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Remedy Selection / RODS for Groundwater Cleanups

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“Summary of Key Existing EPA CERCLA Policies for Groundwater Restoration” June 26, 2009
OSWER Directive 9283.1-33. 11 p.
Available on-line from OSWER [PDF 2.5M]

This Directive provides a compilation of some key existing EPA groundwater policies to assist EPA Regions in making groundwater restoration decisions pursuant to CERCLA and the NCP.  It addresses:

  • Whether CERCLA remedial action is warranted
  • Appropriate role of institutional controls (ICs)
  • Groundwater classification and beneficial use policy
  • Remedial action cleanup levels
  • Groundwater point of compliance

"Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents," July 1999
OSWER Memorandum 9200.1-23P, EPA 540-R-98-031, NTIS Order Number PB98-963241
Available on-line from OSWER HTML

This updated guidance on writing Records of Decision (RODs), Explanations of Significant Difference (ESDs) and ROD amendments includes very good sections on documenting all types of ground water remedy decisions and technical impracticability waivers, including sample language.

"Rules of Thumb for Superfund Remedy Selection," August 1997.
OSWER Publication 9355.0-69, EPA 540-R-97-013, NTIS Order Number PB97-963301, 23p.
Available on-line from OSWER HTML.

This guidance describes key principles and expectations, interspersed with "best practices" based on program experience, that should be consulted during the Superfund remedy selection process. Three major policy areas are covered: risk; remedial alternatives; and ground water. The guidance summarizes key elements of other guidance documents in these areas and provides citations for other EPA guidances an RPM may need to consult for more detailed information.

"Superfund Reforms: Updating Remedy Decisions," September 27, 1996.
OSWER Memorandum 9200.0-22., EPA540/F-96/026, NTIS Order Number PB96-963252.
Available on-line from OSWER PDF (9 pp, 455K).

This memo explains the purpose of the reform, the types of remedy updates anticipated, and the process for updating remedies. It includes specific detail about how the reform relates to ground water remedies, especially with regard to remedy updates which 1. Change the remediation technology, 2. Reconsider remedial objectives, or 3. Reduce monitoring data needs.

"A Guide to Principal Threat and Low Level Threat Wastes" November 1991.
OSWER Publication 9380.3-06FS, NTIS Order Number PB92-963345.
Available on-line from OSWER PDF (4 pp, 227K).

This guidance explains considerations that should be taken into account in categorizing waste for which treatment or containment generally will be suitable and provides definitions, examples, and ROD documentation requirements related to waste that constitute a principal or low level threat. It explains that the concept of principal threat is to be applied when characterizing source material and that contaminated ground water is not generally considered to be a source material, although non-aqueous phase liquids (NAPLs) may be viewed as source materials.

"A Guide on Remedial Actions for Contaminated Ground Water," April 1989.
OSWER Directive 9283.1-1FS, NTIS Order Number PB90-2725676CDH.
Available on-line from OSWER Image PDF (5 pp, 548K), Searchable PDF (5 pp, 147K).

This fact sheet summarizes key issues in the development, evaluation, and selection of ground-water remedial actions at Superfund sites. It provides a short summary of CERCLA requirements, project planning, remedial action objectives, types of response actions, evaluating performance, and a multiple source strategy. For more detail on this topic, see December 1988, "Guidance on Remedial Actions for Contaminated Ground Water at Superfund Sites", below. Use of either document should be augmented by more recent guidance.

"Guidance on Remedial Actions for Contaminated Ground Water at Superfund Sites," December 1988.
OSWER Directive 9283.1-2, EPA/540/G-88/003, NTIS Order Number PB89-184618.
Available on-line from OSWER Searchable PDF (121 pp, 1.7M).

This guidance summarizes policy issues and the decision-making approach to developing, evaluating, selecting, and implementing ground water remedial actions at Superfund sites. It should be supplemented by reference to more recent guidance on specific topics, but is still a useful overview. It includes practical appendices on: a case study, multiple source plume issues, interim action RODs for ground water, and equations for estimating restoration time-frame.

See also:

"Presumptive Response Strategy and Ex-Situ Treatment Technologies for Contaminated Ground Water at CERCLA Sites, Final Guidance," October 1996. (described under "Phased Approach")


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