United States
Environmental Protection
Agency
Solid Waste and
Emergency Response
(5303W)
EPA530-R-04-030
April 2004*
http://www.epa.gov/correctiveaction
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
CVink nq
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* 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. This most recent revision provides (1) an update to section
15.0 - Completing Groundwater Remedies - in order to ensure that this Handbook is consistent with new guidance
on completing corrective action at RCRA facilities (available at
http://www.epa.gov/epaoswer/hazwaste/ca/resource/guidance/gen_ca/compfedr.pdf). and (2) updated internal
navigational and external Internet links to ensure that resources and cited references are available to the reader.
While this most recent version of the Handbook is dated April 2004, the date provided at the beginning of each
policy section reflects the last time EPA made any substantive changes (i.e., beyond updating web links).
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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 m. Contributing authors include Guy Tomassoni from the Corrective Action
Programs Branch, and Deborah Goldblum and Joel Hennessy from EPA Region UJ'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 HI 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)
Groundwater
Cleanup Levels
Completing
Groundwater
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 j
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? yji
How is this Handbook organized? yji
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? 1.1
What is EPA's overall goal for groundwater protection and cleanup? 1.1
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? 1.2
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? 2.2
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? 2.5
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 these two environmental indicators the only short-term protection goals facilities should consider? 2.7
3. Intermediate Performance Goals 3J.
What are intermediate performance goals for groundwater? 3.1
Table of Contents, Pg. 1
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How can intermediate performance goals help me? 3.1
Are intermediate performance goals appropriate for all facilities? 3.2
When should facilities and regulators establish intermediate performance goals? 3.2
How should facilities and regulators develop facility-specific intermediate performance goals? 3.2
What are some examples of intermediate performance goals? 3.2
Why is it important to establish intermediate performance goals on a facility-specific basis? 3.3
4. Final Cleanup Goals 4J.
What are EPA's final cleanup goals for corrective action? 4.1
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? 4.3
How should facilities and regulators evaluate final remedies that meet the threshold criteria? 4.3
How thorough of an assessment should facilities conduct when evaluating
one or more remedial options? 4.4
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? 4.5
5. Groundwater Cleanup Levels 11
What are groundwater cleanup levels? 5.1
How should groundwater cleanup levels be developed? 5.1
Are there other factors regulators and facilities should 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 6J_
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? 6.3
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
8. Source Control 8J_
What does source control mean? 8.1
What are sources of contamination? 8.1
What are EPA's expectations for source control regarding groundwater? 8.1
Table of Contents, Pg. 2
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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 ground-water use designation? 9.1
How does EPA define use, value, and vulnerability? 9.1
What factors should States consider when making groundwater use designations? 9.2
How does EPA's policy on groundwater use designations affect States that 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? 9.4
How do groundwater management or containment zones relate to groundwater use designations? 9.5
10. Institutional Controls 10.1
What are institutional controls? 10.1
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? 11.1
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? 12.1
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? 12.2
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? 12.3
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? 12.4
Should regulators and/or facilities revisit technical impracticability determinations? 12.4
13. Reinjection of Contaminated Groundwater 13.l
Can facilities reinject groundwater that is contaminated with hazardous wastes back in the
subsurface as part of corrective action? 13.1
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? 13.2
Table of Contents, Pg. 3
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What if a facility wants to re-inject groundwater that is contaminated with nonhazardous wastes
as part of corrective action? 13.2
14. Performance Monitoring 14.l
What is performance monitoring? 14.1
What should the performance monitoring accomplish? 14.1
What should a performance monitoring program include? 14.2
How often should a facility monitor? 14.2
How long should performance monitoring continue? 14.2
15. Completing Groundwater Remedies is.i
What does it mean to complete a groundwater remedy? 15.1
What does it mean to complete the implementation phase of a groundwater remedy? 15.1
How does EPA acknowledge when a facility achieves the implementation phases of a final remedy? 15.1
What does it mean to achieve the final cleanup goals for a groundwater remedy? 15.2
How do facilities and regulators typically decide when a groundwater remedy achieves
media cleanup objectives? 15.2
How does EPA acknowledge when a facility achieves final cleanup goals for all media? 15.3
What is the difference between Corrective Action Complete without Controls and
Corrective Action Complete with Controls? 15.3
What type of Corrective Action Complete determination can a facility achieve for a
final remedy where groundwater cleanup is a component of the remedy? 15.3
Appendix 1 - References Appendix i.pg. l
Appendix 2 - Links to Other Helpful Internet Resources Appendix 2, Pg. l
Appendix 3 - Glossary Appendix 3. Pg. l
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/reforms.
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, intermediate
performance goals, and final cleanup goals. EPA
recommends that facilities, regulators, and members
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.
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 http://www.epa.gov/epaoswer/general/orientat/. For more information
about RCRA corrective action, refer to the corrective action Web site at http://www.epa.gov/correctiveaction.
Additionally, an on-line introductory training on RCRA corrective action is available at
http://www.epa.gov/epaoswer/hazwaste/ca/training/index.htm
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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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 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
Overview, Pg. ii
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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 in (pages 19440 - 19455) of the May 1,
1996 Advance Notice of Proposed Rulemaking (ANPR; EPA, 1996a; see also EPA, 1997a).
See glossary to definition of "remedy expectations" used in the context of the RCRA Corrective Program.
See glossary definition of "releases."
For additional information about the list of 1,714 facilities we call the "RCRA Cleanup Baseline," refer to
http://www.epa.gov/epaoswer/hazwaste/ca/lists/base sta.pdf.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Overview, Pg. iii
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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 (http://www.epa.gov/coirectiveaction/regions.htm) 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
Handbook of Ground-water Protection and Cleanup Policies for RCRA Corrective Action
Overview, Pg. iv
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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 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/coiTectiveaction/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/maps/keychrt.pdf
or
http://www.epa.gov/epaoswer/hazwaste/state/stats/maps/coract.pdffor 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, 2001a), 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.
Handbook of Ground-water Protection and Cleanup Policies for RCRA Corrective Action
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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 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
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
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
, . , , -, 1 • 1 1-1 • r- institutions.
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/epaoswer/hazwaste/ca/lists/base_sta.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.
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 http://www.epa.gov/epaoswer/hazwaste/permit/pubpart/manual.htm. You can also contact
EPA regional and State offices to determine whether they have additional guidance concerning public
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
http://www.epa.gov/epaoswer/hazwaste/ca/guidance.htmtfRemediationWaste.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Overview, Pg. vi
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involvement at corrective action facilities.
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
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
Reinjection of Contaminated Groundwater
Performance Monitoring
Completing Groundwater Remedies
* See discussion on page x of this overview
section (or click here) to see how EPA intends
to keep this Handbook current.
and point of compliance address some questions
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Overview, Pg. vii
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unique to corrective action at RCRA regulated units7. You 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 m 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 HI 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
7 Regulated Units are defined in 40 CFR 264.90 (available through
http://www.gpoaccess.gov/cfr/retrieve.html'l 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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further discussion of issues raised for comment in the ANPR, or any other issue 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,
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
-------
1996b) available at http://www.epa.gov/correctiveaction/resource/guidance/gen_ca/coordmem.pdfand
the RCRA-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 Appendix 2.
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/correctiveaction/. 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
Appendix 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 Appendix 3.
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 Ground-water Protection and Cleanup Policies for RCRA Corrective Action
Overview, Pg. x
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References:
EPA, 200la. EPA Indian Policy (July 11). Available at
http://www.epa.gov/indian/pdfs/reafFirmindpolO 1 .pd£
EPA, 2001d. RCRA Cleanup Reforms Round II - Fostering Creative Solutions (EPA/530/F-01/001,
January). Available at http ://www. epa.gov/epaoswer/hazwaste/ca/reforms.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/correctiveaction/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 http://www.epa.gov/ogwdwOOO/gwr/fmalgw.pdf
EPA, 1999c. RCRA Cleanup Reforms (EPA/530/F-99/018). For more information, refer to
http://www.epa.gov/epaoswer/osw/factsheetl.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.htm. Other helpful links regarding MNA available at
http://www.epa.gOv/swerustl/cat/mna.htmandhttp://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/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://yosemite.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/May/Day-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
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Overview, Pg. xi
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http://www.epa. gov/correctiveaction/resource/guidance/gen_ca/coordmem.pd£
EPA, 1996d. RCRA Public Participation Manual ( EPA/530/R-96/007). Available at
http://www.epa.gov/epaoswer/hazwaste/permit/pubpart/manual.htm. Particularly relevant pages: 2.5-
2.7.
EPA, 1992a. Final Comprehensive State Groundwater Protection Program Guidance (EPA/100/R-
93/001). Available at
http://www.epa.gov/correctiveaction/resource/guidance/gw/csgwpp.htm.
EPA, 1991a. Managing the Corrective Action Program for Environmental Results: The RCRA
Stabilization Effort (October 25). Available at http://yosemite.epa.gov/osw/rcra.nsf/
d8382df2d09b64668525652800519745/27dlbaa5cldbb8f38525670f006be76d?OpenDocument.
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.htm#41 OOP.
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 reluming 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, 1991a; 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?
Rationale for
Groundwater Protection and
Cleanup Strategy
Based on EPA's experience with
environmental cleanups overthe 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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EPA's overall goal with respect to groundwater is to prevent adverse affects to human health and 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
goals, intermediate performance goals, and final cleanup goals. You can find more detailed descriptions
of these goals later in this Handbook.
How do short-term, intermediate and final cleanup goals work together to achieve EPA's
overall groundwater goals ?
EPA believes its strategy (see Figure 1) to implement corrective action in terms of short-term,
intermediate, and final cleanup goals is an efficient and effective way to satisfy RCRA's statutory
mandate to protect human health and the environment both now and in the future. EPA does not view
these three goals as discrete elements; rather, EPA designed them to support each other toward
achieving EPA's overall groundwater protection and cleanup goals.
The term "restore" or "restoration" used in this context refers to achieving a certain cleanup level(s)
developed to ensure protection based on maximum beneficial use of the groundwater at a particular facility.
Restoring contaminated groundwater does not necessarily imply cleanup to pristine conditions.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Groundwater Strategy, Pg. 1.2
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Final Clean up Goals
define what it takes to implement
a successful final remedy
RCRA Corrective Action Results
Short-Term Goals
control risks to humans, stop
ground water problems from
getting bigger, focus resources,
help give clearer picture of
challenges ahead
Intermediate Goals
establish achievable
milestones especially when
moving directly from short-
term to final goals is
particularly challenging
Figure 1: Relationship between short-term, intermediate, and final corrective action cleanup goals.
In the short-term3, EPA believes it is important that facilities take actions as soon as possible to 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 goals 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
Short-term in this context refers to the Corrective Action Program's Year 2005 goals EPA established in
response to the Government Performance and Results Act. Refer to the Short-Term Protection Goals section of this
Handbook for specific information pertaining to these short-term goals.
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.
You can leam more about these two indicators at http://www.epa.gov/correctiveaction/eis.htm.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Groundwater Strategy, Pg. 1.3
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stakeholders. These relationships often foster creative, results-based approaches that are increasing the
overall pace, efficiency and effectiveness of 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 final cleanup goals 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 performance goals 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 final cleanup 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
See glossary for definition of "remedy expectations" used in the context of the RCRA Corrective Action
Program.
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
-------
place. The third element defines when the facility should implement and complete an action.
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 http://www.epa.gov/correctiveaction/eis/ei_guida.pdf
EPA, 1997b. Rules of Thumb for Superfund Remedy Selection (EPA/540/R-97/013). Available at
http://www.epa.gov/superfund/resources/rules/rulesthm.pdf 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/May/Day-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.
1 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/correctiveaction/resource/gui dance/gen_ca/rcracap.pd£
EPA, 1991a. Managing the Corrective Action Program for Environmental Results: The RCRA
Stabilization Effort (October 25). Available at http://yosemite.epa.gov/osw/rcra.nsf/
d8382df2d09b64668525652800519745/27dlbaa5cldbb8f38525670f006be76d?OpenDocument.
EPA, 199 Ib. Protecting the Nation's Groundwater: EPA's Strategy for the 1990's. Office of the
Administrator. Washington, D.C. Available at
http ://www. epa. gov/superfund/resources/remedy/pdf/21 z-1020-s. pdf
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 http://www.nap.edu/books/0309049946/html/.
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 can see this list of facilities at http://www.epa.gov/epaoswer/hazwaste/ca/facility .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
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.
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.
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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document that 95 percent of the 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.htm.
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 measures, interim
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.
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 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
Groundwater Protection 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.
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, 199la 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 groundwater use 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 groundwater clean-up levels
developed to be consistent with the groundwater use designation and considering other current routes
of exposure from contaminated groundwater. However, early in corrective action, regulators could be
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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evaluating environmental 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 intermediate
performance goal 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 final cleanup goals.
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
http://www.epa.gov/correctiveaction/state.htm. Additional resources you may find helpful include the
Proceedings of the Groundwater/Surface Water Interaction Workshop (EPA, 2000c) available at
http://www.epa.gov/tio/tsp/download/gwsw/gwsw_partl.pdfand information regarding sediments
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Short-Term Goals, Pg. 2.5
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available at http://www.epa.gov/OST/cs/. Facilities or regulators evaluating environmental indicators
for situations where contaminated groundwater is entering surface water 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 intermediate performance
goals and final cleanup 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
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. For more information on
TMDLs, refer to http://www.epa.gov/owow/tmdl/intro.html.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Short-Term Goals, Pg. 2.6
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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 final cleanup goals. EPA expects that facilities will need to control or 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/tio/tsp/download/gwsw/gwsw_partl.pdf
http://www.epa.gov/tio/tsp/download/gwsw/gwsw_part2.pdf. and
http://www.epa.gov/tio/tsp/download/gwsw/gwsw_part3.pdf
EPA, 1999e. Interim Final Guidance for RCRA Corrective Action Environmental Indicators (February
5). Available at http://www.epa.gov/epaoswer/hazwaste/ca/eis/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/May/Day-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
Additional information and reports concerning NAPL contamination is available at
http://www.epa.gov/oerrpage/superfund/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. 2.7
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EPA, 1991a. Managing the Corrective Action Program for Environmental Results: The RCRA
Stabilization Effort (October 25). Available at http://yosemite.epa.gov/osw/rcra.nsf/
d8382df2d09b64668525652800519745/27dlbaa5cldbb8f38525670f006be76d?OoenDocument.
Handbook of Ground-water Protection and Cleanup Policies for RCRA Corrective Action
Short-Term Goals, Pg. 2.8
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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-term protection goals, but before they achieve
all final cleanup 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:
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 groundwater
cleanups. Establishing site-specific
intermediate performance goals provides a
mechanism to prioritize work and
measure progress toward achieving long-
term goals.
• 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 goals.
How can intermediate performance goals help me?
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 final cleanup goals.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
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 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 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 (cleanup
timeframe).
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
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Intermediate Goals, Pg. 3.2
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of removal, treatment, and containment), plume size reduction, cleaning up off-site plumes, prioritizing
work, and remedy performance enhancements. For example:
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.
References:
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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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://www.epa.gov/swerustl/cat/mna.htm and http://www.epa.gov/swerustl/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/gwguide/index.htm.
Handbook of Groundwater Protection and Cleanup Policies for RCRA 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
tohttp://www.epa.gov/epaoswer/hazwaste/ca/guidance.htm#RemediationWaste.
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.
Media cleanup objectives for final remedies typically includes the more specific concepts of media
cleanup levels, points of compliance, and cleanup timeframes. 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.
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
(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 designation 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
4(... continued)
would present a significant risk to human health or the environment should exposure occur. A complete list of
EPA's general expectations for final remedies is available in EPA, 1996a (page 19448).
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.
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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throughout the groundwater, may be acceptable as long as the remedy protects 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 technically impracticability in this Handbook.
How should facilities and regulators evaluate final remedies that meet the threshold criteria?
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).
o
Refer to the Groundwater Cleanup Levels Section of the Handbook for guidance concerning potential
ways humans or ecologic receptors could be exposed to contaminated groundwater.
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.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Final Cleanup Goals, Pg. 4.3
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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.
How thorough of an assessment should facilities conduct when evaluating one or more
remedial options?
These balancing criteria are not ranked in terms of importance.
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.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Final Cleanup Goals, Pg. 4.4
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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 cleanup 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
(cleanup timeframe).
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.
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
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/superfund/resources/presump.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Final Cleanup Goals, Pg. 4.5
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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
http://www.epa.gov/superfund/resources/rules/rulesthm.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
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
htto://www. eoa.gov/suoerfund/resources/Qfwguide/index.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 chemical concentrations in groundwater that 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 protection
goals! and may be a component of a facility-
specific intermediate performance goal.
How should groundwater cleanup levels be
developed?
Rationale for
Groundwater Cleanup Levels
Groundwater cleanup 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 contaminants). 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 between 10"4
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 excess
cancer risk of 10"4. The numerical estimate means that for people receiving this level of exposure averaged over a 70-
(continued...)
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Groundwater Cleanup Levels, Pg. 5.1
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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 consider 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)
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
http: //www. epa. go v/oerrpage/superfund/resources/soilA
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.htm
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 at
http://www.epa.gov/iris/gloss8.htm).
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.htmtfgp. and
http://www.epa.gov/superfund/programs/risk/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
groundwater use designation 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
A naturally occurring substance is in its unaltered form, or is altered solely through naturally occurring
processes or phenomena, in a location where it is naturally found (Superfund, Section 104(a)(3)(A)).
o
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.
o
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
http://www.epa.gov/correctiveaction/state.htm
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Groundwater Cleanup Levels, Pg. 5.3
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potential source of drinking water, or has value or uses other than drinking water.
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.htmn. 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/correctiveaction/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 designation 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
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 http://www.epa.gov/safewater/mcl.html.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Groundwater Cleanup Levels, Pg. 5.4
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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 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
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,
199Id) which is available at
http://www.epa.gov/oerrpage/superfund/programs/risk/airmodel/guide.pdf. The model itself can be downloaded
from http://www.epa.gov/oerrpage/superfund/programs/risk/airmodel/iohnson ettinger.htm See also EPA's Draft
Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils (Subsurface Vapor
Intrusion Guidance) available athttp://www.epa.gov/epaoswer/hazwaste/ca/eis/vapor.htm
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.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Groundwater Cleanup Levels, Pg. 5.5
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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).
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 source 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 of 40 CFR 264.94(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
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.
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.gpoaccess.gov/cfr/retrieve.html.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Groundwater Cleanup Levels, Pg. 5.6
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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).
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
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).
Note that some State programs do not allow nonresidential scenarios to be used in determining criteria
for clean closure.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Groundwater Cleanup Levels, Pg. 5.7
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land use. For more information on risk based closure, refer to the Risk-Based Clean Closure
Memorandum (EPA, 1998c) and call your overseeing regulator.
References:
EPA, 2002. OSWER Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from
Groundwater and Soils (Subsurface Vapor Intrusion Guidance). Available at
http://www.epa.gov/epaoswer/hazwaste/ca/eis/vapor.htm.
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. epa.gov/epaoswer/osw/docs/riskfinal .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, 1997b. Rules of Thumb for Superfund Remedy Selection (EPA/540/R-97/013). Available at
http://www.epa.gov/superfund/resources/rules/rulesthm.pdf
EPA, 1997f. Exposure Factors Handbook (EPA/600/P-95/002F). Available at
http ://www. epa. gov/ncea/exposfac. 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: 19448-52.
EPA, 1996e. Soil Screening Guidance Fact Sheet (EPA/540/F-95/041, July). Available at
http ://www. epa. gov/oerrpage/superfund/resources/soil/.
EPA, 199Id. USEPA's User's Guide for the Johnson and Ettinger Model for Subsurface Vapor
Intrusion into Buildings. Available at
http://www.epa.gov/oerrpage/superfund/programs/risk/airmodel/guide.pdf The model itself can be
downloaded from
http://www.epa.gOv/oerrpage/superfund/programs/risk/airmodel/j ohnson_ettinger.htm.
EPA, 1990b. National Oil and Hazardous Waste Contingency Plan (55 FR 8666 and 40 CFR 300).
The preamble is available at
http://www.epa.gov/superfund/action/guidance/remedv/pdfs/ncppreamble61.pdf The CFR is available
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Groundwater Cleanup Levels, Pg. 5.8
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through http://www.access.gpo.gov/nara/cfr/waisidx_00/40cfrv20_00.html.
EPA, 1989c. Risk Assessment Guidance for Superfund Volume I: Human Health Evaluation Manual
(Part A). Available at http://www.epa.gov/superfund/programs/risk/ragsa/index.htm.
EPA, 1987. Alternate Concentration Limit Guidance (EPA/530/SW-87/017). Available at
http://www.eoa. gov/correctiveaction/resource/guidance/gw/acl .htm.
Handbook of Ground-water Protection and Cleanup Policies for RCRA Corrective Action
Ground-water Cleanup Levels, Pg. 5.9
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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
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"
groundwaterto 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.
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.
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.
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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compliance (40 CFR 264.100). For more information regarding the point of compliance for regulated
units, refer to 40 CFR 264.90-100, which are available through
http://www.gpoaccess.gov/cfr/retrieve.html. 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.
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I
I
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, intermediate performance goals, and final
cleanup goals. 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?
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 Final
Qoundwater
FlowEfecticn
Hume boundary /
I
PtDpatyboundary
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.
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'!.
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
-------
Cleanup Goals and Groundwater Use Designation) or in situations where the regulator determined that
returning usable groundwater to its maximum beneficial use is technically impracticable.
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).
• Groundwater
I Flow Direction
^ ^
Plume boundary—s
I— -N
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.
Where is the groundwater point of compliance for short-term protection goals?
Achieving the Migration of Contaminated Groundwater Under Control environmental indicator involves
documenting that contaminated groundwater is expected to remain within an existing three-dimensional
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-pagel7).
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).
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Point of Compliance, Pg. 6.3
-------
boundary(ies) of the plume8 (EPA, 1999e). Using the general definition of a 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.
1 Groundwater
1 Flow Direction
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.
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 short-term
protection goal 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.
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
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 http://www.epa.gov/epaoswer/hazwaste/ca/eis/ei_guida.pdf.
EPA, 1997b. Rules of Thumb for Superfund Remedy Selection (EPA/540/R-97/013). Available at
http://www.epa.gov/superfund/resources/rules/rulesthm.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: 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/gwguide/gwfmal .pdf
EPA, 1993b. Waste Management Area and Supplemental Well Guidance (June). Available at
http://www. epa.gov/correctiveaction/resource/gui dance/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 http://www.epa.gov/tio/osc/documents/marl990.pdf The CFR is
available through http://www.access.gpo.gov/nara/cfr/waisidx_00/40cfrv20_00.html.
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 RCRA 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 protectioa intermediate performance, or
final cleanup 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 short-term 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/coiTectiveactiorVfacility.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 performance goal 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 final cleanup goals 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
-------
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.
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 short-term protection
goals. For example, controlling a source of contamination may be important for a facility that wants to
rely on monitored natural attenuation to achieve the Migration of Contaminated Groundwater Under
Control environmental indicator. Source control at many facilities will be an important component of
Rationale for
Source Control
Source control, where necessary, will be
a critical component of a facility's cleanup
strategy aimed at returning contaminated
groundwater 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.
See glossary definition of "source materials."
Additional information and reports concerning DNAPL contamination is available at
http://www.epa. go v/oerrpage/superfund/resources/gwdocs/non_aqu.htm
See glossary for a definition of "remedy expectations."
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Source Control, Pg. 8.1
-------
intermediate performance goals used, for example, to demonstrate progress toward achieving final
cleanup goals. 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):
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
-------
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 final cleanup goals 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/superfund/resources/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/Mav/Dav-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.epa.gov/superfund/action/guidance/remedy/pdfs/ncppreamble61.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 RCRA 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
cleanup 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 fora non-
drinking water use designation.
The term "use" refers to the current use and reasonably expected use of the groundwater. When
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).
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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people think about groundwater use, they often consider only drinking water use; however, there are
many other groundwater uses besides drinking water. These uses include, for example, sanitary water,
cooling water, car washes, livestock watering, and agricultural irrigation.
expected use, but it also considers groundwater's
"Value" depends on the current and reasonably
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?
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?
Factors to Assess
Use, Value, and Vulnerability of
Groundwater Resources
Vulnerability to contamination
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)
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Groundwater Use Designations, Pg. 9.2
-------
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 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 1A 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
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 cleanup levels in some circumstances may have to be lower than
concentrations associated with drinking water standards designed to protect humans.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Groundwater Use Designations, Pg. 9.3
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to make a groundwater use designation.
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 use6.
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.htm). 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 n is groundwater currently used or potentially usable as a source of drinking
water; and Class HI includes groundwater that is not a current or potential source of drinking water.
How can State groundwater use designations enhance protection and flexibility for RCRA
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.epa.gov/safewater/csgwpp.html. Also, refer to the
discussion on CSGWPPs in EPA, 1996a.
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 athttp://www.epa.gov/correctiveaction/state.htm
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Groundwater Use Designations, Pg. 9.4
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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 cleanup timeframe 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 cleanup 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/swerospsM/topics.htm) 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 Goals 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 type of
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.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Groundwater Use Designations, Pg. 9.5
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institutional control8 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 http://www.epa.gov/OGWDW/source/swpguid.html.
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/May/Day-01/pr-547.pdf Particularly relevant
page: 19457.
EPA, 1992a. Final Comprehensive State Groundwater Protection Program Guidance (EPA/100/R-
93/001). Available at http://www.epa.gov/correctiveaction/resource/guidance/gw/csgwpp.htm.
EPA, 199 Ib. Protecting the Nation's Groundwater: EP A's Strategy for the 1990's. Office of the
Administrator. Washington, D.C. Available at
http://www.epa.gOv/superfund/resources/remedy/pdf/2 Iz-1020-s.pdf
To provide overlapping assurances of protection from contamination, EPA recommends that various
forms of institutional controls 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.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Groundwater Use Designations, Pg. 9.6
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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.
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 access this document as well as
supporting other related documents and supporting materials at
http://www.epa.gov/superfund/action/ic/guide/index.htm
While institutional controls may limit exposure to human populations, facilities and regulators should
ensure that cleanup actions also protect ecologic receptors.
See glossary for a definition of "remedy expectations."
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Institutional Controls, Pg. 10.1
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enforcement tools with institutional control components; and
• informational devices.
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/matrxrv3.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
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Institutional Controls, Pg. 10.2
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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) 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/superfund/action/ic/guide/index.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 Particularly relevant
pages: 19448-49, and 52.
Handbook of Ground-water Protection and Cleanup Policies for RCRA Corrective Action
Institutional Controls, Pg. 10.4
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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?
This policy reflects advancements in
Rationale for
Monitored Natural Attenuation
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.
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 groundwater cleanup levels in a
reasonable cleanup timeframe. Facilities should
evaluate and justify monitored natural attenuation
remedies using recommended threshold and balancing
criteria discussed in the Final Cleanup Goal 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 more likely to be acceptable to
regulators1 when:
• the facility can demonstrate that monitored natural attenuation will be able to achieve groundwater
cleanup objectives;
• measures for source control 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;
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.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Monitored Natural Attenuation, Pg. 11.1
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• the contaminant plume(s) is already stable or shrinking in extent;
• the estimated cleanup 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 short-term protection goals! 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,
EPA recommends that proposals for monitored natural attenuation remedies include estimates of the time
needed to achieve groundwater cleanup levels. EPA realizes that such estimates are based on numerous
assumptions, but they are still helpful for comparisons between cleanup options.
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.
EPA's policy (EPA, 1999d) on monitored natural attenuation does not distinguish between on-site and
off-site contaminated groundwater.
Some State programs might require formal concurrence of adjacent property owners for monitored natural
attenuation remedies proposed to address off-site contaminated groundwater.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Monitored Natural Attenuation, Pg. 11.2
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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 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 groundwater cleanup levels
are met at the point of compliance for the final cleanup goals, 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/swerust 1 /directiv/d9200417.htm. Other helpful links regarding MNA available at
http://www.epa.gOv/swerustl/cat/mna.htmandhttp://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.epa.gov/superfund/action/guidance/remedy/pdfs/ncppreamble61.pdf The CFR is available
through http://www.access.gpo.gov/nara/cfr/waisidx_00/40cfrv20_00.html.
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 htto://www.nap. edu/catalog/9792.html
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Monitored Natural Attenuation, Pg. 11.3
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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
groundwater cleanup levels associated with final
cleanup 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.
Rationale for
Technical Impracticability
EPA believes that it is appropriate to recognize
the limitations of current technologies to clean
up groundwaterto 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.
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
For further information regarding challenges associated with groundwater cleanups, refer to Alternatives
for Ground Water Cleanup (NRC, 1994), available athttp://www.nap.edu/books/0309049946/html/. Also, you can
find numerous resources concerning cleanup technologies at EPA's Technology Innovation Office's Web site
(http://www.clu-in.org/'!, including the feature called "Technology Innovation Office's Perspectives"
(http://www.clu-in.org/tiopersp/) where you can view several recent articles summarizing current cleanup technology
practices and developments.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Technical Impracticability, Pg. 12.1
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example, inadequate characterization, selecting inappropriate technologies, or 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 groundwater use designatioa 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 short-term
protection goals (i.e., environmental indicators).
Additional information and reports concerning NAPL contamination is available at
http://www.epa.gov/oerrpage/superfund/resources/gwdocs/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 cleanup goals 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 cleanup 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 final cleanup goals. 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
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Technical Impracticability, Pg. 12.3
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contamination facilities will need to address if and when achieving the groundwater cleanup levels
becomes technically practicable in the future. However, as mentioned previously in this 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, 1993 a) 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
Some cleanup programs (e.g., New York State — see
http://www.clu-in.org/eiforum2000/prez/ppframe 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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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 monitoring.
References:
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: 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/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/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, 1993 a. 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.
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 http://www.nap.edu/books/0309049946/html/.
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 contaminated groundwater
Rationale for
Reinjection of Contaminated
Groundwater
EPA's policy on reinjection of
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 athttp://www.gpoaccess.gov/cfr/retrieve.html or
http://www.epa.gov/safewater/uic/uicregs.html.
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 http://www.epa.gov/safewater/uic.html.
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," (November 27). Available at
http://www.epa.gov/epaoswer/hazwaste/ca/resource/guidance/remwaste/refrnces/l4 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.
intermediate performance goals, or final
cleanup goals.
What should the performance monitoring
accomplish?
Facilities should design performance c|eanup actjons to contm| migratjon Qf
monitoring1 programs to, for example:
• detect changes in environmental conditions
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
contaminated groundwater. Performance
monitoring can assess changes in groundwater
so that facilities can modify cleanup actions to
e 11 i 1-1 ensure maximum efficiency, protectiveness, and
(e.g., hydrogeologic, geochemical, ,. _ , ...
v ° J ° 030 compliance. Performance monitoring can also
demonstrate whether or not a cleanup action is
performing as expected.
microbiological, or other changes) that
may reduce the efficacy of the remedy;
identify any potentially toxic and/or 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
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).
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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• verify attainment of short-term, intermediate, or final goals.
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.
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 Selection (EPA/540/R-97/013). Available at
http://www.epa.gov/superfund/resources/rules/rulesthm.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/pmptreat. htm
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/Mav/Dav-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/correctiveacti on/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/addendum.
rjdf.
EPA, 1992d. Methods for Evaluating Attainment of Cleanup Standards Volume 2: Groundwater
(EPA/230/R-92/014). Available at http://www.clu-in.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
(January 2004)
What does it mean to complete a groundwater remedy?
EPA generally recognizes two phases of
completing1 a final groundwater remedy:
• implementing the final remedy such that all
components of the remedy are in place and
operating as intended;
achieving final cleanup goals
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
construction has been completed and the remedy is
operating as designed. At this point, cleanup
objectives have not necessarily been met, but the
remedial measures are in-place and operating as intended. Cleanup activities would typically be limited
to continued operation, maintenance and monitoring of the remedy.
How does EPA acknowledge when a facility achieves the implementation phases of a final
remedy?
EPA generally uses "Construction Completion" to describe when a facility completed the
implementation phase of its final remedy for all media throughout the site (EPA, 1999f).2
Rationale for
Completing
Groundwater Remedies
This policy on completing groundwater
remedies is meant to encourage regulators
and facilities to recognize construction
completion as well as achievement of final
cleanup goals for groundwater remedies.
Recognition ofthese phases of completion
can demonstrate progress and promote
transfer of ownership of the property and
facilitate reuse of industrial property. This
policy also recognizes that EPA typically
considers groundwater remedies to be
complete when final goals are met, even
though long-term controls are required.
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. This section of the
Handbook was updated from the original September 2001 version to incorporate new Agency guidance (EPA, 2003)
that describes how corrective action can be considered "complete" with or without controls.
2 EPA's RCRA data management system (EPA, 1999f; available at
http://www.epa.gov/epaoswer/hazwaste/ca/facilitv/ca-diction.pdf) 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 achieve the final cleanup goals for a groundwater remedy?
As conveyed earlier in this Handbook, a facility achieves final cleanup goals 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 that facilities achieve site-specific media cleanup objectives3, and control surface and
subsurface sources (see Source Control) to the extent practicable (see Technical Impracticability) 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 a condition suitable for
a drinking water use designation, this phase of completing a remedy typically means that the facility
achieved drinking water standards at a throughout-the-plume/unit boundary point of compliance and it
has controlled further releases of contaminants that might recontaminate the groundwater. 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
and beyond an appropriate point of compliance typically located outside but near the containment area.
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.
Media cleanup objectives refer to broad cleanup objectives that often include the more specific concepts
of media cleanup levels, points of compliance, and cleanup time frames. 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.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Completing Groundwater Remedies, Pg. 15.2
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How does EPA acknowledge when a facility achieves final cleanup goals for all media?
EPA recommends that regulatory agencies acknowledge when a facility achieves final cleanup goals for
all media with a "Corrective Action Complete with Controls" or "Corrective Action Complete without
Controls" determination (EPA, 2003). In addition, a completion determination might apply to the entire
facility or a portion(s) of a facility. We recommend that individuals review the Final Guidance for
Completion of Corrective Action Activities at RCRA Facilities (68 FR 8757; available at
http://www.epa.gov/correctiveaction/complete.pdf) for more guidance on these two types of corrective
action completion, their use, and procedures for acknowledging corrective action complete
determinations.
What is the difference between Corrective Action Complete without Controls and Corrective
Action Complete with Controls?
Corrective Action Complete without Controls means that the facility meets the final site-specific cleanup
objectives for all media, and no further activity or controls are necessary on the part of the regulator or
the facility to maintain protection of human health and the environment. Since the facility will not need
to conduct operation, maintenance, or monitoring of a remedy, or any engineered or institutional
controls, it is likely that the facility will be eligible for a release from financial assurances for corrective
action.
In contrast, a Corrective Action Complete with Controls determination means that the facility meets the
final cleanup objectives, but on-going operation, maintenance and monitoring obligations of engineered
controls, and/or compliance with and maintenance of institutional controls are necessary to ensure
continued protection of human health and the environment. Since the facility will often have ongoing
obligations for which they are responsible, continuation of financial assurance for corrective action may
be necessary.
What type of Corrective Action Complete determination can a facility achieve for a final
remedy where groundwater cleanup is a component of the remedy?
The type of Completion determination generally depends on the groundwater cleanup objectives
selected as part of the final remedy. EPA has discovered that the universe of facilities subject to
corrective action requirements includes facilities that vary widely in complexity and level of risk
presented at the facility. To address this wide variation, EPA has developed multiple approaches to
achieving the final remedy goal of "protection of human health and the environment." However, one of
the key distinctions among remedies is whether they rely upon controls (engineering and/or institutional4)
to ensure that they remain protective.
Institutional controls could, where appropriate, include administrative measures for which the facility
owner /operator and/or some other entity, such as a state or local government, is responsible.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Completing Groundwater Remedies, Pg. 15.3
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In some cases the regulator selects a final remedy that requires cleanup of groundwater and all other
contaminated media to unrestricted use5 levels. Once the facility achieves those unrestricted use levels
for all contaminated media, no controls are necessary to ensure protection; therefore, a corrective
action complete without controls determination would generally be appropriate. In other cases, the
regulator selects a remedy that allows some contamination to remain on site, but relies on engineering
and/or institutional controls to ensure appropriate protection. At sites where final groundwater cleanup
objectives allow contaminated groundwater to remain in place above concentrations suitable for
unrestricted use, a Corrective Action Complete with Controls determination would generally be
appropriate because the remedy would be relying on engineering and/or institutional controls to prevent
future exposure to the contaminated groundwater in such a situation.
References:
EPA, 2003. Final Guidance on Completion of Corrective Action Activities at RCRA Facilities (68 FR
8757, February 25). Available at http://www.epa.gov/correctiveaction/complete.pdf
EPA, 1999f. Resource Conservation and Recovery Act Data Element Dictionary - version 7.2.0.
Available at http://www.epa.gov/epaoswer/hazwaste/ca/facility/ca-diction.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: 19453.
EPA, 1992d. Methods for Evaluating Attainment of Cleanup Standards Volume 2: Groundwater
(EPA/230/R-92/014). Available at http://www.clu-in.org/download/stats/vol2gw.pdf
"Unrestricted use" refers to a walk-away situation, where no further activity or controls are necessary to
protect human health or the environment at the facility. For groundwater, cleaning up to drinking water standards
would generally represent unrestricted use. By comparison containment or cleanup of groundwater to levels in
excess of drinking water standards would usually not be an unrestricted use scenario.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Completing Groundwater Remedies, Pg. 15.4
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Appendix 1 - References
EPA, 2002. OSWER Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from
Groundwater and Soils (Subsurface Vapor Intrusion Guidance). Available at
http://www.epa.gov/epaoswer/hazwaste/ca/eis/vapor.htm.
EPA, 200la. EPA Indian Policy (July 11). Available at
http://www.epa.gov/indian/pdfs/reaffirmindpolO 1 .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. epa.gov/epaoswer/osw/docs/riskfmal .pdf
EPA, 2001d. RCRA Cleanup Reforms Round II - Fostering Creative Solutions (EPA/530/F-01/001,
January). Available at http://www.epa.gov/epaoswer/hazwaste/ca/reforms.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/remwaste/refrnces/pol-mem3 .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/superfund/action/ic/guide/index.htm.
EPA, 2000c. Proceedings of the Ground-Water/Surface-Water Interactions Workshop (EPA/542/R-
00/007, July). Available at http://www.epa.gov/tio/tsp/download/gwsw/gwsw_partl.pdf.
http://www.epa.gov/tio/tsp/download/gwsw/gwsw_part2.pdf and
http ://www. epa. gov/tio/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/correctiveaction/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/gwr/fmalgw.pdf
EPA, 1999c. RCRA Cleanup Reforms (EPA/530/F-99/018, July). For more information, refer to
http://www.epa.gov/epaoswer/hazwaste/ca/reforms.htm
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Appendix l,Pg. 1
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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/swerust 1 /directiv/d9200417.htm. Other helpful links regarding MNA available at
http://www.epa.gov/swerustl/cat/mna.htmand http://www.epa.gov/swerustl/oswermna/mnalinks.htm
EPA, 1999e. Interim Final Guidance for RCRA Corrective Action Environmental Indicators (February
5). Available at http://www.epa. gov/epaoswer/hazwaste/ca/eis/ei_guida.pdf
EPA, 1999 f. Resource Conservation and Recovery Act Data Element Dictionary - version 7.2.0.
Available at http ://www.epa.gov/oswfiles/rcrisbrs/rcris720/ded/ded720.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/Day-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/8BF009F9B3672563852566110072DA71.
EPA, 1997b. Rules of Thumb for Superfund Remedy Selection (EPA/540/R-97/013). Available at
http://www.epa.gov/superfund/resources/rules/rulesthm.pdf
EPA, 1997c. A Citizen's Guide to Understanding Presumptive Remedies (EPA/540/F-97/019,
October). Available at http://www.epa.gov/superfund/resources/presump/finalpdf/citizen.pdf
EPA, 1997d. State Source Water Assessment and Protection Programs Guidance (EPA/816/R-
97/009, August). Available at http://www.epa.gov/OGWDW/source/swpguid.html.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
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EPA, 1997'e. 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, 1997f. Exposure Factors Handbook (EPA/600/P-95/002F). Available at
http ://www. epa. gov/ncea/exposfac. htm.
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/
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/May/Day-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/gwfmal .pdf
EPA, 1996d. RCRA Public Participation Manual (EPA/530/R-96/007). Available at
http://www.epa.gov/epaoswer/hazwaste/permit/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/superfund/resources/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/issue/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/correctiveaction/resource/gui dance/gen_ca/rcracap.pdf
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
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EPA, 1994c. DNAPL Site Characterization (EPA/540/F-94/049). Available at
http://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/gui dance/gw/wma_sup.htm.
EPA, 1992a. Final Comprehensive State Groundwater Protection Program Guidance (EPA/100/R-
93/001). Available at
http://www.epa.gov/correctiveaction/resource/guidance/gw/csgwpp.htm.
EPA, 1992b. RCRA Groundwater Monitoring Draft Technical Guidance (November). Available at
http://www.epa.gov/correctiveacti orVresource/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/addendum.pdf
EPA, 1992d. Methods for Evaluating Attainment of Cleanup Standards Volume 2: Groundwater
(EPA/230/R-92/014). Available at http://www.clu-in.org/download/stats/vol2gw.pdf
EPA, 1991a. Managing the Corrective Action Program for Environmental Results: The RCRA
Stabilization Effort (October 25). Available at
http://vosemite.epa.gov/osw/rcra.nsf/d8382df2d09b64668525652800519745/27dlbaa5cldbb8f3852
5670f006be76d?OpenDocument.
EPA, 199 Ib. Protecting the Nation's Groundwater: EP A's Strategy for the 1990's. Office of the
Administrator. Washington, D.C. Available at
http ://www. epa. gov/superfund/resources/remedy/pdf/21 z-1020-s. pdf
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.epa.gov/oerrpage/superfund/programs/risk/airmodel/guide.pdf The model itself can be
downloaded from
http://www.epa.gov/oerrDage/superfund/programs/risk/airmodel/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.epa.gov/superfund/action/guidance/remedy/pdfs/ncppreamble61.pdf The CFR is available
through http://www.access.gpo.gov/nara/cfr/waisidx_00/40cfrv20_00.html.
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.epa. gov/epaoswer/hazwaste/ca/resource/guidance/remwaste/refrnces/l 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.htm#41 OOP.
EPA, 1989c. Risk Assessment Guidance for Superfund Volume I: Human Health Evaluation Manual
(Part A). Available at http://www.epa.gov/superfund/programs/risk/ragsa/index.htm.
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/correctiveaction/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 http://www.nap.edu/catalog/9792.html
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 http://www.nap.edu/books/0309049946/html/.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Appendix 1, Pg. 5
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Appendix 2 - Links to Other Helpful Internet Resources
EPA's Corrective Action Programs Branch http://www.epa.gov/correctiveaction/
RCRA On-line http://www.epa.gov/rcraonline/
- enables users to locate documents, including
publications and other outreach materials
EPA's Superfund Program http://www.epa.gov/superfund/
EPA's Enforcement Program http://www.epa.gov/compliance
EPA's Office of Underground Storage Tank http://www.epa.gov/swerustl/index.htm
EPA's Water Program http ://www.epa.gov/OW/
EPA's Technology Innovation Office http://www.clu-in.org/
The Training Exchange (TRAINEX) http ://www.trainex. org/
S provides a range
of training information concerning
hazardous waste management and remediation.
EPA's Remediation and Characterization
Innovative Technologies (REACH IT) http://www.epareachit.org/index3 .html
Government Performance and Results Act http://www.epa.gov/ocfo/planning/gpra.htm
EPA' sBrownfields Homepage http://www.brownfieldstsc.org/
EPA's Office of Research and Development -
Subsurface Protection & Remediation Division http://www.epa.gov/ada/
Association of States and Territorial Solid
Waste Management Officials http://www.astswmo.org/
Tribal Association on Solid Waste and
Emergency Response http ://www.taswer. org/
American Indian Environmental Office http://www.epa.gov/indian/
RCRA Hotline http://www.epa.gov/epaoswer/hotline/index.htm
Handbook of Ground-water Protection and Cleanup Policies for RCRA 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/
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 Terms1
cleanup - 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.
cleanup timeframes - 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 to
take an action or construct a remedy designed to achieve a particular short-term protectioa
intermediate performance, or final cleanup goal, (source - EPA, 1996a)
Comprehensive State Groundwater Protection Program (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)
contamination - describes media containing contaminants in any form (e.g., non-aqueous phase
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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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)
contingency plan - (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)
dense non-aqueous phase liquids (DNAPLs) - 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)
environmental indicators (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)
excess lifetime risk - 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 ).
groundwater use designation - 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)
groundwater cleanup levels - facility-specific chemical concentrations in groundwater that regulators
generally establish when defining groundwater cleanup levels for final remedies, (source - adapted from
EPA, 1996a)
groundwater cleanup objectives - includes three components: groundwater cleanup levels, point of
compliance, and cleanup timeframes. (source - EPA, 1996a)
institutional controls - 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).
maximum beneficial groundwater use - within the range of reasonably expected uses, the maximum
(or highest) beneficial groundwater use warrants the most stringent groundwater cleanup levels, (source
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Appendix 3, Pg. 2
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- adapted from EPA, 1996a)
monitored natural attenuation - 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)
non-aqueous phase liquids (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).]
presumptive remedies - 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
http://www.epa.gov/superfund/resources/presump. (source - EPA, 1997c)
principal threats - 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)
point of compliance - 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)
RCRA regulated units - surface impoundments, waste piles, land treatment units, and landfills that
received hazardous waste after July 26, 1982. (source - 40 CFR 264.90)
releases - 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.htmn
remedy expectations - 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)
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source control - 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 materials - 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)
stabilization - 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)
stakeholders - 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.
technical impracticability (TI) - refers to a situation where achieving groundwater cleanup levels
associated with final cleanup 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)
usable groundwater - 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 groundwater use designation policy in this Handbook.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action
Appendix 3, Pg. 4
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