FREQUENTLY ASKED QUESTIONS DRAFT Groundwater Remedy Completion Strategy What is the draft Groundwater Remedy Completion Strategy? The draft Groundwater Remedy Completion Strategy presents a recommended framework for evaluating Superfund groundwater remedy performance and decision making to help facilitate achievement of remedial action objectives and associated cleanup levels. The guidance addresses a number of issues, including the use of updated conceptual site models, performance metrics and data derived from site-specific remedy evaluations. During Superfund cleanups, EPA works to protect groundwater, a precious and finite resource, in coordination with many stakeholders, including the Agency's state, tribal and local counterparts. To that end, EPA will be seeking stakeholder input on the draft Strategy. The draft strategy recommends site-specific metrics to evaluate progress and encourages re-evaluation of site cleanup strategies if cleanup progress is not reasonable. The recommended strategy does NOT: • Alter the Agency approach for setting remedial objectives or cleanup levels • Change existing guidance or policy • Address groundwater classifications or groundwater use designations • Request state/tribes alter existing groundwater classification or use. Why is EPA issuing this draft guidance document now? Groundwater remediation is a component of more than 90% of Superfund sites where a remedy has been selected. Many groundwater actions are making progress towards achieving their associated RAOs and cleanup levels, but it can take decades to achieve completion. To pay for EPA's portion of ongoing long-term response actions (LTRA), EPA currently obligates approximately $50 million/year. Following LTRA, states are responsible for 100% of the ongoing operational costs of Fund-lead restoration actions. At PRP-lead and federal facility-lead sites, the PRPs are responsible for the full cost of groundwater response actions. Collectively, federal agencies, states and responsible parties spend hundreds of millions of dollars each year to address contaminated groundwater. The draft Groundwater Remedy Completion Strategy is intended to help focus resources toward the efficient and effective completion of groundwater remedies that ensure protection of human health and the environment. When finalized, will the Strategy change existing guidance, policy or regulation? When final, the Groundwater Remedy Completion Strategy will NOT change existing guidance, policy or regulation. This guidance is designed to help promote a consistent national approach for implementing groundwater remedies to completion. It does not, however, substitute for CERCLA or EPA's regulations, nor is it a regulation itself. This guidance is designed to help promote a consistent national approach for implementing groundwater remedies to completion. It does not, however, substitute for CERCLA or EPA's regulations, nor is it a regulation itself. EPA, state, tribal and local decision makers retain the discretion to adopt approaches on a case-by-case basis that differ from this guidance where appropriate. ------- Does the strategy alter EPA's approach for setting remedial objectives or cleanup levels? The draft Strategy does NOT alter the Agency approach for setting remedial objectives or cleanup levels. Does the groundwater completion strategy approach make sense in tight budget times? Developing a groundwater completion strategy for a specific site may be especially helpful when budget resources are tight. Development of a site-specific groundwater completion strategy can help a site team focus the Agency's limited resources on gathering the most specific, relevant data and other information that is useful to inform site decision making. While a modest level of effort and funds may be needed to create and maintain the data used to evaluate a remedy-specific strategy, an increased focus on gathering the specific data that best supports cleanup decisions generally is expected to improve cost-efficiency. When should a site-specific remedy completion strategy developed and how should it be documented? It is recommended that the completion strategy be developed as early as possible in the remedy selection and implementation process. Depending on the stage of cleanup when the strategy is first developed, it may be described in one or more site documents. As appropriate, the strategy may be described conceptually as part of a remedy decision document (e.g., ROD, ROD Amendment, Explanation of Significant Differences [ESD]). Development of the strategy as a component of the remedy design phase can help lay the foundation for effective remedy implementation. The strategy also may be described in more detail in the site Operations and Maintenance Plan, monitoring reports and the Five-Year Review. A stand alone document may also be appropriate for describing a completion strategy. Is a site-specific groundwater remedy completion strategy potentially applicable to all Superfund sites with groundwater contamination? EPA recommends that a completion strategy be developed for all Superfund Fund-lead, potentially responsible party (PRP)-lead and federal facility-lead groundwater remedies. The recommended approach generally should be useful throughout all phases of the cleanup - including remedy selection, remedial design/remedial action, long-term remedial action and operation and maintenance. Are state or tribal groundwater classifications or groundwater use designations changed by the strategy? This guidance does not address groundwater classifications or groundwater use designations, and should not be used to request states or tribes to address that issue. Where can I obtain a copy of the draft document? The draft Strategy, a fact sheet and other related materials are available at: http://epa.gov/superfund/gwcompletionstrategy/ How can I provide input on this draft document? Please send input via email to gwcompletionstrategy@epa.gov by December 20, 2013. ------- |