EPA Requests Feedback on Superfund Groundwater Remediation Principles

In June 2020, the Environmental Protection Agency (EPA) Superfund Task Force held two webinars to provide clarification and solicit input on six major Superfund groundwater remediation principles. The regulated community has until July 30, 2020 to provide comments via email on the groundwater principles

A bit of background on the Superfund groundwater initiative

In May 2017, a memorandum from the EPA Administrator directed EPA staff to streamline and improve the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), more commonly known as Superfund.  Part of this direction involved identifying regional Superfund program best practices. As such, EPA devised Superfund groundwater remediation principles around six focus areas that were introduced in EPA's June 2020 Superfund Task Force webinars. The intent of the webinars was to clarify and solicit input to improve the following six Superfund groundwater remediation principles. 

  1. Monitored Natural Attenuation (MNA)
  2. Technical Impracticability (TI)
  3. Remediation Timeframes
  4. Beneficial Use of Groundwater Cleanup Policy
  5. Groundwater Use Designations
  6. Using Phased Remediation Approaches

What’s next? July comment period now open

Throughout July, EPA is soliciting feedback on creating flexible policies surrounding the six Superfund groundwater remediation principles. EPA has posed several questions for the regulated community’s input, including: 

  • How useful is the current Groundwater Beneficial Use Designation policy and could additional clarification be made?
  • What lines-of-evidence for MNA are the most useful in making an MNA determination and are there possible new lines-of-evidence based on advances in science?
  • What are the most important factors to consider in determining an appropriate site-specific remedial timeframe?
  • How are current and future groundwater use and other flexibilities factored into a remediation timeframe analysis?
  • What clarifications to existing TI guidance would be useful to evaluate the site for TI applicability?
  • Is clarification needed for the successful use of a phased approach in a groundwater remedy?
  • Has the use of a completion strategy or plan been useful in facilitating a common understanding amongst all parties for steps and metrics needed for achieving completion goals?

The full list of questions can be found here.

How do I provide input?

EPA is accepting written remarks until July 30, 2020. Regulated community members who wish to comment should email [email protected] and use the subject line “LS6.”  

Trihydro has significant experience with groundwater remediation at Superfund sites.  Contact us today to learn more or discuss strategic approaches.   

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