A | UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
* WASHINGTON, DC.
Of f iCfc Ci-
"• V\ASTT AND tl.ttfi
HfcSPONST
OS WEI Directive
9283.1-33
MEMORANDUM
SUBJECT: Summarj oi'Key Kxisting EPA C'liRCt.A Policies for (iroondwater Restoration
James F, Woolford, Director
Office of Superfund Remediation anU Technology Innovation
•
John fl Reeder, Director (_rl
Federal Facilities ReskTaffon aiul RIMKSC (ifflce
TO: Superfund National Policy Managers., Regions 1 - ! f>
The mission of ihc Superfund program is 10 protect human health and the en\'ironnienK
consistent with the Comprehensive liaviRmmenUil Response, Compensation, and Liability Act of
lc)$0 (CHRCLA),1 as implemented by the National Oil and Hazardous Substance Pollution
Ct'Mitiitgency Plan (NCP), in part by restoring contaminated groundvvaters to beneficial use. The
purpose of this memorandum is to provide a compilation of some key existing EPA groundwaier
policies to assist HFA Regions in making groundwater restoration decisions pursuant lo
CT.KCl.A and the NC1}, In addition. b> providing this infonuation in a Mingle document ti ma%
serve to enhance the transparency and understanding, by the public, state regulators and others,
of HPA's dean up decisions related to groundwater.""
1'hts document provides gyitianct w Region.il >taff tesyrdiH!' how the Agens;\ sntcfiif< t»> sistcr«;'re* and i
the Niittona) Oi! and ILi/ar«,}»»,is Suh^ante PoUuiion Contingv'ncv Fian (NCPt v\hich ptmules ttu- bhieprinr t"«w
O-RCI A imp«einent,Hnsn However, this document does o«t vtihsiitutc for those pr<>\T»ioru ur rcgulati ins, nor is it
,i regulation itseif. Thus i( cannot tttifw>e iegalh hindtnu «i|«i{cmcnt.s or !:PA, swk'>, ur tht" reguljtcd awnmunin,
and tr,3> not appi) u> a partkui.ir shudtiou based upon the csrcumMancev An; deci reg,'Uili»g a particular
situation will be made based on the statute and the regulations, and CP-\ decision-makers tvtaai the discretion to
adopt apivoacheji on a case-by-casc basis that dif'iei from the guidance where appropriate
' ,V>c 14 FR 4685-4686 (J,uumr> 26, 2(M»»» Memoranda from 1'rcsident O/iama to the ilc-ndv »>f Fxecuiive
I )epartmeitts and Agencies " rranvp;trenfy and tlpen GnvcmmerH" t signed Januar}' 21. 2009). I "or example:
Tramparencv prowhrft'i at,I'onntiibtlity andf>rf>rii,lcA ittfurmatnw for ntow
»I'rirrtcd wiSi Vegeuo't* CXI BaAwl Ink.s tm tOt)% Hocy Sed Paper (40%
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This memorandum brings together and highlights some of the husk1 principles related to
groundwater restoration that are articulated In multiple existing A gene \ guidance documents,
including those related more generally to cleanup actions. It does not create any neu guidance to
the EPA legions; raihcr this memorandum addresses some of the key incraii principles for
groundwater remedial actions, as well as important concepts related to the following:
» Whether CCRC'LA remedial action is warranted
* Appropriate role ol" institutional controls (JCs)
» Groundwater classification and beneficial use policy
» Remedial action cleanup levels
* Groundwatcr point of compliance
In working with oilier Federal agencies to make groundwater clean up decisions at sites
where the other Federal agency Is lead for cleanup. EPA Regions should use the principles
highlighted in this document to ihe same extent a,s at non-federal facility .sites. Section
120(a)(2) of CERCI A provides that a!l guidelines, rules, regulations, and criteria for preliminary
assessments, site investigations, National Priorities List (NPI,!4 Jbtiog, and remedial actions are
applicable to federal facilities to the same extent as> they are applicable to other facilities, ft
stales the follow ing: "No department, agency, or instrumentality of the ( 'tilted Slates may adopt
or utilize any such guidelines. rules, regulations, or criteria which are inconsistent "with the
guidelines, rules, regulations, and criteria established hj the Administrator under this Act."
Groundwatcr response actions under CHRCI.A are governed in part b\ the following
mandate established In Congress in CRRTI.A 121fd){2HA):
...Such remedial action shall require a level or standard of control which at least attains
Maximum Contaminant Level Goals established under the Safe Drinking Water Act and
water quality criteria established under section 304 or 303 of the Clean Water Act, where
such goals or criteria are relevant and appropriate under the circumstances of the release
or potential release,
This requirement is reflected in the NCP as follows: "Maximum contaminant level goals
(MCLGs). established under the Safe Drinking Wafer Act, that arc set a! levels above zero, ..."
or "maximum contaminant level (KICI.j shall be attained where relevant -tr.d appropriate to the
circumstance? of the release. . ."^
what their Gwerftm^tti if J< 'ing luform-ait^n ftiastttJitttJ ,V llh~ Ftfderjt ff'tt-ivwuf''// iv a ntifittnai «isst7 Mi
tion v-ill tJ^a \ip/*r<>f>ruti' Atwn. cnuwtsnt \nttj (M~ Midfhn rapiJh Mjwtn.*
that the public can rtfjiiily find and UK, See >A) provides a role fitr I'-PA in the selection of remedies at I cdrrjf facilities on (he
National Priorities I ist.
' ,S\v 55 FR 8666-8865 (March K>
* 4«> CFR §300.430(3 MB) and lO.
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(..\WMsient with CERCLA and the NCf\ Superi'und response actions protect human health
and the environment in a number of ways, such as by remediating contaminated so Us, restoring
contaminated groundwa;ers u> ftidr beneficial uses. preventing migration ot" contaminant plumes.
and protecting groundwatcr and other environmental resources. I'o ensure protective remedies.
CERCLA response actions that clean up contaminated groun-iwater general!) address all
pathways of -exposures that pose an actual or potential risk to human health and the environment.
For example, groundwatcr response actions should generally address the actual or potential
direct contact risk posed by contaminated grwindwater (e.g., human consumption, dermal
contact, or inhalation), and also should consider the potential tor the contaminated groundwaier
to serve as> a source of contamination into other media (e.g., for vapor intrusion into buildings;
sedimem; surface water; or wetlands).
1 he NCP establishes general expectations for purposes of groundwatcr restoration as
follows:
EPA expects to return usable ground waters to their beneficial uses wherever practicable.
within a limeirame lhat is reasonable given the particular circumstances of the site. When
restoration of ground water to beneficial uses is not practicable, EPA expects to prevent
further migration of the plume, prevent exposure to the contaminated ground water, and
evaluate further risk reduction.6
Reeogni/ing that groundwaters of the United States are \ulued natural resources, the
Agency carries out CERCf ,A response actions in a manner thai ensures Superi'und remedies are
protective b>. among other things, restoring contaminated grouiulwater to beneficial uses.
Generally, these response actions MCLs land non-zero MCLGs. where appropriate) for
current or potential drinking wafer aquifers.
Principles for
As discussed in the NCP and in various associated guidance, there are in general, five key
principles that stem from the overarching expectations for groundwatcr restoration. These are as
follows:
1) If groundwater thai is a current or potential source of drinking water is contaminated
above protective levels (e.g., for drinking water aquifers, contamination exceeds Federal
or State MCLs or non-zero MCLGs). a remedial action under CERCLA should seek to
restore lhat aquifer 10 beneficial use (e.g., drinking water standards) whenever practicable
2) Groundwatcr contamination should not be allowed to migrate and further contaminate the
aquifer or other media {e.g.. vapor intrusion into buildings; sediment; surface water: ur
wetland).
3) Technical impracticability waivers and other waivers may be considered, and under
appropriate circumstances granted if the statutory criteria are met, when ground water
clean up is impracticable; the waiver decision should be scientifically supported and
clearly documented.
40 CFR
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41 Early actions (such as source removal, plume containment or pro\ tsion of an alternative
water supply*) should be considered as soon as possible. !Cs related to uroundwater use
or even surface use, ma> be useful to protect the piiWic in the short-iernu as well as in the
Song-term,
51 iCs should not be relied upon as the only response to contaminated groundwater or as a
justification for not taking action under Q:RCf ,A.V To ensure protective remedies,
CERCLA response action cleanup levels tor contaminated ground water should generally
address all pathways of exposure thai pose an actual or potential risk to human health and
the environment.
In addition, the stale or tribe with jurisdiction over the groundwater often can have an
important role in (raining HPA's approach to groundwater characterization and remediation
under Superfund, For example, states and tribes may have antidegradation or similar regulations
or requirements that may be potential applicable, or relevant and appropriate requirements
(ARARs). How state and tribal groundvvater policies potentially impact remediation decisions is
discussed later in this guidance.
tt'kether CERCLA Remedial Action is Warranted
The NCP preamble states, "The results of the baseline risk assessment are used to
determine whether remediation is necessarv, to help provide justification for performing
remedial action, and to assist in determining \\hat exposure pathways need to be remediated.""'
In the '"Role of the Baseline Risk Assessment in Superfund Remedy Seltcf'ou Decisions"
(OSWER Directive ^355,0-30. April 22. 10011
tstfe http:.'Jv>\vAv.cpii.go'. -•'•.Aer'riskayfcssment'rHJf/ly -c:-i»e.pdf'?. the Agerey further clarified
this policy.
Chemical-specific standards itui define acceptable risk lex els (e.g., non-/ero MCLGs,
MCLs) also may be used to determine whether an exposure is associated with an
unacceptable risk to human health or the environment and whether remedial action under
Section 104 or 106 is warranted. For ground water action, MCLs and non-zero MCLGs
will generally be used to gauge whether remedial action is warranted,
In addition, the NCP preamble notes that regulations that help define protecthetiess (e.g., MCLs)
also may help ascertain whether a remedial action taken at a site remains protective for CERCLA
purposes.'!
T S« "Considerations IB iirouitd-Wirer Rerae Italian at Supcrl'und Sites and RCRA f;aciiffbs UpdaUf t Directive
Number 9283.1-06. May 2~, 1992) for a more complete d.iscti>Mi>« of early actions, |S«* pj^wsfj-S.)
* See 55 KR 8S65 (March 8. !*>**rt) for a list of potential uaj •• ofpn,n idins an alternatec waiter supply (Appendix D
.Vtv 40 CFR § 300 4 .>t to he practicable- based on fiw balancing of trade-offs
among alternative that»;. Hwduclctt during the selection of remedy, "\i Also see 40 CFR § ,V»0.43(KaK iit> (A)
related Ui the expecytson for treatment
"' See 55 FR S704} {March 8, 1V90V
" In the context of post-jtOl) changes, the NC P preamble notc^: ", a remedy nuis< be modified if necessary to
protect human health and the environment; newly promulgated or modified reqtiircmenls contribute to that
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A CHRCl.A reoivdtal action general!) is appropriate * in various circumstances,
induding: a regulator)' standard that helps define proteeuvenass tc.g,, a federal or slate MCL or
mnuero MCLG for current or potential drinking wafer aquifers) is exceeded, when the estimated
risk calculated in a risk assessment exceeds a noncarcmogenic level tor an tuhcrse health effect
or the upper end of the NCI* risk range for "'cumulative carcinogenic she risk to an Individual
based on reasonable maximum exposure for both current and future latxl use1''"'; the non-
carcinogenic hazard index is greater one fitting reasonable maximum exposure assumptions
for either the current or reasonabh anticipated future land use!; or the site contaminants cause
adverse environmental impacts.14 It is important to note that all conditions Ai not need to be
present for action and the conditions may he independent of each other.
Under existing Agency policy, groundwaters that arc current or potential sources of
drinking water that exceed risk-based standards (e.g., MCLs) or pose an unacceptable risk
generally warrant a remedial action under CERCLA. Other routes of exposure, such as vapor
intrusion, or current or potential threat to sediment quality* surface water quality, wetlands or
critical habitats for protected species, also may be the basis for remedial action tinder CERCLA,
Appropriate of/Cs
While iCs related to ground water or surface u^e may be used as pan of a response action,
the NC'P preamble indicates that ICs generally are mU to be included when evaluating whether a
CERCLA remedial action k% appropriate in the first place.'" in addition, the NCI* preamble1'**
states that "jtjjhe baseline assessment is essential!) ait evaluation of the no-action alternative.
Insftiutksiiai controls, \vhile not actively cleaning up the contamination at the MIC, can control
exposure and. therefore, are considered to be hmiled action alternatives."'' Therefore, the
baseline assessment should not include the impact of potential or existing 1CX
IK
Furthermore, an 1C. by itself generally should not substitute lor active remediation of
groundwatcr. The NCI* preamble states: "Institutional controls will usually be iKsed as
supplementary protective measures during implementation of ground-water remedies."19
evaluation of protectivcnm." A\v 55 I-'R 8758 (March H,
'" ,Siv "Rules of Thumb for Siipcrfund Remedy Selection" OSWER Directive 9355-0-6*) < August 1WJ;
1' Sec "Role of the Baseline Risk Assessment in SupedunJ Remedy Selection Decisions1' ciSWLR Directive
*»355,0-03( April 22. 1991).
''* 5« '"Rules of Thumb for Supcrfund Remedy Sekrtion" OSWITR Directive 9355 0-6C> \ Aujjisst !«W;
(l^v 55 i-R 8710- 871 L tM.ircii S, H90t.
^.S*v 55 FR S~ I! iMarch 8. ! WV)
1 Some Regions have incorrect!) identified remedies requiring only institutional conlrolx ;»s "no dciion'" remedies,
For further information and gjidjincc regarding iCs. u*c hup' v'u-ww.epa.govfiup»?rfund policy ic-guide,index him
'* iVt: 40 CFR § 30(143il(a)(»ijf t>| i'Tlic me of institutional cuniruk shall not substitute fi«r active response
measures (e.g., treatment and or conuinment of source material, restoration of ground waters to their beneticial
use,1.} as the sole remedy unless >uch active measures are determined not tc» be praetitahlc. based on the balancing of
iradc-ofts among alternatives thai i> conducted during the selection of remedy,'5)
" Scf 55 FR 8732 (March 8, 19«H)>.
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While there may he limited circumstances where an IC-only final remed)"' K
appropriate> generally an IC-only ROD would fblkw selection of other renediai action elements
in previous decision documents. For example, previous decision documents may have selected
active remediation that included removal of sources contributing to ground water contamination.
may have addressed groundxvaters to ifie extent practicable, and may hune invoked a TI waiver
of ARARs for specific contaminants ~>n one part of;» aquifer. Where the cleanup under
pre\ious decision document has not ensured protection o!'human health for that part of the
groundwaier that will not achieve MCLs. a separate decision document would generally be
issued to select one or more It's to prevent current or future exposure to contaminated
ground water.
Where a Region is considering an IC-only ROD that is also an IC-only remedy for all or
a portion of a site for groimdwater, the Region should consult early with the appropriate
Regional Coordinator from Office of Superfund Remediation and Technology innovation
(OSRTI) or Federal Facilities Restoradon and Reuse Office (FHRRO). This consultation is
intended to ensure that the decision making process appropriately evaluates and proper!}1
documents key aspects that may be associated with the remedy selection process leading to an
IC-only remedy. This evaluation mav include consideration of source removal, active
* ^i
remediation, granting a technical liTtrraetieahflity fTTj waiver' for applicable and relevant and
appropriate requirements i ARARs), or adopting monitored natural attenuation"" fMXA)i.
(jfuundwatcr Classification and Beneficial i'.w Pttlicy
The NCT slates thai "EPA expects 10 return usable ground waters to their beneficial uses
wherever practicable, within a timeframc that is reasonable given the particular circumstances of
the site."""1 This policy often hinges 0.1 the determination of the current or potential use of the
groundwater aquifer. The NCP preamble slates.
...to the degree that the state or local governments have classified their ground water,
EPA will consider these classifications and their applicability to tilt- selection of an
appropriate remedy... If a state classification would lead to a less .stringent solution that)
the EPA classification scheme, then the remediation goals will generally be based on
EPA classification, Superfund remedies must be protective. If the use of state
classification would result in the selection of a nonprotective remedy, Hi"* A would not
follow the state scheme."
•'" An IC-enh ROD \< a dccKtoo document tint Is on!\ .sdeenitg an lasiiiutiona! control u achieve- protecuvencs? for
the currem or reasonabK anticipated land, grcund water or Mitfice waer u*c. ft nontiaMv docs not a d yffiround-Water F.tfi.U>ration" (Directive Number 9234,2-25. Sept. !«H»3), For further
information see http1 -www epa.go\ •supemmdTniaJth'conmedia'gxvdocs arars htm
"'' "Use of Monitored Natural Attenuation at Supttrftmd. R('R-\ Collective Actiwi, and l";KJcrgwund Storage Tank
Sites" (OSWER Directive <>200.4-i7I\ April 21, |Q9^H-l«Hitk> {-PA policy regarding the we ofMNA for suils and
groundwater. For further infonnation see http: 'w\v\vcpa.gov'!tu}.*ertiind.health't*>nmedia'u\vdiKs'monit.hlm
'" 40 CFR § 300..l30(aH t
MA'c 55 PR 8733 (March 8.
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Die NCP preamble also states that it' such ground\\ater classification. as discussed aho\e.
is not available, then "faj determination is made as to whether the contaminated ground u liter
falls within Class L II, or ill. Guidance for making this determination is available in "EPA
Guidelines for Ground- Water Classification" i !*>«% Federal Guidelines) (Hnai I Haft, December,
The NCI* preamble guides almost all I- PA grounds\at;r classification and beneficial use
decisions for CERO..A response actions. In Slates that have an EPA-endorsed Comprehenshe-
Stale Ground Water Projection Program (CSGWPP), however, EPA's guidance entitled: "The
Role of CSGWPP in I-iPA Remediation Programs" (April 4. 1997, OS WEE Directive 9283.1-09)
builds on the NO* preamble with respect to the State role. Tue guidance1'' stales:
Superfund and other HPA remediation programs should generally defer to a State's
determination of current and future groundwater uses, when based on criteria or methodology
that 1 } are specified in un IXPA-endorsed Core CSGWPP, ant! 2) can be applied at specific sites
or facilities.
Il further clarifies:
For States chat do not have an EPA-endorseJ CSGWPP, or for CSGWPPs that do not
have provisions for making site-specific determinatkv.ib of ground water use (or resource
value, priority or vulnerability), the Super fund program will continue to follow guidance
provided in the NCP Preamble.
Land use is not identified as a consideration in making groundwater classifications. The
C 'SCI WPP Guidance and the I^K6 Federal Guidance, as wet! as other P-PA guidance related to
groundwater cleanups under CERCLA authority, are available on the "K,c\ ( )S WHR Ground
Water Guidances and Kc ports" on EPA's web page
In summary, groundwaters should be restored to their beneficial use. While a State's
designation of groundwater use will be considered lor establishing remediation goals, EPA's
classification scheme (KP.-I Guidelines for Ground-Water (lasfificatwn (Final Draft, December
1986s) will generally be used if a state's classification would lead to a less stringent solution. In
1 W7. HPA initiated a policy of deferring to a State's determif ation of current and ftiture
groundwater uses, when based on criteria or nieihodology that are specified in an EPA endorsed
CSGWPP, and can be applied ai specific sites or facilities.
"'*' SiV 55 FR 8732 {Mdfdi S, t Wt>> flass I and 11 me eoiwikted tu be cu.rcnt And rn>tcntiai drinking water
a<|ulters.
3f< " I he Role of CSGWM'S in Kl'A, Remediation Frograms," It >S\\'HR Directive 9283 1 -W) April 4. 1997..
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Remedial Actwn Cleanup Litveh
Pursuant to CliROLA section 121, all .Superfund remedial actions must be protective of
hurr.an health anJ the environment anJ must comply with ARARs,' As noted previously,
CHRCLA 121(di spocifjcjllx identifies Safe Drinking Water Act MCl.s and nonzero MCLGs, as
well as Clean Water Act Water Quality Criteria as potentially rcie\ani and appropriate standards
lo he attained by the remedial action. In addition, the NCP slates;
Maximum contaminant level j:oals (MCI.(is), established under the Safe Dnnking Water
Act, that are set at levels above zero, ihall be attained by remedial actions lor ground or surface
waters thai are current or potential sources of drinking water, where the MCLGs are relevant and
appropriate under the circumstances of the release based on the factors in 300.400(g)(2). If an
MCLG is determined not lo be relevant and appropriate, the corresponding maximum
contaminant level (MO/) shall be attained where relevant and appropriate to the circumstances
of the release,28
The NCP preamble further clarifies that:
KPA's policy is- that MCI.s or MCL/is abtne zero should generally he the relevant and
appropriate requirement for ground water thai is or may be used for drinking, and a
waiver is generally needed in biluations where a relevant and appropriate MCL or non-
zero MQXt cannot be attainec.""
Where ground\vater> may impact surface water quattf). "water quality criteria established under
section 304 or 303 of the Clean Water ACL" ma)' be relevant and appropriate standards
consistent with CERCI A §!2!{d)(2MAK'ti).
Cleanup levels for remedial actions under CHRCLA generally arc developed based on
site-specific risk assessments. ARARs1", and/or to-be-considered materials (T'BCs). *' Where
" Under CERCLA section t2l(d)(4), an ARAR may he waived under certain circumKtauccs, See 4(1 CFR
300,430(f){l){i)(A) and See 40 CFR .100.430(00)11 MitHBl The NCP further states "On-site remedial action
selected in a ROD musi attain those ARARs t.nat are identified at the time of the R Ri'niciiadan Goals for Groumhvncr ^ CFRCLA Sties.""
(Directive No. 9283 1-14. No\; ft. 2 tree for any ?.OU.4-I8, Aug. 22. 1997, page 2), See also 40 CFR §
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ARARs are noi available or are not sufficient!) protective, EPA generally sets site-specific
remediation lex els for; i) carcinogens at a level iliat represents an excess upper bound lifeume
cancer risk to an individual of between Iff* u> lu, consistent with the XCP (e.g., restoration to N'U'Ls for current or potential
drinking water aquifers) also adequately address other routes of exposure associated with the
ground \vatet. including ground waters as a source of contamination to other media ('e.g., for vapor
intrusion into buildings; sediment; surface \\ater; wetlands).
As discussed above, groundwater cleanup levels are established based on promulgated
standards (e.g.. Federal or State MCLs or non-/ero MCLGs, or other standards found to be
ARARs), or risk-based levels (e.g., for contaminants when there are no standards that define
protect! venesx),
Groundwafff Area of AttaintttL'ttt OF Point of Compliance
I i ^ -^ ^
The NCI* preamble uses both ''area of attainment" aaJ "point of compliance'* ""* in
discussing where groundwaler cleanup lex ds arc to he achiev ed. 1 he area of attainmentpoint of
compliance is important in the overall framework of developing and implementing cleanup of a
contaminated aquifer. The NCI* preamble sets forth the Agency's policy that lor groundwaler.
300,400(g}(3) diiil CFRCLA Compliance with Other Uws Manual; Interim final (EPA.;540/6-8*'W)6, Aug. 1981),
at 1-76,
"\> fur Contatttiiwtetl (iround Water at Superfund Sites." «^SVl KR Directi\e
9283.1-2, December !9gS, p. xv ) where the area of atuimncnt is defined •« "lt]he area of the plume outside the
Ixiundar}-1 of any waste to be managed in place as pan of the final remedy :ind inside the boundaries oftiie
contaminant plume."
14See 55 FR 8753-8754, March 8, 1990. These terms complement one another and generally mean that
everything down gradient From the point of compliance or area of attainment should achieve the cleanup
level. If the point of compliance is throughout the phwtw, the area of attainment is the entire plume. If the
point of compliance is the uni; boundan-, then the area at'attainment b thtoughout the plume down
gradient of the unit
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"remediation levels gcneralh should be aftnincd throughout the contaminated plume, or at am!
beyond :hc edge of the waste management area"" when waste is left in
The NCP preamble also indicates thai in certain situations it may be appropriate to
address the contamination as one waste management area for purposes of the groundwater point
of compliance: for example, this may be protective of public health and the environment at
certain sites where there are multiple sources from closely spaced waste management areas.'1
The preamble stales:
In such cases, the most feasible and et'Fecti\e ground- water cleanup strategy may be to
address ihe problem as a whole, rather titan scare e-by -source. to draw the point of
compliance to encompass the sources of release. In determining where to draw the point
of compliance in such situations, the lead agency will consider factors such as the
proximity of the sources, the technical practicability of ground-water remediation at fhat
specific site,, the vulnerability of the ground water and its possible uses, exposure and
is
likelihood of exposure and similar considerations."
In summary, the area of attainment/point of compliance for achieving gromtdwater
cleanup levels is generally expected to be throughout the plume or, where there is a waste
management area, at the edge of the v\aste management area. Regions are strongly encouraged
to contact OSRTI groundwuter experts listed at the end of the memorandum concerning
questions regarding the area of attainment/point of compliance .
When addressing groundwater contamination at CERCl.A sites. Regions should carefully
consider the five principles discussed herein, as well as the NCP and other Superiund guidance
documents, in evaluating CTRCLA remedial actions. Regions are requested to consult with
OSRTI or, when a Federal facility is involved, FFRRO, in cases of IC-onlj- groundwater decision
documents or if there are questions related to area of attainment/point of compliance,
This memorandum compiles some fcev aspects of important groundwater policies
regarding CHRCLA remedy selection, For further information on the basis for actions and
ARARu, please contact Robin M. Anderson ai Anderson . Ho hi iiM '.g>ega ..go v (703) 603-8747,
for information related to groundwater response policies, please contact Matt Charsfcy at
Charsk> ..Matthew igepa.gov (703-603-8777) or David Bartenfeider af
' (703-603-9047). For questions related to Federal facilities plea.se
K "TDM APLs arc typiealK not located in a waste management area, as envisioned in the NCP."
'"Presumptive Response Strategy and Ex-Sttu Treatment Technologies for Contaminated Ground Water at CERCI..A
Sites" (Directive 9283.1-12, October 1996 at page IS.
l*"See 55 FR 8753 (March 8, 1990). Similarly, the preamble to the proposed-NCP slates: "For ground water,
remediation levels should generally be attained throughout the contaminated phimc, or at and beyond the edge of this
waste management area when waste is left in place. For surface waters, the selected levels should be attained at tin-
point or points where the release enters the surface waters,1' See 53 PR 51246, December 21,
"7 Li
"*s See 55 FR «?54, March. 8. WO,
10
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contact Tim Mutt at ^fiHiTinio|hi_4i,epa.£ov f7i)3-60?-8807 , Consultations should be
coordinated through the appropriate Regional Coordinator from OSR11 or, if Federal facilities
are involved. FFRRO.
cc: Mat hy Stanislaus, OS WE R
Barry Brccn. OSWL-R
Rence Wynn, C38WER
Debbie Dietrich, OHM
David Lloyd, OBI R
Man I lale. ORCR
Carol) rt floskinsan, CM:ST
Elliott Gilberg. OSRl:
Dave KHng. !;FI:O
ttai! Cooper. FhRRO
OSRI'l Managers
John Midland, IXK"
HI*AM-11.C Membership
Superlund Branch Chiefs, Regions 1-10
Superfund Branch Chiefs, Office of Regitmal Counsel, Regions 1-10
Wendy Lubbe, Supcrfund Lead Region Coordinator, US EPA Region 7
NARPM Co-Chairs
Federal l-aciiity Forum Co-Chairs
Ciroundvvater Fomm Co-Chairs
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