Kevin Ryan GWRMP Coordinator USEPA Region 9 (415) 972‐3806 ryan.kevin@epa.gov

Kevin Ryan
GWRMP Coordinator
USEPA Region 9
(415) 972‐3806
ryan.kevin@epa.gov

“ A speech is a solemn
responsibility. The man who
makes a bad 30-minute speech to
200 hundred people p wastes only a
half-hour of his own time. But he
wastes 100 hours of the
audience’s time- more than 4 days
– which should be a hanging
offense. ”
- Jenkin Lloyd Jones
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On 3/27/12 EPA Proposed Limits
on Greenhouse‐Gas Emissions
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Oops, Wrong
Speech/Presentation!
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GWRMP – Why do one?
How do I do it, or more
importantly, what does EPA want?
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Why? Budget Issues.
• Monitoring every source is costly
• UCMR3 allows UCMR2 approved
GWRMPs; so
• Possible savings for UCMR4?
• Comment on proposed rules ‐
get involved!
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How – Components of a GWRMP
• One plan for entire water system, including
all proposed groundwater representative
sampling locations (GWRSLs)
• Or one plan for each proposed GWRSL
• Plan has 4 sections; so
• What are you responsible for?
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4 Sections of a GWRMP
• Section 1 ‐ Site Map
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Section 1 – Site Map
• Location of all wells and EPTDS and the GWRSL
• Geographical features & potential sources of
contamination
i
• Scale and distances of each well from the proposed
GWRSL
• Illustrate basic information ( # of wells, screened intervals,
aquifer characteristics/confining units, GW directional
flow, time of travel)
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Section 2 – Contamination
Susceptibility of Proposed Area
State Groundwater Contamination i Information
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Section 2 – Contamination
Susceptibility of Proposed Area
• Identification of proposed sources of contamination: for
the proposed GWRSL to be truly representative of the
area, each well should have an equal possibility of
contamination
• Include a susceptibility analysis of the GWRSL(s) and
other wells to the most significant source of contamination
& TOT from the source of contamination
• Summary of source water assessment plans or wellhead
protection plans
• If available, known GW contamination information
should be included
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Section 3 – Similarities of GW Quality for
Proposed Area
Example State Groundwater Source Map
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Section 3 – Similarities of GW Quality
for Proposed Area
• Summary of well log information, well depth, construction
methods (casings & grouting) and strata
• Summary and analysis of H2O quality, including relevant
parameters (historical and representative data) for each
well and the GWRSL over a period of a year
• Well pumping rates (important!)
• GW source maps showing type of aquifer(s), well depths
and IOCs
• Use tables and graphs to illustrate, not raw data
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Section 4 – Summary of Proposal
• Concise summary of why the specified GWRSL should be
permitted
• The GWRMP should demonstrate any GWRSL selected is
representative of a well(s), draws from the same aquifer,
and meets all relevant H2O quality parameters
• Proposals that just include data in other sections without
any analysis will be rejected
• Questions on Proposals? Next section, EPA
Review
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Section 8? – EPA’s Review (3) (i)
Core Elements
Section 141.35 (3) (i)
PWSs may sample at
Representative EPTDS if
• They use ground water as a source
• All of their well sources have either the same treatment or no
treatment; and
• They have multiple EPTDSs from the same source, such as an
aquifer
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Section 8 – EPA’s Review - Continued
Section 141.35 (3) (ii)
• Applicability
• Justification
• Location Details
• Wll Well Documentation
ti
• Homogeneity
• Geography
• Contamination Risk
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Section 8 – EPA’s Review - Continued
Some Key Issues
• Final Rule language changed from Proposed Rule: Proposed Rule
stated the representative well must be one of the higher annual
volume producing and consistently active wells; Final Rule stated “h “the
proposed well must be representative of the highest annual volume
producing and most consistently active wells in the representative
array…”
• Exception to the Rule: if that representative well is not in service at
sampling time, select and sample an alternative representative well
• Importance of selecting a consistently active well, is to minimize the
chance that it will be out of service come sampling time
• Previously approved UCMR2 GWRMPs don’t have to contain the
highest producing and most active well –they just have to be
representative of them (see why I call the review a Section 8?)
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Section 8 – EPA’s Review - Continued
Key Issues
• Previously approved UCMR2 GWRMPs have their
sampling location information i pre‐loaded d into SDWARS
and PWSs must review and confirm or update this data by
October 1, 2012 (note: this date the UCMR3 database
becomes locked)
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Section 8 – EPA’s Review - Continued
Section 141.35 (3) (ii)
• Applicability
• Justification
• Location Details –within 0.5 mile radius or 5‐year TOT
• Wll Well Documentation
ti
• Homogeneity –e.g. pH, dissolved O2,conductivity, Fe, Mn
• Geography
• Contamination Risk – justification of no actual or
potential occurrence or non‐occurrence of contaminants
in the GWRSL or any of the wells represented
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Section 8 – EPA’s Review - Continued
Section 141.35 (3) (ii)
• Contamination Risk (cont.) –at a minimum, no greater
or lesser risk ik of actual or potential il contaminant
occurrence in the GWRSL or any of the representative
wells
• A PWS may not choose to omit a GW location with known
or suspected contamination or select a GWRSL known to
be free of contamination (within the array)
• How ‐ a simple declaration or may include full source
water vulnerability assessment with detailed drawings or
maps
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Section 8 – EPA’s Review - Continued
Section 141.35 (3) (ii)
• Clear as Mud?
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