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| Resource Library > Technology Transfer > Programs and Initiatives > Source Zone Treatment > Regulatory Acceptance |
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Source Zones: Regulatory Acceptance
CERCLA and RCRA Corrective Action programs generally require that remedial actions: 1) prevent exposure to contaminated ground water, above acceptable risk levels; 2) minimize further migration of the plume; 3) minimize further migration of contaminants from source materials; and 4) restore the plume to cleanup levels appropriate for current or future beneficial uses, to the extent practicable. For other cleanup programs, remedial objectives may be focused on preventing exposures above acceptable levels.
A range of positions has been taken relative to NAPL depletion. For example, "regulations under CERCLA and RCRA, and their equivalents at the state level, establish cleanup goals for cleanup of ground water (including that in source zones) to strict numerical concentrations" (NRC, 1994). Furthermore, "NAPL removal to the extent practicable" is often cited in regulatory guidance (e.g. USEPA 1998). On the other hand, published information provides few (if any) instances where sufficient NAPL has been recovered to achieve strict standards for ground water (e.g. MCLs) or meaningful changes in site care requirements. Reflecting this, USEPA (1993) explicitly recognizes that restoration of NAPL zones can be technically impracticable and that alternative site strategies such as long-term containment may be required. In such cases ongoing CERCLA five-year reviews are mandated to verify containment and resolve whether new technologies exist that can achieve numerical cleanup goals in source zones.
Traditionally, a description of the state of regulatory acceptance is based on the historical regulatory concurrence with the use of a particular technology. However, NAPL Source Treatment encompasses a large and continuously expanding list of technologies. Thus, rather than providing subjective estimates of the regulatory acceptance of individual technologies, it may be more productive to consider the collective expectations of regulators with respect to NAPL Source Treatment.
- Is there a general belief that NAPL mass removal will result in significant short and long-term reductions in ground water contaminant concentrations and time to achieve cleanup goals?
- Is there a general belief that technologies exist or are shortly forthcoming that can achieve mass removal efficiencies that will dramatically reduce time to cleanup?
- Is there a general belief that source control technologies can be designed and implemented without a significant risk of uncontrolled contaminant spreading or worker injury?
- Is there a general belief that a significant number of DNAPL source zones have been effectively remediated?
An analysis of current Records of Decisions, Corrective Action Plans, etc. would indicate that regulatory and public expectations could be summarized by answering, "Yes" to all of the above questions. There is limited apparent regulatory acceptance of a "No" answer to any of the questions above. The US EPA Guidance for Evaluating the Technical Impracticability of Ground water Restoration Interim Final Report (http://www.epa.gov/oerrpage/superfund/resources/gwdocs/techimp.htm) provides some guidelines how a responsible party may evaluate when source removal versus source control is indicated.
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