by R. Allan Freeze 8

and John A. Cherry b

458

WHAT HAS GONE WRONG

Introduction • Many countries such as canada, where the authors of this

editorial reside, are far behind the United States in legislation and regulation of ground-water contamination and corrective mea­a~res. canadians should take advantage of experience in the United States in these matters. The purpose of this editorial is to analyze and discuss the main issues to direct attention to what we consider grave deficiencies and possible improvements. The United States is nearing the end of a decade in which much legislation pertaining directly and indirectly to ground water has been enacted, most of which has been in operation for some time. In comparison to nearly all other industrialized countries, the stringent nature of much of the U.S. legislation is exceptional. The legislation (especially the federal CE RCLA and RCRA Acts) has resulted in an increased awareness of ground-water contamination issues in the United States and greatly increased expenditures on site investigation, ground-water monitoring, and remediation. These increases far exceed those in other industrialized countries, even when factors such as population and ground-water usage are taken into account.

In this editorial we reflect on the general state of affairs in the legislation-driven effort by the United States to control ground-water contamination and related problems of waste dis· posal. It is a reaction to observations that we have made of CE RCLA and RCRA projects in the United States and to the strikingly different situation encountered in canada. In our opinion, much has gone wrong with the efforts resulting from the well-intentioned legislative program south of our border. One can­not say this for canada, because in Canada there has been little legislative effort, and therefore little to criticize except that lack of effort. Legislative jurisdiction on ground water in canada resides primarily with the provincial governments, which generally have minimal ground-water legislation, and even less enforcement. In domains where the Canadian federal government does have jurisdiction, the accomplishments have also been limited. In the United States, changes need to be made so tt"lat more is achieved in the 1990's than has been the case in the 1980's. In canada, the federal government and the provinces need to move toward new legislation so that the deterioration in ground-water quality does not continue to go unchecked. For both countries, reflection on the current situation in the United States is timely because each country has so much to learn from these recent experiences.

Our comments are meant to be generic in nature. While RCRA and CERCLA are the most visible U.S. regulations that affect ground water, they are certainly not the only ones. There are NRC regulations with respect to nuclear waste. There are many

8 Professor, Department of Geological Sciences, University of British Columbia, Vancouver, British Columbia, Canada V6T 2B4.

bprofessor, Department of Earth Sciences, University of Waterloo, Waterloo, Ontario, Canada N2L 3G1 .

Vol. 27, No. 4- GROUND WATER-July-August 1989

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state and local regulations. There are regulations that involve ground-water quality that do not arise in a waste-management context. We encourage readers from EPA and other regulatory bodies to recognize that our comments are not directed at any specific agency or law but instead represent a general concern on a broader front. .

If, as we believe, environmental legislation is not working well, there are several directions one might look to see what has gone wrong. The regulations themselves may be faulty. The admin­istration of the regulations may be unfair. The waste generators may be uncooperative. The legal response to the regulations may be inappropriate. The technical response may be inefficient The political influences on the process may be unwelcome.

We believe that there are problems in all of these areas, and the purpose of this editorial is to try in a fair and objective manner to reduce impediments to success in each of these areas as we see them. While we have some general recommendations to offer, we do not purport to have the entire solution. However, we do attempt to present the issues in a manner that may attract the attention of legislators in the United States and Canada to the technical and economic issues that have to be addressed if the problem of ground-water contamination is to be dealt with rationally.

Regulations: The Legislators and Their Advisors Regulations should be comprehensive, logical, practical,

politically acceptable, cost-efficient, simple to administer, and fair. Much of the legislation in the United States designed to protect ground-water quality fails to meet one or more of these criteria.

. Take fairness, for example. It seems patently unfair to make environmental legislation retroactive as is the case for the CERCLA legislation. As individuals, most of us would feel extremely hard done by if we were penalized for something that is illegal now, but wasn't 'when we did it, particularly if it was com­mon practice of the time. Representatives of waste-generating and chemical-use industries feel . the same, and the loss of goodwill between industry and the legislators may outweigh the value of any cost recovery that can be achieved. In addition, there is a loss in credibility, in that industry now feels that it has no protection against future legal action even if it meets current environmental standards. It is unlikely that cooperative compliance can be achieved in this climate of mutual suspicion. Of course, it could be argued that the world is unfair. Furthermore, the retroactive nature of the CERCLA legislation has resulted in some positive responses that perhaps would not have been achieved with any other form of legislation; this issue is discussed later in this editorial .

The practicality of much of the current ground-water-quality legislation can also be questioned. Most of this legislation was promulgated in the early heady years of the environmental move­ment. In many cases it was designated with little hydrogeological input, and without recognition of the true complexities of the

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tion promulgated in state and lower jurisdictions, to set unrealistic compliance goals. In some cases, it seems that performance standards are set at detection level, and as detection levels come down, so too do compliance standards. In some cases, state legislators are considering zero concentration as a standard for some fairly ubiquitous contami­nants. The public demand for complete remedia­tion of contaminated ground water must be tempered with practicability to clean up sites and with the available technology to monitor perfor­mance. Laws that do not take such issues into account lead to wasteful expenditures because of lack of decision-making discipline within a context of reasonable and achievable priorities. They also breed cynical disdain for the legislative process in the technical community.

We are also of the opinion that many of the legislative packages are too rigid in their technical requirements. Every site is different and every hydrogeological environment presents special circumstances. Specification in the regulations of such details as the number and location of moni­toring wells, as is the case with the upstream-down­stream guidelines in the current RCRA regulations, is ill-advised. Even the terminology of the law, if not carefully thought out, can lead to impractical interpretations by regulatory personnel. Some state regulations that require monitoring to protect the "uppermost aquifer" have led to meaningless inter­pretations at sites that do not have layer-cake stra­tigraphy. Strict adherence to the regulations can be counterproductive in that it may lead to monitor­ing networks that do not offer early warning of the most likely modes of leakage.

Perhaps our greatest concern with respect to many of the regulations is that they may have been written to solve the wrong problem. Most legisla­tion was designed to combat pollution from man­aged point sources such as municipal landfills and industrial waste-management facilities. The greatest threat to ground-water quality may well come from nonpoint sources associated with agricultural fertilizers, herbicides and pesticides, and from unmanaged point sources such as machine manu­facturing and repair shops, dry-cleaning shops, photo-processing plants, electronics plants, other industrial concerns, and domestic or communal septic systems or leaks in sewer lines. In addition, most of the legislation predates our emerging understanding of the subsurface behaviour of dense, nonaqueous-phase liquids (DNAPL's), such as chlorinated solvents, coal tar, creosote, and PCB oils. In cases where DNAPL's are prevalent and hydrogeological conditions are perverse, it might be possible to meet all the legal remedial require­ments in current law without decreasing the long­term potential for regional ground-water contami­nation.

460

In summary, future legislation should be more cognizant of available technology, more flexible in its technical requirements, and more applicable to nonpoint sources and DNAPL migration.

Technical Administration of R...,lltions: The R...,laton

Even when good clear legislation is in place, and more importantly when it is not, there is usually a need for interpretation of the terms of the law as it applies at particular sites. This task tends to fall on the shoulders of individual officers of the regulatory agencies. In our experience, we have often found that the response of regulatory officials to findings at field sites is insufficiently flexible to allow field investigations to take their proper course. For example, overreaction to appar­ent "hits," which may be false positives, or which may be due to the difficult technical protocols required when drilling through contaminated ground, is now causing many contractors to design inefficient site-investigation programs in order to avoid even the possibility of such an unexpected hit early in the program. In a more reasonable world, the results of drilling and measurement programs would be interpreted within the context of accepted hydrogeological models. This is not to say that unexpected hits should be allowed to go unexplained, but reasonable hydrogeological inter­pretations should prevail.

As with the regulations themselves, we also feel that the administration of regulations is often too rigid. There is a need for site-specific interpre­tation, where a variance from the letter of the law, but not the spirit, might well be in order (consider, for example, trying to apply rules intended for saturated systems at a site with a very thick unsatu­rated zone, or rules intended for aqueous contami­nation migrating from a surface source being applied where contaminants are actually migrating from a DNAPL pool situated deep in the ground­water system). It ·may be that highly placed offi­cials in the regulatory agencies are loathe to allow too much flexibility in their field offices because

· they recognize the widespread inexperience of many of their junior officers. There is strong evidence that many talented young hydrogeologists working in a regulatory role are quickly hired away by engineering firms representing the waste generators, once their talents are recognized during the regulatory process. This is a serious problem in its own right, in that it leads to an adversarial process with most of the technical talent on one side. In the long run, an unequal adversarial process can lead to poor-quality decision-making, from which either underprotection or overprotection could result. We urge regulatory agencies to keep their salary structures competitive with the private sector and to provide a creative and challenging

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workplace in order to ensure that they can hold on to talented technical people.

More important than any of the issues yet mentioned is the stifling effect of the current quality-control/quality-assurance procedures (QA/ QC) required by regulatory agencies. Over and over we have seen contractors' progress toward remedia­tion at field sites reduced to a crawl under the weight of QA/OC paperwork. In some cases, the situation has become so ludicrous as to actually halt technical work in the interests of bureaucratic paper-shuffling. We recognize the need for good accurate ground-water data, and for a certain level of accountability, but the current situation is one of immense overkill. A reduction in bureaucratic review is imperative if progress is to be achieved on ground-water cleanup. We suspect that the primary motivation behind intensive OA/OC lies in the fear of litigation down the road. Reduction in OA/OC requirements must go hand-in-hand with policies that lessen the likelihood of trying to solve technical problems in the courts.

Next, we raise questions about the administra­tive response to various technical alternatives for remediation. On one end of the spectrum, there are cases where ground water has been assaulted with contaminants from many sources over long periods of time, where potable ground-water aquifers are not at risk, and where remediation is unlikely to be successful. In such cases, a no-action or almost-no­action alternative should be considered. Wasting money in attempts to clean up such sites diverts resources from sites where cleanup is feasible and needed. We are even more worried about the other end of the spectrum. In particular, we are con­cerned about the apparent unwillingness of regula­tory agencies to consider perpetual care at sites where ground water has become contaminated. We believe that in many cases perpetual care, in the form of pumping, injection, and monitoring in perpetuity, may be the only viable remedial approach. An unwillingness to consider this option is driving contractors to propose quick-fix remedial alternatives that are not cost-efficient and are not likely to work.

There seems little question about regulatory dedication at the siting and permitting stage of waste-facility development. But we worry about down-the-road enforcement of environmental per­formance standards. Enforcement is expensive and in most legislative jurisdictions, funding for this exercise is woefully inadequate. As a result, regula­tory agencies too oftP.n focus on sites where the principal responsible parties are large, financially stable corporations for which cost recovery is feasible (the so-called deep-pocket syndrome). It seems that sites are being prioritized on the basis of the probability of successful cost-recovery rather than on the probability for prevention of excessive adverse impact on health and the environment.

To summarize, we believe that regulators must develop greater flexibility in their interpreta­tion of environmental legislation, significantly reduce the scope of their OA/OC procedures, take steps to keep on board good technical people, examine their unwillingness to consider perpetual care as a remedial option, and improve their system for prioritizing remedial sites.

Legal Respon• to Regulations: The Generaton and Their Lawyen

Much of the current environmental legislation sets up an adversarial legal system in which waste generators from the chemical and nuclear industry are pitted against regulatory officials whose task is to protect society against environmental degrada­tion. It is now common for both sides to be repre­sented by legal teams.

It is important that technical personnel recog­nize that the lawyers operate in a different world from scientists and engineers. Their objectives are not the same as those of the engineer, who for the most part, is seeking an optimal solution. In our justice system, the lawyers' role is clearcut: they represent their clients' interests. Their view of the best solution, and of the best way to achieve it, may differ from that of the scientist or engineer. We have begun to see a disturbing trend; we often see technical programs of investigation controlled by the needs of the legal team. This approach leads to a closed, uncooperative atmosphere, in which stonewalling as to the known facts and interpreta­tions becomes more common. As this trend becomes increasingly evident, it will produce a public perception that scientifically based solutions are lost in a labyrinth of legal games. This develop­ment cannot possibly promote environmental pro­tection.

In some countries, environmental legislation allows for a negotiation approach rather thai) a cut­and-dried setting of standards. Such negotiations also involve legal input but perhaps in this case such input would avoid the high costs that often result from an adversarial climate. There may be a greater role for environmental mediation, in which a · mediator attempts to bring the sides together short of a courtroom showdown.

Technical Response to Regulations: Engineering Firms and Their Hydrogeological Consultants

Engineering firms that contract with waste generators and/or regulatory agencies to carry out the technical investigations at new or remedial waste-management sites are not free from responsi­bility in this catalogue of what has gone wrong. Neither are the individual ground-water scientists and engineers who work for such companies or who consult to them.

First, there is the age-old problem of making the technical aspects of the project fit the needs of

461

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the client. In most engineering endeavors, both client and consulting firm have a high degree of technical expertise, well-suited to the project at hand. In the waste-management field, this is not always the case. While the situation is fast improv­ing, it is nevertheless still quite common for chemi­cal or nuclear firms with waste-management prob­lems to have little hydrogeological understanding or expertise. Some engineering firms appear to take advantage of this situation by recommending field investigations and modeling studies that seem un­ending. We are all familiar with remedial investiga­tions (RI), and then feasibility studies (FS), Phase 1 , and then Phase 2; or Phase 1A, Phase 1B, and then Phase 2. It is apparent that there is sometimes no incentive for the consulting firm to close their investigations. Fear of liability may also play a role here, and consulting firms may recommend addi­tional work largely to protect themselves against future lawsuits. To some degree, the responsibility for a failure to close lies with the regulatory agen­cies, who often have political reasons to postpone decisions, but we believe that the engineering com­munity itself has an obligation to make decisions about siting or remedial design at the earliest possible moment in the investigative process when such decisions can be made in good faith.

As a second issue, we note that engineering firms and individual hydrogeologists, when placed in a truly adversarial position between waste gener­ator and regulatory agency, or between one or more potentially responsible parties in a cost­recovery process, often try to serve their clients too well. We worry that hydrogeologists are taking on the style of lawyers. The bending of hydrogeo­logical interpretations to meet the legal rather than technical needs of a client is unethical and more of it is creeping into our business than most of us would like to see.

There is another ethical issue that engineers and hydrogeologists must face. All engineers func­tion under a code of ethics; the first fundamental canon in the ASCE Code of Ethics states that engi ­neers shall hold paramount the safety, health, and welfare of the public in the performance of their professional duties. In the absence of regulations, a design engineer would presumably prepare designs for a waste-management facility that are in keeping · with his interpretation of the code of ethics. How­ever, with the detailed regulatory systems that are now in place, we believe that most design engineers now feel that they have satisfied their ethical obli­gations if they meet the regulatory requirements. In the U.S. high-level nuclear waste program, for example, there is no question that DOE design guidelines are driven by NRC regulations. If this is a correct approach, then an engineering ethic cannot be viewed as morally absolute; it is a function of the regulatory climate.

In summary, we feel that it is imperative that

462

individual engineers and hydrogeologists carefully examine their ethical conduct to ensure that they are bringing R 1/FS studies to closure in an efficient manner, that they are providing objective hydro­aeological interpretation undistorted by their clients' legal needs, and that they are contributing to designs that not only meet the regulations, but also protect the safety, health, and welfare of the public.

Political Influences on the Proc111: The Citizens end Their Lobbyists

It is widely recognized that decisions that are optimal in some sense for society as a whole will not be optimal for all the individuals in the society. As a result, we have LULU's ("locally unwanted land uses") and the NIMBY syndrome ("not in my backyard!"). The existence of lULU's and the NIMBY syndrome lead to special interest groups and lobbyists who work on their behalf. Such groups often become the bane of generators and regulators alike. It is sometimes difficult to remem­ber that people resist LULU siting because they fear a decline in their property values, or worse yet, disease and health decline, and even death. These fears are not irrational, and policymakers must accept peoples' fears as a valid part of policy­making. Successful citizen suits are making it impossible to ignore these fears. Nevertheless, there is no question that politically strong groups can overwhelm the politically weak, and the result is often bad siting. Study after study has shown that the best route to clean ground water is through good hydrogeological siting, not clever engineering design. Regulatory agencies must be willing to defend technically sound siting decisions against political pressures. On the other hand, the political system must begin to examine what types of bene­fits can be offered to communities to offset the unarguable social costs of hosting waste-manage­ment facilities. Under the SARA amendments to CERCLA, it is required that each state be able to certify that it has adequate capacity for the dis­posal of the next 20 years' hazardous waste or the state will lose all Superfund monies. This is

. Congress' attempt to overcome the NIMBY syn­drome at a state level.

We also note at times an unwillingness on the part of regulatory agencies to differentiate between good and bad corporate citizens during the adver­sarial remedial process. In such cases they remain hostile to cooperative waste generators in order to assuage political opinion. In our opinion, this is an unethical stance for a public agency. They should instead take the more difficult route of attempting to explain to the public interest groups in a partic­ular community how the response of their particu­lar corporate nemesis compares with the less coop­erative responses at other sites. If cooperation on the part of waste generators is not rewarded, it is

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unlikely that they will continue to take such a stance in future dealings with regulatory bodies.

Another issue with political overtones con­cerns the role that is to be played by nonregulatory agencies. In the United States, the U.S. Geological Survey and other federal and state geological, agri­culwral, and water-resource agencies have become involved on one side or the other in some of the adversarial procedures. In our opinion, such agencies are ill-suited for this role and may be in conflict of interest. Their involvement usually leads to difficulties on all sides, not least within the agencies themselves. We urge such agencies to re­examine their policies with rewect to their involve­ment in adversarial environmental matters.

It is right and proper for political influences to play a role in environmental decision-making, but it is equally important that this role not be allowed to overwhelm siting decisions or to subvert the technical adversarial process.

Whet We Have Learned The intended outcome of the ground-water­

quality legislation put in place in the United States in the last decade, whether stated explicitly or im­plicitly, seems to have been zero contamination at new waste-management sites, and a return to pris­tine conditions at remedial sites. It is certain that this outcome has not been achieved, and it now appears likely that it is not achievable, at least at DNAPL sites. It is necessary for regulatory person­nel to inform legislators of this fact, and for legisla­tors to inform the public. Current public expecta­tions with respect to remediation are quite unrealistic. What is achievable, and what is being accomplished at most sites, is a reduction in environmental degradation and/or health risk to a level that is in some sense "acceptable." The level of risk that is deemed "acceptable" is something that is decided in the political arena, but hopefully in a political arena that is technically well­informed.

From a hydrogeological perspective, the major outcome from the first generation of legisla­tion has been the creation of a large suite of field laboratories in the form of large-scale remedial actions, which are essentially research experiments to see how cleanup can be accomplished and what level of cleanup is attainable. This outcome was undoubtedly unintended by the legislators, but it is a positive outcome in that it will lead to a more· realistic second generation of legislation in due course.

Since the CERCLA (or Superfund) legislation went into effect in 1980, much has been learned as a result of studies conducted at Superfund sites, and also during this period, at many other sites. First, a significant number of Superfund sites are not situated on or near major aquifers that are sole­source or significant-source water supplies. This is

not to say that CE RCLA sites have not impacted some important aquifers, but rather that in the broad context of the nation's water supply, CE RCLA is less important than is sometimes claimed.

Second, attempts at aquifer remediation, where the goal has been to rewrn a water-supply aquifer to a state where its water meets drinking­water standards, have almost without exception been a failure. If not an outright failure, they have made so little progress that expectation is for. success not to be achieved in this century and maybe not in the next one.

Third, the cost of Superfund· RI/FS site studies is generally large (millions of dollars is not uncommon). The cost of implementation of ground-water remediation that prevents off-site contaminant migration is also large, generally on the order of tens of millions of dollars. It is esti­mated that the CERCLA legislation will eventually cause a total of about 300 billion dollars of expen­diture by industry and an equal amount by govern­ment. For such investment, very little of the nation's exploitable ground water will be protected or improved.

Fourth, new technologies for aquifer remedia­tion have generally contributed little to reducing these costs or providing permanent solutions. Purge wells and aboveground-water treatment, occasion­ally coupled with cutoff walls, and various combi­nations of excavations, soil treatment and soil caps, more or less as used in the 1970's, remain prime items on the menu for the 1990's. There is little likelihood that this situation will change drastically in this century, as a result of scientific or techno­logical breakthroughs. In general, possibilities for cost-effective aquifer cleanup are limited at most sites because of factors related to geological com­plexity, compounded by difficulties imparted by DNAPLs or LNAPLs.

There is now little doubt that at sites where DNAPLs are the problem, the local ground-water zone has terminal cancer. A cure, in the form of returning aquifer quality to drinking-water stan­dards, is unachievable at almost any cost. At DNAPL sites, costs are going up and aquifers are not much improved.

From these points, a conclusion follows: the cost of aquifer protection by minimizing possibil­ities for spills, leaks, or improper disposal on aquifers is generally much smaller than the cost of studying, designing, litigating, and remediating aquifers after contamination in the aquifer is found. There is an urgent need for a shift in total societal expenditures. We should move away from high capital-cost, quick-fix remedial solutions, and recognize the need for long-term operational investment. We should move away from the present overemphasis on attempts at correction of ground-water problems caused by actions of past

463

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decades, and the associated legal costs of guilt­establishment and punishment for these past sins, and move toward investment in current water­resource protection by the prevention of leaks, spills, and improper disposal . In this way, invest­ment today will reap benefits tomorrow. This is much more easily said than done because our industrial society uES 10 many chemicals from which widespread, long-term contamination can result from very small spills or leaks. The difficulty of ground-water protection bodes poorly for much success unless the major protection effort is focused on those aquifers most worthy of protec­tion. The classification and prioritizing of aquifers is a job worth pursuing with urgency.

Perhaps the major achievement of the CERCLA legislation is that it has caused large corporations to become emphatically aware that the improper disposal and accidental spillage or leakage of industrial chemicals, either in product or waste form, can result in remedial and legal costs that can be immense and that can impact signifi­cantly on the year-to-year corporate "bottom-line" for many years, in some cases even to the point of jeopardizing the financial viability of a company. The fact that the legislation is retroactive has caused many large corporations to realize that in the future, avoidance of such financial liabilities should be accomplished by adherence within the corporation to the highest technical and scientific standards, regardless of whether or not these standards exceed those specified in current legisla­tion, or are otherwise different from current legislation.

It is now realized that legislation generally changes from decade to decade and that what is an acceptable corporate environmental achievement one year in the eyes of legislators can become un­acceptable in the next. CERCLA has caused many large corporations in the United States to adopt much higher internal ethics and standards with respect to ground water and other environmental issues. From this approach these corporations hope that they will never again be caught by retroactive legislation.

It may be time for an amnesty for actions taken long ago when such actions were generally accepted practice. But such amnesty should be coupled with very large regulatory penalties for any current malpractice on the part of waste gener­ators. There may be some industrial entities who have not learned the lessons of the 80's. We must ensure that their present-value economic decisions with respect to waste-management practices are

464

strongly influenced by the knowledge that large future penalties will be the results of current care­lessness.

To summarize our views, we worry that the current technical legal and political administration of ground-water-contamination legislation in the United States is subverting proper scientific methodology and good engineering practice. What is needed now is for changes in legislation so that the second generation legislation will be more realistic and flexible, lea dependent on legal adver­sarial action, less open to political interference, and less encumbered by bureaucratic red tape. The legislation should be aimed at protecting those aquifers that are deemed worthy of the cost. We urge a move away from the blanket cleanup of all subsurface contamination to a policy that focuES on protecting aquifers that constitute valuable water supplies and remediating sites where signifi­cant health-risk . reduction can be achieved. We suggest less emphasis on punitive 8118111llent of past practices and more emphasis on proper storage and disposal today to ensure environmental quality tQmorrow.

R. Allllfl FtWZe ha been e Professor et the Unive~ty of Britilh Columble Iince 1969. H• l'flc.ived degtWI In Geo­loglcel Engineering from OUHIII Unlve~ In Onterlo llfld the University of Clllifomie, Berlcei'Y. He h• been PtWI· dent of the Hydrology Divllion of the Amer/CIIfl Geophyli­cel Union end ha l'flc.ived eMrdl for h/$ ground-w.ter ,..erch eccomplilhments from the Geologicel Society of Americe, the Americllfl G.ophylicel Union, end the Cllnldien Geottlehnicel Society. He a the COBUihor, with John Cherry, of the textbook Groundwater (Prentice-Hell, 1979). His current raNrch end comultlng lntemts focus on in.tegi'Btion of economics, hydfO{IIIology, ind rak enelysis in declsion·meking on W8lte dlrpoul llfld related ground-wtlter lswa tuch • lite •feet/on, monitoring design, end ffHTitJdletion.

John A. Olerry hes btlen eProfessor Bt the University of W11terloo Iince 1971. He hes dtJgtWI in Geologicel Engl­nuring from the University of S.lketcheWIIfl Btld the Uni­versity of Clllifornle lit &rkeley Btld In HydfO{IIIOiogy from the Univllrslty of Illinois. He h• received BMrdr for ground-Mter reiiiBrCh 1/CComplilhments from the Geologl­cel Society of AmericB, the Amer/CIIfl Geophylicel Union, Netionsl Weter Well AJtOcletlon, the CMIIIdiBn Geottlehni­cel Society, llfld the Province of OntBt'io. From 1981-1987, he WIIS Director of the Institute for GroundMter R•err:h Bt Weterloo. His currtlflt ,...,-ch end cort~~~ltlng interests pert/lin to the biJhevlour end moniforlng of lndultrlel chemie~~ls in ground Mter Btld on -.nBIIt of hydro­geologic factors In lite remtldletion.

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