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A Guide on Remedial Actions for Contaminated Ground Water

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A Guide on Remedial Actions for Contaminated Ground Water United States Solid Waste and Directive: Environmental Protection Emergency Response 9283.1-2FS April Agency (OS-220) 1989 A Guide On Remedial Actions For Contaminated Ground Water GOAL The goal of Superfund ground-water remediation is to protect human health and the environment by restoring ground water to its beneficial uses within a time frame that is reasonable, given the particular site circumstances. This fact sheet summarizes the key issues in the development, evaluation, and selection of ground-water remedial actions at Superfund sites. For more detailed information, consult Regional Ground-Water Forum members or the Interim Final “Guidance on Remedial Actions for Contaminated Ground Water at Superfund Sites,” (Ground-Water Guidance) December 1988, OSWER Directive No. 9283.1-2. REQUIREMENTS OF CERCLA The approach outlined in this fact sheet is • Satisfy the preference for remedies that • Remedial actions that restore ground designed to ensure that ground-water reme­ employ treatment that permanently and water are to be federally funded until cleanup ial actions will meet the following require­ significantly reduces the mobility, toxicity, or levels are achieved or up to 10 years, ents of CERCLA: volume of hazardous substances as a principal whichever comes first. However, if the • Protect human health and the environ­ element or provide an explanation in the ROD purpose of the ground-water remedial action ment (121(b)) for why the preference was not satisfied is to provide an alternate water supply, for • Comply with applicable or relevant and (121(b)). In addition, the following provisions example, but not to restore ground water, appropriate requirements (ARARs) of Fed­ of CERCLA may or may not be pertinent to then the Federal government will pay capital ral and State laws (121(d)(2)(A)) or warrant groundwater remediation, depending on and startup costs only (104(c)(6)). a waiver under CERCLA Section 121(d)(4) site-specific circumstances: • A review must be conducted at least • Be cost-effective (121(a)) • Alternate concentration limits (ACLs) from every 5 years if wastes are left onsite (121(c)) • Utilize permanent solutions and altern­ otherwise applicable or relevant and above health- or environment based levels to ative treatment technologies or resource appropriate requirements can only be used for verify that the remedy continues to provide recovery technologies to the maximum determining offsite cleanup levels under special adequate protection of human health and the extent practicable (121(b)) circumstances (121(d)(2)(B)(ii)). environment. SCOPING GROUND-WATER SITE MANAGEMENT PLANNING REMEDIAL ACTIVITIES Site management planning identifies the An operable unit is a portion of an overall Before collecting any data, it is useful to response approaches that will be taken to response action that, by itself, eliminates or conduct two planning activities: address the site problems. Two response mitigates a release, a threat of a release, or approaches can be taken to remediate ground an exposure pathway; it may reflect the • Site management planning (See right), water at Superfund sites: final remediation of a defined portion of a which involves identifying the types of site. At many sites, it is appropriate to analyses and actions that are appropriate to • Removal actions implement an operable unit as an interim address site problems and their optimal • Remedial actions, which can be final, or action. Interim actions may be implemented sequence. interim actions to prevent exposure to contaminants or • Project planning (See next prevent further degradation of ground page),which includes such activities as Removal actions are authorized for any water (by remediating hot spots, for scoping data collection efforts, initiating release that presents a threat to public health, example) while the overall remedial identification of ARARs, and work plan welfare, or the environment. CERCLA limits investigation (RI) and feasibility study (FS) preparation. Superfund-financed removal actions to $2 are being conducted. Interim actions million and 12 months unless the criteria for involving pumping can also provide critical granting an exemption to the statutory limits information for evaluating the final remedy. are satisfied. Remedial actions are sometimes addressed as operable units. Word-searchable version – Not a true copy Characterization Characterization of of the Hydrogeology Contamination Describe, the geology using geophysical meth- Consider selecting one or more chemicals for ods and sediment samples collected during monitoring to reduce analytical costs and drilling of soil borings and monitoring wells. simplify modeling. These chemicals may be Present the information using geologic cross selected on the basis of toxicity, exposure, sections and fence diagrams. mobility, persistence, treatability, or volume of contaminants. If appropriate, however, Assess the ground-water movement by using nontoxic constituents or chemical classes, water level measurements from wells screened such as total volatile organic compounds, at various depths. Present a contour map of could also be monitored. each aquifer to determine recharge and discharge and identify the direction of ground- Determine the horizontal and vertical extent of water flow. the contaminant plume through monitoring at various locations and depths. Understand the Evaluate data over time to detect seasonal or relationship of the source to the ground tidal fluctuations. water. Contaminant levels should be monitored over time to identify migration and Aquifer tests may be used to determine the degradation patterns. Note the density of hydraulic properties of the aquifers and contaminants to aid in assessing their aquitards, and to evaluate the performance and behavior in the ground water. effectiveness of the extraction system. Aquifer tests can be used in conjunction with Assess contaminant/soil interactions to aid in modeling. assessing the effectiveness of a ground-water extraction system. Laboratory analysis of contaminant partitioning behavior in the saturated soil may be critical to the development of the remedy and the determination of whether ground-water extraction is practicable. Assessment of Design Evaluation of Parameters for Plume Movement Consideration of Potential Treatment and Response Technical Uncertainty Technologies Consider modeling the ground Identify sources of uncertainty, e.g., pre- Identify several likely remedial water as a tool to guide the dicting the nature, extent, and movement of technologies during scoping to placement of monitoring wells, contamination; determining contaminant focus data collection activities. predict concentrations of movement through the vadose zone; Consider data needs for screening contaminants at exposure points, estimating the rate and direction of the out inappropriate technologies and estimate the effect of source control ground-waterflow; and estimating the cost for designing workable systems to actions, and evaluate the expected of remedial alternatives. Assess the provide a sound basis for selecting a performance of the ground-water magnitude of uncertainty from each of remedy and reducing implementation remedial action. these sources, and weigh the costs and time. Consider the costs and benefits benefits of reducing uncertainty by of conducting a treatability study. collecting additional information. Word-searchable version – Not a true copy REMEDIAL ACTION OBJECTIVES Remedial action objectives include cleanup levels, the area of attainment, and the restoration time frame. Cleanup Levels Cleanup levels will generally be set at Table 1 For systemic (noncarcinogenic) basis of factors related to exposure, Restoration Time Frame aquifer testing or saturated soil core health-based levels, reflecting current toxicants, cleanup levels should be set at technical limitations, and uncertainties. analysis may be warranted. Potential ARARs The restoration time frame is defined as and potential use and exposure. For levels to which humans could be the period of time required to acheive ground water that is a current or • Maximum contaminant levels exposed on a daily basis without Alternate concentration limits (ACLs) cleanup levels in the ground water at all Once technical limits to achieving potential source of drinking water, (MCLs) experiencing appreciable adverse effects may be established in some situations locations within the area of attainment. cleanup levels have been assessed, maximum contaminant levels (MCLs) during their lifetimes. To determine where remediation of the ground water restoration time frames for remedies can • Promulgated State standards For drinkable ground water, at least one under the safe drinking water Act or aggregate effects from systemic is not practicable. CERCLA Section alternative should reach cleanup levels be evaluted relative to this limit on the more stringent State standards devised Other Potential ARARs and TBCs toxicants, the hazard index is used. 121(d)(2)(B)(ii) places restrications on in the minimum time frame technically basis of the following considerations: to protect drinking water generally are the use of ACLs. The ground water must • Proposed MCLs achievable. Technical limits to ARARs. If an MCL or State standard For carcinogens, cleanup levels should discharge to nearby surface water and extracting contaminants that will tend • Feasibility of providing an alternate does not exist for a contaminant, then • Risk-specific doses reflect an individual excess lifetime
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