UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
DEC -6 2005
OFFICE OF
SOLID WASTE AND EBffROBICr
RESPONSE
OSWER No. 9320.2-13
MEMORANDUM
SUBJECT: Addendum to Policy for "Close Out Procedures for National Priorities List Sites"
FROM: Michael B. Cook, .,,-., , ,x ,.
Office of Superfund Remediation and Technology Innovation
TO: Superfund National Policy Managers, Regions 1-10
Purpose
This document provides an addendum to the U.S. Environmental Protection Agency
(EPA) guidance entitled: Close Out Procedures for National Priorities List Sites, EPA 540-R-98-
016, OSWER Directive 9320.2-09A-P, January 2000. This memorandum clarifies the criteria
Regions should use to evaluate site-wide construction completion for in-situ ground water
restoration remedies at Superfund sites, for purposes of that guidance.
Background
For a site being cleaned up under the Comprehensive Environmental Response, I
Compensation, and Liability Act (CERCLA or "Superfund"), site-wide construction completion
typically is achieved when physical construction of all cleanup actions are complete, all
immediate threats have been addressed, and all long-term threats are under control for all
portions of the site. The completion of the last response action at a site generally determines
when it becomes eligible for construction completion status. This document provides definitions
Regions should use for determining construction completion when the last response action is a
ground water restoration remedy and an in-situ treatment technology is used for restoring ground
water quality. For monitored natural attenuation response actions without any additional in-situ
technology, guidelines previously established in the Close Out Procedures guidance for
determining ground water restoration remedy construction completion eligibility should be
utilized.
-------
This document provides guidance to EPA staff It also provides guidance to the public
and to the regulated community on the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP). The guidance is designed to describe EPA's national policy. The
document does not, however, substitute fin: EPA's statutes or regulations, nor is it a regulation
itself Thus, it cannot impose legally-binding requirements on EPA, States, or the regulated
community, and may not apply to a particular situation based upon the circumstances. EPA may
change this guidance in the future, as appropriate.
Evaluating "Construction Complete" for In-Situ Remedies for Ground Water
In-situ treatment remedies for ground water could include chemical oxidation, other types
of chemical treatment, biological treatment, thermal treatment (using steam or other heating
methods), air sparging, permeable reactive barriers, and other methods. In-situ treatment
remedies for ground water typically involve adding treatment agents to the subsurface.
Treatment agents could include chemical agents (e.g., oxidants, or surfactants); agents to
facilitate microbiological activity; heating agents (e.g., steam, or electric current); physical
reactants (such as zero valent iron, oxygen or air); or other agents.
Generally, these in-situ treatment remedies for restoration of ground water may be
considered construction complete when the following activities have been completed and
completion of each activity has been documented in a construction completion site Preliminary
Close-Out Report:
1. Physical construction for all portions of the final remedy should be complete.
Physical construction of all portions of the full-scale remedy should be complete,
including injection wells, metering systems or other components needed to place
or control movement of treatment agents in the subsurface.
If a permeable reactive barrier (PRB) is used, physical construction of all
components of the barrier system, including reactive and non-reactive segments
of the barrier, should be completed.
If a pump and treat system is part of the ground water restoration remedy,
physical construction of all components of the pump and treat system should also
be completed.
If no physical construction is needed for the full-scale remedy (e.g., existing
injection wells or monitoring wells will be used), construction may be considered
complete when final design of the full-scale remedy is completed. In this case,
the final design report should specify the treatment agents to be used, the method
for placing treatment agents in the subsurface, and the location and design of
injection wells (or equivalent) to be used for the full-scale remedy. Also, any
- 2
-------
treatability tests needed for design of the final remedy should have been
completed.
2. At least one round of treatment/agent addition has been initiated, for the full-
scale remedy.
If different agents are to be added in stages, at least one round of the first stage
should have been completed.
For electrical resistive heating and thermal conductive heating, this typically
would mean turning on the power for electrodes or heater elements.
For steam enhanced extraction, this normally would mean commencement of
steam generation.
For in-situ chemical oxidation and surfactant/co-solvent flushing, this usually
would mean initial agent addition.
For a permeable reactive barrier (PRB), the treatment agent (reactive barrier
material) should have been placed during remedy construction.
If Geoprobe"01 points (or similar) are to be used for injection of treatment agents,
injection points needed for at least the first round of treatment should have been
installed.
3. The pre-final inspection should have been conducted and should indicate the
remedy will perform as designed and any expected future adjustments are likely to
be minimal in nature.
Replacement of existing injection wells or installation of additional injection
wells (or equivalent devices used to place treatments agents) generally may be
considered to be adjustments that are minimal in nature.
If a contingency remedy was selected in the Record of Decision (ROD), the
construction completion site Preliminary Close-Out Report should state that use
of the contingency remedy is not anticipated at this site.
Conclusion
The information provided in this document should be used by remedial project managers
when drafting Construction Completion site Preliminary Close-Out Reports beginning in Fiscal
Year 2006. The criteria included should serve as a guide for the type of information to include
with regard to in-situ ground water remedies when documenting site construction completion. If
_ 3 _
-------
you have questions regarding this policy, please contact me or have your staff contact Richard
Jeng at (703) 603-8749
cc: Eric Steinhaus, Superfund Lead Region Coordinator, US EPA Region 8
NARPM Co-Chairs
OSRTI Managers
Debbie Dietrich, OEM
Matt Hale, OSW
CliffRothenstein, OUST
James Woolford, OFFRO
Linda Garczynski, OBCR
Susan Bromm, OSRE
Scott Sherman, OGC
EdChu,OSWER
Carolyn Williams, OSRTI Documents Coordinator
- 4
------- |