EPA Releases Draft Groundwater Remedy Completion Strategy
By Kate E. Beatty, Attorney, Bingham Greenebaum Doll LLP
On October 29, 2013, EPA released a draft Groundwater Remedy Completion Strategy. The draft document is intended to provide a consistent national framework for evaluating Superfund groundwater remedy performance and decision making to assist with achievement of the remedial action objectives (RAOs) and associated cleanup levels. The draft guidance provides information on several key components of an effective groundwater remedy completion strategy which includes: (1) understanding the site characteristics; (2) developing definitive RAOs and associated cleanup levels and timeframes; and (3) improving the current understanding of other site actions related to groundwater cleanup.
The draft guidance explains that decision points, performance metrics and monitoring that are included in a groundwater remedy completion strategy are important when evaluating whether the chosen RAOs are effective or require modification to achieve the remediation goals. The draft Strategy provides recommended remedy evaluation questions and evaluation criteria for site teams to consider during remedy selection and implementation. This draft guidance is intended for use by EPA technical professionals who analyze groundwater data, EPA managers who either review analyses or make decisions based upon them and other regulators and technical representatives of states, tribes, other federal agencies, potentially responsible parties and community members.
This draft guidance does not alter or supersede any existing CERCLA guidance. A copy of the draft Groundwater Remedy Completion Strategy and additional information may be found at http://epa.gov/superfund/gwcompletionstrategy/. Comments on this draft guidance document must be submitted by December 20, 2013.
To view a complete PDF of the September/October 2013 issue of the Environmental Letter, click HERE.