collecting and managing data, which are stored in various state and federal databases. Relevant data from local governments and the federal government are utilized to the extent that it is necessary, available and acceptable. All programs have groundwater monitoring requirements for a variety of purposes, and all programs have in place approved QA/QC protocols. However, all of the programs’ data management systems are not consistent or compatible, which results in cumbersome and time-consuming data sharing across programs. This is a potential gap in the Core CSGWPP for adequacy criterion 1 for this strategic activity. The DEP Secretary recognized and discussed this problem at the conference on Local Solutions to Pennsylvania’s Pollution, which was held in State College in October 1995. DEP is currently conducting a Foundation for Information Exchange (FIX) project that will enhance current computerized data management systems. DEP is moving toward GIS coverages in nearly every program. DEP has developed a GIS 1999 Project with goals and milestones to support permitting, compliance assistance, pollution prevention, emergency response, public education and outreach, resource management, recycling and other land use management decisions. It is anticipated that the gap for adequacy criterion 1 will be solved in the future. A related gap exists for adequacy criterion 3 because there is at the present time no formal definition or set of data elements to facilitate a department-wide data sharing and cross-media analysis. Plans to Attain Core/Fully-Integrating Status The CSGWPP Work Group will work to recommend and implement data exchanging capabilities between programs. As discussed above, DEP Secretary James Seif recognized and discussed this issue at a statewide conference in October 1995. In the past three years, DEP’s Foundation for Information Exchange (FIX) project and GIS efforts have moved toward better cross-program communication that will assist in attaining this criterion.. Barriers to Attaining Core/Fully-Integrating Status A potential barrier to attaining the Core and Fully-Integrating status for these adequacy criteria (5.1 and 5.3) is the possible significant time and resources that would be required to attain a consistent statewide database management system. Implementation of the FIX project and increased application of GIS tools should provide substantial impetus in attaining this criterion. 383-2000-030 / October 1, 1998 / Page 23 6. STRATEGIC ACTIVITY 6: IMPROVING PUBLIC EDUCATION AND PARTICIPATION 6.1 Public Participation is Equivalent to EPA’s in 40 CFR Part 25 The public participation process established and implemented by Pennsylvania meets the objectives of 40 CFR Part 25. The development of the CSGWPP adheres to established DEP policies for public participation, which are consistent with these federal regulations. Pennsylvania meets the Core and Fully-Integrating Adequacy Criteria. 6.2 Public Education Programs for CSGWPP Issues All programs have active education programs to provide information to the public through a variety of forums, including the DEP Internet site. These include manuals, brochures, fact sheets, informational and educational public meetings, periodic newsletters, workshops, training sessions, roundtables, and special educational and outreach programs such as ENVIROTHON, Pennsylvania Groundwater Policy Education Project, and Water Resources Education Network. These existing mechanisms will be used to ensure adequate public education on the continuing development of the CSGWPP. Pennsylvania meets the Core and Fully-Integrating Criteria. 6.3 Outreach Mechanisms - Providing Information to Those Responsible for Implementing Groundwater Protection Measures - An Outreach Process for Data and Information All groundwater regulatory programs have mechanisms in place for interprogram information exchange and mechanisms for providing information to local, federal and other state agencies. For example, the Public Water Supply program works with local water suppliers, the Nonpoint Source Program coordinates with the county conservation districts, and the Environmental Cleanup Program works with local authorities and municipalities in accordance with the provisions of Act 2 of 1995, the Land Recycling and Environmental Remediation Standards Act. Groundwater monitoring data are available to those responsible for implementing groundwater protection measures and to the general public. Pennsylvania DEP is increasingly using the Internet to inform and educate the public on the various programs, publications, and actions of DEP. Most publications and guidances are now available through DEP’s website on the Internet. Sites have been developed that are specifically for public access and comment. Pennsylvania meets the Core and Fully-Integrating Adequacy Criteria. 6.4 Public Education Programs - Common Practices and Activities That Contribute to Groundwater Contamination - Promote Methods for Protecting Private Wells. 383-2000-030 / October 1, 1998 / Page 24 The public education program discussed under adequacy criterion 6.2 is sufficient to meet the objectives of this criterion relating to educating citizens on management of practices and activities that will minimize contamination of groundwater quality. The public water supply program holds meetings at the local level to promote awareness of protecting municipal and public water supplies. Technical assistance is offered to private water suppliers, and a home coliform bacteria testing kit is available for a minimal cost of $10. Special studies in the state promote homeowner awareness of private well water quality by providing results of sampling and interpretation of the results. Pennsylvania meets the Core and Fully-Integrating Adequacy Criteria. SUMMARY STRATEGIC ACTIVITY 6 Criteria Core Fully-Integrating 6.1 Meet Meet 6.2 Meet Meet 6.3 Meet Meet 6.4 Meet Meet Gaps None None None None Discussion/Identified Gaps Pennsylvania’s public participation procedures and policies for all programs are consistent with the objectives defined by EPA in 40 CFR Part 25. The development of the CSGWPP adheres to these same objectives. Additionally, all programs have in place public education and outreach activities which make available groundwater monitoring data and other information to the public and those responsible for implementing groundwater protection measures. These education and outreach programs have been effective in educating the public on measures to protect groundwater quality and they will be utilized in the CSGWPP process. Pennsylvania meets all Core and Fully-Integrating adequacy criteria for this strategic activity. Pennsylvania DEP is increasingly using the Internet to inform and educate the public on the various programs, publications, and actions of DEP. Most publications and guidances are now available through DEP’s website on the Internet. Plans to Attain Core/Fully-Integrating Status No gaps have been identified. Core and Fully-Integrating status is attained. Barriers to Attaining Core/Fully-Integrating Status Both Core and Fully-Integrating status are attained for this strategic activity. 383-2000-030 / October 1, 1998 / Page 25 APPENDIX 1 PENNSYLVANIA COMPREHENSIVE STATE GROUNDWATER PROTECTION PROGRAM PROFILE Pennsylvania Department of Environmental Protection Harrisburg, Pennsylvania October 1, 1998 383-2000-030 / October 1, 1998 / Page 26 TABLE OF CONTENTS FOR APPENDIX 1 ACKNOWLEDGEMENTS ……………………………..………………………………….29 ABBREVIATIONS ……………………………………….…………………………………30 PREFACE ............................................................................................................................32 INTRODUCTION ...........................................................................................................…33 1. STRATEGIC ACTIVITY 1: ESTABLISHING A GROUNDWATER PROTECTION GOAL ............................................................................................................35 1.1 Through Adequate Public Participation........................................................................................ 35 1.2 No Less Protective Than EPA’s Groundwater Protection Goal ................................................... 35 1.3 Guides at Least One Key State Program....................................................................................... 35 2. STRATEGIC ACTIVITY 2: ESTABLISHING PRIORITIES TO ACHIEVE THE STATE’S PROTECTION GOAL...........................................................................................36 2.1 Definitions and Priority-Setting Processes ................................................................................... 36 2.2 Priority Setting Process and Groundwater Characteristics........................................................... 38 2.3 Contamination Source Inventories and Assessments.................................................................... 45 2.4 Technical Capabilities................................................................................................................... 46 2.5 Measures of Groundwater Protection ........................................................................................... 48 2.6 Public Drinking Water Supplies ................................................................................................... 49 2.7 Groundwater Protection Priorities ................................................................................................ 49 2.8 Review and Improvement of the Six Strategic Activities............................................................. 50 3. STRATEGIC ACTIVITY 3: DEFINING AUTHORITIES AND RESPONSIBILITIES FOR ADDRESSING PRIORITIES .................................................51 3.1 Responsible Agencies and Programs ............................................................................................ 51 3.2 Coordination Mechanism.............................................................................................................. 53 3.3 Legal Resources and Authorities .................................................................................................. 53 3.4 Relevant Federal Agencies ........................................................................................................... 55 3.5 Neighboring Tribal Officials ........................................................................................................ 55 3.6 Interstate Coordination.................................................................................................................. 55 3.7 Local Governments ....................................................................................................................... 57 4. STRATEGIC ACTIVITY 4: EFFORTS TO ACCOMPLISH THE STATE’S GOAL ........................................................................................................................................60 4.1 Programs to Address Priorities ..................................................................................................... 60 4.2 Characterization and Assessment to Support Prevention Decision-Making ................................ 60 4.3 Wellhead Protection Program ....................................................................................................... 63 4.4 Implementation of Prevention Activities ...................................................................................... 64 4.5 Programs with Measurable Objectives for Remediation .............................................................. 68 4.6 Characterization and Assessment Support Remediation Decision-Making ................................. 69 4.7 Provisions to Avoid Cross- Contamination During Remediation................................................. 70 383-2000-030 / October 1, 1998 / Page 27 5. STRATEGIC ACTIVITY 5: DATA MANAGEMENT...................................................72 5.1 Data Management to Re-evaluate Priorities and Measure Progress............................................. 72 5.2 Using Data from Local, State and Federal Governments ............................................................. 74 5.3 Data Elements Defined ................................................................................................................. 75 5.4 QA/QC for State Monitoring Programs ........................................................................................ 76 6. STRATEGIC ACTIVITY 6: IMPROVING PUBLIC EDUCATION AND PARTICIPATION....................................................................................................................79 6.1 Public Participation Is Equivalent to EPA’s in 40CFR Part 25.................................................... 79 6.2 Public Education Program for CSGWPP Issues ........................................................................... 81 6.3 Outreach Mechanisms................................................................................................................... 83 6.4 Public Education Programs........................................................................................................... 84 383-2000-030 / October 1, 1998 / Page 28 ACKNOWLEDGMENTS The Department of Environmental Protection gratefully acknowledges the contributions of time and energy from representatives of the Bureaus of Water Supply Management, Watershed Conservation, Water Quality Protection, Land Recycling and Waste Management, Oil and Gas Management, Radiation Protection, Mining and Reclamation, as well as the Pennsylvania Department of Agriculture and the Department of Conservation and Natural Resources, Bureau of Topographic and Geologic Survey. 383-2000-030 / October 1, 1998 / Page 29 ACRONYMS AND ABBREVIATIONS ASCS AST ASTM BMP BTGS BWC BWQP BWSM CAC CERCLA CERCLIS Information CFR CGWPP CRC CSGWPP CWS DEP DOE DOT EPA EQB ERRI FHA FIFRA FIX GIS GPS GWSI HAL HSCA ICRP LAN LWV LUMIS MCL MCLG NCRP NOAA NORM NPL NRC Agricultural Stabilization and Conservation Service Aboveground Storage Tanks American Society of Testing and Materials Best Management Practice Bureau of Topographic and Geologic Survey Bureau of Watershed Conservation Bureau of Water Quality Protection Bureau of Water Supply Management Citizens Advisory Committee Comprehensive Environmental Response, Compensation, and Liability Act Comprehensive Environmental Response, Compensation, and Liability System Code of Federal Regulations Comprehensive Groundwater Protection Program Community Relations Coordinator Comprehensive State Groundwater Protection Program Community Water System Department of Environmental Protection Department of Energy Department of Transportation Environmental Protection Agency Environmental Quality Board Environmental Resources Research Institute (PSU) Farmers Home Administration Federal Insecticide, Fungicide, and Rodenticide Act Foundation for Information Exchange Geographic Information System Global Positioning Systems Groundwater Site Inventory Health Advisory Levels Hazardous Sites Cleanup Act International Commission on Radiation Protection Local Area Networking League of Women Voters Land Use Management Information System Maximum Contaminant Level Maximum Contaminant Level Goal National Council on Radiation Protection and Management National Oceanic and Atmospheric Association Naturally Occurring Radioactive Material National Priority List Nuclear Regulatory Commission 383-2000-030 / October 1, 1998 / Page 30 ACRONYMS AND ABBREVIATIONS (continued) NRCS PA-GPEP PDA PEMA PFBC PRWA PSU PWS QA/QC RCRA SCC SDWA SMCL SMP SOC STAC STORET SWAC UIC USDA USGS UST VAP WHP WHPA WIMS WRAC WWI Natural Resources Conservation Service (USDA) Pennsylvania Groundwater Policy Education Project Pennsylvania Department of Agriculture Pennsylvania Emergency Management Association Pennsylvania Fish and Boat Commission Pennsylvania Rural Water Association Pennsylvania State University Public Water Supply Quality Assurance / Quality Control Resource, Conservation and Recovery Act State Conservation Commission Safe Drinking Water Secondary Maximum Contaminant Level State Management Plan Synthetic Organic Chemical Storage Tank Advisory Committee Storage and Retrieval (EPA Database) Solid Waste Advisory Committee Underground Injection Control United States Department of Agriculture United States Geologic Survey Underground Storage Tanks Vulnerability Assessment Procedure Wellhead Protection Wellhead Protection Area Waste Information Management System Water Resources Advisory Committee Water Well Inventory 383-2000-030 / October 1, 1998 / Page 31 PREFACE Pennsylvania’s original Groundwater Protection Profile was completed on March 29, 1991. It was developed based on the EPA initiative of Fiscal Year 1991 on assisting states in moving toward implementation of a Comprehensive Groundwater Quality Protection Program (CGWPP), as distinguished from the current Comprehensive State Groundwater Protection Program (CSGWPP). The Profile was developed in accordance with specific guidance contained in the EPA State/Federal Relationship Paper. It was intended to fulfill EPA’s stated purpose of establishing the framework to identify and describe the status of each of the CGWPP elements, and provide the basis for tailoring future EPA assistance in developing and implementing a full CGWPP for Pennsylvania. Much of the information contained in the original Profile is relevant to the 1992 EPA guidance for development of the Comprehensive State Groundwater Protection Program. The original Profile has been updated, revised and reformatted to address the six strategic activities outlined in the EPA guidance document (Appendix 2). The title and subtitles used in this Profile have been abbreviated. For a full description of the EPA adequacy criteria of the strategic activities, see Appendix 2. 383-2000-030 / October 1, 1998 / Page 32 INTRODUCTION This document represents Pennsylvania’s Comprehensive State Groundwater Protection Program Profile. It is structured to be consistent with the Pennsylvania Comprehensive State Groundwater Protection Program and Self Assessment. It describes all of the elements of the existing groundwater protection program and is the basis for the development of the Self-Assessment. The state’s groundwater protection program encompasses the rules, regulations, and policies of these programs and agencies with groundwater protection responsibilities. This document is formatted to identify the roles and contributions of each program or bureau to the Comprehensive State Groundwater Protection Program. Some program duties may overlap with other programs in other departments and commissions (for example, nonpoint source and nutrient management). The Water Quality and Environmental Cleanup programs listed for Field Operations are carried out in the regional offices. The programs and agencies with groundwater protection responsibilities in Pennsylvania are listed here. PA DEPARTMENT OF ENVIRONMENTAL PROTECTION: PROGRAM ORGANIZATION Bureau of Water Supply Management Groundwater Quality, Drinking Water, Wellhead Protection, Source Water Protection, and Surface Water Programs Bureau of Watershed Conservation Surface Water Quality, Nonpoint Source Pollution, Volunteer Water Quality Monitoring, Storage Tank Permitting Programs Bureau of Water Quality Protection Permitting, Stormwater, and Nutrient Management Programs Bureau of Land Recycling and Waste CERCLA/HSCA, Storage Tanks, Municipal, Management Residual, and Hazardous Waste, Land Recycling, and Multi-Site Remediation Agreements Programs Field Operations (Regional Offices) Environmental Cleanup, RCRA and Water Quality Programs Bureau of Oil and Gas Management Oil and Gas Program Bureau of Mining and Reclamation Mining Program Bureau of Radiation Protection Low Level Radioactive Waste Program Office of Pollution Prevention and Compliance Assistance Pollution Prevention Program PA DEPARTMENT OF CONSERVATION AND NATURAL RESOURCES: PROGRAM ORGANIZATION Bureau of Topographic and Geologic Water Well Drillers Program, Geology/Ground Survey Water Resources PA DEPARTMENT OF AGRICULTURE: ORGANIZATION PROGRAM Bureau of Plant Industry State Pesticide Management Program 383-2000-030 / October 1, 1998 / Page 33 ORGANIZATION State Conservation Commission PA COMMISSION: PROGRAM Nutrient Management The EPA guidance separates CSGWPPs into two categories: a Core CSGWPP and FullyIntegrating CSGWPP. The Core-CSGWPP is defined as a state’s initial commitment to working jointly with EPA to move toward a Fully-Integrating CSGWPP. The Fully-Integrating CSGWPP is an eventual goal in which groundwater protection efforts are coordinated and focused across all federal, state and local programs. This is based on a state’s understanding and decisions regarding the relative use, value and vulnerability of its groundwater resources, including the relative threat of all actual or projected contamination sources. The EPA CSGWPP Program Guidance document notes that the CSGWPP process is flexible and allows for each state to develop its program according to its unique hydrologic, demographic, and institutional characteristics. Pennsylvania views this as a long term and on-going process in which a Core program evolves to a Fully-Integrating Program. However, Fully-Integrating programs are dynamic in that they must continue to be assessed and evaluated for effectiveness in achieving and attaining desired objectives and goals. The steps that Pennsylvania is following in developing the CSGWPP are consistent with the EPA guidance and are as follows: l l l l l l l Develop an inventory of all groundwater quality protection programs operating in Pennsylvania. Assess the groundwater quality protection activities relative to satisfying the adequacy criteria for each Strategic Activity (See Pennsylvania Comprehensive State Groundwater Protection Program and Self-Assessment). Achieve through the assessment, an EPA endorsed Core CSGWPP that demonstrates Pennsylvania’s commitment to attainment of a Fully-Integrating CSGWPP. Co-develop with EPA a written multi-year agreement that describes how Pennsylvania will further implement and improve the Strategic Activities of the Core CSGWPP, and identify specific actions that the EPA will take to support Pennsylvania’s efforts. Implement yearly work plans that will serve as the vehicle for identifying activities and milestones for implementing the multi-year program agreements. Achieve an EPA endorsed Fully-Integrating CSGWPP for Pennsylvania through fulfillment of the activities outlined in the yearly and multi-year work plans. Continue to assess and evaluate the Fully-Integrating CSGWPP for effectiveness in attaining program goals and objectives, and revise as necessary and appropriate. Coordination among all programs with groundwater protection responsibilities will be through the CSGWPP Work Group. The Work Group will provide for continuing review and update to the CSGWPP and the Pennsylvania CSGWPP profile. 383-2000-030 / October 1, 1998 / Page 34 1. STRATEGIC ACTIVITY 1: ESTABLISHING A GROUNDWATER PROTECTION GOAL 1.1 Through Adequate Public Participation Pennsylvania’s groundwater protection goal is set forth in the Principles for Ground Water Pollution Prevention and Remediation, December 1, 1996. This document underwent extensive public participation, and was also subject to peer review by the Water Resources Advisory Committee and the Agricultural Advisory Board, both of which consist of members from business, industry, academia, and environmental groups. 1.2 No Less Protective Than EPA’s Groundwater Protection Goal Pennsylvania’s groundwater protection goal is based on prevention of contamination whenever possible. This goal is attained through implementation of technology and management practices. The remediation goal is based on attainment of background, human health protection levels, or site-specific standards. Remediation standards are mandated by Act 2 of 1995, the Land Recycling and Environmental Remediation Standards Act. The Pennsylvania Clean Streams Law, Act of 1937, P.L.1987 provides for the preservation and improvement of the waters of the Commonwealth for the protection of human health, animal and aquatic life, and/or industrial consumption and recreation. The Clean Streams Law and the Land Recycling and Remediation Standards Act serve as the basis for integrating state water quality and environmental protection goals. 1.3 Guides at Least One Key State Program Specific program regulations for attaining the groundwater protection goal are: 25 PA Code Chapters 86, 87, 89 and 90 (coal mining) and Chapter 77 (non-coal mining), Oil and Gas Act, 25 PA Code Chapter 78 (Oil and Gas Regulations), Nutrient Management Act (Act 6), Pennsylvania Pesticide Control Act of 1973, 25 PA Code Chapter 128 (storage, use and transport of pesticides), 25 PA Code Chapters 260-270 (Hazardous Waste Regulations), 25 PA Code Chapters 271-285 (Municipal Waste Regulations), 25 PA Code Chapters 287-299 (Residual Waste Regulations), Act 537 (the PA Sewage Facilities Act of 1966, as amended), and Act 610 (Water Well Drillers License Act). In addition, legislative initiatives mandate groundwater and environmental cleanup standards: Act 2 of 1995 (Land Recycling and Environmental Remediation Standards Act), Act 32 (Storage Tank and Spill Prevention Act), and Act 108 (Hazardous Sites Cleanup Act). Implementing policies and guidances for these statutes and regulations is consistent with the goal for protection of groundwater quality. 383-2000-030 / October 1, 1998 / Page 35 2. STRATEGIC ACTIVITY 2: ESTABLISHING PRIORITIES TO ACHIEVE THE STATE’S PROTECTION GOAL 2.1 Definitions and Priority-Setting Processes All state programs with groundwater quality protection responsibilities have priority setting processes and procedures that are established through regulations, policies, and/or guidances. DEP’s groundwater quality protection goal is established in the Principles for Ground Water Pollution Prevention and Remediation. The Clean Streams Law provides for basic definitions on pollution and waters of the Commonwealth. Other terms such as wellhead protection areas and groundwater are defined in program regulations and guidances. Consistent definitions are used across programs. Program specific responsibilities are discussed below: Groundwater Quality Program: The 478 groundwater basins included in the Bureau of Water Supply Management’s Ambient and Fixed Station Network Groundwater Monitoring Programs were ranked to determine sampling priority. Groundwater use, land use, and environmental sensitivity were the three factors used to establish the priority order. The prioritization list is used to determine the order for basin surveys by DEP region. Some of the top fifty basins will be sampled long enough to determine trends in water quality, and selected basins will be sampled twice to obtain a snapshot of the groundwater quality for those areas. Drinking Water Program: Wellhead Protection Areas are set by regulation under 25 PA Code Chapter 109.1 and are the priority for protection of the source water for public water supplies using groundwater. This program is conducted by the Bureau of Water Supply Management. Groundwater sources that are possibly under the influence of surface water are being evaluated by DEP. Groundwater sources are being evaluated by priority of concern. Well depth, geology, location, and construction are the main factors used in determining the priority for assessment. Storage Tank Program: Regulations have been finalized that specify siting requirements for specific Aboveground Storage Tanks (ASTs) and Underground Storage Tanks (USTs). Considerations will be given to the presence of flood plains, wetlands, sinkholes, and solution channels and prevalence of deep mining. Release sites, where the party responsible for remedial action cannot be located or is unwilling to comply, are ranked for potential action using Leaking Underground Storage Tank Trust Fund money. Depending on the score, DEP may undertake remedial action at these sites. The priority ranking system is based on five factors: 1) water supply contamination and potential, 2) injury, illness, and fatality, 3) potential for special protection areas to be affected, 4) contamination of groundwater and surface water, and 5) fire/explosion potential. Land Recycling and Waste Management/Environmental Cleanup Programs: Within the Land Recycling Program, definitions, standards, and approaches used for the remediation of groundwater contamination are found in Act 2 of 1995: The Land Recycling and Environmental Remediation Standards Act. This Act is the primary law establishing the land recycling 383-2000-030 / October 1, 1998 / Page 36 program and provides the foundation for standards, procedures, cleanup liability limits, and funding for environmental studies and cleanups. The primary goal of Act 2 is to encourage the voluntary cleanup and reuse of contaminated commercial and industrial sites. Within the Hazardous Sites Cleanup Program, the Pennsylvania Priority List for Remedial Response was generated using the EPA Hazardous Ranking Score (HRS) system. The priority setting used for CERCLA (Comprehensive Environmental Response, Compensation, and Liability Act) sites includes a ranking system for making siting and remediation decisions. The factors include 1) groundwater/soil/air/surface water contamination, 2) residence located in the site vicinity, 3) Hazardous Ranking System score for a site, 4) emergency action if immediate threat to groundwater, 5) human health and environment, and 6) site characterization completed after ranking. In the Municipal/Residual Waste Program, siting of facilities in pollution-prone settings is prohibited. Even in less susceptible settings, where siting is permissible, wastes and/or facilities presenting a greater threat to the environment are managed more stringently (i.e. greater containment and monitoring requirements). The Residual Waste Program regulations (which went into effect in 1992) are among the strictest in the nation. Residual waste landfills are classified to their potential for their adverse effects on groundwater and on public health, safety and the environment. Application and site analysis requirements include details groundwater and geology descriptions. The protection of groundwater resources in the Hazardous Waste Program is based upon the technological design requirements for the various types of facilities that are used for the treatment, storage, or disposal of hazardous waste. Regulations governing these activities can be found at Title 25, Chapters 260-270. In addition to the technological design requirements, a number of environmental siting criteria are used to determine the suitability of sites for hazardous waste management activities. These criteria include proximity to water supplies, flood hazard areas, wetland areas, carbonate areas, oil and gas areas, exceptional value watersheds and other criteria that are aimed at protecting public health and safety as well as the resource. Monitoring is required for new and existing facilities to determine whether or not the facility has impacted the resource. An evaluation of monitoring data using an approved statistical methodology is employed to make this determination. In the event the resource has been impacted the facility is required to perform an assessment of the site and if necessary, to implement a Corrective Action Program, which includes abatement measures to be used at the facility. The voluntary Multi-Site Remediation Agreements Program can be applied to companies that have multiple contaminated sites in different DEP regions of Pennsylvania. This program provides for a statewide prioritization of company sites and works in conjunction with the Act 2 program. Sites are prioritized based on risk, size, level of contamination, and resources needed to address the site while considering efficiency. The prioritization process will address the significant sites first. Mining Program: Priorities are based on the use of the resource. Highest priority is given to groundwater in Exceptional Value (antidegradation) Watersheds, and groundwater used for public water supply and multiple private supplies. The program is actively trying to encourage remining of unreclaimed, abandoned mine areas so as to promote improvement of surface and groundwater resources that have been degraded by past mining. A comprehensive plan for abandoned mine reclamation has been developed. This plan outlines guiding principles for reclamation activities across Pennsylvania. 383-2000-030 / October 1, 1998 / Page 37 Nonpoint Source Program: The Section 319 Nonpoint Source Program has developed a priority Degraded Watershed List. This list is used to target grant monies and resources to those watersheds identified as a high priority. Data used for this priority list include the Section 305(b) Assessment database and the priority list of groundwater basins developed by the Bureau of Water Supply Management. Nutrient Management Program: The Nutrient Management program is administered by the State Conservation Commission and delegated county conservation districts. The requirements of the Nutrient Management Act and regulations were designed to minimize water quality impacts. Compliance with the Act and regulations will, in most cases, meet other applicable state and federal requirements, such as the PA Clean Streams Law and federal Concentrated Animal Feeding Operation (CAFO) requirements. PA Department of Agriculture: Priority concerns for groundwater protection include population dependence on groundwater, aquifer vulnerability, pesticide usage patterns, contribution of the aquifer to baseflow surface water, and the use of the aquifer for future needs. Of these concerns, aquifer vulnerability and population dependence on the water supply have the highest priorities. Pollution Prevention: DEP has created a new Office of Pollution Prevention and Compliance Assistance (OPPCA). The primary role of OPPCA is to facilitate, communicate, and demonstrate the environmental value and economic benefits of preventing pollution in the first place. The office also works to integrate the use of pollution prevention techniques, “green technologies” and compliance assistance across all the state environmental programs. 2.2 Priority Setting Process and Groundwater Characteristics Pennsylvania’s groundwater resources have been and continue to be characterized by numerous state and federal programs and research projects. Some of these include the Bureau of Watershed Conservation’s (BWC) statewide biennial Water Quality Assessment Reports, with input on groundwater quality by Bureau of Water Supply Management (BWSM), the BWSM Ambient and Fixed Station Network Groundwater Quality Monitoring and Wellhead Protection Area (WHPA) delineation programs, EPA’s Sole Source Aquifer designations, the Bureau of Topographic and Geologic Survey’s numerous groundwater investigations and reports, the United States Geological Survey research projects, and interdepartmental coordinated projects such as the Pequea-Mill Creek Geographic Information System (GIS) Project. The following projects and programs consider numerous groundwater characteristics including those listed in Figure 1. These characteristics are generally used to set priorities, determine appropriate remediation methods, and make siting decisions. 383-2000-030 / October 1, 1998 / Page 38 FIGURE 1 Groundwater characteristics such as, but not limited to, the following are to be used in setting priorities, determining appropriate remediation methods, and making siting decisions: 1. Intrinsic sensitivity, hydrogeologic regimes and flow patterns (recharge/discharge areas), geologic/hydraulic parameters and local hydrogeologic setting 2. Quantity and potential yield 3. Ambient and/or background groundwater quality as determined by monitoring 4. Potential for remediation where contamination already exists 5. Current use 6. Reasonably expected future use based on demographics, land use, remoteness, quality, and availability of alternative water supplies 7. Values attributed to groundwater resources 8. The interactions and potential contamination impacts between surface and groundwater and the value of groundwater quality to the maintenance of ecosystem integrity 9. Inter-jurisdictional characteristics Groundwater Quality Programs: In the early 1980s, the state was divided into 478 groundwater basins using the H.W. Higbee Stream Map of Pennsylvania The state’s 478 groundwater basins were prioritized based on groundwater use, potential unmonitored sources of pollution, and environmental sensitivity. The top 50 were categorized as Fixed Station Network (FSN) Basins and were scheduled to be monitored twice per year for 27 analytes to characterize the background groundwater quality. Twenty-seven of the basins have been monitored to date, accounting for 652 monitoring points. Because of resource constraints in DEP, the ambient surveys are being emphasized to cover areas of the state where groundwater quality is essentially unknown. Under the Ambient Survey Program, selected basins that have not been surveyed are to be sampled twice for the same 27 analytes. Twenty-one of these groundwater basins have been monitored at 450 sampling locations. All of the data generated from this program is incorporated into the national STORET (STOrage and RETrieval) database system. This groundwater quality database has been used to generate groundwater quality maps and statistical reports. Eighteen statistical trend analysis reports have been generated using statistical software programs. A summary of all groundwater data collected from 1985 to 1997 has been completed (DEP publication 3800-BK-DEP2246, June 1998). PADEP prepares a biennial Water Quality Assessment Summary Report as required by the Clean Water Act. The groundwater quality of the state is assessed through evaluation of the data generated from the BWSM Groundwater Monitoring Programs, public water suppliers that 383-2000-030 / October 1, 1998 / Page 39 use groundwater, and indicator parameters such as nitrates. A portion of this summary includes prioritizing the major sources of groundwater contamination and associated types of waste. The continued development of the monitoring program will improve DEP’s ability to detect emerging groundwater problems, to evaluate the impacts of unmonitored sources of pollution, and to assess the overall effectiveness of our regulatory program. Wellhead Protection Area Delineation: The 1986 Safe Drinking Water Act amendments established the Wellhead Protection (WHP) Program under Section 1428. Pennsylvania is developing a state program to support local protection measures. The Bureau of Water Supply Management, which oversees the WHP Program, has funded a joint study with the USGS on the delineation of Wellhead Protection Areas in Pennsylvania. Two of the scheduled reports have been published. These reports are titled Evaluation of Methods for Delineating Areas That Contribute Water to Wells Completed in Valley-Fill Aquifers in Pennsylvania (Open-File Report 92-635) and A Strategy for Delineating the Area of Ground-Water Contribution to Wells Completed in Fractured Bedrock Aquifers in Pennsylvania (Water Resources Investigation Report 95-4033). Under the Safe Drinking Water Regulations (25 PA Code Chapter 109 as revised on 10/8/94), water suppliers seeking to obtain DEP approval for a local wellhead protection program must meet a series of minimum criteria as noted in Section 109.713 of the regulations. Some of the required information includes site specific hydraulic and hydrogeologic information such as pumping rate or yield, aquifer properties, water table or potentiometric surface configuration and hydrogeologic mapping for rigorous wellhead protection area delineation; existing and potential sources of contamination within each wellhead protection area; and at least one wellhead protection area management option which may include a groundwater monitoring network that serves as an early warning system. Sole Source Aquifer Designation: The Safe Drinking Water Act (P.L. 93-523) was enacted on December 16, 1974. Section 1424(e) requires the Administrator of EPA to publish notice of Sole Source Aquifer determinations in the Federal Register. After publication of such notice, no commitment for federal financial assistance may be entered for any project the Administrator determines may contaminate the aquifer through a recharge zone so as to create a significant hazard to public health. One of the requirements on the application for this program includes a hydrogeologic assessment of the groundwater resources within the critical protection area along with a comprehensive management plan. This plan is to include an identification of existing and potential point and nonpoint sources of groundwater degradation, an assessment of the relationship between activities on the land surface and groundwater quality, and specific actions and management practices to be implemented in the critical protection area to prevent adverse impacts on groundwater quality. Effective April 15, 1985, the groundwater system of a limestone aquifer of the Piedmont Region around Seven Valleys, York County, Pennsylvania, was designated as a sole source aquifer. The designated area consists of the area directly overlying the Conestoga Limestone Formation in the 383-2000-030 / October 1, 1998 / Page 40 vicinity of Sinsheim, Jefferson, and Seven Valleys, and the streamflow source zones of that portion of the Conestoga Limestone Formation. The streamflow source zones include the drainage basins of the East Branch of West Branch Codorus Creek, from its headwaters to its confluence with West Branch Codorus Creek and the South Branch Codorus Creek from its headwaters to the town of Glatfelters and including the drainage basins of Fishel Creek, Buffalo Valley Creek, Brush Valley Creek, Krebs Valley Creek, Glen Rock Valley Creek, Trout Run and Cherry Run. Effective August 8, 1988, the New Jersey Coastal Plain Aquifer System was designated as a Sole Source Aquifer. In Pennsylvania, the project review area includes that portion of the streamflow source zone which lies within two miles of the Delaware River. This includes parts of Delaware, Philadelphia, Bucks, Monroe, Northampton, Pike and Wayne Counties. Storage Tank Program: Release sites where the party responsible for remedial action cannot be located or is unwilling to comply, are ranked for potential action using Federal Leaking Underground Storage Tank Trust Fund and/or state Storage Tank Fund money. Depending on the score, DEP may undertake the remedial action at these sites. The priority ranking system is based on five factors: 1) water supply contamination and potential, 2) injury, illness, and fatality, 3) potential for special protection areas to be affected, 4) contamination of groundwater and surface water, and 5) fire/explosion potential. Land Recycling and Waste Management/Environmental Cleanup Programs: The Land Recycling Program allows private industries and persons to select cleanup levels that are protective of human health and the environment and compatible with their selected reuse of the sites. Under Act 2 and Act 4 (of July 18, 1995), funds are provided for assessments of industrial reuse sites by the Department of Community and Economic Development, which was given authority to distribute grants and loans by the Act 2 and Act 4 laws. In the federal CERCLA Program, a priority list (CERCLIS) is used to determine which sites may appear in the NPL List (Superfund), or are undertaken through emergency actions. The Hazardous Sites Cleanup Program uses a computer ranking system (EPA HRS) based on the site assessments (Preliminary Assessment/Site Investigation). The Source Reduction Strategy (SRS) Scoring system is a numerical indication of the degree of hazard at a site. The SRS scoring system is used for making siting and remediation decisions. Factors used include groundwater/soil/air surface water contamination and impact on groundwater; residence population located in the site vicinity; use and/or consumption of water; availability of public water supplies; and human health and the environment. Nutrient Management Program: The Nutrient Management program is designed to address those operations that have the largest potential for impacting water quality, and at the same time to develop educational program for operators of all livestock operations. The program gives Concentrated Animal Operations (CAO) the highest priority. However, all livestock operations will be targeted with the educational program to prevent pollution by nutrients. For example, setback distances are required from drinking water sources, open sinkholes and water bodies for the application of nutrients. This considers the sensitivity of these areas. 383-2000-030 / October 1, 1998 / Page 41 Mining Program: The mining program regulations contain provisions that essentially address most of the groundwater characteristics in Figure 1. For example, requirements for groundwater information for coal mining include well inventories, hydrogeologic properties, and groundwater availability and quality. This information is used to develop an operation plan that will protect the hydrologic balance and prevent adverse hydrologic consequences. Nonpoint Source Program: Using monies from the Clean Water Act’s Section 319 Nonpoint Source Grant, Pennsylvania State University and the Somerset and Westmoreland Conservation Districts are completing an assessment of groundwater quantity and quality in the Laurel Ridge area. It may be possible to use procedures developed in this watershed elsewhere in the state for groundwater assessment. The Chesapeake Bay Program has completed watershed assessments for most of the Susquehanna and Potomac River Basins. These assessments focused on the impacts from agriculture. Using funding from the 205(j)(5) grant, the Bureau of Watershed Conservation completed agricultural assessments in 10 watersheds outside the Chesapeake Bay Drainage area. These assessments identified water quality problems from agriculture and developed a plan to address these problems. The Section 319 Program has been allowed by EPA to fund up to $250,000 in assessment activities. Assessments of the Tulpehocken and Evitts Creek Watersheds have started. Some of the money has been used to continue the development of a decision support system for the program to handle data collected from various assessments. These data will be for use in the prioritization of watersheds and the documentation of environmental improvement. A Watershed Assessment Program has been developed for nonpoint sources. Groundwater issues will be considered in the implementation of this program. PA Geologic Survey: The Bureau of Topographic and Geologic Survey conducts comprehensive, systematic, and detailed surveys of the topography, geology, mineral and energy resources, and groundwater resources of Pennsylvania. These activities support and provide information to programs that have groundwater quality protection responsibilities. The Survey provides information on the intrinsic sensitivity, hydrogeologic regimes and flow patterns (recharge/discharge areas), geologic/hydraulic parameters and local hydrogeologic setting; quantity and potential yield; ambient and/or background groundwater quality as determined by monitoring; and current use. This information is available in a series of reports that are listed in the Pennsylvania Geological Publications catalog. For a copy, contact the Survey at 717-787-2169. PA Department of Agriculture: The priorities established by the Department adheres to the list established in Figure 1, with the exception to include pesticide usage patterns. Specifically, priorities are based on the following: 383-2000-030 / October 1, 1998 / Page 42 1. 2. 3. 4. 5. 6. Areas of pesticide use and intensity of agriculture (the basis for establishing a monitoring program under the Department of Agriculture’s draft Pesticides and Ground Water Strategy); Importance of groundwater resources to the population of the area (current usage), based on public and private water supplies; Aquifer vulnerability (generally, areas underlain by carbonate geologic formations); The interactions and potential contamination between surface and groundwater; Quantity and potential yield of the aquifer; and Future use of groundwater, based on land use, demographics, etc. USGS Groundwater Related Investigations: The list of reports that follows contains some of the USGS investigations that have been completed or underway. In addition to these, the USGS has worked extensively with the Bureau of Topographic and Geologic Survey and other state agencies to publish numerous other cooperative reports on groundwater including the Pennsylvania Geologic Survey’s Water Resource Reports. l l l l l l l l l l l l l l l l l l l l l l l l l Groundwater Stations - Fifty-one wells are monitored for groundwater level data. Ground-Water Quality and Data on Wells and Springs in PA, Volume I -- Ohio and St. Lawrence River Basins; Volume II, Susquehanna and Potomac River Basins; Volume III, Delaware River Basin. Hydrology of W. Valley Creek Basin, Central Chester County. Selected Ground-Water Data, Chester County, PA. Effect of Urbanization on the Water Resources of Eastern Chester County, PA. Geohydrology of the Furnace Creek Basin and Vicinity, Berks, Lancaster, and Lebanon Counties, PA. Hydrogeology of the Mesozoic Rocks of the Newark-Gettysburg Basin, Northern Bucks County. Role of Abandoned Multi-Aquifer Wells in Regional Ground Water Contamination, Bucks and Montgomery Counties. Hydrogeology and Ground-Water Quality of Northern Bucks County, PA. A Strategy for Delineating the Area of Ground Water Contribution to Wells Completed in Fractured Bedrock Aquifers in PA. Geohydrology and Water Quality of the Unconsolidated Deposits in Erie County, PA National Water Quality Assessment Program: Lower Susquehanna River Basin Study Unit; AlleghenyMonongahela River Basin Study Unit; Delaware River Basin Study Unit. Geohydrology and Ground-Water Resources of Philadelphia, PA. Relation of Ground-Water Quality to Land Use in the Philadelphia, PA- Camden, NJ Area. Hydrologic Data for Aquifers in Philadelphia, PA. Compilation of Ground-Water-Quality Data in PA. A Feasibility Study to Estimate Minimum Surface-Casing Depths of Oil and Gas Wells to Prevent GroundWater Contamination in Four Areas of Western PA. Hydrology of Area 5, Eastern Coal Province, PA, MD and WV; Hydrology of Area 1, Eastern Coal Province, PA.; Hydrology of Area 5, Eastern Coal Province, PA and NY. Quality of Water in Mines in the Western Middle Field, Anthracite Region, Eastcentral PA. Water Quality of Large Discharges from Mines in the Anthracite Region of Eastern PA. Ground Water Quality Assessment of a Fractured Crystalline Rock Aquifer System in the Piedmont Province of the Lower Delaware River Basin. Effects of Agricultural Best-Management Practices on the Bush Run Headwaters, Adams County, PA Prior to and During Nutrient Management. Hydrology and the Effects of Selected Agricultural Best-Management Practices in the Bald Eagle Creek Watershed, York County, PA. A Synthesis of Nutrient and Sediment Data from Watersheds Within the Chesapeake Bay Drainage Basin. Radium and Radon in Ground Water in the Chickies Quartzite, Southeastern PA. 383-2000-030 / October 1, 1998 / Page 43 l l l l l l l l l l l l l l l l l l l l l Ground Water Resources of Cambrian and Ordovician Carbonate Rocks in the Valley and Ridge Physiographic Province of PA. Large Springs in the Valley and Ridge Physiographic Province of PA: A Contribution to the Appalachian Valley-Piedmont Regional Aquifer System Analysis Study. Water Resources Data for Indiana County, PA. Water Resources of Indiana County, PA. Evaluation of Methods for Delineating Areas that Contribute Water to Wells Completed in Valley Fill Aquifers in PA. Ground Water Resources Data for Warren County, PA. Hydrologic Data for Northern Bucks County, PA. Geographic Information System Data Sets of Hydrologic Conditions in Pequea and Mill Creek Watersheds, PA: Part I -- Basic Data; Part II -- Hydrogeologic Interpretations. Assessment of Severity and Distribution of Corrosive Ground Water in PA. An Appraisal of the Ground-Water Resources of the Upper Susquehanna River Basin. An Appraisal of the Ground-Water Resources of the Lower Susquehanna River Basin. An Appraisal of the Juniata River Basin, Susquehanna River Basin. Hydrogeologic Setting and Evaluation of Pesticide Fate and Transport in the Unsaturated Zone of a RegolithMantles, Carbonate Rock Terrain near Newville, PA. Occurrence and Concentrations of Volatile Organic Compounds in Shallow Ground Water in the Lower Susquehanna River Basin, PA and MD. Radon in Ground Water of the Lower Susquehanna and Potomac River Basins. Bacteriological Quality of Ground Water Used for Household Supply, Lower Susquehanna River Basin, PA and MD. Ground Water Quality and its Relation to Hydrogeology, Land Use and Surface Water Quality in the Red Clay Creek Basin, Piedmont Physiographic Province, PA and Delaware. Ground Water Quality Assessment of Warren County, PA. Ground Water Quality of Erie County, PA. Evaluation of Methods to Delineate the Area of Ground Water Contribution for Various Hydrogeologic Settings in PA. Ground Water Flow in a Mantled Carbonate System, Cumberland Valley, PA. Pequea-Mill Creek Watersheds Project: In 1991, a state committee was formed to coordinate the various research and educational activities taking place in the Pequea and Mill Creek Watersheds. This State Coordinating Committee is made up of 19 agencies and interest groups. The Pequea-Mill Creek watersheds are located in central Lancaster County in southcentral Pennsylvania. The project area is 135,000 acres, approximately 22 percent of the county. Although there are some poultry and swine operations in the watershed, with 55,000 dairy cows, dairy is the dominant agricultural enterprise. These livestock operations are distributed among the 1,000 small farms located in the watersheds. Extensive physical, chemical, and biological water quality monitoring have been conducted by the United States Geologic Survey (USGS), DEP, and Pennsylvania Fish and Boat Commission (PFBC) within the study area. Some of the assessment type of monitoring includes an extensive groundwater quality survey of 363 samples that were analyzed for nitrates and triazine herbicides; synoptic sampling of 46 surface water sites and 39 groundwater sites; a project to evaluate cause/effect relations of implementation of agricultural management practices on surface and groundwater quality; 250 farmers and 100 homeowners were surveyed on well construction, nutrient and pesticide usage, and potential sources of groundwater pollution; Geographic Information System coverages were developed for topography, water table contours, 383-2000-030 / October 1, 1998 / Page 44 geology, hydrologic units, faults, sinkholes, wells, springs and groundwater quality data, unsaturated zone thickness, regolith thickness, over 1,100 property boundaries, and soils. Wellhead Protection Areas have been delineated for three boroughs in the study area and potential point sources of contamination have been identified. 2.3 Contamination Source Inventories and Assessments Compliance and reporting requirements and contamination source inventories are part of groundwater protection programs in Pennsylvania. GIS developments in DEP will make it easier to track the locations of contamination sources. The continued development of contaminant tracking programs will improve DEP’s ability to detect emerging groundwater problems, to evaluate the impacts of unmonitored sources of pollution, and to assess the overall effectiveness of our regulatory program. Programs that are tracking contamination are as follows: Surface Water Quality Program: The Bureau of Watershed Conservation is developing a GIS database of discharge locations and related surface water quality. These data are expected to be integrated into the assessment of watersheds. Drinking Water Program: All Public Water Supplies must meet appropriate treatment requirements for the type system; treated water must meet Federal Safe Drinking Water MCLs. Monitoring for these chemicals with regulated MCLs is required according to system type, size, and source. In addition, operational monitoring is required for some treatment types. Pennsylvania issues monitoring waivers for synthetic organic chemicals, and asbestos based upon source vulnerability to these substances. Compliance is determined by reporting from certified labs and by field staff inspection. In addition, the operator is required to conduct an annual sanitary survey and DEP conducts one triennially. This survey includes the inspection of portions of the drainage area or Wellhead Protection Area necessary to identify and evaluate actual and probable sources of contamination (25 PA Code Chapter 109.705(a)(1)). A water supplier is required under 25 PA Code Chapter 109.4(4) to take whatever investigative or corrective action is necessary to assure that a safe and potable water is continuously supplied to the users. The state’s WHP program will form the cornerstone of the Source Water Protection Program for groundwater resources serving public water systems. The Source Water Protection program is required to define the boundaries of areas providing source water to public water systems and to identify contaminants in the delineated source areas to determine the susceptibility of public water supplies to contaminants. These assessments are to be completed within two years after EPA approval of the state’s Source Water Protection program. GIS technology will play a crucial role in the development and implementation of these programs. Storage Tank Program: Six regional offices are responsible for data entry and maintenance of the Land Recycling Program Database, which is used to track the status of confirmed storage tank release sites. This database may be used to establish priorities for cleanup in accordance with the priority ranking system discussed in Section 2.2. 383-2000-030 / October 1, 1998 / Page 45 Land Recycling and Waste Management/Environmental Cleanup Programs: In the Land Recycling Program, the person reusing the site to gain Act 2 release must meet selected standards and indicate this in a final remedial investigation report. Sites under the Hazardous Sites Cleanup Program must comply with the cleanup standard established by DEP (Land Recycling Program Database is used for the inventory list). In the CERCLA Program, the CERCLIS List is used for setting priorities, with the worst case scenario sites being added to the EPA National Priorities List (Superfund). In the Municipal/Residual/Hazardous Waste Programs, EPA NPL listings, cleanup standards for contaminated soils, groundwater monitoring requirements in the Hazardous Waste Regulations, and the Land Recycling Program Database are used to add to the contamination source inventories. Reporting requirements are covered by various statutes, including Act 2, the Storage Tank and Spill Prevention Act, and the Clean Streams Law. The contamination source inventory is accomplished using the Land Recycling Program database. Mining Program: The mining program maintains a comprehensive, computerized inventory of active and inactive/reclaimed mining activities on the Land Use Management Information System (LUMIS). In addition, the program maintains a data/mapping system (paper) of underground coal mining that has occurred since the 1930s, surface coal mining since the 1960s and noncoal mining since 1972. Nutrient Management Program: The confined animal operations that are required to implement plans under the Nutrient Management Act are being identified. Preliminary estimates are available, but exact locations and numbers need further evaluation and development. In addition, DEP has completed a study assessing other sources of nutrient pollution besides agriculture. These include improper water well construction, atmospheric deposition, on-lot septic systems, application of fertilizer for non-agricultural activities such as lawn care and golf course maintenance, and stormwater runoff. Groundwater effects will be identified as part of these studies. This information on background water quality data for nutrients will be used to prioritize and address pollution sources. PA Department of Agriculture: The Pesticide Management Program will commence by monitoring within areas of Lancaster County. The program has the capability to add to the contamination source inventory by establishing groundwater monitoring programs in additional areas of the Commonwealth to provide a broader monitoring database. Future monitoring studies will be expanded to additional geographic areas of concern as budget constraints allow. 2.4 Technical Capabilities Pennsylvania’s technical resources are found throughout the state, federal and local agencies. DEP is currently conducting a Foundation for Information Exchange (FIX) project that will enhance current computerized data management systems. In addition, many programs are becoming more involved in Geographic Information Systems and making improvements to current data management systems. Data management activities for programs are described below: 383-2000-030 / October 1, 1998 / Page 46 FIX Project - FIX is a two-phase project that will foster cross-program communication, support new initiatives, better manage DEP resources and support decision making. The first phase includes developing a database to support application processing for DEP programs and to develop a DEP-wide base of Client and Site information. Phase I has been completed. Phase II includes replacing LUMIS (Land Use Management Information System) and WQFIS (Water Quality Facility Inventory System) with a DEC/Oracle platform, converting program specific data with an interface to the DEP-wide Client/Site and Application Processing System, and providing an opportunity to implement DEP-wide compliance requirements. Phase II is expected to be implemented in July of 1998. Water Quality Management Program: The surface water program is developing a GIS to assess the quality of the waters of the Commonwealth. It will also be used for program planning purposes. Drinking Water Program: The Safe Drinking Water Program is developing a GIS to improve program planning, assess potential threats to drinking water sources, assist in implementing the Safe Drinking Water and Source Water Protection programs, and assist in coordination with other DEP programs. The use of GPS technology to more accurately locate sources and facilities also is being implemented. The Groundwater Protection Program is using GIS to track monitoring point locations and data from the Ambient and FSN Monitoring programs. Storage Tank Program: A Storage Tank Data System is used to track the list of facilities to be inspected based on criteria from Chapter 245.21(b). Leaking ASTs with a capacity greater than 21,000 gallons are required to submit a report that includes latitude and longitude information. The Corrective Action Tracking System (Powerbase) has been mapped into the Land Recycling Program Database (Microsoft Access). This is used to prepare semi-annual status reports on UST cleanups to EPA. Land Recycling and Waste Management/Environmental Cleanup Programs: The Land Recycling Program has developed the Land Recycling Program Database for setting priorities for state conducted projects. It is used to maintain an inventory of Act 2 sites, and case information for the Storage Tanks, Hazardous Sites Cleanup, and special projects programs. The Hazardous Sites Cleanup program is beginning to use GIS to identify aspects of specific study areas. The Municipal/Residual/Hazardous Waste Management Programs use a database referred to as the Waste Information Management System (WIMS). It is used to store the groundwater data for quarterly sampling at waste facilities. Statistical programs are sometimes used to set priorities where groundwater protection is concerned. Sites with groundwater parameters with statistically significant changes may be placed on a priority list for corrective measures. Mining Program: The mining program is currently working on transferring its antiquated mine location mapping system to a GIS system. Mine site locations are being digitized for input onto a GIS in cooperation with the PSU Environmental Resources Research Institute (ERRI). Oil and Gas Program: The Oil and Gas Program is currently involved in implementing several improvements and additions to current data management systems which will interface with 383-2000-030 / October 1, 1998 / Page 47 extensive regional GIS work supported with Trimble GPS locational units. Since the mid-1980s, the Oil and Gas Program has made extensive modifications to the on-line LUMIS data management system that resides on the current Burroughs system. LUMIS serves as the tracking system for all permit applications, bonding, names and addresses, inspections, violations, and enforcement actions. In addition, the database contains site-specific information on wells in the well inventory database. The regional and central office GIS/GPS work is in the preliminary stage of development. Most equipment is in place and a plan to convert all paper files and 7.5 minute topographic maps to a digitized format is being developed. Nonpoint Source Program: The Nonpoint Source Program has completed the design of a Decision Support System using GIS capabilities in cooperation with the PSU Environmental Resources Research Institute (ERRI). This project developed the designs and specifications for a GIS that can be used by the program to document nonpoint source problems, prioritize watersheds, develop watershed management plans, complete assessments, and document progress. This project will build on data layers already developed by ERRI, USGS, DEP, and others to complete the system. A GIS System was used to develop a ranking system of the state water plan watersheds according to their agricultural pollution potential. The results of this system were used to prioritize efforts in the Chesapeake Bay Program, and to identify watersheds for study using Section 205(j)(5) grant funding. In addition, the results of this study were used in the development of the state Nonpoint Source Degraded/Priority Watershed List, which is used for the prioritization of projects for the Section 319 Nonpoint Source Program. The Chesapeake Bay and Nonpoint Source Programs have begun developing a system to document the implementation of management measures using GPS. This will enable both programs to pinpoint the locations of measures implemented using EPA grant funding. PA Geologic Survey: The state Geologic Survey is working on the development of a PC-based GIS to manipulate and geographically relate water well data. A workstation-based GIS is being used to create base layer information for use by DCNR and DEP. This includes a Pennsylvania stream map and geologic map. GPS units are also used to refine and streamline the work of locating water wells. Pequea-Mill Creek Project: Numerous data layers were prepared within the Pequea-Mill Creek Watersheds as part of a coordinated project with the DEP, PDA, EPA, USGS, and Cooperative Extension Service. These include topography, water table contours, geology, hydrologic units, faults, sinkholes, wells, springs and groundwater quality data, unsaturated zone thickness, regolith thickness, over 1,100 property boundaries, and soils. 2.5 Measures of Groundwater Protection At the current time, prevention of groundwater pollution is achieved through program specific regulations and policies that use water quality and performance measures such as background levels, drinking water standards or other appropriate health and environmental protection standards. Act 2 of 1995 specifies certain levels to be attained for groundwater cleanup and 383-2000-030 / October 1, 1998 / Page 48 remediation. Section 105 of Act 2 created a Cleanup Standards Scientific Advisory Board whose duty was to review and develop cleanup and remediation standards. The Principles of Ground Water Pollution Prevention and Remediation states the goal that groundwater protection will be based on prevention of contamination whenever possible. 2.6 Public Drinking Water Supplies One of the state’s highest priorities is protecting public water supplies. Authority for such protection is addressed under the Pennsylvania Clean Streams Law and Safe Drinking Water Program statutes and regulations. All programs consider water supply locations in the implementation of management and protection measures. A state Wellhead Protection Program is active and will be submitted for approval to EPA. 2.7 Groundwater Protection Priorities Coordination and integration of groundwater quality protection priorities with surface water and other environmental priorities are accomplished as follows for the various programs. Surface Water Quality Program: Ground/surface water interactions are evaluated in the implementation of the surface water quality protection program. Permitted activities take into consideration cross-media impacts. Drinking Water Program: All Public Water Supplies must meet federal MCLs at their entry points. The direct influence of surface water on groundwater sources in terms of appropriate treatment requirements for the source to address microbial safety, is being evaluated. In addition, the delineation of WHP area Zone III, as defined in Chapter 109.1, involves an assessment of surface water contribution to the aquifer. Storage Tank Program: Information is provided to applicable programs on surface and groundwater quality impacts of leaking underground storage tanks. Nutrient Management: The Nutrient Management program deals with groundwater and surface water interaction through its connections with other programs. The State Conservation Commission (SCC) has the lead role in providing outreach on the proper utilization and management of nutrients on farms, to develop and provide technical and financial assistance for nutrient management and promulgating regulations. The PDA, DEP and the Cooperative Extension Service of the Pennsylvania State University play the primary support role to the SCC and the county conservation districts. The Nutrient Management Program is directly connected to the Chesapeake Bay Program. The Bay Program is a cooperative effort of county conservation districts, DEP, the State Conservation Commission, Department of Agriculture, U.S. Environmental Protection Agency, the Natural Resource Conservation Service and other agencies. Within DEP, nutrient management is integrated as necessary with the Nonpoint Source Program in the Bureau of Watershed Conservation. Land Recycling and Waste Management/Environmental Cleanup Program: In general, remediation projects require assessment of air, soil, surface water and groundwater protection elements. If applicable, remediation projects under the Hazardous Sites Cleanup Program, 383-2000-030 / October 1, 1998 / Page 49 CERCLA, and the Land Recycling Programs consider the interactions though the various media. The Municipal, Residual, and Hazardous Waste Management regulations include provisions for protecting surface waters as well as groundwater. Mining Program: Underground mining, coal refuse disposal, and noncoal mining activities must be planned and conducted to minimize changes to the prevailing hydrologic balance in the permit and adjacent areas (Chapter 89.52; 90.101; 77.521). The program assumes a direct coupling between surface water and groundwater. The goal is to maintain instream criteria and prevent a discharge to the surface that exceeds Best Available Technology. Oil and Gas Program: Information related to oil and gas wells is provided to the Bureau of Watershed Conservation or any other applicable program or bureau for the assessment of surface water quality. Nonpoint Source Program: Many watershed assessments have been completed to document surface and groundwater quality problems caused by agriculture. As part of an assessment, an implementation plan to address these problems is also developed. These assessments are completed by county conservation districts. Since the focus of these assessments is agriculture, the data collected deal with farming practices and animal populations. In watershed assessments, when water quality data are collected, groundwater from landowner wells are analyzed for nitrates and coliforms as an incentive to the landowner to participate in the interviews being completed as part of the assessment process. Project selection criteria developed for the Section 319 NPS Implementation Grant focus on the integration of resources to address NPS problems through demonstrations and comprehensive watershed projects. Groundwater considerations are integrated into these criteria. PA Department of Agriculture: Where pesticides are detected from water samples collected from public and domestic water supplies, a site assessment may be required to provide additional information for source identification. The PDA, as part of its program, evaluates specific conditions related to the use, mixing and loading of pesticides and cleaning of pesticide equipment. Where indications of improper handling of pesticides are present, the PDA takes appropriate actions to correct these situations under the current provisions of FIFRA and the state Pesticide Control Act of 1973. Where contamination appears to occur from nonpoint sources (normal field use), the use of BMPs to prevent further contamination of the water resources is employed. Also, one of the priority concerns used in the development of the State Management Plan for Pesticides is the contribution of the aquifer to baseflow surface water. 2.8 Review and Improvement of the Six Strategic Activities CSGWPP development is an ongoing and dynamic process. It will be regularly reviewed, updated and improved. Statutes, regulations and guidances related to groundwater quality protection will be consistently refined and updated to reflect technological advances and changing state and federal priorities. The CSGWPP Work Group will provide for coordination and review among program areas with groundwater protection responsibilities. 383-2000-030 / October 1, 1998 / Page 50 3. STRATEGIC ACTIVITY 3: DEFINING AUTHORITIES AND RESPONSIBILITIES FOR ADDRESSING PRIORITIES 3.1 Responsible Agencies and Programs The following table identifies the agencies and programs with responsibilities for protecting groundwater quality through implementation of specific regulatory programs. The Bureau of Water Supply Management is the primary point of contact for the CSGWPP. BUREAU WATER QUALITY PROTECTION GROUNDWATER MANAGEMENT ACTIVITY On-lot sewage disposal systems Land disposal/treatment of nonhazardous wastes Industrial and sewage waste impoundments; response to pollution incidents Underground injection of nonhazardous wastes; discharges to dry swales STATUTORY AND REGULATORY CITATIONS The Clean Streams Law of PA; the PA Sewage Facilities Act; 25 PA Code Chapters 71-73 The Clean Streams Law of PA The Clean Streams Law of PA; 25 PA Code Chapter 101 The Clean Streams Law of PA; 25 PA Code Chapter 97; Clean Water Act Nutrient Management Underground Storage Tanks/Above Ground WATERSHED CONSERVATION Storage Tanks Nonpoint Source Programs including Chesapeake Bay, Delaware Estuary, Coastal Zone Management, Section 319-NPS Implementation, E&S Control, and Stormwater Management 383-2000-030 / October 1, 1998 / Page 51 The Nutrient Management Act; 25 PA Code Chapter 83. Act 32 (Storage Tank and Spill Prevention Act); 25 PA Code Chapter 245. The Clean Streams Law of PA; the Nutrient Management Act; 25 PA Code Chapter 83; 25 PA Code Chapter 102; Federal Clean Water Act; Act 167 (Stormwater Management Act); Coastal Zone Act Reauthorizaton Amendments BUREAU WATER SUPPLY MANAGEMENT LAND RECYCLING AND WASTE MANAGEMENT GROUNDWATER MANAGEMENT ACTIVITY Regulates and monitors public surface and groundwater supplies; Wellhead Protection Program, groundwater quality monitoring, groundwater quality protection program Municipal and Residual Waste Management facilities Hazardous Waste Management facilities Hazardous Site Cleanup Program Land Recycling Program Multi-Site Remediation Agreements Program Storage Tank Cleanup Program MINING AND RECLAMATION Surface mining of coal and noncoal, underground mining operations, coal prep plants, coal refuse disposal OIL AND GAS MANAGEMENT Regulates oil and gas wells and brine disposal 383-2000-030 / October 1, 1998 / Page 52 STATUTORY AND REGULATORY CITATIONS Fed. Safe Drinking Water Act of 1974 and amendments, PA Safe Drinking Water Act, The Clean Streams Law of PA; 25 PA Code Chapter 109 PA Solid Waste Management Act; PA Municipal Waste Planning, Recycling & Waste Reduction Act; 25 PA Code Chapters 271-285 and 287299 25PA Code Chapters 260-270 PA Hazardous Sites Cleanup Act (Act 108 of 1988) PA Land Recycling and Environmental Remediation Standards Act (Act 2 of 1995); The Clean Streams Law of PA; RCRA; the Storage Tank and Spill Prevention Act; 40 CFR Part 280; 25 PA Code Chapter 245; Act 2 of 1995. Surface Mining Conservation and Reclamation Act; Noncoal Surface Mining Conservation and Reclamation Act, Bituminous Mine Subsidence and Land Conservation Act, Coal Refuse Disposal Act, 25 PA Code Chapters 77 and 86-90; The Clean Streams Law of Pennsylvania The Oil and Gas Act, the Coal and Gas Resource Coordination Act, the Oil and Gas Conservation Law, the Clean Streams Law of PA, and the PA Solid Waste Management Act, 25 PA Code Chapters 78, 79, & 97 BUREAU RADIATION PROTECTION TOPOGRAPHIC AND GEOLOGIC SURVEY DEPARTMENT OF AGRICULTURE OFFICE OF POLLUTION PREVENTION AND COMPLIANCE ASSISTANCE GROUNDWATER MANAGEMENT ACTIVITY Low Level Radioactive Waste Program Performs groundwater surveys and prepares reports of findings, oversees the Water Well Drillers License Program, maintains an inventory of water wells drilled in PA, and responds to well abandonment concerns Responsible for developing Pesticide State Management Plans STATUTORY AND REGULATORY CITATIONS Low Level Radioactive Waste Disposal Act of 1980, 1985 amendments; Radiation Protection Act; Appalachian States Low Level Radioactive Waste Compact Act The Water Well Drillers License Act; 17PA Code Chapter 47 Federal Insecticide Fungicide and Rodenticide Act Provides site visit service to assist in the Voluntary initiative prevention of groundwater pollution by identifying ways the regulated industries can reduce or eliminate the creation of pollutants through more efficient use of water, raw materials, energy and other resources. 3.2 Coordination Mechanism The CSGWPP Work Group is represented by agencies in the state with groundwater quality protection responsibilities. These programs include the Bureau of Water Supply Management, Bureau of Watershed Conservation, Bureau of Land Recycling and Waste Management, Bureau of Oil and Gas Management, Bureau of Mining and Reclamation, Bureau of Radiation Protection, Bureau of Waterways Engineering, Bureau of Water Quality Protection, the Bureau of Topographic and Geologic Survey, Bureau of Laboratories, Office of Chief Counsel, Bureau of Regulatory Counsel, Water Management Deputate, a regional office representative, and the PDA Bureau of Plant Industry. All of the programs have provided input to the development of the CSGWPP. 3.3 Legal Resources and Authorities All programs with groundwater protection responsibilities have the legal authority, under the Pennsylvania Clean Streams Law and specific program statutes, to address groundwater protection needs (See also Section 3.1.). Ground and Surface Water Quality Programs: Sufficient legal authority is provided through the Pennsylvania Clean Streams Law and associated regulations under Title 25. 383-2000-030 / October 1, 1998 / Page 53 Drinking Water Program: Groundwater protection for drinking water goals is achieved through cooperation and coordination with state, local, and federal agencies along with the water supplier. There is sufficient authority through these programs and the municipal planning code to meet these goals. Storage Tank Program: The Clean Streams Law and the Storage Tank and Spill Prevention Act provide legal authority to address groundwater protection needs. Land Recycling and Waste Management/Environmental Cleanup Program: The Hazardous Sites Cleanup Program receives authority to address contamination to the waters of the Commonwealth through the Clean Streams Law, the Hazardous Sites Cleanup Act, Storage Tank Act, the Land Recycling and Environmental Remediation Standards Act and regulations provide sufficient authority. The CERCLA Program’s authority is found in the Clean Streams Law and federal and state CERCLA requirements. In the Land Recycling Program, the Land Recycling and Remediation Standards Act and relevant waste management regulations provide sufficient authority for groundwater protection. The Municipal/Residual waste program requirements are contained in Act 97, the Solid Waste Management Act of 1980, as amended. In the Hazardous Waste Management Program, Title 25, Chapters 260-270, the Clean Streams Law, the Solid Waste Management Act (Act 97), and 40 CFR Parts 260-269 provide the legal authority to address the programs groundwater protection needs. Mining Program: There is sufficient legal authority for the mining program to address groundwater protection. Permit applications must demonstrate that there is no “presumptive evidence of potential pollution of the waters of the Commonwealth” (25 PA Code, Chapter 86). Oil and Gas Program: There is sufficient legal authority available to address groundwater protection needs through the Clean Streams Law, the Oil and Gas Act, and 25 PA Code Chapter 78. Radiation Protection Program: Regulatory authority is not clear, both on the federal and state level, for diffuse Naturally Occurring Radioactive Material (NORM) that is distributed through a matrix such as soil or rock. Approaches to this problem are being worked on by several federal agencies (EPA, Nuclear Regulatory Commission, Department of Energy), states, the Conference of Radiation Control Program Directors, advisory groups (NCRP and ICRP) and industry groups (especially the Oil and Gas Industry). Nonpoint Source and Nutrient Management Programs: As part of the development of the Coastal Nonpoint Source Pollution Program required under Chapter 6217 of the Coastal Zone Act Reauthorization Amendments, the Bureau of Watershed Conservation completed a detailed analysis of all laws and regulations in the state to determine if sufficient legal authority existed to implement this program. The conclusion was that there is sufficient legal authority. Most of this authority is derived from the Clean Steams Law, but additional authority comes from the Nutrient Management Act. Additional legal authority for the Bureau to develop and implement stormwater management plans comes from the Act 167 Program (Stormwater Management). 383-2000-030 / October 1, 1998 / Page 54 Finally, grant programs such as the Section 319 Program were developed in response to the authority identified by the Federal Clean Water Act. PA Department of Agriculture: Sufficient legal authorities are provided relating to groundwater quality protection. Authority is provided through 7 PA Code, Chapter 128, Pesticides Rules and Regulations and the Pennsylvania Pesticide Control Act of 1973 (3 P.S. Section III.21 - III.61. Regulations are specific regarding groundwater protection and the use of pesticides. 3.4 Relevant Federal Agencies Pennsylvania coordinates closely with federal agencies working in the state. EPA Region III was closely consulted throughout the CSGWPP process. Other federal program contacts in the state are as follows: U.S. Department of Interior: United States Geological Survey United States Fish and Wildlife Service United States Bureau of Mines U.S. Department of Agriculture: Natural Resources Conservation Service Agricultural Research Service Cooperative State Research Services Economic Research Service Office of Surface Mining Bureau of Land Management Extension Service Farm Service Agency National Agriculture Library United States Forest Service U.S. Department of Defense: U.S. Department of Energy: U.S. Department of Transportation: U.S. Coast Guard U.S. Department of Commerce: National Oceanic and Atmospheric Administration 3.5 Neighboring Tribal Officials There are no tribal lands in Pennsylvania. Interstate coordination is discussed in the following Section 3.6. 3.6 Interstate Coordination Mechanisms for interstate consideration exist through coordination with other state environmental protection agencies (e.g. the New Jersey Department of Environmental Protection and the Maryland Department of Environment and Natural Resources) and within various interstate commissions: 383-2000-030 / October 1, 1998 / Page 55 l l l l l l l Susquehanna River Basin Commission Delaware River Basin Commission Interstate Commission on the Potomac River Basin Ohio River Valley Water Sanitation Commission Interstate Oil and Gas Commission Interstate Mining Compact Commission Delaware Estuary Program Some programs, by their very nature, require interstate coordination: Radiation Protection Program: The Conference of Radiation Control Program Directors coordinates interstate effects in regulation, including Naturally Occurring Radioactive Material. The committee list does not include anything specific to groundwater; however, groundwater could be addressed through this forum. Nonpoint Source Program: The Chesapeake Bay Program is an interstate effort with the states of Pennsylvania, Maryland, Virginia, and Washington, D.C. The Program has also had some interaction with the state of New York to discuss their role. The Bay Program has completed a Nutrient Reduction Tributary Strategy. They also have developed a Toxics Reduction Strategy. While neither of these strategies address groundwater issues specifically, the mechanisms are in place to do so, if it is determined to be necessary to protect the resources of the Chesapeake Bay. The Delaware Estuary Program is another interstate effort with the states of New Jersey, Delaware, and Pennsylvania. The program has recently completed a Comprehensive Conservation Management Plan that does address some groundwater protection issues. Of special interest are action items dealing with toxics, water use management, and land management. The Section 319 Nonpoint Source Program is involved in two watershed initiatives that require interstate coordination. The first project is the development of a Nonpoint Source Strategy for the Christina Basin. This project is being completed by a task force with membership from the states of Delaware and Pennsylvania. This project has an ongoing public participation committee. The second project is an implementation program in the Evitts Creek Watershed, Bedford County. This project is a joint effort between the states of Maryland and Pennsylvania. Both of these initiatives have a surface water focus, but the communication network is in place, should groundwater issues develop. Nutrient Management: The interests of the Nutrient Management Program overlap with several other programs. The Nutrient Management Program is directly connected to the Chesapeake Bay Program. Facilities that receive funding from the Chesapeake Bay Nonpoint Source Pollution Abatement Program are required to follow the specified nutrient management plans. The Bay Program is a cooperative effort of the county conservation districts, DEP, the State Conservation Commission, Department of Agriculture, U.S. Environmental Protection Agency, the Natural Resource Conservation Service and other agencies. 383-2000-030 / October 1, 1998 / Page 56 The nutrient management plan is also complying with the federal Clean Water Act and the federal National Pollution Discharge Elimination System (NPDES) Program regulations (40 CFR Part 122.23) that require states to develop water quality permitting requirements to cover concentrated animal feeding operations. PA Department of Agriculture: PDA participates in conference calls with neighboring EPA Region III states to develop consistencies and to address concerns regarding the implementation of State Management Plans (SMPs) for specific pesticides. These State Management Plans are being developed and implemented by each state to protect water resources. Oil and Gas Program: The Oil and Gas program participates in the Interstate Oil and Gas Compact Commission. This commission has produced the document Environmental Guidelines for State Oil & Gas Regulatory Programs. This document includes guidelines for the protection of groundwater including guidelines for addressing abandoned oil and gas sites. 3.7 Local Governments The draft CSGWPP and Self Assessment and the CSGWPP profile were made available for public comment by a notice in the Pennsylvania Bulletin and the DEP Update in June of 1997. Public comments were accepted during this time. The text of the draft CSGWPP has been posted on DEP’s website. Each program with groundwater protection and remediation responsibilities utilizes various methods and mechanisms to ensure local notification, involvement and participation with its respective programs. Although local governments have no inherent powers to regulate (only powers that have been specifically given by the state), land use and growth management may be accomplished through the Municipalities Planning Code. This code gives local governments the authority to develop comprehensive planning including issues dealing with “safe, reliable, and adequate water supplies.” Access to DEP program guidance, policies, and information is available on DEP’s Internet site (http://www.dep.state.pa.us). A local government help center has been established on the website to assist local governments in the interaction with state programs and policies. Also, the CSGWPP was presented to advisory committees that have a stake in the CSGWPP. This included the Water Resources Advisory Committee and the Agricultural Advisory Board. Program specific details are discussed below: Groundwater and Surface Water Quality Programs: Local governments are included through efforts of the Pennsylvania Groundwater Policy Education Project, the Water Resources Education Network, Community of Governments, planning commissions, conservation districts, and regional Citizen Roundtables. Wellhead Protection Program: A key element of the Wellhead Protection Program is involvement of local municipalities. Workshops have been presented at numerous local government organization meetings across the state including the Pennsylvania Municipal Authority Associations, Pennsylvania Township Supervisors Association, Pennsylvania Planners Association and the Pennsylvania Bar Association Law Colloquium for Municipal Solicitors. The purpose of these meetings is to raise awareness of the role of local government in water 383-2000-030 / October 1, 1998 / Page 57 supply protection. Notices and articles in association publications, the NewsSplash, and DEP’s Update keep local governments apprised of issues and invite participation. The tools of community planning are key to the Water Supply Planning and WHP grants that have been offered to Pennsylvania counties for the last three years. Fourteen grants totaling over one million dollars have been awarded under this program. Storage Tank Program: Local government is represented by four members on the Storage Tank Advisory Committee (STAC). This committee was created by the Storage Tank and Spill Prevention Act to review regulations prior to submission to the Environmental Quality Board (EQB). The Citizens Advisory Committee (CAC) and Regional Roundtables are given the opportunity to provide comments on significant program changes. Land Recycling and Waste Management/Environmental Cleanup Programs: Local government provides some approvals for site cleanups related to the Hazardous Sites Cleanup Program. By authority of Act 2 and Act 4 of 1995, the state Department of Community and Economic Development provides financial assistance to encourage voluntary investigation and remediation activities at industrial sites. In addition, the Cleanup Standards Scientific Advisory Board was created by Act 2 to help create Act 2 cleanup standards used for site remediation. In the Southeast Region, the local government also is involved through the Chester County Health Department, Montgomery County Health Department, Philadelphia County Health Department and Bucks County Health Department. Correspondence letters are copied to the municipalities. Act 2 requires public notification via newspaper Legal Notice and Pennsylvania Bulletin notice. Community Relations Plans for CERCLA are used to keep the public informed at NPL sites and a repository for the project documents (workplans, etc.) are located in a public building in the municipality. Local governments are notified of all activities involving waste management decisions. For Municipal/Residual/Hazardous Waste Facilities, the Solid Waste Advisory Committee, and Water Resources Advisory Committee, Citizens Advisory Committee, and Regional Roundtables are given the opportunity to provide comments on significant program changes. Mining Program: Local governments are routinely notified by direct mailing relative to mining permit applications submitted and they have the opportunity to review and comment on such applications. Radiation Protection Program: The Low Level Radioactive Waste program provides for extensive involvement of county and local governments in the siting process as well as extensive financial benefits to the ultimate host community. Site characterization involves detailed consideration of hydrogeology. Nonpoint Source Program: The County Conservation Districts provide guidance on what works at the local level. A considerable amount of staff time is devoted to developing the guidance and training needed by the conservation districts to implement DEP programs. In some cases public comment is solicited. Two examples are public meetings held to review the Delaware Estuary Program Comprehensive Conservation Management Plan and the Chesapeake 383-2000-030 / October 1, 1998 / Page 58 Bay Nutrient Reduction Tributary Strategy. These meetings were designed to get additional local input. Nutrient Management Program: The Nutrient Management program works with the county conservation districts by providing guidance and technical support. PA Department of Agriculture: The local government generally does not become involved in the development of agricultural groundwater protection strategies. However, the PDA may involve local government in the surface and groundwater monitoring program. Specifically, public water supplies may be routinely sampled for pesticides through the cooperation of the municipal authority. The Pesticides and Ground Water Strategy will be published in the Pennsylvania Bulletin. No local government mailings are required or anticipated. 383-2000-030 / October 1, 1998 / Page 59 4. STRATEGIC ACTIVITY 4: EFFORTS TO ACCOMPLISH THE STATE’S GOAL 4.1 Programs to Address Priorities Programs with groundwater protection and remediation responsibilities have measurable objectives aimed at preventing pollution from reaching groundwater and remediating groundwater that has been polluted. These measures can include increased efforts to educate the regulated community on pollution prevention through source reduction (i.e. not creating polluting substances to begin with, through process and raw material shifts), siting of facilities and activities, permitting requirements, technological controls and performance standards, implementation of best management practices, and compliance and enforcement activities. For example, the water supply program is developing a Wellhead Protection Program to ensure protection of public water supplies, the mining and oil and gas programs issue permits that specify technologies, the Chesapeake Bay, Nonpoint Source, and Nutrient Management Programs identify effective best management practices for agricultural related activities, the storage tank program establishes siting and construction standards to prevent groundwater pollution, the waste management programs (municipal, residual, and hazardous) issue permits and establish performance and construction standards for landfills to prevent surface and groundwater pollution, and the Pennsylvania Department of Agriculture controls pesticide usage through the State Pesticide Management Plan. Remediation programs such as the land recycling program and environmental cleanup program establish standards for environmental cleanup consistent with the mandates of Act 2 of 1995. Also, the Office of Pollution Prevention and Compliance Assistance (OPPCA) has been formed to assist regulated industries, local governments, homeowners, and others in preventing pollution through increasing efficiencies in energy use, water use, raw materials, and other resources and through protecting natural resources by conservation. OPPCA’s mission will be achieved by providing direct technical assistance and through integration of pollution prevention activities across Departmental programs so that prevention takes precedence over cleanup. OPPCA provides a site visit service that can assist in the prevention of groundwater pollution. During these site visits, OPPCA pollution prevention teams, consisting of DEP personnel from across various programs, help to identify ways in which the regulated industries can reduce or eliminate the creation of pollutants through more efficient use of water, raw materials, energy and other resources. 4.2 Characterization and Assessment to Support Prevention Decision-Making Groundwater related programs have procedures in place for groundwater assessment and characterization for regulated activities. The Groundwater Monitoring Guidance Manual has been developed to provide consistency across all programs in making site assessments for monitoring decisions. These programs are described below: Bureau of Water Quality Protection Programs: When permitting activities such as land application or septic tanks, an assessment is conducted relative to the vulnerability of the groundwater resource and the effectiveness of the treatment technology. Many of the factors listed in Figure 1 are evaluated. 383-2000-030 / October 1, 1998 / Page 60 Drinking Water Program: A vulnerability assessment procedure (VAP) was established to provide a state-wide screening methodology to determine which public water supplies are vulnerable to pesticide and certain industrial organic contaminants in groundwater sources. The Federal Safe Drinking Water (SDWA) regulations published in 1991 and 1992 require public water suppliers (PWS) to monitor for 43 synthetic organic chemicals (SOC) beginning the first quarter of 1995. In accordance with Federal SDWA regulations Pennsylvania promulgated regulations which permit implementation of an SOC monitoring waiver program for community water systems and nontransient, noncommmunity water systems. Initially, state-wide monitoring waivers were granted for 13 pesticides that met the use waiver criteria on a state basis. The BWSM then conducted a study to evaluate the vulnerability of PWS sources across the state to potential sources of pesticide contamination. The study identified the most critical pesticides relative to the potential of groundwater contamination within a water supply source’s contribution area. To address the large amount of geographic data required to derive a vulnerability score for each system in the state, a GIS is utilized. Results from the vulnerability assessment set initial monitoring waivers for each PWS entry point in the state. The vulnerability assessment study shows that PWS groundwater sources located in agricultural areas and underlain by limestone bedrock are particularly vulnerable to pesticide contaminants (which comprise most of the regulated and unregulated SOCs designated by EPA). Fewer waivers in these areas can, therefore, be granted. Conversely, PWSs whose contribution areas are mostly forested benefit from increased waivers because of a general lack of pesticide use. Priorities and monitoring waivers for other potential contaminants are or will be developed in a similar way and GIS will be applied where appropriate. Storage Tank Program: Regulations have been finalized that specify siting requirements for new large aboveground storage tanks, field constructed underground storage tanks, and highly hazardous underground storage tanks. Considerations are given to the presence of flood plains, wetlands, sinkholes, solution channels, and prevalence of deep mining. The Land Recycling Program Database is used to track the status of confirmed storage tank release sites. Land Recycling and Waste Management/Environmental Cleanup Programs: The Land Recycling Program Database is used within the Hazardous Sites Cleanup Program and CERCLA to provide a status list of Environmental Cleanup Program sites. In the Land Recycling Program, the Technical Guidance Manual is based on ASTM and EPA procedures and provides for consistent site assessments. Site specific considerations are employed. These programs are involved in remediation and controlling existing contamination. Provisions for updating and improving technical capabilities include computer hardware/software that can be used statewide, GIS, and integrated programming. In the Hazardous Waste Program, Chapters 264 and 265 of the Hazardous Waste Regulations include detection and compliance monitoring programs to protect groundwater quality. The Waste Management programs require baseline groundwater studies as part of its permitting process for proposed facilities. Identification of all known surface and groundwater resources in the area of the proposed facility also is required. 383-2000-030 / October 1, 1998 / Page 61 Mining Program: Permit applicants must submit an extensive amount of information on surface and groundwater resources within and adjacent to the proposed mining area (see discussion under criteria 4.4 below). Oil and Gas Program: A predrilling water quality assessment of home water wells that may be affected by the drilling is conducted to establish the quality and quantity for water replacement if the drilling affects the homeowner’s water supply. Radiation Protection Program: The Low Level Radioactive Waste Program has specific provisions for consideration of groundwater. The NRC, EPA, or DOE requirements for demonstration of meeting site cleanup requirements include consideration of groundwater contamination as part of pathway modeling, which is usually done using models like RESRAD, by using mostly default parameters. Nonpoint Source Program: Remediation measures for NPS pollution are identified and designed on a site-specific basis. These assessments are typically more surface water oriented since it would be time and cost prohibitive to complete groundwater vulnerability assessments for every site. Research is being done by the Chesapeake Bay Program and the Section 319 Nonpoint Source Pollution Program to better document the effects management measures for nonpoint source remediation have on groundwater. Nutrient Management Program: The Nutrient Management Program was charged with assessing the contribution to pollution of the waters of the Commonwealth by 1) malfunctioning on-lot sewage systems, 2) improper water well construction, 3) application of chemical fertilizers and plant nutrients used for non-agricultural purposes, 4) nutrients from stormwater runoff, and 5) atmosphere deposition of nutrients. The Pennsylvania State University was contracted by DEP to develop a report quantifying the nutrient load reaching the State’s surface and groundwater from each of the five identified sources. The report is entitled “Quantification of NPS Pollution Loads Within Pennsylvania Watersheds.” This information on background water quality data for nutrients will be used to prioritize and address pollution abatement measures. PA Geologic Survey: The Survey provides information on groundwater resources, geology, and naturally occurring groundwater quality across the state. This information supports programs that have groundwater quality protection responsibilities. The Geologic Survey provides information on groundwater characteristics 1-3, and 5 as noted on Figure 1. Most research emphasizes natural conditions, but some studies of man-made changes to groundwater quality and quantity also are conducted. PA Department of Agriculture: The PDA evaluates groundwater degradation related to pesticides based on the MCLs, or HALs where MCLs are unavailable. Specifically, where pesticides are detected at levels of 1/3 or less of the MCL, a system of voluntary BMPs for water quality management is instituted through extension and other educational programs. Associated ASCS, NRCS, and Conservation District programs include BMPs for pesticide management. These BMPs include all chemical-specific users (agriculture, lawn care, right-of-way and 383-2000-030 / October 1, 1998 / Page 62 homeowner pesticide usage) within the area of concern. The use of BMPs is based on the level of vulnerability within the area to be protected. If detection levels are at or above 1/3 of the MCL, a more rigorous set of BMPs is employed. The PDA designates selected mandatory BMPs to address specific avenues of contamination of the aquifer. The use of mandatory BMPs may apply to single chemicals or to groups of chemicals having similar potentials for contamination. If monitoring data indicate general levels of contamination are increasing in spite of mandatory BMPs, the PDA may take additional measures up to the elimination of product use within aquifers of concern. Aquifer assessment and the establishment of a pesticide monitoring database are initial priorities for the State Management Plan (SMP). As funding becomes available, aquifer assessments will be conducted in areas of the state that typify the state’s major geologic settings. Of concern will be the carbonate areas of the Valley and Ridge province and the glaciated regions of northern Pennsylvania. The SMP will extend monitoring efforts into these areas of the state. The development of subcounty level data should give chemical specific management plans the ability to provide subcounty level protection based on local vulnerability and pesticide usage patterns. 4.3 Wellhead Protection Program Pennsylvania will be submitting a WHP Program to EPA in early 1998. Under the state program, local WHP programs are voluntary. Water suppliers developing new groundwater sources are required to address certain WHP provisions under the Safe Drinking Water Regulations. The approach is to encourage development of local WHP program by local municipalities and water suppliers through technical, educational and financial assistance. The Bureau of Water Supply Management has been actively developing and implementing the state program based upon this approach of support and incentives for development of local WHP program. These efforts include public education, training, grants, technical assistance, and a regulatory framework for public water suppliers to develop local WHP programs. Including the pilot projects under the county grant programs, there are over 150 community water systems and municipalities actively developing or implementing local WHP programs. Wellhead Protection has been incorporated into the Safe Drinking Water regulations as revised on October 8, 1994. In those regulations, the Wellhead Protection Areas (WHPA) are defined, the area immediately surrounding the well that must be protected is set, and criteria are established for approval of voluntary local WHP programs. The state WHP Program will suffice for the groundwater component of the Source Water Assessment Program, which is required to be developed under the Safe Drinking Water Act. The focal point of a WHP program is the WHPA delineation and the resultant map. The Bureau of Water Supply Management has been involved in a joint study with the USGS to evaluate EPA’s WHPA delineation methods for the various hydrogeologic settings of Pennsylvania. The USGS has published and released the first two of a series of reports and the remaining reports are in final review. These reports will be the basis for developing guidelines for delineation of WHPAs in Pennsylvania. In addition to this study, a Request For Proposal will be advertised in 383-2000-030 / October 1, 1998 / Page 63 the near future to develop approaches to assist municipalities in developing management programs for these areas. Funding has been available in the form of state and federal grants for demonstration projects, state County Water Supply Planning and Wellhead Protection Grants, and financing through PENNVEST and the USDA Rural Development program (formerly referred to as the Farmers Home Administration). 4.4 Implementation of Prevention Activities Programs with groundwater protection or remediation responsibilities have integrated procedures to prevent or minimize contamination, implement additional controls if contamination is increasing toward levels that exceed a criterion or reference point and take actions to remediate groundwater that exceeds established health and environmental protection levels. Program specific procedures are as follows: Bureau of Water Quality Protection Programs: All permitted activities are designed to prevent or minimize contamination and prevent pollution. When contamination increases toward a reference point, additional limitations such as imposed additional controls or cessation of the activity may be imposed. When contamination has been documented to exceed a reference point, corrective actions are imposed. Drinking Water Program: Community Water System (CWS) permittees using groundwater sources are required to obtain the highest quality source available and to take reasonable measures to protect the source. An initial set back distance for new CWSs or expanding CWSs is required to prevent contamination from potential sources of contamination. Water suppliers may not store or use potential contaminants in this zone unless they are properly used to treat the water supply. All new sources are required to implement this protection to the extent feasible. Monitoring is required if contaminants are detected. If the MCL or MCLG is exceeded, the supplier must reduce the contaminant in the treated water to less than the MCL and provide public notice. Public Water Suppliers are required to conduct sanitary surveys yearly to determine new potential sources of contamination. PWSs are required to take all reasonable measures to protect the source. The state encourages, promotes, and supports local development of WHP programs. Storage Tank Program: Leak detection is required on all regulated underground storage tanks (except for emergency generator tanks). The goal is to detect and stop a leak prior to any impact on groundwater or in time to prevent any widespread groundwater contamination that cannot be effectively remediated. All new regulated underground storage tanks are also required to have corrosion and spill/overfill protection; existing regulated tanks will be required to have corrosion and spill/overfill protection by December 22, 1998. Site specific permitting requirements have been developed for targeted storage tanks including new large aboveground storage tanks, field constructed underground storage tanks, and highly hazardous underground storage tanks. The applicant must provide information on the presence of carbonate bedrock. An environmental assessment must be developed that considers potential 383-2000-030 / October 1, 1998 / Page 64 impacts to public health and safety, and the environment (including water quality and features such as public water supplies). The Corrective Action Regulations require immediate interim remedial actions to be taken, upon confirmation of a release, and the necessary site characterization work to define any impacts on groundwater and implement remedial actions as necessary. Land Recycling and Waste Management/Environmental Cleanup Programs: Remediation requirements for contaminated sites that qualify for the Land Recycling Program are addressed within Act 2 of 1995. Act 2 regulations were finalized in August 1997. In the Municipal/Residual/ Hazardous Waste Programs, extensive groundwater studies include background analysis (prior to facility siting), detection and compliance monitoring, and assessment/abatement monitoring (if contamination is detected). When contamination is confirmed, actions such as bioremediation, total fluid extraction, pump and treat, and soil-gas venting are employed. In the Land Recycling/HSCA/CERCLA Programs, remediation at contaminated sites is required in accordance with the provisions and final regulations of Act 2. Various remediation technologies are used to clean up and control contamination. Innovative technologies also are being considered as they are developed. Mining Program: Groundwater levels, infiltration rates, subsurface flow and storage characteristics, and the quality of groundwater must be monitored in a manner approved by the mining program to determine the effects of mining activities on the recharge capacity of reclaimed lands and on the quantity and quality of groundwater in the permit and adjacent areas. When mining activities may affect the groundwater systems that serve as aquifers which significantly ensure the hydrologic balance of water use on or off the permit area, groundwater levels and groundwater quality must be periodically monitored. Monitoring must include measurements from a sufficient number of wells and chemical analyses of water from aquifers which adequately reflect changes in groundwater quantity and quality resulting from those activities. Monitoring must be adequate to plan for modification of mining activities, if necessary, to minimize disturbance of the prevailing hydrologic balance. As specified in the program regulations, DEP also may require mining activities to conduct additional hydrologic tests, including, but not limited to drilling, infiltration tests, aquifer tests, and chemical and mineralogical analyses of overburden and spoil to demonstrate potential impacts on surface and groundwater resources. Oil and Gas Program: Oil and gas wells are cased beyond fresh water zones to prevent groundwater contamination. If contamination is detected it is usually localized and the casing is replaced. Radiation Protection Program: The field offices would be involved with any major contaminating event although control would be with NRC or EPA. 383-2000-030 / October 1, 1998 / Page 65 Nonpoint Source and Nutrient Management Programs: The approach for the Chapter 6217 Coastal Nonpoint Pollution Program is to implement a series of management measures as defined by EPA and NOAA by land use category, whether or not the activity is causing a water quality problem. Provisions in the state’s program also must define what additional measures will be taken if it is determined that the implementation of these technological measures is not enough to improve and protect the coastal zone waters. The Bureau of Watershed Conservation has submitted the program plan for the implementation of the Chapter 6217 Coastal Nonpoint Program for approval to NOAA and EPA. NOAA and EPA recently published conditions for approval of the Pennsylvania program in the Federal Register. All of the programs have information, education and technical assistance components. These activities are geared to inform and train the public and those affected, thereby “preventing” pollution from various nonpoint source activities. Examples of these programs include: 1. Conservation District Technicians are financed by both the Chesapeake Bay and Section 319 program to work with landowners to develop nutrient management plans which address the problems on their farms. 2. A technical assistance component to the Nutrient Management Act is required. Components of this program include a cooperative agreement within the Penn State Cooperative Extension, and delegation agreements with conservation districts to hire additional technical staff to review and approve nutrient management plans. The Section 319 Program is in the final stages of developing a comprehensive strategy to address nonpoint source issues in the state. This strategy will identify action items to address three focus areas: GIS, Monitoring and Assessment, and Public Input. This strategy will be used to re-write the state Nonpoint Source Management Plan and revise the state Nonpoint Source Priority Watershed List. PA Department of Agriculture: The proposed State Pesticide Management Plan provides that where pesticides are detected at levels of 1/3 or less of the MCL, a system of voluntary BMPs for water quality management is instituted through extension and other educational programs. Associated ASCS, NRCS and Conservation District programs include BMPs for pesticide management. These BMPs will include all chemical-specific users (agriculture, lawn care, right of way and homeowner pesticide usage) within the area of concern. The use of BMPs is based on the level of vulnerability within the area to be protected. If detection levels are at or above 1/3 of the MCL level, a more rigorous set of BMPs is employed. The PDA designates selected mandatory BMPs to address specific avenues of contamination of the aquifer. The use of mandatory BMPs may apply to a single chemical or to groups of chemicals having similar potentials for contamination. If monitoring data indicates that contamination is increasing in spite of mandatory BMPs, the PDA may take additional measures up to the elimination of product use within aquifers of concern. 383-2000-030 / October 1, 1998 / Page 66 Where general monitoring trends reveal a decrease in detection levels (below 1/3 of MCL) as a result of BMPs, the PDA may require the continued use of the BMPs to ensure aquifer protection. The continued use of BMPs will be evaluated by the PDA through water quality data and the review of economic constraints placed on chemical users as a result of mandatory BMPs. The intent of the PDA is to maintain water quality and minimize the economic impacts placed upon pesticide users. When pesticide concentrations exceed 2/3 of the MCL, use restrictions or product cancellations are reasonable choices. Whether contamination results from normal field applications or point source discharges, the PDA’s regulatory strategy is based upon the nature of contamination and the value of the groundwater resource. Unless site-specific (geographic area) conditions exist, the PDA expects EPA to take appropriate action up to and including product cancellation based on a product’s potential for pollution on a national basis. Failure to take such actions may constitute failure to meet its federal mandate. The PDA works with state and federal agencies to develop practical remediation strategies to address contamination levels at or in excess of the MCL. Remediations would involve the use of Best Demonstrated Technologies (BDT). Resources for remediation may be acquired through the joint efforts of landowner, pesticide users, product registrants, EPA and the PDA. Where specific landowners or operators have been determined to be principal contributors to pesticide contamination from point or nonpoint sources, these landowners and/or specific business situated thereon would share in the cost of remediation activities. Where contamination levels exceed the MCL as a result of point source contamination, from spills, leaks or improper mixing and loading, the PDA acknowledges that DEP assumes the primary regulatory authority for water quality concerns. PDA works with DEP to ensure groundwater protection and remediation within its FIFRA mandate. The PDA attempts to identify sources of contamination and, where possible, determine if product use is consistent with label language. If product misuse is documented, appropriate enforcement action is taken. Where contamination levels exceed the Health Advisory Levels or MCL, the PDA works with DEP to ensure public drinking water safety. Guidelines to protect public water supplies are set by the Bureau of Water Supply Management. The PDA works with DEP to provide prevention and remediation strategies. Mandatory BMPs and use restrictions may be employed to ensure the safety of public water supplies. Private water supplies that reach or exceed the MCL will require the notification of the well owner along with explanatory information such as health advisories. Domestic wells that do not reach the MCL will be handled similar to public supplies where the PDA identifies areas of contamination, involving multiple wells, resulting from the normal usage of specific chemical. Where appropriate, enforcement actions may be taken by the PDA against pesticide users whose product use has resulted in private well contamination. Private well construction is evaluated where necessary to ensure integrity of the water system. If the PDA identifies, through monitoring, a pattern of domestic water supply contamination, use restrictions may result to protect the aquifer. The PDA evaluates private well contamination through pesticide use investigations or generally through product use restrictions. The PDA works with DEP to ensure that concerns for pesticide contamination of domestic water supplies are addressed. 383-2000-030 / October 1, 1998 / Page 67 4.5 Programs with Measurable Objectives for Remediation Programs with remediation responsibilities have measurable objectives based on remediation of groundwater resources as follows: Water Quality Program: Regional staff may oversee the remediation of groundwater pollution incidents that do not fall under the jurisdiction of other programs. They also coordinate with other programs such as the Bureau of Land Recycling and Waste Management, Bureau of Water Supply Management, and the Environmental Cleanup Program, and provide technical assistance and support as required. Storage Tank Program: Chapter 245, Administration of the Storage Tank and Spill Prevention Program, formalizes the Corrective Action Process (CAP). These regulations include requirements for confirming or disproving suspected releases; reporting releases; determining the extent of soil, sediment, surface water and groundwater contamination; taking necessary actions to abate risks to human health and the environment; taking steps to prevent further migration of the released substance into the environment; restoring or replacing affected or diminished water supplies; and proper storage of contaminated soil at the site of the release. Land Recycling and Waste Management/Environmental Cleanup Programs: Most remediations are in accordance with Act 2 of 1995. Act 2 provides clear objectives for achieving the remediation standards. Primary and secondary sources of contamination can be addressed by onand off-site remedies to achieve the cleanup standards. The Land Recycling Program coordinates activities that involve Act 2 remediation actions for contaminated sites. Mining Program: Remediation is required when it becomes evident that mining activities have contaminated or diminished water supplies, or when nearby streams have become contaminated from mining impacts on the local groundwater system. Oil and Gas Program: Remediation is performed by the operator. Orphaned or abandoned well sites are remediated through the Abandoned and Orphan Well Plugging Program. Radiation Protection Program: Site cleanups are tracked, but the Bureau of Radiation Protection does not generally be involved with remediation activities. These are typically handled by the Environmental Cleanup Program. Nonpoint Source Program: Criteria for the selection of projects funded with Section 319 Nonpoint Source Implementation grant money requires the identification and documentation of measurable objectives for water quality improvement. This program has funded approximately 100 different watershed programs and demonstration projects in the past six years to remediate various problems caused by nonpoint source problems. Most of these programs have focused on abandoned mine drainage and agriculture, but some urban runoff projects have been included. PA Department of Agriculture: See Section 4.4. 383-2000-030 / October 1, 1998 / Page 68 4.6 Characterization and Assessment Support Remediation Decision-Making Programs with remediation responsibilities described in Section 4.5 conduct comprehensive site assessments in accordance with the following provisions: Water Quality Program: Regional staff may oversee the remediation of groundwater pollution incidents that do not fall under the jurisdiction of other program areas. Support is provided to the programs with remediation responsibilities upon request. Storage Tank Program: Site specific permitting requirements have been developed for targeted storage tanks including new large aboveground storage tanks, field constructed underground storage tanks, and highly hazardous underground storage tanks. The applicant must provide information on the presence of carbonate bedrock. An environmental assessment must be developed that considers potential impacts to public health and safety, and the environment (including water quality and features such as public water supplies). Regional offices make remediation decisions that are based on requirements of the corrective action process regulations, and on the provisions of Act 2 of 1995. Land Recycling and Waste Management/Environmental Cleanup Programs: The Land Recycling Program Technical Guidance Manual provides for consistency for site remediated under Act 2. The Technical Guidance Manual, Groundwater Monitoring Guidance Manual, and ASTM documents consider characteristics listed in Figure 1. Sites must be characterized to determine the nature, extent, direction, volume, and composition of contamination. Training is encouraged and numerous technology transfer sessions have been facilitated. In the Hazardous Site Cleanup Program and CERCLA Program, innovative technologies and ex-situ treatments are being considered at sites where cleanup was originally thought to be infeasible due to technological or economic factors. Considerations are based on affected receptors (private and municipal water wells) and historical degradation. In the Municipal/Residual/ Hazardous Waste Management Programs, facility siting and the impacts on groundwater use, value, and vulnerability are considered through the Waste Management regulations. These regulations require baseline studies, monitoring, and post-closure responsibilities. Development of GIS related capabilities will be an asset to this evaluation. Mining Program: Remediation is required when it becomes evident that mining activities have contaminated or diminished water supplies, or when nearby streams have become contaminated from mining impacts on the local groundwater system. The program continues efforts to improve capabilities through evaluation of “failures” and refinement of techniques for determining the potential for acid mine drainage. Radiation Protection Program: Standards are being developed on the national level by NRC, EPA, and DOE under the rulemaking process. The state may incorporate the results into regulations at some later time. Nonpoint Source and Nutrient Management Programs: Management measures implemented by the Chesapeake Bay Program, the Section 319 Program, the Chapter 6217 Coastal Nonpoint 383-2000-030 / October 1, 1998 / Page 69 Program, and the Nutrient Management program are tailored to specific site characteristics and requirements. These measures must comply with defined standards and specifications. PA Department of Agriculture: Vulnerability assessments at the sub-county level require extensive data collection outside the PDA’s area of expertise. The PDA pursues and relies on inter-agency cooperation for these assessments. PDA is working with the U.S. Geological Survey to implement the vulnerability assessment plan. Work is nearly complete on the quality assurance portion of the plan. 4.7 Provisions to Avoid Cross- Contamination During Remediation Provisions that are in place to provide for interprogram coordination in order to avoid crossmedia contamination during remediation activities are discussed below: Water Quality Program: Water quality remediation projects that may impact on air quality are coordinated with the Bureau of Air Quality. Storage Tank Program: Coordination with air/waste/water is handled through regional offices (Environmental Cleanup Program) through the necessary permits and approvals. Land Recycling and Waste Management/Environmental Cleanup Program: The Hazardous Sites Cleanup Program and Environmental Cleanup Program coordinate with the Bureau of Air Quality for remediation that contributes emissions to the air, and with the Water Quality program or the Bureau of Watershed Conservation where there are discharges to surface water. The CERCLA Program coordinates with the Bureau of Water Quality Protection or Water Quality program, Bureau of Watershed Conservation, Bureau of Air Quality, and the Bureau of Radiation Protection on remediation projects. Mining Program: Remediation is limited to efforts that protect stream usage, namely pumping and treating underground mine waters and treating surface discharges from surface mines. The Bureau of Mining and Reclamation coordinates with the Bureau of Watershed Conservation to ensure protection of surface water uses. Oil and Gas Program: All coordination with other bureaus or agencies is handled on a case-bycase basis. Radiation Protection Program: This program coordinates with the RCRA program to avoid mixing RCRA waste with radioactive material. Low Level Radioactive Waste Sites will not allow this waste in the facilities. The hazardous material must be removed from the matrix. Nonpoint Source and Nutrient Management Programs: NPS activities and problems are connected to water quality problems caused by land use activities. Therefore, all the programs are addressing concerns in both the land and water medias. Air pollution concerns have not been addressed in the past. However, there have been discussions in the Chesapeake Bay Program on how the program could address nutrient contributions to the Bay from the atmosphere. Also, 383-2000-030 / October 1, 1998 / Page 70 DEP has completed a study to identify the contribution of atmospheric deposition of nutrients to surface and groundwater. PA Department of Agriculture: Remediation activities are coordinated with ASCS, NRCS, and County Conservation Districts, which oversee BMPs, and DEP, which oversees remediation activities. Pesticide remediation activities will be evaluated on a site-specific basis by PDA. 383-2000-030 / October 1, 1998 / Page 71 5. STRATEGIC ACTIVITY 5: DATA MANAGEMENT 5.1 Data Management to Re-evaluate Priorities and Measure Progress All groundwater regulatory programs have a system for collecting and managing data and information, which are stored in various state and federal databases. In addition, DEP is currently conducting a Foundation for Information Exchange (FIX) project that will enhance current computerized data management systems. DEP is moving toward GIS coverages in nearly every program. DEP has developed a GIS 1999 Project with goals and milestones to support permitting, compliance assistance, pollution prevention, emergency response, public education and outreach, resource management, recycling and other land use management decisions. All DEP staff will have desktop access to the GIS to conduct day-to-day activities. Collection, storage and management systems by program are as follows: Groundwater Quality Program: Groundwater quality data collected from ambient and fixed station network monitoring are stored on the federal STORET database and utilized in groundwater quality assessments and trend analyses. Data have been added into a GIS. Drinking Water Program: Drinking water quality data are entered into a database maintained by a private contractor. It is planned to convert this database to a SAS (Statistical Analysis System) database administered by DEP. Facility data are already on this SAS database. A GIS coverage of source locations and facilities is being constructed from data in the SAS database. Storage Tank Program: The Storage Tank Database tracks many aspects of the program. The Land Recycling Program Database documents information relating to leaking storage tanks. This database is used to generate semi-annual reports for EPA. Land Recycling and Waste Management/Environmental Cleanup Programs: In the Waste Management Program, ORACLE and Microsoft Access computer programs are used to manage groundwater data. These programs are not yet integrable. The Land Recycling Program Database (Microsoft Access) is used to track sites participating in the Land Recycling Program (Act 2 of 1995). The Environmental Cleanup Program also uses the Land Recycling Program Database, which includes the Storage Tank Program sites, Hazardous Sites Cleanup Program sites, and Act 2 Voluntary Cleanup sites. In EPA, there is a CERCLA database for tracking the EPA CERCLIS and NPL sites, and some GIS files, which plot the location of the NPL sites in the state. Mining Program: The mining program maintains a comprehensive computerized inventory of active and inactive/reclaimed mining activities on the LUMIS computer system. In addition, the program maintains a data/mapping system (paper) of underground coal mining that has occurred since the 1930s, surface coal mining since the 1960s, and noncoal mining since 1972. Oil and Gas Program: Groundwater samples are collected on a case-by-case basis or for particular projects. Data are stored on a Microsoft Access database in the regional office and on DEP’s Laboratory Computer System. The groundwater sample source is related to the well 383-2000-030 / October 1, 1998 / Page 72 permit number. Also, a computerized inventory of oil and gas sites is maintained on the LUMIS computer system. Data are summarized in Project Reports, which are available in hard copy or diskette format. Radiation Protection Program: The Bureau of Laboratories, Radiation Measurements Section, maintains a PC-based file of all samples that are analyzed. The Bureau of Radiation Protection’s Environmental Surveillance Section maintains a spreadsheet application of data from routine environmental samples collected in the vicinity of nuclear power plants and several other locations. These environmental data are published annually in the Environmental Radiation Report. Nonpoint Source Program: The Section 319 Nonpoint Source Program has a very detailed system to track progress on the implementation of various projects and restoration efforts. Reports are sent on a semi-annual basis to EPA. In addition, an annual report is written and sent to EPA summarizing success and progress made during the year. The 319 Program also has milestones in the State Management Plan that are tracked and added to the annual report each year. The state Nonpoint Source Degraded Watershed List is reviewed and updated each year. This list is used to define the priority watersheds for the selection of projects for each grant. The Chesapeake Bay Program also tracks and reports progress to EPA on a quarterly basis. Information sent to EPA includes the number of management measures implemented, where they were implemented, costs, and the amount of sediment and nutrients reduced. EPA also develops various reports on the progress of the Chesapeake Bay Program, which include water quality and biological data collected in the Bay drainage area. The state also has a monitoring network on the Susquehanna and Potomac Rivers to document any improvements in the water quality. Besides the data management files kept to track progress by the 319 and Bay Program, the Bureau uses the 305(b) database, the Special Protection designated use records, and other assessment databases. The Bureau is in the process of developing a Geographic Information System for the Nonpoint Source Program to better handle large amounts of data, integrate with other programs in the state, and prioritize efforts to those watersheds where measurable environmental results are possible. PA Geologic Survey: Databases containing water well and spring locations, production, construction, and water quality information are maintained on a LAN server. Data is shared across programs upon request. Instructions and standardized reports are being prepared to allow easy access to the data via DEP’s computer connections and via the Internet. A database containing location, construction, and well log information on active and historical gas wells is also maintained. USGS: The following information is stored in the USGS office in Lemoyne, and accessed via a direct line in that office: (1) Water Well Inventory (WWI): Production, construction, and location information on water wells provided to BTGS by water well drillers. The information has not been field verified. (2) Groundwater Site Inventory (GWSI): Production, construction, field water quality, and location information collected and/or verified by BTGS or USGS staff, or 383-2000-030 / October 1, 1998 / Page 73 other USGS cooperators. Information from the WWI is used as a starting point to collect and verify information on wells in the GWSI database. (3) Quality of Water (QW data): Results of lab analysis conducted on samples collected from some wells inventoried for the GWSI database. The USGS downloads this information to EPA’s STORET database on a regular basis. 5.2 Using Data from Local, State and Federal Governments All programs coordinate interprogram use of groundwater data and utilize data from local government and federal agencies to the extent that it is necessary, available and acceptable. For example, all programs rely on basic geologic and hydrogeologic data from the USGS and BTGS. Also, under the Municipalities Planning Code, a local government may undertake environmental studies and water surveys. Groundwater Quality Program: Data from the USGS, the Bureau of Topographic and Geologic Survey, the Department of Agriculture, and U.S. EPA are used in making assessments of groundwater quality. Local government data from the League of Women Voters are accessed as needed. Drinking Water Program: The location of wells and surface water sources serving Public Water Supplies is maintained on a GIS coverage. WHPAs as defined in regulation and from local programs are also on a GIS coverage. Local WHP program data are maintained on computer databases. Other data are utilized as they are made available, such as the results of the County Water Supply / Wellhead Protection Grants. This information is made available to the field offices through a GIS. Information from other programs on potential sources of contamination that are related to geographic location may be available. Any such information is used to assess water supply well vulnerability and to prioritize assistance and support of local WHP Programs. Land Recycling and Waste Management/Environmental Cleanup Programs: The Hazardous Sites Cleanup Program uses relevant data from all available sources for specific site cleanups. The CERCLA Program uses relevant data from the site specific investigations. The Land Recycling Program uses data provided by the persons conducting the characterization and cleanup. This data includes paper reports, files, and computer files. Municipal/Residual Waste Programs may occasionally use federal or local program data, but typically data are generated within the required self-monitoring program of the operators. The Hazardous Waste program uses data provided by facilities for compliance purposes. These data are maintained in paper files, reports, and computer files. Storage Tank Program: Relevant data are shared from periodic EPA inspections of underground storage tank facilities in Pennsylvania. Mining Program: The mining program routinely coordinates with the Water Supply Management Program regarding the identity and location of public water supply systems. Oil and Gas Program: Underground Injection information is shared with the Underground Injection Control (UIC) Program at EPA Region III. 383-2000-030 / October 1, 1998 / Page 74 Nonpoint Source Program: There is a very strong working relationship with county conservation districts, the River Basin Commissions, and the USGS. The county conservation districts routinely provide data and expertise to DEP and the State Conservation Commission concerning local issues. PA Geologic Survey: The USGS databases (GWSI and Qwdata), publications, and geologic, mineral resource and mapping information are used extensively by DEP programs. Also, numerous cooperative projects have been conducted between the federal and state geologic surveys, and other state agencies. Citizen Monitoring Program: The recently established Citizen Monitoring Program in DEP will develop criteria for data collection, provide training, and serve as a liaison between the various programs in DEP and watershed associations, citizen monitoring groups, and other local groups. Once this program is implemented, the various programs will have access to various groups who can help collect needed data and set priorities. PA Department of Agriculture: PDA uses relevant data from other state and federal programs, including the USGS. 5.3 Data Elements Defined The use of EPA’s Minimum Set of Data Elements is being promoted as applicable for all program specific areas. In addition, the DEP Office of Management and Technical Services is developing a department-wide locational data policy for facilities, sites, and observation points. This policy will be used in conjunction with the GIS developments, and will be consistent with guidance in EPA’s Minimum Set of Data Elements. Groundwater Quality Program: The Ambient and Fixed Station Network Groundwater Monitoring programs are implemented consistent with EPA’s guidelines for minimum standards for data elements. Drinking Water Program: During the conversion of the SAS database and creation of GIS coverages and metadata, EPA’s minimum set of data elements will be followed where practical. Waste Management/Environmental Cleanup Program: Geographic, well, and sample descriptors are implemented consistent with EPA’s Minimum Set of Data Elements. Mining Program: DEP’s FIX project is intended to allow programs within DEP to exchange data on regulated activities and water resources. Oil and Gas Program: Data are collected consistent with the minimum set of data elements to the extent that resources allow (items 1-8 and 11-14 from EPA 813/B-92-002). The program will be using the standard data definitions formed from the FIX initiative. Much of the data have been digitized for GIS capabilities. Part of the well log information is stored in the Bureau of Topographic and Geologic Survey’s Water Well Inventory System. 383-2000-030 / October 1, 1998 / Page 75 Nonpoint Source Pollution Program: Most information exchange and data sharing within the Bureau of Watershed Conservation are done through the conservation districts. This includes various brochures, fact sheets, training sessions, workshops, etc. targeted to appropriate audiences. The Bureau has defined sufficient data elements to track progress of the various programs, and these data are available to anyone interested in reviewing it. PA Geologic Survey: To a large degree, the methods used for data collection and storage are based on USGS standards. The Survey collects and stores water quality data, well construction, location, production, precipitation, and stream flow information. PA Department of Agriculture: The Pennsylvania Department of Agriculture has established the following data elements for groundwater quality: 1. 2. 3. General Descriptor (describes where the well information is maintained): All information will be maintained in a database developed by DEP. Geographic Descriptors (latitude/longitude coordinates): All locations (groundwater monitoring points) will be located and identified with latitude /longitude coordinates, reported in degrees, minutes and seconds, and accurate to + 50 feet. A GPS unit or a 7.5 minute USGS topographic map will be used to determine all coordinates. Well Descriptor (describes various features of a well or spring): Each well will have an assigned numeric identifier. In addition, well use will be recorded at the time of sampling. Well construction data will be recorded when available, generally from the driller’s records that are submitted to the Bureau of Topographic and Geologic Survey. 5.4 QA/QC for State Monitoring Programs All regulatory programs have requirements for monitoring for a variety of purposes, and have QA/QC protocols in place. The Groundwater Monitoring Guidance Manual lists basic requirements for a QA/QC plan. Groundwater Quality Program: The Groundwater Monitoring Program has an EPA approved QA/QC Plan. Drinking Water Program: The groundwater monitoring performed under the Safe Drinking Water Act Program is primarily compliance monitoring conducted by the water supplier and is taken after any required treatment. The drinking water program has an approved QA/QC plan. Storage Tank Program: Ambient and compliance monitoring is not routinely conducted at operational storage tank facilities. Implementation of a remedial action plan may require assessment and remediation monitoring. Corrective action regulations require one year of “post closure monitoring” upon completion of remediation. The site characterization report and the remedial action plan required by the corrective action regulations are required to have a QA/QC Plan. Land Recycling and Waste Management/Environmental Cleanup Programs: The Hazardous Sites Cleanup Program and CERCLA Program conduct groundwater monitoring related to 383-2000-030 / October 1, 1998 / Page 76 assessment, remediation, and post-remediation monitoring. They all have QA/QC Plans. For the Land Recycling Program, no prior approvals are required for background or statewide standards for remediation activities under Act 2 of 1995. QA/QC plans are developed and implemented for each specific case, as required. The Municipal/Residual/Hazardous Waste Management Programs have QA/QC Plans in cooperation with the Bureau of Laboratories. In the Hazardous Waste Management Program monitoring is conducted to establish baseline conditions at a site and to ensure compliance. Upon closure of certain types of facilities monitoring is routinely required as part of the post-closure care of the facility. Monitoring at these facilities would include provisions for QA/QC procedures. Mining Program: The mining program has an established QA/QC program with the DEP Bureau of Laboratories. This covers all types of water monitoring which the program carries out. Oil and Gas Program: Samples are collected in accordance with procedures established by the Bureau of Laboratories. Water wells are sampled in response to complaints related to oil and gas well exploration or production. Sites using wetlands treatment of produced water discharges are monitored by the Bureau of Oil and Gas Management. A project has been developed to construct and monitor wetland treatment of produced water. The Bureau has conducted a project to monitor ground and surface water impacts from the road spreading of production water from oil and gas wells on secondary dirt roads for dust suppression. Radiation Protection Program: QA/QC programs are in place for ambient surface and drinking water monitoring programs around power plants and other facilities. The analytical labs participate in the EPA Laboratory Cross Check program, which is the accepted standard for radiation labs. Nonpoint Source Program: The Susquehanna River Basin Commission maintains a network of monitoring stations in the Susquehanna River drainage basin to document trends in water quality in the basin. It is hoped that improvements in nutrient and sediment content will be detected and attributed to the implementation of management measures by the Chesapeake Bay Program. The Interstate Commission for the Potomac River Basin maintains two stations for the same purpose on the Potomac River. These monitoring activities are conducted in accordance with EPA approved QA/QC plans. Many of the Section 319 projects have monitoring components. This monitoring is intended to document improvements in water quality attributed to the implementation of various measures identified in project workplans. All monitoring activities must have an approved QA/QC plan before beginning. The Chapter 6217 Coastal Nonpoint Program will have to develop a monitoring program as part of the implementation plan. Monitoring will be required to document the successful implementation and maintenance of the management measures, as well as improvements in water quality. 383-2000-030 / October 1, 1998 / Page 77 PA Department of Agriculture: The type of monitoring being developed by the PDA is related to pesticides in groundwater from nonpoint pollution sources. This monitoring program could be classified as ambient (background) and possibly compliance. If detections of pesticides are noted from water sample analysis, a remediation type monitoring program could be initiated to supplement BMPs. The QA/QC plan for the vulnerability assessment is nearly complete. This plan will be consistent with those practiced by other EPA-certified agencies, including DEP. 383-2000-030 / October 1, 1998 / Page 78 6. STRATEGIC ACTIVITY 6: IMPROVING PUBLIC EDUCATION AND PARTICIPATION 6.1 Public Participation Is Equivalent to EPA’s in 40CFR Part 25. With input from the Citizens Advisory Council, DEP has revised its public participation procedures. One of the primary objectives is to improve public access to information and decision-making in DEP. As stated in the policy, all regulations and technical guidance documents should be developed with effective involvement from the public. As part of DEP’s “PRIME” (Privatize, Retain, Innovate, Modify and Eliminate) initiative, all program guidance documents have been placed on DEP’s website. The CSGWPP has undergone public participation based on the final procedures established through the Citizens Advisory Committee. The CSGWPP was presented to advisory committees that have a stake in the CSGWPP. This included the Water Resources Advisory Committee and the Agricultural Advisory Board. Public participation methods employed by groundwater protection programs are discussed below. Groundwater and Surface Water Quality Programs: Public participation is carried out in accordance with provisions of 40 CFR Part 25 (i.e. public meetings, public hearings, advisory groups, responsiveness summaries, etc.). Drinking Water Program: Public participation is provided through the Technical Assistance Center Advisory Board and other standing advisory committees such as the Citizens Advisory Council, Air and Water Resources Advisory Committee, and the Nutrient Management Advisory Committee. Storage Tank Program: For corrective actions conducted by the responsible party, the responsible party must notify the local municipality in writing of the confirmation of any reportable release within 15 days of the occurrence. For state lead correction actions, DEP, prior to conducting and terminating corrective action, will notify the local government and public directly affected, allow the local government and public sufficient time to comment, and hold a public meeting if there is sufficient interest. Land Recycling and Waste Management/Environmental Cleanup Programs: The Municipal/Residual/Hazardous Waste Management Programs invite the public to participate and provide comments at Regional Roundtables. These Regional Roundtables provide a forum for a wide range of environmental issues and topics, including groundwater protection and remediation. Municipalities are copied on correspondence to parties responsible for groundwater pollution incidents. In accordance with municipal, residual, and hazardous waste regulations, Community Relations Coordinators (CRCs) facilitate public comment activities for permit applications, site cleanup plans, permit modifications and closure plans prior to their occurrence. For the Land Recycling Program, public participation is carried out in accordance with provisions mandated by Act 2. Also, the Cleanup Standards Scientific Advisory Board was instrumental in setting statewide health standards under Act 2. In the CERCLA Program, a Community Relations Plan is in place to keep the public informed of the progress of the work at NPL sites. A public repository for the public documents (workplans, etc.) for the project is 383-2000-030 / October 1, 1998 / Page 79 located in a public building in the municipality. The Hazardous Sites Cleanup Program holds open meetings with municipalities in which the public is invited, and a repository for public documents is available at the municipal building (i.e. library, court house, etc.). Mining Program: Public participation occurs during the normal permitting process, during review of significant amendments to the permit, and when bond releases are being requested in conjunction with reclamation work. At the time of filing an application for a permit, the applicant is required to place an advertisement in a local newspaper of general circulation in the locality of the proposed coal mining activities at least once a week for four consecutive weeks. They must also file a complete copy of the application for the public to copy and inspect at a public office approved by DEP. The Bureau of Mining and Reclamation must publish notice of the proposed activities in the Pennsylvania Bulletin. DEP sends notices to the city, borough, incorporated town, or township where the activities are located; sewage and water treatment authorities and water companies that may be affected by the activities; and government planning agencies responsible for land use, air quality, or water quality planning. Public participation also drives the Lands Unsuitable for Mining petition process, which is integrated into the mining program. The program also is conducting a customer needs study, which involves significant public participation. Oil and Gas Program: All public participation is done through the Technical Advisory Board whose meetings are open to the public. Also, the Oil and Gas Act provides an opportunity for a conference for anyone having a direct interest in oil and gas matters. Radiation Protection Program: There is major public participation in the Low Level Radioactive Waste Program at advisory committee meetings. Statewide public meetings have been held at each step in the process. The public process gets more intensive when potential sites are identified and detailed characterization begins. Nonpoint Source and Nutrient Management Programs: Most public participation is accomplished through the county conservation districts. However, the program has solicited public participation for various specific purposes, including: 1) public meetings and comment review periods were held as the Chesapeake Bay Nutrient Reduction Strategy was being drafted, 2) the Bureau was part of the public participation process as the Comprehensive Conservation Management Plan was developed for the Delaware Estuary Program (This program will continue with various outreach efforts and public meetings as the plan is finalized and implemented.), 3) the Section 319 Nonpoint Source Program solicits public input in the project development process for each grant, and 4) public meetings and hearings were held to review the regulations for the Nutrient Management Act. The regulations also were published in the Pennsylvania Bulletin. In addition, any revisions to the Nonpoint Source State Management Plan or the Nonpoint Source Degraded Watershed List are submitted for public review and comment through publication in the Pennsylvania Bulletin. A Liaison Committee is being created to rewrite the State Assessment Report and Management Plan. Members of this group will include representatives of most of the local, state, and federal agencies involved in nonpoint source issues. 383-2000-030 / October 1, 1998 / Page 80 PA Geologic Survey: An advisory committee recently provided input to the Bureau on the overall direction of the Groundwater Resources Division, and on the goal and structure of individual projects. This committee was composed of representatives of academia, consultants, and DEP. PA Department of Agriculture: Notification for public participation will be requested through publication in the Pennsylvania Bulletin. Other notification will occur in papers, journals and newsletters as dictated by standard state protocol for public policy announcements. The Department of Agriculture will make information on the State Management Plan for pesticides available to the news media through public news bulletins available to all media services. Letters of notification will be sent to all major agricultural organizations within the state to provide opportunity for comment. A subsequent period of 60 days will be provided for the receipt of written comments on the Pesticides and Ground Water Strategy. Public participation will be initiated through the public outreach to all sectors of the regulated community and the general public. Information on detections will be reported to domestic well owners and users as described in Section 4.4. Public water supply systems will be under the purview of the DEP as required under the SDWA. Detections of pesticides within an aquifer will be announced to the public when monitoring programs identify concentrations of concern. Information will be provided to the public on specific chemicals detected in these monitoring programs along with technical information on human health considerations using the one-page health advisories currently available from EPA. 6.2 Public Education Program for CSGWPP Issues DEP has numerous methods by which the various programs actively implement public education efforts. The specifics for each program, which will be utilized in promoting and informing the public on the CSGWPP process are described in the following paragraphs. All programs are participating in DEP’s Internet site. Program descriptions, guidance documents, fact sheets, etc. are included for all programs. Technical Advisory Committees: The CSGWPP was presented to advisory committees that have a stake in the CSGWPP. This included the Water Resources Advisory Committee and the Agricultural Advisory Board. Groundwater Quality Program: Public education is accomplished through fact sheets, educational publications, active participation in educational forums and projects such as the state and national Envirothon Competition, the Pennsylvania Groundwater Policy Education Project, and the Water Resources Education Network. Drinking Water Program: Numerous meetings have been held and will continue to be held with state municipal organizations, water supplier organizations, planning groups, and local citizen groups to raise public awareness and promote the concept of wellhead protection. 383-2000-030 / October 1, 1998 / Page 81 Storage Tank Program: Fact sheets have been developed for all aspects of the storage tank program. The Storage Tank Monitor is published quarterly and is readily available for public distribution. Land Recycling and Waste Management/Environmental Cleanup Programs: The Bureau of Land Recycling and Waste Management supplies fact sheets on groundwater protection to the public upon request. Also, the Pennsylvania Bulletin is sent to individuals upon request so that they may keep informed of DEP actions. In the Hazardous Sites Cleanup Program, public education is accomplished through fact sheets, press releases, Citizen Roundtable Meetings, and surveys. In the Land Recycling Program, with the passage of Act 2, there was an extensive effort to get accurate information out to the public. Paid advertisements in nationally distributed publications were used to inform the public of the program. A technical manual on the Land Recycling Program was developed (and later revised) along with numerous brochures and fact sheets on the program. Public meetings were held throughout the state describing the program. Workshops on the program continue to be held for the public. Mining Program: Public education is accomplished through fact sheets, brochures, and informational and educational public meetings that are held periodically. Oil and Gas Program: Public education is accomplished through fact sheets and on-site programs between Oil and Gas Inspectors, Water Quality Specialists, and the landowners. Nonpoint Source Program: Most public education activities are completed through the county conservation districts, which hold various training sessions, workshops, etc. that are relevant to the issues in their county. Information on the CSGWPP may be distributed to the general public via the county conservation districts. Additional activities have begun with local watershed organizations in the past few years. In addition, presentations and interaction on the CSGWPP may be conducted through the quarterly Pennsylvania Association for Conservation District Executive Council Meetings. Public input has been identified as a priority for the development of the DEP Nonpoint Source Strategy. Public comment and input were solicited through a questionnaire, a statewide NPS conference, and review process. Through contracts with the Pennsylvania Association of Conservation Districts and the League of Women Voters, additional education and outreach efforts will be implemented. These two agencies will be generating various brochures, videos, etc. for describing nonpoint source issues. They also will be holding workshops and awarding mini-grants for local groups to address nonpoint source and water resource issues. Nutrient Management Program: The Nutrient Management Program will give high priority to providing education to owners of livestock operations to prevent pollution by nutrients. PA Geologic Survey: A major component of the Bureau of Topographic and Geologic Survey programs is public education. Technical publications contain information on geology and 383-2000-030 / October 1, 1998 / Page 82 hydrogeology of Pennsylvania that is useful to environmental educators, consultants, regulators, and other groups. PA Department of Agriculture: Public education is addressed through the Agriculture Department's inspection staff, the County Conservation Service and Penn State Cooperative Extension. Each office promotes groundwater protection through various training sessions, meetings and participation in educational programs. 6.3 Outreach Mechanisms All groundwater regulatory programs have mechanisms in place for interprogram and federal and local information exchange. These are utilized in disseminating information on the CSGWPP. In addition, rules and regulations are available upon request for all DEP programs. All DEP programs are using DEP’s Internet site for public education and information dissemination. The Pennsylvania Geologic Survey and the Pennsylvania Department of Agriculture also provide information on a website. DEP technical guidance manuals are available on the Internet. Drinking Water Program: The NewsSplash is a newsletter published quarterly for the water suppliers and the public to advise them of new programs, program changes, available support and assistance including news on the state WHP program. This is published by the Technical Assistance Center. Other publications include the Citizens Guide to Volatile Synthetic Organisms in Drinking Water, the Citizens Guide to Home Drinking Water Treatment Devices, and numerous fact sheets and brochures. The Groundwater Program actively participates in the Pennsylvania Groundwater Policy Education Project, the Water Resources Education Network and numerous presentations to the public and regulated community. Storage Tanks Program: The program newsletter, Storage Tank Monitor, and numerous fact sheets are available upon request. The program is represented at numerous trade shows throughout the state. Land Recycling and Waste Management/Environmental Cleanup Programs: Speakers are provided upon request to participate at job fairs, technical expositions, and Earth Day programs. All files related to the program are open to the public upon request. Numerous informative public meetings were held throughout the state on the Act 2 program. DEP staff participate with EPA in public meetings on CERCLA. Mining Program: Case files are open to the public upon request. As noted in the 1998 annual workplan agreement between the U.S. Department of the Interior’s Office of Surface Mining (OSM) and DEP, public input is a critical aspect of the OSM oversight process. DEP and OSM oversight planning “necessitates outreach to citizens, environmental groups, local governments, other State and Federal Agencies, the coal industry, consultants, and other public interest groups.” Oil and Gas Program: Information is provided to responsible and interested parties through distribution of the program rules and regulations. 383-2000-030 / October 1, 1998 / Page 83 Nonpoint Source Program: The Citizen Monitoring Coordinator funded by the Section 319 Nonpoint Source Program will have the capability through the various monitoring groups and watershed associations to collect and distribute monitoring data to the public. In addition, as described above, information can be disseminated through county conservation districts. PA Geologic Survey: The Bureau of Topographic and Geologic Survey has developed numerous technical publications that contain information on the geology and hydrogeology of Pennsylvania. In addition, hundreds of individual questions and requests for services are answered every year. Some of the requests may require very technical answers, while other may require providing a general ‘lesson’ in geology or hydrogeology to a concerned citizen with little or no background in geology. In addition, the Bureau publishes a quarterly magazine entitled Pennsylvania Geology, which is available to the public free of charge. Public speakers are available to talk about geology, hydrogeology, and other related environmental issues to schools and youth groups such as the Girl Scouts and Boy Scouts. Basic data collected by the BTGS are available to anyone upon request. PA Department of Agriculture: Information on detections is reported to domestic well owners and users as stated in Section 6.1. If detections are present in public water supplies, the municipality and BWSM are notified (also described in Section 4.4). 6.4 Public Education Programs The following public education forums are employed by the various programs dealing with groundwater: Water Resources Education Network (WREN): The League of Women Voters established this new network, which is represented by numerous state agencies, local government officials, private citizens, and special interest groups. WREN is a nonpartisan informal collaboration among organizations and public officials working for the protection and management of Pennsylvania’s water resources, both surface and groundwater, through education and informed policy making. The goals of the network are to convene and support local stakeholder communities that will educate themselves, other citizens, and local officials about their water resources and the public policies necessary to protect them; to facilitate water resources education in schools; to exchange information among its members about activities and resources relating to water resources in Pennsylvania; to enhance coordination and cooperation between its members; to make water resources protection a priority at the state and local level; and to make recommendations about meeting needs for future education needs on water resources. W.K. Kellogg Foundation Funded Projects: The Pennsylvania Groundwater Policy Education Project (PA-GPEP) is a partnership between the League of Women Voters -Citizen Education Fund and Penn State Cooperative Extension, and is funded in part by a grant from the W.K. Kellogg Foundation. PA-GPEP produced the publication GROUNDWATER: A Primer for Pennsylvanians, which is a basic guide for citizens, the Groundwater Policy Education Reports, and A Groundwater Protection and Management Handbook for Local Officials in Pennsylvania. They also publish a bimonthly newsletter, Groundwater Policy News, which is currently distributed to 3,100 individuals in Pennsylvania. In addition, the project has sponsored twelve 383-2000-030 / October 1, 1998 / Page 84 local groundwater policy education projects around the state to help improve citizen participation in decision making about groundwater issues. Fact Sheets: DEP has written several fact sheets related to groundwater quality protection. In addition, Penn State University has developed a series of fact sheets on groundwater protection. Groundwater Quality Program: The Bureau of Water Supply Management participates in the Pennsylvania Groundwater Policy Education Project and the Water Resources Education Network, which were described previously. DEP has also participated in the ENVIROTHON program, which is an environmental competition for high school students. Numerous educational fact sheets and booklets are available, including the Sandcastle Moats and Petunia Bed Holes booklet about groundwater for junior high school students. DEP provides speakers for educational forums and has provided funding for educational projects. The Ground Source Heat Pump (GSHP) Manual was developed as a proactive, educational measure to prevent groundwater contamination by the growing ground source heat pump industry. The manual considers the environmental aspects of GSHP systems. It also provides guidance to the industry, homeowners, and installers of GSHPs on proper installation and operation of the systems. Drinking Water Program: The Bureau of Water Supply Management has supported or sponsored dozens of meetings at the local, regional and state level to raise public awareness and promote the concept of WHP. These meetings include most of the state’s municipal organizations, water supplier associations, planning groups, the League of Women Voters and local citizens groups. Since 1994, the bureau has worked with PennDOT, the Pennsylvania Rural Water Association (PRWA), the Pennsylvania Emergency Management Agency (PEMA), and the LWV to design and make available to local municipalities a road sign to alert the public when they enter a public water supply area. The bureau has sponsored or supported workshops with EPA, PRWA and local citizens coalitions across the state for water suppliers, municipal officials and citizens groups on how to develop and implement a local WHP program. The existence of the local citizens coalitions was facilitated by the Groundwater Policy Education Project, which is now continuing these small grants in cooperation with the bureau and EPA to promote local education and debate on local WHP programs. In addition to bureau staff making presentations on WHP, each DEP regional office has been given a complete set of slides and teaching guides to conduct regional WHP workshops. Private water supplies are not regulated by DEP; however, technical assistance is offered by the regional BWSM staff. In addition, private water supply owners can obtain a coliform bacterial sampling kit from DEP for $10. The kit includes a sample bottle, envelope and instructions on taking a bacteriological water sample and returning the sample to the DEP Bureau of Laboratories. The lab will return the results of the analysis to the owner along with an explanation of results. Storage Tank Program: Program staff have conducted numerous seminars and public speaking engagements at the request of the regulated community. They participate in a number of trade shows and conduct training seminars on leak detection and closure for owners and operators of storage tanks. Regional offices conduct “consultant’s days” to explain program regulations, 383-2000-030 / October 1, 1998 / Page 85 policies and procedures to consultants and contractors working for responsible parties in response to program requirements. Land Recycling and Waste Management/Environmental Cleanup Programs: The Bureau of Land Recycling and Waste Management provides guidance on prevention of groundwater contamination to interested citizens groups and consultants upon request. This includes general geology, well construction, septic tank management, and monitoring protocols. The Bureau holds public forums to present and discuss any new regulations or policies. Numerous fact sheets are available to the public. The Land Recycling Program has developed numerous fact sheets describing the program and participates in numerous informational speaking engagements and conferences. The CERCLA Program maintains a National Priority List of sites in Pennsylvania that is made available to the public. In an annual report to the Governor, the Hazardous Sites Cleanup Program summarizes the progress of these sites. This report is available to the public. Mining Program: Public meetings are held when requested. Policies and fact sheets are available on the DEP website. The Comprehensive Plan for Abandoned Mine Reclamation was developed with public input. One of the guiding principles of this plan is to form partnerships with watershed associations, local governments, environmental groups, other state agencies, federal agencies, other groups organized to reclaim abandoned mine lands. Nonpoint Source Program: EPA has encouraged the state to develop a Farm-A-Syst program in cooperation with the Extension Service, the Natural Resources Conservation Service, and EPA. The development of a Farm-A-Syst package has been done for the Pequea/Mill Creek Initiative. Another concept completed by the Pennsylvania Association of Conservation Districts and the Natural Resources Conservation Service is the development of One Plan for a landowner. One Plan identifies all the resource management activities that should be done to protect the resources on a farm. This would include a nutrient management plan, a conservation plan, and any other issues the landowner wants to see addressed. Both the One Plan and the Farm-A-Syst package can be used as a public education program for the CSGWPP. With funding from the Section 319 Nonpoint Source Program, the scope of the Chesapeake Bay Education Office has been expanded to include education outreach activities in the rest of the state. This office is maintained by the Pennsylvania Association of Conservation Districts. Additional funding will be awarded to the League of Women Voters to continue components of WREN, as described at the beginning of this section. Nutrient Management Program: Under the Nutrient Management program, nutrient management plans and plan amendments have to be developed by Nutrient Management Specialists certified in accordance with the Pennsylvania Department of Agriculture requirements. The Department of Agriculture has compiled a list of certified Nutrient Management Specialists that can assist farmers in writing nutrient management plans. Pennsylvania Geologic Survey: The Bureau has speakers who are available to speak on general geology, hydrogeology, and related environmental issues to schools, girl and boy scout troops, 383-2000-030 / October 1, 1998 / Page 86 and any other interested group. They also publish and distribute numerous education booklets and brochures which are available free of charge. The basic data collected by the Bureau are also available to the public upon request. PA Department of Agriculture: Public education projects and activities will be developed when EPA identifies five pesticides which will be subject to approved State Management Plans as a condition of legal sale and use. USGS: The USGS has developed a colorful series of water resource education posters which are available in grade school or middle school editions. Call 1-800-426-9000. The USGS has written numerous educational publications on groundwater and geology. EPA Water Resource Center: EPA provides copies of technical and public information developed by EPA’s Office Water at no cost. Call 202-260-7786. 383-2000-030 / October 1, 1998 / Page 87 APPENDIX 2 THE SIX STRATEGIC ACTIVITIES AND THEIR ADEQUACY CRITERIA This appendix lists the specific adequacy criteria under each of the six Strategic Activities for both a Core and a Fully-Integrating CSGWPP. The language in bold print indicates the specific differences between the criteria at the Core level and the Fully-Integrating level. (From pages 2-5 through 2-17 of EPA’s Final Comprehensive State Ground Water Protection Program Guidance) EPA 100-R-93-001 December 1992 383-2000-030 / October 1, 1998 / Page 88 STRATEGIC ACTIVITY 1 ESTABLISHING A GROUND WATER PROTECTION GOAL TO GUIDE ALL RELEVANT PROGRAMS IN THE STATE FULLY-INTEGRATING ADEQUACY CRITERIA CORE ADEQUACY CRITERIA 1. A State ground water protection goal is established through adequate public participation. 1. Same 2. The State’s ground water protection goal is: No less protective than EPA’s overall ground water protection goal of preventing adverse effects to human health and the environment and protecting the environmental integrity of the nation’s ground water resources. Integrated with its other water quality and environmental goals. 2. Same 3. The State’s ground water protection goal guides all federal, State and local ground water related programs operating within the State which address potential sources of contamination, including federally unregulated sources. 3. The State’s ground water protection goal guides at least one key state ground water-related program ADDITIONAL FACTORS TO BE CONSIDERED 1. The State is encouraged to incorporate water supply goals and objectives, including support of valuable ecological systems and other beneficial uses, into its ground water protection goal. 383-2000-030 / October 1, 1998 / Page 89 STRATEGIC ACTIVITY 2 ESTABLISHING PRIORITIES, BASED ON CHARACTERIZATION OF THE RESOURCE, IDENTIFICATION OF SOURCES OF CONTAMINATION, AND PROGRAMMATIC NEEDS, TO DIRECT ALL RELEVANT PROGRAMS AND ACTIVITIES IN THE STATES TOWARD THE MOST EFFICIENT AND EFFECTIVE MEANS OF ACHIEVING THE STATE’S PROTECTION GOAL FULLY-INTEGRATING ADEQUACY CRITERIA 1. The State has established basic definitions and approaches for a coherent priority-setting process and is applying them in a consistent manner across all federal, State, and local ground water related programs operating within the State. 2. A State ground water priority-setting process is based on sufficient consideration of varying ground water characteristics, Such as but not limited to those in Figure 1 3. The State has sufficient contamination source inventories and assessments to support its process for identifying all significant potential sources of contamination (including federally unregulated sources) and to consistently determine its ground water protection priorities based on the relative threat of these sources to the resource. CORE ADEQUACY CRITERIA 1. The State has established basic definitions and approaches for a coherent priority-setting process and is applying them in at least one key ground water related program. 2. A State ground water priority-setting process is based primarily on consideration of varying ground water characteristics, such as but not limited to those in Figure 1 3. The State is systematically implementing a plan to add to its contamination source inventories and assessments to support its process for identifying all significant potential sources of contamination (including federally unregulated sources) and to consistently determine its ground water protection priorities based on the relative threat of the sources to the resource. 4. The State has sufficient technical capabilities to support its priority-setting process and determinations. 4. The State is systematically implementing a plan to further develop its technical capabilities to support its prioritysetting process and determinations. 5. The State has formally adopted measures of ground water protection (e.g. performance standards, quality standards, reference points, etc), which are sufficient to support consistent priority setting and the measurement of progress. 5. The State is systematically implementing a plan to formally adopt measures of ground water protection (e.g. performance standards, reference points, etc.) to support consistent program priority setting and the measurement of progress. 383-2000-030 / October 1, 1998 / Page 90 FULLY-INTEGRATING ADEQUACY CRITERIA CORE ADEQUACY CRITERIA 6. Same 6. Protecting public water supplies is among the State’s highest priorities and controlling sources in wellhead protection and recharge areas and basins of drinking water is a priority. 7. The State is coordinating its ground water 7. The State is sufficiently coordinating its protection priorities under its Core ground water protection priorities with its CSGWPP with its surface water quality and surface water quality and other other environmental priorities. environmental priorities. 8. State priorities incorporate and support a 8. State priorities sufficiently incorporate process of ongoing review and improvement and support a process of ongoing review and of the six strategic activities of the State’s improvement of the six strategic activities of CSGWPP. the State’s CSGWPP. ADDITIONAL FACTORS TO BE CONSIDERED 1. For stability, the State is encouraged to make its priorities long-term in nature and change them only in the face of compelling new information or needs. 2. The State is encouraged to include in its ground water characterization effort: - Detailed mapping and assessment to address the State’s highest priority needs at an appropriate scale as determined by a coordinated State effort; - A comprehensive well inventory that includes private and municipal production wells, monitoring and test wells, and injection wells; and - A system for utilizing and integrating State and federal (e.g., USGS, USDA, SCS) ground water assessment and mapping programs. 3. The State is encouraged to have its formally adopted measures of ground water protection include an integrated set of direct measures such as MCLs, State water quality standards, and indirect measures such as BMPs, technology standards, siting criteria, and construction standards. 383-2000-030 / October 1, 1998 / Page 91 4. The State is encouraged to consider deployment of new and alternative technologies for improved pollution prevention as a priority. 383-2000-030 / October 1, 1998 / Page 92 STRATEGIC ACTIVITY 3 DEFINING AUTHORITIES, ROLES, RESPONSIBILITIES, RESOURCES, AND COORDINATING MECHANISMS ACROSS RELEVANT FEDERAL, STATE, TRIBAL, AND LOCAL PROGRAMS FOR ADDRESSING IDENTIFIED GROUND WATER PROTECTION PRIORITIES FULLY-INTEGRATING ADEQUACY CRITERIA CORE ADEQUACY CRITERIA 1. All agencies and programs responsible for addressing the State’s priorities are identified and a primary point of contact (e.g. lead agency, coordinating committee, governor’s staff, etc.) with EPA is established for the development and implementation of CSGWPPs across all involved agencies. 1. Same 2. A coordinating mechanism is operating that includes all State agencies and programs with ground water protection responsibilities and all programs’ expertise is brought to bear on the State’s ground water protection priorities. 2. A coordinating mechanism is operating that includes all State agencies and programs with ground water protection responsibilities and more than one program’s expertise is brought to bear on the State’s ground water priorities. 3. Sufficient legal authorities and resources are available to address the State’s ground water protection needs, requirements and priorities under its CSGWPP. 3. Legal authorities and resources are available to address the State’s ground water protection needs, requirements and priorities under its Core CSGWPP, and the State has identified the gaps in authorities and resources for achieving a fully-integrating CSGWPP. 4. Relevant federal agencies, operating within the State, are sufficiently consulted in the development and implementation of the CSGWPP. 4. Relevant federal agencies, operating within the State, are notified of and given the opportunity to comment on the State’s decisions in the development and implementation of the Core CSGWPP. 5. Neighboring Tribal officials and States sufficiently consult each other in the development and implementation of their joint or independent CSGWPPs. 5. Neighboring Tribal officials and States consult each other in the development and implementation of their joint or independent CSGWPPs. 6. The State has established capabilities and mechanisms for inter-State coordination of ground water protection issues. 6. Same 383-2000-030 / October 1, 1998 / Page 93 FULLY-INTEGRATING ADEQUACY CRITERIA 7. Local governments are sufficiently included in the development and implementation of the CSGWPP and the State is sufficiently implementing coordination, guidance, or oversight mechanisms where local governments have authorization to address State ground waterrelated objectives and priorities. CORE ADEQUACY CRITERIA State’s decisions in the development and implementation of the Core CSGWPP. 7. Local governments are notified of and provided opportunity to comment on the ADDITIONAL FACTORS TO BE CONSIDERED 1. The State is encouraged to adopt a coordinating mechanism that is capable of influencing the movement of human and financial resources to target joint efforts valuable to more than one State program. 2. The State is encouraged to provide a field management presence for ground water of priority concern either by supporting local government efforts to protect ground water or establishing special districts, boards, or other similar institutional arrangements. 3. The State is encouraged to consider assessing fees for various activities that pose potential threats to ground water to augment funds for prevention of ground water contamination as well as for remediation activities. 383-2000-030 / October 1, 1998 / Page 94 STRATEGIC ACTIVITY 4 MPLEMENTING ALL NECESSARY EFFORTS TO ACCOMPLISH THE STATE’S GROUND WATER PROTECTION GOAL CONSISTENT WITH THE STATE’S PRIORITIES AND SCHEDULES FULLY-INTEGRATING ADEQUACY CRITERIA CORE ADEQUACY CRITERIA Prevention of Contamination Prevention of Contamination 1. Programs with measurable objectives aimed at prevention and control of contamination are being implemented to the degree sufficient for attaining the State’s ground water protection goal and addressing the priorities of the State’s -CSGWPP 1. Programs with measurable objectives aimed at prevention and control of contamination are being implemented to address the priorities of the State’s Core CSGWPP 2. For site-specific or area-specific prevention measures, characterization and assessment of the ground water resource’s vulnerability and, where appropriate, the ground water’s use and value, sufficiently support rational decisionmaking. 2. For site-specific or area-specific prevention measures, characterization and assessment of the ground water resource’s vulnerability and, where appropriate, the ground water use and value, support rational decision-making. - Definitions and approaches for ground water characterization and vulnerability assessment are applied in a consistent manner Same - Factors considered include intrinsic sensitivity, geologic/hydrogeologic settings and potential sources of contamination; when necessary, other ground water characteristics, such as, but not limited to those listed in Figure 1 are considered Same - The State has sufficient technical capabilities to support its decision making The State is systematically implementing a plan to further develop its technical capabilities to support its decision making 383-2000-030 / October 1, 1998 / Page 95 FULLY-INTEGRATING ADEQUACY CRITERIA CORE ADEQUACY CRITERIA 3. The State is sufficiently implementing an EPA approved wellhead protection program (as called for under section 1428 of the SDWA). (Required). 3. (Optional) 4. The State is sufficiently carrying out across all programs an integrated strategy to: 4. The State is carrying out in at least one key program an integrated strategy to: - implement a variety of prevention measures in the absence of actual detection of contamination; - Same - Implement additional controls necessary if contamination is detected or increasing towards a concentration considered as a reference point for the State’s protection goal; and - Take immediate action to prevent further contamination if contamination has reached or exceeded a concentration considered as a reference point for the State’s protection goal. Remediation and Facility Siting … 5. Programs with measurable objectives aimed at remediating ground water contamination are being implemented to the degree sufficient for attaining the State’s ground water protection goal and addressing the priorities of the State’s CSGWPP. 6. For site-specific remediation measures and facility siting, characterization and assessment based on the use, value and vulnerability of the ground water resource sufficiently support rational decision-making. - Definitions and approaches for ground water characterization and assessment are applied in a consistent manner. - Ground water characteristics such as, but not limited to, those listed in Figure 1 are considered. - The State has sufficient technical capabilities to support its decision-making. - Same - Same Remediation and Facility Siting 5. Programs with measurable objectives aimed at remediating ground water contamination are being implemented to address the priorities of the State’s Core-CSGWPP. 6. For site-specific remediation measures and facility siting, characterization and assessment based on the use, value and vulnerability of the ground water resource support rational decisionmaking. - Same - Same 383-2000-030 / October 1, 1998 / Page 96 to support its decision making. - The State is systematically implementing a plan to further develop its technical capabilities FULLY-INTEGRATING ADEQUACY CRITERIA CORE ADEQUACY CRITERIA 7. Provisions are in place and are being 7. Provisions are in place and are being implemented in at least one program to implemented across all programs to avoid avoid cross-contamination during cross-contamination during remediation remediation activities. activities. ADDITIONAL FACTORS TO BE CONSIDERED 1. The State is encouraged, as part of its efforts to address potential sources of ground water contamination which are not federally regulated, to consider the following items: – Certification program for drillers, pump installers, and test samplers; – A plan for addressing abandoned and poorly constructed wells (i.e., problem wells) that is consistent with the State priorities and objectives; – Legally enforceable standards for well construction, abandonment, and testing, and a compliance program that ensures that the driller community is complying (Note: For disposal wells, these standards must be consistent with the regulatory requirements under the SDWA’s Underground Injection Control (UIC) Program); – Regulatory and non-regulatory approaches by the State to address on-site sewage disposal as a ground water contamination concern; and – Other efforts to control sources of ground water protection not addressed by federal statutes or regulations. 383-2000-030 / October 1, 1998 / Page 97 STRATEGIC ACTIVITY 5 COORDINATING INFORMATION COLLECTION AND MANAGEMENT TO MEASURE PROGRESS, RE-EVALUATE PRIORITIES, AND SUPPORT ALL GROUND WATER RELATED PROGRAMS FULLY-INTEGRATING ADEQUACY CRITERIA CORE ADEQUACY CRITERIA 1. The State collect, coordinate, and manage information, including record-keeping, monitoring, and other necessary information, within and across all programs to re-evaluate priorities, measure progress toward meeting the State’s ground water protection goal and priorities, and support all related program activities. 1. The State has developed a systematic process to collect, coordinate, and manage information, including record-keeping, monitoring, and other necessary information, within and across all programs to re-evaluate priorities, measure progress toward meeting the State’s ground water protection goal and priorities, and support all related program activities and is using it in at least one program. 2. The State is using relevant data from local governments and other State and federal programs (i.e. wellhead, public water supply, etc.). 2. Same 3. The State has defined a sufficient set of data elements to facilitate efficient data sharing and cross media analyses and provide users with consistent and comparable data, and is using it in all ground water related programs. 3. The State has defined a set of data elements to facilitate efficient data sharing and cross media analyses and provide users with consistent and comparable data, and is using it in at least one key ground water related program. 4. The State monitoring program scope and design reflect the State’s ground water priorities and contain sufficient QA/QC plans for data acquisition and analysis based on sound scientific protocols. 4. The State monitoring program scope and design reflect the State’s ground water priorities and contain QA/QC plans for data acquisition and analysis based on sound scientific protocols. 383-2000-030 / October 1, 1998 / Page 98 ADDITIONAL FACTORS TO BE CONSIDERED 1. The State is encouraged to computerize its databases and use geographic information systems (GIS) technology to better integrate data in a manner most useful to comprehensive ground water decision making 2. The State is encouraged to used EPA’s Minimum Set of Data Elements for Ground Water Quality, which EPA programs are required to use for new ground water information systems or when modernizing old ones. 3. The State is encouraged to use EPA’s location policy to assign latitude/longitude positions of Public Water Supplies and sources of ground water contamination in its ground water related information systems. 4. The State is encouraged toparticipate with EPA in the development of one or more environmental indicators that will help provide a national picture of ground water protection progress and needs. The State is encouraged to use the indicators(s), once developed, as part of its own efforts to measure progress and needs. 5. The State is encouraged to establish and track environmental indicators to measure progress in protecting its ground water resources. 383-2000-030 / October 1, 1998 / Page 99 STRATEGIC ACTIVITY 6 IMPROVING PUBLIC EDUCATION AND PARTICIPATION IN ALL ASPECTS OF GROUND WATER PROTECTION TO ACHIEVE SUPPORT OF THE STATE’S PROTECTION GOAL, PRIORITIES, AND PROGRAMS FULLY-INTEGRATING ADEQUACY CRITERIA CORE ADEQUACY CRITERIA 1. Public participation in the development and implementation of a CSGWPP is equivalent to the objectives defined and employed by EPA in 40 CFR Part 25. 1. Same 2. An active public education program exists that addresses the key issues in decisions on the goal, objectives, priorities, and progress of the State’s CSGWPP. 2. Same 3. The State is Implementing: 3. Same - A mechanism to provide information to those responsible for implementing ground water protection measures; and - An outreach process for making ground water monitoring data and information available to the public. 4. The State is implementing a public education program to: 4. The State has developed a public education program to: - Enable citizens to better manage common practices and activities that contribute to ground water contamination (e.g., private well construction, septic tanks, etc.) that are not now regulated; and - Same - Promote methods for protecting the ground water quality supplying individuals’ private wells. - Same 383-2000-030 / October 1, 1998 / Page 100 ADDITIONAL FACTORS TO BE CONSIDERED 1. The State is encouraged to undertake a Farm-A-Syst program in cooperation with the USDA’s Extension Serve, the Soil Conservation Service, and EPA. 383-2000-030 / October 1, 1998 / Page 101 For more information, visit us through the Pennsylvania homepage at www.state.pa.us or visit DEP directly at www.dep.state.pa.us An Equal Opportunity Employer Recycled Paper
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