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

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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