United States
              Environmental Protection
              Agency
  Solid Waste and
Emergency Response
    (5303W)
         EPA/530/R-01/015
         September 2002*
http://www.epa.gov/correctiveaction
rEPA    Handbook of Groundwater
              Protection  and Cleanup Policies
              for  RCRA Corrective Action
              for Facilities Subject to Corrective Action Under
              Subtitle C of the Resource Conservation and Recovery Act
     * As described on page xof the Introduction, EPA intends to keep this Handbook current. This document is an
     update to the original version dated September 2001. The sole purpose of this September 2002 version is to
     update a number of Internet links to ensure that cited references and resources are available to the reader. Note,
     however, that each policy section of the Handbook continues to retain the original September 2001 date since no
     substantive textural changes were made in this updated version. In the event of substantive changes to a policy
     section(s), the date on top of that section will be changed accordingly.

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                                   Acknowledgments
       This Handbook was produced by EPA's Office of Solid Waste, Permits and State Program
Division in conjunction with EPA Region III. Contributing authors include Guy Tomassoni from the
Corrective Action Programs Branch, and Deborah Goldblum and Joel Hennessy from EPA Region Ill's
Waste and Chemicals Management Division. We express a special thanks to Joel and Deborah for their
expertise, time and dedication to this effort.  We also thank Region III management, who supported
their involvement.  We also acknowledge and thank the individuals and organizations that provided
comments and suggested improvements on previous draft versions.

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  Links to State
Cleanup Programs
     If you are viewing an electronic version,
you can click a button to take you to a topic of interest.
                Links to
              EPA Regions
                             Handbook Overview
                                What does this Handbook do?
                               Who should use this Handbook?
                             Applicability to State Cleanup Programs
                                  Roles and Responsibilities
             Short Term
           Protection Goals
               including
           Environmental Indicators
                Intermediate
             Performance Goals
Final Cleanup Goals
      including
   Remedy Selection
    Future Policy
    (place holder)
                                                  Ground water
                                                 Cleanup Levels
  Completing
 Ground water
  Remedies
 Performance
  Monitoring
             Groundwater
               Protection
        and Cleanup Strategy
                    for
         RCRA Corrective Action
                 Point of
               Compliance
                Cleanup
                Timeframe
    Reinjection of
    Contaminated
    Groundwater
                                                 Source Control
           Technical
         Impracticability
     References
                               Monitored
                                Natural
                              Attenuation
                          Institutional
                           Controls
                                            Groundwater
                                                Use
                                            Designations
                             Links to Internet Resources
                                                 Glossary

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                                       Table of Contents

Overview	i
        What does this Handbook do?  	i
        What is the difference between statements in this Handbook and EPA statutory or
                regulatory requirements?  	ii
        Who should use this Handbook?  	 ii
        How will this Handbook help me?	ii
        What does the RCRA Corrective Action Program do? 	iii
        What are the general roles and responsibilities of various stakeholders involved
                with RCRA corrective action?  	iv
        How do the policies in this Handbook apply to State cleanup programs?  	vii
        How is this Handbook organized?  	vii
        Where do the policies in this Handbook come from?  	viii
        Are the policies contained in this Handbook consistent with EPA's other cleanup programs?  	ix
        How will I know that the policies in this Handbook are current? 	 x
        How can I get further information about the policies in this Handbook?	 x
        What if I have comments on this Handbook?	 x

1. Groundwater Protection and Cleanup  Strategy                                           H
        What is EPA's groundwater protection and cleanup strategy for RCRA corrective action?	1.1
        How does this strategy benefit the public, regulators, and facilities?	LI
        What is EPA's overall goal for groundwater protection and cleanup?	LI
        How should facilities and regulators implement this groundwater protection and cleanup strategy
                for RCRA corrective action?	1.2
        How do  short-term, intermediate, and final cleanup goals work together to achieve EPA's overall
                groundwater goals? 	JL2
        How should facilities and regulators implement these goals?	1.4

2. Short-Term Protection (Environmental Indicator) Goals	2J_
        What are EPA's short-term protection goals for groundwater?	2.1
        How does EPA monitor progress toward these goals?	2.1
        Who evaluates and determines whether a facility meets environmental indicator goals?	2.2_
        How should regulators and facilities evaluate environmental indicators?  	2.2
        How does a facility get to YES?	Z2
        How should facilities and regulators develop facility-specific short-term protection goals?	2.3
        How should facilities and regulators consider groundwater use when evaluating
                "Current Human Exposures Under Control?"	2.4
        How should facilities and regulators evaluate the "Migration of Contaminated Groundwater
                Under Control" indicator?  	2.4
        Can a facility achieve the "Migration of Contaminated Groundwater Under Control"
                indicator when the plume extends beyond the facility boundary?  	2L5
        Can a facility achieve the "Migration of Contaminated Groundwater Under Control" indicator when
                contaminated groundwater discharges to surface water?	2.5
        Will an environmental indicator evaluation require additional investigation?	2.6
        Do facilities need to perform additional investigation or cleanup, once they achieve the
                environmental indicator goals?	2.6
        Do facilities need to control sources to meet the environmental indicator goals?  	2.6
        Are the two environmental indicators  the only short-term protection goals
                facilities should consider?  	2.7
                                        Table of Contents, Pg. 1

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3. Intermediate Performance Goals  	3J,
        What are intermediate performance goals for groundwater?	   .1
        How can intermediate performance goals help me?
        Are intermediate performance goals appropriate for all facilities?
        When should facilities and regulators establish intermediate performance goals?	
        How should facilities and regulators develop facility-specific intermediate performance goals?
        What are some examples of intermediate performance goals?  	
        Why is it important to establish intermediate performance goals on a facility-specific basis?  . .
4. Final Cleanup Goals  	4.1
        What are EPA's final cleanup goals for corrective action?	4J_
        What are EPA's final cleanup goals for groundwater?	4,2
        When does EPA consider groundwater "usable" for selecting final cleanup goals?	4.2
        What if groundwater is not usable?  	4.2
        What if returning contaminated groundwater to its maximum beneficial use
                is not technically practicable?	4,1
        How should facilities and regulators evaluate final remedies that meet the threshold criteria?  	4.4
        How thorough of an assessment should facilities conduct when evaluating
                one or more remedial options?	4^5
        How should facilities and regulators develop facility-specific final groundwater cleanup goals? 	4,5,
        What are the media cleanup objectives if containment is the final goal rather than meeting
                cleanup levels throughout contaminated groundwater?	4.6

5. Groundwater Cleanup Levels  	5.1
        What are groundwater cleanup levels?	5.1
        How should groundwater cleanup levels be developed? 	5J_
        Are there other factors that should be considered when developing groundwater cleanup levels?	5,2
        What is the role of groundwater use in setting cleanup levels?	5.3
        What are the groundwater cleanup levels for a current or potential source of drinking water?  	5.4
        What is the cleanup level if the groundwater is designated as something other than a current
                or potential source of drinking water?  	5,4.
        Are there any situations where regulators might not establish specific groundwater cleanup levels? . . . 5.6
        What are alternate concentration limits and do they apply to setting groundwater
                cleanup levels for facility-wide corrective action?	5.6
        What are cleanup levels for groundwater if a facility is clean closing a RCRA regulated unit?	5,7

 6.  Point of Compliance  	  jSJ.
        What is a point of compliance for groundwater?  	6,1
        Where is the point of compliance for RCRA regulated units?	6.1
        Where is the groundwater point of compliance for RCRA (facility-wide) corrective action?	6.2
        Where is the groundwater point of compliance for final cleanup goals?	6.2
        Where is the groundwater point of compliance for short-term protection goals?	6,1
        Where is the groundwater point of compliance for intermediate performance goals?  	6.4

7. Cleanup Timeframe	7J_
        What is the cleanup timeframe?	7.1
        What is the cleanup timeframe for EPA's short-term goals?	7.1
        How should regulators establish cleanup timeframes for intermediate performance goals?	7.2
        How should regulators establish cleanup timeframes for achieving final cleanup goals?	7,2
                                         Table of Contents, Pg. 2

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8. Source Control 	ILL
        What does source control mean?  	8.1
        What are sources of contamination?	8.1
        What are EPA's expectations for source control regarding groundwater?	8J_
        When should facilities and regulators consider source control measures?	8,2
        When can facilities contain the sources rather than treat them?	8.2
        Why should facilities control sources when they have already achieved
                environmental indicators goals?	8.3,

9. Groundwater Use Designations	9.1
        What is a groundwater use designation?	9J_
        How does EPA define use, value, and vulnerability?   	9J_
        What factors should States consider when making groundwater use designations?	9.2
        How does EPA's policy on groundwater use designations affect States which consider all of their
                groundwater to be a potential drinking water supply?	9.2
        Who makes groundwater use designations?	9.3.
        What is EPA's groundwater use classification?  	9.4
        How can State groundwater use designations enhance protection and flexibility for RCRA cleanups?  . 9.5
        How do groundwater management or containment zones relate to groundwater use designations?  .... 9.5.

10.  Institutional Controls	10.1
        What are institutional controls?	KXj
        What are the general categories and some specific examples of institutional controls?	10,1
        How can facilities and regulators use institutional controls to address contaminated groundwater?  . . 10.2
        How should facilities develop and stakeholders evaluate institutional controls?  	10.3

11.  Monitored Natural Attenuation 	11.1
        What is monitored natural attenuation?	11.1
        When is monitored natural attenuation a likely cleanup option?	1_1_J_
        Is monitored natural attenuation acceptable when contaminated groundwater is off-site?	11,2
        Should monitored natural attenuation remedies include formal contingency measures?  	11.2
        How long should a facility monitor a monitored natural attenuation remedy?  	11.3

12.  Technical Impracticability   	12.1
        What does technical impracticability mean?	12.1
        What are the primary factors that might lead to a technical impracticability determination?  	VL\_
        Is the mere  presence of non-aqueous phase liquids (NAPLs) sufficient to justify a
                technical impracticability determination?	12.2
        What should facilities include in a technical impracticability evaluation?	12.2
        When should a facility recommend technical impracticability?  	J2.2
        Should regulators make technical impracticability determinations prior to a facility's attempt
                to meet groundwater cleanup levels?  	12.3
        If a regulator makes a formal technical impracticability determination, has the facility satisfied
                all of their corrective action obligations for groundwater?  	123_
        Why should facilities conduct investigations within the technical impracticability zone?	12,3,
        Why should facilities control sources within the technical impracticability zone?	12.3
        How does a technical impracticability determination affect the point of compliance?	12.4
        How long should a technical impracticability determination last?	J2.4
        Should regulators and/or facilities revisit technical impracticability determinations?	1.2,4
                                         Table of Contents, Pg. 3

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13. Reinjection of Contaminated Groundwater	J3JL
        Can facilities reinject groundwater that is contaminated with hazardous wastes back
               in the subsurface as part of corrective action?	OJ:_
        What are the specific conditions facilities have to meet prior to reinjecting groundwater
               contaminated with hazardous waste into the subsurface? 	13.1
        Does section 3020(b) allow the reinjection of contaminated groundwater after the
               addition of nutrients or other in situ treatment products? 	J3.2
        What if a facility wants to reinject groundwater that is  contaminated with
               nonhazardous wastes as part of corrective action?  	13.2

14. Performance Monitoring	j4J_
        What is performance monitoring?  	14.1
        What should the performance monitoring accomplish? 	14.1
        What should a performance monitoring program include?	J4.2
        How often should a facility monitor?	JA2
        How long should performance monitoring continue?	14.2

15. Completing Groundwater Remedies                                                    L5J,
        What does completing a groundwater remedy mean with respect to RCRA Corrective Action?  	15.1
        What does it mean to complete the implementation phase of a groundwater remedy?	15.1
        What does it mean to complete a groundwater remedy  with respect to achieving final cleanup goals?  J5.2
        What does it mean to fulfill all cleanup obligations associated with contaminated groundwater
               at a particular facility?	15.2
        How do facilities and regulators typically decide when  a groundwater remedy achieves
               media cleanup objectives?  	J5._3

Appendix 1 - References	Appendix 1.  Pg. 1

Appendix 2 - Links to Other Helpful Internet Resources  	Appendix 2,  Pg. 1

Appendix 3 - Glossary	
                                       Table of Contents, Pg. 4

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                                        Overview
                                     (September 2001)
What does this Handbook do?
This Handbook is designed to help you as a
regulator, member of the regulated community, or
member of the public find and understand EPA
policies on protecting and cleaning up
groundwater at Resource Conservation and
Recovery Act (RCRA) corrective action
facilities1. EPA developed this Handbook as part
of the RCRA Cleanup Reforms (refer to
http://www.epa.gov/epaoswer/hazwaste/ca/refor
ms.htm) that EPA announced in July 1999 and
January 2001 (EPA, 200Id and EPA, 1999c).
EPA's goal for this Handbook is to help meet the
objectives of these reforms by reducing time-
consuming uncertainties and confusion about
EPA's policies concerning groundwater
protection and cleanup at RCRA facilities. We
believe clarifying EPA's groundwater policies will
help promote faster, focused,  and more flexible
cleanups, and foster creative solutions.

This Handbook recommends  that groundwater
cleanups2 generally be implemented in terms of
short-term protection
            goals, and             gals- EPA
recommends that facilities, regulators, and
members of the public use these goals to focus       ^^^^^^^^^^^^^^^^^^^^^^
discussions as well  as resources, and  to ultimately
improve the quality of groundwater at and near corrective action facilities.  EPA is issuing this
     Why is groundwater
           important?

Beneath the surface of the earth, a huge
supply of fresh water is available to
support the health and economic well-
being of our country. More specifically,

/ Groundwater supplies drinking water
   to half of the  nation and virtually all
   people living  in rural areas.

/ Groundwater supplies the majority of
   water in streams and rivers in large
   areas of the country and provides
   much of the water in lakes and
   wetlands; these surface water bodies
   provide the balance of drinking water
   to those areas that do not rely on
   groundwater as their primary source
   for drinking water.

/ Groundwater supports many billions of
   dollars worth  of food production and
   industrial activity.

(EPA, 1999b)
       1 This Handbook primarily addresses corrective action as required by the 1984 Hazardous and Solid
Waste Amendments (HSWA) to RCRA. For additional background regarding RCRA in general, refer to the
RCRA Orientation Manual (EPA, 1998a) available at hJMl/toH^eMJI^                      Fr more
information about RCRA corrective action, refer to the corrective action Web site at
http://www.epa.gov/correctiveaction.

        The terms cleanup or cleaning up, when used in this Handbook, refer to the range of activities that could
occur in the context of addressing environmental contamination at RCRA facilities.  For example, cleanup
activities could include removing waste or contaminated media (e.g., excavation and pumping groundwater), in-
place treatment of the waste or contaminated media (e.g., bioremediation), containment of the waste or
contaminated media (e.g., barrier walls, low-permeable covers, and liners), or various combinations of these
approaches.  The term "cleanup" is often interchanged with the term "remediate" or "remediation."
          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                        Overview, Pg. i

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Handbook to communicate what we believe should generally occur at RCRA corrective action
facilities to protect human health and the environment.

What is the difference between statements in this Handbook and EPA statutory or regulatory
requirements?

This Handbook provides guidance to EPA regional and State RCRA Corrective Action Program
implementers, as well as to owners and operators of facilities subject to RCRA corrective action
requirements, and to the general public. More specifically, this Handbook conveys how EPA
generally expects to exercise its discretion in implementing RCRA statutory and regulatory
provisions that concern RCRA corrective action. EPA designed this guidance to explain and
clarify national policy on issues related to the protection and cleanup of groundwater at RCRA
corrective action facilities.

The statutory provisions and EPA regulations discussed in this Handbook contain legally binding
requirements.  This Handbook itself does not substitute for those provisions or regulations, nor is
it regulation itself.  Thus, this Handbook does not impose legally binding requirements on EPA,
States, or the regulated community, and may not apply to a particular situation based upon the
specific circumstances of the corrective action facility.  EPA and State regulators retain their
discretion to use approaches on a case-by-case basis that differ from this Handbook where
appropriate. EPA and State  regulators base their corrective action decisions on the statute and
regulations as applied to the  specific facts of the corrective action facility.  Interested parties are
free to raise questions and concerns about the substance of this Handbook and appropriateness of
the application of recommendations in this Handbook to a particular situation.  Whether or not
the recommendations in this  Handbook are appropriate  in a given situation will depend on  facility-
specific circumstances.

Who should use this Handbook?

This Handbook is designed to help anyone who wants to develop a better understanding of EPA's
groundwater cleanup policies for RCRA corrective action facilities.  We wrote this Handbook for
State and EPA regulators, owners  and operators of facilities  subject to RCRA corrective action,
and members of the public.  Throughout the rest of this Handbook we will refer to these three
groups as "regulators," "facilities," and the "public," respectively.  Sometimes, we will refer to all
three groups collectively as "stakeholders."

How will this Handbook help me?

If you are a regulator, the Handbook can help clarify key groundwater-related policies that you
should consider, where appropriate, to guide investigations and cleanups at your assigned
facilities (via permits, orders, or voluntary actions). EPA designed this Handbook to help  you  do
your part in promoting a technically sound,  reasonable, and consistent approach to protecting and
cleaning up our Nation's groundwater.
          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

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If you represent a facility, the Handbook can help you reduce your uncertainties about the actions
a regulator may require of you.  Reducing uncertainties can help you in your financial planning
and project management. Clarity in EPA's expectations will allow you to phase your
investigation and cleanup strategy in a manner consistent with the RCRA Corrective Action
Program priorities.  These policies can help if you are currently undergoing RCRA corrective
action under some form of regulatory oversight, or if you intend to begin cleanup in advance of
oversight by an EPA or State regulator.

If you are a member of the public, this Handbook can help you understand what EPA generally
expects3 regulators and facilities to do during an investigation and cleanup of contaminated
groundwater at a RCRA corrective action facility. EPA encourages you to use this Handbook as
a tool in your interaction with regulators or facilities. In essence, EPA wrote this Handbook, in
part, to help you influence decisions related to groundwater protection and cleanup at RCRA
corrective action facilities.

What does the RCRA Corrective Action Program do?

Accidents or other activities at RCRA facilities have sometimes resulted in releases4 of hazardous
waste or hazardous  constituents into soil, groundwater, surface water, sediments, or air.  The
Corrective Action Program requires such facilities to conduct investigations and cleanup actions
as necessary to protect human health and the environment. Currently, EPA believes that there are
over 5,000 facilities subject to RCRA corrective action statutory authorities.  Of these,
approximately 3,700 facilities have corrective action already underway or will need to implement
any necessary corrective action as part of the process to obtain a permit to treat, store, or dispose
of hazardous waste. To help prioritize resources, EPA established specific goals for 1,714
facilities5 that generally warrant attention in the next several years.

EPA's authority to require facility-wide  corrective action comes from the Resource Conservation
and Recovery Act (RCRA). The following specific  sections of the RCRA statute that regulators
use to require corrective action  (or aspects of corrective action) include:  3004(u)&(v),
3005(c)(3), 3008(h), 3013,  and  7003. EPA's regulatory provisions for corrective action at
permitted facilities are found primarily in 40 CFR Part 264 Subpart F. EPA provides additional
direction on corrective action through guidance, policy directives, and related regulations. The
most recent  and comprehensive guidance issued for RCRA corrective action is in Section III
(pages 19440  - 19455) of the May  1, 1996 Advance Notice of Proposed Rulemaking (ANPR;
EPA, 1996a; see also EPA, 1997a).
       3 See glossary to definition of "remedy expectations" used in the context of the RCRA Corrective
Program.

       4 See glossary definition of "releases."

       5 For additional information about the list of 1,714 facilities we call the "RCRA Cleanup Baseline," refer
to  http://www.cpa.gov/coiTcctivcaction/facility.hlm.

          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

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If you are relatively new to RCRA corrective action, you can learn more about the program by
referring to the background information at http://www.epa.gov/correctiveaction/backgnd.htm.

What are the general roles and responsibilities of various stakeholders involved with RCRA
corrective action?

EPA Headquarters

EPA Headquarters oversees the national Corrective Action Program through its Office of Solid
Waste and its Office of Site Remediation Enforcement. In general, major responsibilities of these
offices for corrective action include: developing goals for the regional Corrective Action
Programs and monitoring progress toward those goals; developing regulations, policies, and
guidance on implementing corrective action; providing technical and policy assistance; acting as a
liaison to other EPA programs (e.g., Superfund) and Federal Agencies (e.g., Departments of
Defense and Energy) involved in cleanup issues; providing information and testimony to
Congress; and, seeking input from outside stakeholders (e.g., regulated community, public interest
groups, and environmental groups) to consider various and diverse interests.

Lead Regulators

Typically, there will be a "lead regulator" who is the first-line staff person for the government
authority that is responsible for ensuring that a facility implements corrective action as necessary
to meet facility-specific corrective action goals.  The lead regulator could either be a Federal
employee working in an EPA regional office or an employee of a particular State or Territory.
The lead regulator is typically responsible for a variety of activities, including, for example:

   drafting permits, orders, or voluntary agreements;
   reviewing documents developed by the facility;
   recommending facility-specific approaches and, where  appropriate, making decisions
    pertaining to a variety of corrective action issues; and
   ensuring the public has opportunities to provide input on corrective action issues.

EPA Regional Offices

Staff within EPA's 10 regional offices (httg;//www^                                 will
typically be the lead regulator for facilities located in States that have not yet been  authorized (see
discussion below regarding States and Territories) to implement corrective action.  Sometimes,
EPA may continue carrying out lead regulator responsibilities during early stages of a newly
authorized State cleanup program. EPA staff may also be the lead regulators on specific
corrective action enforcement issues (e.g.,  issuing administrative orders) in both authorized and
unauthorized States.

EPA's regional offices are also responsible for overseeing  State programs in situations where the
State has the lead role for implementing corrective action.  Responsibilities of that  oversight role
include, for example: establishing goals, tracking progress, and reporting progress  to EPA

          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

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Headquarters; developing and distributing guidance; contributing to EPA Headquarters initiatives
(e.g., supplying comments on guidance and regulations); conducting training; and providing
facility-specific assistance on technical, policy, and public participation issues.

States and Territories

Staff within State or territorial (http://www.epa.gov/correctiveaction/state.htm) cleanup programs
are typically the lead regulators for overseeing corrective action at particular facility when: (1)
EPA has authorized the State Corrective Action Program, or (2) an EPA regional office has
entered into a "worksharing agreement" with either an unauthorized or authorized State program.
EPA Headquarters supports the variety of creative approaches EPA regions and States/Territories
use to work together toward achieving corrective action goals.

As of September 2001, EPA has authorized 38 States and Territories for facility-wide corrective
action under RCRA 3004(u). EPA's authorization of a State Corrective Action Program is
based on a determination that the State is capable of implementing corrective action equivalently
to EPA, and in a manner consistent with applicable Federal statutes, regulations, and guidance.
These authorized States have the primary responsibility for corrective action at hazardous waste
treatment, storage, and disposal facilities (TSDFs). This responsibility includes making decisions
dealing with the policies addressed in this Handbook. You can refer to
http://www.epa.gov/epaoswer/hazwaste/state/stats/charts/charts2pdf or
http://www.epa.gov/epaoswer/hazwaste/state/stats/maps/coract.pdf  for a current list or map,
respectively,  of the States authorized to implement RCRA corrective action.

Federally Recognized Indian Tribes

In keeping with the EPA Policy for the Administration of Environmental Programs on Indian
Reservations (EPA, 200la), EPA is committed to ensuring that Tribes play an active role in
RCRA corrective action when Tribal rights and interests are at stake. This commitment is clearly
present when EPA personnel serve as lead regulators for a given facility - especially when the
facility is located on Tribal  or Federal lands. However, the commitment is also present when
Tribes are potentially affected by facilities regulated by authorized non-Federal regulators. While
Tribal members are able to  participate as part of the established RCRA public involvement
activities, Tribal governments have a unique status and can play a more significant role.  Although
EPA cannot authorize a Tribe to be a lead regulator, the Agency can enter into cooperative
agreements with the Tribe,  ensure the Tribe has full access for meaningful participation in
corrective action activities,  and give the Tribe's concerns special consideration throughout the
regulatory process.

Facilities

Facilities subject to RCRA  corrective action are responsible for conducting investigations and
cleanups as necessary to protect human health and the environment.  Facilities subject to a permit,
order, or sometimes even a voluntary agreement typically present their recommendations for
investigation and cleanup activities to the lead regulator for review and approval. However, many

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facilities are also proactively conducting investigations and cleanup actions in advance of
oversight6 by a State or EPA regulator.  Additionally, many facilities are also assuming greater
responsibility to involve the public throughout corrective action.

Public

EPA strongly encourages the public to be involved with corrective action to help ensure
protection of human health and their environment. The RCRA statute and EPA's regulations and
detailed guidance describe a variety of public involvement opportunities and activities.  The
following are just some of the actions you (see highlight box) can take to help influence corrective
action decisions:
Find out if a particular facility of interest is on the
list of facilities EPA believes warrant attention in
the next several years
(http://www.epa. gov/correctiveaction/li sts/base_st
a.pdf):

Contact the State or EPA region to identify the
lead regulator and ask for your name to be placed
on mailing lists for notices, fact sheets, and other
documents distributed by EPA, the State, or the
facility; and

Actively participate in public hearings and other
meetings.
                                                             Who is the public?

                                                        The "public" in the context of RCRA
                                                        refers not only to private citizens, but
                                                        also representatives of consumer,
                                                        environmental, and  minority
                                                        associations; trade,  industrial,
                                                        agricultural, and labor organizations;
                                                        public health, scientific, and
                                                        professional societies; civic
                                                        associations; public officials; and
                                                        government and educational
                                                        institutions.
For a more complete list of activities as well as other detailed guidance pertaining to public
participation, you should refer to EPA's 1996 RCRA Public Participation Manual (EPA, 1996d)
available at htt]3^/wjWj:|)a1go^^                                              You can also
contact EPA regional and State offices to determine whether they have additional guidance
concerning public involvement at corrective action facilities.
         To avoid duplicating efforts and to ensure compliance with applicable laws and regulations, EPA
strongly recommends that facilities conducting cleanup actions without oversight by an EPA or State regulator do
so with a clear understanding of applicable State and EPA requirements and implementation guidance. In
particular, facilities should be fully aware of requirements associated with managing remediation waste. For more
information about Federal requirements and implementation guidance associated with remediation waste, you
should refer to htli)://ww^;i)aj|ov/^
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How do the policies in this Handbook apply to State cleanup programs?
EPA expects States to consider this guidance carefully when they have a lead role in implementing
cleanups at RCRA corrective action facilities. However, as mentioned previously, this document
reflects Agency guidance and is not a binding statute or regulation. Therefore, States have
considerable latitude in making decisions that would lead to equivalent levels of protection EPA
would achieve if the Federal Government were implementing the program.  Also, it is extremely
important that Handbook users consult with the appropriate State cleanup program prior to
conducting corrective action to ensure that State requirements and guidance are addressed.  Some
specific examples you should be aware of with regard to State cleanup programs include:

   Some States have their own specific requirements regarding administrative procedures and
    cleanup criteria (e.g., primary and secondary drinking water standards, risk levels, and
    exposure scenarios for closing waste management units); such States may not be able to take
    advantage  of some of the approaches
    described in this Handbook.
  Regulators (both State and Federal)
   typically make investigation and cleanup
   decisions on a case-by-case basis;
   therefore, a particular approach used at
   one facility may be inappropriate at
   another facility.

How is this Handbook organized?

EPA organized this  Handbook to address its
overall implementation strategy for
contaminated groundwater and to summarize
and clarify policies that are often the subject of
questions and confusion. While some topics
deal with broader issues, the primary focus of
this Handbook is on groundwater.
Furthermore, the topics addressed in this
Handbook predominantly were designed to
address facilities undergoing facility-wide
corrective action under 3004(u) and (v), and
3008(h), which were enacted as part of the
Hazardous and Solid Waste Amendments
(HSWA) to RCRA.  However, the policies on  groundwater cleanup levels and point of
compliance address  some questions unique to corrective action at RCRA regulated units7. You
      TOPICS PRESENTED*

    Groundwater Protection and Cleanup
    Strategy
    Short-Term Protection Goals
    Intermediate Performance Goals
    Final Cleanup Goals
    Groundwater Cleanup Levels
    Point of Compliance
    Cleanup Timeframe
    Source Control
    Groundwater Use Designations
    Institutional Controls
    Monitored Natural Attenuation
    Technical Impracticability
    ReinjectionofContaminated
    Groundwater
    Performance Monitoring
    Completing Groundwater Remedies

* See discussion on page x of this overview
section {Qr_ciick_herel to see how EPA intends
to keep this Handbook current.
       7 Regulated Units are defined in 40 CFR 264.90 (available through
hUp:/Avww.acccss.gpo.gov/nara/cfr/cfr-rct.ricvc.html#pagcl')
                                                                             (continued...)

          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                      Overview, Pg. vii

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should be aware that 40 CFR Part 264, Subpart F includes specific groundwater monitoring and
corrective action requirements for RCRA regulated units8.

Note that key topics mentioned within the text are often underlined and "hyperlinked." This
feature allows you to recognize and quickly go to topics that are expanded elsewhere in the
Handbook.

Where do the policies in this Handbook come from?

Most of the topics in this Handbook are already addressed in an existing EPA guidance document,
directive, or memorandum.  We do not intend for this Handbook to replace previous guidance,
but it does reflect EPA's latest thinking on groundwater policies for RCRA corrective action.

You will notice that many of the policies come from Section III of the May 1, 1996 Advance
Notice of Proposed Rulemaking (ANPR; EPA, 1996a). EPA issued the ANPR, in part, to seek
public comment on how to address the proposed regulations for corrective action (55 FR 30798,
July 27, 1990; EPA, 1990c). After considering comments on the ANPR, EPA opted against
finalizing these regulations because, among other things, the Agency decided it was not necessary
for successful implementation of the program. In fact, since a majority of the States and
Territories were already authorized to implement facility-wide corrective action in lieu of EPA,
and several others were seeking authorization, EPA decided that issuing corrective action
regulations would be unnecessarily disruptive. In an October 7,  1999 Federal Register Notice (64
FR 54604; EPA, 1999a), EPA announced its withdrawal of most of the provisions of the 1990
proposed corrective action regulations.  In this notice, EPA stated that rather than issuing a rule
to achieve consistency at all facilities, it would be more appropriate to develop guidance and
training to promote consistency, where appropriate. This Handbook is an example of such
guidance.

The October 7, 1999 notice also stated that Section III of the ANPR should serve as the primary
corrective action implementation guidance.  For that reason, the ANPR is a key reference for
many of the topics in this Handbook.  Section V of the ANPR requested comments on a number
of topics addressed in this Handbook, such as the point of compliance.  This Handbook does not
foreclose further discussion of issues raised for comment in the ANPR, or any other issue
       7(...continued)
as surface impoundments, waste piles, land treatment units, and landfills that received hazardous wastes after July
26, 1982.

       8 The Post-Closure Regulations (EPA, 1998d), 63 FR 56710, October 22, 1999 (available at
http://www.epa.gov/fedrgstr/EPA-WASTE/1998/October/Dav-22/f28221.pdf) provides flexibility for regulators to
replace requirements, associated with regulated units, for groundwater monitoring and corrective action for
releases to groundwater in certain circumstances (see 264.90(f)). EPA encourages States to adopt and seek
authorization for this provision, either separately or as part of the full post-closure rule; but, some States might
choose not to adopt all or parts of this rule. Pending authorization or adoption for this portion of the post-closure
rule, States authorized for corrective action would be able to implement the provision if they could do so as a
matter of State law, and they implemented it in a way that was no less stringent than Federal requirements. For
more detail on authorization for the post-closure rule see the preamble to the rule.

          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                       Overview, Pg. viii

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discussed in this Handbook, and EPA intends to update this Handbook as the Corrective Action
Program continues to evolve.

EPA recognizes that some elements in this Handbook may appear new because of the names used
to describe them. For example, "Intermediate Performance Goals" is a term introduced in this
Handbook; however, it is consistent with the phased approach to corrective action that EPA
emphasized in the ANPR and other guidance going back to the early 1990s (EPA, 199la and
EPA, 1990a).

You may also notice that the choice of words to describe a policy in this Handbook may differ
from the words in the ANPR or another original source of the policy; however, the substance of
the policy remains the same. There are two primary reasons for this difference. First, we wrote
this document in "plain language" and second, the terminology in RCRA is evolving.

"Plain language" uses everyday words, active voice, and shorter sentences. EPA has used  this
style to help make documents easier to read and more understandable. While it may appear at
times that EPA has changed its position on a particular topic because we are using different words
in this Handbook, the policy is actually still the same.  For example, the Handbook recommends
several factors for assessing use, value, and vulnerability of groundwater. These factors are the
same  factors as those listed in the Comprehensive State Groundwater Protection Program
("CSGWPP") Guidance (EPA, 1992a) except we modified the words to meet the goals of plain
language.

Another source of perceived change stems from the maturing of RCRA corrective action
terminology9. As the program has evolved, so have RCRA definitions. For example RCRA's
early guidance, Subpart S (EPA, 1990c) and the ANPR, refer to point of compliance only in the
context of final cleanup. We now formally recognize that the concept of "point of compliance"
can be used in the context of short-term, intermediate,  and final cleanup goals. We made this
change because we recognized that the general definition of point of compliance for groundwater
applies to a variety of situations where regulators require facilities to achieve certain
concentrations of chemicals in groundwater.

Are the policies contained in this Handbook consistent with EPA's other cleanup programs?

The basic approaches described in this Handbook are consistent with EPA's Superfund,
Underground Storage Tank, and Brownfields cleanup programs.  Much of the Handbook is
derived from guidance developed jointly by EPA's cleanup programs (e.g., Use of Monitored
Natural Attenuation  at Superfund, RCRA and Underground Storage Tank Sites (EPA, 1999d)).
This Handbook, therefore, is consistent with EPA's long-standing goal for EPA's cleanup
programs to yield similar remedies in similar circumstances. To learn more about RCRA-
CERCLA coordination issues, you should refer to "Coordination between RCRA Corrective
Action and Closure and CERCLA Site Activities" (EPA, 1996b) available at
http://www.epa.gov/correctiveaction/resource/guidance/gen ca/coordmem.pdf and the RCRA-
       9 Some States may have their own terms to describe similar concepts addressed in this Handbook.

          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                     Overview, Pg. ix

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CERCLA deferral policy found in 54 FR 41004-41006 (October 4, 1989b). For more detailed
information about EPA's Superfund, Underground Storage Tank, and Brownfields cleanup
programs, you can link to their respective Internet Web sites found in AjgendixJL

How will I know that the policies in this Handbook are current?

As necessary, EPA intends to maintain this Handbook as a living document by adding new topics,
new policies, or by changing or clarifying existing policies.  Since this Handbook is guidance,
EPA may make such revisions without public notice.  Therefore, if you are reading a printed copy
of this Handbook, we urge you to access the electronic version available via the Internet at
http://www.epa.gov/correctiveacti on/. The front page of the Internet version will indicate the
most recent date EPA revised the Handbook. Additionally, the top of each policy section includes
the date of the most recent revision. You should compare this date to the Internet version to
ensure that you are reading the Agency's most current guidance.

How can I get further information about the policies in this Handbook?

You can get further information on policies in this Handbook in several  ways.  You can refer to
the references at the end of each policy or to the complete list of references at the end of the
Handbook in           1.  Note that most references provide an Internet Web  address and a
"hotlink" that allows you to directly access the document of interest. You can also get more
information by contacting individuals in EPA regional or State cleanup programs.  If you are
viewing this document electronically and have access to the Internet, you can press the link to
State or EPA program buttons on the interactive button page at the beginning  of the Handbook to
guide you to contacts in EPA or  State  offices. Internet Web links are also provided in
Appendix 2 to help you find more information.  Lastly, if you are uncertain of a meaning of a
term, you can refer to the glossary provided in AjgendjxJi.

What if I have comments on this Handbook?

EPA welcomes public comments on this Handbook at any time and will  consider those comments
in any future revisions.  You can submit your comments to:

                    Corrective Action Programs Branch (mail code 5303W)
                    Permits and State Programs Division
                    Office of Solid Waste
                    US Environmental Protection Agency
                    Ariel Rios Building
                     1200 Pennsylvania Avenue
                    Washington, DC 20460
          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                      Overview, Pg. x

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References:

EPA, 2001a. EPA Indian Policy (July 1 1). Available at
http://www.epa.gov/indian/pdfs/reaffirmindpol01.pdf.

EPA, 2001d. RCRA Cleanup Reforms Round II - Fostering Creative Solutions (EPA/530/F-
01/001, January) . Avail abl e at    ://www. epa.gov/epaoswer/hazwaste/ca/refortn s.htm .

EPA, 1999a. Corrective Action for Solid Waste Management Units at Hazardous Waste
Management Facilities (64 FR 54604, October 7). Available at
http://www.epa.gov/correctiveacti on/resource/guidance/gen_ca/withdrwl. htm.

EPA, 1999b. Safe Drinking Water Act, Section 1429 Groundwater Report to Congress. EPA-
816-R-99-016;  October, 1999. Available at httpi/Zwovi^eja^^
EPA, 1999c. RCRA Cleanup Reforms (EPA/530/F-99/018). For more information, refer to
http://www.epa.gov/epaoswer/osw/factsheet 1 .pdf .

EPA, 1999d. Use of Monitored Natural Attenuation at Superfund, RCRA Corrective Action and
Underground Storage Tank Sites (April 21).  OSWER Policy Directive 9200.4-17P. Available at
http://www.epa.gov/swerustl/directiv/d9200417.htiTi. Other helpful links regarding MNA
available at ktt|3i//w.vw^^                           and
http://www.epa.gov/swerustl/oswermna/mnalinks.htm

EPA, 1998a. RCRA Orientation Manual (EPA/530/R-98/004). Available at
http://www.epa.gov/epaoswer/general/orientat/index.htm.

EPA, 1998d. Standards Applicable to Owners and Operators of Closed and Closing
Hazardous Waste Management Facilities: Post-Closure Permit Requirement
and Closure Process; Final Rule (63 FR 56710).  Available at
http://www.epa.gov/fedrgstr/EPA-WASTE/1998/October/Dav-22/G8221.pdf.

EPA, 1997a. Memorandum from Elliott P. Laws and Steven A. Herman to RCRA/CERCLA
Senior Policy Managers titled, "Use of the Corrective Action Advance Notice of Proposed
Rulemaking as Guidance" (January 17).  Available at
http://vosemite.epa.gov/osw/rcra.nsf/documents/8BF009F9B3672563852566110072DA71.

EPA, 1996a. Advance Notice of Proposed Rulemaking (61 FR 19432, May 1). Available at
http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/Mav/Dav-01/pr-547.pdf. Particularly
relevant pages: 19440-55.

EPA, 1996b. Memorandum from Steven A. Herman and Elliott P. Laws to RCRA/CERCLA
Senior Policy Managers titled, "Coordination between RCRA Corrective Action and Closure and
CERCLA Site Activities" (September 24).  Available at
http://www.epa.gov/correctiveaction/resource/guidance/gen ca/coordmem.pdf.
          Handbook of Groundwater Protection and Cleanup Policies for RCPvA Corrective Action

                                     Overview, Pg. xi

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EPA, 1996d. RCRAPublic Participation Manual (EPA/53O/R-96/007). Available at
http://www.epa.gov/epaoswer/hazwaste/perniit/pubpart/manual.htm. Particularly relevant pages:
2.5-2.7.

EPA, 1992a. Final Comprehensive State Groundwater Protection Program Guidance, EPA 100-
R-93-001. For more information, refer to
http://www.epa.gov/correctiveaction/resource/guidance/gw/csgwpp.htm.

EPA, 199la. Managing the Corrective Action Program for Environmental Results: The RCRA
Stabilization Effort (October 25). Available atJittg://yosemlteeBaji^^


EPA, 1990a. The Nation's Hazardous Waste Management Program at a Crossroads: The RCRA
Implementation Study (EPA/530/SW-90/069).

EPA, 1990c. Corrective Action for Solid Waste Management Units at Hazardous Waste
management Facilities; Proposed Rule (55 FR 30798, July 27).

EPA, 1989b. National Priorities List for Uncontrolled Hazardous Waste Sites - Final Rule
Covering Sites Subject to the Subtitle C Corrective Action Authorities of the Resource
Conservation and Recovery Act (commonly referred to as the RCRA Deferral Policy). Available
in Section V which appears on 54 FR 41004-41006. Available at
http://www.epa.gov/superfund/sites/npl/f891004.htmtf41000.
          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                     Overview, Pg. xii

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                     1. Groundwater Protection and Cleanup Strategy
                                      (September 2001)

 What is EPA's groundwater protection and cleanup strategy for RCRA corrective action?

EPA's groundwater strategy generally is to:

   focus resources at facilities that warrant attention in the near term;
   control short-term threats;
   prioritize actions within facilities to address the greatest risks first; and
   make progress toward the ultimate goal of returning contaminated groundwater to its
    maximum beneficial use1.

This strategy guides regulators  and facilities toward achieving environmental results rather than
following any particular administrative process, and emphasizes clear communication among all
stakeholders.  This strategy is consistent with the phased approaches recommended in past
Agency guidance (EPA, 1990a; EPA,  199la; EPA, 1994b, EPA, 1996a; EPA, 1996c, and others),
and is also consistent with EPA's overall groundwater protection and cleanup goals described
below.
How does this strategy benefit the public,
regulators, and facilities?

This strategy benefits the public because it
promotes early actions and continued progress
toward our overall groundwater protection and
cleanup goals.  Regulators benefit because it
helps them focus their oversight resources on
defining, tracking, and, if necessary, enforcing
measurable milestones.  Facilities benefit because
the strategy helps them plan for investigation and
cleanup actions.

What is EPA's overall goal for groundwater
protection and cleanup?

EPA's overall goal with respect to groundwater
is to prevent  adverse affects to human health and
           Rationale for
   Groundwater Protection and
         Cleanup Strategy

Based on EPA's experience with
environmental cleanups over the past 20
years, it is clear that addressing
contaminated groundwater is challenging
from both a resource and technology
perspective. Therefore, EPA believes its
strategy involving short-term, intermediate,
and final goals provides a realistic
approach that focuses resources on the
greatest threats first and emphasizes
results rather than a particular process.
This strategy emphasizes protection and
cleanup of groundwater by using
meaningful  and measurable milestones, as
well as clear and effective communication.
          EPA recognizes that groundwater serves a variety of uses and purposes, including for example,
drinking water, agricultural irrigation, and discharge to adjacent groundwater and surface water bodies.  As such,
EPA also recognizes that there could be a variety of ways humans as well as ecological receptors (including aquatic
fauna residing in groundwater) can be exposed to contaminated groundwater.  Within the range of reasonably
expected uses and exposures, the maximum beneficial groundwater use is the one that warrants the most stringent
groundwater cleanup levels and approaches.

          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                  Groundwater Strategy, Pg. 1.1

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the environment, which includes protecting the integrity of the nation's groundwater resources,
both now and in the future (EPA, 1991b).  EPA believes that short-term prevention and long-term
cleanup goals are both essential elements of a strategy designed to achieve this overall goal.

With respect to prevention, we should protect groundwater to: (1) ensure that the nation's public
and private drinking water supplies, including those currently used as well as those reasonably
expected to be used, do not cause adverse health effects both in the short term as well as for
future generations; and, (2) avoid negative impacts to ecosystems such as those caused by
contaminated groundwater flowing into surface water (EPA, 1991b).

With respect to cleanup of contaminated groundwater, facilities as well as regulators should
generally: (1) prioritize cleanup activities to limit the risk to human health first; and then, (2)
restore2 currently used and reasonably expected sources of drinking water and groundwater
closely hydraulically connected to surface waters, whenever such restorations are practicable and
attainable (EPA, 1991b).

Stakeholders evaluating appropriate prevention and cleanup strategies should consider use, value
and vulnerability of the groundwater resources, as well as social and economic values.  For more
information regarding this overall goal, refer to "Protecting the Nation's Groundwater: EPA's
Strategy for the  1990's" (EPA, 1991b).  The groundwater protection and cleanup strategy
presented in this Handbook supports EPA's overall groundwater goals.

How should facilities and regulators implement this groundwater protection and cleanup
strategy for RCRA corrective action?

EPA recommends that regulators and facilities implement this strategy  in terms of short-term
protection                                     and JmsLdemSMLgQ
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                                            Final Cleanup Goals
                                        define what it takes to implement
                                           a successful final remedy
           RCRA Corrective Action  Results
                                                           Intermediate Goals
                                                           establish achievable
                                                         milestones especially when
                                                         moving directly from short-
                                                           term to final goals is
                                                           particularly challenging
                Short-Term Goals
            control risks to humans, stop
             groundwater problems from
           getting bigger, focus resources,
             help give clearer picture of
                 challenges ahead
 Figure 1: Relationship between short-term, intermediate, and final corrective action cleanup goals.
ensure that (1) humans are not being exposed to unacceptable levels of contamination, and (2)
contaminated groundwater is not continuing to migrate beyond its current extent4.  EPA measures
these short-term protection      with two environmental indicators5 called "Current Human
Exposures Under Control" and "Migration of Contaminated Groundwater Under Control" (EPA,
1999e). EPA has found that these environmental indicators are proving to have benefits beyond
just demonstrating facilities are meeting these two important goals. For example, clear,
achievable, and meaningful milestones associated with environmental indicators help promote
effective working relationships between stakeholders.  These relationships often foster creative,
results-based approaches that are increasing the overall pace, efficiency and effectiveness of
       3(...continued)
response to the Government Performance and Results Act. Refer to the Short^rgrmj^rotegtion_Goals section of
this Handbook for specific information pertaining to these short-term goals.


       4 Cleaning up contaminated groundwater can be very challenging; therefore, this element of the overall
strategy is designed to prevent existing problems associated with contaminated groundwater from getting worse.


       5 You can learn more about these two indicators at http://www.epa.gov/correctiveaction/eis.litin.

          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                  Groundwater Strategy, Pg. 1.3

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subsequent actions leading to final cleanup goals.  Furthermore, the actions facilities take to
achieve these goals should often help them achieve the final goals. For example, stopping a plume
of contaminated groundwater from getting bigger in the short term limits the extent of the
problem the facility will have to address to achieve final cleanup goals.

With respect to fjnaJjdMnyjijoak for contaminated groundwater, EPA expects6 to return usable
groundwater to its maximum beneficial use wherever practicable within a timeframe that is
reasonable given the particular circumstances of the facility.  EPA recognizes, however, that some
States determine that certain groundwater is either not usable and/or they have no intention to use
it in the foreseeable future7.  For such situations, EPA acknowledges that final cleanup goals such
as source control and long-term plume containment may provide an appropriate level of
protection to human  health and the environment (EPA, 1996c and 1997b). However, prior to
selecting such alternatives, regulators should ensure that other exposures to contaminants in or
from groundwater do not exist and the groundwater is not used for purposes not recognized in,
for example, a "non-use" State designation.  Regardless of the approach, clear final  cleanup goals
are important because they provide the target to which regulators and facilities should focus their
activities.  Establishing clear final  cleanup goals should  also help facilities determine what they will
have to do to implement a successful final remedy.

Intermediate                  can often serve as helpful milestones between short-term and final
cleanup goals. EPA  recognizes, as does the general scientific community (NRC,  1994), that
achieving cleanup goals for contaminated groundwater  can be very challenging. For some
facilities, these challenges can appear to be so insurmountable that moving directly to, for
example, returning all of the contaminated groundwater to its maximum beneficial use diminishes
the ability of regulators and facilities to identify a  realistic path forward. Therefore, for  such
facilities, EPA recommends that facilities and regulators consider developing a series of facility-
specific intermediate performance goals designed to promote continuous progress toward the
        goals.

How should facilities and regulators implement these goals?

EPA recommends that facilities implement short-term protection, intermediate performance, and
final cleanup goals in terms of clearly defined, facility-specific media cleanup objectives. These
objectives typically include elements that  clearly define "what, where, and when." The first
element defines what action the facility should conduct. The second element defines where the
specific action should take place.  The third element defines when the facility should implement
and complete an action.
       6 See glossary for definition of "remedy expectations" used in the context of the RCRA Corrective Action
Program.

       7 EPA recognizes that most States classify the majority of their groundwater as potential sources of
drinking water. Refer to the Final Remedy, Point of Compliance and Groundwater Use Designation sections of
this Handbook for further discussion on final cleanup goals, the role of groundwater use in the RCRA Corrective
Action Program, and additional guidance concerning groundwater use decisions and exposures associated with
various uses/purposes of groundwater.

          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                  Groundwater Strategy, Pg. 1.4

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Along with defining "what, where, and when," EPA also recommends that facilities and regulators
describe actions in terms of "who, why, and how." Describing "who" performs an action helps
communicate to the public the different roles and responsibilities of the facility and the regulator.
Describing "why" provides the opportunity to explain the relationship between particular actions
and how they help achieve short-term, intermediate, or final goals. And lastly, describing "how"
ensures that stakeholders understand the techniques and approaches that a facility will use to
implement an activity.

Implementing goals in terms of "what, where, and when" is not a new approach to corrective
action but rather a clarification of "cleanup objectives" as described in the May 1, 1996 Advance
Notice of Proposed Rulemaking (ANPR - EPA, 1996a; page 19449).  For example, to measure
achievement of final groundwater cleanup goals, the ANPR described final cleanup objectives in
terms of (1) groundwater cleanup levels, (2) the point of compliance, and (3) cleanup timeframes8
(see EPA, 1996a - page 19449).  For such final groundwater remedies, groundwater cleanup
levels represent the "what," point of compliance represents the "where," and cleanup timeframes
represent the "when" associated with implementing a groundwater remedy and estimates on how
long it would take to achieve the final cleanup goals.

EPA encourages facilities and regulators to describe short-term, intermediate,  and final cleanup
goals in terms of "what, where, when, who, why, and how" to enhance and clarify  communication
among all stakeholders.

References:

EPA, 1999e. Interim Final Guidance for RCRA Corrective Action Environmental Indicators
(February 5).  Available at htlj^/w^wjgga^^
EPA, 1997b.  Rules of Thumb for Superfund Remedy Select on (EPA/540/R-97/0 13).  Available
at irtt]3://wawj^^                                        Particularly relevant page: 17.

EPA, 1996a.  Advance Notice of Proposed Rulemaking (61 FR 19432, May 1).  Available at
http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/Mav/Dav-01/pr-547.pdf. Particularly
relevant pages: 19440-55.

EPA, 1996c.  Presumptive Response Strategy and Ex-Situ Treatment Technologies for
Contaminated Groundwater at CERCLA Sites (EPA/540/R-96/023, October). Available at
http://www.epa.gov/superfund/resources/gwguide/index.htm.  Particularly relevant pages: 15-17.
        Previous guidance (EPA, 1996a) referred to "Cleanup timeframes" as compliance timeframes.

          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                Groundwater Strategy, Pg. 1.5

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EPA, 1994b. The RCRA Corrective Action Plan (EPA/520/R-94/004, May).  Available at
http://www.epa.gov/correctiveacti on/resource/guidance/gen_ca/rcracap.pdf.

EPA, 199la. Managing the Corrective Action Program for Environmental Results: The RCRA
Stabilization Effort (October 25). Available atjitt]3://yo^^
d8382df2d09b64668525652800519745/27dlbaa5cldbb8f38525670fD06be76d?OpenDocument.

EPA, 1991b. Protecting the Nation's Groundwater:  EPA's Strategy for the 1990's.  Office of the
Administrator.  Washington,  D.C. Excerpts available at
http ://www. epa. gov/epaoswer/hazwaste/ca/resource/gui dance/gw/gwstr.htm

EPA, 1990a. The Nation's Hazardous  Waste Management Program at a Crossroads: The RCRA
Implementation Study (EPA/530/SW-90/069).

NRC, 1994.  Alternatives for Ground Water Cleanup I Committee on Ground Water Cleanup
Alternatives, Water Science and Technology Board, Board on Radioactive Waste Management,
Commission on Geosciences, Environment, and Resources, National Research Council.  National
Academy Press, 1994. Available at httBi//wwjQia|^^
          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                Groundwater Strategy, Pg. 1.6

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                2. Short-Term Protection (Environmental Indicator) Goals
                                     (September 2001)

What are EPA's short-term protection goals for groundwater?

EPA's short-term goals associated with groundwater1 are to ensure that (1) humans are not being
exposed to unacceptable levels of contamination, and (2) contaminated groundwater is not
migrating above levels of concern2 beyond its current extent (EPA, 1999e).
How does EPA monitor progress toward these
goals?

EPA developed two facility-wide "environmental
indicators" to help monitor progress in achieving
short-term protection goals on a national basis.
The two environmental indicators (Els) are called
"Current Human Exposures Under Control"
and "Migration of Contaminated Groundwater
Under Control."  EPA commonly refers to these
two environmental indicators as the Human El
and Groundwater El, respectively.  In general
terms, these measures indicate current
"environmental conditions"-- whether people are
currently being exposed to environmental
contamination at unacceptable levels  and
whether any existing plumes of contaminated
groundwater are getting larger or adversely
affecting surface water bodies. EPA is specifically
tracking progress in meeting these environmental
indicator goals at 1,714 facilities that EPA
considers to warrant attention in the near term; you
http://www.epa.gov/epaoswer/hazwaste/ca/facilitv.
             Rationale for
      Short-Term Protection Goals

   The highest short-term priorities of the
   RCRA Corrective Action Program are to
   make sure that people are not being
   exposed to unacceptable levels of
   contaminants and to prevent further
   contamination of our Nation's groundwater
   resources. While final remedies remain
   the RCRA Corrective Action Program's
   long-term objective, EPA developed two
   environmental indicators to focus efforts
   on early risk reduction, risk
   communication, and resource protection.
   This focus on short-term protection goals
   enables the Agency to achieve an
   increased overall level of protection  by
   implementing a greater number of actions
   across  many facilities.
can see this list of facilities at
htm.
EPA is using these two environmental indicators to monitor progress in response to the
Government Performance and Results Act (GPRA - see
http://www.epa.gov/ocfo/planning/gpra.htm). EPA's specific GPRA goals for these indicators
are as follows: By 2005, the States and EPA will verify and document that 95 percent of the
       1 EPA's short-term goals apply to all contaminated media, not just groundwater. For example, our short-
term goals associated with protecting humans include ensuring that humans are not being exposed to unacceptable
levels of contaminants in soils. However, we focus here on short-term goals associated with groundwater
contamination because the focus of this Handbook is on groundwater.

       2 Levels of concern are concentrations of each contaminant in groundwater appropriate for the protection
of the groundwater resource typically based on its maximum beneficial use.

          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                   Short-Term Goals, Pg. 2.1

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GPRA baseline facilities will have "Current Human Exposures Under Control" and 70 percent will
have "Migration of Contaminated Groundwater Under Control." You can see the progress
toward achieving these goals at http://www.epa.gov/epaoswer/hazwaste/ca/facility/stofrcra.htmtfeis

Who evaluates and determines whether a facility meets environmental indicator goals?

The lead regulator makes the actual environmental indicator determination. However, EPA,
States, or the facility (or the facility's consultant) can conduct an environmental indicator
evaluation. EPA developed environmental indicator forms to guide regulators and facilities
through this evaluation.  In some cases, facilities have voluntarily filled out environmental
indicator forms to "self-assess" their status and have even initiated  activities on their own to meet
the environmental indicators. You can obtain these environmental  indicator forms at
http://www.epa.gov/correctiveaction/eis.htm.

How should regulators and facilities evaluate environmental indicators?

EPA issued detailed guidance (EPA, 1999e) to help those conducting environmental indicator
evaluations; you can access that guidance at http://www.epa.gov/epaoswer/hazwaste/ca/eis.htm.
The guidance includes a series of questions and a flow chart to help arrive at one of the following
three possible outcomes: YES, the facility has achieved an environmental indicator goal; NO, the
facility has not achieved an environmental indicator goal; or, IN, there is insufficient information
available to determine whether or not a facility has achieved an environmental indicator goal.

How does a facility get to YES?

For the Current Human  Exposures Under Control environmental indicator, a facility should be
able to demonstrate that there are no unacceptable human exposures to contamination3 that can be
reasonably expected under current land and groundwater use conditions. For the Migration of
Contaminated Groundwater Under Control environmental indicator, a facility should be able to
demonstrate that contaminant plumes throughout the facility are not continuing to get larger4 or
continuing to negatively impact adjacent  surface water bodies, and  that the facility will monitor
groundwater to verify whether the environmental indicator determination remains valid.

Facilities typically meet these goals either by: (1) demonstrating that no cleanup actions are
warranted; (2) taking  short-term cleanup  actions sometimes referred to as interim remedial
       3 Contamination in this context describes media containing contaminants in any form (e.g., non-aqueous
phase liquids, dissolved in water, vapors, and solids) that are subject to RCRA corrective action and present in
concentrations in excess of appropriately protective levels of concern.

       4 A plume getting larger typically refers to groundwater contamination above levels of concern moving
beyond a previously defined furthest three-dimensional extent of the contaminant plume.

          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                   Short-Term Goals, Pg. 2.2

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measures, interim measures, interim actions, or stabilization5 measures; or (3) implementing a final
remedy that also meets short-term cleanup goals.

How should facilities and regulators develop facility-specific short-term protection goals?

Facilities and regulators should work together, with the input from the public as appropriate, to
develop clearly defined objectives focused on meeting short-term protection goals. As described
in the GromidwMer_roteMm_and_Cleanup_Strategy_ in this Handbook, EPA recommends these
objectives be expressed in terms of what actions  the facility will take, and where and when the
facility will take the action.

If some form of cleanup action is needed to achieve the Current Human Exposures Under Control
indicator, stakeholders should understand:

   What action the facility will take to ensure that there are no  current or near-term future
    unacceptable exposures to contaminated groundwater. For example, the facility might
    provide for alternative water supplies to eliminate exposure due to contaminated groundwater
    in residential wells.

   Where the facility will implement an action to eliminate unacceptable human exposures to
    contamination from groundwater.

   When the facility will eliminate all unacceptable human exposures to contaminants from
    groundwater.

To  achieve the Migration of Contaminated Groundwater Under Control indicator when
contaminants are present in groundwater above levels of concern, stakeholders should
understand:

   What the levels of concern are for defining the current limit  of the groundwater contaminant
    plume.

   Where the current three-dimensional limit of the groundwater contaminant plume is, as
    defined by the levels of concern, and where the facility will monitor groundwater to
    demonstrate that they achieved and will continue to achieve the prevention of further
    migration of contaminated groundwater above levels of concern.

   When the facility will be able to demonstrate that the groundwater contaminant plume is not
    migrating above levels of concern.
       5 The term stabilization used in this context refers to "stabilizing" a situation so that, for example, the
contamination does not represent unacceptable threats or does not continue to spread. Stabilization used in this
context does not refer to engineered treatment used to "solidify" wastes although such technologies could be used
as a stabilization action. For more information on the RCRA Corrective Action Program's stabilization initiative,
refer to EPA, 1991a and EPA, 1996a.

           Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                   Short-Term Goals, Pg. 2.3

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If a cleanup action is needed to achieve a particular goal, EPA believes all interested stakeholders,
particularly the public, will benefit from a clear understanding of who is taking the action(s), why
they are taking the action(s), and how they will implement the action. For example, all interested
members of the public might not realize that the facility, rather than the government, is responsible
for implementing a particular cleanup. Furthermore, communicating "why" can help the public
understand the reasoning behind selecting, for example, a particular treatment technology such as
a subsurface treatment wall as compared with a pump-and-treat approach to clean up
contaminated groundwater. Communicating "how" can help educate stakeholders about the
particular steps involved with implementing a remedy.  For example, during installation of a
subsurface treatment wall, stakeholders may be interested in how contaminated soils and other
contaminated media will be managed.

How should facilities and regulators consider groundwater use when evaluating "Current
Human Exposures Under Control?"

The individual conducting the environmental indicator evaluation should first consider whether
there is any current human exposure to contaminated groundwater. This determination relies on
actual current conditions rather than on a groujidwateruse_designation or its potential uses. In
making this environmental indicator determination, the regulator should consider all direct and
indirect ways humans could currently be exposed to contaminated groundwater. Some examples
of direct routes of exposure include drinking  contaminated groundwater or having skin come into
contact with contaminated groundwater from bathing. Examples of indirect exposure include
breathing contaminated vapors entering buildings from underlying contaminated groundwater, and
ingesting sediments, surface water, or fish that are  contaminated from groundwater discharging to
surface water.

How should facilities and regulators evaluate the "Migration of Contaminated Groundwater
Under Control" indicator?

The individual conducting the evaluation should first be reasonably confident that the furthest
three-dimensional boundary of the groundwater contaminant plume(s) is defined using an
appropriate number and location of groundwater monitoring wells (or some other devices
approved by the regulator to assess groundwater quality)6.  To  achieve a YES determination, the
evaluator should be able to demonstrate that the plume is not continuing to expand above
contaminant-specific levels of concern.  The evaluator should base this determination on whether
the contaminant concentrations found in the groundwater near the outer perimeter of the plume
remain below the levels of concern over time. Levels of concern used for this indicator would
commonly be the groundwatgr_cieai>upjeygls developed to be  consistent with the groundwater
use            and considering other current routes of exposure from contaminated
groundwater. However, early in corrective action,  regulators could be evaluating environmental
        Facilities and regulators typically define a plume boundary based on estimating a division between
where groundwater is contaminated above and below levels of concern. They commonly make this estimate based
on professional interpretation (often with the aid of computer software) of chemical analyses of groundwater
samples collected from properly located monitoring wells or other monitoring devices.

          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                  Short-Term Goals, Pg. 2.4

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indicators prior to designating groundwater use or developing final cleanup levels. In such
situations, regulators often use readily available screening levels (e.g., drinking water standards)
to define a plume boundary.  Generally, drinking water standards will be acceptable to define the
boundary of a plume when evaluating this environmental indicator unless more stringent levels are
needed based on other actual exposures to contaminated groundwater.

Can a facility achieve the "Migration of Contaminated Groundwater Under Control"
indicator when the plume extends beyond the facility boundary?

EPA typically does not differentiate on-site contaminated groundwater from off-site contaminated
groundwater as a factor in determining whether a facility achieves the groundwater environmental
indicator (EPA, 1999e). The primary intent of this indicator is to demonstrate that groundwater
problem is not expanding, regardless of whether the contamination is on-site or off-site.
However, cleanup of the off-site plume will often be a high priority and may be an appropriate
            performance     because facilities typically have less ability to control exposures
outside the boundary of their property.

Can a facility achieve the "Migration of Contaminated Groundwater Under Control"
indicator when contaminated groundwater discharges to surface water?

According to EPA guidance (EPA, 1999e), a facility could potentially achieve this indicator if the
regulator determines that the discharge of contaminated groundwater into surface water is
currently acceptable. "Currently acceptable" in this context means that the current discharge of
contaminated groundwater into surface water does not cause unacceptable impacts to surface
water, sediments, or ecosystems in ways that should not be allowed to continue until the facility
implements a remedy selected to achieve
Appropriate levels for surface water protection should generally be based on the designated uses
of the impacted surface waters and available Federal water quality criteria or State water quality
standards for any of the contaminants found in the discharging ground water. Regulators and
facilities should also evaluate possible adverse effects of the groundwater discharge for actual
pathways of exposure to humans or aquatic life.  Based on these evaluations, facilities and
regulators should verify whether available generic cleanup values will protect the surface water
and its sediments. If generic cleanup values are not available, facilities should propose facility-
specific groundwater cleanup levels designed to prevent appropriate water quality standards in the
surface water body from being exceeded, and to prevent unacceptable risks to human health or
the environment.

For additional information concerning groundwater/surface water interaction, contact the State
cleanup program because many  States have specific groundwater cleanup levels based on
protecting surface water bodies. Links to State cleanup programs are available at
    : //www. epa . gov/correcti veacti on/state .    . Additional resources you may find helpful
include the Proceedings of the Groundwater/Surface Water Interaction Workshop (EPA, 2000c)
available at http://www.epa.gov/ti o/tsp/download/gwsw/gwsw_partl.pdf and information
regarding sediments available at http://www.epa.gov/OST/cs/.  Facilities or regulators evaluating
environmental indicators for situations where contaminated groundwater is entering surface water

          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                   Short-Term Goals, Pg. 2.5

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should also consider Total Maximum Daily Loads (TMDLs7) for the receiving surface water;
additional information concerning TMDLs is available at http://www.epa. gov/owow/tmdl/.

Will an environmental indicator evaluation require additional investigation?

The act of evaluating environmental indicators should not result in additional investigations
beyond those that would typically be conducted to support facility-wide corrective action.
However, pursuing environmental indicators may result in collecting information earlier than
when a facility was  planning to conduct a more comprehensive, site-wide investigation needed to
support, for example, final cleanup goals.

Do facilities need to perform additional investigation or cleanup,  once they achieve the
environmental indicator goals?

Achieving the environmental indicator goals is an important milestone but does not relieve a
facility from meeting other investigation objectives or from meeting  any facility-specific
                             and finajj^^iiii^goals. The facility will often need to conduct
further investigation to support evaluation and selection of final remedies.  Furthermore, the
facility may need to conduct remedial actions that might be outside  the scope of these two
environmental indicators to achieve other short-term, intermediate, and final goals for
groundwater (e.g., returning contaminated groundwater to its maximum beneficial use).

Do facilities need to control sources to meet the environmental indicator goals?

Source control may not always be necessary to meet the environmental indicator goals. For
example, a facility could meet the Migration of Contaminated Groundwater Under Control
indicator, without controlling an original source, by installing a pump-and-treat system designed
to stop the further migration of the outer fringes of a plume of contaminants dissolved in
groundwater. However, there  are many instances where source control would be essential to
meeting these goals. For example, source control of some kind would typically be necessary to
achieve the Human  Exposures Under Control indicator if there were direct human exposures to
the source material, such  as an old disposal area with no covering and unrestricted access.  Two
examples of situations that would typically warrant source control to achieve the Migration of
Contaminated Groundwater Under Control indicator would be if a non-aqueous phase liquid8
(NAPL) was directly discharging to a stream,  or where a mobile NAPL plume was migrating
faster (and farther) than the dissolved contaminants moving with groundwater. Source control is
often still desirable in many circumstances because minimizing any further releases into the
environment is often easier to manage than trying to clean up contaminants after they have spread.
Furthermore, to meet fmal_cleanup_gg_als, EPA expects that facilities will need to control or
       7 A TMDL is a calculation of the maximum amount of a pollutant that a water body can receive and still
meet water quality standards, and an allocation of that amount to the pollutant's sources.

       8 Additional information and reports concerning NAPL contamination is available at
http://www.epa.gov/oerrpage/superfiind/resources/gwdocs/non aqu.htm  See also EPA, 1995b and 1994c.

          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                   Short-Term Goals, Pg. 2.6

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eliminate surface and subsurface sources of groundwater contamination as necessary to protect
human health and the environment.

Are these two environmental indicators the only short-term protection goals facilities should
consider?

EPA chose these two indicators as significant short-term protection goals to track on a national
basis. However, facilities may need to take other short-term actions to protect receptors when
site conditions warrant. For example, a facility might need to take action to protect ecological
receptors that are currently exposed to facility contaminants. Furthermore, EPA's focus on the
two environmental indicators should not deter facilities from taking any other short-term actions
to protect human health or the environment, or from taking early action to prevent environmental
problems from getting worse.

References:

EPA, 2000c.  Proceedings of the Ground-Water/Surface-Water Interactions Workshop
(EPA/542/R-00/007, July). Available at
http://www.epa. gov/ti o/tsp/download/gwsw/gwsw_part 1 .pelf,
http://www.epa.gov/tio/tsp/download/gwsw/gwsw_part2.pdf. and
http://www.epa.gov/tio/tsp/download/gwsw/gwswjart3.pdf.

EPA, 1999e.  Interim Final Guidance for RCRA Corrective Action Environmental Indicators
(February 5).  Available at    ://www.epa.gov/epaoswer/osw/ei_guida.pdf.

EPA, 1996a.  Advance Notice of Proposed Rulemaking (61 FR 19432, May 1).  Available at
http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/Mav/Dav-01/pr-547.pdf. Particularly
relevant pages describing the stabilization initiative and environmental indicators on 19436-37,
and discussion of interim measures on page 19446-47.

EPA, 1995b.  Groundwater Issue: Light Non-Aqueous Phase Liquids (EPA/540/S-95/500).
Available at http://www.epa.gov/ada/download/issue/lnapl.pdf.

EPA, 1994c.  DNAPL Site Characterization (EPA/540/F-94/049).  Available at
http://www.epa.gov/oerrpage/superfund/resources/gwdocs/dnapl.pdf.

EPA, 199la.  Managing the Corrective Action Program for Environmental Results:  The RCRA
Stabilization Effort (October 25). Available atJvtt^Vy^sgrnite1epa.goy/_osw/jgrajisf/
          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                  Short-Term Goals, Pg. 2.7

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                           3. Intermediate Performance Goals
                                     (September 2001)

What are intermediate performance goals for groundwater?

Intermediate performance goals are facility-specific environmental conditions or measures that
demonstrate progress towards achieving the final cleanup goals.  EPA refers to these goals as
"intermediate" because actions taken to meet these goals will typically occur after a facility
achieves its short^tgrm^rotectioiLgQals. but before
they achieve all             goals.  EPA
encourages regulators and facilities to establish
intermediate goals when they can use such goals to
demonstrate progress toward the ultimate final
cleanup goals and:
   help focus resources,
   improve environmental conditions, or
   enhance performance of a cleanup action.

Achieving intermediate performance goals does not
relieve a facility from meeting any facility-specific
investigation or cleanup actions necessary to
achieve final_cleanup_gQals.

How can intermediate performance goals help
me?
          Rationale for
   Intermediate Performance
              Goals
EPA's approach for intermediate
performance goals recognizes that for
many sites, using a "phased-approach" is
often appropriate for complex
ground water cleanups.  Establishing site-
specific intermediate performance goals
provides a mechanism to prioritize work
and measure progress toward achieving
long-term goals.
Intermediate performance goals help facilities, regulators, and the public see and document
progress towards meeting final cleanup goals.

Intermediate performance goals also help to prioritize work necessary to meet the final cleanup
goals.  Facilities may use intermediate performance goals to outline a phased approach toward the
cleanup. A phased approach allows a facility to use information obtained from previous phases to
plan and refine subsequent work (EPA, 1996a and EPA, 1996c). Facilities can also direct
response actions to achieve intermediate performance goals at high-priority areas of the facility
first, and address lower priority areas at a later time.

Intermediate performance goals may also serve to bridge differences in opinion between
regulators, facilities, and the public on the scope of environmental response at a facility. There
may be consensus on intermediate actions that facilities can take that  provide significant
environmental benefit while stakeholders continue to negotiate issues associated with
goals.
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                                  Intermediate Goals, Pg. 3.1

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Are intermediate performance goals appropriate for all facilities?

No. For example, intermediate performance goals may not be appropriate for those situations
where facilities can achieve final cleanup goals in a relatively short period of time (e.g., months to
several years).

When should facilities and regulators establish intermediate performance goals?

Regulators and facilities should establish intermediate performance goals as part of a final remedy
to create milestones of environmental progress. However, where significant uncertainties exist as
to what a final remedy should involve and could achieve, EPA believes it may be appropriate to
establish and strive to achieve intermediate performance goals prior to a formal evaluation and
selection of a final remedy. In this latter situation, stakeholders could use the information gained
from implementing actions to achieve the intermediate performance goals to help improve the
effectiveness and efficiency of the final remedy.

How should facilities and regulators develop facility-specific intermediate performance goals?

Facilities and regulators should work together, with the input from the public as appropriate, to
develop clearly defined objectives focused on meeting intermediate performance goals. As
described in the Groundwater Protection and Cleanup         in this Handbook, EPA
recommends these objectives be expressed in terms of what actions the facility will take, and
where and when the facility will take the action.

If some form of cleanup action is needed to achieve an intermediate performance goal,
stakeholders should understand:

   What the specific goals are and what actions the facility will take to achieve those goals.

   Where the facility will implement an action and/or where the facility will measure to
    determine if the action has been successful.

   When the facility can implement a remedy and achieve facility-specific intermediate goals
In addition to these three elements, EPA believes stakeholders should also clearly understand who
is taking the responsibility for implementing an action designed to achieve a particular
intermediate performance goal, why they are taking the action, and how they are going to
implement the action.

What are some examples of intermediate performance goals?

Some examples of intermediate performance goals include: source control (e.g., various
combinations of removal, treatment, and containment), plume size reduction,  cleaning up off-site
plumes, prioritizing work, and remedy performance enhancements.  For example:
          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                  Intermediate Goals, Pg. 3.2

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Source control:  A facility is pumping and treating groundwater to prevent a contaminant plume
from migrating off-site. The site investigation identifies an area of soil contaminated with
chlorinated solvents that appears to be contributing to the groundwater contamination.  The
facility estimates if they clean up the contaminated soil (using soil vapor extraction) to a particular
level as an intermediate performance goal, monitored natural attenuation1 will have a greater
likelihood of being able to address the remaining groundwater contamination.

Cleaning up off-site plumes: A facility has an off-site plume and had to install vapor recovery
systems under individual homes to eliminate exposures to indoor air impacted by contaminated
groundwater. By focusing on achieving cleanup levels in groundwater off site as an intermediate
performance goal, the facility is able to reduce its long-term liabilities associated with relying
solely  on the in-home vapor recovery systems to ensure protection.

Prioritizing work: A large industrial facility identifies several areas that need to be addressed,
but has limited resources available for cleanup.  The regulator and facility work together to
establish a sequence of intermediate goals directed toward achieving the final cleanup goal.  In
establishing the sequence of work to be conducted, the regulator and facility consider the relative
risk and/or potential environmental harm associated with the current contamination in the different
areas.  They then can establish a series of intermediate goals with different cleanup timeframes for
the different areas based on the relative risk.  The result is that the most environmentally
significant areas are cleaned up first, and  the facility is able to budget resources efficiently.

Why is it important to establish intermediate performance goals on a facility-specific basis?

Intermediate performance goals should be specific to the environmental problem(s) that need to
be solved at a facility.  The environmental benefit of a particular intermediate performance goal
will vary for different facilities based on the type of contaminants, environmental receptors,
anticipated timing of groundwater use, and the current extent of contamination, among other
factors. Therefore, EPA cautions stakeholders against automatically applying an intermediate
performance goal that makes sense at one facility to another facility since no two facilities are
exactly alike. For example, controlling a source of contamination at one facility as an
intermediate performance goal may be appropriate, while at another facility, controlling a source
might be more  appropriately addressed as part of a short-term or final cleanup action.
       1 For more information, refer to the Monitored Natural Attenuation section of this Handbook and EPA,
1999d.

          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                   Intermediate Goals, Pg. 3.3

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References:

EPA, 1999d.  Use of Monitored Natural Attenuation at Superfund, RCRA Corrective Action and
Underground Storage Tank Sites (April 21).  OSWER Policy Directive 9200.4-17P. Available at
http://www.epa.gov/swerustl/directiv/d9200417.htm. Other helpful links regarding MNA
available at http;//_w_w_w_^^                        	and
http://www.epa.gov/swemstl/oswermna/mnalinks.htm.

EPA, 1996a.  Advance Notice of Proposed Rulemaking (61 FR 19432, May 1).  Available at
http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/May/Day-01/pr-547.pdf. Particularly
relevant page (pertaining to phasing remedies):  19441.

EPA, 1996c.  Presumptive Response Strategy and Ex-Situ Treatment Technologies for
Contaminated Groundwater at CERCLA Sites (EPA/540/R-96/023, October). Available at
http ://www. epa. gov/superfund/resources/gwgui de/i ndex. htm.
          Handbook of Groundwater Protection and Cleanup Policies for RCPvA Corrective Action

                                 Intermediate Goals, Pg. 3.4

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                                    4. Final Cleanup Goals
                                        (September 2001)
What are EPA's final cleanup goals for
corrective action?


EPA recommends that regulators and facilities use
the following three threshold criteria1 as general
goals for final cleanup and as screening tools for
potential remedies, including final groundwater
remedies:


1.   Protect human health and the environment2;


2.   Achieve media cleanup objectives3; and


3.   Control the source(s) of release so as to reduce
    or eliminate, to the extent practicable, further
    releases  of hazardous waste or hazardous
    constituents that may pose a threat to human
    health  and the environment4.
           Rationale for
       Final Cleanup Goals

This policy on final cleanup goals for
contaminated groundwater is important to
protect human health and the
environment by ensuring the short- and
long-term availability of our Nation's
groundwater resources and by preserving
and protecting hydraulically connected
surface waters and their ecosystems.
EPA's policy on final cleanup goals states
that the situations where long-term
containment remedies are acceptable
should generally be limited to when
cleaning  up contaminated groundwater is
technically impracticable, or to where
EPA or the State designates the
groundwater as having no use or value.
          The 1996 ANPR lists four remedy threshold criteria. EPA believes that the fourth criterion "complying
with applicable standards for waste management" is not necessary since complying with applicable waste
management standards is automatically required under existing RCRA Subtitle C and D regulations.  For more
information about Federal requirements and implementation guidance associated with remediation waste, refer to
htip://www.cpa.gov/cpaoswcr/lia/wastc/ca/guidancc.him#Rcmcdiation Waste


        2 Protecting the environment means, among other things, considering the ecological setting at and around
a facility in evaluating and selecting final remedies. This is especially important for groundwater remedies where
contaminated groundwater discharges into surface water.


        3 Media cleanup objectives for final remedies typically includes the more specific concepts of media
cleanup levels. BMnts.of.comp!iaiicc, and clcanupjimcfjramcs.  In previous guidance (EPA, 1996a - page 19449),
EPA referred to media cleanup objectives as media cleanup standards; we now use media cleanup objectives to
avoid confusion over the term "standard" that is often associated just with numeric values.


        4 EPA expects (see glossary for a definition of "remedy expectations") facilities to control or eliminate
surface and subsurface sources of groundwater contamination as necessary to protect human health and the
environment. In controlling sources, EPA prefers approaches that lead to permanent reductions in toxicity,
mobility, or volume. Additionally, EPA expects that treatment will be used to address source materials considered
to be "principal threats," i.e., materials that are highly toxic or highly mobile that generally cannot be  reliably
contained or would present a significant risk to human health or the environment should exposure occur.  A
                                                                                    (continued...)

           Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                    Final Cleanup Goals, Pg. 4.1

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Protecting human health and the environment is the mandate from the RCRA statute and
regulations; therefore, it is appropriate to include this goal as the first and overarching threshold
criterion for final RCRA corrective action remedies. Use of this threshold criterion also serves to
ensure that remedies include protective activities (e.g., providing an alternative drinking water
supply) that would not necessarily be needed to achieve the other recommended criteria.
However, EPA also recommends that remedies meet the second (achieving media cleanup
objectives) and third (controlling sources) criteria as a means to demonstrate progress toward
achieving the overall mandate to protect human health and the environment.

What are EPA's final cleanup goals for groundwater?

EPA expects final remedies to return "usable" groundwaters to their maximum beneficial use5,
wherever practicable, within a timeframe that is reasonable given the particular circumstances of
the facility  (EPA, 1996a).  Facilities and regulators should establish specific media cleanup
objectives that will meet this expectation.  EPA also expects final remedies to control or eliminate
surface and subsurface sources of groundwater contamination. In determining appropriate and
protective media cleanup objectives for groundwater remedies, stakeholders should consider the
use, value,  and vulnerability of the groundwater resource, and all potential pathways that could
result in human or ecological exposure to contaminants in or from groundwater.

When does EPA consider groundwater "usable" for selecting final cleanup goals?

EPA recognizes that "usable" groundwater may serve a variety of purposes.  Common purposes
of groundwater include, for example, drinking water, agricultural irrigation, car washes, and
manufacturing. Groundwater also has less formally acknowledged purposes such as replenishing
adjacent aquifers or surface water bodies. Regulators should consider purposes such as these to
acknowledge whether groundwater is "usable"  and to determine appropriate cleanup goals. For
more guidance regarding groundwater use, see the groundwater use            policy  in this
Handbook.

What if groundwater is not usable?

For groundwater formally designated by EPA or a State6 as having no use or value, final cleanup
goals  such  as source control and/or long-term containment, rather than meeting a particular
cleanup level throughout the groundwater, may be acceptable as long  as the remedy protects
       4(...continued)
complete list of EPA's general expectations for final remedies is available in EPA, 1996a (page 19448).

       5 Within the range of reasonably expected uses and exposures, the maximum beneficial groundwater use
is the one which that warrants the most stringent groundwater cleanup levels and approaches.

       6 EPA recognizes that most States classify the majority of their groundwater as potential sources of
drinking water.

          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                  Final Cleanup Goals, Pg. 4.2

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human health and the environment7. However, stakeholders should consider all
potential pathways8 that could result in human or ecological exposure before deciding that not
cleaning up the entire groundwater plume is acceptable.

Even in those instances when groundwater is not usable, final remedies should still achieve the
three threshold criteria described above. In addition, EPA recommends that regulators ensure
that:  (1) the non-use designation is appropriate; (2) humans or ecological receptors would not be
exposed to contaminants in or from groundwater9; (3) the approaches used to achieve the final
cleanup goals would be effective in the long term; (4) they consider the potential impacts to
human health or the environment if the remedy were to fail; and (5) the facility has the financial
ability to maintain the remedy for as long as necessary to ensure protection of human health and
the environment10.

When significant uncertainties exist regarding the reliability of a containment system, regulators
should strongly consider establishing the goal of cleaning up the groundwater so that relying on
long-term containment is not be needed to ensure protection.

What if returning  contaminated groundwater to its maximum beneficial use is not technically
practicable?

Where returning contaminated groundwater to its maximum beneficial use is not technically
practicable, EPA generally expects facilities to prevent or minimize the further migration of a
plume, prevent exposure to the contaminated groundwater, and evaluate further risk reduction.
For more information on what to do if returning contaminated groundwater to its maximum
beneficial use is technically impracticable, see the policy on tedrnkMbLJIBI^^         in this
Handbook.
       7 In the Superfund Program, final cleanup goals or objectives that are not associated with returning
contaminated groundwater to its beneficial use are often referred to as "non-restoration" goals or objectives (EPA,
1997b).

       8 Refer to the Groundwaterj^gam        Section of the Handbook for guidance concerning potential
ways humans or ecologic receptors could be exposed to contaminated groundwater.

       9 For example, humans could be exposed to indoor air contamination resulting from contaminants that
volatilize from underlying groundwater. Further, aquatic organisms living within the groundwater or within
surface water to which groundwater discharges, could be exposed to unacceptable levels of contamination.

       10 RCRA 3004(u) and 40 CFR 264.101(b) require that RCRA permits contain assurances of financial
responsibility for completing RCRA corrective action.

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                                   Final Cleanup Goals, Pg. 4.3

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How should facilities and regulators evaluate final remedies that meet the threshold criteria?

EPA recommends (EPA, 1996a) that facilities consider the following seven balancing criteria11
when evaluating a single cleanup alternative or choosing among several alternatives anticipated to
meet the final remedy threshold criteria:

(1) Long-term reliability and effectiveness, along with the degree of certainty that remedies will
    remain protective of human health and the environment, considering, as appropriate: the
    magnitude of risks that will remain at a site from untreated hazardous wastes and hazardous
    constituents and treatment residuals, and the reliability of any containment systems and
    institutional controls:

(2) Reduction of toxicity, mobility, or volume through treatment of hazardous wastes and
    hazardous constituents, including how treatment is used to address principal threats posed by
    the facility, and the degree to which remedies employ treatment that reduces the toxicity,
    mobility, or volume of hazardous waste and hazardous constituents, considering, as
    appropriate: the treatment processes to be  used and the amount of hazardous waste and
    hazardous constituents that will be treated;  the degree to which treatment is irreversible; and
    the types of treatment residuals that will be produced;

(3) Short-term effectiveness and short-term risks remedies pose, along with the amount of time it
    will take for remedy design, construction, and implementation;

(4) Ease or difficulty of remedy implementation, considering, as appropriate: the technical
    feasibility of constructing, operating, and monitoring the remedy; the administrative feasibility
    of coordinating with and obtaining necessary approvals and permits from other agencies; and
    the availability of services and materials, including capacity and location of needed treatment,
    storage and disposal services;

(5) Capital as well as operation and maintenance costs, and the net present value of these costs.

(6) The degree to which remedies are acceptable to the surrounding community; and

(7) The degree to which remedies are acceptable to the State in which the facility is located12.
       11 These balancing criteria are not ranked in terms of importance.

       12 The last two recommended balancing criteria (State and community acceptance) were not explicitly
stated in the May 1, 1996 ANPR (EPA, 1996a). EPA believes these criteria are important considerations to ensure
that both regulators and facilities consider public views and opinions, as well as State requirements, guidance and
policies. Considering State input is especially important for those situations where EPA, not the State, selects the
final remedy.  Including these last two balancing criteria has the added benefit of improving consistency between
the RCRA Corrective Action Program and EPA's Superfund Program.

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                                   Final Cleanup Goals, Pg. 4.4

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How thorough of an assessment should facilities conduct when evaluating one or more
remedial options?

EPA encourages facilities to focus their evaluations on realistic remedies and tailor the scope and
substance of studies to the complexity of contamination and hydrogeologic conditions at a given
facility.  EPA emphasizes that it does not expect facilities to undertake studies simply for the
purpose of completing procedural steps. Furthermore, there are a number of opportunities to
significantly streamline remedy evaluation.  For example, where there are straightforward
solutions (e.g., when standard engineering solutions have proven effective in similar situations) or
where presumptive remedies13 are appropriate and can be applied, it may not be necessary to
evaluate  more than one alternative. However, when facilities only evaluate one alternative, they
should still justify their proposal based on EPA's recommended threshold and balancing criteria.

How should facilities and regulators develop facility-specific final groundwater cleanup
goals?

Facilities and regulators should work together, with input from the public as appropriate, to
develop clearly defined media cleanup objectives to implement final cleanup goals. As described
in the Groundwater Protection and Cleanup Strategy. EPA recommends that these objectives be
expressed in terms of what actions the facility will take, and where and when the facility will take
the action.

If some form of cleanup action is needed to achieve a final cleanup goal, stakeholders should
understand:

   What the groundwater        level is for contaminants in groundwater.

   Where the facility will demonstrate it has achieved groundwater cleanup levels (i.e., the
    groundwater point of compliance).

   When the facility anticipates it can implement a remedy and can achieve a groundwater
    cleanup (cjeaiii|nimejra

In addition to these three elements, EPA believes stakeholders should also clearly understand who
is implementing the final remedy, why they are taking the action, and how they are going to
implement the action.
       13 Presumptive remedies are preferred technologies for common categories of sites, based on historical
patterns of remedy selection and EPA's scientific and engineering evaluation of how well technologies perform
(EPA, 1996c). You can access EPA's guidance on presumptive remedies at
http://www.epa.gov/siipeifond/resources/presiiiiip.

          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                  Final Cleanup Goals, Pg. 4.5

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What are the media cleanup objectives if containment is the final goal rather than meeting
cleanup levels throughout contaminated groundwater?

When containment is part of the final remedy, facilities and regulators should develop systems to
monitor the effectiveness of the containment. For example, the what could include the cleanup
levels the facility needs to meet outside the containment area. The where could include locations
outside the containment area at which the facility will be monitoring groundwater conditions to
verify the containment system is working. The when could include how often and for how long
the monitoring will continue.  In addition, the facility and regulator should identify the specific
measures or conditions that will indicate whether the containment is effective, and what actions
the facility will take if the containment fails.

Key References:

EPA, 1997b.  Rules of Thumb for Superfund Remedy Selection (EPA 540-R-97-013). Available
at lrtl|x//wyjjg|3^
EPA, 1996a.  Advance Notice of Proposed Rulemaking (61 FR 19432, May 1).  Available at
http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/Mav/Dav-01/pr-547.pdf.  Particularly
relevant pages: 19448-52.

EPA, 1996c.  Presumptive Response Strategy and Ex-Situ Treatment Technologies for
Contaminated Groundwater at CERCLA Sites (EPA/540/R-96/023, October). Available at
http ://www. epa. gov/superfund/resources/gwgui de/i ndex . htm .
          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                 Final Cleanup Goals, Pg. 4.6

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                             5. Groundwater Cleanup Levels
                                     (September 2001)
What are groundwater cleanup levels?

Groundwater cleanup levels are facility-specific
regulators generally establish when defining
groundwater cleanup objectives for final
remedies. EPA recommends that groundwater
cleanup levels be based on the maximum
beneficial use of the groundwater to ensure
protection of human health and the environment
Additionally, groundwater cleanup levels often
serve as the basis for identifying the "level of
concern" used for the Migration of
Contaminated Groundwater Under Control
environmental indicator (i.e., short-term
          goals), and may be a component of a
facility-specific intermediate             goal.

How should groundwater cleanup levels be
developed?
chemical concentrations in groundwater that
               Rationale for
       Groundwater Cleanup Levels

     Groundwater clean up levels provide clear
     numerical targets that stakeholders can use
     to measure the success of groundwater
     cleanup actions.  EPA recommends that
     groundwater cleanup levels be based on
     the maximum beneficial use to ensure that
     groundwater is cleaned up to levels that
     protect human health  and the environment
     both now and in the future. Identifying
     cleanup levels in this way helps to protect
     the environmental integrity of our nation's
     groundwater resources.
Groundwater cleanup levels for human health
should typically be developed by using existing cleanup standards (e.g., drinking water standards)
when they are available and when using them is protective of current and reasonably expected
exposures.

If a cleanup standard is not available for a constituent, a facility should first assess all actual and
potential exposures to the contaminant(s). Then, a groundwater cleanup level should be
developed based on the magnitude of exposure (i.e., dose1), and the toxicity of the contaminant
resulting in an estimate of risk.  Groundwater cleanup levels are then calculated to fall within
generally acceptable levels of risk. EPA recommends that regulators choose risk-based cleanup
levels as follows:

(1) For known or suspected carcinogens,  regulators should establish groundwater cleanup levels
    at concentrations that represent an excess upper bound lifetime  risk2 to an individual of
       1 Dose is the amount of substance to which a person or other organism is exposed.  Dose often takes body
weight into account. Total dose is the sum of doses received by a person or organism from a contaminant in a
given time interval resulting from interaction with all environmental media that contain the contaminant.

         EPA expresses cancer risk in terms of the likelihood that a person might develop cancer from exposure
to contaminants from a facility. For example, a risk assessment might say that a receptor has an upper bound
                                                                              (continued...)

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                               Groundwater Cleanup Levels, Pg. 5.1

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    between 10"4 and 10"6 (commonly referred to as EPA's cancer risk range3).  Note that EPA
    prefers cleanup levels at the more protective end of the risk range.  For facilities with multiple
    contaminants or exposure pathways, cleanup levels should generally be set so that cumulative
    (total) excess4 upper bound lifetime risk from all contaminants still falls within the risk range.

(2) For toxic substances associated with adverse effects other than cancer, regulators should
    establish groundwater cleanup levels at concentrations to which human populations, including
    sensitive subgroups, could be exposed to on a daily basis without appreciable risk of negative
    effect during a lifetime.  Such levels are generally interpreted as equal to or below a hazard
    quotient5 of one.  For facilities with multiple contaminants or exposure pathways,
    groundwater cleanup levels should generally be equal to or below a hazard index6 of one.

Are there other factors regulators and facilities should considered when developing
groundwater cleanup levels?

Yes. Groundwater cleanup levels that are higher or lower than the levels described above, might
be appropriate in circumstances, such as those described below, provided the cleanup protects
human health and the environment:
        2(... continued)
excess cancer risk of 10"4. The numerical estimate means that for people receiving this level of exposure averaged
over a 70-year lifetime, approximately one person out of every 10,000 would develop cancer as a result of the
exposure. Note that the range of 10"6 to 10"4 translates to from one in one million to one in ten thousand. Values
(i.e., screening values or "action levels") used as "triggers" for conducting additional corrective action activities are
generally set at a cancer risk of 10"6. For additional guidance concerning screening levels, refer to EPA, 1996e and
liUp://www.cpa.gov/ocrtpagc/supcrfund/resourccs/soil/.

        3  Refer also to  State regulations and guidance on risk and risk ranges.  For example, the State of Florida
specifies 10"6 for risk assessments. Links to State hazardous waste programs are available at
http://www.epa.gov/correctiveaction/state.htni.

        4 The term "excess" in this context refers to the additional or extra risk of developing cancer due to
exposure to a toxic substance incurred over the lifetime of an individual (source: Glossary of IRIS Terms available
        5  EPA expresses noncancer health risk as a ratio, known as the Hazard Quotient (HQ), which is defined
as the calculated exposure from a single contaminant in a single medium divided by a reference dose.  The
reference dose is the level of exposure that EPA believes will not cause adverse affect in human populations,
including sensitive individuals. Note that some chemicals may be associated with both carcinogenic as well as
noncarcinogenic effects (such as liver or kidney disease); both should be considered when setting the cleanup level.
          The hazard index (HI) assesses potential for toxicity following exposure to multiple contaminants. It is
equal to the sum of the hazard quotients.  However, where information is available to identify the critical toxic
effect for non-carcinogens, only hazard quotients associated with similar critical effects (target organs) are
combined.

           Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                  Groundwater Cleanup Levels, Pg. 5.2

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(1)    Higher cleanup levels may be appropriate, for a given facility, for example, when:

       (a) in addition to contamination originating from releases from the RCRA facility,
       groundwater is also contaminated by hazardous constituents that are naturally occurring7
       or have originated from a source not associated with the subject facility, and those
       hazardous constituents are present in concentrations such that remediation of the release
       would not provide significant reduction8 in risks to actual or potential receptors; or,

       (b) the groundwater designation is not a current or reasonably expected source of
       drinking water, and contaminants in groundwater would not result in unacceptable impacts
       to hydraulically connected surface water bodies.

(2)    Lower groundwater cleanup levels may be necessary, for example, because of
       unacceptable risks to human receptors from combined effects of hazardous wastes or
       hazardous constituents, or to protect ecological receptors9, or to protect potential
       receptors exposed through cross-media transfer.

For additional information,  refer to numerous resources concerning human health and ecological
risk issues including EPA, 2001b; EPA, 2001c; EPA, 1997f; EPA, 1989c; and,  the following
internet sites:  http://www.epa.gov/superfund/programs/risk/tooltrad.htm#gp. and
http://www.epa. gov/superfund/programs/ri sk/commeng. htm.

What is the role of groundwater use in setting cleanup levels?

Regulators and facilities should base groundwater cleanup levels on the maximum beneficial
groundwater use.  The maximum beneficial use,  determined by EPA or State regulators, is the
current or reasonably expected use that warrants the most stringent groundwater cleanup levels.
Typically the             use            is the starting point for determining  the appropriate
reasonably expected uses and exposures to evaluate risks and identify groundwater cleanup levels.
Facilities and regulators should consider groundwater use designations when evaluating the
reasonably expected future  uses of groundwater.  The groundwater use designation may define
whether the groundwater is a current or potential source  of drinking water, or has value or uses
other than drinking water.
       7
         A naturally occurring substance is in its unaltered form, or is altered solely through naturally occurring
         )r phenomena, in a location where it is naturally found (Superfund, Section 104(a)(3)(A)).
processes or phenomena, in a
         What would or would not constitute "significant reductions in risk" should be defined on a case-by-case
basis by the regulator. EPA's primary intent with this guidance is to convey that regulators have the flexibility to
adjust cleanup levels to avoid, where appropriate, creating a groundwater "island of purity" in the midst of regional
contamination from sources outside the facility in question.

       9 You should make sure to contact the cleanup program for the State in which a particular facility is
located to determine applicability of any State-specific guidance or regulations concerning ecologic risk assessment
procedures. Links to State hazardous waste programs are available at
hUp:/Av\w.cpa.gov/corrcctivcaction/statc.htiTi.

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                                Groundwater Cleanup Levels, Pg. 5.3

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What are the groundwater cleanup levels for a current or potential source of drinking water?

For groundwater that is currently used or designated as a current or reasonably expected source
of drinking water, EPA recommends that regulators identify cleanup levels based on a residential
drinking water exposure scenario.  Even if no one is currently drinking the groundwater, the
cleanup level should generally be based on drinking water use if the aquifer is considered by EPA
or the State to be a reasonably expected future source of drinking water.  For each constituent,
regulators should determine whether a maximum contaminant level (MCL) has been established
under the  Safe Drinking Water Act (see http://www.epa.gov/safewater/sdwa/sdwa.html). They
should also determine whether the State has adopted the Federal MCL for that constituent, or has
promulgated a more stringent State MCL for drinking waters.  Regulators should compare the
Federal MCL and State MCL for each constituent and typically should use the more stringent as
the cleanup level10.

For chemicals that do not have Federal MCLs, you should contact the particular State program in
which the facility is located to determine whether that State has a list of its own drinking water
standards.  Internet links to State hazardous waste  programs are available at
http://www.epa.gov/correctiveacti on/state, htm.

For constituents for which no Federal or State MCLs have been promulgated, regulators typically
rely on other established drinking water standards and goals or a risk assessment incorporating
residential exposure assumptions (for example, ingestion rate of 2 liters/day, and exposure
frequency of 350 days/year) to estimate contaminant dose, derive risk estimates, and determine
groundwater cleanup levels.

What is the cleanup level if the groundwater is designated as something other than a current
or potential source of drinking  water?

Regulators should develop cleanup levels that are consistent with the groundwater use
designation.  However, they should first verify that the groundwater use            is valid. For
example, even if a State-wide designation system defines (or would define) the aquifer as a non-
drinking water resource, regulators and facilities should verify that no one is drinking the
groundwater and that no other unacceptable exposure to contamination from groundwater is
occurring.

Once verified, a non-drinking groundwater use designation could serve as a starting point for
establishing groundwater cleanup levels.  Some States have established generic cleanup levels in
regulations or guidance for groundwater in non-drinking water aquifers.  In those States, facilities
       10  In the Superfund Program, non-zero maximum contaminant level goals (MCLGs) established under
the Safe Drinking Water Act are also used as cleanup levels. At Superfund sites, regulators should compare the
Federal MCL, Federal non-zero MCLG, and the State MCL for each constituent and use the most stringent of the
these as the cleanup level.  Relatively few chemicals have a non-zero MCLG, and for most of these the non-zero
MCLG is equal to the MCL. For constituents that have an MCLG equal to zero, EPA's Superfund Program uses
the MCL as the cleanup level (EPA, 1990b - 40 CFR 300.430(e)(2)(i)(B&C)).  A table of MCLs and MCLGs
established by EPA under the Safe Drinking Water Act is available at htlB^/wmQ^CBiyMv/sa^
          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                               Groundwater Cleanup Levels, Pg. 5.4

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and regulators should consider these levels when appropriate. However, at a facility-specific
level, there may be uses of groundwater or exposures to contaminants from groundwater that
might not be considered in a State-wide groundwater use designation. Regulators should,
therefore, verify that the generic values are protective of the known or reasonably expected
groundwater uses and the potential exposures through cross-media transfer.  For example,
regulators should consider whether contaminants in groundwater could transfer (through
volatilization) into soil gas that could migrate into overlying buildings11 and negatively impact the
quality of indoor air.  Additionally, regulators should consider whether contaminants in
groundwater could negatively impact adjacent aquifers or surface water bodies.

For example, a State designation may identify groundwater in a particular area as industrial and
provide a generic value, but the groundwater discharges into an adjacent surface water body.  In
this case, regulators and facilities should determine the designated uses of the impacted surface
water, and identify any Federal or State water quality criteria for those contaminants found in the
discharging groundwater.  Regulators and facilities should also evaluate possible adverse effects
of the groundwater discharge for actual pathways of exposure to humans or aquatic life12.  Based
on these evaluations, facilities and regulators should verify whether available generic cleanup
values are protective of the surface water and  its sediments. If these generic levels are not
protective, facilities should propose facility-specific groundwater cleanup levels designed to
prevent exceeding appropriate water quality standards in the surface water body, and
unacceptable risks to human health or the environment.

Additionally, in the absence of appropriate generic values for non-drinking water, facilities should
identify the various actual and potential uses and exposures (i.e., pathways) to contaminants from
groundwater to develop protective groundwater cleanup levels for the facility. To estimate dose,
facilities or regulators should evaluate all current and potential routes of exposure within each
pathway, such as inhalation,  dermal (skin) contact,  and inadvertent ingestion. Since EPA does
not currently have standard exposure assumptions for nonresidential uses of groundwater,  such as
industrial or agricultural uses, facilities and regulators will generally need to quantify facility-
specific exposure assumptions for all expected pathways by collecting facility-specific or other
relevant data to develop an appropriate  numerical value  for those exposures.  These exposure
values along with toxicity values  for each contaminant can then be used to calculate contaminant-
specific concentrations  (groundwater cleanup  levels) to achieve protective risk levels  (i.e.,
generally an excess upper bound lifetime cancer risk of 10"4 to 10"6, or equal to or below a  hazard
index of one).
       11 For information on a tool designed to assess impacts from contaminated groundwater to indoor air,
refer to EPA's User's Guide for the Johnson and Ettinger Model for Subsurface Vapor Intrusion into Buildings
(EPA, 1991d) which is available at
 http://www.epa.gov/oerroage/supeifiind/prograiiis/risk/airiiiodel/giiide.pdf. The model itself can be downloaded
from http://www.epa.gov/oerrpage/supeifund/progranis/risk/airniodel/iolmson ettinger.htm.

       12 Refer to EPA, 200 Ib for recent guidance concerning the use of screening level risk assessments and
refining contaminants of concern for baseline ecological risk assessments.

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                               Groundwater Cleanup Levels, Pg. 5.5

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Are there any situations where regulators might not establish specific groundwater cleanup
levels?

Yes.  In some cases, the groundwater will already be at acceptable levels for its designated use(s).
In other situations, regulators might not establish specific groundwater cleanup levels if:

   the contaminated groundwater is within a designated non-drinking water aquifer;
   has no current or foreseeable beneficial use;
   does not discharge to surface water or to a drinking water aquifer at levels that could cause
    concern; and,
   does not cause other exposures through media transfer (e.g., indoor air).

However, the regulator may still require facilities to conduct monitoring or to provide
containment to ensure continued protection of human health and the environment. If containment
is warranted, then cleanup levels may be needed to help evaluate the effectiveness of the
containment system.  Other protective measures, such as sourc.e.controL would still likely apply in
this situation.

What are alternate concentration limits and do they apply to setting groundwater cleanup
levels for facility-wide corrective  action?

EPA's regulations pertaining to alternate concentration limits (ACLs) appear at 40 CFR
264.94(b) in the section of EPA's  regulations that apply to corrective action for RCRA regulated
units13 for the purposes of detecting, characterizing and responding to releases to the uppermost
aquifer. Alternate concentration limits are levels that the Regional Administrator may establish
under certain defined circumstances as a component of the groundwater protection standard14 for
RCRA regulated units.  The regulations refer to these levels as "alternate" because, if approved by
the regulator, they are used instead of background concentrations or the values conveyed in Table
1 of40CFR264.94(a)(2).

The ACL regulations (see 40 CFR 264.94(b)) take a risk-based approach that provides the
Regional Administrator with the ability to establish an alternative level(s) that "will not pose a
substantial present or potential hazard to human  health and the environment."  In establishing
ACLs, the regulations also list factors the Regional  Administrator will consider, such as "the
physical and chemical characteristics of the waste in the regulated unit, including its potential for
migration, and the potential adverse effects on hydraulically connected surface water." You can
find further  information setting ACLs, including on how to account for natural attenuation
processes, in EPA Alternate Concentration Limit guidance (EPA, 1987).
       13 Regulated units are defined in 40 CFR 264.90 as surface impoundments, waste piles, land treatment
units, and landfills that received hazardous waste after July 26, 1982.

       14 The groundwater protection standard (40 CFR 264.92) for RCRA regulated units consists of four
elements including:  hazardous constituents (40 CFR 264.93), concentration limits (40 CFR 264.94), the point of
compliance (40 CFR 264.95), and the compliance period (40 CFR 264.96). These regulations are available
through http://www.access.gpo.gov/nara/cfr/cfr-retrieve.litiiiltfpagel.

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                               Groundwater Cleanup Levels, Pg. 5.6

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Alternate concentration limits as described in 40 CFR 264.94(b) do not apply (see 40 CFR 264.90
regarding "applicability") to the facility-wide corrective action15 of solid waste management units
under 40 CFR 264.101.  However, regulators and facilities could use many of the concepts of
ACLs in developing cleanup levels and approaches for site-wide corrective action.  For example,
as described elsewhere in this Handbook, facilities and regulators should consider impacts of
groundwater on hydraulically connected surface water, and cleanups can in certain circumstances
rely on natural  attenuation processes (see Handbook section on Monitored Natural Attenuation).

What are cleanup levels for groundwater if a facility is clean closing a RCRA regulated unit?

To achieve "clean closure," facilities should remove or decontaminate all hazardous waste, liners
and environmental media contaminated by releases from the unit.  However,  hazardous
constituents may remain at some level in environmental media, such as groundwater, after clean
closure provided that the constituents are below levels that may pose a risk to human health or the
environment.

In 1998, EPA issued a memorandum (EPA, 1998c) reaffirming risk-based  clean closure standards.
The memorandum interpreted EPA's regulations to permit some limited quantity of hazardous
constituents to remain in environmental media after clean closure provided they are at
concentrations below levels that may pose a risk to human health and the environment.  This
allows appropriate use of non-residential exposure assumptions16 when identifying closure
standards.  Typically, regulators should not rely on nonresidential exposure assumptions for their
clean-closure decisions unless they are reasonably confident that future land use will conform to
those assumptions.  Furthermore, regulators should make sure that the area covered by the
nonresidential land use assumptions is clearly delineated.  Facilities and regulators should also
establish procedures (see Institutional Controls) to alert future users to the presence of
contamination and risks presented, and to provide for periodic evaluations  of actual land use. For
more information on risk based closure, refer to the Risk-Based Clean Closure Memorandum
(EPA, 1998c) and call your overseeing regulator.
       15 Under limited circumstances specified in CERCLA 121(d)(2)(B)(ii), alternate concentration limits may
also be used at Superfund sites. Additional guidance for using Superfund ACLs is found in the "Rules of Thumb
for Superfund Remedy Selection" (EPA, 1997b). More specifically, the conditions under which ACLs may be
considered in the Superfund Program include where: (1) contaminated groundwater discharges into surface water;
(2) such groundwater discharge does not lead to "statistically significant" increases of contaminants in the surface
water; and (3) enforceable measures can be implemented to prevent human consumption of the contaminated
groundwater.  In general, ACLs can be used in the Superfund Program when the preceding three conditions are
satisfied and where restoration of the groundwater is found to be impracticable based on a balancing of
Superfund's remedy selection criteria (EPA, 1990 - NCP preamble pages 8732 and 8754, and EPA, 1997b).

       16 Note that some State programs do not allow nonresidential scenarios to be used in determining criteria
for clean closure.

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                               Groundwater Cleanup Levels, Pg. 5.7

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References:

EPA, 2001b. ECO-UPDATE: The Role of Screening Level Risk Assessments and Refining
Contaminants of Concern in Baseline Ecologic Risk Assessments (EPA/540/F-01/014, June).
Available at totg;//_www_._ejm^
EPA, 2001c. Risk Business (EPA/530/F-00/032, February).  Available at
http ://www. epa. gov/epaoswer/osw/docs/ri skfinal .pdf.

EPA, 1998c. Memorandum from Elizabeth Cotsworth to RCRA Senior Policy Advisors titled,
Risk-Based Clean Closure (March 16). Available at
http://www.epa.gov/correctiveaction/resoiirce/giiidance/risk/cdosfnl.pdf

EPA, 1997b. Rules of Thumb for Superfund Remedy Select on (EPA/540/R-97/0 13). Available
at http ://www. epa.gov/superfund/resources/rules/rulesthm. pdf

EPA, 1997 f. Exposure Factors Handbook (EPA/600/P-95/002F). Available at
http://www.epa.gov/ncea/exposfac.htiTi.

EPA, 1996a. Advance Notice of Proposed Rulemaking (61 FR 19432, May 1). Available at
http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/May/Day-01/pr-547.pdf.  Particularly
relevant pages: 19448-52.

EPA, 1996e. Soil Screening Guidance Fact Sheet (EPA/540/F-95/041, July).  Available at
http://www.epa.gov/oerrpage/superflind/resources/soil/.

EPA, 199 Id. USEPA's User's Guide for the Johnson and Ettinger Model for Subsurface Vapor
Intrusion into Buildings.  Available at
http ://www.    gov/oerrpage/superfund/programs/ri sk/airmodel/gui de. pdf.  The model itself can
be downloaded from
http ://www.    gov/oerrpage/superfund/programs/ri sk/airmodel/j ohnson^ettinger.    .

EPA, 1990b. National Oil and Hazardous Waste Contingency Plan (55 FR 8666 and 40 CFR
300). The preamble is available at  .http://www.oscreadiness.org/cec_courses/documents/marl990.pdf
The CFR is available throughjitjj)!//^
EPA, 1989c. Risk Assessment Guidance for Superfund Volume I: Human Health Evaluation
Manual (Part A). Available at httpi//www,.epa,.gQv/Mp^

EPA, 1987.  Alternate Concentration Limit Guidance (EPA/530/SW-87/017). Available at
http://www.epa.eov/correctiveaction/resource/guidance/ew/acl.htm.
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                             Groundwater Cleanup Levels, Pg. 5.8

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                                  6. Point of Compliance
                                      (September 2001)
What is a point of compliance for
groundwater?
As a general definition, the point of
compliance for groundwater is where a facility
should monitor groundwater quality and/or
achieve specified cleanup levels to meet
facility-specific goals1. For RCRA regulated
units2, EPA defines the location of the point of
compliance in regulation (40 CFR 264.95).
For groundwater contamination subject to
facility-wide RCRA corrective  action, EPA
uses guidance to convey its recommendations
for establishing the point of compliance.

Where is the point of compliance for RCRA
regulated units?

For RCRA regulated units, Federal regulations
define the point of compliance as the "vertical
surface located at the hydraulically down
gradient limit of the waste management area3
that extends down to the uppermost aquifer
underlying the regulated units"(40 CFR
264.95). The purpose of this point of
compliance is to define where the facility must
monitor groundwater and evaluate compliance
with groundwater concentration limits (i.e.,
cleanup levels).  Additionally, the regulations
require facilities to take action, if necessary, to
achieve cleanup levels within the volume of
contaminated groundwater at and beyond the
point of compliance (40 CFR 264.100). For more
             Rationale for
          Point of Compliance

Defining where a facility should achieve
specified levels of groundwater quality
provides stakeholders a way to assess
progress toward achieving cleanup goals.
EPA recognizes that facilities often use a
series of goals to address contaminated
groundwater.

EPA's policies in this Handbook reflect
different approaches for points of compliance
depending on whether the facility is pursuing a
short-term, intermediate, or final cleanup goal.

EPA believes the recommended throughout-
the-plume/unit boundary point of compliance
for final  clean up goals is consistent with
EPA's overarching goal of protecting human
health and the environment by returning
"usable" groundwater to its maximum
beneficial  use, where appropriate.

This policy also helps ensure that operation
and maintenance, including monitoring,
continue as long as necessary to ensure
protection of human health and the
environment. Such monitoring is important
because contamination represents a potential
threat to human health and the environment
as long  as the contamination is present above
levels of concern.
information regarding the point of compliance
       1 Progress toward meeting a particular cleanup goal is typically measured at the point of compliance using
groundwater monitoring wells.  The locations of these monitoring wells may change during different stages of a
groundwater cleanup action.

       2 Regulated Units are defined in 40 CFR 264.90 as surface impoundments, waste piles, land treatment
units, and landfills that received hazardous wastes after July 26, 1982.

       3 If the facility contains more than one regulated unit [in close proximity to each other], the waste
management area is described by an imaginary line circumscribing several regulated units (40 CFR 264.95(b)(2)).

          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                   Point of Compliance, Pg. 6.1

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for regulated units, refer to 40 CFR 264.90-100, which are available through
http://www.access.gpo.gov/nara/cfr/cfr-retrieve.htmltfpagel.  Also, see footnote number 8 in the
Overview to read how EPA's Post Closure regulations (63 FR 56710, EPA 1998d) can provide
additional flexibility for cleanup of regulated units.  For additional guidance concerning
groundwater monitoring of regulated units, refer to EPA, 1993b.

Where is the groundwater point of compliance for RCRA (facility-wide) corrective action?

EPA recognizes that the general definition of the point of compliance can apply to a variety of
facility-specific goals, in particular short-term protection goals4,                          gals*
and finaLcleanuBjroals. Therefore, EPA recognizes the point of compliance may vary depending
on the particular goal the facility and regulator are pursuing5.  EPA recommends consideration of
the following factors when developing a
facility-specific groundwater point of
compliance:  proximity of sources of
contamination; technical practicability of
achieving particular cleanup levels;
vulnerability of the groundwater and its
possible uses; and exposure and likelihood of
exposure and similar considerations (EPA,
1996a).

Where is the groundwater point of
compliance for final cleanup goals?
                                \  Qxxndwater
                                  HowEfecticn
The location of the point of compliance
should depend on whether the final cleanup is
selected to (1) return usable groundwater to
its maximum beneficial use;  or (2) contain
contamination within groundwater that EPA
or a State has designated as not being usable
(see Finaj_Cleanup_Goals and Groundwatgr
Use Designation) or in situations where the
regulator determined that returning usable
groundwater to its maximum beneficial use is tec|miMlvilIlB!igticablg-
                Rrjpotyboundary
Figure 1:  Example groundwater point of compliance for final
cleanup goal involving returning contaminated groundwater to
its maximum beneficial use. The shaded area represents a
throughout the plume/unit boundary point of compliance
corresponding to the volume of contaminated groundwater that
needs to achieve specific groundwater cleanup levels.
       4 The groundwater point of compliance in the context of short-term goals refers primarily to the
Migration of Contaminated Groundwater Under Control Environmental Indicator, which is one of two
environmental indicators used to track the progress of the RCRA Corrective Action Program (see Short-Term
Protection Goals).

       5 EPA's intent in recognizing that there could be various locations for the groundwater point of
compliance is to illustrate flexibility available to program implementers. EPA does not, however, want to create
confusion over the names we attach to certain elements of corrective action. Regulators often have to define where
facilities need to meet cleanup levels in order to achieve a particular goal. Whenever regulators define such
locations, they are in essence establishing a point of compliance, but it is not necessary to refer to these locations as
a point of compliance unless they find it beneficial to do so.

           Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                   Point of Compliance, Pg. 6.2

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For final cleanups selected to return groundwater to its maximum beneficial use, EPA
recommends regulators set the point of compliance throughout the area of contaminated
groundwater, or when waste is left in place6, at and beyond the boundary of the waste
management area encompassing the original
source(s) of groundwater contamination (EPA,
1996a - page 19450).  EPA typically refers to
this area (more accurately described as a
volume) as the "throughout-the-plume/unit
boundary" point of compliance7  (See Figure 1
on previous page).
If the final groundwater cleanup objective is to
contain the plume rather than to return the
groundwater to its maximum beneficial use, the
point of compliance should generally be located
at and, if appropriate, beyond the boundary of
the containment zone.  This point of
compliance is similar to the approach regulators
typically use to measure whether a facility
achieves the Migration of Contaminated
Groundwater Under Control environmental
indicator (see answer to next question).

Where is the groundwater point of
compliance for short-term protection goals?
I
'
                               Groundwater
                               Flow Direction
                                                   i
                       j?
      Hume boundary
                 Property boundary
Figure 2:  Plume boundary point of compliance for short-
term protection goal associated with the Migration of
Contaminated Groundwater Under Control environmental
indicator. The heavy dashed line represents the point of
compliance (i.e., boundary of the plume) defined by
"contaminated" and "uncontaminated" monitoring wells.
Achieving the Migration of Contaminated Groundwater Under Control environmental indicator
involves documenting that contaminated groundwater is expected to remain within an existing
three-dimensional boundary(ies) of the plume8 (EPA, 1999e). Using the general definition of a
         In the context of RCRA corrective action, "waste in place" typically refers to the waste management area
encompassing the original source(s) of a release that the regulator determined is acceptable to leave in place as part
of a final remedy. For example, a properly closed landfill represents a waste management area commonly allowed
to stay in place as part of a final remedial action. EPA typically does  not refer to contamination that has migrated
from the original source(s) (e.g., non-aqueous phase liquid (NAPL)) as a waste management area or waste left in
place (EPA, 1996c - page 17).

       7 This definition of a point of compliance for final remedies is consistent with the "area of attainment"
(EPA, 1988) and "point of compliance" (EPA, 1997b) used in EPA's  Superfund cleanup program.  For more
information concerning how the Superfund Program uses a point of compliance, refer to page 8753 of the NCP
preamble (EPA, 1990b).

       8 Facilities and regulators typically define a plume boundary  based on estimating a division between
where groundwater  is contaminated above and below levels of concern.  They commonly  make this estimate based
on professional interpretation (often with the aid of computer software) of chemical analyses of groundwater
                                                                                  (continued...)

           Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                   Point of Compliance, Pg. 6.3

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point of compliance described above, regulators and facilities could, in appropriate circumstances,
recognize a plume boundary (see Figure 2) as a point of compliance for the Migration of
Contaminated Groundwater Under Control environmental indicator. Evaluators should recognize
that they need to account for all plumes of contaminated groundwater at a facility since EPA
designed this indicator to reflect facility-wide conditions.

Where is the groundwater point of compliance for intermediate performance goals?

The need for, and location of, a point of compliance for an intermediate performance goal
depends on facility-specific circumstances. Many intermediate performance goals for
contaminated groundwater will  not warrant establishing a point of compliance (e.g., source
removal actions). In general, establishing a point of compliance as a component of an
intermediate performance goal is only
beneficial when a facility takes an action that
includes  assessment through groundwater
monitoring.  If the facility and the regulator
wish to establish a point of compliance as a
component of an intermediate performance
goal, it should be located between the
existing boundary of the plume  and the
original source of groundwater
contamination. For example, establishing a
facility boundary point of compliance may
make sense when a groundwater contaminant
plume extends off-site (see Figure 3).  In this
case, a facility boundary point of compliance
establishes a way to measure when a facility
achieves an intermediate goal of cleaning up
the off-site groundwater.
                                                 I
                                                                              Groundwater
                                                                              Flow Direction
                                                     Plume boundary
                                             Figure 3: Example of a point of compliance for an
                                             intermediate performance goal. In this example, the point of
                                             compliance is considered to be throughout the portion of the
                                             contaminant plume that extends beyond the facility boundary.
In contrast, a facility boundary point of
compliance would generally not be an
appropriate component of an intermediate
performance goal when a groundwater contaminant plume has not yet reached a property
boundary because: (1) it would likely be inconsistent with EPA's general pollution prevention
goals, and with the EPA's sh^rMerm_protectiQn_gQal of preventing the spread of contaminated
groundwater; (2) monitoring uncontaminated wells at the facility boundary would not measure
progress toward achieving the final cleanup goal; and, (3) as a practical matter, preventing
groundwater contamination is usually much less costly than cleaning up the contamination after it
has spread.
       8(...continued)
samples collected from properly located monitoring wells or other monitoring devices.

          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                  Point of Compliance, Pg. 6.4

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   References:

   EPA, 1999e. Interim Final Guidance for RCRA Corrective Action Environmental Indicators
   (February 5). Available at    ://www.epa.gov/epaoswer/osw/ei_guida.pdf.

   EPA, 1997b. Rules of Thumb for Superfund Remedy Select on (EPA/540/R-97/013). Available
   at http://www.epa.gov/superfund/resources/rules/rolesthiTi.pdf.

   EPA, 1996a. Advance Notice of Proposed Rulemaking (61 FR 19432, May 1).  Available at
   http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/May/Day-01/pr-547.pdf.  Particularly
   relevant page: 19450.

   EPA, 1996c. Presumptive Response Strategy and Ex-Situ Treatment Technologies for
   Contaminated Groundwater at CERCLA Sites (EPA/540/R-96/023, October).  Available at
   http ://www. epa. gov/superfund/resources/gwgui de/i ndex. htm.

   EPA, 1993b. Waste Management Area and Supplemental Well Guidance (June).  Available at
   http://www.epa.gov/correctiveaction/resource/guidance/gw/wma_sup.htm.

   EPA, 1990b. National Oil and Hazardous Waste Contingency Plan (55 FR 8666 and 40 CFR
300). The preamble is available at httpj//wj^wj3screMll^^                             1990.pdf.
   The CFR is available through http://www.      gpo.gov/nara/cfr/waisidx_00/40cfrv20_00.

   EPA, 1988. OSWER Directive 9283.1-2, "Guidance on Remedial Actions for Contaminated
   Groundwater at Superfund Sites," (December 1).
             Handbook of Groundwater Protection and Cleanup Policies for RCPvA Corrective Action

                                   Point of Compliance, Pg. 6.5

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                                  7. Cleanup Timeframe
                                     (September 2001)
What is the cleanup timeframe?
The cleanup timeframe is an estimate of when groundwater quality will achieve a certain level at a
specified location and/or the schedule
developed to take an action or construct a
remedy designed to achieve a particular short:
term protection, intermediate             or
             goal.
EPA believes that cleanup timeframes should
be reasonable, linked to specific goals, and
based on facility-specific conditions.
Examples of factors regulators and facilities
should, where appropriate, take into account
when developing cleanup timeframe(s) for a
given facility include (EPA, 1996a):

   potential risks from exposures to
    contamination;
    current and reasonably expected future
    land and water use(s);
   type, source(s), and extent of
    contamination;
   hydrogeologic  characteristics;
   reliability of exposure  controls;
    design and capabilities of cleanup
    technologies;
    availability of treatment and/or disposal
    options;
    community preferences; and
   financial resources of the facility.
What is the cleanup timeframe for EPA's short-term goals?

As described previously in this Handbook, the Corrective Action Program's shortjgrm_goals that
EPA is currently using to monitor progress in response to the Government Performance and
Results Act include:  documenting that current human exposures to unacceptable levels of
contamination are under control, and preventing plumes of contaminated groundwater from
getting larger or adversely affecting surface water bodies. To help focus the program, EPA
established nationwide goals which are as follows:
            Rationale for
         Cleanup Timeframe
Establishing reasonable timeframes based
on specific goals offers facilities realistic
objectives, provides flexibility, helps
prioritize resources efficiently, and maintains
protection.

EPA's short-term goals are directed toward
eliminating unacceptable exposures to
contamination and preventing plumes from
spreading as soon as possible. After
achieving the short-term goals, facilities can
move toward final cleanup goals in a
timeframe commensurate with the technical
difficulties and potential risks.  Considering
these factors to determine acceptable
cleanup timeframes allows the RCRA
Corrective Action  Program to direct its
resources toward  reducing potential threats
at more facilities, while maintaining its long
term environmental cleanup goals.
          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                  Cleanup Time Frame, Pg. 7.1

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By 2005, EPA's goal is to verify and document that 95 precent of a baseline of 1,714 RCRA
corrective action facilities (see http://www.epa.gov/correctiveaction/facility.htm) have human
exposures under control and 70 precent have the migration of contaminated groundwater under
control. EPA encourages regulators and facilities to work together to establish appropriate
cleanup timeframes, based on the particular circumstances of each facility, that will help meet
these near-term objectives. If people are currently using or being exposed to contaminated
groundwater or contaminants transferred from groundwater (e.g., indoor air),  facilities and
regulators should take action as soon as possible to prevent these exposures and to achieve short-
term protection goals.

How should regulators establish cleanup timeframes for intermediate performance goals?

If an intermediate                 is warranted, the timeframe to achieve that goal should be
reasonable and based on facility-specific factors.  In situations where facilities and regulators
anticipate the time to achieve                  will be long, establishing cleanup timeframes for
intermediate goals can help provide meaningful measures to assess and communicate progress
among interested stakeholders.  Timeframes for intermediate goals should generally help to
prioritize actions at a facility. For example, at a complex site with many areas of contamination,
the regulator and facility may want to consider a sequence of intermediate goals for the purpose
of demonstrating progress toward the final cleanup  goals.  A key consideration in prioritizing
actions should be the relative risk and/or potential environmental harm associated with the current
contamination.

How should regulators establish cleanup timeframes for achieving final cleanup goals?

EPA recognizes that uncertainties associated with the cleanup may make it impossible to specify
with a high level of confidence when  a remedy will  achieve final cleanup goals. Regulators and
facilities can't always accurately predict how long it will take to return groundwater to its
maximum beneficial use because of the following kinds of complexities: type  of contaminants;
hydrogeologic characteristics; contaminant interactions; and, technology limitations among other
factors.  In these circumstances, facilities should generally still attempt to predict the time needed
to achieve final cleanup goals, but stakeholders should recognize that such predictions are best
considered in a  relative sense for comparing one cleanup option to another.  Where such
predictions are difficult, EPA recommends that cleanup timeframes primarily focus on the
schedules associated with implementing the remedy and perhaps anticipated timeframes associated
with achieving certain other facility-specific milestones.

In general, a regulator is more likely to accept a longer timeframe for final cleanup goals when
adequate monitoring and reliable controls are in place to prevent exposure (e.g., drinking water
wells are prohibited). For example, a regulator might allow  a facility to have an extended
timeframe to clean up groundwater when the facility overlies groundwater designated as a future
source of drinking water but where no one is currently using or anticipated to use the water in the
foreseeable future.
          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                  Cleanup Time Frame, Pg. 7.2

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Reference:

EPA, 1996a.  Advance Notice of Proposed Rulemaking (61 FR 19432, May 1).  Available at
http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/Mav/Dav-01/pr-547.pdf. Particularly
relevant page: 19450.
          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                 Cleanup Time Frame, Pg. 7.3

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                                    8. Source Control
                                     (September 2001)
What does source control mean?

Source control refers to a range of actions (e.g., removal, treatment in place, and containment)
designed to protect human health and the
environment by eliminating or minimizing migration
of, or exposure to, significant contamination.
What are sources of contamination?

EPA typically describes sources1 as contaminated
material that acts as a reservoir for the continued
migration of contamination to surrounding
environmental media (i.e., soil, groundwater,
surface water, sediment, or air), or provides a direct
threat to a receptor.  Sources are not always
stationary, but can migrate from a location, such as
a landfill or surface impoundment, where the
contamination was originally released. For
example, dense non-aqueous phase liquids
(DNAPLs2) may be present as a "mobile" phase that
continues to migrate  deeper into the subsurface,
migrate along a subsurface feature, or accumulate in
a subsurface feature,  such as a depression in a low
permeable layer of clay.
          Rationale for
          Source Control

Source control, where necessary, will be
a critical component of a facility's
cleanup strategy aimed at returning
contaminated ground water to its
maximum beneficial use in a reasonable
timeframe. Controlling sources of
contamination is also consistent with the
Agency's long-standing pollution
prevention goals; it is generally easier to
deal with the contamination at the
source than to clean up wide-spread
contamination.
What are EPA's expectations for source control regarding groundwater?

As conveyed in the 1996 Advance Notice of Proposed Rulemaking (ANPR), EPA expects3
facilities to control or eliminate surface and subsurface sources of groundwater contamination
(EPA, 1996a). EPA believes most facilities will need to control sources of contamination to
achieve facility-specific cleanup goals.  Sometimes facilities may need to implement source
controls to achieve stort4erm4ai>tec!M        For example, controlling a source of
contamination may be important for a facility that wants to rely on monitored
to achieve the Migration of Contaminated Groundwater Under Control environmental indicator.
Source control at many facilities will be an important component of intermediate ..performance.
      used, for example, to demonstrate progress toward achieving final cleanup goals.
       1 See glossary definition of "source materials."

        Additional information and reports concerning DNAPL contamination is available at
liltp://wvvw.cpa.gov/ocrrpagc/supcrfund/rcsourccs/gwdocs/non aqu.htm

       3 See glossary for a definition of "remedy expectations."

          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                    Source Control, Pg. 8.1

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Furthermore, as addressed in the Final Cleanup Goal section of this Handbook, EPA identifies
source control as a recommended threshold criterion for final corrective action remedies.  More
specifically, facilities should propose final remedies that control the source(s) of releases so as to
reduce or eliminate, to the extent practicable4, further releases of hazardous wastes or hazardous
constituents that may pose a threat to human health or the environment. EPA expects facilities to
control the sources of contamination regardless of the current groundwater use or the
groundwater use designation.

When should facilities and regulators consider source control measures?

You should consider source control measures as early as possible in corrective action.  For
example, you should consider whether source controls will be necessary to achieve short-term
protection goals, or whether they would be more appropriate to implement as part of an
intermediate performance goal or a final remedy. Furthermore, early consideration of potential
source control technologies can help facilities focus their data collection to ensure they have
adequate evaluation and design information.

When can facilities contain the sources rather than treat them?

EPA expects facilities to use treatment to address wastes and contaminated media that EPA
considers principal threats (EPA,  1996a and EPA, 1990b).  EPA considers sources or "source
materials" to be principal threats when they are highly toxic or highly mobile that generally cannot
be reliably contained or would present a significant risk to human health or the environment
should exposure occur (EPA, 1997b; EPA, 1996a; and EPA, 1991c). EPA expects to use
engineering controls, such as containment, for wastes and contaminated media that can be reliably
contained, pose relatively low long-term threats, or for which treatment is impracticable. The
exact balance between treating, removing, and containing the source is best determined on a case-
by-case basis during remedy evaluation and selection, and may depend on whether the facility is
trying to achieve short-term, intermediate, or final cleanup goals. Along with identifying principal
threats, you should also generally consider other factors such as long-term reliability, short-term
risks, and community acceptance when evaluating the right balance between containment and
treatment.

In some situations, it may be appropriate to contain rather than treat even principal threat wastes
due to difficulties in treating the wastes. For example, the following situations could, depending
on facility-specific circumstances, justifiably lead a regulator to decide that containment rather
than treatment would be acceptable for principal threat wastes (EPA, 1997b):
       4 EPA recognizes that finding subsurface sources of contamination can be very challenging. Therefore,
in this context, "practicable" refers to both finding as well as cleaning up sources of contamination. Decisions
pertaining to the practicability of source control actions are best determined on a facility-specific basis.

          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                    Source Control, Pg. 8.2

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   Treatment technologies are not technically feasible or are not available within a reasonable
    timeframe.

   The extraordinary volume of materials or complexity of the site may make implementation of
    treatment technologies impracticable (e.g., large landfills).

   Implementation of a treatment-based remedy would result in greater overall risk to human
    health and the environment due to risks posed to workers, the surrounding community, or
    impacted ecosystems during implementation (to the degree that these risks cannot otherwise
    be controlled during implementation).

   Implementation of the treatment technology would have severe effects across environmental
    media.

Why should facilities control sources when they have already achieved environmental
indicators goals?

Environmental Indicators are only milestones on the way to meeting finajj:lea|iu]ijoj|ls and
completing corrective action. For example, EPA believes that source control will often be
necessary to achieve the final cleanup goal of returning groundwater to its maximum beneficial
use within a reasonable timeframe.

References:

EPA, 1997b.  Rules of Thumb for Superfund Remedy Selection, OSWER Directive No. 9355.0-
69 (EPA/540/R-97/013, August). Available  at
http://www.epa.gov/oerrpage/siiperfund/resoiirces/rules/index.htm.  Particularly relevant text
pertaining to applicability to RCRA corrective action found on page 1, and on Treatment of
Principal Threat Wastes on pages 11 and 12.

EPA, 1996a.  Advance Notice of Proposed Rulemaking (61 FR 19432, May 1).  Available at
http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/May/Day-01/pr-547.pdf. Particularly
relevant page: 19448.

EPA, 1991c.  A Guide to Principal Threats and Low Level Threat Wastes.  Superfund Publication
9380.3-06FS (November). Available at
http://www.epa.gov/oerrpage/superfund/resources/gwdocs/threat.pdf.

EPA, 1990b.  National Oil and Hazardous Waste Contingency Plan (55 FR 8666 and 40 CFR
300).  The preamble is available at http://www.oscreadiness.org/cec_courses/documents/mar 1990.pdf.
The CFR is available through http://www.access.gpo.gov/nara/cfr/waisidx 00/40cfrv20  00.html
          Handbook of Groundwater Protection and Cleanup Policies for RCPvA Corrective Action

                                   Source Control, Pg. 8.3

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                             9. Groundwater Use Designations
                                      (September 2001)
What is a groundwater use designation?


A groundwater use designation is a
determination of the reasonably expected
use(s)1, resource value (e.g., priority),
and/or vulnerability of groundwater in a
particular area.  A system used to make
protective groundwater use designations
should account for these factors and be:


   based on an overall goal that is no
    less protective than EPA's
    groundwater protection goal2;


   applied consistently to all
    groundwaters of a State; and


    developed with thorough opportunity
    for public participation.


EPA and States can use the designation
as a factor in determining the maximum3
(highest) beneficial use of the
groundwater in order to establish facility-
specific corrective action goals.


How does EPA define use, value, and
vulnerability?
              Rationale for
    Groundwater Use Designations

States should have the primary responsibility for
managing and protecting their groundwater
resources. Therefore, EPA prefers, where
appropriate, to rely on State groundwater use
designations when developing groundwater
clean up objectives.

EPA supports State groundwater use designation
systems that promote a consistent and
comprehensive approach to groundwater
protection based on varying groundwater
characteristics. EPA's primary objectives are to
advocate approaches for groundwater use
designations that protect both the current as well
as reasonably expected uses of groundwater. In
particular, EPA wants to avoid inappropriate
groundwater use designations and associated
cleanup decisions that would  rely on the lack of
current drinking water use at or around an
individual facility as the only justification for a
non-drinking water use designation.
The term "use" refers to the current use
and reasonably expected use of the groundwater.  When people think about groundwater use,
they often consider only drinking water use; however, there are many other groundwater uses
       1 Further guidance on defining "reasonably expected uses of groundwater" is available in Appendix B of
the EPA guidance titled, Final Comprehensive State Groundwater Protection Program Guidance (EPA, 1992a).


         EPA's overall groundwater protection goal is to prevent adverse effects to human health and the
environment and to protect the environment by, among other things, protecting that integrity of the Nation's
groundwater resources (EPA, 1991b).


       3 Within the range of reasonably expected uses and exposures, maximum beneficial groundwater use
warrants the most stringent groundwater cleanup levels.


           Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                               Groundwater Use Designations, Pg. 9.1

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besides drinking water. These uses include, for example, sanitary water, cooling water, car
washes, livestock watering, and agricultural irrigation.

 "Value" depends on the current and reasonably expected use, but it also considers groundwater's
potential impact on other media; exposures to contaminants from groundwater can occur even
when there is no direct use of the groundwater. For example, groundwater may recharge adjacent
or underlying aquifers that are used for
drinking water, or discharge to surface
water to  support aquatic life, recreation,
and drinking water. In addition, exposure
to contaminated indoor air can result from
underlying groundwater contaminated
with volatile chemicals. Value also refers
to the irreplaceability of groundwater
either as a source of drinking water (e.g.,
sole source aquifer) or to support vital
ecological systems.

Groundwater "vulnerability" is the relative
ease with which a contaminant introduced
into the environment can migrate to an
aquifer under a given set of management
practices, contaminant properties, and
aquifer hydrogeologic characteristics.

For additional information regarding how
EPA defines the use, value, and
vulnerability of groundwater, refer to
Appendix B of EPA, 1992a.

What factors should States consider
when making groundwater use
designations?
           Factors to Assess
    Use, Value, and Vulnerability of
       Groundwater Resources
   Vu I ne rabi lity to conta mi n atio n
   Hydrogeologic regimes
   (recharge and discharge areas)
   Flow patterns
   Quantity and potential yield
   Ambient and/or background quality
   Wide-spread contamination
   Current use and exposures (including public
   water supply systems and private drinking
   water supply wells)
   Reasonably expected future uses (based on
   demographics, remoteness, and availability
   of alternative water supplies)
   Connections to surface waters
   Impacts to ecological receptors
   Value attributed to a groundwater resource,
   including public opinion
   Governmental and legal boundary
   considerations (e.g., groundwater migrating
   across State boundaries)

(based on EPA, 1992a)
To promote consistency, where appropriate, EPA issued guidance to States (EPA, 1992a) that
includes a list of factors (see adjacent box) they should generally consider in assessing use, value,
and vulnerability of their groundwater resources.

How does EPA's policy on groundwater use designations affect States that consider all of
their groundwater to be a potential drinking water supply?

EPA recognizes that some States have statutes, regulations, or policies designating all
groundwater to be a potential drinking water supply, and requiring that all contaminated
groundwater be cleaned up to drinking water standards.  States may take a more stringent
approach than what EPA would otherwise use for making groundwater use and cleanup
decisions. However, EPA still encourages such States to develop methods for prioritizing
          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                              Groundwater Use Designations, Pg. 9.2

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groundwater resources to focus cleanup actions on facilities in more sensitive areas first.
Examples of factors or criteria that States might use to distinguish among potential drinking
waters on a facility-specific basis are:

    expected timeframe of future use;
   likelihood of use within a certain time period (e.g., 30 years);
   relative priority or value;
   relative vulnerability;
   proximity to existing public and private water supplies;
   presence of elevated concentrations of naturally occurring contaminants; and,
   likelihood of impacting sensitive areas (e.g., wetlands) or environmental receptors4

States are already acquiring this kind of information for other EPA programs. For example,
Section 1453 of the Safe Drinking Water Act (SDWA) as amended in 1996 requires States to
develop and implement Source Water Assessment Programs (SWAPs). These programs must
assess source waters within the State that support public drinking water systems.  A source water
assessment program will consist of: (1) a delineation of the source water area; (2) an inventory of
potential sources of contaminants; (3) a susceptibility analysis of public drinking water systems;
and (4) making the results of the assessments available to the public.

States were required to submit their Source Water Assessment Programs for approval by
February 1999, and have 3  /^ years to complete the assessment following program approval.
Most States will have completed their assessments by May 2003. EPA will not consider
assessments to be complete until the results have been made available to the public. EPA believes
that these assessments will prove to be helpful in identifying areas needing greater protection of
groundwater resources. For more information on Source Water Assessment Programs, refer to
State Source Water Assessment and Protection Programs Guidance (EPA,  1997d). Electronic
information is available at http://www.epa.gov/OGWDW/swp/swappg.html.

Who makes groundwater use designations?

The regulator makes the groundwater use designation for the purposes of facility-specific RCRA
corrective action, since regulators are responsible for ensuring that corrective action is protective
of human health and the environment.  However, a facility can provide the information the
regulator needs to make a groundwater use designation.
       4 Risks to ecological receptors may in some situations be the primary reasons for cleanups, especially for
groundwater that is not designated as a source of drinking water. To protect particularly sensitive ecological
receptors, concentrations of groundwater       levels in some circumstances may have to be lower than
concentrations associated with drinking water standards designed to protect humans.

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                              Groundwater Use Designations, Pg. 9.3

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EPA generally prefers to base its cleanup decisions on State-developed groundwater use
designations.  In particular, EPA generally intends to defer to a State groundwater use designation
when it is part of an EPA-endorsed Comprehensive State Groundwater Protection Program
("CSGWPP") that provides for facility-specific decision making in EPA's remediation programs5.
Also, in the absence of such an EPA-endorsed CSGWPP, EPA may, where appropriate, rely on
an alternative protective State groundwater use designation especially when that designation
considers the same factors listed in the CSGWPP guidance (EPA, 1992a).  States authorized for
corrective action have the lead in making groundwater use designations for cleanups they are
overseeing. However, States may choose to use EPA's groundwater use classification (see next
question) in the absence of a State groundwater use designation system.

Depending on facility-specific circumstances, EPA may find it appropriate to use its own
classification (see next question) to make groundwater use designations.  These circumstances
could include, for example, when:  (1) EPA has the lead role in implementing corrective action at
a facility, and (2) a State designation system is not available or is not in EPA's opinion adequately
protective. You should consult the lead regulatory agency to determine how they generally
determine reasonably expected groundwater use 6.

What is EPA's groundwater use classification?

EPA's groundwater classification system for site-specific groundwater use designations is found
in "Guidelines for Groundwater Classification under the EPA Ground-Water Protection Strategy"
(EPA, 1986 - available at
http://www.epa.gov/correctiveaction/resource/guidance/gw/gwclass.htni).  These guidelines
describe three classes of groundwater that represent a hierarchy of groundwater resource values
to society:  Class I is groundwater that is an irreplaceable source of drinking water and/or
ecologically vital. Class II is groundwater currently used or potentially usable as a source of
drinking water; and Class III includes groundwater that is not a current or potential source  of
drinking water.
       5 A Comprehensive State Groundwater Protection Program (CSGWPP) is a groundwater management
strategy developed by a State.  EPA reviews CSGWPPs and "endorses" those that successfully meet six strategic
activities. EPA outlines specific considerations for each strategic activity in the CSGWPP guidance (EPA, 1992a).
In particular, EPA remediation programs review State guidelines in the CSGWPP to prioritize groundwater based
upon use, value, and vulnerability.  In 1997, EPA's Office of Solid Waste and Emergency Response issued a
directive (EPA, 1997e) encouraging EPA's remediation programs generally to defer to State determinations of
current and future use when based on an EPA-endorsed CSGWPP that has provisions for facility-specific decisions.
A map of States with EPA-endorsed CSGWPPs is available at http://www.cpa.gov/sa.fcwatcr/csgwpp.html. Also,
refer to the discussion on CSGWPPs in EPA, 1996a.

       6  Some States have groundwater classification schemes based on specific parameters (e.g., total dissolved
solids) that mandate particular cleanup standards (e.g., primary and secondary drinking water standards). Links to
State hazardous waste programs are available at httB^/w^^.cBajoy/corroctiyjaclion^tatc.htni.

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                              Groundwater Use Designations, Pg. 9.4

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How can State groundwater use designations enhance protection and flexibility for RCRA
cleanups?

Regulators can prioritize their workload to address those facilities overlying more highly valued
groundwaters first.  In addition, groundwater use designations can serve as a starting place for
predicting the  reasonably expected use(s) of groundwater. Therefore, for States with protective
groundwater use designation systems, regulators may modify groundwater cleanup objectives
while still ensuring protection of human health and the environment based on both current and
potential future uses.

Flexibility associated with groundwater use designations provides more cleanup options to
facilities and regulators. For example, regulators could allow a facility to have an extended
                 to clean up groundwater when the facility overlies groundwater designated as a
future drinking water source, but where no one is currently using or anticipated to use the water
in the foreseeable future.

Another example is that some States have developed groundwater        levels based on
industrial or non-drinking water use. These non-drinking water cleanup levels may be higher in
concentration than drinking water standards, and may facilitate redevelopment of facilities (e.g.,
brownfields -    http://www.epa.gov/swerosps/bf/) that might otherwise remain unused.
However, it is important to evaluate various uses of and exposures to groundwater on a facility-
specific basis prior to relying on generic cleanup levels to ensure these levels would be protective.

Some States also formally identify groundwater that has no beneficial use.  For such situations, as
described in the Final Cleanup       section of this Handbook, regulators could consider source
control and long-term containment rather than cleaning up the groundwater to achieve a particular
cleanup level(s) throughout the contaminant plume. When long-term containment is the cleanup
objective,  regulators should generally establish a point of compliance at the boundary of the
containment zone.

Facilities should not interpret that accepting a higher groundwater cleanup level based on a
groundwater use designation means that less stringent prevention measures are acceptable.
Regardless of the groundwater use designation, facilities should comply with all State and Federal
laws for preventing new releases of contamination, and do their part to minimize hazardous waste
generation.

How do groundwater management or containment zones relate to groundwater use
designations?

Some States7 formally define existing areas of broadly contaminated groundwater as groundwater
management zones. States typically do not use these groundwater management zones to change a
groundwater use designation; rather, they generally use groundwater management zones as a
       7 Illinois, Delaware and Texas are examples of States that have adopted groundwater management zone
approaches. California has a adopted a similar approach called a "containment zone," but does not use it for
facilities subject to RCRA corrective action.

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                              Groundwater Use Designations, Pg. 9.5

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type ofinstitutionaLcontrol8 to publically acknowledge that the contaminated groundwater is
currently unsuitable for its designated use, and to provide reasonable flexibility to facilities that are
implementing long-term groundwater remedies.  While some differences exist among States,
groundwater management zones typically are granted only if a facility satisfies specific provisions.
Some of the more common conditions, which are also consistent with the policies in this
Handbook, include:

   the facility has controlled sources of contamination where appropriate;
   the facility has defined existing boundaries of the contaminated groundwater;
   the facility is currently conducting a groundwater cleanup action under regulatory oversight,
    that is designed to prevent migration of contamination outside the groundwater management
    zone; and
   the facility recognizes that its obligations to ensure protection of human health and the
    environment continue until the groundwater is returned to its designated use.

In general, EPA supports and encourages creative and flexible approaches to address
contaminated groundwater. As such, EPA supports the use of groundwater management zones
when they streamline corrective action decision making, while still ensuring that facilities achieve
protective short- and long-term cleanup goals.

References:

EPA, 1997d. State Source Water Assessment and Protection Programs Guidance (EPA/816/R-
97/009, August).  Available at
EPA, 1997e. The Role of Comprehensive State Groundwater Protection Programs (CSGWPPS)
in OSWER Remediation Programs.  OSWER Directive 9283.1-09.  Available at
http://www.epa.gov/superfund/resources/csgwpp/role.pdf.

EPA, 1996a. Advance Notice of Proposed Rulemaking (61 FR 19432, May 1). Available at
http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/Mav/Dav-01/pr-547.pdf. Particularly
relevant page: 19457.
        To provide overlapping assurances of protection from contamination, EPA recommends that various
forms of institutionjdcontrols be "layered" (i.e., use of multiple institutional controls) or implemented in a series.
For example, prohibitions against installing drinking water wells could be used in conjunction with defining a
groundwater management zone.

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                              Groundwater Use Designations, Pg. 9.6

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EPA, 1992a.  Final Comprehensive State Groundwater Protection Program Guidance
(EPA/100/R-93/001).  Available at
http ://www. epa. gov/correcti veacti on/resource/gui dance/gw/csgwpp.htm.

EPA, 1991b.  Protecting the Nation's Groundwater: EP A's Strategy for the 1990's. Office of the
Administrator. Washington, D.C.  Excerpts available at
http ://www. epa. gov/epaoswer/hazwaste/ca/resource/gui dance/gw/gwstr.htm

EPA, 1986.  Guidelines for Groundwater Classification under the EPA Groundwater Protection
Strategy. Available at http://www.epa.gov/correctiveaction/resource/guidance/gw/gwclass.htm.
          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                             Groundwater Use Designations, Pg. 9.7

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                                   10.  Institutional Controls
                                       (September 2001)
What are institutional controls?
EPA typically describes institutional controls as non-engineered measures1 such as administrative
and/or legal controls that minimize the potential for human exposure2 to contamination by limiting
land or resource use.
EPA expects3 to use institutional controls, such as
water and land use restrictions, primarily to
supplement engineering controls as appropriate to
prevent or limit exposure to hazardous waste and
constituents (EPA, 1996a).  Institutional controls
are appropriate during all stages of the cleanup
process to accomplish various cleanup-related
objectives.  To provide overlapping assurances of
protection from contamination, institutional
controls should be "layered" (i.e., use  of multiple
institutional controls)  or implemented  in a series.

What are the general categories and some
specific examples of institutional controls?

There are four general categories of institutional
controls:

   governmental controls;
   proprietary controls;
          Rationale for
       Institutional Controls

EPA recognizes that, depending on the
site-specific circumstances, facilities can
achieve short-term, intermediate, or final
cleanup goals through various
combinations of removal, treatment,
engineering, and institutional controls.
For groundwater that will likely remain
contaminated for a considerable period
of time, EPA believes that some form of
institutional control will typically be a
critical part of the groundwater remedy
to prevent exposure. Therefore,
institutional controls should be
evaluated,  implemented, and monitored
just like any other component of a
remedy needed to ensure protection.
    enforcement tools with institutional control components; and
    informational devices.
         Fences that restrict access to sites are often termed institutional controls; however, EPA does not
consider fences to be institutional controls because fences are physical barriers instead of administrative or legal
measures. Furthermore, while the term "deed restriction" is often used in remedy decision documents to describe
easements or other forms of institutional controls, "deed restriction" is not a traditional property law term and
should be avoided. For more detailed guidance on institutional controls, refer to a recent document (EPA, 2000b)
issued by EPA titled, "Institutional Controls: A Site Manager's Guide to Identifying, Evaluating and Selecting
Institutional Controls at Superfund and RCRA Corrective Action Cleanups." You can download this document as
well as supporting materials at http://www.cpa.gov/cpaoswcr/ha^wastc/ca/guidancc.ht.m#InstJiutional Controls
         While institutional controls may limit exposure to human populations, facilities and regulators should
ensure that cleanup actions also protect ecologic receptors.

       3 See glossary for a definition of "remedy expectations."

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                                   Institutional Controls, Pg. 10.1

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Each of these categories is briefly described below. For more detailed descriptions of these
categories, including benefits and limitations of different institutional control mechanisms, refer to
the institutional control matrix available at:
http://www.epa.gov/epaoswer/hazwaste/ca/resource/guidance/ics/iTiatrxrv3.pdf.

Governmental Controls - These controls are usually implemented and enforced by State or local
governments.  Once implemented, local and State entities often use traditional police powers to
regulate and enforce the controls. Since this category of institutional control is put in place under
local jurisdiction, they may be changed or terminated with little notice to EPA, and EPA generally
has no authority to enforce such controls. Examples include zoning, ordinances (e.g., restricting
well drilling or water use),  statutes, building permits, or other provisions that restrict land or
resource use.

Proprietary Controls - These controls rely on legal instruments placed in the chain of title for the
subject site or property. The specific instrument may convey a property interest from the owner
(grantor) to a second party (grantee) for the purpose of restricting land or resource use.  One
example of this type of control is an easement that provides access rights for monitoring and
inspection. Another example is a covenant not to dig or drill wells in certain areas. A major
benefit of these controls is that they can be binding on subsequent purchasers of the property and
are transferable. However, enforcement of proprietary controls depends on the party to which the
property interest has been granted. Unlike EPA's Superfund Program, RCRA does not authorize
EPA to acquire property interests to conduct a cleanup, and, therefore, EPA cannot generally
hold or directly enforce proprietary controls associated with a RCRA cleanup.

Enforcement Tools - Federal, State and local governments can, in some circumstances, issue or
negotiate permits, orders, or other enforceable agreements that direct a facility to refrain from
using a property in specific ways. These tools can be very effective but the major limitation is that
most enforcement agreements are only binding on those who enter into the agreement.
Furthermore, restrictions based on enforcement tools are not typically transferable through a
property transaction.

Informational Devices - These tools are typically used to provide information or notification
regarding contamination present at a property.  Common examples include State registries of
contaminated properties, deed notices, and advisories. Informational devices are not typically
enforceable; therefore,  they are best used as a secondary "layer" to help ensure the overall
reliability of other institutional controls.

How can facilities and regulators use institutional controls to address contaminated
groundwater?

For contaminated groundwater, the most common purpose of institutional controls is to protect
human health by preventing exposure. As  described previously, institutional controls "layered" or
used in series provide the best means to ensure protection from contaminated groundwater. For
example, to prevent exposure to contaminated groundwater associated with a given facility,
institutional controls could  include all  or various combinations of the following components: (1)

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                                 Institutional Controls, Pg. 10.2

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State or local governmental controls prohibiting well drilling and use of groundwater in a
designated area; (2) a proprietary easement or covenant providing access to monitor groundwater
for facility investigations or performance monitoring, and/or restrictions on using groundwater
after construction of the remedy is complete; (3) enforceable conditions in a State or EPA permit
or administrative order preventing use of contaminated groundwater and requiring training for
those who could come in contact with contaminated groundwater; (4) placing a notice on the
deed about the existence of contaminated groundwater under the property;  and (5) distributing an
advisory notice to local citizens in a given area that they should avoid drinking or contact with
groundwater.  Facilities and regulators should also consider establishing procedures for
terminating an institutional control(s) when it is no longer necessary to protect human health and
the environment.

How should facilities develop and stakeholders evaluate institutional controls?

It is  helpful for stakeholders to consider institutional controls in a similar manner to how they
would evaluate, implement and monitor an engineered remedy. Therefore,  institutional controls
should go through an evaluation, selection, implementation, and an operation and maintenance
phase.  All four phases are important because institutional controls can work well, work
somewhat, or not work at all.

The  evaluation phase should involve assessing the purpose and type of institutional control based
on how well it would meet a specific short-term protection, intermediate performance, or final
cleanup goal.  This phase should identify all parties that would need to be involved to successfully
implement the institutional control.  Additionally, this phase should include evaluation of the
approaches facilities and regulators will  use to assess the effectiveness of the institutional control.

As with other components of a remedy, the facility should recommend a specific institutional
control approach, and regulators should determine, with input from the public, whether the
facility's recommendation is satisfactory. This selection phase should be based on EPA's
recommended threshold and balancing criteria as discussed in the Final_Cleanup_Goals section of
this Handbook.

The  implementation phase typically involves negotiating, drafting, and recording documents to
put into place the institutional controls that successfully made it through the evaluation phase.
For example, implementing an institutional control could involve placing provisions in a State
permit, creating an easement, putting a notice in a deed, and distributing advisories.

Operation and maintenance should include periodic actions serving to ensure that the institutional
control is working as designed.  Examples of operation and maintenance of an institutional control
include: physical inspection of legal documents including deeds, enforcing institutional controls if
necessary,  and routine distribution of advisories to local citizens.
          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                 Institutional Controls, Pg. 10.3

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References:

EPA, 2000b.  Institutional Controls: A Site Manager's Guide to Identifying, Evaluating and
Selecting Institutional Controls at Superfund and RCRA Corrective Action Cleanups
(EPA/540/F-00/005, September). OSWER Directive 9355.0-74FS-P. Available at
http://www.epa.gov/epaoswer/hazwaste/ca/uidance.htm#Institutional Controls	.

EPA, 1996a.  Advance Notice of Proposed Rulemaking (61 FR 19432, May 1).  Available at
http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/Mav/Dav-01/pr-547.pdf.  Particularly
relevant pages: 19448-49, and 52.
          Handbook of Groundwater Protection and Cleanup Policies for RCPvA Corrective Action

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                            11. Monitored Natural Attenuation
                                      (September 2001)

What is monitored natural attenuation?

The term "monitored natural attenuation" refers to an approach to clean up environmental
contamination by relying on natural processes and monitoring.  Natural attenuation processes
include a variety of physical, chemical, or biological processes that, under favorable conditions,
act without human intervention to reduce the mass,
toxicity, mobility, volume, or concentration of
contaminants in groundwater.
When is monitored natural attenuation a likely
cleanup option?

Monitored natural attenuation may be an
appropriate cleanup option (EPA, 1996a) when the
facility can demonstrate that the remedy is capable
of achieving facility-specific
      in a reasonable                   Facilities
should evaluate and justify monitored natural
attenuation remedies using recommended
threshold and balancing criteria discussed in the
Final Cleanup      section of this Handbook.
Monitored natural attenuation should be justified
on a facility-specific basis and compared with,
where appropriate, other plausible options.  In
general, monitored natural attenuation proposals are
when:
            Rationale for
    Monitored Natural Attenuation

  This policy reflects advancements in
  EPA's understanding of how natural
  attenuation processes can be part of an
  effective cleanup strategy.  Monitored
  natural attenuation is not a "no action"
  cleanup option. Appropriate use of
  monitored natural attenuation supports
  EPA's cleanup objectives, which include
  source control, prevention of plume
  migration, and returning contaminated
  groundwater to its maximum beneficial
  use.
more likely to be acceptable to regulators1
    the facility can demonstrate that monitored natural attenuation will be able to achieve
    groundwater cleanup objectives;

    measures for               of groundwater contamination are already in place;

    the dominant natural attenuation processes cause degradation or destruction of contaminants
    as opposed to those processes that merely dilute contamination or prevent its movement;

    the contaminant plume(s) is already stable or shrinking in extent;
       1 Some States may have specific guidelines, requirements, or restrictions associated with monitored
natural attenuation remedies. For example, some States have specific guidelines for when monitored natural
attenuation would be acceptable, based on: (1) contaminant concentrations, (2) plume location (i.e., off-site), and
(3) anticipated timeframe to clean up the groundwater.

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   the estimated        timeframe2 to meet cleanup levels is reasonable considering factors such
    as groundwater use and timeframes required for other remedies, and the timeframe is
    comparable to that which could be achieved through active remediation (EPA, 1990b - NCP
    preamble page 8734); and

   the facility uses monitored natural attenuation in conjunction with an active remedial system
    or as a follow-up measure.3

For a more complete list of recommended factors, a list of advantages and disadvantages of
monitored natural attenuation remedies, and additional policy and technical guidance, refer to
EPA, 1999d, and EPA, 1998b.  You can also find additional information concerning monitored
natural attenuation in report developed by the National Research Council (NRC, 2000).

Is monitored natural attenuation acceptable when contaminated groundwater is off-site?

The regulator should determine whether monitored natural  attenuation will be acceptable for off-
site contaminated groundwater.4  In making this determination, the regulator should consider
facility-specific circumstances, as well as any applicable Federal  and State requirements and
guidance. One situation where a regulator might accept a monitored natural attenuation remedy
is where no one is currently  exposed to unacceptable levels of contamination and the plume is not
expanding (i.e., the facility meets EPA's stort4erm4ai>tec!M        Other very important
factors to consider when deciding whether to rely on monitored natural attenuation for off-site
contamination include  the thoroughness of public participation5, the ability to conduct long-term
monitoring and prevent exposures, and whether the facility is controlling the source of the
groundwater contamination.

Should monitored natural attenuation remedies include formal contingency measures?

In general, EPA recommends that facilities and regulators evaluating monitored natural
attenuation as a cleanup option should consider the need for identifying one or more contingency
remedies (EPA, 1999d).  A contingency measure (or contingency plan or contingency remedy) is
a cleanup approach specified in a remedy decision document that functions as a "backup" remedy
in the event that the "selected" remedy fails to perform as anticipated. Contingency measures
       2 EPA recommends that proposals for monitored natural attenuation remedies include estimates of the
time needed to achieve groundwater       levels. EPA realizes that such estimates are based on numerous
assumptions, but they are still helpful for comparisons between cleanup options.

       3 While EPA believes regulators will generally be more likely to approve monitored natural attenuation
remedies that involve other more active source control and treatment measures, we recognize that there will be
some situations where monitored natural attenuation may be sufficient as a stand-alone remedial alternative.

       4 EPA's policy (EPA, 1999d) on monitored natural attenuation does not distinguish between on-site and
off-site contaminated groundwater.

       5 Some State programs might require formal concurrence of adjacent property owners for monitored
natural attenuation remedies proposed to address off-site contaminated groundwater.

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                              Monitored Natural Attenuation, Pg. 11.2

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should generally be flexible, allowing for new information about risks and technologies.
Contingency measures are especially appropriate for a monitored natural attenuation remedy that
is selected based primarily on predictive analyses rather than documented trends of decreasing
contaminant concentrations.

How long should a facility monitor a monitored natural attenuation remedy?

A facility should monitor a monitored natural attenuation remedy until the groiindwateiicleanuB
levels are met at the      of           for the                  and longer, where
appropriate, for example where the final remedy involves a component designed for long-term
containment.  EPA specifically added the term "monitored" to the name of this cleanup alternative
to emphasize the importance of long-term performance monitoring. EPA's Policy Directive
States, "Performance monitoring should continue until remediation objectives have been achieved,
and longer if necessary to verify that the facility no longer poses a threat to human health or the
environment." However, the Directive also emphasizes that it is important to include flexibility
sufficient to adjust the frequency (more frequent or less frequent) of monitoring as the situation
warrants.

References:

EPA,  1999d.  Use of Monitored Natural Attenuation at Superfund, RCRA Corrective Action and
Underground Storage Tank Sites (April 21). OSWER Policy Directive 9200.4-17P. Available at
http://www.epa.gov/swerustl/directiv/d9200417.htiTi.  Other helpful links regarding MNA
available at ktti3i//w.vw^                              and
http://www.epa.gov/swerustl/oswermna/mnalinks.htm.

EPA,  1998b.  Technical Protocol for Evaluating Natural Attenuation of Chlorinated Solvents in
Groundwater (EPA/600/R-98/128).  Available at
http://www.epa. gov/correctiveaction/resource/guidance/rem_eval/protocol.pdf

EPA,  1996a.  Advance Notice of Proposed Rulemaking (61 FR 19432, May 1). Available at
http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/Mav/Dav-01/pr-547.pdf. Particularly
relevant pages:  19451-52.

EPA,  1990b.  National Oil and Hazardous Waste Contingency Plan (55 FR 8666 and 40 CFR
300).  The preamble is available at http://www.oscreadiness.org/cec_courses/documents/mar 1990.pdf
The CFR is available throughjhtt]3^/ww^
NRC, 2000. Natural Attenuation for Groundwater Remediation. Committee on Intrinsic
Remediation, Water Science and Technology Board, Board on Radioactive Waste Management,
National Research Council.  Available at http://www.nap.edu/catalog/9792.html
          Handbook of Groundwater Protection and Cleanup Policies for RCPvA Corrective Action

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                               12. Technical Impracticability
                                      (September 2001)

What does technical impracticability mean?

Technical impracticability (TI) for
contaminated groundwater refers to a situation
where achieving                     levels
associated with final         goals is not
practicable from an engineering perspective
(EPA, 1996a; EPA, 1995a; and EPA, 1993a).
The term "engineering perspective" refers to
factors such as feasibility, reliability, scale or
magnitude of a project, and safety.  For
example, a certain cleanup approach might be
technically possible, but the scale of the
operation might be of such magnitude that it
was not technically practicable.

What are the primary factors that might lead
to a technical impracticability
determination ?

Reasons for technical impracticability
generally fall  into one of two categories1:

(1) Hydrogeologic factors, or
(2) Contaminant-related factors.

Examples of limiting hydrogeologic factors
include very low-permeable or highly
heterogeneous soils, or complex fractures or solution cavities in bedrock.  A contaminant-related
factor could be presence of residual non-aqueous phase liquids (NAPLs).  Other contaminant-
related factors could be associated  with extensive volume of or limited access to contaminated
material.

EPA  expects that poor cleanup performance due to inadequate remedial design would not be
sufficient justification for a technical impracticability determination. Design inadequacies could
stem  from, for example, inadequate characterization, selecting inappropriate technologies, or
            Rationale for
      Technical Impracticability

EPA believes that it is appropriate to
recognize the limitations of current
technologies to clean up groundwater to its
maximum beneficial use. This policy provides
facilities a recommended framework to
technically justify such limitations and to focus
resources on protective alternative remedial
strategies.  EPA's policy concerning technical
impracticability does not, however, signal a
scaling back of efforts to address
contaminated groundwater. Rather, this policy
reaffirms EPA's commitment to protect human
health and the environment from
contamination associated with RCRA
corrective action facilities. In particular, the
policy encourages regulators to (1) base their
technical impracticability decisions on sound
science, and (2) where technical
impracticability is adequately justified, ensure
that facilities maintain their alternative
remedial strategies (e.g., containment) as long
as necessary to protect both human health and
the environment.
        1 For further information regarding challenges associated with groundwater cleanups, refer to
Alternatives for Ground Water Cleanup (NRC, 1994), available at http://www.nap.edu/books/0309049946/html/.
Also, you can find numerous resources concerning cleanup technologies at EPA's Technology Innovation Office's
Web site (httpj//www.chMn.org/), including the feature called "Technology Innovation Office's Perspectives"
(Mtel//www;]i^^                    where you can view several recent articles summarizing current
cleanup technology practices and developments.

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                                Technical Impracticability, Pg. 12.1

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deficiencies associated with implementing a particular technology.

Is the mere presence of non-aqueous phase liquids (NAPLs) sufficient to justify a technical
impracticability determination ?

No.  In determining that it is technically impracticable to achieve a set cleanup level, regulators
should not rely solely on the presence of NAPLs2.  The presence of NAPL is just one of many
factors facilities and regulators should consider when evaluating technical impracticability. Other
factors to consider are the type, amount, and location of NAPL, as well as the technologies that
are available to clean up the NAPL. Facilities should, therefore, avoid basing their technical
impracticability justification solely on the presence of NAPL or the apparent inability of any one
technology (e.g., pump-and-treat). A technical impracticability evaluation should be based on a
comprehensive understanding of hydrogeologic factors,  chemical characteristics, and conventional
as well as innovative technologies.

What should facilities include in a technical impracticability evaluation?

EPA generally expects that technical impracticability determinations would be based on an
evaluation by the facility.  EPA's guidance (EPA, 1993a) on technical impracticability suggests
that this evaluation generally include the following:

   Spatial area (the TI zone) over which the TI decision would apply;
  Specific groundwater cleanup levels, consistent with the groujidwatgr_usg_d_esigriation, that are
   considered technically impracticable to achieve;
  Conceptual site model that describes geology, hydrology, groundwater contamination sources,
   transport, and fate;
  Evaluation of the "restoration potential" of the TI zone;
   Cost estimates;
  Any additional information EPA or the State program deems necessary; and
  Description of an alternative remedial  strategy.

When should a facility recommend technical impracticability?

Considering technical impracticability early in corrective action (e.g., during facility
characterization) is a good idea if available information suggests that a facility has hydrogeologic
or chemical-related cleanup limitations.  The facility should submit a technical impracticability
evaluation along with a recommendation for a final remedy. However, as a general matter, we
recommend facilities do not devote significant resources on a technical impracticability
evaluations until they achieve shorMgrm_grotection_gQals (i.e., environmental indicators).
       2 Additional information and reports concerning NAPL contamination is available at
http://www.epa.gov/oerrpage/superiiind/resoiirces/giYdocs/non aqu.htm  See also EPA, 1995b and 1994c.

          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                               Technical Impracticability, Pg. 12.2

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Should regulators make technical impracticability determinations prior to a facility's attempt
to meet groundwater cleanup levels?

In many case, regulators should make technical impracticability determinations only after  facilities
implement pilot or full-scale groundwater cleanup systems because it is often difficult to predict
the  effectiveness of remedies based solely on site characterization data.  However, in some cases,
regulators could make technical impracticability determinations prior to remedy implementation.
Regulators should base these pre-implementation or "front-end" technical impracticability
determinations  on appropriate  site characterization that define the most critical limitations to
meeting a groundwater cleanup level.

If a regulator makes a formal technical impracticability determination, has the facility
satisfied all of their corrective action obligations for groundwater?

A technical impracticability determination does not override the RCRA statutory obligation that
remedies protect human health and the environment.  When the regulator determines that
achieving groundwater cleanup levels associated with final             is technically
impracticable, the regulator should select an "alternative remedial strategy" that protects human
health and the environment and:

   is technically practicable;
   achieves short-term protection goals and, if appropriate, intermediate performance goals;
    controls the sources  of contamination;
   achieves groundwater        levels outside the TI zone;
   provides for appropriate long-term operation, maintenance, and monitoring; and
   is consistent with the overall cleanup goals for the facility.

Why should facilities conduct investigations within the technical impracticability zone?

Facilities should characterize within the TI zone to: (1) support the technical impracticability
evaluation; (2) identify sources that they should control,  even within the TI zone; (3) evaluate the
potential for cross-media transfer of contamination they may need to manage (e.g., from
groundwater to air) as part of an alternative remedial strategy; and (4) support the development of
an alternative remedial strategy as discussed above.  The particular circumstances of the facility
will govern the amount of characterization needed to accomplish these objectives.

Why should facilities control sources within the technical impracticability zone?

Source control  is typically an important part of an acceptable alternative remedial strategy and is
one EPA's three recommended threshold criteria associated with                    Source
control prevents the continued input of contamination into surrounding environmental media and
can help improve the likelihood that the alternative remedial strategy will be effective in the long
term.  Controlling sources within the technical impracticability zone will help to limit the amount
of contamination facilities will need to address if and when achieving the groundwatgr_cleariug
levels becomes  technically practicable in the future. However, as mentioned previously in this

          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                               Technical Impracticability, Pg. 12.3

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Handbook (see Final Cleanup Goals and Source Control), EPA believes the exact balance
between treating, removing, and containing the source, even in the context of a technical
impracticability determination, is best evaluated on a case-by-case basis.

How does a technical impracticability determination affect the point of compliance?

Even when regulators make a technical impracticability determination, they should establish a
point of compliance as necessary to track progress in meeting cleanup goals associated with the
alternative remedial strategy. For example, when an alternative remedial strategy involves
returning a portion of the plume to its maximum beneficial use, regulators should generally
establish a point of compliance throughout the contaminated groundwater outside of the technical
impracticability zone. Additionally, if the alternative remedial strategy involves long-term
containment, regulators  should generally establish a point of compliance at the boundary of the
technical impracticability zone to verify that the containment system is working as intended.

How long should a technical impracticability determination last?

EPA generally recommends that, for RCRA corrective action, technical impracticability
determinations  and the responsibility of the facility to maintain its  alternative remedial strategy
remain in place until subsequent advances in technology make achievement of the groundwater
cleanup levels within the TI zone technically practicable. Facilities should realize that a technical
impracticability determination for many circumstances could warrant ongoing3 care to ensure
long-term protection.

Should regulators and/or facilities revisit technical impracticability determinations?

Technical impracticability determinations are based  on current understanding of capabilities and
limitations of cleanup technologies. Cleanup goals that are technically impracticable today could
become technically practicable at some point in the  future.  Therefore, EPA's 1993  guidance on
technical impracticability (EPA, 1993a) recognizes that regulators overseeing RCRA corrective
action may require, where appropriate, facilities to "undertake additional remedial measures in the
future if subsequent advances in remediation technology make attainment of media  cleanup
objectives technically practicable." Examples could  include situations where new information or
new technologies become available that indicate the facility could  achieve groundwater cleanup
levels that were previously  determined to be technically impracticable. Sometimes,  the facility
might want to revisit the technical impracticability determination without prompting by the
regulator. For example, the facility might want to try  a new technology that has the ability to
achieve the original cleanup objectives rather than continuing to implement an alternative remedial
strategy. Therefore, EPA recommends that both facilities and regulators periodically re-evaluate
the technical impracticability decision as part of routine performance
       3 Some cleanup programs (e.g., New York State ~ see
http://www.clii-in.org/eiformii2000/prez/ppfraine 1 .cfm?id=81) have referred to long-term containment of
contaminated groundwater in terms of "perpetual care" obligations.

          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                Technical Impracticability, Pg. 12.4

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References:

EPA, 1996a.  Advance Notice of Proposed Rulemaking (61 FR 19432, May 1).  Available at
http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/Mav/Dav-01/pr-547.pdf. Particularly
relevant page: 19451.

EPA, 1995a.  Consistent Implementation of the FY 1993 Guidance on Technical Impracticability
of Ground Water Restoration at Superfund Sites (January). OSWER Directive 9200.4-14.
Additional information available at
http://www.epa.gov/oerrpage/superfond/resoorces/gwdocs/tecjmp.htm.

EPA, 1995b.  Groundwater Issue: Light Non-Aqueous Phase Liquids (EPA/540/S-95/500).
Available at http://www.epa.gov/ada/download/issue/lnapl.pdf.

EPA, 1994c.  DNAPL Site Characterization (EPA/540/F-94/049). Available at
http://www.epa.gov/oerrpage/supeifund/resources/gwdocs/dnapl.pdf.

EPA, 1993a.  Guidance for Evaluating the Technical Impracticability of Groundwater Restoration
(EPA/540/R-93/080, September).  Available at
http://www.epa.gov/oerrpage/superfund/resources/gwdocs/techimp.htni.

NRC, 1994. Alternatives for Ground Water Cleanup I Committee on Ground Water Cleanup
Alternatives, Water Science and Technology Board, Board on Radioactive Waste Management,
Commission on Geosciences, Environment, and Resources, National Research Council. National
Academy Press, 1994. Available at htj^i//wwwjiapJMu/b^^
          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                              Technical Impracticability, Pg. 12.5

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                     13.  Reinjection of Contaminated Groundwater
                                     (September 2001)

Can facilities reinject groundwater that is contaminated with hazardous wastes back in the
subsurface as part of corrective action?

RCRA section 3020(a) bans hazardous waste
disposal by underground injection into or above a
[geologic] formation that contains (within 1/4 mile of
the well used for such underground injection) an
underground source of drinking water.  However,
RCRA section 3020(b) exempts from that ban the
injection of groundwater contaminated with
hazardous wastes provided that certain conditions
are met.1
        Rationale for
 Reinjection of Contaminated
         Groundwater

EPA's policy on reinjection of
contaminated groundwater
encourages facilities and
regulators to consider
opportunities for using in-situ
bioremediation and other in-situ
treatments where such
technologies are protective and
offer advantages over other
cleanup alternatives.
What are the specific conditions facilities have to
meet prior to reinjecting groundwater
contaminated with hazardous waste into the
subsurface?

The exemption provided by RCRA section 3020(b)
allows facilities to reinject groundwater that is
contaminated with hazardous wastes back into the
aquifer from which it was withdrawn if:  (1) the re-
injection is part of a response action under section
104 or 106 of the Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA), or part of RCRA corrective action intended to clean up such contamination; (2) the
contaminated groundwater is treated to substantially reduce hazardous constituents prior to such
reinjection; and (3) the cleanup will, upon completion, be sufficient to protect human health and
the environment.

The second element of the statutory provision in the preceding paragraph means that treatment
must occur prior to reinjection, and the treatment substantially reduces hazardous constituents in
the groundwater either before or after reinjection of the contaminated groundwater back into the
aquifer from which it was withdrawn (EPA, 2000a;  also, see EPA, 1989a).
       1  40 CFR 144.13 and 144.23 of the Underground Injection Control (UIC) Program regulations include an
exemption for Class IV wells (wells involving the injection of hazardous waste) similar to that found in RCRA
section 3020(b).  Under the UIC Program, these Class IV wells are authorized by rule. Prior to construction of
such wells, facilities must notify their state UIC Program and submit inventory information as required by 144.26.
You can access UIC regulations at hJMl//HaQJgessj^                              or
http://www.epa.gov/safewater/uic/iiicregs.litnTl.

          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                         Reinjection of Contaminated Groundwater, Pg. 13.1

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Does section 3020(b) allow the reinjection of contaminated groundwater after the addition of
nutrients or other in situ treatment products?

Yes. Section 3020(b) allows the reinjection of contaminated groundwater containing these
additives as long as the hazardous constituents in the groundwater are substantially reduced,
either before reinjection or as a result of subsequent in-situ treatment consistent with section
3020(b)(2).  The remedy must also comply with sections 3020(b)(l) and (3) described in the
previous question. Furthermore, the substantial reduction  should occur in a reasonable period of
time (i.e., in a time period consistent with the CERCLA and/or RCRA cleanup objectives made
for the groundwater) and the regulator should consider whether hydraulic containment would be
appropriate to ensure protection of the groundwater resource.  Also, stakeholders should be
aware that while the RCRA statute could allow for such reinjection, facilities may also have to
comply with requirements of State Underground Injection Control (UIC) programs. Therefore,
facilities should coordinate with State regulators to obtain, as necessary, variances, waivers,
construction permits, approvals, etc.

What if a facility wants to re-inject groundwater that is contaminated with nonhazardous
wastes as part of corrective action?

The ban on injecting hazardous wastes described in RCRA Section 3020(a) does not apply if the
reinjected groundwater does not contain hazardous wastes. However, injection wells that re-
inject groundwater that is contaminated with nonhazardous wastes are Class V wells and facilities
must still comply with all UIC Program requirements, including notifying the UIC Program prior
to construction of any injection well.  Facilities should also consult with their State regulators
because many States have stricter groundwater protection laws that could prohibit the reinjection
of any  contaminated groundwater, regardless of whether it is hazardous or not. For more
information about State UIC Programs, refer to http://www.epa.gov/safewater/uic/primacy .html.
For information about EPA's UIC Program, refer to  httg^/w^w1ega^goWsafjewjtgr/uic1htoil.

References:

EPA, 2000a. Applicability of RCRA Section 3020 to In-Situ Treatment of Ground Water.
Memorandum from Elizabeth Cotsworth, Director, Office  of Solid Waste to RCRA Senior Policy
Advisors (December 27).  Available at
http://www.epa.gov/epaoswer/hazwaste/ca/resource/guidance/remwaste/refrnces/pol-mem3.pdf.

EPA, 1989a. OSWER Directive 9234.1-06, "Applicability of Land Disposal Restrictions to
RCRA and CERCLA Groundwater Treatment Reinjection Superfund Management Review:
Recommendation No. 26," (December).  Available at
http://www.epa.gOv/epaoswer/hazwaste/ca/resource/guidance/retnwaste/refrnces/l 4_3020b.pdf
          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                        Reinjection of Contaminated Groundwater, Pg. 13.2

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                               14. Performance Monitoring
                                     (September 2001)

What is performance monitoring?

EPA defines performance monitoring as the periodic measurement of physical and/or chemical
parameters to evaluate whether a remedy is
performing as expected. Facilities should
conduct performance monitoring to
evaluate whether the facility is making
progress toward achieving short-term
protection goals.             performance
      or finaljd(M!lJ|LgQMs.

What should the performance monitoring
accomplish?

Facilities should design performance
monitoring1 programs to, for example:

    detect changes in environmental
    conditions (e.g., hydrogeologic,
    geochemical, microbiological, or other
    changes) that may reduce the efficacy of
    the remedy;
             Rationale for
        Performance Monitoring
Properly designed performance monitoring
programs are especially important for
groundwater cleanups because the
concentration and distribution of contamination
in groundwater often change with time.
Likewise, natural and human factors (e.g.,
seasonal precipitation or nearby groundwater
usage) can influence the ability of cleanup
actions to control migration of contaminated
groundwater. Performance monitoring can
assess changes in groundwater so that facilities
can modify cleanup actions to ensure maximum
efficiency, protectiveness, and compliance.
Performance monitoring can also demonstrate
whether or not a cleanup action is performing as
    identify any potentially toxic and/or        expec e
    mobile transformation products;
    verify that the plume(s) is not
    expanding above levels of concern (either down gradient, laterally, or vertically);
    assess effectiveness of the cleanup or treatment system2;
    evaluate whether advances in technologies or approaches could improve the ability of a
    remedy to achieve cleanup goals;
    verify no unacceptable exposure to down gradient receptors;
    detect new releases of contaminants to the environment that could impact the effectiveness of
    the remedy;
    demonstrate the effectiveness of institutional controls that were put in place to protect
    potential receptors; and
    verify attainment of short-term, intermediate,  or final goals.
       1 For more information, refer to the numerous documents EPA has produced that address groundwater
monitoring (EPA, 1997b; EPA, 1997g; EPA, 1996a; EPA, 1996c; EPA, 1994a; and EPA, 1992b; EPA, 1992c; and
EPA, 1992d).

       2  Such evaluations can also provide information facilities can use to verify or adjust their estimates of
cleanup timeframes.

          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                Performance Monitoring, Pg. 14.1

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What should a performance monitoring program include?

Facilities should include the specific approaches they intend to use to periodically assess remedy
effectiveness towards meeting short-term, intermediate, or final goals. The performance
monitoring program should include a description of the location(s), frequency, type3 and quality
of samples, techniques, and measurements that a facility will use to collect information needed to
make decisions associated with a particular cleanup goal. However, EPA urges facilities and
regulators to design performance monitoring approaches to be flexible and easily adaptable to
account for changing conditions and information needs.

How often should a facility monitor?

The frequency of monitoring should be adequate to detect, in a timely manner, the potential
changes in facility conditions listed above.  This means that the rate of groundwater flow and
contaminant movement are important factors to  consider when facilities and regulators determine
monitoring frequency.  The monitoring plan should include flexibility for adjusting the monitoring
requirements over the life of the remedy. For example, it may be appropriate to decrease the
monitoring frequency (e.g., semiannually, annually, or for even longer time periods) and number
of constituents once it has been determined that the remedy is performing as expected and very
little change is observed from one sampling round to the next. In contrast, the monitoring
frequency may need to be increased, for example:  (1) when unexpected conditions (e.g., plume
migration or change in groundwater use) occur,  or (2) to determine the effect of modifications to
a cleanup action (e.g., changes in pumping rates).

How long should performance monitoring continue?

For final remedies that  involve restoring contaminated groundwater to its maximum beneficial
uses, facilities should generally continue performance monitoring for a specified period (e.g., 3
years) after the facility  achieves the groundwater cleanup levels at the throughout-the-plume/unit
boundary point of compliance. Extending the performance monitoring to this point helps to verify
that the groundwater no longer poses a threat, and that concentrations of contaminants will not
rise (i.e., "rebound")  after the facility shuts down its active cleanup system. In general, regulators
will typically determine how long performance monitoring needs to continue for any given facility.
For final cleanup objectives based on containment, performance monitoring should continue as
long as the containment is necessary to protect human health and the environment.
       3 Many stakeholders only associate performance monitoring with chemical analysis of groundwater
samples. For some cleanup actions, especially those involving hydraulic containment, facilities can often
demonstrate performance with frequent hydrogeologic measurements (e.g., groundwater elevation monitoring)
supplemented with less frequent groundwater quality measurements.

          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                               Performance Monitoring, Pg. 14.2

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References:

EPA, 1997b. Rules of Thumb for Superfund Remedy Select on (EPA/540/R-97/013).  Available
at http://www.epa.gov/superfund/resources/rules/mlesthiTi.pdf.

EPA, 1997g. Groundwater Issue Paper: Design Guidelines for Conventional Pump and Treat
Systems (EPA/540/S-97/504). Available at
http://www.epa.gov/oerrpage/superfund/resources/gwdocs/pniptreat.htni

EPA, 1996c. Presumptive Response Strategy and Ex-Situ Treatment Technologies for
Contaminated Ground Water at CERCLA Sites (EPA/540/R-96/023, October). Available at
http://www.epa. gov/oerrpage/superfund/resources/gwdocs/pum_tre.htm

EPA, 1996a. Advance Notice of Proposed Rulemaking (61 FR 19432, May 1). Available at
http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/May/Day-01/pr-547.pdf.  Particularly
relevant pages: 19452-53.

EPA, 1994a. Guidance for the Data Quality Objective Process (EPA/600/R-96/055, September).
Available at: http://www.epa.gov/correctiveaction/resource/guidance/qa/epaqag4.pdf.

EPA, 1992b. RCRA Groundwater Monitoring Draft Technical Guidance (November). Available
at http://www.epa.gov/correcti veaction/resource/guidance/sitechar/gwmonitr/rcra_gw. pdf.

EPA, 1992c. Statistical Analysis of Groundwater Monitoring Data at RCRA Facilities 
Addendum to Interim Final Guidance (July). Available at:
http://www.epa.gov/correctiveaction/resource/guidance/sitechar/gwstats/gritsstat/download/adde
ndum.pdf.

EPA, 1992d. Methods for Evaluating Attainment of Cleanup Standards Volume 2: Groundwater
(EPA/230/R-92/014). Available at http://www.clu4n.org/download/stats/vol2gw.pdf
          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                              Performance Monitoring, Pg. 14.3

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                          15. Completing Groundwater Remedies
                                      (September 2001)

What does completing a groundwater remedy mean with respect to RCRA Corrective Action?

EPA generally recognizes the following phases of completing1 a groundwater remedy designed to
achieve
   implementing the final remedy (i.e.,
    construction is complete and the remedy is
    operating as intended);

    achieving final cleanup goals; and

   fulfilling all cleanup obligations associated
    with the contaminated groundwater including
    long-term monitoring.

What does it mean to complete the
implementation phase of a groundwater
remedy?

Completing the implementation phase of a final
groundwater remedy means that physical
construction2 has been completed and the remedy
is operating as  designed.  Further cleanup
activities are limited to continued operation, maintenance, and monitoring of the remedy.
Sometimes EPA refers (EPA, 1997f) to this phase in the completion of a remedy as Construction
Completion.3
                                                             Rationale for
                                                              Completing
                                                        Groundwater Remedies

                                                   This policy on completing groundwater
                                                   remedies encourages regulators and
                                                   facilities to recognize various phases or
                                                   milestones associated with remedies
                                                   designed to achieve final cleanup goals.
                                                   However, EPA also discourages facilities
                                                   from prematurely considering that they
                                                   have fulfilled all of their corrective action
                                                   obligations when further operation,
                                                   maintenance, or monitoring is needed to
                                                   protect human health or the environment.
       1 This Handbook addresses corrective action completion only in the context of contaminated groundwater
and sources of groundwater contamination.  Facilities often have cleanup activities other than those associated with
groundwater that they need to address to fulfill all of their corrective action obligations. Furthermore, the Office of
Solid Waste is currently developing a new guidance memorandum addressing various administrative issues
associated with completion of Corrective Action at RCRA facilities. That document, when issued, will be available
at Mji^/wwwxaMyioy^xHTi^^        EPA acknowledges that this Handbook may need to be updated to be
consistent with the new completion guidance memorandum. Also refer to EPA, 1996a for additional guidance
concerning "completion of corrective measures."

       2 Remedies that rely solely on monitore^Jiaturalattenuation to address contaminated groundwater would
not typically involve "construction" apart from installing monitoring wells.

       3 EPA's RCRA data management system (EPA, 1999f; available at
http://www.cpa.gov/cpaoswcr/hay.wastc/ca/facilitv/ca-diction.pdf - page 23 describes construction completion
as code CA550 titled "Certification of a Remedy Completion or Construction Completion."

           Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                            Completing Groundwater Remedies, Pg. 15.1

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What does it mean to complete a groundwater remedy with respect to achieving final cleanup
goals?

As conveyed earlier in this Handbook, a facility achieves                  for groundwater by
taking actions as necessary to ensure protection of human health and the environment from
contaminated groundwater.  As a means to demonstrate achieving this overall statutory and
regulatory mandate, EPA recommends facilities achieve site-specific media cleanup objectives4,
and control surface and subsurface sources (see Source..Control), to the extent practicable, that
would otherwise result in increases of contaminants in groundwater above levels of concern.

For example, for a final remedy designed to return contaminated groundwater to its maximum
beneficial use, this phase of completing a remedy typically means that the facility achieved
groundwater         levels at the throughout-the-plume pdnljjfjxiiipiian^ and they have
controlled further releases of contaminants from sources. Alternatively, if the final remedy
involves long-term containment, this phase of completion could, for example, correspond to the
facility successfully controlling sources and achieving groundwater cleanup levels at a point of
compliance located outside the containment area.

What does it mean to fulfill all cleanup obligations associated with contaminated groundwater
at a particular facility?

Regulators will generally consider that a facility has fulfilled all of its cleanup obligations5
associated with contaminated groundwater when a facility:

  achieves final        goals;
  no longer needs to conduct                         to ensure protection of human health and
   the  environment6;
       4 Media cleanup objectives refer to broad cleanup objectives that often include the more specific concepts
of media cleanup levels, points of compliance, and cleanup timeframes.  In the Overview section of this Handbook,
we explain that you could consider these three concepts as the "what, where, and when" elements of a cleanup. In
the 1996 ANPR (EPA, 1996a), EPA referred to media cleanup objectives as media cleanup standards; we now use
media cleanup objectives to avoid confusion with the term "standard," which is often associated with just numeric
values.

       5 EPA's RCRA data management system (EPA,  1999f; available at
http://www.epa.gov/epaoswer/tozwaste/ca/facilitv/ca-diction.pdf - page 37) describes completion in terms of
satisfying all permit or order requirements for corrective action, and assigns the code CA 999 titled Corrective
Action Process Terminated. This event code can apply to the cleanup of an entire facility or the cleanup of an
individual area or portion of a facility.

       6 For example, the facility no longer needs to conduct performance monitoring to ensure the
concentrations of contaminants in groundwater do not rebound above levels of concern, or that a long-term
containment remedy is working as designed.  Note that some cleanup programs (e.g., New York State - see
http://www.clii-in.org/eifoniin2000/prez/ppfranie 1 .cfm?id=81) have referred to long-term containment of
contaminated groundwater in terms of "perpetual care" obligations.

           Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                             Completing Groundwater Remedies, Pg. 15.2

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   is not responsible for maintaining institutionaLcontrols;
   does not need to maintain financial assurances for corrective action activities associated with
    the groundwater cleanup;
   fulfills all procedures specified in a permit or order for removal and decontamination of units,
    equipment, devices, and structures associated with the groundwater remedy;
   fulfills public participation responsibilities associated with groundwater remedy decisions; and
   fulfills all other facility-specific permit or order requirements pertaining to the groundwater
    remedy.

How do facilities and regulators typically decide when a groundwater remedy achieves media
cleanup objectives?

Facilities and regulators often rely on statistical procedures to determine whether a remedy has
achieved specific media cleanup objectives.  Interested stakeholders can refer to EPA's detailed
guidance on this subject contained in "Methods for Evaluating the Attainment of Cleanup
Standards Volume 2: Groundwater" (EPA, 1992d) which is available at
http://www.clu-in.org/download/stats/vol2gw.pdf. Some of the helpful topics and resources
addressed in that guidance include:

   Introduction to statistical concepts and decisions;
   Defining attainment objectives (e.g., cleanup levels);
   Designing the sampling and analysis plan used to determine success of cleanup;
   Descriptive statistics (e.g., mean and variance) and hypothesis testing;
   Deciding to terminate treatment; and,
    Statistical tables, examples, and blank worksheets.

References:

EPA, 1999f.  Resource Conservation and Recovery Act Data Element Dictionary - version 7.2.0.
Available at htt]3:/6ywwji)a^                                             Particularly relevant
pages: 23 and 37.

EPA, 1996a.  Advance Notice of Proposed Rulemaking (61 FR 19432, May 1).  Available at
http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/Mav/Dav-01/pr-547.pdf. Particularly
relevant page: 19453.

EPA, 1992d.  Methods for Evaluating Attainment of Cleanup Standards  Volume 2: Groundwater
(EPA/230/R-92/014).   Available at http://wjwA
          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                           Completing Groundwater Remedies, Pg. 15.3

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                                Appendix 1 - References

EPA, 2001a. EPA Indian Policy (July 11). Available at
http://www.epa.gov/indian/pdfs/reaffirniindpol01.pdf.

EPA, 2001b. ECO-UPDATE: The Role of Screening Level Risk Assessments and Refining
Contaminants of Concern in Baseline Ecologic Risk Assessments (EPA/540/F-01/014, June).
Available at http://www.epa.gov/superfund/programs/risk/ecoup/slera0601.pdf.

EPA, 2001c. Risk Business (EPA/530/F-00/032, February).  Available at
http ://www.   gov/epaoswer/osw/docs/ri      . pdf.

EPA, 2001d. RCRA Cleanup Reforms Round II -- Fostering Creative Solutions (EPA/530/F-
01/001, January). Available at    ://www.epa.gov/epaoswer/hazwaste/ca/refortns.htm.

EPA, 2000a. Applicability of RCRA Section 3020 to In-Situ Treatment of Ground Water.
Memorandum from Elizabeth Cotsworth, Director, Office of Solid Waste to RCRA Senior Policy
Advisors (December 27). Available at
http://www.epa.gov/epaoswer/hazwaste/ca/resource/guidance/reiTiwaste/refmces/pol-meiTi3.pdf.

EPA, 2000b. Institutional Controls: A Site Manager's Guide to Identifying, Evaluating and
Selecting Institutional Controls at Superfund and RCRA Corrective Action Cleanups
(EPA/540/F-00/005, September). OSWER Directive 9355.0-74FS-P.  Available at
http://www.epa.gov/epaoswer/hazwaste/ca/resource/guidance/ics/icfactfinal.pdf.

EPA, 2000c. Proceedings of the Ground-Water/Surface-Water Interactions Workshop
(EPA/542/R-00/007, July).  Available at
http://www.epa.gov/ti o/tsp/download/gwsw/gwsw_partl.pdf.
http://www.epa.gov/tio/tsp/download/gwsw/gwswjart2.pdf. and
http://www.epa.gov/ti o/tsp/download/gwsw/gwsw_part3.pdf.

EPA, 1999a. Corrective  Action for  Solid Waste Management Units at Hazardous Waste
Management Facilities (64 FR 54604, October 7).  Available at
http://www.epa.gov/correctiveacti on/resource/guidance/gen_ca/withdrwl.htm.

EPA, 1999b.  Safe Drinking Water Act, Section 1429 Groundwater Report to Congress
(EPA/816/R-99/016, October).  Available at http://www.epa.gov/ogwdwOOO/gwT/finalgw.pdf.

EPA, 1999c. RCRA Cleanup Reforms (EPA/530/F-99/018, July). For more information, refer to
http://www.epa.eov/epaoswer/hazwaste/ca/reforms.htm
          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

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EPA, 1999d.  Use of Monitored Natural Attenuation at Superfund, RCRA Corrective Action and
Underground Storage Tank Sites (April 21). OSWER Policy Directive 9200.4-17P. Available at
http://www.epa.gov/swerustl/directiv/d9200417.htiTi.  Other helpful links regarding MNA
available at ktt|3i//w.yj^^^                            and
http://www.epa.gov/swerustl/oswermna/mnalinks.htm

EPA, 1999e.  Interim Final Guidance for RCRA Corrective Action Environmental Indicators
(February 5).  Available at    ://www. epa.gov/epaoswer/osw/ei_guida. pdf .

EPA, 1999 f. Resource Conservation and Recovery Act Data Element Dictionary - version 7.2.0.
Available at http ://www. epa. gov/epaoswer/hazwaste/ca/faci 1 i ty/ca-di cti on . pdf.

EPA, 1998a.  RCRA Orientation Manual (EPA/530/R-98/004). Available at
http://www.epa.gov/epaoswer/general/orientat/index.htm.

EPA, 1998b.  Technical Protocol for Evaluating Natural Attenuation of Chlorinated Solvents in
Groundwater (September).  EPA/600/R-98/128.  Available at
http://www.epa. gov/correctiveaction/resource/guidance/rem_eval/protocol. pdf.

EPA, 1998c.  Memorandum from Elizabeth Cotsworth to RCRA Senior Policy Advisors titled,
Risk-Based Clean Closure (March 16). Available at
http://www.epa.gov/correctiveaction/resource/guidance/risk/cclosfnl.pdf.

EPA, 1998d.  Standards Applicable to Owners and Operators of Closed and Closing Hazardous
Waste Management Facilities: Post-Closure Permit Requirement and Closure Process; Final Rule
(63 FR 56710). Available at
http://www.epa.gov/fedrgstr/EPA-WASTE/1998/October/Dav-22/f28221.pdf.

EPA, 1997a.  Memorandum from Elliott P. Laws and Steven A. Herman to RCRA/CERCLA
Senior Policy Managers titled, "Use of the Corrective Action Advance Notice of Proposed
Rulemaking as Guidance" (January 17). Available at
http://vosemite.epa.gov/osw/rcra.nsf/documents/8BF009F9B3672563852566H0072DA71.

EPA, 1997b.  Rules of Thumb for Superfund Remedy  Select on (EPA/540/R-97/0 13).  Available
at hltp;//www jg^
EPA, 1997c. A Citizen's Guide to Understanding Presumptive Remedies (EPA/540/F-97/019,
October). Available at hjjji^ywwiyjipjy^
EPA, 1997d. State Source Water Assessment and Protection Programs Guidance (EPA/816/R-
97/009, August). Available at httpi//waw,epa.,^^
          Handbook of Groundwater Protection and Cleanup Policies for RCPvA Corrective Action

                                     Appendix 1, Pg. 2

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EPA, 1997e. The Role of Comprehensive State Groundwater Protection Programs (CSGWPPS)
in OSWER Remediation Programs. OSWER Directive 9283.1-09.  Available at
    ://www.    gov/superfund/resources/csgwpp/rol e.pdf.

EPA, 1997f.  Exposure Factors Handbook (EPA/600/P-95/002F).  Available at
http://www.epa.gov/ncea/exposfac.htm.

EPA, 1997'g. Groundwater Issue Paper: Design Guidelines for Conventional Pump and Treat
Systems (EPA/540/S-97/504). Available at
http://www.epa.gov/oerrpage/superfund/resources/gwdocs/ pmptreat.htm

EPA, 1996a. Advance Notice of Proposed Rulemaking (61 FR 19432, May 1).  Available at
http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/Mav/Dav-01/pr-547.pdf.

EPA, 1996b. Memorandum from Steven A. Herman and Elliott P. Laws to RCRA/CERCLA
Senior Policy Managers titled, "Coordination between RCRA Corrective Action and Closure and
CERCLA Site Activities" (September 24).  Available at
http://www.epa. gov/correctiveaction/resource/guidance/gen_ca/coordmem.pdf.

EPA, 1996c. Presumptive Response Strategy and Ex-Situ Treatment Technologies for
Contaminated Groundwater at CERCLA Sites (EPA/540/R-96/023, October). Available at
http://www.epa.gov/superfund/resources/gwguide/index.htm.

EPA, 1996d. RCRA Public Participation Manual (EPA/53O/R-96/007). Available at
http://www.epa.gov/epaoswer/hazwaste/perniit/pubpart/manual.htm. Particularly relevant pages:
2.5-2.7.

EPA, 1996e. Soil Screening Guidance Fact Sheet (EPA/540/F-95/041, July).  Available at
http://www.epa.gov/oerrpage/superfond/resoorces/soil/.

EPA, 1995a. Consistent Implementation of the FY 1993 Guidance on Technical Impracticability
of Ground Water Restoration at Superfund Sites (January). OSWER Directive 9200.4-14.
Additional information available at
http://www.epa.gov/oerrpage/superfund/resources/gwdocs/tec_imp.htm.

EPA, 1995b. Groundwater Issue: Light Non-Aqueous Phase Liquids (EPA/540/S-95/500).
Available at http://www.epa.gov/ada/download/issiie/lnapl.pdf.

EPA, 1994a. Guidance for the Data Quality Objective Process (EPA/600/R-96/055, September).
Available at http://www.epa.gov/correctiveaction/resource/guidance/qa/epaqag4.pdf.

EPA, 1994b. The RCRA Corrective Action Plan (EPA/520/R-94/004, May).  Available at
http://www.epa.gov/epaoswer/hazwaste/ca/resource/guidance/gen_ca/rcracap.pdf
          Handbook of Groundwater Protection and Cleanup Policies for RCPvA Corrective Action

                                    Appendix 1, Pg. 3

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EPA, 1994c. DNAPL Site Characterization (EPA/540/F-94/049).  Available at
    ://www. epa. gov/oerrpage/superfund/resources/gwdocs/dnapl. pdf.

EPA, 1993a. Guidance for Evaluating the Technical Impracticability of Groundwater Restoration
(EPA/540/R-93/080, September).  Available at
http://www.epa.gov/oerrpage/superfund/resources/gwdocs/techimp.htm

EPA, 1993b. Waste Management Area and Supplemental Well Guidance (June).  Available at
http://www.epa. gov/correctiveaction/resource/guidance/gw/wma_sup.htm.

EPA, 1992a. Final Comprehensive State Groundwater Protection Program Guidance
(EPA/100/R-93/001). Available at
    ://www.    gov/correcti veacti on/resource/gui dance/gw/csgwpp .htm.

EPA, 1992b. RCRA Groundwater Monitoring Draft Technical Guidance  (November).  Available
at http://www.epa..gov/correctiveaction/resource/guidance/sitechar/gwmonitr/rcra^.gw.pdf.

EPA, 1992c. Statistical Analysis of Groundwater Monitoring Data at RCRA Facilities -
Addendum to Interim Final Guidance (July). Available at:  http://www.epa.gov/correctiveaction/
resource/guidance/sitechar/gwstats/gritsstat/downl oad/addendum.pdf.

EPA, 1992d. Methods for Evaluating Attainment of Cleanup Standards Volume 2: Groundwater
(EPA/230/R-92/014). Available at http://www.du4n.org/download/stats/vol2gw.pdf

EPA, 199la. Managing the Corrective Action Program for Environmental Results: The RCRA
Stabilization Effort (October 25). Available at
http://vosemite.epa.gov/osw/rcra.nsf/d8382df2d09b64668525652800519745/27dlbaa5cldbb8f38
525670fD06be76d?OpenDocument.

EPA, 1991b. Protecting the Nation's Groundwater: EP A's Strategy for the 1990's.  Office of the
Administrator.  Washington, D.C. Excerpts available at
    ://www. epa. gov/epaoswer/hazwaste/ca/resource/guidance/gw/gwstr.htm

EPA, 1991c. A Guide to Principal Threats and Low Level Threat Wastes. Superfund Publication
9380.3-06FS (November). Available at
http://www.epa.gov/oerrpage/superfund/resources/gwdocs/threat.pdf.

EPA, 199Id. USEPA's User's Guide for the Johnson and Ettinger Model for Subsurface Vapor
Intrusion into Buildings.  Available at
http://www.    gov/oenpage/superfund/programs/risk/airmodel/guide.pdf.  The model itself can
be downloaded from
http://www.epa.gov/oerrpaee/superfund/programs/risyairmodel/iohnson  ettinger.htm.
          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                     Appendix 1, Pg. 4

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EPA, 1990a. The Nation's Hazardous Waste Management Program at a Crossroads: The RCRA
Implementation Study (EPA/530/SW-90/069).

EPA, 1990b. National Oil and Hazardous Waste Contingency Plan (55 FR 8666 and 40 CFR
300). The preamble is available at http://www.oscreadiness.org/cec_courses/documents/marl 990.pdf
The CFR is available throughjhttp;^

EPA, 1990c. Corrective Action for Solid Waste Management Units at Hazardous Waste
management Facilities; Proposed Rule (55 FR 30798).

EPA, 1989a. OSWER Directive 9234.1-06, "Applicability of Land Disposal Restrictions to
RCRA and CERCLA Groundwater Treatment Reinjection Superfund Management Review:
Recommendation No. 26," (November 27).  Available at
http ://www.     gov/epaoswer/hazwaste/ca/resource/gui dance/rem waste/refrnces/ 1 4_3 020b .pdf

EPA, 1989b. National Priorities List for Uncontrolled Hazardous Waste Sites - Final Rule
Covering Sites Subject to the Subtitle C Corrective Action Authorities of the Resource
Conservation and Recovery Act (commonly referred to as the RCRA Deferral Policy). Available
in Section V, which appears on 54 FR 41004-41006. Available at
http://www.epa.gov/superfund/sites/npl/f891004.htmtf41000.

EPA, 1989c. Risk Assessment Guidance for Superfund Volume I: Human Health Evaluation
Manual (Part A). Available at Mtpi//wwv,epa,.gQv/M^^
EPA, 1988. OSWER Directive 9283.1-2, "Guidance on Remedial Actions for Contaminated
Groundwater at Superfund Sites," (December 1).

EPA, 1987. Alternate Concentration Limit Guidance  (EPA/530/SW-87/017).  Available at
http://www.epa. gov/correcti veaction/resource/guidance/gw/acl .htm .

EPA, 1986.  Guidelines for Groundwater Classification under the EPA Groundwater Protection
Strategy. Available at http://www.epa.gov/correctiveaction/resource/guidance/gw/gwclass.htm.

NRC, 2000. Natural Attenuation for Groundwater Remediation. Committee on Intrinsic
Remediation, Water Science and  Technology Board, Board on Radioactive Waste Management,
National Research Council.  Available at hiHj)://wiwjiajy^
NRC, 1994.  Alternatives for Groundwater Cleanup I Committee on Groundwater Cleanup
Alternatives, Water Science and Technology Board, Board on Radioactive Waste Management,
Commission on Geosciences, Environment, and Resources, National Research Council. National
Academy Press, 1994.  Available at httBi//wwjoia|)jg^^
          Handbook of Groundwater Protection and Cleanup Policies for RCPvA Corrective Action

                                    Appendix 1, Pg. 5

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                                                http://www.epa.gov/rcraonline/
                 Appendix 2 - Links to Other Helpful Internet Resources

EPA's Corrective Action Programs Branch         Mjj^/wwwjJiM^^

RCRA On-line
   enables users to locate documents, including
   publications and other outreach materials

EPA's Superfund Program

EPA's Enforcement Program        ____________
EPA's Office of Underground Storage Tanks

EPA's Water Program

EPA's Technology Innovation Office

The Training Exchange (TRAINEX)
S  provides a range
   of training information concerning
   hazardous waste management and remediation.

EPA's Remediation and Characterization
Innovative Technologies (REACH IT)

Government Performance and Results Act

EPA's Brownfields Homepage

EPA's Office of Research and Development -
Subsurface Protection & Remediation Division

Association of States and Territorial Solid
Waste Management Officials

Tribal Association on Solid Waste and
Emergency Response

American Indian Environmental Office
RCRA Hotline

National Environmental Publications
Internet Site (NEPIS)
                                                http://www.epa.gov/swerustl/index.htm

                                                http ://www. epa. gov/OW/

                                                            uA
                                                MtPl//wwwja.jn_ex._org/
                                                http://www.epa.gov/ocfo/planning/gpra.htm
                                                http://www.brownfieldstsc.org/
                                                http ://www. epa. gov/ada/
                                                http://www.astswmo.org/
                                                http ://www.taswer. org/
                                                http ://www. epa. gov/indian/
                                                http://www.epa.gov/cincl/
          Handbook of Groundwater Protection and Cleanup Policies for RCPvA Corrective Action

                                     Appendix 2, Pg. 1

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                              Appendix 3 - Glossary

Glossary Internet Links

Terms of Environment (including a list of common acronyms) produced by EPA's Office of
Communication, Education and Public Affairs (OCEPA) - available at
http://www.epa.gov/OCEPAterms/

Superfund Acronyms Glossary - available at http://www.epa.gov/superfund/glossl.htm

Glossary of Integrated Risk Information System (IRIS) Terms - available at
http://www.epa.gov/iris/gloss8.htm

Office of Water Glossary - available at http://www.epa.gov/safewater/glossary.htm

Handbook Glossary of Termsl

        - The term "cleanup" or the phrase "cleaning up" refers to the range of activities that could
occur in the context of addressing environmental contamination at RCRA facilities.  For example,
cleanup activities could include removing waste or contaminated media (e.g., excavation, and pumping
groundwater), in-place treatment of the waste or contaminated media (e.g., bioremediation),
containment of the waste or contaminated media (e.g., barrier walls,  low-permeable  covers, and liners)
or various combinations of these approaches.  The term cleanup is often used interchangeably with the
term remediate.

                  - The cleanup timeframe, with respect to groundwater, is an estimate of when
groundwater quality will achieve a certain level at a specified location and/or the schedule developed tc
take an action or construct a remedy designed to achieve a particular sh^rtterm_prQtectjon,
            performance, or fma]_cieanup_gQaL. (source - EPA, 1996a)

Comprehensive                                    (CSGWPP) - a groundwater
management strategy developed by a State. EPA reviews CSGWPPs and "endorses" those that
successfully meet six strategic activities. EPA established recommended adequacy criteria for each
strategic activity in CSGWPP guidance. In particular, EPA remediation programs review State
guidelines in the CSGWPP to prioritize groundwater based upon use,  value, and vulnerability. EPA's
Office of Solid Waste and Emergency Response issued a directive (EPA, 1997e) encouraging EPA's
remediation programs to defer, where appropriate, to State determinations of current and future use
when based on an EPA-endorsed CSGWPP that has provisions for facility-specific decisions,  (source
-EPA, 1992a)
        The definitions in this Glossary are for the purposes of this Handbook only.

             Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                   Appendix 3, Pg. 1

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               - describes media containing contaminants in any form (e.g., non-aqueous phase
liquids, dissolved in water, vapors, and solids) that are subject to cleanup under  RCRA and are
present in concentrations in excess of appropriately protective levels of concern, (source - EPA,
1999e)

                 - (or contingency remedy or a contingency measure) is a cleanup approach
specified in a remedy decision document that functions as a "backup" remedy in the event that the
"selected" remedy fails to perform as anticipated, (source - EPA,  1999d)

      lion-aqueous             (PMAPLs) - such as chlorinated solvents, creosote-based
wood-treating oils, coal tar wastes, and pesticides are immiscible (i.e., they are not dissolved in
water) fluids [most commonly organic] with a density greater than water, (source - EPA, 1994c
and EPA, 1995b)

                         (for RCRA corrective action) - two corrective action environmental
indicators, Current Human Exposures Under Control and Migration of Contaminated
Groundwater Under Control, are measures of program progress and are being used by the Agency
to track whether it meets the goals set under the Government Performance and Results Act
(GPRA). In general terms, these measures indicate current "environmental conditions"-  whether
people are currently being exposed to environmental contamination at unacceptable levels, and
whether any existing plumes of contaminated groundwater are getting larger or adversely
affecting surface water bodies.  Environmental indicator guidance for the RCRA Corrective
Action Program is available at http://www.epa.gov/correctiveaction/eis.htm. (source - EPA,
1999e)

                   - the additional or extra risk of developing cancer due to exposure to a toxic
substance incurred over the lifetime of an individual  (source: Glossary of IRIS Terms available at
http://www.epa.gov/iris/gloss8.htm ).

             use             - a determination of reasonably anticipated use, resource value
(e.g., priority), and/or vulnerability of groundwater in a particular area, (source - adapted from
EPA, 1992a)

                           - facility-specific chemical concentrations in groundwater that
regulators generally establish when defining groundwater cleanup  levels for final remedies.
(source - adapted from EPA, 1996a)

                                - includes three components: groundwater_cleanupjeygls, goint
of compliance, and cleanupjjmefranies.  (source - EPA, 1996a)

                     - non-engineered instruments such as administrative and/or legal controls
that minimize the potential for human exposure to contamination by limiting land or resource use.
(source - EPA, 2000b).
          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                     Appendix 3, Pg. 2

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                                 use - within the range of reasonably expected uses, the
maximum (or highest) beneficial groundwater use warrants the most stringent groundwater
cleanup levels, (source - adapted from EPA, 1996a)

                              - refers to the reliance on natural attenuation processes (within
the context of a carefully controlled and monitored site cleanup approach) to achieve site-specific
remediation objectives within a timeframe that is reasonable compared to that offered by other
more active methods.  The natural attenuation processes that are at work in such a remediation
approach include a variety of physical, chemical, or biological processes that, under favorable
conditions, act without human intervention  to reduce the mass, toxicity, mobility, volume or
concentration of contaminants in soil  or groundwater.  (source - EPA, 1999d)

                           (NAPLs) - are hydrocarbons that exist as a separate immiscible
phase when in contact with water or air.  Differences in the physical and chemical properties of
water and NAPLs result in the formation of a physical  interface between the two fluids which
prevent the two fluids from mixing. NAPLs are typically classified as either light non-aqueous
phase liquids (LNAPLs), which have densities less than that of water, or dense non-aqueous phase
liquids, which have densities greater than that of water, (source - EPA, 1995b). [Note, some
professionals have referred to NAPLs with  densities close to that of water as neutrally buoyant
non-aqueous phase liquids (NNAPLs).]

                      - preferred technologies for common categories of sites, based on
historical patterns of remedy selection and EPA's scientific and engineering evaluation of how
well technologies perform. You can access EPA's guidance on presumptive remedies at
    ://www.    gov/superfund/resources/presump. (source - EPA, 1997c)

                 - source materials considered to be highly toxic or highly mobile that generally
cannot be reliably contained or would present a significant risk to human health or the
environment should exposure occur.  (Source - EPA, 1997b and EPA, 1991c)

      of            - for groundwater, represents where a facility should monitor groundwater
quality and/or achieve specified levels of groundwater quality to achieve facility-specific cleanup
goals, (source - adapted from EPA, 1996a)

                       - surface  impoundments, waste piles, land treatment units, and landfills
that received hazardous waste after July 26, 1982. (source - 40 CFR 264.90)

        - any spilling, leaking, pumping,  pouring, emitting, emptying, discharging, injecting,
escaping, leaching, dumping, or disposing into the environment of a hazardous or toxic chemical,
or extremely hazardous substance, (source  - http://www.epa.gov/ocepaterms/rterms.html       )
          Handbook of Groundwater Protection and Cleanup Policies for RCPvA Corrective Action

                                     Appendix 3, Pg. 3

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                     - are not binding requirements; rather, they reflect collective experience and
are designed to guide development of remedial alternatives.  In effect, remedial expectations allow
program implementers and facility owner/operators to profit from prior EPA experience and focus
resources on the most plausible remedial alternatives, (source - EPA, 1996a, page 19448)

              - Source control refers to a range of actions (e.g., removal, treatment in place, and
containment) designed to protect human health and the environment by eliminating or minimizing
migration of or exposure to significant contamination, (source - adapted from EPA,  1996a)

source           - material that includes or contains hazardous substances, pollutants or
contaminants that act as a reservoir (either stationary or mobile) for migration of contamination to
groundwater, to surface water, to air (or other environmental media)], or acts as a source for
direct exposure.  Contaminated groundwater generally is not considered to be a source material
although non-aqueous phase liquids  (occurring as residual or free-phase) may be viewed as source
materials, (source - EPA, 1991c)

             - refers to "stabilizing" a situation so that,  for example, the contamination does not
represent unacceptable near-term threats or does not continue to spread. Stabilization used in this
context does not refer to engineered treatment used to "solidify" wastes although such
technologies could be used as a stabilization action,  (source - EPA, 199la)

             - term used in this Handbook collectively  referring to State and EPA regulators,
owners  and operators of facilities subject to RCRA corrective action, members of tribal
governments, and members of the public and affected communities. The "public" in the context
of RCRA refers not only to private citizens, but also representatives of consumer, environmental,
and minority associations; trade, industrial, agricultural,  and labor organizations; public health,
scientific, and professional societies; civic associations; public officials;  and government and
educational associations.

                          (TD - refers to a situation where achieving
levels associated with final^leanuj^goals is not practicable from an "engineering perspective."
The phrase "engineering perspective" refers to how factors such as feasibility, reliability, scale,
and safety influence the  ability to achieve groundwater cleanup objectives, (source - EPA, 1993a)

                    - EPA recognizes that "usable" groundwater may serve a variety of
purposes.  Common purposes of groundwater  include, for example, drinking water, agricultural
irrigation, car washes, and manufacturing.  Groundwater also has less formally acknowledged
purposes such as replenishing adjacent aquifers or surface water bodies. For more guidance
regarding groundwater use, see the giMSldwMSLusejie^gsiStioii policy in this Handbook.
          Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

                                      Appendix 3, Pg. 4

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