EPA-542-F-15-010
                                                                                      April 2015
            United States
            Environmental Protection
            Agency
                            orum issue roper
           Ground  Water Technical Considerations
               during the Five-Year Review Process
          Table of Contents
1.  INTRODUCTION                  1
2.  FYR TECHNICAL REVIEW TEAM     2
3.  TECHNICAL CONSIDERATIONS
   DURING THE SCOPING MEETING    2
4.  VALIDATION OF THE
   HYDROGEOLOGIC CSM           2
5.  GROUNDWATER DOCUMENT REVIEW 3
6.  GROUNDWATER DATA REVIEW     4
7.  GROUNDWATER CONSIDERATIONS
   FOR THE SITE INSPECTION         4
8.  GROUNDWATER TECHNICAL
   ASSESSMENT                   5
9.  GROUNDWATER REMEDY
   PERFORMANCE                  6
11. CONCLUSIONS                   7
10. EXAMPLE GROUNDWATER ISSUES
   AND RECOMMENDATIONS          7
12. CITED REFERENCES              7
13. ACKNOWLEDGMENTS             9
14. NOTICE AND DISCLAIMER         10
15. TABLES                       11
   Table 1.  Common Technical Questions
          at Groundwater Sites        11
   Table 2.  Remedial Performance
          Technical Elements to Evaluate 14
16. FIGURES
21
   Figure 1. Hydrogeologic CSM Example
          Block Diagram            21
   Figure 2. Hydrogeologic CSM Example
          Cross Section             22
   Figure 3. Groundwater/Surface Water
          CSM Example            23
17. KEY TECHNICAL RESOURCES FOR
   FYRS AT GROUNDWATER SITES    24
1.  INTRODUCTION

This issue paper has been developed to highlight technical consid-
erations as well as technical resources available to Remedial Project
Managers (RPMs) in conducting Five-Year Reviews (FYRs) at
CERCLA1 sites with contaminated groundwater. While it has been
developed with the needs of the U.S. Environmental Protection
Agency's (EPA) RPMs  in mind, it may also be helpful to other
federal and state agencies that have the lead for conducting FYRs
and may assist EPA staff in reviewing those FYRs. In addition,
Table 1 provides FYR teams with examples of technical consider-
ations that can be used as a resource for practicing hydrogeologists
when reviewing groundwater remedy implementation.

Groundwater is the pathway of concern at many sites, either as a
potential water supply source or as the medium for transporting
contaminants that then discharge to sediments, surface water, or
air. Many of the more challenging CERCLA remedies involve the
management of contaminated groundwater, whether the remedial
action objectives (RAOs) include restoration or containment. Almost
90 percent of National Priorities List sites with remedy decisions have
a remedy that addresses contaminated groundwater (EPA? 2014).

This issue paper is not guidance.  Instead, it outlines technical
considerations and resources within EPA regions and states
to  help RPMs consider groundwater concerns in more detail
throughout the FYR process. The issue paper also highlights the
importance of involving a hydrogeologist2 early and consistently
throughout the FYR process for groundwater sites. It identifies
technical information that may benefit from review by and input
from hydrogeologists. It also suggests opportunities for identifying
groundwater remedy issues and developing recommendations to
address them.  Finally, it provides a list of references and technical
resources for RPMs and technical staff.
1 Comprehensive Environmental Response, Compensation, and Liability Act,
  also referred to as "Superfund"
2 A hydrogeologist as referred to in this report can be either a hydrologist,
  environmental scientist, geologist or earth scientist/engineer that is trained
  to understand the physical and chemical aspects of the groundwater remedy
  (e.g., the conceptual site model (CSM), groundwater extraction and injection
  system integrity, and long-term monitoring program)

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2.  FYR TECHNICAL REVIEW TEAM

Conducting FYRs  at complex  sites may benefit from
EPA establishing a multi-disciplinary technical review
team (EPA, 2001). The members of the technical review
team provide technical expertise and assistance to RPMs.
Many groundwater site conditions are so complex and
unique that the GWF recommends that the technical
review team include a hydrogeologist. If EPA does not
have this expertise  available in their regional office, it is
recommended that the RPM explore opportunities  to
leverage other EPA and state technical resources. These
resources may include  experts in other EPA  regions,
EPA Technical Support Centers  (e.g., the Groundwa-
ter Technical Support Center) and EPA Headquarters
support (e.g., Environmental Response Team and the
Technology Assessment Branch). In addition, some
states and other federal agencies (e.g., the U.S. Geologi-
cal Survey and the U.S. Army Corps of Engineers) have
technical experts available to provide valuable  input.
At sites where EPA is the lead agency for the FYR,
the technical review team may be involved throughout
the FYR process.  If EPA is not the lead agency, the
team's involvement in a FYR may be limited to review-
ing relevant site  documents and a final or  draft final
document developed by the lead agency. The remainder
of this document is written assuming the participation
of a hydrogeologist on the technical review team.

3.  TECHNICAL CONSIDERATIONS  DURING THE
    SCOPING MEETING

For FYRs where EPA is the lead agency,  a  scoping
meeting with  the  technical review team is generally
conducted early in the FYR process. Below are some
recommendations of groundwater topics to be consid-
ered and discussed during this meeting:

• Ensure the team understands the decision document
  requirements (e.g., groundwater RAOs and associated
  cleanup levels), expected timeframe(s) to achieve RAOs,
  source control activities and RAOs, and the remedial
  actions selected.
• Identify available information related to current ground-
  water conditions  and remedy progress (e.g., sampling
               data, updated conceptual site model (CSM), and ground-
               water remedy completion strategy3).
             •  Determine if existing groundwater data are sufficient to
               conduct a meaningful analysis of remedy performance.
               If not, identify additional monitoring data needed.
             •  Identify the groundwater concerns expected to take
               the most time to resolve (e.g., Is the plume behaving as
               expected? Are there possible new exposure routes?).
             •  Properly schedule the collection and analysis of any new
               data needed for the FYR (e.g., installation of additional
               wells and related sampling and analysis) to ensure proper
               consideration in the review cycle.
             •  Ensure that the team is aware of the anticipated time-
               frame for the FYR process, particularly document review
               periods.
             At sites where EPA is not the lead, it is recommended
             that the RPM consult with the technical review team
             to ensure all applicable reports can be reviewed a few
             months before the draft FYR report is due. This process
             is already established in some EPA regions and has been
             very effective for all parties involved.

             4.  VALIDATION OF THE HYDROGEOLOGIC CSM

             Validation of the CSM by the technical review team is
             a critical part of the  technical evaluation of  ground-
             water remedies.  The  CSM requires revision with the
             expansion of  site knowledge and  serves as a primary
             project planning and  management tool  (EPA? 2011 a).
             New site data and scientific insights into how contami-
             nants migrate in groundwater ensure that the CSM will
             always be a work in progress.
             At sites with contaminated groundwater, the CSM
             generally includes two  major  components: 1)  the
             pathway-receptor network diagram, which is mainly
             used by  risk assessors and  concentrates on whether
             receptors exist and whether pathways  are complete;
             and 2) the hydrogeologic CSM, which focuses on the
             occurrence, fate  and  specific  migration pathways of
             contaminants in all site media, and aims to include all
             the factors that  control contaminant distribution  and
            3  For more information on groundwater remedy completion
               strategies, refer to http://epa.gov/superfund/health/conmedia/
               gwdocs/pdfs/EPA Groundwater Remedy Completion.pdf
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3 Water Technical Considerations during the Five-Year Review Process

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remedy effectiveness. The GWF recommends that both
CSM components be reviewed during the FYR process.
A hydrogeologic CSM provides a framework for evaluat-
ing the groundwater data and information. In some
instances, the technical review team may identify early
in the FYR process (e.g., during the scoping meeting)
that the site does not yet have a hydrogeologic CSM. In
such cases, it is suggested that the hydrogeologist work
with the RPM using available data to develop a prelim-
inary hydrogeologic CSM. As discussed in the previous
section, the hydrogeologist may also identify issues with
the completeness of an existing CSM. In this case, the
hydrogeologist may recommend the CSM be updated
with the collection and evaluation of additional data.

More information  about  the  hydrogeologic  CSM is
found in the highlight box.
  The Hydrogeologic Conceptual Site Model: What is it and why is it important?

  The hydrogeologic CSM focuses on the occurrence, fate and migration pathways of contaminants in all site
  media. It is meant to include all the factors that control contaminant distribution and remedy effectiveness. The
  hydrogeologic CSM should be described well enough to enable the technical review team to evaluate whether
  the data collected to date, and other new information, are consistent with the contaminant behavior predicted
  by the existing CSM. If not, elements of the CSM may need updating to reflect any new information. Typically,
  figures are necessary to ensure that the team can visualize and understand the hydrogeologic CSM (See example
  CSM figures at the end of this document.). Cross sections, particularly multiple or intersecting cross sections,
  can be useful for visualizing complex sites in three dimensions. Understanding of complex contaminant sources,
  in  particular, can be improved through use of more sophisticated visualization tools (e.g.,  three-dimensional
  geostatistical models), which can provide a variety of visual outputs that show source strength and distribution.
  With adequate data, visualization tools also can be used to estimate contaminant mass. In addition to facilitating
  the current review, an updated or newly developed CSM will benefit future remedy assessments.

  Scientific understanding of how  sources persist and contaminants migrate has advanced greatly since the
  Superfund program began. Therefore, the GWF recommends considering new science when reviewing or
  updating the CSM. Site assumptions made years ago may have been based on more limited information or
  concepts that are more fully or differently understood today. For example, although dense non-aqueous phase
  liquids (DNAPLs) were recognized as subsurface contaminant sources early in the Superfund program, our
  understanding of  DNAPL sources and the resulting plume architecture has evolved and is still developing
  today. Our  current understanding of contaminant behavior has resulted in significant changes in strategies
  for characterizing  source and plume extent, estimating cleanup timeframes for remedial actions, and assessing
  whether the remedy is adequate to meet RAOs or whether the RAOs are technically practicable. Understand-
  ing of the local hydrogeology also may change over time. For example, an aquitard that was thought to be
  regionally thick and continuous may subsequently be found to be discontinuous or thin in places, calling into
  question previous assumptions about the potential for contaminant transport to deeper aquifers.

  For more information, consult, 'Environmental Cleanup Best Management Practices: Effective Use of the Project Life
  Cycle Conceptual Site Model (EPA. 2011 a).
5.  GROUNDWATER DOCUMENT REVIEW

The GWF recommends that the technical review team
review site documents that  support the groundwater
technical evaluation. It may be helpful to provide these
documents electronically in a central location (e.g.,
Micros oft™ OneDrive) for the technical review team
to review.
The following documents may assist the technical review
team in the FYR process. More detail is provided for
information of particular interest to the hydrogeologist
team member.

1.  Remedial investigation and feasibility study (RI/FS)
   reports that describe the CSM (including site hydroge-
   ology and the nature and extent of contamination) and
   evaluate the selected remedial alternative.
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2.  Baseline human health (and ecological, if appropriate)
   risk assessments conducted as part of the RI/FS.
3.  Decision documents, including all the figures and tables,
   which are not always available in the online versions,
   especially older records of decision (RODs). The ROD
   generally establishes RAOs and selects remedial actions
   that either contain sources or  portions of  plumes,
   reduce concentrations, restore contaminated ground-
   water, prevent  exposure, or require improvements to
   drinking water. It is important for the technical review
   team to understand the  groundwater restoration and
   associated cleanup timeframe, and containment remedy
   elements in the ROD.
4.  Remedial design and remedial action  (RD/RA) work
   plan, including the monitoring strategy and design
   (i.e., the operations and  maintenance  (O&M) plan or
   compliance monitoring plan).
5.  Remedial design investigation reports.
6.  Any document that presents an updated CSM.
7.  Any document that presents a performance evaluation
   of a remedy component (e.g., pump and treat capture
   zone analysis or groundwater modeling report).
8.  All previous FYRs for the  site.
9.  Current monitoring plans  (including standard operat-
   ing procedures), quality assurance project plan, or
   other documents that set forth the required locations,
   methodologies, and frequency of sampling for all media
   being remediated.
10. Historical site data including water-quality and water-
   level data along with well construction information,
   ideally compiled in an electronic format (spreadsheet
   or database) that can be manipulated; a complete set
   of well logs; any changes that have occurred to  the
   monitoring well network since the previous FYR
   (e.g., new,  modified or  decommissioned wells); and
   O&M reports, which may be separate from the annual
   monitoring reports.

6.  GROUNDWATER DATA  REVIEW

The hydrogeologist  reviews contaminant concentra-
tion data to identify trends, anomalies and data gaps. A
major element of the technical review at contaminated
groundwater  sites is  the comparison of contaminant
concentrations in each well  to:  1) the plume behavior
             anticipated based on the hydrogeologic CSM; and 2)
             remedy expectations established in the site decision
             documents. This comparison typically includes perform-
             ing or reviewing statistical trend  analyses  of data
             for individual wells and evaluation  of overall plume
             behavior, either through plume map  comparisons over
             time or through statistical analyses that describe changes
             in plume characteristics over time (e.g., MAROS package
             analyses4). In particular, the team needs to confirm that
             the plume is not expanding or behaving in an unantici-
             pated way, and that timely progress is being made toward
             meeting RAOs and associated cleanup levels.

             Ideally, the data should be made available to the technical
             review team to review in enough time for this evalua-
             tion. The hydrogeologist  needs time to evaluate the
             validity of the groundwater monitoring data and the
             associated  trends (including the appropriateness  of
             the statistical approach) in the monitoring reports. If
             monitoring reports do not include a robust data analysis,
             the hydrogeologist may need time to  develop statistical
             trends to  include in the FYR report.

             7.   GROUNDWATER CONSIDERATIONS FOR THE
                 SITE INSPECTION

             The GWF recommends that members of the technical
             review team visit the site to evaluate current conditions,
             including those related to the groundwater remedy.
             The inspection allows the  team to identify changes in
             site conditions  (e.g., new  construction and exposure
             pathways), confirm reported  site conditions, and
             evaluate the condition of existing remediation facilities
             and monitoring networks. If any team member cannot
             accompany the RPM on the site inspection or visit the
             site separately, the RPM may consider documenting
             these site conditions photographically.

             If  the RPM uses a site inspection checklist, the GWF
             recommends that the hydrogeologist review the checklist
             to  ensure it includes an adequate evaluation of the
             condition and functionality of the groundwater remedi-
             ation facilities and monitoring networks.

             Examples of issues related to groundwater remedies
             that may  be encountered during the FYR site  inspec-
             tion include excessive vegetation that blocks access to
             4  MAROS 3.0 is available at: http://old.gsi-net.com/en/softwafe/
               free-software /maros-30. html
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monitoring wells and the loss of monitoring wells as a
result of site redevelopment or maintenance.

In addition, if previous evaluation of analytical data
identified possible problems with sampling procedures
or data quality, the GWF recommends, if possible, that
the hydrogeologist and RPM schedule the site visit to
coincide with a sampling event.

8.  GROUNDWATER TECHNICAL ASSESSMENT

Beyond the  document review,  data  review, and site
inspection, the technical review team may assist the RPM
in answering the three technical assessment questions in
the 2001 Comprehensive Five-Year Review Guidance:

• Question A — Is the remedy functioning as intended by
  the decision documents?
• Question B — Are the exposure assumptions, toxicity
  data, cleanup levels, and RAOs used at the time of the
  remedy selection still valid?
• Question C — Has any other information come to light
  that could call into question the protectiveness of the
  remedy?
This GWF issue paper outlines recommended concepts,
particularly those related to groundwater, that may be
evaluated by the hydrogeologist to assist the RPM in
developing answers to these questions. It also identifies
possible issues that may arise for groundwater remedies,
and provides some examples of recommendations that
may be considered.

/. CSM validation: Site characterization efforts conducted
   to date should generally be reflected in the current CSM.
   In some cases, data may  be insufficient to develop or
   maintain a robust hydrogeologic CSM. If the hydro-
   geologist cannot validate the CSM, this may lead to
   questions regarding the performance of the remedy. If
   time allows, it may be appropriate to conduct additional
   sampling activities to support the FYR process. If not,
   it may be  appropriate to identify the data needs and
   recommend additional sampling activities.
2. Long-term monitoringprogram and groundwater remedy comple-
   tion strategy: The hydrogeologist evaluates the data to
   ensure that the current long-term monitoring program
   effectively characterizes the plume and allows  the
   evaluation of progress toward RAOs and  associated
   cleanup levels.  This evaluation includes a  review  of
   monitoring well placement and construction, as well
   as the quality of data obtained from monitoring wells,
   to  ensure that both hydrogeologic and water quality
   data are representative and reliable. Because sampling
   protocols and equipment have improved over time, as
   has our understanding of what a given  groundwater
   sample represents, it is suggested that sampling proto-
   cols be reviewed to confirm that they are  sufficient
   for obtaining representative  samples. Data evaluation
   may also include a review of the site-specific ground-
   water remedy completion  strategy documentation
   to  ensure that monitoring data are  being  evaluated
   against appropriate performance metrics and remedy
   evaluation decisions. Following review of the monitor-
   ing plan, the hydrogeologist may suggest including a
   recommendation to conduct spatial and/or temporal
   long-term monitoring optimization (LTMO) to verify
   and continually improve the effectiveness and efficiency
   of groundwater remedies.  For example, evaluation
   of the frequency and spatial density of sampling can
   help  determine if monitoring can be  scaled back.
   Conversely, analysis of the monitoring program may
   identify apparent monitoring gaps and indicate the
   need for a geospatial  analysis of the monitoring well
   network. Some LTMO  software  packages include
   geospatial analysis modules for this purpose (EPA,
   2005): however, such analyses do not take groundwater
   gradients into  account and  generally cannot identify
   when plumes are unbounded unless contaminant trends
   are increasing in a network boundary well. Based on a
   review of the groundwater remedy completion strategy
   documentation, the hydrogeologist may also suggest
   including a recommendation to  either modify the
   strategy components (i.e., performance metrics and/or
   remedy evaluations). In the event that the groundwater
   remedy completion strategy is not clearly documented,
   the hydrogeologist may also suggest including a recom-
   mendation  to  develop a more robust groundwater
   remedy completion strategy  document.
3.  Monitoring well integrity. The hydrogeologist evaluates well
   conditions to determine if redevelopment or replace-
   ment of any monitoring wells is necessary. Over time,
   degradation of a monitoring well's performance can
   occur through sedimentation, corrosion, or biofouling.
   The GWF recommends that a desktop review of the
   sampling records  be  conducted to identify possible
   degradation of well integrity. Sampling field notes may
Ground Water Technical Considerations during the Five-Year Review Process
                  Ground Water Forum Issue Paper 5

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   reveal red flags such as changes in measured well depth,
   changes in drawdown behavior during well purging,
   or changes in indicator parameters such as turbidity.

   During the site inspection, the technical review team
   visually inspects all wells for any damage, inside and
   outside. If damage is found that affects performance
   of the well, or could cause the well itself to become a
   potential contaminant migration pathway, the hydroge-
   ologist may recommend the well be repaired, replaced
   or decommissioned. For example, a well left uncapped
   can be vulnerable to surface contamination or vandal-
   ism. If exterior damage that may alter wellhead eleva-
   tions is found, the hydrogeologist may identify this as
   an issue and provide a recommendation to resurvey any
   affected wells to ensure that groundwater flow gradients
   are not mis characterized.
4.  Groundwater extractioni'injection/ re-infiltration system integrity.
   The GWF recommends that the technical review team
   assess the integrity of any site pumping wells, re-injec-
   tion wells, or re-infiltration galleries. The hydrogeologist
   identifies any issues with the system's performance and
   recommends corrective activities (e.g., redevelopment
   or replacement). Likewise, if some  portion  of the
   system is not functioning optimally, the hydrogeologist
   evaluates the effects on the overall system to ensure that
   any pump and treat remedy is operating effectively. If
   the  hydrogeologist determines that the system is not
   functioning optimally or if plume capture could  be
   compromised, the hydrogeologist may identify a data
   need and recommend a formal capture zone analysis
   (EPA. 2008a).
5.  Assessment of new information: As part of the FYR process,
   the technical review team reviews site documentation,
   current site conditions, and  contaminant-specific
   information to check for changes regarding exposure
   assumptions, contaminant toxicity, cleanup levels, new
   contaminants, and standards. While a risk assessor will
   typically provide guidance on changes in toxicity and
   cleanup levels, a hydrogeologist may provide input on
   changes in exposure assumptions or new contami-
   nants identified in groundwater sampling activities. In
   addition, there may be new information that changes
   our understanding of site hydrogeology or new  site
   features that might affect groundwater flow or exposure
   to site contaminants. These features could include new
   ponds, new public supply or other large capacity pumping
               wells, or newly paved or unpaved surfaces. Hydrogeologic
               impacts of these features might include changes in water
               recharge rates, groundwater flow directions or velocity,
               groundwater contaminant vapor migration into ambient
               or indoor air (EPA, 2012a). or groundwater discharge to
               surface water. Changes in land use may also indicate the
               potential for new exposure pathways. If new information
               suggests a change to assumptions made at the time of
               remedy selection, this may be identified as an issue.
             6. Institutional controls: The adequacy of and compliance
               with implemented institutional controls (ICs) limiting
               groundwater use  for the site  are generally evaluated
               during the  FYR  process.  The GWF reccommends
               that the technical review team identify and  evaluate
               any changes in land use that may create the potential
               for exposure to groundwater. Changes may include
               the installation of new wells or new construction over
               shallow plumes. In addition, if a review of monitor-
               ing data indicates  that a plume is expanding, the team
               may recommend that the existing groundwater ICs be
               modified and operational updates be implemented to
               address plume expansion.
             Table 1 provides this list of topics and related questions
             that hydrogeologists commonly evaluate at groundwater
             sites.

             9. GROUNDWATER REMEDY PERFORMANCE

             The FYR evaluates remedy performance to determine
             if the remedy is functioning as intended. The FYR also
             presents a good opportunity to evaluate the ground-
             water remedy components to ensure they function well
             together and are effective and cost efficient. In addition,
             the FYR provides an opportunity to review existing data,
             performance metrics and remedy evaluation decisions
             to evaluate whether the estimated remedial timeframe is
             achievable with the implemented remedy (EPA? 2012b).
             If the technical review team identifies issues with system
             performance, it may recommend characterization activi-
             ties such as determining plume stability, containment or
             plume hydraulic capture.  In  some cases, an evaluation
             of remedy performance may result in recommendations
             to consider a remedy change.  For example, the hydroge-
             ologist may recommend evaluating a transition to more
             passive treatment technologies (e.g., monitored natural
             attenuation) as part of  the groundwater treatment
             train. Conversely, poor remedy performance  may be
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attributed to  remaining groundwater contaminant
sources that require additional characterization. Based
on the  remedy-specific characteristics, the  technical
review team may suggest that the RPM either consider
enhancements to the existing remedy (e.g., more aggressive
source treatment or in situ plume treatments) or recommend
evaluating an alternative remedial strategy (e.g., a technical
impracticability or "TI" waiver (EPA. 1993)5). Table 2 lists
some specific issues to consider for common remedial
technologies for contaminant sources  and associated
groundwater plumes.

10. EXAMPLE GROUNDWATER ISSUES AND
    RECOMMENDATIONS

As discussed in the previous sections, when groundwater
issues are identified throughout the FYR process, the
technical review team works with the RPM to document
these issues and develop clear and concise recommen-
dations to address them.

Some common groundwater remedy issues that may be
identified include, but are not limited to the following:

• Underestimated source mass, both in the saturated and
  the unsaturated zones.
• Underestimated source extent, including unidentified
  source areas.
• Inadequately characterized groundwater plumes in
  three dimensions, including insufficient information
  to identify and monitor the most contaminated plume
  intervals or to recognize the  potential for migration of
  contaminants through presumed aquitards.
• Inadequately documented or unclear groundwater rem-
  edy completion strategy.
• Inadequate understanding of the effect of matrix storage
  on remedial time frames due  to back diffusion.
• Inadequate understanding of connections with other
  exposure media, including surface water, sediment, and
  soil vapor (and potentially complete exposure pathways
  associated with vapor intrusion).
5 Both EPA (EPA. 20lib) and the National Research Council
  (NRC. 2012) have recommended processes for evaluating
  alternative strategies in the event that a groundwater remedy is
  not progressing as anticipated and is unlikely to meet remedial
  goals.
• Contaminants not previously identified as a concern.
  For example 1,4-dioxane may not have been previously
  identified as a contaminant of concern at the ROD stage
  because the detection limit may have changed.
In general, recommendations are developed to address
the issues raised in the review. These recommendations
will be specific to site conditions and reflect specific
activities necessary to effectively address the issue.

11. CONCLUSIONS

Groundwater sites and remedies have specific technical
issues and complexities that are better understood by
hydrogeologists and other groundwater experts. EPA,
other federal agencies, and states  have a significant
amount of technical  expertise  available to assist the
RPM in  conducting FYRs that include groundwater
components. Leveraging these resources, as part of
the FYR technical review team, will assist  the RPM in
reviewing complex groundwater site conditions and
remedies. When  a  technical review team is developed
to review groundwater elements  of a remedy, the GWF
recommends that they are involved early in the FYR process
to ensure they have adequate time and resources necessary
to conduct data review, document review, and participate
in the site inspection. This time frame will depend on the
complexity of the site and remedies implemented. Profes-
sional judgment is required to properly schedule a FYR.

12. CITED REFERENCES

Bradbury, K.R., etal., 2006. Contaminant Transport through
Aquitards: Technical Guidance for Aquitard Assessment.
AWWA Research Foundation, Denver, Colorado, 143
pp., Report 91133B. http://www.waterrf.org/PublicRe-
portLibrary/91133b.pdf

EPA, 1986. Final RCRA Comprehensive Ground-Water
Monitoring Evaluation Guidance  Document.  December.
Available at: http://www2.epa.gov/sites/production/
files /2013-10 /documents / frcracmedoc-rpt.pdf

EPA, 1989. Superfund Ground Water Issue: Ground Water
Sampling for Metals Analyses. (EPA/540/4-89/001).
March, http://www.epa.gov/superfund/remedytech/
tsp  /download /gws amp2.pdf

EPA, 1992. RCRA GroundWaterMonitoring.DraftTechni-
cal Guidance. November. Available at: http://www.epa.
gov/region09/qa/pdfs 7rcra_gwm92.pdf
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EPA, 1993. Guidance for Evaluating the Technical Imprac-
ticability of Ground-Water Restoration,  Interim Final.
(Directive 9234.2-25). September. Available at: http://
www.epa.gov/superfund/health/conmedia/gwdocs/
techimp.htm

EPA, 1994. Methods for Monitoring Pump-and-Treat Perfor-
mance. (EPA/600/R-94/123). June. Available at: http://
www.epa.gov/superfund/health/conmedia/gwdocs/
pdfs/ptmethods.pdf

EPA, 1995. Ground Water Issue: Light Non-Aqueous Phase
Liquids.  (EPA/540/S-95/500). Available  at: http://www.
epa.gov/superfund/remedYtech/tsp/download/lnapl.pdf

EPA, 1997. Ground Water Issue: How Heat Can Enhance
In-situ Soil and Aquifer Remediation: Important Chemical
Properties and Guidance on Choosing the Appropriate Technique.
(EPA/540/S-97/502). April. Available at: http://nepis.
epa.gov/Adobe/PDF/2000BC87.pdf

EPA, 1998a.  Technical Protocol for Evaluating Natural
Attenuation of Chlorinated Solvents in Ground Water.
(EPA/600/R-98/128). September. Available at: http://
www.epa.gov/superfund/health/conmedia/gwdocs/
protocol.htm

EPA, 1998b. Ground Water Issue: Steam Injection for Soil and
AquiferRemediation. (EPA/540/S-97/505). January. Available
at: http://nepis.epa.gov/Adobe/PDF/10002ElU.pdf

EPA, 1998c. Evaluation of Subsurface Engineered Barriers at
Waste Sites. (EPA 542-R-98-005). August. Available at:
http://www.epa.gov/tio/download/remed/subsurf.pdf

EPA, 2000. Superfund Reform  Strategy,  Implementation
Memorandum: Optimisation of Fund-lead Ground Water Pump
and Treat (P&T) Systems. (OSWER 9283.1-13). October.
Available at:  http://epa.gov/superfund/programs/
reforms/docs/implem.pdf

EPA, 2001. Comprehensive Five-Year Review Guidance.
(EPA 540-R-01-007, OSWER No. 9355.7-03B-P), June.
Available at: http://www.epa.gov/superfund/accomp/
5year/index.htm

EPA, 2002. Ground-Water Sampling Guidelines for Superfund
andRCRA Project Managers. (EPA 542-S-02-001). May.
Available at: http://www.epa.gov/superfund/remedv-
tech/tsp /download /gw_samp ling__guide.pdf
             EPA, 2004a. Performance Monitoring of MNA  Remedies
            for VOCs in  Ground Water.  (EPA/600/R-04/027).
             April. Available  at: http://nepis.epa.gov/Adobe/
             PDF/10004FKY.pdf

             EPA, 2004b. What Is Remediation Process Optimisation and
             How Can It Help Me Identify Opportunities for Enhanced and
             More Efficient Site Remediation? Sponsored by: Interstate
             Technology and Regulatory Council.  September.
             Archived presentation available at: http://www.clu-in.
             org/conf/itrc/rpo 092804/

             EPA, 2005. Roadmap to Eong-TermMonitoring Optimisation.
             (EPA 542-R-05-003). May. Available at: http://www.epa.
             gov/tio/download/char/542-r-05-003.pdf
             EPA, 2007a. Monitored Natural Attenuation oj
             Contaminants in Ground Water, Volume 1:  Technical Basis
            for Assessment (EPA 600-R-07-139). October. Available
             at: http://nepis.epa.gov/Adobe/PDF/60000N4K.pdf

             EPA, 2007b. Monitored Natural Attenuation of Inorganic
             Contaminants in Ground Water, Volume 2: Assessment for
             Non-Radionuclides, Including Arsenic, Cadmium, Chromium,
             Copper, Eead, Nickel, Nitrate, Perchlorate, and Selenium (EPA
             600-R-07-140). October. Available at: http://nepis.epa.
             gov/Adobe/PDF/60000N76.pdf

             EPA, 2007c. Optimisation Strategies for Eong-Term Ground
             Water Remedies (with Particular Emphasis on Pump and Treat
             Systems). (EPA 542-R-07-007). May. Available at: http://
             www.cluin.org/download/remed/hyopt/542r07007.pdf

             EPA, 2008a. A Systematic Approach for Evaluation of Capture
             Zones at Pump and Treat  Systems (EPA/600/R-08/003).
             January. Available at: http://cfpub.epa.gov/si/si_public_
             record_report.cfm?dirEntryId= 187788

             EPA, 2008b. Interim Record of Decision, Moses Eake Wellfield
             Superfund Site, Moses Eake, Washington. September. Page
             14. Available at: http://www.epa.gov/regionlO/pdf/
             sites/moses_lake_wellfield/mlwc_interim_ROD.pdf

             EPA, 2009a. GroundWaterlssue: Assessment andDelineation
             of DNAPE Source Zones at Hazardous Waste Sites. (600-R-
             09-119). September. Available at: http://www.epa.gov/
             ada/pubs/issue.html

             EPA, 2009b. Third Five-Year Review Report for Commence-
             ment Bay Nearshore/Tideflats Superfund Site. Tacoma,
             Washington. December. Available at: http: / /www.epa.gov/
             regionlO/pdf/sites/cb-nt/cbnt_3rd_5yr_122309.pdf
   Ground Water Forum Issue Paper
rf Water Technical Considerations during the Five-Year Review Process

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EPA, 201 la.  'Environmental Cleanup 'Rest Management
Practices: Effective Use of the Project Life Cycle Conceptual Site
Model. (EPA 542-F-l 1-011). July. Available at: http://
epa.gov/tio/download/remed/csm-life-cycle-fact-
sheet-final.pdf

EPA, 20 lib. Groundwater Road Map: Recommended Process
for Restoring Contaminated Groundwater at Superfund Sites.
(OSWER 9283.1-34). July. Available at: http://www.
epa.gov/superfund/health/conmedia/gwdocs/pdfs/
gwroadmapfinal.pdf

EPA, 201 Ic. An Approach to Evaluating the Progress  of
Natural Attenuation in Groundwater. (EPA 600/R-l 1/204).
December. Available at: http://nepis.epa.gov/Adobe/
PDF/PlOODPOE.pdf

EPA, 2012a. Assessing Protectiveness at Sites for  Vapor
Intrusion: Supplement to the "Comprehensive Five-Year Review
Guidance."  (OSWER Directive 9200.2-84). November.
Available at: http://www.epa.gov/superfund/cleanup/
pos tcon structi on/pdfs/VI_F YR_Gui dance-Fi-
nal-ll-14-12.pdf

EPA, 2012b. National Strategy to Expand Superfund Optimi-
^ation Practices from Site Assessment to Site Completion.
(OSWER Directive 9200.3-75). September. Available
at: http://www.epa.gov/oerrpage/superfund/cleanup/
postconstruction/2012strategy.pdf

EPA, 2012c. A  Citizen's Guide to Soil Vapor Extraction
and Air Sparging. (EPA  5542-F-12-018). September.
Available at: http://www.clu-in.org/download/citi2ens/
citsve.pdf

EPA, 2012d. A Citizen's Guide to Bioremediation.  (EPA
542-F-12-003). September. Available at: http://www.
clu-in.org/download/citizens/bioremediation.pdf

EPA, 2012e. A Citizen's Guide to Capping. (EPA 542-F-12-
004). September. Available at: http://www.clu-in.org/
download /citizens /a_citJ2ens_guide_to_capping.pdf

EPA, 2012E A Citizen's Guide to Permeable Reactive 'Barriers.
(EPA 542-F-12-015).  September. Available at: http://
www.clu-in.org/download /Citizens /a_citizens_guide_
to_permeable_reactive_barriers.pdf
EPA, 2014.  Groundwater Remedy  Completion Strategy
(OSWER Directive 9200.2-144).  May. Available at:
http://www.epa.gov/superfund/health/conmedia/gwdocs/
pdfs/EPA_Groun dwater_Remedy_Completion.pdf

ESTCP (Environmental Security Testing and Certifica-
tion Program), 2007. Frequently Asked Questions Regarding
Management of Chlorinated Solvents in Soils and Groundwater.
July. Available at: http://serdp-estcp.org/content/
download/5045/72039/file/ER-0530-FAQ.pdf

FRTR (Federal Remediation Technologies  Roundta-
ble), 2002. Evaluation of Permeable Reactive Carrier Perfor-
mance. Available at: http://www.clu-in.org/download/
rtdf72-prbperformance_web.pdf

ITRC (Interstate Technology & Regulatory Council), 2004.
Remediation Process Optimisation: Identifying Opportunities for
Enhanced and More Efficient Site Remediation. RPO-1. ITRC,
Washington, DC September. Available at: http://www.
itrcweb.org/Guidance/GetDocumentPdocumentID=78

NRC (National Research Council), 20\2. Alternatives for
Managing the Nation's Complex Contaminated Groundwater
Sites. National Academies Press. Available at: http://
www.nap.edu/catalog.php?record_id= 14668

13. ACKNOWLEDGMENTS

A document of this scope involved significant participa-
tion from a number of people, such that any omission
in these acknowledgments is purely unintentional. The
Ground Water Forum thanks all of the participants
involved in the development of this document. We
acknowledge the active participation and valuable input
from our workgroup co-leads, Marcia Knadle of EPA
(Region 10, retired) and Kay Wischkaemper (Region 4,
retired), and workgroup members Jean Choi (Region 1),
Mike Scorca and Kevin Willis (Region 2), Vince Malott
(Region 6), Lisa Gotto and Dan Nicoski  (Region 7),
Rene Fuentes and Jonathan Williams (Region 10), Mike
Bailey (U.S. Army Corps of Engineers), and Barb Vetort
(Michigan Department of  Environmental Quality).
Other contributors and reviewers included Matt Charsky
(retired), Anne Dailey, Linda Fiedler, Kate Garufi, Ed
Gilbert, Tracy Hopkins, Mike Hurd (retired), and Steve
Ridenour  (EPA Office of  Superfund Remediation and
Technology Innovation).
 Ground Water Technical Considerations during the Five-Year Review Process
                  Ground Water Forum Issue Paper 9

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14. NOTICE AND DISCLAIMER

The Ground Water Forum, a component of the U.S.
EPA Superfund Technical Support Project, has authored
this issue paper. Information and opinions  contained
in this document were developed by the Ground Water
Forum,  are technical in  nature, and represent profes-
sional opinions of the participants. This information
has not received formal EPA peer review and does not
necessarily reflect the views of EPA or other participat-
ing organizations, and no  official endorsement should be
            inferred. The information is not intended, nor can it be
            relied upon, to create any rights enforceable by any party
            in litigation with the United States or any other party.
            Use or mention of trade names  does not constitute an
            endorsement or recommendation for use.

            A PDF version of Ground Water Forum Issue Paper:
            Groundwater Technical Considerations during the Five-Year
            Review Process is available to view or download at http://
            www.epa.gov/superfund and http://www.cluin.org.
10 Ground Water Forum Issue Paper
3 Water Technical Considerations during the Five-Year Review Process

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15. TABLES
Table 1. Common Technical Questions at Groundwater Sites
                                 Review Needs
                                                        Questions
 GSM validation
Review documentation of the site
geological and hydrological charac-
terization. This includes the RI/
FS reports, along with any supple-
mental information that was used
to develop the findings presented in
the  ROD and any characterization
performed during RD/RA.
Considering the current state of the practice, have
the site characterization efforts conducted to date
been sufficient?
Is the CSM adequate and up to date?
Has the three-dimensional  nature and extent of
contamination been fully delineated?
Has the potential for dense non-aqueous phase liquid
(DNAPL) source been adequately considered, includ-
ing the potential for DNAPL movement through
aquitards (Bradbury, et al. 2006)?
Might other contaminants  be present that were
unknown then or are of greater concern today?
Were  contaminant  migration pathways to sediment
and surface water fully characterized?
Has the potential for vapor intrusion been evaluated?
 Long-term monitor-
 ing program
 (adequacy of
 monitoring well
 network and data
 quality and quantity)
Review the adequacy of the
monitoring well network, including
construction details of the existing
monitoring wells to develop a
technical evaluation of the monitor-
ing well design and construction.
This may require review of well
logs.

Review the sampling and analysis
plan, including standard operat-
ing procedures, and the quality
assurance project plan (QAPP). This
review may involve both a hydroge-
ologist and a quality assurance
expert. Field oversight of  a sampling
event may be advisable.
Have the wells been properly placed, both horizontally
and vertically, to define the plume(s), to characterize
concentrations throughout the aquifer thickness and
to track the rate and extent of plume migration?
Are the screen intervals and lengths appropriate?
Are additional wells needed in response to changes
in plume configuration?
If there is a pump-and-treat remedy, are wells appro-
priately located to provide information for a capture
zone analysis?
Are  monitoring wells accessible to  EPA and its
contractors yet protected from  likely avenues of
accidental damage or  vandalism? (Wells with flush
mount completions are particularly vulnerable to
burial under gravel or pavement.)
Are appropriate chemical constituents being analyzed
at appropriate  quantitation limits, including parent/
daughter (biodegradation) products,  indicators of
change in geochemical conditions, as well as the site's
chemicals of concern?
If new chemicals of potential concern have been
identified, have they been included in the  analytical
program?
Are sampling protocols appropriate and up to date?
Are monitoring wells being sampled at an appropri-
ate frequency to establish  and maintain statistically
robust contaminant trends at appropriate  locations
(e.g., source wells, plume centerline wells, boundary
wells, and sentinel wells)?
Ground Water Technical Considerations during the Five-Year Review Process
                                                    Ground Water Forum Issue Paper 11

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Table 1. Common Technical Questions at Groundwater Sites (continued)
        Topic
 Monitoring well
 integrity
                                Review Needs
                      Assess the integrity of the site
                      monitoring wells. Parts of this
                      evaluation should be performed
                      in the office by reviewing the
                      sampling records to determine if
                      well integrity has been degrading,
                      and conditions  should be confirmed
                      during the field visit.
                       Assess the integrity of any site
                       pumping wells, re-injection wells, or
                       re-infiltration galleries.
                 Questions
Are the monitoring wells functioning as designed and
constructed?
Is there a plan for periodic assessment and mainte-
nance?
Is total  depth measured periodically to check for
sedimentation when water levels are measured?
Are there damaged, out-of-date, or poorly constructed
wells (e.g., those with inappropriately long screens)
that should be properly decommissioned?
Groundwater
extraction and
injection system
Are all the wells functioning? If not, what are the
ramifications for overall plume capture?
Is biofouling or premature pump failure an issue?
Are water levels unexpectedly low in pumping wells
or high in re-injection wells?
Are groundwater levels around infiltration galleries
consistent with historical operating conditions?
 Revised and new
 information
                      Check for changed or new informa-
                      tion regarding remedy assumptions.
                      Check whether site conditions have
                      changed in any way that could alter
                      groundwater flow conditions.
Have there been changes  in contaminant toxicity,
cleanup levels, or groundwater standards?
Are there newly identified contaminants of potential
concern at the site?
Has enough analytical information been collected to
evaluate these questions?
Is there new information to indicate that RAOs may
not be achievable with the current remedy?
Are there new  scientific insights that call a  critical
element of  the CSM into question?
At or near  the  site, are there new features (ponds,
public supply wells, newly paved or unpaved surfaces,
etc.) which may have affected groundwater recharge
or discharge  or otherwise altered the  subsurface
hydrogeology (e.g., groundwater flow directions  or
velocity)?
Have there  been land use changes that may lead to
exposures in a new population?
 Institutional controls
 (ICs)
                      Review the adequacy of and compli-
                      ance with implemented groundwater
                      ICs for the site.
Has land use or zoning changed?
Have any new water wells been installed in or near
the plume area?
Has  there been new  construction above  shallow
plumes of volatile organic compounds (VOCs)?
Have such changes compromised the effectiveness
of groundwater remedies and/or  presented new
exposures (e.g., vapor intrusion) that did not exist at
the time of remedy selection?
12 Ground Water Forum Issue Paper
                                         3 Water Technical Considerations during the Five-Year Review Process

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Table 1.  Common Technical Questions at Groundwater Sites (continued)
        Topic
 Environmental
 indicators
          Review Needs
Check to ensure consistency with
current understanding of site
conditions, including exposure
scenarios as confirmed during the
field visit.
                 Questions
Are the indicators  for "human  exposure under
control" and "migration of contaminated ground-
water under control" still valid?
 Remedy optimization
Evaluate whether contaminant
concentration data may indicate a
need for remediation system evalua-
tion (EPA, 2000) or LTMO (EPA.
2005).
Is the groundwater remedy effective (and cost effec-
tive)
For a pump-and-treat remedy, has a capture zone
analysis been conducted recently?
Do the data suggest that there may be a contaminant
source that has not been controlled?
If contaminant levels have "tailed" and the plume is
stable,  could monitored natural attenuation (MNA)
play a larger role in the groundwater remedy?
What are the life-cycle energy costs?
Could  sampling frequencies be reduced without a
significant loss in ability to track contaminant trends?
Are there any redundant monitoring wells?
Ground Water Technical Considerations during the Five-Year Review Process
                                                   Ground Water Forum Issue Paper  13

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Table 2. Remedial Performance Technical Elements to Evaluate
 Groundwater Remediation    Common Groundwater Elements t
   Description/Objectives                   c"~l1 "-*~
                                                Internet Resources
 Extraction Systems
 Remove contaminated fluids, treat, and discharge (soil gas or water) to contain contamination and/or to restore
 groundwater to beneficial use.
 Groundwater Pump and
 Treat fP&Tl
 Actively extract contaminated
 groundwater and treat
  Have extraction systems captured the
  entire plume length, width and depth (or
  the entire target zone if the goal is partial
  capture)?
  Has the source area been remediated or
  controlled successfully?
  Did the site have light or dense non-aque-
  ous phase liquids (LNAPL or DNAPL)
  besides the dissolved plume, and were
  these remediated?
  Is the system  meant to  deal with a
  dissolved plume or also with a NAPL
  source?
  Is any reintroduced treated water having
  the anticipated effect on site hydraulics or
  on the plume?
  Does the  treatment system remove all
  the contaminants in  the groundwater,
  including newly identified contaminants
  of concern?
A Systematic Approach for Evaluation of
Capture Zones at Pump and Treat Systems.
(EPA. 2008a).
 Soil Vapor Extraction (SVE)
 Actively remove contam-
 inated soil vapor and
 discharge, or treat and
 discharge.
  Was the SVE checked for meeting goals
  of remedial action objectives after it was
  shut down?
  Has there been a rebound of ground-wa-
  ter  concentrations since the SVE was
  turned off?
  SVE only addresses unsaturated zone
  (vadose) contamination. If implemented
  to protect groundwater, might additional
  sources exist in the saturated zone (below
  the water table)?
Soil Vapor Extraction focus area:
http://www.clu-in.org/techfocus/
default.focus/sec/Soil  Vapor
Extraction /cat /Overview/
 In-Situ Treatment
 Contaminants are actively or passively degraded or immobilized in the aquifer.
 Air Sparging
 Introduce air to vadose zone
 and groundwater to enhance
 removal from soils and
 groundwater. Coupled with
 soil vapor extraction.
Same as for SVE
A Citizen's Guide to Soil Vapor Extraction and
Air Sparging. (EPA. 2012c).
14 Ground Water Forum Issue Paper
           3 Water Technical Considerations during the Five-Year Review Process

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Table 2. Remedial Performance Technical Elements to Evaluate (continued)
 Groundwater Remediation   Common Groundwater Elements t
    Description/Objectives                   Evaluate
 Bioremediation
 Chemicals of concern are
 remediated by bacteria. The
 environment for increased
 biologic activity can be
 enhanced by injecting carbon
 sources (oils, sugars) and/or
 bacteria.
Is contaminant breakdown complete or
stuck at toxic intermediate forms?
Is breakdown fast enough?
Can injected amendments reach the entire
contaminated target zone?
Can necessary conditions be maintained
naturally?
                                               Internet Resources
A Citizen s Guide to Bioremediation. (EPA.
2012d).
 Phvtoremediation
 Chemicals of concern are
 taken up by the root zones of
 plants (e.g., poplars and hyper-ac-
 cumulating ferns) and destroyed
 through metabolization.
Are the plants healthy?
Do the roots  extend deep enough to
intercept a significant portion of the
plume mass?
Phytotechnologies focus area: http:
www.clu-in.org/techfocus /defaull
focus/sec/Phytotechnologies/cat/
Overview/
 Monitored Natural Attenua-
 tion
 Monitor and confirm that
 natural processes are remedi-
 ating plumes in an acceptable
 timeframe that would be
 comparable to active remedi-
 ation.
Evaluate whether natural attenuation is
progressing as expected, if not annually,
at least for each FYR. Use concentra-
tion trend analyses and possibly plume
moment analysis. If progress is inade-
quate, a more active remedy may be
required to meet cleanup objectives.
May also need to evaluate whether
additional untreated or uncontained
sources exist.
In some cases MNA cannot be sustained
over time; in others, site conditions may
not have been as favorable as was believed
when MNA was chosen.
There may be breakdown products which
are as  much of a problem as the original
contaminant.
Geochemical conditions may vary season-
ally in shallow aquifers; The recommen-
dation is that monitoring plans account
for this temporal effect on contaminant
solubility's and associated transport.
Technical Protocol for Evaluating Natural
Attenuation of Chlorinated Solvents in
Ground Water. (EPA. 1998a).
Monitored Natural Attenuation of Inorganic
Contaminants in Ground Water,  Volume
1: Technical Basis for Assessment. (EPA.
2Q07a).
Monitored Natural Attenuation of Inorganic
Contaminants in Ground Water,  Volume
2: Assessment for Non-Radionuclides
Including Arsenic, Cadmium, Chromium,
Copper,Lead, Nickel, Nitrate, Perchlorate,
and Selenium. (EPA. 2007b).
An Approach for Evaluating the Progress
of Natural Attenuation in Groundwater.
(EPA. 2011c).
Ground Water Technical Considerations during the Five-Year Review Process
                                         Ground Water Forum Issue Paper 15

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Table 2. Remedial Performance Technical Elements to Evaluate (continued)
 Groundwater Remediation   Common Groundwater Elements t
   Description/Objectives                  c.,~i..~*~
 Source Zone Remediation
 Sources are identified, delineated, and removed or destroyed. "How clean is clean?" is a major question. RAOs
 may be based on percentage of source mass destroyed or removed, but that is very difficult to determine.
 Reductions in remaining groundwater concentrations, and/or reductions in mass flux to the groundwater plume
 may be easier objectives to demonstrate. A treatment train approach may be most effective.
 LNAPL Sources
 NAPL sources are only
 slightly soluble in water and
 are persistent sources to
 groundwater contamination
 that are difficult to remove.
 LNAPLs are easier to find
 because they float on the
 water table.
Were LNAPLs found or suspected at site?
Were LNAPLs removed or just contained
at site?
Have  concentrations rebounded at site
due to LNAPLs?
Do multiple LNAPLs  have different
solubilities and thus different transport
potentials?
Ground Water Issue: Light Non-Aqueous
Phase Uquids. fEPA. 1995V
 DNAPL Sources
 DNAPLs are difficult to
 locate because they are
 heavier than water and sink
 through aquifers, potentially
 until they reach a much less
 permeable layer. In addition,
 they may flow in relatively
 narrow flowpaths, which are
 easily missed, rather than
 create a broader pool. They
 may also pool or flow down
 dip slope regardless of the
 groundwater flow direction.
Were DNAPLs found or suspected at
site (groundwater concentrations >  1%
to 10% of DNAPL solubility)?
Were DNAPLs monitored at the site?
Were wells correctly screened to detect
DNAPLs?
Were DNAPLs removed or just contained
at site?
Have concentrations rebounded at  site
due to DNAPLs?
DNAPL Focus Area: wwwcluin.org/
dnapl

Ground Water Issue: Assessment and
Delineation of DNAPL Source Zones at
Hazardous Waste Sites. (EPA. 2009aY

Frequently Asked Questions Regarding
Management of  Chlorinated Solvents in Soils
    Groundwater (ESTCP. 2007V
 Excavation
 Sources are dug up and
 treated ex situ or disposed
 elsewhere.
Could the entire source be excavated i.e.,
Was there contamination deeper than
excavation could reach, or was horizontal
excavation constrained by infrastructure?
If the water table varies seasonally, was
excavation performed when the water
table was low?
Were excavations backfilled with hydro-
geologically comparable soil to minimize
changes in site hydrology?
Was monitoring sufficient to evaluate
short-term and long-term effects on
downgradient groundwater?
DNAPL Focus Area: Source Area
Excavation: http: //www:clu-in.org/
contaminantfocus/default.focus/sec/
Dense Nonaqueous Phase Liquids
(DNAPLs)/cat/Treatment  Technolo-
gies/p/10
16 Ground Water Forum Issue Paper
         3 Water Technical Considerations during the Five-Year Review Process

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Table 2. Remedial Performance Technical Elements to Evaluate (continued)
 Groundwater Remediation   Common Groundwater Elements to
   Description/Objectives                   Evaluate
 Thermal Remediation
                                              Internet Resources
 Thermal energy (via steam or
 electricity) is applied to soil
 to remove and/or destroy
 contaminants, either in situ or
 ex situ (applied to excavated
 material at the surface).
 Contaminants are recovered
 from the vapor phase (or
 vapor and liquid phases,
 in the case of steam)  and
 treated.
Is groundwater flow adequately controlled
to maintain target temperatures through-
out the treatment area?
Can the system be modified to increase
removal efficiency?
If the energy is injected via steam, did the
energy reach the entire source volume?
After shutdown, have concentrations
rebounded?
Ground Water Issue: How Heat Can
Enhance In-situ Soil and Aquifer ^medi-
ation: Important Chemical Properties and
Guidance on Choosing the Appropriate
Technique. fEPA. 1997V

Ground Water Issue: Steam Injection for Soil
and Aquifer Remediation. (EPA. 1998b).

In Situ Thermal Treatment focus
area: http://www.clu-in.org/techfo-
cus/default, focus/sec/Thermal
                                     Treatment%3A In  Situ/cat/
                                     Overview/
 In Situ Chemical Treatment
 Chemicals are injected
 into a contaminated area
 to remove or destroy the
 environment-contaminat-
 ing chemicals of concern,
 usually by manipulating redox
 conditions.
Can the chemical conditions required to
treat source materials be maintained long
enough for complete treatment?
Did injected food or bacteria reach the
entire source volume?
Has the chemical treatment been success-
ful? Has the contamination rebound-
ed (come back after being reduced/
removed)?
In Situ Chemical Reduction focus area:
http://www.clu-in.org/techfocus/
default.focus/sec/In  Situ Chemical
Reduction/cat/Qverview/
 Bioremediation
 Chemicals of concern are
 remediated by bacteria. This
 process can be enhanced by
 enhancing the environment
 for increased biologic activity.
Has  the bioreaction produced  other
contaminants of concern? Is the remedial
system continuing to operate efficiently?
Did injected food or bacteria reach the
entire source volume?
Bioremediation focus area:
http://www.clu-in.org/techfocus/
default.focus/sec/Bioremediation/cat/
Overview/
 Containment Barriers
 Containment barriers isolate contaminant sources with engineered structures. The source mass remains in place
 and the integrity of the remedy is limited by the life of the engineered structure. The potential for leakage in both
 horizontal and vertical directions should be considered. Long-term monitoring to detect releases through contain-
 ment failure must continue for as long as the source exists, even after the plume outside the containment unit is
 cleaned up.
 Surface Engineered Barriers
 Surface engineered barriers
 (caps) reduce infiltration and
 limit direct exposure.
Are "chemicals of concern" for a site
being observed in downgradient monitor-
ing wells at stable or increasing concen-
trations?
Is the cap continuing to allow runoff, or
has differential settlement caused ponding
on the surface?
Has large vegetation become established?
Are animals compromising the cap by
digging or burrowing?
A Citizen s Guide to Capping (EPA.
2012e).
Ground Water Technical Considerations during the Five-Year Review Process
                                         Ground Water Forum Issue Paper 17

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Table 2. Remedial Performance Technical Elements to Evaluate (continued)
 Groundwater Remediation   Common Groundwater Elements to
   Description/Objectives                  Evaluate
 Subsurface Engineered Barriers
                                              Internet Resources
 Subsurface engineered
 barriers (impermeable walls)
 isolate hazardous wastes from
 adjacent groundwater and
 surface water.
If the containment surrounds a source
area, are water levels within the contain-
ment area unaffected by external water
level changes?
Are  "contaminants of concern" for a
site  being observed  in downgradient
monitoring wells at stable or increasing
concentrations?
Can contamination flow around or under
the barrier?
Evaluation of Subsurface Engineered
Carriers at Waste Sites (EPA. 1998c).
 Permeable Reactive Barriers
 Reactive barriers are designed
 to treat the entire plume as it
 flows through, so understand-
 ing and managing groundwa-
 ter flow is critical. Reaction
 products  may gradually
 reduce the permeability of
 the barrier and cause the
 reactants  to become depleted
 or unavailable.
Performance monitoring is critically
important for PRBs. Are downgradient
water concentrations as clean as expected?
If not, the wall may not be thick enough
to completely treat the plume, especially
if the plume is more stratified and has a
higher range of concentrations than was
anticipated at design.
Can it be demonstrated from  sampling
and water level data that contamination
is not flowing around or  beneath the
barrier? Is the wall still permeable?  If
not, groundwater may be diverted around
or under the wall, especially if it was not
properly oriented relative to (i.e., at right
angles to) the local groundwater flow
direction. PRB cementation or bio fouling
can occur surprisingly quickly.
^4 Citizen s Guide to Permeabk Reactive
Carriers (EPA. 2012f).
Evaluation of Permeable Reactive Barrier
Performance. (FRTR 2002V
18 Ground Water Forum Issue Paper
         3 Water Technical Considerations during the Five-Year Review Process

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Table 2. Remedial Performance Technical Elements to Evaluate (continued)
 Groundwater Remediation   Common Groundwater Elements t
   Description/Objectives                   c"~l1 "-*~
                                              Internet Resources
 Monitoring
 Monitoring is an integral element of all groundwater remedies, whether to evaluate the effects of a particular
 remedial action on nearby groundwater or to evaluate the response of site-wide groundwater plumes. It is also
 integral to the management of groundwater institutional controls.
 Long-Term Monitoring
 The long-term monitoring
 plan must provide adequate
 information to demonstrate
 effectiveness.
In general, are wells properly sampled
using an acceptable sampling procedure?
Are the QAPP and work plan up to date?
Are  plumes bounded on all sides  by
monitoring wells? If the plume may be
advancing, are  there enough sentinel
wells to evaluate plume  migration in a
timely fashion, including vertically if
appropriate?
Do sampling and water level measurement
frequency account for seasonal effects, if
present?
Are there enough wells within the plume
to evaluate progress toward RAOs? (e.g.,
If reduction in plume mass is an objective,
are there enough centerline wells to track
changes in  contaminant mass or plume
moments statistically?)
Have there been changes in groundwater
levels or gradients?  Increasing ground-
water levels can increase groundwater
contamination when contaminants that
had  been in the vadose zone are now
below the water table. Also, different
types of strata, such as gravelly layers, may
become saturated and allow contaminant
plumes to migrate much more quickly.
 Ground-Water Sampling Guidelines for
 Superfund and RCRA Project Managers.
 rEPA. 2002V

 Final RCRA Comprehensive Ground-Water
 Monitoring Evaluation (CME) Guidance
 Document. (EPA. 1986V

 Ground Water Sampling for Metals
 Analysis. (EPA. 1989V

 RCRA Ground Water Monitoring. Draft
 Technical Guidance. (EPA. 1992V

 Cleanups at Federal Facilities (EPA
 webpage with several good links):
 http://www.epa.gov/fedfac/
 documents/qualityassurance.htm#ufp-
 qapp
 Performance Monitoring
 The monitoring program
 at a site must be appropri-
 ately designed to assure that
 a specific remedial action
 functions as designed. Once a
 remedial action is determined
 to be functional, the
 long-term monitoring system
 replaces it.
Are the wells in the network sufficient
and properly placed, both to ensure that
groundwater flow is as expected (water
level measurements) and to ensure that
remedial actions were effective (contam-
inant reductions where desired) and that
they didn't spread contamination (no
unanticipated plume spread)?
Were the wells sampled frequently enough
to identify changes attributable to the
remedial action?
Performance Monitoring of MNA Remedies
for VQCs in Ground Water. (EPA.
2Q04a).
Methods for Monitoring P&T Performance
Parts 1 and 2. (EPA. 1994V
Ground Water Technical Considerations during the Five-Year Review Process
                                         Ground Water Forum Issue Paper  19

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Table 2. Remedial Performance Technical Elements to Evaluate (continued)
 Groundwater Remediation   Common Groundwater Elements to
    Description/Objectives                   "  '
                                              Internet Resources
 Optimization
 Remedy optimizations can yield significant operational cost savings and improve remedy effectiveness, either by
 increasing mass removal rates (thus reducing the length active remediation is required) or by ensuring that the
 right amount of sampling data is collected.
 Remedial Systems Evaluation /
 Remedial Process Optimization
 A remediation system may
 need to be evaluated for
 cost-efficiency and integrity
 after it operates for a while.
Have concentration  trends stopped
declining, or have they  rebounded?
Is the groundwater capture zone well
understood?
Is biofoulingin pumping wells impacting
extraction rates?
 Optimisation Strategies for Long-Term
 Ground Water Remedies. (EPA. 2007c).
 Remediation Process Optimisation: Identi-
fying Opportunities for Enhanced and More
 Efficient Site Remediation. RPO-1. (TTRC.
 2004^
 Superfund Reform Strategy Pump and Treat
 Optimisation: Questions and Answers.
 http: //www.clu-in.org/download/
                                                                     remed/hyopt/questionanswer2.pdf
                                                                      What Is Remediation Process Optimisation
                                                                      and How Can It Help Me Identify Opportu-
                                                                      nities for Enhanced and More Efficient Site
                                                                      Remediation? (EPA. 2004b)	
 Long-Term Monitoring
 Optimization
 Long-term monitoring can
 periodically be optimized
 both temporally to reduce the
 frequency of sampling and
 spatially to ensure that the
 spacing of wells is  sufficient
 to meet monitoring objectives
 while eliminating any
 redundant wells.
Is groundwater sampling still being
conducted at the same frequency (quarter-
ly or semiannually) in all wells?
Are there seasonal variations in contam-
inant concentrations or in water levels?
Wells which are no longer needed for
sampling may still be useful for water level
measurements.
Roadmap to Long-Term Monitoring Optimi-
sation. rEPA. 2005V
MAROS Overview: http://www.frtr.
gov/decisionsupport/DST Tools/
maros.htm (MAROS 2.2)
MAROS 3.0: http://old.gsi-net.com/en/
software/free-software/maros-30.html
20 Ground Water Forum Issue Paper
         3 Water Technical Considerations during the Five-Year Review Process

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16. FIGURES
Figure 1:  Hydrogeologic CSM Example Block Diagram
                  A

                 0.
Area of Former Solvent Tank
and Ongoing Source Controls
                      Target Monitoring Zones

                    1. Source area L	_l
                    2. Contaminated zones of highest
                      concentrations and mobility
                    3. Plume fringes exhibiting low
                      contaminant concentrations
                    4. Plume boundaries
                    5. Recalcitrant zone determined
                      from historical trends
                    6. Upgradient locations
                                            Legend

                                     Gravel,gravel-sand mixtures

                                     Medium to coarse-grained sand

                                     Fine-grained silty sand

                                     Bedrock

                                     Dissolved Plume
Source: Performance Monitoring of MNA Remedies for VOCs in Ground Water (EPA. 2004a)
Ground Water Technical Considerations during the Five-Year Review Process
                                                  Ground Water Forum Issue Paper 21

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Figure 2: Hydrogeologic CSM Example Cross Section
             NNE
                                                                                      ssw
                                                                                                    Legend
    Roza 3
                Conceptual diagram - not to scale
                                                                                                  Potential High
                                                                                                  Concentration Source
                                                                                                  (DNAPL residual or
                                                                                                  sorbed/diffused TCE mass)
                                                                                            TCE in water or soil gas
                                                                                                  10-100 ppb
                                                                                                  Observed
                                                                                                  Potential/
                                                                                                •  Inferred
                                                                                                  1-10 ppb
                                                                                                  Observed
                                                                                             CpGp Potential/
                                                                                              o ° Inferred
Source: EPA. 2008b. Interim Record of Decision, Moses Lake Wellfield Superfund Site, Moses Lake, Washington
22 Ground Water Forum Issue Paper
Water Technical Considerations during the Five-Year Review Process

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Figure 3: Groundwater/Surface Water CSM Example
                         Conceptual Site  Model
                                                                      \(MlUS|)herie
                                                                       Deposition
                                                            Rh'erbank
                                                 Imhistiiiil     Erosion
        I ^urreu

    I
                 tlvtt'liun lliro
                  C
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17. KEY TECHNICAL RESOURCES FOR FYRS AT
    GROUNDWATER SITES

Because web links tend to change over time, an attempt
has been made to include enough information about
each document to facilitate web searches.

17.1   General Groundwater References

EPA, 1990. Handbook: Ground Water - Volume 1: Ground
Water and Contamination. (EPA 625690016a). Available
at: http://www.epa.gov/ncepihom/

U.S. Geological Survey, 1998. Basic Ground-Water'Hydrology.
(Water Supply Paper 2220). Available at: http://pubs.
er.usgs.gov/usgspubs/wsp/wsp2220

17.2   EPA Five-Year Review Guidance

EPA, 2001. Comprehensive Five-Year Rem'ew Guidance. (EPA
540-R-01-007, OSWERNo. 9355.7-03B-P). Available at:
http://www.epa.gov/superfund/accomp/5year/index.htm

EPA, 2011.  Recommended Evaluation of Institutional
Controls: Supplement to the "Comprehensive Five-Year Review
Guidance." (OSWER Directive 9355.7-18, September).
Available at: http://www.epa.gov/superfund/cleanup/
postconstruction/641333.pdf

EPA, 2012. AssessingProtectiveness at Sites for Vaporlntrusion,
Supplement to the "Comprehensive Five-Year Review Guidance."
(OSWER Directive 9200.2-84, November). Available
at: http://www.epa.gov/superfund/cleanup/postcon-
struction/pdfs/VI FYR Guidance-Fmal-ll-14-12.pdf

17.3   Site Management Policy

EPA, 2008. Superfund Environmental Indicators Guidance:
Human  Exposure Revisions. (OSRTI). March. Available
at: http://www.epa.gov/superfund/accomp/ei/pdfs/
final_ei_guidance_march_2008.pdf

EPA, 2009. Summary of Key  Existing EPA CERCEA
Policies for Groundwater Restoration. (OWSER Directive
9283.1-33). June  2009. Available at:  http://www.
epa.gov/superfund/health/conmedia/gwdocs/
pdfs/9283 l-33.pdf

EPA, 2011. Environmental Cleanup 'Rest Management Practices:
Effective Use of the Project Eife Cycle Conceptual Site Model.
(EPA 542-F-l 1-011) July 2011. Available at: http://epa.
gov/tio/download/remed/csm-life-cycle-fact-sheet-
final.pdf
             EPA, 2011. Groundwater Road Map: Recommended Process
            for Restoring Contaminated Groundwater at Superfund Sites.
             (OSWER 9283.1-34). July 2011. Available at: http://
             www.epa.gov/superfund/health/conmedia/gwdocs/
             pdfs/gwroadmapfinal.pdf

             NRG (National Research Council), 2012. Alternatives-for
             Managing the Nation's Complex Contaminated Groundwater
             Sites. National Academies Press. Available at: http://www.
             nap.edu/catalog.php?record_id= 14668

             17.4  Remedy Optimization

             EPA, 2002. Pilot Project to Optimise Superfund-financedPump
             and Treat Systems: Summary Report and Lessons Learned.
             (EPA 542-R-02-008a-u). November 2002. Available
             at: http://www.clu-in.org/download/remed/rse/
             phase_ii_report.pdf

             EPA, 2004. Action Plan for Ground Water Remedy Optimisa-
             tion. (OSWER 9283.1-25). August. Available at: http://
             www.epa.gov/superfund/cleanup/postconstruction/
             action_plan.pdf

             EPA,  2004. ITRC (Interstate Technology &  Regulatory
             Council), 2004. Remediation Process Optimisation: Identifying
             Opportunities for Enhanced and More Efficient Site Remediation.
             RPO-1. Washington, DC September. Available at: http://
             www.itrcweb.org/GuidanceDocuments/RPO-l.pdf

             EPA, 2004. What Is Remediation Process Optimisation and
             How Can It Help Me  Identify Opportunities for Enhanced
             and More Efficient Site Remediation? Webinar sponsored
             by: Interstate Technology and Regulatory Council.
             September.  Archived  presentation available at: http://
             www.clu-in.org/conf/itrc/rpo_092804/

             EPA,  2007. A  Cost Comparison Framework for Use in
             Optimising Ground Water Pump and Treat Systems.  (EPA
             542-R-07-005).  Available  at: http://www.cluin.org/
             download/remed/hyopt/542r07005.pdf

             EPA, 2007. Optimisation  Strategies for Eong-Term Ground
             Water Remedies (with Particular Emphasis on Pump and Treat
             Systems). (EPA 542-R-07-007). Available at: http://www.
             cluin.org/download/remed/hyopt/542r07007.pdf

             EPA, 2012.  National Strategy to Expand Superfund Optimi-
             sation Practices from Site Assessment to Site Completion.
             (OSWER Directive 9200.3-75, September). Available
             at: http://www.epa.gov/oerrpage/superfund/cleanup/
             postconstruction/2012strategy.pdf
24 Ground Water Forum Issue Paper
3 Water Technical Considerations during the Five-Year Review Process

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17.5  Groundwater Monitoring and Monitoring
      Optimization

AFCEE, 2006. Monitoring and Remediation Optimisation
System (MAROS) User's Guide. March 2006 (in revision).
User's guide and software Version 2.2 available at:
http: //www. frtr.gov /decisionsupport/DST_Tools/
maros.htm

Version 3.0 available  at: http://old.gsi-net.com/en/
software/free-software/maros-30.html

EPA, 1991. Handbook of  Suggested Practices for the
Design and Installation of Ground-Water Monitoring Wells.
(EPA/600/4-89/034). Available  at: http://www.epa.
gov/oust/cat Avwelldct.pdf

EPA, 1996. Low-Flow (Minimal Drawdown) Ground-Water
Sampling Procedures. (EPA/540/S-95/504). April 1996.
Available at: http://www.epa.gov/superfund/remedy-
tech/tsp/download/Iwflw2a.pdf

EPA, 2002. Ground-Water Sampling Guidelines for Superfund
andRCRA Project Managers.  (EPA 542-S-02-001). May
2002. Available at:  http://www.epa.gov/superfund/
remedytech/tsp/download/gw_sampling_guide.pdf

EPA, 2004. Guidance for Monitoring at Hazardous Waste
Sites: Framework for Monitoring Plan Development and
Implementation. (OSWER  Directive No. 9355.4-28).
Available at: http://www.epa.gov/superfund/policy/
pdfs7dir9355.pdf

EPA, 2005. Roadmap to Long-Term Monitoring Optimisation.
(EPA 542-R-05-003, May 2005). Available at: http://
www.epa.gov/tio/download/char/542-r-05-003.pdf

17.6  Pump and Treat

EPA, 1994. Methods for Monitoring Pump-and-Treat Perfor-
mance. (EPA/600/R-94/123). Available at: http://www.
epa.gov/rlOearth/offices/oea/gwf/issue20.pdf

EPA, 2002. Elements for Effective Management  of Operat-
ing Pump and Treat Systems. (OSWER 9355.4-27FS-A).
Available at: http://www.cluin.org/download/remed/
rse/factsheet.pdf

EPA, 2005. Cost-Effective Design of Pump andTreatSystems.
(OSWER 9283.1-20FS, EPA 542-R-05-008). Available
at: http://www.cluin.org/download/remed/hyopt/
factsheets/cost-effective_design.pdf
EPA, 2005. Effective Contracting Approaches for Operating
Pump and Treat Systems.  (OSWER 9283.1-21FS, EPA
542-R-05-009). Available at: http://www.clum.org/
download/remed/hyopt/factsheets/contracting.pdf

EPA, 2005. O&M  Report Template for Ground Water
Remedies (With Emphasis on  Pump and Treat Systems).
(OSWER 9283.1-22FS, EPA 542-R-05-010). Available
at: http://www.epa.gov/superfund/action/postcon-
struction/omtemplate.pdf

EPA, 2008. A Systematic ApproachforEvaluation of Capture
Zones at Pump and Treat Systems. (EPA/600/R-08/003).
Available at:  http://cfpub.epa.gov/si/si_public_
record  Report.cfm?dirEntryId = 1 87788&C-
FID = 185702309&CFTOKEN=43140093&)session-
id=86304823e89c24cfd2d26467575723747969

17.7   Monitored Natural Attenuation

EPA, 1998. Technical Protocol for Evaluating Natural
Attenuation of Chlorinated Solvents in Ground  Water.
(EPA/600/R-98/128). Available at: http://www.epa.
gov/tio/download/remed/pro tocol.pdf

EPA, 1999. Use  of Monitored Natural Attenuation  at
Superfund, RCRA Corrective Action, and Underground Storage
Tank Sites. (EPA/540/R-99/009, OSWER 9200.4-17P).
Available at:  http: / /www.epa.gov/OUST/directiv /
d9200417.htm

EPA, 2004. Performance Monitoring of MNA Remedies for
VOCsm GroundWater. (EPA/600/R-04/027). Available
at: http://nepis.epa.gov/Adobe/PDF/10004FKY.pdf

EPA, 2011. An Approach  to Evaluating the Progress of
Natural Attenuation in Groundwater. (EPA 600/R-11/204).
December 2011. Available at: http://nepis.epa.gov/
Adobe/PDF/PlOODPOE.pdf

17.8  Vapor Intrustion

EPA, 2002. OSWER Draft Guidance for Evaluating the
Vapor Intrusion to Indoor Air Pathway from Groundwater
and Soils (Subsurface Vapor Intrusion Guidance). (EPA
530-D-02-004). Available at: http://epa.gov/osw/
hazard/correctiveaction/eis/vapor.htm
 Ground Water Technical Considerations during the Five-Year Review Process
                  Ground Water Forum Issue Paper 25

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EPA, 2012. A Citizen's Guide to Soil Vapor Extraction
and Air Sparging. (OSWER 542-F-12-018). Available at:
http://www.clu-in.org/download/citizens/a_citizens_
guide_to_soil_vapor_extraction_and_air_sparging.pdf

17.9   Groundwater/Surface Water Interactions

EPA, 2000. Proceedings of the Ground-Water/Surface-Wa-
ter Interactions  Workshop.  (EPA/524/R-00/007). July.
Available at: http://www.epa.gov/superfund/remedy-
tech /tsp /download /gwsw 7gwsw_partl.pdf

http://www.epa.gov/superfund/remedytech/tsp/
download/gwsw/ gwsw_part2.pdf (Poster Session
Abstracts)

http://www.epa.gov/superfund/remedytech/tsp/
download7gwsw7gwsw_part3.pdf (Appendices)

EPA, 2008. ECO Update/Ground WaterForum Issue Paper:
Evaluating Ground-Water/ Surf ace-Water Transition Zones
in Ecological Risk Assessments. (EPA 540-R-06-42). July.
Available at: http://www.epa.gov/oswer/riskassess-
ment/ecoup/pdf 7eco_update_08.pdf

U.S. Geological Survey, 1998. Ground Water and Surface
Water; a Single Resource. Circular  1139. Washington:
Government Printing Office. 1998. Available at: http://
pubs.usgs.gov/circ/circll39/

17.10  Alternate Concentration Limits

EPA, 2005.  Alternate Concentration Eimits (ACE's) in
Superfund Cleanups. (OSWER Directive 9200.4-39).
Available at: http://www.epa.gov/superfund/health/
conmedia/gwdocs/acls.htm

17.11  Contaminated Sediment

EPA, 2005. Contaminated SedimentRemediation Guidance for
Hazardous Waste Site.  (EPA-540-R-05-012). December.
Available at: http://www.epa.gov/superfund/health/
conmedia/sediment /guidance, htm

17.12  Closeout of Groundwater Cleanups

EPA, 1992. Methods for Evaluating the Attainment of Cleanup
Standards, Vol. 2: Ground Water. (EPA/230-R-92-014).
Available at: http://www.epa.gov/superfund/resources/
remedy /pdf/230r-92014-s.pdf
            EPA, 2013. Guidance for Evaluating Completion of Ground-
            water Restoration Remedial Actions.  (OSWER  9355.0-
            129). November. Available at: http://www.epa.gov/
            superfund/health/conmedia/gwdocs/pdfs/Groundwa-
            terAttainmentPolicy-finalsigned-ll%2025%202013.pdf

            EPA, 2014. Groundwater Remedy  Completion Strategy.
            (OSWER Directive  9200.2-144). May.  Available at:
            http://www.epa.gov/superfund/health/conmedia/gwdocs/
            pdfs/EPA_Groundwa ter_Remedy_Completion.pdf

            EPA, 2014.  Groundwater Statistics Tool (OSTRTI).
            August. Available at:  http://www.epa.gov/superfund/
            health/conmedia/gwdocs/download/GW_Stats_
            Tool 08112014.final.xlsm

            EPA, 2014. Recommended ApproachforEvaluating Completion
            of Groundwater Restoration Remedial Actions at a Monitoring
            Well. (OSWER 9283.1-44). August. Available at: http://
            www.epa.gov/superfund/health/conmedia/gwdocs/
            pdfs /GWcompletion-recommendedapproach-fi-
            nal-8.4.2014.pdf

            17.13 RCRA Groundwater Guidance

            EPA, 1986. Final RCRA Comprehensive Ground-Wa-
            ter Monitoring Evaluation (CME)  Guidance Document.
            December. Available at: http://www2.epa.gov/sites/
            production /files /2013-10 /documents /frcracmed-
            oc-rpt.pdf

            EPA, 1988.  Operation and Maintenance Inspection Guide
            (RCRA  Ground-Water Monitoring Systems), Final. March.
            Available at: http://www2.epa.gov/sites/production/
            files/documents/rcrainspecguid-rpt.pdf

            EPA, 1992. RCRA Ground-WaterMonitoring.FJraftTechni-
            cal Guidance. November. Available at: http://www.epa.
            gov/region09/qa/pdfs/rcra_gwm92.pdf

            EPA, 2004. Handbook of Groundwater Protection
            and  Cleanup Policies for RCRA Corrective  Action.
            (EPA530-R-04-030). Available at: http://www.epa.gov/
            osw/hazard/correctiveaction/resources/guidance/
            pdfs/gwhb041404.pdf
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17.14 Useful Websites

EPA's Five-Year Reviews web page (links to guidance,
supplements, fact sheets,  reports to Congress, etc.)
http://www.epa.gov/superfund/fiveyearreview/

EPA's Technical Support Project Ground Water Forum
http://www.epa.gov/superfund/remedytech/tsp/issue.
htm#GWF

Topics Include:

• Groundwater Sample Preservation and In Situ Chemical
  Oxidation Sites
• Evaluating Ground-Water/Surface-Water Transition
  Zones in Ecological Risk  Assessments
• Fingerprint Analysis of Contaminant Data
• Phytoremediation of Contaminated Soil and Ground
  Water at Hazardous Waste Sites
• Steam Injection for Soil And Aquifer Remediation
• How Heat Can Enhance  In-Situ Soil and Aquifer Re-
  mediation
• Natural Attenuation of Hexavalent Chromium in
  Groundwater and Soils

• Suggested Operating Procedures for Aquifer Pumping
  Tests

• Chemical Enhancements to Pump-and-Treat Remedi-
  ation

• In-Situ Bioremediation of Contaminated Ground Water

• Groundwater Sampling Guidelines

CLU-IN: EPA's Hazardous Waste Cleanup Information
http: / /www.clu-in.org/.  The DNAPL Contaminant
Focus Area on CLU-IN has over a thousand references:
http://www.clu-in.org/dnapl

FRTR: Federal Remediation Technologies Roundtable
http: / /www. frtr.gov/

ITRC: Interstate Technology and Regulatory Council
http://www.itrc.web.org
Ground Water Technical Considerations during the Five-Year Review Process
                  Ground Water Forum Issue Paper 27

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