United States

Environmental Protection

Agency

Solid Waste and

Emergency Response

(5303W)

EPA530-R-04-030

April 2004*

http://www.epa.gov/correctiveaction

Handbook of Groundwater

Protection and Cleanup Policies

for RCRA Corrective Action

for Facilities Subject to Corrective Action Under 

Subtitle C of the Resource Conservation and Recovery Act

* As described on page x of the Introduction, EPA intends to keep this Handbook current. This document is an

update to the original version dated September 2001. This most recent revision provides (1) an update to section

15.0 - Completing Groundwater Remedies - in order to ensure that this Handbook is consistent with new guidance

on completing corrective action at RCRA facilities (available at

http://www.epa.gov/epaoswer/hazwaste/ca/resource/guidance/gen_ca/compfedr.pdf), and (2) updated internal

navigational and external Internet links to ensure that resources and cited references are available to the reader. 

While this most recent version of the Handbook is dated April 2004, the date provided at the beginning of each

policy section reflects the last time EPA made any substantive changes (i.e., beyond updating web links). 
Acknowledgments

This Handbook was produced by EPA’s Office of Solid Waste, Permits and State Program Division

in conjunction with EPA Region III. Contributing authors include Guy Tomassoni from the Corrective Action

Programs Branch, and Deborah Goldblum and Joel Hennessy from EPA Region III’s Waste and Chemicals

Management Division. We express a special thanks to Joel and Deborah for their expertise, time and

dedication to this effort. We also thank Region III management, who supported their involvement. We also

acknowledge and thank the individuals and organizations that provided comments and suggested

improvements on previous draft versions.
Links to State

Cleanup Programs

Links to

EPA Regions

Handbook Overview 

What does this Handbook do?

Who should use this Handbook?

Applicability to State Cleanup Programs

Roles and Responsibilities

Future Policy

(place holder)

Short Term 

Protection Goals

including

Environmental Indicators

Completing

Groundwater

Remedies

Final Cleanup Goals 

including

Remedy Selection

Performance

Monitoring

Groundwater

Cleanup Levels

Reinjection of

Contaminated

Groundwater

Point of

Compliance 

Groundwater 

Protection 

and Cleanup Strategy

for 

RCRA Corrective Action Cleanup 

Timeframe

Technical

Impracticability

Monitored

Natural

Attenuation

Source Control

Institutional

Controls 

Groundwater

Use

Designations

Links to Internet Resources

References Glossary

Intermediate

Performance Goals

If you are viewing an electronic version, 

you can click a button to take you to a topic of interest.

 

 
This page intentionally left blank. 
Table of Contents, Pg. 1

Table of Contents

Overview ........................................................................................... i

What does this Handbook do? ...................................................................... i

What is the difference between statements in this Handbook and EPA statutory or 

regulatory requirements? .................................................................. ii

Who should use this Handbook? .................................................................... ii

How will this Handbook help me? ................................................................... ii

What does the RCRA Corrective Action Program do? .................................................. iii

What are the general roles and responsibilities of various stakeholders involved 

with RCRA corrective action? ............................................................. iv

How do the policies in this Handbook apply to State cleanup programs? ................................... vii

How is this Handbook organized? .................................................................. vii

Where do the policies in this Handbook come from? ................................................... viii

Are the policies contained in this Handbook consistent with EPA’s other cleanup programs? ................... ix

How will I know that the policies in this Handbook are current? ........................................... x

How can I get further information about the policies in this Handbook? ..................................... x

What if I have comments on this Handbook? .......................................................... x

1. Groundwater Protection and Cleanup Strategy .............................................. 1.1

What is EPA’s groundwater protection and cleanup strategy for RCRA corrective action? .................... 1.1

How does this strategy benefit the public, regulators, and facilities? ...................................... 1.1

What is EPA’s overall goal for groundwater protection and cleanup? ...................................... 1.1

How should facilities and regulators implement this groundwater protection and 

cleanup strategy for RCRA corrective action? ................................................ 1.2

How do short-term, intermediate and final cleanup goals work together to achieve EPA’s overall

groundwater goals? ..................................................................... 1.2

How should facilities and regulators implement these goals? ............................................ 1.4

2. Short-Term Protection (Environmental Indicator) Goals .................................... 2.1

What are EPA’s short-term protection goals for groundwater? ........................................... 2.1

How does EPA monitor progress toward these goals? ................................................. 2.1

Who evaluates and determines whether a facility meets environmental indicator goals? ........................ 2.2

How should regulators and facilities evaluate environmental indicators? ................................... 2.2

How does a facility get to YES? ................................................................... 2.2

How should facilities and regulators develop facility-specific short-term protection goals? .................... 2.3

How should facilities and regulators consider groundwater use when evaluating 

“Current Human Exposures Under Control?” ................................................ 2.4

How should facilities and regulators evaluate the “Migration of Contaminated Groundwater

 Under Control” indicator? ............................................................... 2.4

Can a facility achieve the “Migration of Contaminated Groundwater Under Control” indicator 

when the plume extends beyond the facility boundary? ........................................ 2.5

Can a facility achieve the “Migration of Contaminated Groundwater Under Control” indicator 

when contaminated groundwater discharges to surface water? ................................... 2.5

Will an environmental indicator evaluation require additional investigation? ................................. 2.6

Do facilities need to perform additional investigation or cleanup, once they achieve the 

environmental indicator goals? ............................................................ 2.6

Do facilities need to control sources to meet the environmental indicator goals? ............................. 2.6

Are these two environmental indicators the only short-term protection goals facilities should consider? .......... 2.7

3. Intermediate Performance Goals ............................................................ 3.1

What are intermediate performance goals for groundwater? ............................................. 3.1
Table of Contents, Pg. 2

How can intermediate performance goals help me? .................................................... 3.1

Are intermediate performance goals appropriate for all facilities? ......................................... 3.2

When should facilities and regulators establish intermediate performance goals? ............................. 3.2

How should facilities and regulators develop facility-specific intermediate performance goals? ................. 3.2

What are some examples of intermediate performance goals? ............................................ 3.2

Why is it important to establish intermediate performance goals on a facility-specific basis? ................... 3.3

4. Final Cleanup Goals .......................................................................... 4.1

What are EPA’s final cleanup goals for corrective action? ............................................... 4.1

What are EPA’s final cleanup goals for groundwater? .................................................. 4.2

When does EPA consider groundwater “usable” for selecting final cleanup goals? ............................ 4.2

What if groundwater is not usable? ................................................................ 4.2

What if returning contaminated groundwater to its maximum beneficial use is 

not technically practicable? .............................................................. 4.3

How should facilities and regulators evaluate final remedies that meet the threshold criteria? ................... 4.3

How thorough of an assessment should facilities conduct when evaluating 

one or more remedial options? ............................................................ 4.4

How should facilities and regulators develop facility-specific final groundwater cleanup goals? ................. 4.5

What are the media cleanup objectives if containment is the final goal rather than 

meeting cleanup levels throughout contaminated groundwater? .................................. 4.5

5. Groundwater Cleanup Levels ................................................................ 5.1

What are groundwater cleanup levels? .............................................................. 5.1

How should groundwater cleanup levels be developed? ................................................ 5.1

Are there other factors regulators and facilities should considered when developing 

groundwater cleanup levels? .............................................................. 5.2

What is the role of groundwater use in setting cleanup levels? ........................................... 5.3

What are the groundwater cleanup levels for a current or potential source of drinking water? ................... 5.4

What is the cleanup level if the groundwater is designated as something other than a

 current or potential source of drinking water? ............................................... 5.4

Are there any situations where regulators might not establish specific groundwater cleanup levels? .............. 5.6

What are alternate concentration limits and do they apply to setting groundwater 

cleanup levels for facility-wide corrective action? ............................................. 5.6

What are cleanup levels for groundwater if a facility is clean closing a RCRA regulated unit? ................... 5.7

 6. Point of Compliance ......................................................................... 6.1

What is a point of compliance for groundwater? ...................................................... 6.1

Where is the point of compliance for RCRA regulated units? ............................................ 6.1

Where is the groundwater point of compliance for RCRA (facility-wide) corrective action? .................... 6.2

Where is the groundwater point of compliance for final cleanup goals? .................................... 6.2

Where is the groundwater point of compliance for short-term protection goals? ............................. 6.3

Where is the groundwater point of compliance for intermediate performance goals? .......................... 6.4

7. Cleanup Timeframe ........................................................................... 7.1

What is the cleanup timeframe? ................................................................... 7.1

What is the cleanup timeframe for EPA’s short-term goals? ............................................. 7.1

How should regulators establish cleanup timeframes for intermediate performance goals? ..................... 7.2

How should regulators establish cleanup timeframes for achieving final cleanup goals? ........................ 7.2

8. Source Control ................................................................................ 8.1

What does source control mean? .................................................................. 8.1

What are sources of contamination? ................................................................ 8.1

What are EPA’s expectations for source control regarding groundwater? ................................... 8.1
Table of Contents, Pg. 3

When should facilities and regulators consider source control measures? ................................... 8.2

When can facilities contain the sources rather than treat them? ........................................... 8.2

Why should facilities control sources when they have already achieved environmental

 indicators goals? ...................................................................... 8.3

9. Groundwater Use Designations .............................................................. 9.1

What is a groundwater use designation? ............................................................. 9.1

How does EPA define use, value, and vulnerability? ................................................... 9.1

What factors should States consider when making groundwater use designations? ............................ 9.2

How does EPA’s policy on groundwater use designations affect States that consider all of 

their groundwater to be a potential drinking water supply? ..................................... 9.2

Who makes groundwater use designations? .......................................................... 9.3

What is EPA’s groundwater use classification? ....................................................... 9.4

How can State groundwater use designations enhance protection and flexibility for RCRA cleanups? ............ 9.4

How do groundwater management or containment zones relate to groundwater use designations? ............... 9.5

10. Institutional Controls ....................................................................... 10.1

What are institutional controls? .................................................................. 10.1

What are the general categories and some specific examples of institutional controls? ........................ 10.1

How can facilities and regulators use institutional controls to address contaminated groundwater? .............. 10.2

How should facilities develop and stakeholders evaluate institutional controls? ............................ 10.3

11. Monitored Natural Attenuation ............................................................ 11.1

What is monitored natural attenuation? ............................................................ 11.1

When is monitored natural attenuation a likely cleanup option? ......................................... 11.1

Is monitored natural attenuation acceptable when contaminated groundwater is off-site? ..................... 11.2

Should monitored natural attenuation remedies include formal contingency measures? ....................... 11.2

How long should a facility monitor a monitored natural attenuation remedy? .............................. 11.3

12. Technical Impracticability .................................................................. 12.1

What does technical impracticability mean? ........................................................ 12.1

What are the primary factors that might lead to a technical impracticability determination? ................... 12.1

Is the mere presence of non-aqueous phase liquids (NAPLs) sufficient to justify a 

technical impracticability determination? ................................................... 12.2

What should facilities include in a technical impracticability evaluation? .................................. 12.2

When should a facility recommend technical impracticability? .......................................... 12.2

Should regulators make technical impracticability determinations prior to a facility’s

 attempt to meet groundwater cleanup levels? ............................................... 12.3

If a regulator makes a formal technical impracticability determination, has the facility satisfied 

all of their corrective action obligations for groundwater? ...................................... 12.3

Why should facilities conduct investigations within the technical impracticability zone? ..................... 12.3

Why should facilities control sources within the technical impracticability zone? ........................... 12.3

How does a technical impracticability determination affect the point of compliance? ........................ 12.4

How long should a technical impracticability determination last? ........................................ 12.4

Should regulators and/or facilities revisit technical impracticability determinations? ......................... 12.4

13. Reinjection of Contaminated Groundwater ............................................... 13.1

Can facilities reinject groundwater that is contaminated with hazardous wastes back in the 

subsurface as part of corrective action? .................................................... 13.1

What are the specific conditions facilities have to meet prior to reinjecting groundwater contaminated 

with hazardous waste into the subsurface? ................................................. 13.1

Does section 3020(b) allow the reinjection of contaminated groundwater after the 

addition of nutrients or other in situ treatment products? ...................................... 13.2
Table of Contents, Pg. 4

What if a facility wants to re-inject groundwater that is contaminated with nonhazardous wastes 

as part of corrective action? ............................................................. 13.2

14. Performance Monitoring ................................................................... 14.1

What is performance monitoring? ................................................................ 14.1

What should the performance monitoring accomplish? ................................................ 14.1

What should a performance monitoring program include? .............................................. 14.2

How often should a facility monitor? ............................................................. 14.2

How long should performance monitoring continue? .................................................. 14.2

15. Completing Groundwater Remedies ....................................................... 15.1

What does it mean to complete a groundwater remedy? ............................................... 15.1

What does it mean to complete the implementation phase of a groundwater remedy? ........................ 15.1

How does EPA acknowledge when a facility achieves the implementation phases of a final remedy? ............ 15.1

What does it mean to achieve the final cleanup goals for a groundwater remedy? ............................ 15.2

How do facilities and regulators typically decide when a groundwater remedy achieves 

media cleanup objectives? .............................................................. 15.2

How does EPA acknowledge when a facility achieves final cleanup goals for all media? ...................... 15.3

What is the difference between Corrective Action Complete without Controls and 

Corrective Action Complete with Controls? ................................................ 15.3

What type of Corrective Action Complete determination can a facility achieve for a 

final remedy where groundwater cleanup is a component of the remedy? ......................... 15.3

Appendix 1 - References............................................................. Appendix 1, Pg. 1

Appendix 2 - Links to Other Helpful Internet Resources .......................... Appendix 2, Pg. 1

Appendix 3 - Glossary ............................................................... Appendix 3, Pg. 1
1

This Handbook primarily addresses corrective action as required by the 1984 Hazardous and Solid Waste

Amendments (HSWA) to RCRA. For additional background regarding RCRA in general, refer to the RCRA

Orientation Manual (EPA, 1998a) available at http://www.epa.gov/epaoswer/general/orientat/. For more information

about RCRA corrective action, refer to the corrective action Web site at http://www.epa.gov/correctiveaction. 

Additionally, an on-line introductory training on RCRA corrective action is available at

http://www.epa.gov/epaoswer/hazwaste/ca/training/index.htm.

2

The terms cleanup or cleaning up, when used in this Handbook, refer to the range of activities that could

occur in the context of addressing environmental contamination at RCRA facilities. For example, cleanup activities

could include removing waste or contaminated media (e.g., excavation and pumping groundwater), in-place treatment

of the waste or contaminated media (e.g., bioremediation), containment of the waste or contaminated media (e.g.,

barrier walls, low-permeable covers, and liners), or various combinations of these approaches. The term “cleanup” is

often interchanged with the term “remediate” or “remediation.” 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Overview, Pg. i

Why is groundwater

important?

Beneath the surface of the earth, a huge

supply of fresh water is available to support

the health and economic well-being of our

country. More specifically, 

T Groundwater supplies drinking water to

half of the nation and virtually all people

living in rural areas. 

T Groundwater supplies the majority of

water in streams and rivers in large

areas of the country and provides much

of the water in lakes and wetlands;

these surface water bodies provide the

balance of drinking water to those

areas that do not rely on groundwater

as their primary source for drinking

water. 

T Groundwater supports many billions of

dollars worth of food production and

industrial activity.

Overview

(September 2001)

What does this Handbook do?

This Handbook is designed to help you as a

regulator, member of the regulated community, or

member of the public find and understand EPA

policies on protecting and cleaning up groundwater

at Resource Conservation and Recovery Act

(RCRA) corrective action facilities1. EPA

developed this Handbook as part of the RCRA

Cleanup Reforms (refer to 

http://www.epa.gov/epaoswer/hazwaste/ca/reforms.

htm) that EPA announced in July 1999 and January

2001 (EPA, 2001d and EPA, 1999c). EPA’s goal

for this Handbook is to help meet the objectives of

these reforms by reducing time-consuming

uncertainties and confusion about EPA’s policies

concerning groundwater protection and cleanup at

RCRA facilities. We believe clarifying EPA’s

groundwater policies will help promote faster,

focused, and more flexible cleanups, and foster

creative solutions. 

This Handbook recommends that groundwater

cleanups2 generally be implemented in terms of

short-term protection goals, intermediate

performance goals, and final cleanup goals. EPA

recommends that facilities, regulators, and members
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Overview, Pg. ii

of the public use these goals to focus discussions as well as resources, and to ultimately improve the

quality of groundwater at and near corrective action facilities. EPA is issuing this Handbook to

communicate what we believe should generally occur at RCRA corrective action facilities to protect

human health and the environment. 

What is the difference between statements in this Handbook and EPA statutory or regulatory

requirements?

This Handbook provides guidance to EPA regional and State RCRA Corrective Action Program

implementers, as well as to owners and operators of facilities subject to RCRA corrective action

requirements, and to the general public. More specifically, this Handbook conveys how EPA generally

expects to exercise its discretion in implementing RCRA statutory and regulatory provisions that

concern RCRA corrective action. EPA designed this guidance to explain and clarify national policy on

issues related to the protection and cleanup of groundwater at RCRA corrective action facilities. 

The statutory provisions and EPA regulations discussed in this Handbook contain legally binding

requirements. This Handbook itself does not substitute for those provisions or regulations, nor is it

regulation itself. Thus, this Handbook does not impose legally binding requirements on EPA, States, or

the regulated community, and may not apply to a particular situation based upon the specific

circumstances of the corrective action facility. EPA and State regulators retain their discretion to use

approaches on a case-by-case basis that differ from this Handbook where appropriate. EPA and State

regulators base their corrective action decisions on the statute and regulations as applied to the specific

facts of the corrective action facility. Interested parties are free to raise questions and concerns about

the substance of this Handbook and appropriateness of the application of recommendations in this

Handbook to a particular situation. Whether or not the recommendations in this Handbook are

appropriate in a given situation will depend on facility-specific circumstances. 

Who should use this Handbook?

This Handbook is designed to help anyone who wants to develop a better understanding of EPA’s

groundwater cleanup policies for RCRA corrective action facilities. We wrote this Handbook for State

and EPA regulators, owners and operators of facilities subject to RCRA corrective action, and

members of the public. Throughout the rest of this Handbook we will refer to these three groups as

“regulators,” “facilities,” and the “public,” respectively. Sometimes, we will refer to all three groups

collectively as “stakeholders.” 

How will this Handbook help me?

If you are a regulator, the Handbook can help clarify key groundwater-related policies that you should

consider, where appropriate, to guide investigations and cleanups at your assigned facilities (via permits,

orders, or voluntary actions). EPA designed this Handbook to help you do your part in promoting a

technically sound, reasonable, and consistent approach to protecting and cleaning up our Nation’s

groundwater.
3

See glossary to definition of “remedy expectations” used in the context of the RCRA Corrective Program.

4

See glossary definition of “releases.”

5

For additional information about the list of 1,714 facilities we call the “RCRA Cleanup Baseline,” refer to

http://www.epa.gov/epaoswer/hazwaste/ca/lists/base_sta.pdf.

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Overview, Pg. iii

If you represent a facility, the Handbook can help you reduce your uncertainties about the actions a

regulator may require of you. Reducing uncertainties can help you in your financial planning and project

management. Clarity in EPA’s expectations will allow you to phase your investigation and cleanup

strategy in a manner consistent with the RCRA Corrective Action Program priorities. These policies

can help if you are currently undergoing RCRA corrective action under some form of regulatory

oversight, or if you intend to begin cleanup in advance of oversight by an EPA or State regulator. 

If you are a member of the public, this Handbook can help you understand what EPA generally

expects3 regulators and facilities to do during an investigation and cleanup of contaminated groundwater

at a RCRA corrective action facility. EPA encourages you to use this Handbook as a tool in your

interaction with regulators or facilities. In essence, EPA wrote this Handbook, in part, to help you

influence decisions related to groundwater protection and cleanup at RCRA corrective action facilities. 

What does the RCRA Corrective Action Program do?

Accidents or other activities at RCRA facilities have sometimes resulted in releases4 of hazardous waste

or hazardous constituents into soil, groundwater, surface water, sediments, or air. The Corrective

Action Program requires such facilities to conduct investigations and cleanup actions as necessary to

protect human health and the environment. Currently, EPA believes that there are over 5,000 facilities

subject to RCRA corrective action statutory authorities. Of these, approximately 3,700 facilities have

corrective action already underway or will need to implement any necessary corrective action as part of

the process to obtain a permit to treat, store, or dispose of hazardous waste. To help prioritize

resources, EPA established specific goals for 1,714 facilities5 that generally warrant attention in the next

several years. 

EPA’s authority to require facility-wide corrective action comes from the Resource Conservation and

Recovery Act (RCRA). The following specific sections of the RCRA statute that regulators use to

require corrective action (or aspects of corrective action) include: §§3004(u)&(v), 3005(c)(3),

3008(h), 3013, and 7003. EPA’s regulatory provisions for corrective action at permitted facilities are

found primarily in 40 CFR Part 264 Subpart F. EPA provides additional direction on corrective action

through guidance, policy directives, and related regulations. The most recent and comprehensive

guidance issued for RCRA corrective action is in Section III (pages 19440 – 19455) of the May 1,

1996 Advance Notice of Proposed Rulemaking (ANPR; EPA, 1996a; see also EPA, 1997a).
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Overview, Pg. iv

If you are relatively new to RCRA corrective action, you can learn more about the program by referring

to the background information at http://www.epa.gov/correctiveaction/backgnd.htm.

What are the general roles and responsibilities of various stakeholders involved with RCRA

corrective action?

EPA Headquarters

EPA Headquarters oversees the national Corrective Action Program through its Office of Solid Waste

and its Office of Site Remediation Enforcement. In general, major responsibilities of these offices for

corrective action include: developing goals for the regional Corrective Action Programs and monitoring

progress toward those goals; developing regulations, policies, and guidance on implementing corrective

action; providing technical and policy assistance; acting as a liaison to other EPA programs (e.g.,

Superfund) and Federal Agencies (e.g., Departments of Defense and Energy) involved in cleanup

issues; providing information and testimony to Congress; and, seeking input from outside stakeholders

(e.g., regulated community, public interest groups, and environmental groups) to consider various and

diverse interests. 

Lead Regulators

Typically, there will be a “lead regulator” who is the first-line staff person for the government authority

that is responsible for ensuring that a facility implements corrective action as necessary to meet facilityspecific corrective action goals. The lead regulator could either be a Federal employee working in an

EPA regional office or an employee of a particular State or Territory. The lead regulator is typically

responsible for a variety of activities, including, for example: 

• drafting permits, orders, or voluntary agreements; 

• reviewing documents developed by the facility;

• recommending facility-specific approaches and, where appropriate, making decisions pertaining to

a variety of corrective action issues; and

• ensuring the public has opportunities to provide input on corrective action issues. 

EPA Regional Offices

Staff within EPA’s 10 regional offices (http://www.epa.gov/correctiveaction/regions.htm) will typically

be the lead regulator for facilities located in States that have not yet been authorized (see discussion

below regarding States and Territories) to implement corrective action. Sometimes, EPA may continue

carrying out lead regulator responsibilities during early stages of a newly authorized State cleanup

program. EPA staff may also be the lead regulators on specific corrective action enforcement issues

(e.g., issuing administrative orders) in both authorized and unauthorized States. 

EPA’s regional offices are also responsible for overseeing State programs in situations where the State
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Overview, Pg. v

has the lead role for implementing corrective action. Responsibilities of that oversight role include, for

example: establishing goals, tracking progress, and reporting progress to EPA Headquarters;

developing and distributing guidance; contributing to EPA Headquarters initiatives (e.g., supplying

comments on guidance and regulations); conducting training; and providing facility-specific assistance

on technical, policy, and public participation issues.

States and Territories

Staff within State or territorial (http://www.epa.gov/correctiveaction/state.htm) cleanup programs are

typically the lead regulators for overseeing corrective action at particular facility when: (1) EPA has

authorized the State Corrective Action Program, or (2) an EPA regional office has entered into a

“worksharing agreement” with either an unauthorized or authorized State program. EPA Headquarters

supports the variety of creative approaches EPA regions and States/Territories use to work together

toward achieving corrective action goals. 

As of September 2001, EPA has authorized 38 States and Territories for facility-wide corrective action

under RCRA §3004(u). EPA’s authorization of a State Corrective Action Program is based on a

determination that the State is capable of implementing corrective action equivalently to EPA, and in a

manner consistent with applicable Federal statutes, regulations, and guidance. These authorized States

have the primary responsibility for corrective action at hazardous waste treatment, storage, and disposal

facilities (TSDFs). This responsibility includes making decisions dealing with the policies addressed in

this Handbook. You can refer to http://www.epa.gov/epaoswer/hazwaste/state/stats/maps/keychrt.pdf

or 

http://www.epa.gov/epaoswer/hazwaste/state/stats/maps/coract.pdf for a current list or map,

respectively, of the States authorized to implement RCRA corrective action. 

Federally Recognized Indian Tribes

In keeping with the EPA Policy for the Administration of Environmental Programs on Indian

Reservations (EPA, 2001a), EPA is committed to ensuring that Tribes play an active role in RCRA

corrective action when Tribal rights and interests are at stake. This commitment is clearly present when

EPA personnel serve as lead regulators for a given facility – especially when the facility is located on

Tribal or Federal lands. However, the commitment is also present when Tribes are potentially affected

by facilities regulated by authorized non-Federal regulators. While Tribal members are able to

participate as part of the established RCRA public involvement activities, Tribal governments have a

unique status and can play a more significant role. Although EPA cannot authorize a Tribe to be a lead

regulator, the Agency can enter into cooperative agreements with the Tribe, ensure the Tribe has full

access for meaningful participation in corrective action activities, and give the Tribe’s concerns special

consideration throughout the regulatory process.
6

To avoid duplicating efforts and to ensure compliance with applicable laws and regulations, EPA strongly

recommends that facilities conducting cleanup actions without oversight by an EPA or State regulator do so with a

clear understanding of applicable State and EPA requirements and implementation guidance. In particular, facilities

should be fully aware of requirements associated with managing remediation waste. For more information about

Federal requirements and implementation guidance associated with remediation waste, you should refer to

http://www.epa.gov/epaoswer/hazwaste/ca/guidance.htm#RemediationWaste. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Overview, Pg. vi

Who is the public?

The “public” in the context of RCRA

refers not only to private citizens, but

also representatives of consumer,

environmental, and minority

associations; trade, industrial,

agricultural, and labor organizations;

public health, scientific, and

professional societies; civic

associations; public officials; and

government and educational

institutions.

Facilities

Facilities subject to RCRA corrective action are responsible for conducting investigations and cleanups

as necessary to protect human health and the environment. Facilities subject to a permit, order, or

sometimes even a voluntary agreement typically present their recommendations for investigation and

cleanup activities to the lead regulator for review and

approval. However, many facilities are also proactively

conducting investigations and cleanup actions in advance of

oversight6 by a State or EPA regulator. Additionally,

many facilities are also assuming greater responsibility to

involve the public throughout corrective action. 

Public

EPA strongly encourages the public to be involved with

corrective action to help ensure protection of human health

and their environment. The RCRA statute and EPA’s

regulations and detailed guidance describe a variety of

public involvement opportunities and activities. The

following are just some of the actions you (see highlight

box) can take to help influence corrective action decisions:

• Find out if a particular facility of interest is on the list of facilities EPA believes warrant attention in

the next several years (http://www.epa.gov/epaoswer/hazwaste/ca/lists/base_sta.pdf). 

• Contact the State or EPA region to identify the lead regulator and ask for your name to be placed

on mailing lists for notices, fact sheets, and other documents distributed by EPA, the State, or the

facility; and 

• Actively participate in public hearings and other meetings.

For a more complete list of activities as well as other detailed guidance pertaining to public

participation, you should refer to EPA’s 1996 RCRA Public Participation Manual (EPA, 1996d)

available at http://www.epa.gov/epaoswer/hazwaste/permit/pubpart/manual.htm. You can also contact

EPA regional and State offices to determine whether they have additional guidance concerning public
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Overview, Pg. vii

TOPICS PRESENTED*

• Groundwater Protection and Cleanup

Strategy

• Short-Term Protection Goals

• Intermediate Performance Goals

• Final Cleanup Goals

• Groundwater Cleanup Levels

• Point of Compliance

• Cleanup Timeframe

• Source Control

• Groundwater Use Designations

• Institutional Controls

• Monitored Natural Attenuation

• Technical Impracticability 

• Reinjection of Contaminated Groundwater

• Performance Monitoring

• Completing Groundwater Remedies

* See discussion on page x of this overview

section (or click here) to see how EPA intends

to keep this Handbook current. 

involvement at corrective action facilities. 

How do the policies in this Handbook apply to State cleanup programs?

EPA expects States to consider this guidance carefully when they have a lead role in implementing

cleanups at RCRA corrective action facilities. However, as mentioned previously, this document

reflects Agency guidance and is not a binding statute or regulation. Therefore, States have considerable

latitude in making decisions that would lead to equivalent levels of protection EPA would achieve if the

Federal Government were implementing the program. Also, it is extremely important that Handbook

users consult with the appropriate State cleanup program prior to conducting corrective action to

ensure that State requirements and guidance are addressed. Some specific examples you should be

aware of with regard to State cleanup programs include:

• Some States have their own specific requirements regarding administrative procedures and cleanup

criteria (e.g., primary and secondary drinking water standards, risk levels, and exposure scenarios

for closing waste management units); such States may not be able to take advantage of some of the

approaches described in this Handbook.

• Regulators (both State and Federal) typically

make investigation and cleanup decisions on

a case-by-case basis; therefore, a particular

approach used at one facility may be

inappropriate at another facility.

How is this Handbook organized?

EPA organized this Handbook to address its

overall implementation strategy for contaminated

groundwater and to summarize and clarify

policies that are often the subject of questions

and confusion. While some topics deal with

broader issues, the primary focus of this

Handbook is on groundwater. Furthermore, the

topics addressed in this Handbook

predominantly were designed to address facilities

undergoing facility-wide corrective action under

§3004(u) and (v), and §3008(h), which were

enacted as part of the Hazardous and Solid

Waste Amendments (HSWA) to RCRA. 

However, the policies on groundwater cleanup levels and point of compliance address some questions
7

 Regulated Units are defined in 40 CFR 264.90 (available through

http://www.gpoaccess.gov/cfr/retrieve.html) as surface impoundments, waste piles, land treatment units, and

landfills that received hazardous wastes after July 26, 1982.

8

 The Post-Closure Regulations (EPA, 1998d), 63 FR 56710, October 22, 1999 (available at

http://www.epa.gov/fedrgstr/EPA-WASTE/1998/October/Day-22/f28221.pdf) provides flexibility for regulators to

replace requirements, associated with regulated units, for groundwater monitoring and corrective action for releases

to groundwater in certain circumstances (see 264.90(f)). EPA encourages States to adopt and seek authorization for

this provision, either separately or as part of the full post-closure rule; but, some States might choose not to adopt

all or parts of this rule. Pending authorization or adoption for this portion of the post-closure rule, States authorized

for corrective action would be able to implement the provision if they could do so as a matter of State law, and they

implemented it in a way that was no less stringent than Federal requirements. For more detail on authorization for the

post-closure rule see the preamble to the rule.

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Overview, Pg. viii

unique to corrective action at RCRA regulated units7. You should be aware that 40 CFR Part 264,

Subpart F includes specific groundwater monitoring and corrective action requirements for RCRA

regulated units8.

Note that key topics mentioned within the text are often underlined and “hyperlinked.” This feature

allows you to recognize and quickly go to topics that are expanded elsewhere in the Handbook. 

Where do the policies in this Handbook come from?

Most of the topics in this Handbook are already addressed in an existing EPA guidance document,

directive, or memorandum. We do not intend for this Handbook to replace previous guidance, but it

does reflect EPA’s latest thinking on groundwater policies for RCRA corrective action. 

You will notice that many of the policies come from Section III of the May 1, 1996 Advance Notice of

Proposed Rulemaking (ANPR; EPA, 1996a). EPA issued the ANPR, in part, to seek public comment

on how to address the proposed regulations for corrective action (55 FR 30798, July 27, 1990; EPA,

1990c). After considering comments on the ANPR, EPA opted against finalizing these regulations

because, among other things, the Agency decided it was not necessary for successful implementation of

the program. In fact, since a majority of the States and Territories were already authorized to

implement facility-wide corrective action in lieu of EPA, and several others were seeking authorization,

EPA decided that issuing corrective action regulations would be unnecessarily disruptive. In an

October 7, 1999 Federal Register Notice (64 FR 54604; EPA, 1999a), EPA announced its

withdrawal of most of the provisions of the 1990 proposed corrective action regulations. In this notice,

EPA stated that rather than issuing a rule to achieve consistency at all facilities, it would be more

appropriate to develop guidance and training to promote consistency, where appropriate. This

Handbook is an example of such guidance. 

The October 7, 1999 notice also stated that Section III of the ANPR should serve as the primary

corrective action implementation guidance. For that reason, the ANPR is a key reference for many of

the topics in this Handbook. Section V of the ANPR requested comments on a number of topics

addressed in this Handbook, such as the point of compliance. This Handbook does not foreclose
9

Some States may have their own terms to describe similar concepts addressed in this Handbook. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Overview, Pg. ix

further discussion of issues raised for comment in the ANPR, or any other issue discussed in this

Handbook, and EPA intends to update this Handbook as the Corrective Action Program continues to

evolve. 

EPA recognizes that some elements in this Handbook may appear new because of the names used to

describe them. For example, “Intermediate Performance Goals” is a term introduced in this Handbook;

however, it is consistent with the phased approach to corrective action that EPA emphasized in the

ANPR and other guidance going back to the early 1990s (EPA, 1991a and EPA, 1990a).

You may also notice that the choice of words to describe a policy in this Handbook may differ from the

words in the ANPR or another original source of the policy; however, the substance of the policy

remains the same. There are two primary reasons for this difference. First, we wrote this document in

“plain language” and second, the terminology in RCRA is evolving. 

“Plain language” uses everyday words, active voice, and shorter sentences. EPA has used this style to

help make documents easier to read and more understandable. While it may appear at times that EPA

has changed its position on a particular topic because we are using different words in this Handbook,

the policy is actually still the same. For example, the Handbook recommends several factors for

assessing use, value, and vulnerability of groundwater. These factors are the same factors as those

listed in the Comprehensive State Groundwater Protection Program (“CSGWPP”) Guidance (EPA,

1992a) except we modified the words to meet the goals of plain language.

Another source of perceived change stems from the maturing of RCRA corrective action terminology9. 

As the program has evolved, so have RCRA definitions. For example RCRA’s early guidance,

Subpart S (EPA, 1990c) and the ANPR, refer to point of compliance only in the context of final

cleanup. We now formally recognize that the concept of “point of compliance” can be used in the

context of short-term, intermediate, and final cleanup goals. We made this change because we

recognized that the general definition of point of compliance for groundwater applies to a variety of

situations where regulators require facilities to achieve certain concentrations of chemicals in

groundwater.

Are the policies contained in this Handbook consistent with EPA’s other cleanup programs?

The basic approaches described in this Handbook are consistent with EPA’s Superfund, Underground

Storage Tank, and Brownfields cleanup programs. Much of the Handbook is derived from guidance

developed jointly by EPA’s cleanup programs (e.g., Use of Monitored Natural Attenuation at

Superfund, RCRA and Underground Storage Tank Sites (EPA, 1999d)). This Handbook, therefore, is

consistent with EPA’s long-standing goal for EPA’s cleanup programs to yield similar remedies in

similar circumstances. To learn more about RCRA-CERCLA coordination issues, you should refer to

“Coordination between RCRA Corrective Action and Closure and CERCLA Site Activities” (EPA,
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Overview, Pg. x

1996b) available at http://www.epa.gov/correctiveaction/resource/guidance/gen_ca/coordmem.pdf and

the RCRA-CERCLA deferral policy found in 54 FR 41004-41006 (October 4, 1989b). For more

detailed information about EPA’s Superfund, Underground Storage Tank, and Brownfields cleanup

programs, you can link to their respective Internet Web sites found in Appendix 2. 

How will I know that the policies in this Handbook are current?

As necessary, EPA intends to maintain this Handbook as a living document by adding new topics, new

policies, or by changing or clarifying existing policies. Since this Handbook is guidance, EPA may

make such revisions without public notice. Therefore, if you are reading a printed copy of this

Handbook, we urge you to access the electronic version available via the Internet at

http://www.epa.gov/correctiveaction/. The front page of the Internet version will indicate the most

recent date EPA revised the Handbook. Additionally, the top of each policy section includes the date

of the most recent revision. You should compare this date to the Internet version to ensure that you are

reading the Agency’s most current guidance. 

How can I get further information about the policies in this Handbook?

You can get further information on policies in this Handbook in several ways. You can refer to the

references at the end of each policy or to the complete list of references at the end of the Handbook in

Appendix 1. Note that most references provide an Internet Web address and a “hotlink” that allows

you to directly access the document of interest. You can also get more information by contacting

individuals in EPA regional or State cleanup programs. If you are viewing this document electronically

and have access to the Internet, you can press the link to State or EPA program buttons on the

interactive button page at the beginning of the Handbook to guide you to contacts in EPA or State

offices. Internet Web links are also provided in 

Appendix 2 to help you find more information. Lastly, if you are uncertain of a meaning of a term, you

can refer to the glossary provided in Appendix 3. 

What if I have comments on this Handbook?

EPA welcomes public comments on this Handbook at any time and will consider those comments in

any future revisions. You can submit your comments to:

Corrective Action Programs Branch (mail code 5303W)

Permits and State Programs Division 

Office of Solid Waste

US Environmental Protection Agency

Ariel Rios Building

1200 Pennsylvania Avenue

Washington, DC 20460 
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Overview, Pg. xi

References:

EPA, 2001a. EPA Indian Policy (July 11). Available at

http://www.epa.gov/indian/pdfs/reaffirmindpol01.pdf. 

EPA, 2001d. RCRA Cleanup Reforms Round II - Fostering Creative Solutions (EPA/530/F-01/001,

January). Available at http://www.epa.gov/epaoswer/hazwaste/ca/reforms.htm.

EPA, 1999a. Corrective Action for Solid Waste Management Units at Hazardous Waste Management

Facilities (64 FR 54604, October 7). Available at

http://www.epa.gov/correctiveaction/resource/guidance/gen_ca/withdrwl.htm.

EPA, 1999b. Safe Drinking Water Act, Section 1429 Groundwater Report to Congress. EPA-816-

R-99-016; October, 1999. Available at http://www.epa.gov/ogwdw000/gwr/finalgw.pdf. 

EPA, 1999c. RCRA Cleanup Reforms (EPA/530/F-99/018). For more information, refer to

http://www.epa.gov/epaoswer/osw/factsheet1.pdf. 

EPA, 1999d. Use of Monitored Natural Attenuation at Superfund, RCRA Corrective Action and

Underground Storage Tank Sites (April 21). OSWER Policy Directive 9200.4-17P. Available at

http://www.epa.gov/swerust1/directiv/d9200417.htm. Other helpful links regarding MNA available at

http://www.epa.gov/swerust1/cat/mna.htm and http://www.epa.gov/swerust1/oswermna/mnalinks.htm 

EPA, 1998a. RCRA Orientation Manual (EPA/530/R-98/004). Available at

http://www.epa.gov/epaoswer/general/orientat/index.htm.

EPA, 1998d. Standards Applicable to Owners and Operators of Closed and Closing

Hazardous Waste Management Facilities: Post-Closure Permit Requirement

and Closure Process; Final Rule (63 FR 56710). Available at

http://www.epa.gov/fedrgstr/EPA-WASTE/1998/October/Day-22/f28221.pdf. 

EPA, 1997a. Memorandum from Elliott P. Laws and Steven A. Herman to RCRA/CERCLA Senior

Policy Managers titled, “Use of the Corrective Action Advance Notice of Proposed Rulemaking as

Guidance” (January 17). Available at

http://yosemite.epa.gov/osw/rcra.nsf/documents/8BF009F9B3672563852566110072DA71. 

EPA, 1996a. Advance Notice of Proposed Rulemaking (61 FR 19432, May 1). Available at 

http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/May/Day-01/pr-547.pdf. Particularly relevant

pages: 19440-55. 

EPA, 1996b. Memorandum from Steven A. Herman and Elliott P. Laws to RCRA/CERCLA Senior

Policy Managers titled, “Coordination between RCRA Corrective Action and Closure and CERCLA

Site Activities” (September 24). Available at
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Overview, Pg. xii

http://www.epa.gov/correctiveaction/resource/guidance/gen_ca/coordmem.pdf. 

EPA, 1996d. RCRA Public Participation Manual ( EPA/530/R-96/007). Available at

http://www.epa.gov/epaoswer/hazwaste/permit/pubpart/manual.htm. Particularly relevant pages: 2.5-

2.7. 

EPA, 1992a. Final Comprehensive State Groundwater Protection Program Guidance (EPA/100/R93/001). Available at 

http://www.epa.gov/correctiveaction/resource/guidance/gw/csgwpp.htm. 

EPA, 1991a. Managing the Corrective Action Program for Environmental Results: The RCRA

Stabilization Effort (October 25). Available at http://yosemite.epa.gov/osw/rcra.nsf/

d8382df2d09b64668525652800519745/27d1baa5c1dbb8f38525670f006be76d?OpenDocument.

EPA, 1990a. The Nation’s Hazardous Waste Management Program at a Crossroads: The RCRA

Implementation Study (EPA/530/SW-90/069). 

EPA, 1990c. Corrective Action for Solid Waste Management Units at Hazardous Waste management

Facilities; Proposed Rule (55 FR 30798, July 27). 

EPA, 1989b. National Priorities List for Uncontrolled Hazardous Waste Sites – Final Rule Covering

Sites Subject to the Subtitle C Corrective Action Authorities of the Resource Conservation and

Recovery Act (commonly referred to as the RCRA Deferral Policy). Available in Section V which

appears on 54 FR 41004-41006. Available at

http://www.epa.gov/superfund/sites/npl/f891004.htm#41000.
1

 EPA recognizes that groundwater serves a variety of uses and purposes, including for example, drinking

water, agricultural irrigation, and discharge to adjacent groundwater and surface water bodies. As such, EPA also

recognizes that there could be a variety of ways humans as well as ecological receptors (including aquatic fauna

residing in groundwater) can be exposed to contaminated groundwater. Within the range of reasonably expected

uses and exposures, the maximum beneficial groundwater use is the one that warrants the most stringent

groundwater cleanup levels and approaches.

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Groundwater Strategy, Pg. 1.1

Rationale for

Groundwater Protection and

Cleanup Strategy

Based on EPA’s experience with

environmental cleanups over the past 20

years, it is clear that addressing

contaminated groundwater is challenging

from both a resource and technology

perspective. Therefore, EPA believes its

strategy involving short-term, intermediate,

and final goals provides a realistic approach

that focuses resources on the greatest

threats first and emphasizes results rather

than a particular process. This strategy

emphasizes protection and cleanup of

groundwater by using meaningful and

measurable milestones, as well as clear and

effective communication.

1. Groundwater Protection and Cleanup Strategy

(September 2001)

What is EPA’s groundwater protection and cleanup strategy for RCRA corrective action?

EPA’s groundwater strategy generally is to:

• focus resources at facilities that warrant attention in the near term; 

• control short-term threats; 

• prioritize actions within facilities to address the greatest risks first; and

• make progress toward the ultimate goal of returning contaminated groundwater to its maximum

beneficial use1. 

This strategy guides regulators and facilities toward achieving environmental results rather than following

any particular administrative process, and emphasizes clear communication among all stakeholders. 

This strategy is consistent with the phased approaches recommended in past Agency guidance (EPA,

1990a; EPA, 1991a; EPA, 1994b, EPA, 1996a; EPA, 1996c, and others), and is also consistent with

EPA’s overall groundwater protection and cleanup

goals described below. 

How does this strategy benefit the public,

regulators, and facilities?

This strategy benefits the public because it

promotes early actions and continued progress

toward our overall groundwater protection and

cleanup goals. Regulators benefit because it helps

them focus their oversight resources on defining,

tracking, and, if necessary, enforcing measurable

milestones. Facilities benefit because the strategy

helps them plan for investigation and cleanup

actions. 

What is EPA’s overall goal for groundwater

protection and cleanup? 
2

 The term “restore” or “restoration” used in this context refers to achieving a certain cleanup level(s) 

developed to ensure protection based on maximum beneficial use of the groundwater at a particular facility. 

Restoring contaminated groundwater does not necessarily imply cleanup to pristine conditions. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Groundwater Strategy, Pg. 1.2

EPA’s overall goal with respect to groundwater is to prevent adverse affects to human health and the

environment, which includes protecting the integrity of the nation’s groundwater resources, both now

and in the future (EPA, 1991b). EPA believes that short-term prevention and long-term cleanup goals

are both essential elements of a strategy designed to achieve this overall goal. 

With respect to prevention, we should protect groundwater to: (1) ensure that the nation’s public and

private drinking water supplies, including those currently used as well as those reasonably expected to

be used, do not cause adverse health effects both in the short term as well as for future generations;

and, (2) avoid negative impacts to ecosystems such as those caused by contaminated groundwater

flowing into surface water (EPA, 1991b). 

With respect to cleanup of contaminated groundwater, facilities as well as regulators should generally:

(1) prioritize cleanup activities to limit the risk to human health first; and then, (2) restore2 currently used

and reasonably expected sources of drinking water and groundwater closely hydraulically connected to

surface waters, whenever such restorations are practicable and attainable (EPA, 1991b). 

Stakeholders evaluating appropriate prevention and cleanup strategies should consider use, value and

vulnerability of the groundwater resources, as well as social and economic values. For more

information regarding this overall goal, refer to “Protecting the Nation’s Groundwater: EPA’s Strategy

for the 1990's” (EPA, 1991b). The groundwater protection and cleanup strategy presented in this

Handbook supports EPA’s overall groundwater goals. 

How should facilities and regulators implement this groundwater protection and cleanup

strategy for RCRA corrective action?

EPA recommends that regulators and facilities implement this strategy in terms of short-term protection

goals, intermediate performance goals, and final cleanup goals. You can find more detailed descriptions

of these goals later in this Handbook. 

How do short-term, intermediate and final cleanup goals work together to achieve EPA’s

overall groundwater goals? 

EPA believes its strategy (see Figure 1) to implement corrective action in terms of short-term,

intermediate, and final cleanup goals is an efficient and effective way to satisfy RCRA’s statutory

mandate to protect human health and the environment both now and in the future. EPA does not view

these three goals as discrete elements; rather, EPA designed them to support each other toward

achieving EPA’s overall groundwater protection and cleanup goals. 
3

Short-term in this context refers to the Corrective Action Program’s Year 2005 goals EPA established in

response to the Government Performance and Results Act. Refer to the Short-Term Protection Goals section of this

Handbook for specific information pertaining to these short-term goals. 

4

 Cleaning up contaminated groundwater can be very challenging; therefore, this element of the overall

strategy is designed to prevent existing problems associated with contaminated groundwater from getting worse. 

5 You can learn more about these two indicators at http://www.epa.gov/correctiveaction/eis.htm. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Groundwater Strategy, Pg. 1.3

Figure 1: Relationship between short-term, intermediate, and final corrective action cleanup goals. 

In the short-term3, EPA believes it is important that facilities take actions as soon as possible to ensure

that (1) humans are not being exposed to unacceptable levels of contamination, and (2) contaminated

groundwater is not continuing to migrate beyond its current extent4. EPA measures these short-term

protection goals with two environmental indicators5 called “Current Human Exposures Under Control”

and “Migration of Contaminated Groundwater Under Control” (EPA, 1999e). EPA has found that

these environmental indicators are proving to have benefits beyond just demonstrating facilities are

meeting these two important goals. For example, clear, achievable, and meaningful milestones

associated with environmental indicators help promote effective working relationships between
6

See glossary for definition of “remedy expectations” used in the context of the RCRA Corrective Action

Program. 

7

EPA recognizes that most States classify the majority of their groundwater as potential sources of

drinking water. Refer to the Final Remedy, Point of Compliance and Groundwater Use Designation sections of this

Handbook for further discussion on final cleanup goals, the role of groundwater use in the RCRA Corrective Action

Program, and additional guidance concerning groundwater use decisions and exposures associated with various

uses/purposes of groundwater. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Groundwater Strategy, Pg. 1.4

stakeholders. These relationships often foster creative, results-based approaches that are increasing the

overall pace, efficiency and effectiveness of subsequent actions leading to final cleanup goals. 

Furthermore, the actions facilities take to achieve these goals should often help them achieve the final

goals. For example, stopping a plume of contaminated groundwater from getting bigger in the short

term limits the extent of the problem the facility will have to address to achieve final cleanup goals. 

With respect to final cleanup goals for contaminated groundwater, EPA expects6 to return usable

groundwater to its maximum beneficial use wherever practicable within a timeframe that is reasonable

given the particular circumstances of the facility. EPA recognizes, however, that some States determine

that certain groundwater is either not usable and/or they have no intention to use it in the foreseeable

future7. For such situations, EPA acknowledges that final cleanup goals such as source control and

long-term plume containment may provide an appropriate level of protection to human health and the

environment (EPA, 1996c and 1997b). However, prior to selecting such alternatives, regulators should

ensure that other exposures to contaminants in or from groundwater do not exist and the groundwater is

not used for purposes not recognized in, for example, a “non-use” State designation. Regardless of the

approach, clear final cleanup goals are important because they provide the target to which regulators

and facilities should focus their activities. Establishing clear final cleanup goals should also help facilities

determine what they will have to do to implement a successful final remedy.

Intermediate performance goals can often serve as helpful milestones between short-term and final

cleanup goals. EPA recognizes, as does the general scientific community (NRC, 1994), that achieving

cleanup goals for contaminated groundwater can be very challenging. For some facilities, these

challenges can appear to be so insurmountable that moving directly to, for example, returning all of the

contaminated groundwater to its maximum beneficial use diminishes the ability of regulators and facilities

to identify a realistic path forward. Therefore, for such facilities, EPA recommends that facilities and

regulators consider developing a series of facility-specific intermediate performance goals designed to

promote continuous progress toward the final cleanup goals. 

How should facilities and regulators implement these goals? 

EPA recommends that facilities implement short-term protection, intermediate performance, and final

cleanup goals in terms of clearly defined, facility-specific media cleanup objectives. These objectives

typically include elements that clearly define “what, where, and when.” The first element defines what

action the facility should conduct. The second element defines where the specific action should take
8

Previous guidance (EPA, 1996a) referred to “Cleanup timeframes” as compliance timeframes.

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Groundwater Strategy, Pg. 1.5

place. The third element defines when the facility should implement and complete an action. 

Along with defining “what, where, and when,” EPA also recommends that facilities and regulators

describe actions in terms of “who, why, and how.” Describing “who” performs an action helps

communicate to the public the different roles and responsibilities of the facility and the regulator. 

Describing “why” provides the opportunity to explain the relationship between particular actions and

how they help achieve short-term, intermediate, or final goals. And lastly, describing “how” ensures

that stakeholders understand the techniques and approaches that a facility will use to implement an

activity. 

Implementing goals in terms of “what, where, and when” is not a new approach to corrective action but

rather a clarification of “cleanup objectives” as described in the May 1, 1996 Advance Notice of

Proposed Rulemaking (ANPR - EPA, 1996a; page 19449). For example, to measure achievement of

final groundwater cleanup goals, the ANPR described final cleanup objectives in terms of (1)

groundwater cleanup levels, (2) the point of compliance, and (3) cleanup timeframes8 (see EPA, 1996a

- page 19449). For such final groundwater remedies, groundwater cleanup levels represent the “what,”

point of compliance represents the “where,” and cleanup timeframes represent the “when” associated

with implementing a groundwater remedy and estimates on how long it would take to achieve the final

cleanup goals. 

EPA encourages facilities and regulators to describe short-term, intermediate, and final cleanup goals in

terms of “what, where, when, who, why, and how” to enhance and clarify communication among all

stakeholders. 

References: 

EPA, 1999e. Interim Final Guidance for RCRA Corrective Action Environmental Indicators (February

5). Available at http://www.epa.gov/correctiveaction/eis/ei_guida.pdf. 

EPA, 1997b. Rules of Thumb for Superfund Remedy Selection (EPA/540/R-97/013). Available at

http://www.epa.gov/superfund/resources/rules/rulesthm.pdf. Particularly relevant page: 17.

 

EPA, 1996a. Advance Notice of Proposed Rulemaking (61 FR 19432, May 1). Available at 

http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/May/Day-01/pr-547.pdf. Particularly relevant

pages: 19440-55. 

EPA, 1996c. Presumptive Response Strategy and Ex-Situ Treatment Technologies for Contaminated

Groundwater at CERCLA Sites (EPA/540/R-96/023, October). Available at

http://www.epa.gov/superfund/resources/gwguide/index.htm. Particularly relevant pages: 15-17.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Groundwater Strategy, Pg. 1.6

EPA, 1994b. The RCRA Corrective Action Plan (EPA/520/R-94/004, May). Available at

http://www.epa.gov/correctiveaction/resource/guidance/gen_ca/rcracap.pdf.

EPA, 1991a. Managing the Corrective Action Program for Environmental Results: The RCRA

Stabilization Effort (October 25). Available at http://yosemite.epa.gov/osw/rcra.nsf/

d8382df2d09b64668525652800519745/27d1baa5c1dbb8f38525670f006be76d?OpenDocument.

EPA, 1991b. Protecting the Nation’s Groundwater: EPA’s Strategy for the 1990's. Office of the

Administrator. Washington, D.C. Available at

http://www.epa.gov/superfund/resources/remedy/pdf/21z-1020-s.pdf.

EPA, 1990a. The Nation’s Hazardous Waste Management Program at a Crossroads: The RCRA

Implementation Study (EPA/530/SW-90/069). 

NRC, 1994. Alternatives for Ground Water Cleanup / Committee on Ground Water Cleanup

Alternatives, Water Science and Technology Board, Board on Radioactive Waste Management,

Commission on Geosciences, Environment, and Resources, National Research Council. National

Academy Press, 1994. Available at http://www.nap.edu/books/0309049946/html/. 
1

EPA’s short-term goals apply to all contaminated media, not just groundwater. For example, our shortterm goals associated with protecting humans include ensuring that humans are not being exposed to unacceptable

levels of contaminants in soils. However, we focus here on short-term goals associated with groundwater

contamination because the focus of this Handbook is on groundwater. 

2

Levels of concern are concentrations of each contaminant in groundwater appropriate for the protection

of the groundwater resource typically based on its maximum beneficial use.

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Short-Term Goals, Pg. 2.1

Rationale for

Short-Term Protection Goals 

The highest short-term priorities of the

RCRA Corrective Action Program are to

make sure that people are not being

exposed to unacceptable levels of

contaminants and to prevent further

contamination of our Nation’s groundwater

resources. While final remedies remain

the RCRA Corrective Action Program’s

long-term objective, EPA developed two

environmental indicators to focus efforts on

early risk reduction, risk communication,

and resource protection. This focus on

short-term protection goals enables the

Agency to achieve an increased overall

level of protection by implementing a

greater number of actions across many

facilities.

2. Short-Term Protection (Environmental Indicator) Goals

(September 2001)

What are EPA’s short-term protection goals for groundwater?

EPA’s short-term goals associated with groundwater1 are to ensure that (1) humans are not being

exposed to unacceptable levels of contamination, and (2) contaminated groundwater is not migrating

above levels of concern2 beyond its current extent

(EPA, 1999e).

How does EPA monitor progress toward these

goals?

EPA developed two facility-wide “environmental

indicators” to help monitor progress in achieving

short-term protection goals on a national basis. The

two environmental indicators (EIs) are called

“Current Human Exposures Under Control” and

“Migration of Contaminated Groundwater

Under Control.” EPA commonly refers to these

two environmental indicators as the Human EI and

Groundwater EI, respectively. In general terms,

these measures indicate current “environmental

conditions”-- whether people are currently being

exposed to environmental contamination at

unacceptable levels -- and whether any existing

plumes of contaminated groundwater are getting

larger or adversely affecting surface water bodies. 

EPA is specifically tracking progress in meeting these

environmental indicator goals at 1,714 facilities that EPA considers to warrant attention in the near

term; you can see this list of facilities at http://www.epa.gov/epaoswer/hazwaste/ca/facility.htm.

EPA is using these two environmental indicators to monitor progress in response to the Government

Performance and Results Act (GPRA - see http://www.epa.gov/ocfo/planning/gpra.htm). EPA’s

specific GPRA goals for these indicators are as follows: By 2005, the States and EPA will verify and
3 Contamination in this context describes media containing contaminants in any form (e.g., non-aqueous

phase liquids, dissolved in water, vapors, and solids) that are subject to RCRA corrective action and present in

concentrations in excess of appropriately protective levels of concern. 

4 A plume getting larger typically refers to groundwater contamination above levels of concern moving

beyond a previously defined furthest three-dimensional extent of the contaminant plume.

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Short-Term Goals, Pg. 2.2

document that 95 percent of the GPRA baseline facilities will have “Current Human Exposures Under

Control” and 70 percent will have “Migration of Contaminated Groundwater Under Control.” You can

see the progress toward achieving these goals at

http://www.epa.gov/epaoswer/hazwaste/ca/facility/stofrcra.htm. 

Who evaluates and determines whether a facility meets environmental indicator goals? 

The lead regulator makes the actual environmental indicator determination. However, EPA, States, or

the facility (or the facility’s consultant) can conduct an environmental indicator evaluation. EPA

developed environmental indicator forms to guide regulators and facilities through this evaluation. In

some cases, facilities have voluntarily filled out environmental indicator forms to “self-assess” their status

and have even initiated activities on their own to meet the environmental indicators. You can obtain

these environmental indicator forms at http://www.epa.gov/correctiveaction/eis.htm.

How should regulators and facilities evaluate environmental indicators? 

EPA issued detailed guidance (EPA, 1999e) to help those conducting environmental indicator

evaluations; you can access that guidance at http://www.epa.gov/epaoswer/hazwaste/ca/eis.htm. The

guidance includes a series of questions and a flow chart to help arrive at one of the following three

possible outcomes: YES, the facility has achieved an environmental indicator goal; NO, the facility has

not achieved an environmental indicator goal; or, IN, there is insufficient information available to

determine whether or not a facility has achieved an environmental indicator goal. 

How does a facility get to YES?

For the Current Human Exposures Under Control environmental indicator, a facility should be able to

demonstrate that there are no unacceptable human exposures to contamination3 that can be reasonably

expected under current land and groundwater use conditions. For the Migration of Contaminated

Groundwater Under Control environmental indicator, a facility should be able to demonstrate that

contaminant plumes throughout the facility are not continuing to get larger4 or continuing to negatively

impact adjacent surface water bodies, and that the facility will monitor groundwater to verify whether

the environmental indicator determination remains valid. 

Facilities typically meet these goals either by: (1) demonstrating that no cleanup actions are warranted;

(2) taking short-term cleanup actions sometimes referred to as interim remedial measures, interim
5

The term stabilization used in this context refers to “stabilizing” a situation so that, for example, the

contamination does not represent unacceptable threats or does not continue to spread. Stabilization used in this

context does not refer to engineered treatment used to “solidify” wastes although such technologies could be used

as a stabilization action. For more information on the RCRA Corrective Action Program’s stabilization initiative, refer

to EPA, 1991a and EPA, 1996a.

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Short-Term Goals, Pg. 2.3

measures, interim actions, or stabilization5 measures; or (3) implementing a final remedy that also meets

short-term cleanup goals. 

How should facilities and regulators develop facility-specific short-term protection goals?

Facilities and regulators should work together, with the input from the public as appropriate, to develop

clearly defined objectives focused on meeting short-term protection goals. As described in the

Groundwater Protection and Cleanup Strategy in this Handbook, EPA recommends these objectives

be expressed in terms of what actions the facility will take, and where and when the facility will take the

action. 

If some form of cleanup action is needed to achieve the Current Human Exposures Under Control

indicator, stakeholders should understand: 

• What action the facility will take to ensure that there are no current or near-term future

unacceptable exposures to contaminated groundwater. For example, the facility might provide for

alternative water supplies to eliminate exposure due to contaminated groundwater in residential

wells.

• Where the facility will implement an action to eliminate unacceptable human exposures to

contamination from groundwater. 

• When the facility will eliminate all unacceptable human exposures to contaminants from

groundwater. 

To achieve the Migration of Contaminated Groundwater Under Control indicator when contaminants

are present in groundwater above levels of concern, stakeholders should understand:

• What the levels of concern are for defining the current limit of the groundwater contaminant plume.

• Where the current three-dimensional limit of the groundwater contaminant plume is, as defined by

the levels of concern, and where the facility will monitor groundwater to demonstrate that they

achieved and will continue to achieve the prevention of further migration of contaminated

groundwater above levels of concern. 

• When the facility will be able to demonstrate that the groundwater contaminant plume is not

migrating above levels of concern. 
6

Facilities and regulators typically define a plume boundary based on estimating a division between where

groundwater is contaminated above and below levels of concern. They commonly make this estimate based on

professional interpretation (often with the aid of computer software) of chemical analyses of groundwater samples

collected from properly located monitoring wells or other monitoring devices. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Short-Term Goals, Pg. 2.4

If a cleanup action is needed to achieve a particular goal, EPA believes all interested stakeholders,

particularly the public, will benefit from a clear understanding of who is taking the action(s), why they

are taking the action(s), and how they will implement the action. For example, all interested members

of the public might not realize that the facility, rather than the government, is responsible for

implementing a particular cleanup. Furthermore, communicating “why” can help the public understand

the reasoning behind selecting, for example, a particular treatment technology such as a subsurface

treatment wall as compared with a pump-and-treat approach to clean up contaminated groundwater. 

Communicating “how” can help educate stakeholders about the particular steps involved with

implementing a remedy. For example, during installation of a subsurface treatment wall, stakeholders

may be interested in how contaminated soils and other contaminated media will be managed. 

How should facilities and regulators consider groundwater use when evaluating “Current

Human Exposures Under Control?” 

The individual conducting the environmental indicator evaluation should first consider whether there is

any current human exposure to contaminated groundwater. This determination relies on actual current

conditions rather than on a groundwater use designation or its potential uses. In making this

environmental indicator determination, the regulator should consider all direct and indirect ways humans

could currently be exposed to contaminated groundwater. Some examples of direct routes of exposure

include drinking contaminated groundwater or having skin come into contact with contaminated

groundwater from bathing. Examples of indirect exposure include breathing contaminated vapors

entering buildings from underlying contaminated groundwater, and ingesting sediments, surface water,

or fish that are contaminated from groundwater discharging to surface water.

How should facilities and regulators evaluate the “Migration of Contaminated Groundwater

Under Control” indicator?

The individual conducting the evaluation should first be reasonably confident that the furthest threedimensional boundary of the groundwater contaminant plume(s) is defined using an appropriate number

and location of groundwater monitoring wells (or some other devices approved by the regulator to

assess groundwater quality)6. To achieve a YES determination, the evaluator should be able to

demonstrate that the plume is not continuing to expand above contaminant-specific levels of concern. 

The evaluator should base this determination on whether the contaminant concentrations found in the

groundwater near the outer perimeter of the plume remain below the levels of concern over time. 

Levels of concern used for this indicator would commonly be the groundwater clean-up levels

developed to be consistent with the groundwater use designation and considering other current routes

of exposure from contaminated groundwater. However, early in corrective action, regulators could be
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Short-Term Goals, Pg. 2.5

evaluating environmental indicators prior to designating groundwater use or developing final cleanup

levels. In such situations, regulators often use readily available screening levels (e.g., drinking water

standards) to define a plume boundary. Generally, drinking water standards will be acceptable to

define the boundary of a plume when evaluating this environmental indicator unless more stringent levels

are needed based on other actual exposures to contaminated groundwater.

Can a facility achieve the “Migration of Contaminated Groundwater Under Control”

indicator when the plume extends beyond the facility boundary?

EPA typically does not differentiate on-site contaminated groundwater from off-site contaminated

groundwater as a factor in determining whether a facility achieves the groundwater environmental

indicator (EPA, 1999e). The primary intent of this indicator is to demonstrate that groundwater

problem is not expanding, regardless of whether the contamination is on-site or off-site. However,

cleanup of the off-site plume will often be a high priority and may be an appropriate intermediate

performance goal because facilities typically have less ability to control exposures outside the boundary

of their property.

Can a facility achieve the “Migration of Contaminated Groundwater Under Control”

indicator when contaminated groundwater discharges to surface water?

According to EPA guidance (EPA, 1999e), a facility could potentially achieve this indicator if the

regulator determines that the discharge of contaminated groundwater into surface water is currently

acceptable. “Currently acceptable” in this context means that the current discharge of contaminated

groundwater into surface water does not cause unacceptable impacts to surface water, sediments, or

ecosystems in ways that should not be allowed to continue until the facility implements a remedy

selected to achieve final cleanup goals. 

Appropriate levels for surface water protection should generally be based on the designated uses of the

impacted surface waters and available Federal water quality criteria or State water quality standards for

any of the contaminants found in the discharging ground water. Regulators and facilities should also

evaluate possible adverse effects of the groundwater discharge for actual pathways of exposure to

humans or aquatic life. Based on these evaluations, facilities and regulators should verify whether

available generic cleanup values will protect the surface water and its sediments. If generic cleanup

values are not available, facilities should propose facility-specific groundwater cleanup levels designed

to prevent appropriate water quality standards in the surface water body from being exceeded, and to

prevent unacceptable risks to human health or the environment. 

For additional information concerning groundwater/surface water interaction, contact the State cleanup

program because many States have specific groundwater cleanup levels based on protecting surface

water bodies. Links to State cleanup programs are available at

http://www.epa.gov/correctiveaction/state.htm. Additional resources you may find helpful include the

Proceedings of the Groundwater/Surface Water Interaction Workshop (EPA, 2000c) available at

http://www.epa.gov/tio/tsp/download/gwsw/gwsw_part1.pdf and information regarding sediments
7

 A TMDL is a calculation of the maximum amount of a pollutant that a water body can receive and still

meet water quality standards, and an allocation of that amount to the pollutant's sources. For more information on

TMDLs, refer to http://www.epa.gov/owow/tmdl/intro.html.

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Short-Term Goals, Pg. 2.6

available at http://www.epa.gov/OST/cs/. Facilities or regulators evaluating environmental indicators

for situations where contaminated groundwater is entering surface water should also consider Total

Maximum Daily Loads (TMDLs7) for the receiving surface water; additional information concerning

TMDLs is available at http://www.epa.gov/owow/tmdl/. 

Will an environmental indicator evaluation require additional investigation?

The act of evaluating environmental indicators should not result in additional investigations beyond those

that would typically be conducted to support facility-wide corrective action. However, pursuing

environmental indicators may result in collecting information earlier than when a facility was planning to

conduct a more comprehensive, site-wide investigation needed to support, for example, final cleanup

goals. 

Do facilities need to perform additional investigation or cleanup, once they achieve the

environmental indicator goals?

Achieving the environmental indicator goals is an important milestone but does not relieve a facility from

meeting other investigation objectives or from meeting any facility-specific intermediate performance

goals and final cleanup goals. The facility will often need to conduct further investigation to support

evaluation and selection of final remedies. Furthermore, the facility may need to conduct remedial

actions that might be outside the scope of these two environmental indicators to achieve other shortterm, intermediate, and final goals for groundwater (e.g., returning contaminated groundwater to its

maximum beneficial use).

Do facilities need to control sources to meet the environmental indicator goals?

Source control may not always be necessary to meet the environmental indicator goals. For example, a

facility could meet the Migration of Contaminated Groundwater Under Control indicator, without

controlling an original source, by installing a pump-and-treat system designed to stop the further

migration of the outer fringes of a plume of contaminants dissolved in groundwater. However, there are

many instances where source control would be essential to meeting these goals. For example, source

control of some kind would typically be necessary to achieve the Human Exposures Under Control

indicator if there were direct human exposures to the source material, such as an old disposal area with

no covering and unrestricted access. Two examples of situations that would typically warrant source

control to achieve the Migration of Contaminated Groundwater Under Control indicator would be if a
8

 Additional information and reports concerning NAPL contamination is available at

http://www.epa.gov/oerrpage/superfund/resources/gwdocs/non_aqu.htm See also EPA, 1995b and 1994c. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Short-Term Goals, Pg. 2.7

non-aqueous phase liquid8 (NAPL) was directly discharging to a stream, or where a mobile NAPL

plume was migrating faster (and farther) than the dissolved contaminants moving with groundwater. 

Source control is often still desirable in many circumstances because minimizing any further releases into

the environment is often easier to manage than trying to clean up contaminants after they have spread. 

Furthermore, to meet final cleanup goals, EPA expects that facilities will need to control or eliminate

surface and subsurface sources of groundwater contamination as necessary to protect human health and

the environment. 

Are these two environmental indicators the only short-term protection goals facilities should

consider?

EPA chose these two indicators as significant short-term protection goals to track on a national basis. 

However, facilities may need to take other short-term actions to protect receptors when site conditions

warrant. For example, a facility might need to take action to protect ecological receptors that are

currently exposed to facility contaminants. Furthermore, EPA’s focus on the two environmental

indicators should not deter facilities from taking any other short-term actions to protect human health or

the environment, or from taking early action to prevent environmental problems from getting worse. 

References: 

EPA, 2000c. Proceedings of the Ground-Water/Surface-Water Interactions Workshop (EPA/542/R00/007, July). Available at http://www.epa.gov/tio/tsp/download/gwsw/gwsw_part1.pdf,

http://www.epa.gov/tio/tsp/download/gwsw/gwsw_part2.pdf, and

http://www.epa.gov/tio/tsp/download/gwsw/gwsw_part3.pdf.

EPA, 1999e. Interim Final Guidance for RCRA Corrective Action Environmental Indicators (February

5). Available at http://www.epa.gov/epaoswer/hazwaste/ca/eis/ei_guida.pdf. 

EPA, 1996a. Advance Notice of Proposed Rulemaking (61 FR 19432, May 1). Available at 

http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/May/Day-01/pr-547.pdf. Particularly relevant

pages describing the stabilization initiative and environmental indicators on 19436-37, and discussion of

interim measures on page 19446-47. 

EPA, 1995b. Groundwater Issue: Light Non-Aqueous Phase Liquids (EPA/540/S-95/500). Available

at http://www.epa.gov/ada/download/issue/lnapl.pdf. 

EPA, 1994c. DNAPL Site Characterization (EPA/540/F-94/049). Available at

http://www.epa.gov/oerrpage/superfund/resources/gwdocs/dnapl.pdf. 
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Short-Term Goals, Pg. 2.8

EPA, 1991a. Managing the Corrective Action Program for Environmental Results: The RCRA

Stabilization Effort (October 25). Available at http://yosemite.epa.gov/osw/rcra.nsf/

d8382df2d09b64668525652800519745/27d1baa5c1dbb8f38525670f006be76d?OpenDocument.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Intermediate Goals, Pg. 3.1

Rationale for

Intermediate Performance

Goals 

EPA’s approach for intermediate

performance goals recognizes that for

many sites, using a “phased-approach” is

often appropriate for complex groundwater

cleanups. Establishing site-specific

intermediate performance goals provides a

mechanism to prioritize work and

measure progress toward achieving longterm goals.

3. Intermediate Performance Goals

(September 2001)

What are intermediate performance goals for groundwater?

Intermediate performance goals are facility-specific environmental conditions or measures that

demonstrate progress towards achieving the final cleanup goals. EPA refers to these goals as

“intermediate” because actions taken to meet these

goals will typically occur after a facility achieves its

short-term protection goals, but before they achieve

all final cleanup goals. EPA encourages regulators

and facilities to establish intermediate goals when they

can use such goals to demonstrate progress toward

the ultimate final cleanup goals and: 

• help focus resources,

• improve environmental conditions, or

• enhance performance of a cleanup action.

Achieving intermediate performance goals does not

relieve a facility from meeting any facility-specific

investigation or cleanup actions necessary to achieve

final cleanup goals. 

How can intermediate performance goals help me?

Intermediate performance goals help facilities, regulators, and the public see and document progress

towards meeting final cleanup goals. 

Intermediate performance goals also help to prioritize work necessary to meet the final cleanup goals. 

Facilities may use intermediate performance goals to outline a phased approach toward the cleanup. A

phased approach allows a facility to use information obtained from previous phases to plan and refine

subsequent work (EPA, 1996a and EPA, 1996c). Facilities can also direct response actions to

achieve intermediate performance goals at high-priority areas of the facility first, and address lower

priority areas at a later time. 

Intermediate performance goals may also serve to bridge differences in opinion between regulators,

facilities, and the public on the scope of environmental response at a facility. There may be consensus

on intermediate actions that facilities can take that provide significant environmental benefit while

stakeholders continue to negotiate issues associated with final cleanup goals. 
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Intermediate Goals, Pg. 3.2

Are intermediate performance goals appropriate for all facilities?

No. For example, intermediate performance goals may not be appropriate for those situations where

facilities can achieve final cleanup goals in a relatively short period of time (e.g., months to several

years). 

When should facilities and regulators establish intermediate performance goals?

Regulators and facilities should establish intermediate performance goals as part of a final remedy to

create milestones of environmental progress. However, where significant uncertainties exist as to what

a final remedy should involve and could achieve, EPA believes it may be appropriate to establish and

strive to achieve intermediate performance goals prior to a formal evaluation and selection of a final

remedy. In this latter situation, stakeholders could use the information gained from implementing actions

to achieve the intermediate performance goals to help improve the effectiveness and efficiency of the

final remedy. 

How should facilities and regulators develop facility-specific intermediate performance

goals?

Facilities and regulators should work together, with the input from the public as appropriate, to develop

clearly defined objectives focused on meeting intermediate performance goals. As described in the

Groundwater Protection and Cleanup Strategy in this Handbook, EPA recommends these objectives

be expressed in terms of what actions the facility will take, and where and when the facility will take the

action. 

If some form of cleanup action is needed to achieve an intermediate performance goal, stakeholders

should understand: 

• What the specific goals are and what actions the facility will take to achieve those goals. 

• Where the facility will implement an action and/or where the facility will measure to determine if the

action has been successful. 

• When the facility can implement a remedy and achieve facility-specific intermediate goals (cleanup

timeframe). 

In addition to these three elements, EPA believes stakeholders should also clearly understand who is

taking the responsibility for implementing an action designed to achieve a particular intermediate

performance goal, why they are taking the action, and how they are going to implement the action. 

What are some examples of intermediate performance goals?

Some examples of intermediate performance goals include: source control (e.g., various combinations
1

For more information, refer to the Monitored Natural Attenuation section of this Handbook and EPA,

1999d.

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Intermediate Goals, Pg. 3.3

of removal, treatment, and containment), plume size reduction, cleaning up off-site plumes, prioritizing

work, and remedy performance enhancements. For example: 

Source control: A facility is pumping and treating groundwater to prevent a contaminant plume from

migrating off-site. The site investigation identifies an area of soil contaminated with chlorinated solvents

that appears to be contributing to the groundwater contamination. The facility estimates if they clean up

the contaminated soil (using soil vapor extraction) to a particular level as an intermediate performance

goal, monitored natural attenuation1 will have a greater likelihood of being able to address the remaining

groundwater contamination. 

Cleaning up off-site plumes: A facility has an off-site plume and had to install vapor recovery

systems under individual homes to eliminate exposures to indoor air impacted by contaminated

groundwater. By focusing on achieving cleanup levels in groundwater off site as an intermediate

performance goal, the facility is able to reduce its long-term liabilities associated with relying solely on

the in-home vapor recovery systems to ensure protection. 

Prioritizing work: A large industrial facility identifies several areas that need to be addressed, but has

limited resources available for cleanup. The regulator and facility work together to establish a sequence

of intermediate goals directed toward achieving the final cleanup goal. In establishing the sequence of

work to be conducted, the regulator and facility consider the relative risk and/or potential environmental

harm associated with the current contamination in the different areas. They then can establish a series

of intermediate goals with different cleanup timeframes for the different areas based on the relative risk. 

The result is that the most environmentally significant areas are cleaned up first, and the facility is able to

budget resources efficiently.

Why is it important to establish intermediate performance goals on a facility-specific basis?

Intermediate performance goals should be specific to the environmental problem(s) that need to be

solved at a facility. The environmental benefit of a particular intermediate performance goal will vary for

different facilities based on the type of contaminants, environmental receptors, anticipated timing of

groundwater use, and the current extent of contamination, among other factors. Therefore, EPA

cautions stakeholders against automatically applying an intermediate performance goal that makes sense

at one facility to another facility since no two facilities are exactly alike. For example, controlling a

source of contamination at one facility as an intermediate performance goal may be appropriate, while

at another facility, controlling a source might be more appropriately addressed as part of a short-term

or final cleanup action. 

References: 
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Intermediate Goals, Pg. 3.4

EPA, 1999d. Use of Monitored Natural Attenuation at Superfund, RCRA Corrective Action and

Underground Storage Tank Sites (April 21). OSWER Policy Directive 9200.4-17P. Available at

http://www.epa.gov/swerust1/directiv/d9200417.htm. Other helpful links regarding MNA available at

http://www.epa.gov/swerust1/cat/mna.htm and http://www.epa.gov/swerust1/oswermna/mnalinks.htm.

EPA, 1996a. Advance Notice of Proposed Rulemaking (61 FR 19432, May 1). Available at 

http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/May/Day-01/pr-547.pdf. Particularly relevant

page (pertaining to phasing remedies): 19441. 

EPA, 1996c. Presumptive Response Strategy and Ex-Situ Treatment Technologies for Contaminated

Groundwater at CERCLA Sites (EPA/540/R-96/023, October). Available at

http://www.epa.gov/superfund/resources/gwguide/index.htm. 
1

 The 1996 ANPR lists four remedy threshold criteria. EPA believes that the fourth criterion “complying

with applicable standards for waste management” is not necessary since complying with applicable waste

management standards is automatically required under existing RCRA Subtitle C and D regulations. For more

information about Federal requirements and implementation guidance associated with remediation waste, refer

tohttp://www.epa.gov/epaoswer/hazwaste/ca/guidance.htm#RemediationWaste.

2

Protecting the environment means, among other things, considering the ecological setting at and around a

facility in evaluating and selecting final remedies. This is especially important for groundwater remedies where

contaminated groundwater discharges into surface water.

3 Media cleanup objectives for final remedies typically includes the more specific concepts of media

cleanup levels, points of compliance, and cleanup timeframes. In previous guidance (EPA, 1996a - page 19449), EPA

referred to media cleanup objectives as media cleanup standards; we now use media cleanup objectives to avoid

confusion over the term “standard” that is often associated just with numeric values. 

4

EPA expects (see glossary for a definition of “remedy expectations”) facilities to control or eliminate

surface and subsurface sources of groundwater contamination as necessary to protect human health and the

environment. In controlling sources, EPA prefers approaches that lead to permanent reductions in toxicity, mobility,

or volume. Additionally, EPA expects that treatment will be used to address source materials considered to be

“principal threats,” i.e., materials that are highly toxic or highly mobile that generally cannot be reliably contained or

(continued...)

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Final Cleanup Goals, Pg. 4.1

Rationale for

Final Cleanup Goals

This policy on final cleanup goals for

contaminated groundwater is important to

protect human health and the environment

by ensuring the short- and long-term

availability of our Nation’s groundwater

resources and by preserving and protecting

hydraulically connected surface waters and

their ecosystems. EPA’s policy on final

cleanup goals states that the situations

where long-term containment remedies are

acceptable should generally be limited to

when cleaning up contaminated

groundwater is technically impracticable,

or to where EPA or the State designates

the groundwater as having no use or value.

4. Final Cleanup Goals

(September 2001)

What are EPA’s final cleanup goals for

corrective action?

EPA recommends that regulators and facilities use the

following three threshold criteria1 as general goals for

final cleanup and as screening tools for potential

remedies, including final groundwater remedies: 

1. Protect human health and the environment2;

2. Achieve media cleanup objectives3; and

3. Control the source(s) of release so as to reduce or

eliminate, to the extent practicable, further releases

of hazardous waste or hazardous constituents that

may pose a threat to human health and the

environment4. 
4

(...continued)

would present a significant risk to human health or the environment should exposure occur. A complete list of

EPA’s general expectations for final remedies is available in EPA, 1996a (page 19448).

5 Within the range of reasonably expected uses and exposures, the maximum beneficial groundwater use is

the one which that warrants the most stringent groundwater cleanup levels and approaches.

6

EPA recognizes that most States classify the majority of their groundwater as potential sources of

drinking water. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Final Cleanup Goals, Pg. 4.2

Protecting human health and the environment is the mandate from the RCRA statute and regulations;

therefore, it is appropriate to include this goal as the first and overarching threshold criterion for final

RCRA corrective action remedies. Use of this threshold criterion also serves to ensure that remedies

include protective activities (e.g., providing an alternative drinking water supply) that would not

necessarily be needed to achieve the other recommended criteria. However, EPA also recommends

that remedies meet the second (achieving media cleanup objectives) and third (controlling sources)

criteria as a means to demonstrate progress toward achieving the overall mandate to protect human

health and the environment.

What are EPA’s final cleanup goals for groundwater? 

EPA expects final remedies to return “usable” groundwaters to their maximum beneficial use5, wherever

practicable, within a timeframe that is reasonable given the particular circumstances of the facility (EPA,

1996a). Facilities and regulators should establish specific media cleanup objectives that will meet this

expectation. EPA also expects final remedies to control or eliminate surface and subsurface sources of

groundwater contamination. In determining appropriate and protective media cleanup objectives for

groundwater remedies, stakeholders should consider the use, value, and vulnerability of the

groundwater resource, and all potential pathways that could result in human or ecological exposure to

contaminants in or from groundwater.

When does EPA consider groundwater “usable” for selecting final cleanup goals? 

EPA recognizes that “usable” groundwater may serve a variety of purposes. Common purposes of

groundwater include, for example, drinking water, agricultural irrigation, car washes, and manufacturing. 

Groundwater also has less formally acknowledged purposes such as replenishing adjacent aquifers or

surface water bodies. Regulators should consider purposes such as these to acknowledge whether

groundwater is “usable” and to determine appropriate cleanup goals. For more guidance regarding

groundwater use, see the groundwater use designation policy in this Handbook. 

What if groundwater is not usable?

For groundwater formally designated by EPA or a State6 as having no use or value, final cleanup goals

such as source control and/or long-term containment, rather than meeting a particular cleanup level
7

 In the Superfund Program, final cleanup goals or objectives that are not associated with returning

contaminated groundwater to its beneficial use are often referred to as “non-restoration” goals or objectives (EPA,

1997b). 

8

 Refer to the Groundwater Cleanup Levels Section of the Handbook for guidance concerning potential

ways humans or ecologic receptors could be exposed to contaminated groundwater. 

9

 For example, humans could be exposed to indoor air contamination resulting from contaminants that

volatilize from underlying groundwater. Further, aquatic organisms living within the groundwater or within surface

water to which groundwater discharges, could be exposed to unacceptable levels of contamination. 

10 RCRA §3004(u) and 40 CFR 264.101(b) require that RCRA permits contain assurances of financial

responsibility for completing RCRA corrective action. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Final Cleanup Goals, Pg. 4.3

throughout the groundwater, may be acceptable as long as the remedy protects human health and the

environment7. However, stakeholders should consider all 

potential pathways8 that could result in human or ecological exposure before deciding that not cleaning

up the entire groundwater plume is acceptable. 

Even in those instances when groundwater is not usable, final remedies should still achieve the three

threshold criteria described above. In addition, EPA recommends that regulators ensure that: (1) the

non-use designation is appropriate; (2) humans or ecological receptors would not be exposed to

contaminants in or from groundwater9; (3) the approaches used to achieve the final cleanup goals would

be effective in the long term; (4) they consider the potential impacts to human health or the environment

if the remedy were to fail; and (5) the facility has the financial ability to maintain the remedy for as long

as necessary to ensure protection of human health and the environment10. 

When significant uncertainties exist regarding the reliability of a containment system, regulators should

strongly consider establishing the goal of cleaning up the groundwater so that relying on long-term

containment is not be needed to ensure protection.

What if returning contaminated groundwater to its maximum beneficial use is not

technically practicable?

Where returning contaminated groundwater to its maximum beneficial use is not technically practicable,

EPA generally expects facilities to prevent or minimize the further migration of a plume, prevent

exposure to the contaminated groundwater, and evaluate further risk reduction. For more information

on what to do if returning contaminated groundwater to its maximum beneficial use is technically

impracticable, see the policy on technically impracticability in this Handbook.

How should facilities and regulators evaluate final remedies that meet the threshold criteria?
11 These balancing criteria are not ranked in terms of importance. 

12 The last two recommended balancing criteria (State and community acceptance) were not explicitly stated

in the May 1, 1996 ANPR (EPA, 1996a). EPA believes these criteria are important considerations to ensure that both

regulators and facilities consider public views and opinions, as well as State requirements, guidance and policies. 

Considering State input is especially important for those situations where EPA, not the State, selects the final

remedy. Including these last two balancing criteria has the added benefit of improving consistency between the

RCRA Corrective Action Program and EPA’s Superfund Program. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Final Cleanup Goals, Pg. 4.4

EPA recommends (EPA, 1996a) that facilities consider the following seven balancing criteria11 when

evaluating a single cleanup alternative or choosing among several alternatives anticipated to meet the

final remedy threshold criteria:

(1) Long-term reliability and effectiveness, along with the degree of certainty that remedies will remain

protective of human health and the environment, considering, as appropriate: the magnitude of risks

that will remain at a site from untreated hazardous wastes and hazardous constituents and treatment

residuals, and the reliability of any containment systems and institutional controls; 

(2) Reduction of toxicity, mobility, or volume through treatment of hazardous wastes and hazardous

constituents, including how treatment is used to address principal threats posed by the facility, and

the degree to which remedies employ treatment that reduces the toxicity, mobility, or volume of 

hazardous waste and hazardous constituents, considering, as appropriate: the treatment processes

to be used and the amount of hazardous waste and hazardous constituents that will be treated; the

degree to which treatment is irreversible; and the types of treatment residuals that will be produced;

(3) Short-term effectiveness and short-term risks remedies pose, along with the amount of time it will

take for remedy design, construction, and implementation; 

(4) Ease or difficulty of remedy implementation, considering, as appropriate: the technical feasibility of

constructing, operating, and monitoring the remedy; the administrative feasibility of coordinating

with and obtaining necessary approvals and permits from other agencies; and the availability of

services and materials, including capacity and location of needed treatment, storage and disposal

services; 

(5) Capital as well as operation and maintenance costs, and the net present value of these costs. 

(6) The degree to which remedies are acceptable to the surrounding community; and 

(7) The degree to which remedies are acceptable to the State in which the facility is located12.

How thorough of an assessment should facilities conduct when evaluating one or more

remedial options?
13 Presumptive remedies are preferred technologies for common categories of sites, based on historical

patterns of remedy selection and EPA’s scientific and engineering evaluation of how well technologies perform

(EPA, 1996c). You can access EPA’s guidance on presumptive remedies at

http://www.epa.gov/superfund/resources/presump.

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Final Cleanup Goals, Pg. 4.5

EPA encourages facilities to focus their evaluations on realistic remedies and tailor the scope and

substance of studies to the complexity of contamination and hydrogeologic conditions at a given facility. 

EPA emphasizes that it does not expect facilities to undertake studies simply for the purpose of

completing procedural steps. Furthermore, there are a number of opportunities to significantly

streamline remedy evaluation. For example, where there are straightforward solutions (e.g., when

standard engineering solutions have proven effective in similar situations) or where presumptive

remedies13 are appropriate and can be applied, it may not be necessary to evaluate more than one

alternative. However, when facilities only evaluate one alternative, they should still justify their proposal

based on EPA’s recommended threshold and balancing criteria.

How should facilities and regulators develop facility-specific final groundwater cleanup

goals?

Facilities and regulators should work together, with input from the public as appropriate, to develop

clearly defined media cleanup objectives to implement final cleanup goals. As described in the

Groundwater Protection and Cleanup Strategy, EPA recommends that these objectives be expressed

in terms of what actions the facility will take, and where and when the facility will take the action.

If some form of cleanup action is needed to achieve a final cleanup goal, stakeholders should

understand: 

• What the groundwater cleanup level is for contaminants in groundwater.

• Where the facility will demonstrate it has achieved groundwater cleanup levels (i.e., the

groundwater point of compliance). 

• When the facility anticipates it can implement a remedy and can achieve a groundwater cleanup

(cleanup timeframe).

In addition to these three elements, EPA believes stakeholders should also clearly understand who is

implementing the final remedy, why they are taking the action, and how they are going to implement the

action. 

What are the media cleanup objectives if containment is the final goal rather than meeting

cleanup levels throughout contaminated groundwater?

When containment is part of the final remedy, facilities and regulators should develop systems to
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Final Cleanup Goals, Pg. 4.6

monitor the effectiveness of the containment. For example, the what could include the cleanup levels

the facility needs to meet outside the containment area. The where could include locations outside the

containment area at which the facility will be monitoring groundwater conditions to verify the

containment system is working. The when could include how often and for how long the monitoring

will continue. In addition, the facility and regulator should identify the specific measures or conditions

that will indicate whether the containment is effective, and what actions the facility will take if the

containment fails. 

Key References: 

EPA, 1997b. Rules of Thumb for Superfund Remedy Selection (EPA 540-R-97-013). Available at

http://www.epa.gov/superfund/resources/rules/rulesthm.pdf . 

EPA, 1996a. Advance Notice of Proposed Rulemaking (61 FR 19432, May 1). Available at 

http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/May/Day-01/pr-547.pdf. Particularly relevant

pages: 19448-52. 

EPA, 1996c. Presumptive Response Strategy and Ex-Situ Treatment Technologies for Contaminated

Groundwater at CERCLA Sites (EPA/540/R-96/023, October). Available at

http://www.epa.gov/superfund/resources/gwguide/index.htm. 
1 Dose is the amount of substance to which a person or other organism is exposed. Dose often takes body

weight into account. Total dose is the sum of doses received by a person or organism from a contaminant in a given

time interval resulting from interaction with all environmental media that contain the contaminant.

2

EPA expresses cancer risk in terms of the likelihood that a person might develop cancer from exposure to

contaminants from a facility. For example, a risk assessment might say that a receptor has an upper bound excess

cancer risk of 10-4. The numerical estimate means that for people receiving this level of exposure averaged over a 70-

(continued...)

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Groundwater Cleanup Levels, Pg. 5.1

Rationale for 

Groundwater Cleanup Levels

Groundwater cleanup levels provide clear

numerical targets that stakeholders can use

to measure the success of groundwater

cleanup actions. EPA recommends that

groundwater cleanup levels be based on the

maximum beneficial use to ensure that

groundwater is cleaned up to levels that

protect human health and the environment

both now and in the future. Identifying

cleanup levels in this way helps to protect

the environmental integrity of our nation’s

groundwater resources. 

5. Groundwater Cleanup Levels

(September 2001)

What are groundwater cleanup levels?

Groundwater cleanup levels are facility-specific chemical concentrations in groundwater that regulators

generally establish when defining groundwater

cleanup objectives for final remedies. EPA

recommends that groundwater cleanup levels be

based on the maximum beneficial use of the

groundwater to ensure protection of human health

and the environment. Additionally, groundwater

cleanup levels often serve as the basis for identifying

the “level of concern” used for the Migration of

Contaminated Groundwater Under Control

environmental indicator (i.e., short-term protection

goals), and may be a component of a facilityspecific intermediate performance goal. 

How should groundwater cleanup levels be

developed?

Groundwater cleanup levels for human health

should typically be developed by using existing cleanup standards (e.g., drinking water standards) when

they are available and when using them is protective of current and reasonably expected exposures. 

If a cleanup standard is not available for a constituent, a facility should first assess all actual and

potential exposures to the contaminant(s). Then, a groundwater cleanup level should be developed

based on the magnitude of exposure (i.e., dose1), and the toxicity of the contaminant resulting in an

estimate of risk. Groundwater cleanup levels are then calculated to fall within generally acceptable

levels of risk. EPA recommends that regulators choose risk-based cleanup levels as follows:

(1) For known or suspected carcinogens, regulators should establish groundwater cleanup levels at

concentrations that represent an excess upper bound lifetime risk2 to an individual of between 10-4
2

(...continued)

year lifetime, approximately one person out of every 10,000 would develop cancer as a result of the exposure. Note

that the range of 10-6 to 10-4 translates to from one in one million to one in ten thousand. Values (i.e., screening

values or “action levels”) used as “triggers” for conducting additional corrective action activities are generally set at

a cancer risk of 10-6. For additional guidance concerning screening levels, refer to EPA, 1996e and

http://www.epa.gov/oerrpage/superfund/resources/soil/. 

3

 Refer also to State regulations and guidance on risk and risk ranges. For example, the State of Florida

specifies 10-6 for risk assessments. Links to State hazardous waste programs are available at 

http://www.epa.gov/correctiveaction/state.htm. 

4

The term “excess” in this context refers to the additional or extra risk of developing cancer due to

exposure to a toxic substance incurred over the lifetime of an individual (source: Glossary of IRIS Terms available at

http://www.epa.gov/iris/gloss8.htm).

5

 EPA expresses noncancer health risk as a ratio, known as the Hazard Quotient (HQ), which is defined as

the calculated exposure from a single contaminant in a single medium divided by a reference dose. The reference

dose is the level of exposure that EPA believes will not cause adverse affect in human populations, including

sensitive individuals. Note that some chemicals may be associated with both carcinogenic as well as

noncarcinogenic effects (such as liver or kidney disease); both should be considered when setting the cleanup level.

6

 The hazard index (HI) assesses potential for toxicity following exposure to multiple contaminants. It is

equal to the sum of the hazard quotients. However, where information is available to identify the critical toxic effect

for non-carcinogens, only hazard quotients associated with similar critical effects (target organs) are combined.

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Groundwater Cleanup Levels, Pg. 5.2

and 10-6 (commonly referred to as EPA’s cancer risk range3). Note that EPA prefers cleanup

levels at the more protective end of the risk range. For facilities with multiple contaminants or

exposure pathways, cleanup levels should generally be set so that cumulative (total) excess4 upper

bound lifetime risk from all contaminants still falls within the risk range. 

(2) For toxic substances associated with adverse effects other than cancer, regulators should establish

groundwater cleanup levels at concentrations to which human populations, including sensitive

subgroups, could be exposed to on a daily basis without appreciable risk of negative effect during a

lifetime. Such levels are generally interpreted as equal to or below a hazard quotient5 of one. For

facilities with multiple contaminants or exposure pathways, groundwater cleanup levels should

generally be equal to or below a hazard index6 of one.

Are there other factors regulators and facilities should consider when developing

groundwater cleanup levels? 

Yes. Groundwater cleanup levels that are higher or lower than the levels described above, might be

appropriate in circumstances, such as those described below, provided the cleanup protects human

health and the environment: 
7

 A naturally occurring substance is in its unaltered form, or is altered solely through naturally occurring

processes or phenomena, in a location where it is naturally found (Superfund, Section 104(a)(3)(A)). 

8

 What would or would not constitute “significant reductions in risk” should be defined on a case-by-case

basis by the regulator. EPA’s primary intent with this guidance is to convey that regulators have the flexibility to

adjust cleanup levels to avoid, where appropriate, creating a groundwater “island of purity” in the midst of regional

contamination from sources outside the facility in question. 

9 You should make sure to contact the cleanup program for the State in which a particular facility is located

to determine applicability of any State-specific guidance or regulations concerning ecologic risk assessment

procedures. Links to State hazardous waste programs are available at

http://www.epa.gov/correctiveaction/state.htm. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Groundwater Cleanup Levels, Pg. 5.3

(1) Higher cleanup levels may be appropriate, for a given facility, for example, when:

(a) in addition to contamination originating from releases from the RCRA facility, groundwater

is also contaminated by hazardous constituents that are naturally occurring7 or have originated

from a source not associated with the subject facility, and those hazardous constituents are

present in concentrations such that remediation of the release would not provide significant

reduction8 in risks to actual or potential receptors; or, 

(b) the groundwater designation is not a current or reasonably expected source of drinking

water, and contaminants in groundwater would not result in unacceptable impacts to

hydraulically connected surface water bodies.

(2) Lower groundwater cleanup levels may be necessary, for example, because of unacceptable

risks to human receptors from combined effects of hazardous wastes or hazardous constituents,

or to protect ecological receptors9, or to protect potential receptors exposed through crossmedia transfer.

For additional information, refer to numerous resources concerning human health and ecological risk

issues including EPA, 2001b; EPA, 2001c; EPA, 1997f; EPA, 1989c; and, the following internet sites: 

http://www.epa.gov/superfund/programs/risk/tooltrad.htm#gp, and

http://www.epa.gov/superfund/programs/risk/commeng.htm. 

What is the role of groundwater use in setting cleanup levels?

Regulators and facilities should base groundwater cleanup levels on the maximum beneficial

groundwater use. The maximum beneficial use, determined by EPA or State regulators, is the current

or reasonably expected use that warrants the most stringent groundwater cleanup levels. Typically the

groundwater use designation is the starting point for determining the appropriate reasonably expected

uses and exposures to evaluate risks and identify groundwater cleanup levels. Facilities and regulators 

should consider groundwater use designations when evaluating the reasonably expected future uses of

groundwater. The groundwater use designation may define whether the groundwater is a current or
10

 In the Superfund Program, non-zero maximum contaminant level goals (MCLGs) established under the

Safe Drinking Water Act are also used as cleanup levels. At Superfund sites, regulators should compare the Federal

MCL, Federal non-zero MCLG, and the State MCL for each constituent and use the most stringent of the these as

the cleanup level. Relatively few chemicals have a non-zero MCLG, and for most of these the non-zero MCLG is

equal to the MCL. For constituents that have an MCLG equal to zero, EPA’s Superfund Program uses the MCL as

the cleanup level (EPA, 1990b - 40 CFR §300.430(e)(2)(i)(B&C)). A table of MCLs and MCLGs established by EPA

under the Safe Drinking Water Act is available at http://www.epa.gov/safewater/mcl.html. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Groundwater Cleanup Levels, Pg. 5.4

potential source of drinking water, or has value or uses other than drinking water.

What are the groundwater cleanup levels for a current or potential source of drinking water?

For groundwater that is currently used or designated as a current or reasonably expected source of

drinking water, EPA recommends that regulators identify cleanup levels based on a residential drinking

water exposure scenario. Even if no one is currently drinking the groundwater, the cleanup level should

generally be based on drinking water use if the aquifer is considered by EPA or the State to be a

reasonably expected future source of drinking water. For each constituent, regulators should determine

whether a maximum contaminant level (MCL) has been established under the Safe Drinking Water Act

(see http://www.epa.gov/safewater/sdwa/sdwa.html). They should also determine whether the State

has adopted the Federal MCL for that constituent, or has promulgated a more stringent State MCL for

drinking waters. Regulators should compare the Federal MCL and State MCL for each constituent

and typically should use the more stringent as the cleanup level10. 

For chemicals that do not have Federal MCLs, you should contact the particular State program in

which the facility is located to determine whether that State has a list of its own drinking water

standards. Internet links to State hazardous waste programs are available at

http://www.epa.gov/correctiveaction/state.htm. 

For constituents for which no Federal or State MCLs have been promulgated, regulators typically rely

on other established drinking water standards and goals or a risk assessment incorporating residential

exposure assumptions (for example, ingestion rate of 2 liters/day, and exposure frequency of 350

days/year) to estimate contaminant dose, derive risk estimates, and determine groundwater cleanup

levels. 

What is the cleanup level if the groundwater is designated as something other than a current

or potential source of drinking water?

Regulators should develop cleanup levels that are consistent with the groundwater use designation. 

However, they should first verify that the groundwater use designation is valid. For example, even if a

State-wide designation system defines (or would define) the aquifer as a non-drinking water resource,

regulators and facilities should verify that no one is drinking the groundwater and that no other

unacceptable exposure to contamination from groundwater is occurring. 

Once verified, a non-drinking groundwater use designation could serve as a starting point for
11 For information on a tool designed to assess impacts from contaminated groundwater to indoor air, refer

to EPA’s User’s Guide for the Johnson and Ettinger Model for Subsurface Vapor Intrusion into Buildings (EPA,

1991d) which is available at

http://www.epa.gov/oerrpage/superfund/programs/risk/airmodel/guide.pdf. The model itself can be downloaded

from http://www.epa.gov/oerrpage/superfund/programs/risk/airmodel/johnson_ettinger.htm. See also EPA’s Draft

Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils (Subsurface Vapor

Intrusion Guidance) available at http://www.epa.gov/epaoswer/hazwaste/ca/eis/vapor.htm.

12 Refer to EPA, 2001b for recent guidance concerning the use of screening level risk assessments and

refining contaminants of concern for baseline ecological risk assessments. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Groundwater Cleanup Levels, Pg. 5.5

establishing groundwater cleanup levels. Some States have established generic cleanup levels in

regulations or guidance for groundwater in non-drinking water aquifers. In those States, facilities and

regulators should consider these levels when appropriate. However, at a facility-specific level, there

may be uses of groundwater or exposures to contaminants from groundwater that might not be

considered in a State-wide groundwater use designation. Regulators should, therefore, verify that the

generic values are protective of the known or reasonably expected groundwater uses and the potential

exposures through cross-media transfer. For example, regulators should consider whether

contaminants in groundwater could transfer (through volatilization) into soil gas that could migrate into

overlying buildings11 and negatively impact the quality of indoor air. Additionally, regulators should

consider whether contaminants in groundwater could negatively impact adjacent aquifers or surface

water bodies.

For example, a State designation may identify groundwater in a particular area as industrial and provide

a generic value, but the groundwater discharges into an adjacent surface water body. In this case,

regulators and facilities should determine the designated uses of the impacted surface water, and identify

any Federal or State water quality criteria for those contaminants found in the discharging groundwater. 

Regulators and facilities should also evaluate possible adverse effects of the groundwater discharge for

actual pathways of exposure to humans or aquatic life12. Based on these evaluations, facilities and

regulators should verify whether available generic cleanup values are protective of the surface water and

its sediments. If these generic levels are not protective, facilities should propose facility-specific

groundwater cleanup levels designed to prevent exceeding appropriate water quality standards in the

surface water body, and unacceptable risks to human health or the environment. 

Additionally, in the absence of appropriate generic values for non-drinking water, facilities should

identify the various actual and potential uses and exposures (i.e., pathways) to contaminants from

groundwater to develop protective groundwater cleanup levels for the facility. To estimate dose,

facilities or regulators should evaluate all current and potential routes of exposure within each pathway,

such as inhalation, dermal (skin) contact, and inadvertent ingestion. Since EPA does not currently have

standard exposure assumptions for nonresidential uses of groundwater, such as industrial or agricultural

uses, facilities and regulators will generally need to quantify facility-specific exposure assumptions for all

expected pathways by collecting facility-specific or other relevant data to develop an appropriate

numerical value for those exposures. These exposure values along with toxicity values for each
13 Regulated units are defined in 40 CFR 264.90 as surface impoundments, waste piles, land treatment units,

and landfills that received hazardous waste after July 26, 1982.

14 The groundwater protection standard (40 CFR 264.92) for RCRA regulated units consists of four

elements including: hazardous constituents (40 CFR 264.93), concentration limits (40 CFR 264.94), the point of

compliance (40 CFR 264.95), and the compliance period (40 CFR 264.96). These regulations are available through

http://www.gpoaccess.gov/cfr/retrieve.html. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Groundwater Cleanup Levels, Pg. 5.6

contaminant can then be used to calculate contaminant-specific concentrations (groundwater cleanup

levels) to achieve protective risk levels (i.e., generally an excess upper bound lifetime cancer risk of 10-4

to 10-6, or equal to or below a hazard index of one).

Are there any situations where regulators might not establish specific groundwater cleanup

levels?

Yes. In some cases, the groundwater will already be at acceptable levels for its designated use(s). In

other situations, regulators might not establish specific groundwater cleanup levels if: 

• the contaminated groundwater is within a designated non-drinking water aquifer;

• has no current or foreseeable beneficial use; 

• does not discharge to surface water or to a drinking water aquifer at levels that could cause

concern; and,

• does not cause other exposures through media transfer (e.g., indoor air). 

However, the regulator may still require facilities to conduct monitoring or to provide containment to

ensure continued protection of human health and the environment. If containment is warranted, then

cleanup levels may be needed to help evaluate the effectiveness of the containment system. Other

protective measures, such as source control, would still likely apply in this situation.

What are alternate concentration limits and do they apply to setting groundwater cleanup

levels for facility-wide corrective action? 

EPA’s regulations pertaining to alternate concentration limits (ACLs) appear at 40 CFR 264.94(b) in

the section of EPA’s regulations that apply to corrective action for RCRA regulated units13 for the

purposes of detecting, characterizing and responding to releases to the uppermost aquifer. Alternate

concentration limits are levels that the Regional Administrator may establish under certain defined

circumstances as a component of the groundwater protection standard14 for RCRA regulated units. 

The regulations refer to these levels as “alternate” because, if approved by the regulator, they are used

instead of background concentrations or the values conveyed in Table 1 of 40 CFR 264.94(a)(2). 

The ACL regulations (see 40 CFR 264.94(b)) take a risk-based approach that provides the Regional

Administrator with the ability to establish an alternative level(s) that “will not pose a substantial present

or potential hazard to human health and the environment.” In establishing ACLs, the regulations also list

factors the Regional Administrator will consider, such as “the physical and chemical characteristics of
15 Under limited circumstances specified in CERCLA 121(d)(2)(B)(ii), alternate concentration limits may also

be used at Superfund sites. Additional guidance for using Superfund ACLs is found in the “Rules of Thumb for

Superfund Remedy Selection” (EPA, 1997b). More specifically, the conditions under which ACLs may be

considered in the Superfund Program include where: (1) contaminated groundwater discharges into surface water; (2)

such groundwater discharge does not lead to “statistically significant” increases of contaminants in the surface

water; and (3) enforceable measures can be implemented to prevent human consumption of the contaminated

groundwater. In general, ACLs can be used in the Superfund Program when the preceding three conditions are

satisfied and where restoration of the groundwater is found to be impracticable based on a balancing of Superfund’s

remedy selection criteria (EPA, 1990 - NCP preamble pages 8732 and 8754, and EPA, 1997b).

16 Note that some State programs do not allow nonresidential scenarios to be used in determining criteria

for clean closure. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Groundwater Cleanup Levels, Pg. 5.7

the waste in the regulated unit, including its potential for migration, and the potential adverse effects on

hydraulically connected surface water.” You can find further information setting ACLs, including on

how to account for natural attenuation processes, in EPA Alternate Concentration Limit guidance

(EPA, 1987). 

Alternate concentration limits as described in 40 CFR 264.94(b) do not apply (see 40 CFR 264.90

regarding “applicability”) to the facility-wide corrective action15 of solid waste management units under

40 CFR 264.101. However, regulators and facilities could use many of the concepts of ACLs in

developing cleanup levels and approaches for site-wide corrective action. For example, as described

elsewhere in this Handbook, facilities and regulators should consider impacts of groundwater on

hydraulically connected surface water, and cleanups can in certain circumstances rely on natural

attenuation processes (see Handbook section on Monitored Natural Attenuation). 

What are cleanup levels for groundwater if a facility is clean closing a RCRA regulated unit?

To achieve “clean closure,” facilities should remove or decontaminate all hazardous waste, liners and

environmental media contaminated by releases from the unit. However, hazardous constituents may

remain at some level in environmental media, such as groundwater, after clean closure provided that the

constituents are below levels that may pose a risk to human health or the environment. 

In 1998, EPA issued a memorandum (EPA, 1998c) reaffirming risk-based clean closure standards. 

The memorandum interpreted EPA’s regulations to permit some limited quantity of hazardous

constituents to remain in environmental media after clean closure provided they are at concentrations

below levels that may pose a risk to human health and the environment. This allows appropriate use of

non-residential exposure assumptions16 when identifying closure standards. Typically, regulators should

not rely on nonresidential exposure assumptions for their clean-closure decisions unless they are

reasonably confident that future land use will conform to those assumptions. Furthermore, regulators

should make sure that the area covered by the nonresidential land use assumptions is clearly delineated. 

Facilities and regulators should also establish procedures (see Institutional Controls) to alert future users

to the presence of contamination and risks presented, and to provide for periodic evaluations of actual
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Groundwater Cleanup Levels, Pg. 5.8

land use. For more information on risk based closure, refer to the Risk-Based Clean Closure

Memorandum (EPA, 1998c) and call your overseeing regulator. 

References: 

EPA, 2002. OSWER Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from

Groundwater and Soils (Subsurface Vapor Intrusion Guidance). Available at 

http://www.epa.gov/epaoswer/hazwaste/ca/eis/vapor.htm.

EPA, 2001b. ECO-UPDATE: The Role of Screening Level Risk Assessments and Refining

Contaminants of Concern in Baseline Ecologic Risk Assessments (EPA/540/F-01/014, June). 

Available at http://www.epa.gov/superfund/programs/risk/ecoup/slera0601.pdf. 

EPA, 2001c. Risk Business (EPA/530/F-00/032, February). Available at

http://www.epa.gov/epaoswer/osw/docs/riskfinal.pdf. 

EPA, 1998c. Memorandum from Elizabeth Cotsworth to RCRA Senior Policy Advisors titled, RiskBased Clean Closure (March 16). Available at

http://www.epa.gov/correctiveaction/resource/guidance/risk/cclosfnl.pdf

EPA, 1997b. Rules of Thumb for Superfund Remedy Selection (EPA/540/R-97/013). Available at

http://www.epa.gov/superfund/resources/rules/rulesthm.pdf 

EPA, 1997f. Exposure Factors Handbook (EPA/600/P-95/002F). Available at

http://www.epa.gov/ncea/exposfac.htm.

EPA, 1996a. Advance Notice of Proposed Rulemaking (61 FR 19432, May 1). Available at 

http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/May/Day-01/pr-547.pdf. Particularly relevant

pages: 19448-52. 

EPA, 1996e. Soil Screening Guidance Fact Sheet (EPA/540/F-95/041, July). Available at

http://www.epa.gov/oerrpage/superfund/resources/soil/.

EPA, 1991d. USEPA’s User’s Guide for the Johnson and Ettinger Model for Subsurface Vapor

Intrusion into Buildings. Available at

http://www.epa.gov/oerrpage/superfund/programs/risk/airmodel/guide.pdf. The model itself can be

downloaded from

http://www.epa.gov/oerrpage/superfund/programs/risk/airmodel/johnson_ettinger.htm. 

EPA, 1990b. National Oil and Hazardous Waste Contingency Plan (55 FR 8666 and 40 CFR 300). 

The preamble is available at

http://www.epa.gov/superfund/action/guidance/remedy/pdfs/ncppreamble61.pdf. The CFR is available
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Groundwater Cleanup Levels, Pg. 5.9

through http://www.access.gpo.gov/nara/cfr/waisidx_00/40cfrv20_00.html.

EPA, 1989c. Risk Assessment Guidance for Superfund Volume I: Human Health Evaluation Manual

(Part A). Available at http://www.epa.gov/superfund/programs/risk/ragsa/index.htm.

EPA, 1987. Alternate Concentration Limit Guidance (EPA/530/SW-87/017). Available at

http://www.epa.gov/correctiveaction/resource/guidance/gw/acl.htm. 
1

Progress toward meeting a particular cleanup goal is typically measured at the point of compliance using

groundwater monitoring wells. The locations of these monitoring wells may change during different stages of a

groundwater cleanup action. 

2 Regulated Units are defined in 40 CFR 264.90 as surface impoundments, waste piles, land treatment units,

and landfills that received hazardous wastes after July 26, 1982. 

3

If the facility contains more than one regulated unit [in close proximity to each other], the waste

management area is described by an imaginary line circumscribing several regulated units (40 CFR 264.95(b)(2)).

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Point of Compliance, Pg. 6.1

Rationale for

Point of Compliance

Defining where a facility should achieve

specified levels of groundwater quality provides

stakeholders a way to assess progress toward

achieving cleanup goals. EPA recognizes that

facilities often use a series of goals to address

contaminated groundwater. 

EPA’s policies in this Handbook reflect different

approaches for points of compliance depending

on whether the facility is pursuing a short-term,

intermediate, or final cleanup goal. 

EPA believes the recommended throughout-theplume/unit boundary point of compliance for

final clean up goals is consistent with EPA’s

overarching goal of protecting human health and

the environment by returning “usable”

groundwater to its maximum beneficial use,

where appropriate. 

This policy also helps ensure that operation and

maintenance, including monitoring, continue as

long as necessary to ensure protection of

human health and the environment. Such

monitoring is important because contamination

represents a potential threat to human health

and the environment as long as the

contamination is present above levels of

concern.

 6. Point of Compliance

(September 2001)

What is a point of compliance for

groundwater?

As a general definition, the point of compliance

for groundwater is where a facility should monitor

groundwater quality and/or achieve specified

cleanup levels to meet facility-specific goals1. 

For RCRA regulated units2, EPA defines the

location of the point of compliance in regulation

(40 CFR 264.95). For groundwater

contamination subject to facility-wide RCRA

corrective action, EPA uses guidance to convey

its recommendations for establishing the point of

compliance.

Where is the point of compliance for RCRA

regulated units? 

For RCRA regulated units, Federal regulations

define the point of compliance as the “vertical

surface located at the hydraulically down gradient

limit of the waste management area3 that extends

down to the uppermost aquifer underlying the

regulated units”(40 CFR 264.95). The purpose

of this point of compliance is to define where the

facility must monitor groundwater and evaluate

compliance with groundwater concentration limits

(i.e., cleanup levels). Additionally, the regulations

require facilities to take action, if necessary, to

achieve cleanup levels within the volume of contaminated groundwater at and beyond the point of
4

 The groundwater point of compliance in the context of short-term goals refers primarily to the Migration

of Contaminated Groundwater Under Control Environmental Indicator, which is one of two environmental indicators

used to track the progress of the RCRA Corrective Action Program (see Short-Term Protection Goals). 

5

 EPA’s intent in recognizing that there could be various locations for the groundwater point of compliance

is to illustrate flexibility available to program implementers. EPA does not, however, want to create confusion over

the names we attach to certain elements of corrective action. Regulators often have to define where facilities need to

meet cleanup levels in order to achieve a particular goal. Whenever regulators define such locations, they are in

essence establishing a point of compliance, but it is not necessary to refer to these locations as a point of

compliance unless they find it beneficial to do so.

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Point of Compliance, Pg. 6.2

Property boundary

Plume boundary

Groundwater

Flow Direction

Figure 1: Example groundwater point of compliance for final

cleanup goal involving returning contaminated groundwater to

its maximum beneficial use. The shaded area represents a

throughout the plume/unit boundary point of compliance

corresponding to the volume of contaminated groundwater that

needs to achieve specific groundwater cleanup levels. 

compliance (40 CFR 264.100). For more information regarding the point of compliance for regulated

units, refer to 40 CFR 264.90-100, which are available through

http://www.gpoaccess.gov/cfr/retrieve.html. Also, see footnote number 8 in the Overview to read how

EPA’s Post Closure regulations (63 FR 56710, EPA 1998d) can provide additional flexibility for

cleanup of regulated units. For additional guidance concerning groundwater monitoring of regulated

units, refer to EPA, 1993b. 

Where is the groundwater point of compliance for RCRA (facility-wide) corrective action? 

EPA recognizes that the general definition of the point of compliance can apply to a variety of facilityspecific goals, in particular short-term protection goals4

, intermediate performance goals, and final

cleanup goals. Therefore, EPA recognizes the

point of compliance may vary depending on the

particular goal the facility and regulator are

pursuing5. EPA recommends consideration of

the following factors when developing a facilityspecific groundwater point of compliance: 

proximity of sources of contamination; technical

practicability of achieving particular cleanup

levels; vulnerability of the groundwater and its

possible uses; and exposure and likelihood of

exposure and similar considerations (EPA,

1996a). 

Where is the groundwater point of

compliance for final cleanup goals?

The location of the point of compliance should

depend on whether the final cleanup is selected

to (1) return usable groundwater to its maximum

beneficial use; or (2) contain contamination

within groundwater that EPA or a State has

designated as not being usable (see Final
6

 In the context of RCRA corrective action, “waste in place” typically refers to the waste management area

encompassing the original source(s) of a release that the regulator determined is acceptable to leave in place as part

of a final remedy. For example, a properly closed landfill represents a waste management area commonly allowed to

stay in place as part of a final remedial action. EPA typically does not refer to contamination that has migrated from

the original source(s) (e.g., non-aqueous phase liquid (NAPL)) as a waste management area or waste left in place

(EPA, 1996c - page 17).

7

This definition of a point of compliance for final remedies is consistent with the “area of attainment” (EPA,

1988) and “point of compliance” (EPA, 1997b) used in EPA’s Superfund cleanup program. For more information

concerning how the Superfund Program uses a point of compliance, refer to page 8753 of the NCP preamble (EPA,

1990b). 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Point of Compliance, Pg. 6.3

Property boundary

Plume boundary

Groundwater

Flow Direction

Figure 2: Plume boundary point of compliance for shortterm protection goal associated with the Migration of

Contaminated Groundwater Under Control environmental

indicator. The heavy dashed line represents the point of

compliance (i.e., boundary of the plume) defined by

“contaminated” and “uncontaminated” monitoring wells. 

Cleanup Goals and Groundwater Use Designation) or in situations where the regulator determined that

returning usable groundwater to its maximum beneficial use is technically impracticable. 

For final cleanups selected to return groundwater to its maximum beneficial use, EPA recommends

regulators set the point of compliance throughout

the area of contaminated groundwater, or when

waste is left in place6, at and beyond the boundary

of the waste management area encompassing the

original source(s) of groundwater contamination

(EPA, 1996a - page 19450). EPA typically

refers to this area (more accurately described as a

volume) as the “throughout-the-plume/unit

boundary” point of compliance7 (See Figure 1 on

previous page). 

If the final groundwater cleanup objective is to

contain the plume rather than to return the

groundwater to its maximum beneficial use, the

point of compliance should generally be located at

and, if appropriate, beyond the boundary of the

containment zone. This point of compliance is

similar to the approach regulators typically use to

measure whether a facility achieves the Migration

of Contaminated Groundwater Under Control

environmental indicator (see answer to next

question). 

Where is the groundwater point of compliance for short-term protection goals?

Achieving the Migration of Contaminated Groundwater Under Control environmental indicator involves

documenting that contaminated groundwater is expected to remain within an existing three-dimensional
8

Facilities and regulators typically define a plume boundary based on estimating a division between where

groundwater is contaminated above and below levels of concern. They commonly make this estimate based on

professional interpretation (often with the aid of computer software) of chemical analyses of groundwater samples

collected from properly located monitoring wells or other monitoring devices. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Point of Compliance, Pg. 6.4

Plume boundary

Off-site plume

Groundwater

Flow Direction

Figure 3: Example of a point of compliance for an intermediate

performance goal. In this example, the point of compliance is

considered to be throughout the portion of the contaminant

plume that extends beyond the facility boundary. 

boundary(ies) of the plume8 (EPA, 1999e). Using the general definition of a point of compliance

described above, regulators and facilities could, in appropriate circumstances, recognize a plume

boundary (see Figure 2) as a point of compliance for the Migration of Contaminated Groundwater

Under Control environmental indicator. Evaluators should recognize that they need to account for all

plumes of contaminated groundwater at a facility since EPA designed this indicator to reflect facilitywide conditions. 

Where is the groundwater point of compliance for intermediate performance goals?

The need for, and location of, a point of compliance for an intermediate performance goal depends on

facility-specific circumstances. Many intermediate performance goals for contaminated groundwater

will not warrant establishing a point of compliance (e.g., source removal actions). In general,

establishing a point of compliance as a component

of an intermediate performance goal is only

beneficial when a facility takes an action that

includes assessment through groundwater

monitoring. If the facility and the regulator wish

to establish a point of compliance as a

component of an intermediate performance goal,

it should be located between the existing

boundary of the plume and the original source of

groundwater contamination. For example,

establishing a facility boundary point of

compliance may make sense when a

groundwater contaminant plume extends off-site

(see Figure 3). In this case, a facility boundary

point of compliance establishes a way to

measure when a facility achieves an intermediate

goal of cleaning up the off-site groundwater.

In contrast, a facility boundary point of compliance

would generally not be an appropriate component of an intermediate performance goal when a

groundwater contaminant plume has not yet reached a property boundary because: (1) it would likely

be inconsistent with EPA’s general pollution prevention goals, and with the EPA’s short-term

protection goal of preventing the spread of contaminated groundwater; (2) monitoring uncontaminated

wells at the facility boundary would not measure progress toward achieving the final cleanup goal; and,

(3) as a practical matter, preventing groundwater contamination is usually much less costly than cleaning

up the contamination after it has spread. 
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Point of Compliance, Pg. 6.5

References: 

EPA, 1999e. Interim Final Guidance for RCRA Corrective Action Environmental Indicators (February

5). Available at http://www.epa.gov/epaoswer/hazwaste/ca/eis/ei_guida.pdf.

EPA, 1997b. Rules of Thumb for Superfund Remedy Selection (EPA/540/R-97/013). Available at

http://www.epa.gov/superfund/resources/rules/rulesthm.pdf. 

EPA, 1996a. Advance Notice of Proposed Rulemaking (61 FR 19432, May 1). Available at 

http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/May/Day-01/pr-547.pdf. Particularly relevant

page: 19450.

EPA, 1996c. Presumptive Response Strategy and Ex-Situ Treatment Technologies for Contaminated

Groundwater at CERCLA Sites (EPA/540/R-96/023, October). Available at

http://www.epa.gov/superfund/resources/gwguide/gwfinal.pdf.

EPA, 1993b. Waste Management Area and Supplemental Well Guidance (June). Available at

http://www.epa.gov/correctiveaction/resource/guidance/gw/wma_sup.htm.

EPA, 1990b. National Oil and Hazardous Waste Contingency Plan (55 FR 8666 and 40 CFR 300). 

The preamble is available at http://www.epa.gov/tio/osc/documents/mar1990.pdf. The CFR is

available through http://www.access.gpo.gov/nara/cfr/waisidx_00/40cfrv20_00.html. 

EPA, 1988. OSWER Directive 9283.1-2, “Guidance on Remedial Actions for Contaminated

Groundwater at Superfund Sites,” (December 1).
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Cleanup Time Frame, Pg. 7.1

Rationale for

Cleanup Timeframe

Establishing reasonable timeframes based on

specific goals offers facilities realistic

objectives, provides flexibility, helps prioritize

resources efficiently, and maintains

protection. 

EPA’s short-term goals are directed toward

eliminating unacceptable exposures to

contamination and preventing plumes from

spreading as soon as possible. After

achieving the short-term goals, facilities can

move toward final cleanup goals in a

timeframe commensurate with the technical

difficulties and potential risks. Considering

these factors to determine acceptable cleanup

timeframes allows the RCRA Corrective

Action Program to direct its resources toward

reducing potential threats at more facilities,

while maintaining its long term environmental

cleanup goals. 

7. Cleanup Timeframe

(September 2001)

What is the cleanup timeframe?

The cleanup timeframe is an estimate of when

groundwater quality will achieve a certain level at

a specified location and/or the schedule

developed to take an action or construct a

remedy designed to achieve a particular shortterm protection, intermediate performance, or

final cleanup goal. 

EPA believes that cleanup timeframes should be

reasonable, linked to specific goals, and based

on facility-specific conditions. Examples of

factors regulators and facilities should, where

appropriate, take into account when developing

cleanup timeframe(s) for a given facility include

(EPA, 1996a): 

• potential risks from exposures to

contamination; 

• current and reasonably expected future land

and water use(s);

• type, source(s), and extent of contamination;

• hydrogeologic characteristics;

• reliability of exposure controls;

• design and capabilities of cleanup

technologies; 

• availability of treatment and/or disposal options; 

• community preferences; and

• financial resources of the facility.

What is the cleanup timeframe for EPA’s short-term goals?

As described previously in this Handbook, the Corrective Action Program’s short-term goals that 

EPA is currently using to monitor progress in response to the Government Performance and Results

Act include: documenting that current human exposures to unacceptable levels of contamination are

under control, and preventing plumes of contaminated groundwater from getting larger or adversely

affecting surface water bodies. To help focus the program, EPA established nationwide goals which

are as follows: 
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Cleanup Time Frame, Pg. 7.2

By 2005, EPA’s goal is to verify and document that 95 precent of a baseline of 1,714 RCRA

corrective action facilities (see http://www.epa.gov/correctiveaction/facility.htm) have human exposures

under control and 70 precent have the migration of contaminated groundwater under control. EPA

encourages regulators and facilities to work together to establish appropriate cleanup timeframes, based

on the particular circumstances of each facility, that will help meet these near-term objectives. If people

are currently using or being exposed to contaminated groundwater or contaminants transferred from

groundwater (e.g., indoor air), facilities and regulators should take action as soon as possible to prevent

these exposures and to achieve short-term protection goals. 

How should regulators establish cleanup timeframes for intermediate performance goals?

If an intermediate performance goal is warranted, the timeframe to achieve that goal should be

reasonable and based on facility-specific factors. In situations where facilities and regulators anticipate

the time to achieve final cleanup goals will be long, establishing cleanup timeframes for intermediate

goals can help provide meaningful measures to assess and communicate progress among interested

stakeholders. Timeframes for intermediate goals should generally help to prioritize actions at a facility. 

For example, at a complex site with many areas of contamination, the regulator and facility may want to

consider a sequence of intermediate goals for the purpose of demonstrating progress toward the final

cleanup goals. A key consideration in prioritizing actions should be the relative risk and/or potential

environmental harm associated with the current contamination. 

How should regulators establish cleanup timeframes for achieving final cleanup goals?

EPA recognizes that uncertainties associated with the cleanup may make it impossible to specify with a

high level of confidence when a remedy will achieve final cleanup goals. Regulators and facilities can’t

always accurately predict how long it will take to return groundwater to its maximum beneficial use

because of the following kinds of complexities: type of contaminants; hydrogeologic characteristics;

contaminant interactions; and, technology limitations among other factors. In these circumstances,

facilities should generally still attempt to predict the time needed to achieve final cleanup goals, but

stakeholders should recognize that such predictions are best considered in a relative sense for

comparing one cleanup option to another. Where such predictions are difficult, EPA recommends that

cleanup timeframes primarily focus on the schedules associated with implementing the remedy and

perhaps anticipated timeframes associated with achieving certain other facility-specific milestones. 

In general, a regulator is more likely to accept a longer timeframe for final cleanup goals when adequate

monitoring and reliable controls are in place to prevent exposure (e.g., drinking water wells are

prohibited). For example, a regulator might allow a facility to have an extended timeframe to clean up

groundwater when the facility overlies groundwater designated as a future source of drinking water but

where no one is currently using or anticipated to use the water in the foreseeable future.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Cleanup Time Frame, Pg. 7.3

Reference: 

EPA, 1996a. Advance Notice of Proposed Rulemaking (61 FR 19432, May 1). Available at 

http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/May/Day-01/pr-547.pdf. Particularly relevant

page: 19450. 
1

See glossary definition of “source materials.”

2 Additional information and reports concerning DNAPL contamination is available at

http://www.epa.gov/oerrpage/superfund/resources/gwdocs/non_aqu.htm 

3

See glossary for a definition of “remedy expectations.” 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Source Control, Pg. 8.1

Rationale for

Source Control

Source control, where necessary, will be

a critical component of a facility’s cleanup

strategy aimed at returning contaminated

groundwater to its maximum beneficial

use in a reasonable timeframe. 

Controlling sources of contamination is

also consistent with the Agency’s longstanding pollution prevention goals; it is

generally easier to deal with the

contamination at the source than to clean

up wide-spread contamination. 

8. Source Control

(September 2001)

What does source control mean?

Source control refers to a range of actions (e.g., removal, treatment in place, and containment)

designed to protect human health and the environment

by eliminating or minimizing migration of, or exposure

to, significant contamination. 

What are sources of contamination?

EPA typically describes sources1 as contaminated

material that acts as a reservoir for the continued

migration of contamination to surrounding

environmental media (i.e., soil, groundwater, surface

water, sediment, or air), or provides a direct threat to

a receptor. Sources are not always stationary, but can

migrate from a location, such as a landfill or surface

impoundment, where the contamination was originally

released. For example, dense non-aqueous phase

liquids (DNAPLs2) may be present as a “mobile”

phase that continues to migrate deeper into the

subsurface, migrate along a subsurface feature, or

accumulate in a subsurface feature, such as a

depression in a low permeable layer of clay.

What are EPA’s expectations for source control regarding groundwater?

As conveyed in the 1996 Advance Notice of Proposed Rulemaking (ANPR), EPA expects3 facilities to

control or eliminate surface and subsurface sources of groundwater contamination (EPA, 1996a). EPA

believes most facilities will need to control sources of contamination to achieve facility-specific cleanup

goals. Sometimes facilities may need to implement source controls to achieve short-term protection

goals. For example, controlling a source of contamination may be important for a facility that wants to

rely on monitored natural attenuation to achieve the Migration of Contaminated Groundwater Under

Control environmental indicator. Source control at many facilities will be an important component of
4

 EPA recognizes that finding subsurface sources of contamination can be very challenging. Therefore, in

this context, “practicable” refers to both finding as well as cleaning up sources of contamination. Decisions

pertaining to the practicability of source control actions are best determined on a facility-specific basis. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Source Control, Pg. 8.2

intermediate performance goals used, for example, to demonstrate progress toward achieving final

cleanup goals. Furthermore, as addressed in the Final Cleanup Goal section of this Handbook, EPA

identifies source control as a recommended threshold criterion for final corrective action remedies. 

More specifically, facilities should propose final remedies that control the source(s) of releases so as to

reduce or eliminate, to the extent practicable4, further releases of hazardous wastes or hazardous

constituents that may pose a threat to human health or the environment. EPA expects facilities to

control the sources of contamination regardless of the current groundwater use or the groundwater use

designation. 

When should facilities and regulators consider source control measures?

You should consider source control measures as early as possible in corrective action. For example,

you should consider whether source controls will be necessary to achieve short-term protection goals,

or whether they would be more appropriate to implement as part of an intermediate performance goal

or a final remedy. Furthermore, early consideration of potential source control technologies can help

facilities focus their data collection to ensure they have adequate evaluation and design information. 

When can facilities contain the sources rather than treat them?

EPA expects facilities to use treatment to address wastes and contaminated media that EPA considers

principal threats (EPA, 1996a and EPA, 1990b). EPA considers sources or “source materials” to be

principal threats when they are highly toxic or highly mobile that generally cannot be reliably contained

or would present a significant risk to human health or the environment should exposure occur (EPA,

1997b; EPA, 1996a; and EPA, 1991c). EPA expects to use engineering controls, such as

containment, for wastes and contaminated media that can be reliably contained, pose relatively low

long-term threats, or for which treatment is impracticable. The exact balance between treating,

removing, and containing the source is best determined on a case-by-case basis during remedy

evaluation and selection, and may depend on whether the facility is trying to achieve short-term,

intermediate, or final cleanup goals. Along with identifying principal threats, you should also generally

consider other factors such as long-term reliability, short-term risks, and community acceptance when

evaluating the right balance between containment and treatment.

In some situations, it may be appropriate to contain rather than treat even principal threat wastes due to

difficulties in treating the wastes. For example, the following situations could, depending on facilityspecific circumstances, justifiably lead a regulator to decide that containment rather than treatment

would be acceptable for principal threat wastes (EPA, 1997b):
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Source Control, Pg. 8.3

• Treatment technologies are not technically feasible or are not available within a reasonable

timeframe.

• The extraordinary volume of materials or complexity of the site may make implementation of 

treatment technologies impracticable (e.g., large landfills).

• Implementation of a treatment-based remedy would result in greater overall risk to human health

and the environment due to risks posed to workers, the surrounding community, or impacted

ecosystems during implementation (to the degree that these risks cannot otherwise be controlled

during implementation).

• Implementation of the treatment technology would have severe effects across environmental media.

Why should facilities control sources when they have already achieved environmental

indicators goals?

Environmental Indicators are only milestones on the way to meeting final cleanup goals and completing

corrective action. For example, EPA believes that source control will often be necessary to achieve

the final cleanup goal of returning groundwater to its maximum beneficial use within a reasonable

timeframe.

References: 

EPA, 1997b. Rules of Thumb for Superfund Remedy Selection, OSWER Directive No. 9355.0-69

(EPA/540/R-97/013, August). Available at

http://www.epa.gov/oerrpage/superfund/resources/rules/index.htm. Particularly relevant text pertaining

to applicability to RCRA corrective action found on page 1, and on Treatment of Principal Threat

Wastes on pages 11 and 12. 

EPA, 1996a. Advance Notice of Proposed Rulemaking (61 FR 19432, May 1). Available at 

http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/May/Day-01/pr-547.pdf. Particularly relevant

page: 19448. 

EPA, 1991c. A Guide to Principal Threats and Low Level Threat Wastes. Superfund Publication

9380.3-06FS (November). Available at

http://www.epa.gov/oerrpage/superfund/resources/gwdocs/threat.pdf. 

EPA, 1990b. National Oil and Hazardous Waste Contingency Plan (55 FR 8666 and 40 CFR 300). 

The preamble is available at

http://www.epa.gov/superfund/action/guidance/remedy/pdfs/ncppreamble61.pdf. The CFR is available

through http://www.access.gpo.gov/nara/cfr/waisidx_00/40cfrv20_00.html.
1

Further guidance on defining “reasonably expected uses of groundwater” is available in Appendix B of

the EPA guidance titled, Final Comprehensive State Groundwater Protection Program Guidance (EPA, 1992a).

2

EPA’s overall groundwater protection goal is to prevent adverse effects to human health and the

environment and to protect the environment by, among other things, protecting that integrity of the Nation’s

groundwater resources (EPA, 1991b).

3

 Within the range of reasonably expected uses and exposures, maximum beneficial groundwater use

warrants the most stringent groundwater cleanup levels.

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Groundwater Use Designations, Pg. 9.1

Rationale for

Groundwater Use Designations

States should have the primary responsibility for

managing and protecting their groundwater

resources. Therefore, EPA prefers, where

appropriate, to rely on State groundwater use

designations when developing groundwater

cleanup objectives.

EPA supports State groundwater use designation

systems that promote a consistent and

comprehensive approach to groundwater

protection based on varying groundwater

characteristics. EPA’s primary objectives are to

advocate approaches for groundwater use

designations that protect both the current as well

as reasonably expected uses of groundwater. In

particular, EPA wants to avoid inappropriate

groundwater use designations and associated

cleanup decisions that would rely on the lack of

current drinking water use at or around an

individual facility as the only justification for a nondrinking water use designation. 

9. Groundwater Use Designations

(September 2001)

What is a groundwater use designation?

A groundwater use designation is a

determination of the reasonably expected

use(s)1, resource value (e.g., priority),

and/or vulnerability of groundwater in a

particular area. A system used to make

protective groundwater use designations

should account for these factors and be: 

• based on an overall goal that is no less

protective than EPA’s groundwater

protection goal2; 

• applied consistently to all groundwaters

of a State; and 

• developed with thorough opportunity

for public participation. 

EPA and States can use the designation as

a factor in determining the maximum3

(highest) beneficial use of the groundwater

in order to establish facility-specific

corrective action goals.

How does EPA define use, value, and

vulnerability? 

The term “use” refers to the current use and reasonably expected use of the groundwater. When
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Groundwater Use Designations, Pg. 9.2

Factors to Assess

 Use, Value, and Vulnerability of

Groundwater Resources

• Vulnerability to contamination 

• Hydrogeologic regimes

(recharge and discharge areas) 

• Flow patterns

• Quantity and potential yield

• Ambient and/or background quality

• Wide-spread contamination 

• Current use and exposures (including public

water supply systems and private drinking

water supply wells)

• Reasonably expected future uses (based on

demographics, remoteness, and availability of

alternative water supplies)

• Connections to surface waters 

• Impacts to ecological receptors

• Value attributed to a groundwater resource,

including public opinion

• Governmental and legal boundary

considerations (e.g., groundwater migrating

across State boundaries) 

(based on EPA, 1992a) 

people think about groundwater use, they often consider only drinking water use; however, there are

many other groundwater uses besides drinking water. These uses include, for example, sanitary water,

cooling water, car washes, livestock watering, and agricultural irrigation. 

 “Value” depends on the current and reasonably expected use, but it also considers groundwater’s

potential impact on other media; exposures

to contaminants from groundwater can occur

even when there is no direct use of the

groundwater. For example, groundwater

may recharge adjacent or underlying

aquifers that are used for drinking water, or

discharge to surface water to support

aquatic life, recreation, and drinking water. 

In addition, exposure to contaminated

indoor air can result from underlying

groundwater contaminated with volatile

chemicals. Value also refers to the

irreplaceability of groundwater either as a

source of drinking water (e.g., sole source

aquifer) or to support vital ecological

systems.

Groundwater “vulnerability” is the relative

ease with which a contaminant introduced

into the environment can migrate to an

aquifer under a given set of management

practices, contaminant properties, and

aquifer hydrogeologic characteristics. 

For additional information regarding how

EPA defines the use, value, and vulnerability

of groundwater, refer to Appendix B of

EPA, 1992a. 

What factors should States consider when making groundwater use designations? 

To promote consistency, where appropriate, EPA issued guidance to States (EPA, 1992a) that

includes a list of factors (see adjacent box) they should generally consider in assessing use, value, and

vulnerability of their groundwater resources.

How does EPA’s policy on groundwater use designations affect States that consider all of

their groundwater to be a potential drinking water supply?
4

 Risks to ecological receptors may in some situations be the primary reasons for cleanups, especially for

groundwater that is not designated as a source of drinking water. To protect particularly sensitive ecological

receptors, concentrations of groundwater cleanup levels in some circumstances may have to be lower than

concentrations associated with drinking water standards designed to protect humans. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Groundwater Use Designations, Pg. 9.3

EPA recognizes that some States have statutes, regulations, or policies designating all groundwater to

be a potential drinking water supply, and requiring that all contaminated groundwater be cleaned up to

drinking water standards. States may take a more stringent approach than what EPA would otherwise

use for making groundwater use and cleanup decisions. However, EPA still encourages such States to

develop methods for prioritizing groundwater resources to focus cleanup actions on facilities in more

sensitive areas first. Examples of factors or criteria that States might use to distinguish among potential

drinking waters on a facility-specific basis are: 

• expected timeframe of future use;

• likelihood of use within a certain time period (e.g., 30 years);

• relative priority or value;

• relative vulnerability;

• proximity to existing public and private water supplies;

• presence of elevated concentrations of naturally occurring contaminants; and,

• likelihood of impacting sensitive areas (e.g., wetlands) or environmental receptors4

States are already acquiring this kind of information for other EPA programs. For example, Section

1453 of the Safe Drinking Water Act (SDWA) as amended in 1996 requires States to develop and

implement Source Water Assessment Programs (SWAPs). These programs must assess source

waters within the State that support public drinking water systems. A source water assessment

program will consist of: (1) a delineation of the source water area; (2) an inventory of potential sources

of contaminants; (3) a susceptibility analysis of public drinking water systems; and (4) making the results

of the assessments available to the public. 

States were required to submit their Source Water Assessment Programs for approval by February

1999, and have 3 1⁄2 years to complete the assessment following program approval. Most States will

have completed their assessments by May 2003. EPA will not consider assessments to be complete

until the results have been made available to the public. EPA believes that these assessments will prove

to be helpful in identifying areas needing greater protection of groundwater resources. For more

information on Source Water Assessment Programs, refer to State Source Water Assessment and

Protection Programs Guidance (EPA, 1997d). Electronic information is available at

http://www.epa.gov/OGWDW/swp/swappg.html.

Who makes groundwater use designations?

The regulator makes the groundwater use designation for the purposes of facility-specific RCRA

corrective action, since regulators are responsible for ensuring that corrective action is protective of

human health and the environment. However, a facility can provide the information the regulator needs
5

 A Comprehensive State Groundwater Protection Program (CSGWPP) is a groundwater management

strategy developed by a State. EPA reviews CSGWPPs and “endorses” those that successfully meet six strategic

activities. EPA outlines specific considerations for each strategic activity in the CSGWPP guidance (EPA, 1992a). In

particular, EPA remediation programs review State guidelines in the CSGWPP to prioritize groundwater based upon

use, value, and vulnerability. In 1997, EPA’s Office of Solid Waste and Emergency Response issued a directive

(EPA, 1997e) encouraging EPA’s remediation programs generally to defer to State determinations of current and

future use when based on an EPA-endorsed CSGWPP that has provisions for facility-specific decisions. A map of

States with EPA-endorsed CSGWPPs is available at http://www.epa.gov/safewater/csgwpp.html. Also, refer to the

discussion on CSGWPPs in EPA, 1996a. 

6

 Some States have groundwater classification schemes based on specific parameters (e.g., total dissolved

solids) that mandate particular cleanup standards (e.g., primary and secondary drinking water standards). Links to

State hazardous waste programs are available at http://www.epa.gov/correctiveaction/state.htm. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Groundwater Use Designations, Pg. 9.4

to make a groundwater use designation. 

EPA generally prefers to base its cleanup decisions on State-developed groundwater use designations. 

In particular, EPA generally intends to defer to a State groundwater use designation when it is part of

an EPA-endorsed Comprehensive State Groundwater Protection Program (“CSGWPP”) that provides

for facility-specific decision making in EPA’s remediation programs5. Also, in the absence of such an

EPA-endorsed CSGWPP, EPA may, where appropriate, rely on an alternative protective State

groundwater use designation especially when that designation considers the same factors listed in the

CSGWPP guidance (EPA, 1992a). States authorized for corrective action have the lead in making

groundwater use designations for cleanups they are overseeing. However, States may choose to use

EPA’s groundwater use classification (see next question) in the absence of a State groundwater use

designation system. 

Depending on facility-specific circumstances, EPA may find it appropriate to use its own classification

(see next question) to make groundwater use designations. These circumstances could include, for

example, when: (1) EPA has the lead role in implementing corrective action at a facility, and (2) a

State designation system is not available or is not in EPA’s opinion adequately protective. You should

consult the lead regulatory agency to determine how they generally determine reasonably expected

groundwater use 6. 

What is EPA’s groundwater use classification?

EPA’s groundwater classification system for site-specific groundwater use designations is found in

“Guidelines for Groundwater Classification under the EPA Ground-Water Protection Strategy” (EPA,

1986 - available at http://www.epa.gov/correctiveaction/resource/guidance/gw/gwclass.htm). These

guidelines describe three classes of groundwater that represent a hierarchy of groundwater resource

values to society: Class I is groundwater that is an irreplaceable source of drinking water and/or

ecologically vital. Class II is groundwater currently used or potentially usable as a source of drinking

water; and Class III includes groundwater that is not a current or potential source of drinking water. 

How can State groundwater use designations enhance protection and flexibility for RCRA
7

Illinois, Delaware and Texas are examples of States that have adopted groundwater management zone

approaches. California has a adopted a similar approach called a “containment zone,” but does not use it for

facilities subject to RCRA corrective action.

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Groundwater Use Designations, Pg. 9.5

cleanups?

Regulators can prioritize their workload to address those facilities overlying more highly valued

groundwaters first. In addition, groundwater use designations can serve as a starting place for

predicting the reasonably expected use(s) of groundwater. Therefore, for States with protective

groundwater use designation systems, regulators may modify groundwater cleanup objectives while still

ensuring protection of human health and the environment based on both current and potential future

uses. 

Flexibility associated with groundwater use designations provides more cleanup options to facilities and

regulators. For example, regulators could allow a facility to have an extended cleanup timeframe to

clean up groundwater when the facility overlies groundwater designated as a future drinking water

source, but where no one is currently using or anticipated to use the water in the foreseeable future. 

Another example is that some States have developed groundwater cleanup levels based on industrial or

non-drinking water use. These non-drinking water cleanup levels may be higher in concentration than

drinking water standards, and may facilitate redevelopment of facilities (e.g., brownfields -

http://www.epa.gov/swerosps/bf/topics.htm) that might otherwise remain unused. However, it is

important to evaluate various uses of and exposures to groundwater on a facility-specific basis prior to

relying on generic cleanup levels to ensure these levels would be protective. 

Some States also formally identify groundwater that has no beneficial use. For such situations, as

described in the Final Cleanup Goals section of this Handbook, regulators could consider source

control and long-term containment rather than cleaning up the groundwater to achieve a particular

cleanup level(s) throughout the contaminant plume. When long-term containment is the cleanup

objective, regulators should generally establish a point of compliance at the boundary of the

containment zone.

Facilities should not interpret that accepting a higher groundwater cleanup level based on a groundwater

use designation means that less stringent prevention measures are acceptable. Regardless of the

groundwater use designation, facilities should comply with all State and Federal laws for preventing new

releases of contamination, and do their part to minimize hazardous waste generation. 

How do groundwater management or containment zones relate to groundwater use

designations?

Some States7 formally define existing areas of broadly contaminated groundwater as groundwater

management zones. States typically do not use these groundwater management zones to change a

groundwater use designation; rather, they generally use groundwater management zones as a type of
8

To provide overlapping assurances of protection from contamination, EPA recommends that various

forms of institutional controls be “layered” (i.e., use of multiple institutional controls) or implemented in a series. For

example, prohibitions against installing drinking water wells could be used in conjunction with defining a

groundwater management zone. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Groundwater Use Designations, Pg. 9.6

institutional control8 to publically acknowledge that the contaminated groundwater is currently unsuitable

for its designated use, and to provide reasonable flexibility to facilities that are implementing long-term

groundwater remedies. While some differences exist among States, groundwater management zones

typically are granted only if a facility satisfies specific provisions. Some of the more common

conditions, which are also consistent with the policies in this Handbook, include:

• the facility has controlled sources of contamination where appropriate;

• the facility has defined existing boundaries of the contaminated groundwater; 

• the facility is currently conducting a groundwater cleanup action under regulatory oversight, that is

designed to prevent migration of contamination outside the groundwater management zone; and

• the facility recognizes that its obligations to ensure protection of human health and the environment

continue until the groundwater is returned to its designated use. 

In general, EPA supports and encourages creative and flexible approaches to address contaminated

groundwater. As such, EPA supports the use of groundwater management zones when they streamline

corrective action decision making, while still ensuring that facilities achieve protective short- and longterm cleanup goals. 

References: 

EPA, 1997d. State Source Water Assessment and Protection Programs Guidance (EPA/816/R97/009, August). Available at http://www.epa.gov/OGWDW/source/swpguid.html .

EPA, 1997e. The Role of Comprehensive State Groundwater Protection Programs (CSGWPPS) in

OSWER Remediation Programs. OSWER Directive 9283.1-09. Available at

http://www.epa.gov/superfund/resources/csgwpp/role.pdf. 

EPA, 1996a. Advance Notice of Proposed Rulemaking (61 FR 19432, May 1). Available at 

http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/May/Day-01/pr-547.pdf. Particularly relevant

page: 19457. 

EPA, 1992a. Final Comprehensive State Groundwater Protection Program Guidance (EPA/100/R93/001). Available at http://www.epa.gov/correctiveaction/resource/guidance/gw/csgwpp.htm. 

EPA, 1991b. Protecting the Nation’s Groundwater: EPA’s Strategy for the 1990's. Office of the

Administrator. Washington, D.C. Available at

http://www.epa.gov/superfund/resources/remedy/pdf/21z-1020-s.pdf.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Groundwater Use Designations, Pg. 9.7

EPA, 1986. Guidelines for Groundwater Classification under the EPA Groundwater Protection

Strategy. Available at http://www.epa.gov/correctiveaction/resource/guidance/gw/gwclass.htm.
1

 Fences that restrict access to sites are often termed institutional controls; however, EPA does not

consider fences to be institutional controls because fences are physical barriers instead of administrative or legal

measures. Furthermore, while the term “deed restriction” is often used in remedy decision documents to describe

easements or other forms of institutional controls, “deed restriction” is not a traditional property law term and should

be avoided. For more detailed guidance on institutional controls, refer to a recent document (EPA, 2000b) issued by

EPA titled, “Institutional Controls: A Site Manager’s Guide to Identifying, Evaluating and Selecting Institutional

Controls at Superfund and RCRA Corrective Action Cleanups.” You can access this document as well as

supporting other related documents and supporting materials at

http://www.epa.gov/superfund/action/ic/guide/index.htm.

2 While institutional controls may limit exposure to human populations, facilities and regulators should

ensure that cleanup actions also protect ecologic receptors. 

3

 See glossary for a definition of “remedy expectations.”

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Institutional Controls, Pg. 10.1

Rationale for

Institutional Controls

EPA recognizes that, depending on the

site-specific circumstances, facilities can

achieve short-term, intermediate, or final

cleanup goals through various

combinations of removal, treatment,

engineering, and institutional controls. 

For groundwater that will likely remain

contaminated for a considerable period of

time, EPA believes that some form of

institutional control will typically be a

critical part of the groundwater remedy to

prevent exposure. Therefore, institutional

controls should be evaluated, 

implemented, and monitored just like any

other component of a remedy needed to

ensure protection.

10. Institutional Controls

(September 2001)

What are institutional controls?

EPA typically describes institutional controls as non-engineered measures1 such as administrative and/or

legal controls that minimize the potential for human exposure2 to contamination by limiting land or

resource use. 

EPA expects3 to use institutional controls, such as

water and land use restrictions, primarily to

supplement engineering controls as appropriate to

prevent or limit exposure to hazardous waste and

constituents (EPA, 1996a). Institutional controls are

appropriate during all stages of the cleanup process

to accomplish various cleanup-related objectives. 

To provide overlapping assurances of protection

from contamination, institutional controls should be

“layered” (i.e., use of multiple institutional controls)

or implemented in a series.

What are the general categories and some

specific examples of institutional controls?

There are four general categories of institutional

controls: 

• governmental controls; 

• proprietary controls; 
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Institutional Controls, Pg. 10.2

• enforcement tools with institutional control components; and

• informational devices. 

Each of these categories is briefly described below. For more detailed descriptions of these categories,

including benefits and limitations of different institutional control mechanisms, refer to the institutional

control matrix available at:

http://www.epa.gov/epaoswer/hazwaste/ca/resource/guidance/ics/matrxrv3.pdf. 

Governmental Controls - These controls are usually implemented and enforced by State or local

governments. Once implemented, local and State entities often use traditional police powers to regulate

and enforce the controls. Since this category of institutional control is put in place under local

jurisdiction, they may be changed or terminated with little notice to EPA, and EPA generally has no

authority to enforce such controls. Examples include zoning, ordinances (e.g., restricting well drilling or

water use), statutes, building permits, or other provisions that restrict land or resource use.

Proprietary Controls - These controls rely on legal instruments placed in the chain of title for the

subject site or property. The specific instrument may convey a property interest from the owner

(grantor) to a second party (grantee) for the purpose of restricting land or resource use. One example

of this type of control is an easement that provides access rights for monitoring and inspection. Another

example is a covenant not to dig or drill wells in certain areas. A major benefit of these controls is that

they can be binding on subsequent purchasers of the property and are transferable. However,

enforcement of proprietary controls depends on the party to which the property interest has been

granted. Unlike EPA’s Superfund Program, RCRA does not authorize EPA to acquire property

interests to conduct a cleanup, and, therefore, EPA cannot generally hold or directly enforce

proprietary controls associated with a RCRA cleanup. 

Enforcement Tools - Federal, State and local governments can, in some circumstances, issue or

negotiate permits, orders, or other enforceable agreements that direct a facility to refrain from using a

property in specific ways. These tools can be very effective but the major limitation is that most

enforcement agreements are only binding on those who enter into the agreement. Furthermore,

restrictions based on enforcement tools are not typically transferable through a property transaction. 

Informational Devices - These tools are typically used to provide information or notification regarding

contamination present at a property. Common examples include State registries of contaminated

properties, deed notices, and advisories. Informational devices are not typically enforceable; therefore,

they are best used as a secondary “layer” to help ensure the overall reliability of other institutional

controls. 

How can facilities and regulators use institutional controls to address contaminated

groundwater? 

For contaminated groundwater, the most common purpose of institutional controls is to protect human
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Institutional Controls, Pg. 10.3

health by preventing exposure. As described previously, institutional controls “layered” or used in

series provide the best means to ensure protection from contaminated groundwater. For example, to

prevent exposure to contaminated groundwater associated with a given facility, institutional controls

could include all or various combinations of the following components: (1) State or local governmental

controls prohibiting well drilling and use of groundwater in a designated area; (2) a proprietary

easement or covenant providing access to monitor groundwater for facility investigations or

performance monitoring, and/or restrictions on using groundwater after construction of the remedy is

complete; (3) enforceable conditions in a State or EPA permit or administrative order preventing use of

contaminated groundwater and requiring training for those who could come in contact with

contaminated groundwater; (4) placing a notice on the deed about the existence of contaminated

groundwater under the property; and (5) distributing an advisory notice to local citizens in a given area

that they should avoid drinking or contact with groundwater. Facilities and regulators should also

consider establishing procedures for terminating an institutional control(s) when it is no longer necessary

to protect human health and the environment. 

How should facilities develop and stakeholders evaluate institutional controls?

It is helpful for stakeholders to consider institutional controls in a similar manner to how they would

evaluate, implement and monitor an engineered remedy. Therefore, institutional controls should go

through an evaluation, selection, implementation, and an operation and maintenance phase. All four

phases are important because institutional controls can work well, work somewhat, or not work at all.

The evaluation phase should involve assessing the purpose and type of institutional control based on

how well it would meet a specific short-term protection, intermediate performance, or final cleanup

goal. This phase should identify all parties that would need to be involved to successfully implement the

institutional control. Additionally, this phase should include evaluation of the approaches facilities and

regulators will use to assess the effectiveness of the institutional control. 

As with other components of a remedy, the facility should recommend a specific institutional control

approach, and regulators should determine, with input from the public, whether the facility’s

recommendation is satisfactory. This selection phase should be based on EPA’s recommended

threshold and balancing criteria as discussed in the Final Cleanup Goals section of this Handbook. 

The implementation phase typically involves negotiating, drafting, and recording documents to put into

place the institutional controls that successfully made it through the evaluation phase. For example,

implementing an institutional control could involve placing provisions in a State permit, creating an

easement, putting a notice in a deed, and distributing advisories. 

Operation and maintenance should include periodic actions serving to ensure that the institutional

control is working as designed. Examples of operation and maintenance of an institutional control

include: physical inspection of legal documents including deeds, enforcing institutional controls if

necessary, and routine distribution of advisories to local citizens.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Institutional Controls, Pg. 10.4

References: 

EPA, 2000b. Institutional Controls: A Site Manager’s Guide to Identifying, Evaluating and Selecting

Institutional Controls at Superfund and RCRA Corrective Action Cleanups (EPA/540/F-00/005,

September). OSWER Directive 9355.0-74FS-P. Available at

http://www.epa.gov/superfund/action/ic/guide/index.htm.

EPA, 1996a. Advance Notice of Proposed Rulemaking (61 FR 19432, May 1). Available at 

http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/May/Day-01/pr-547.pdf. Particularly relevant

pages: 19448-49, and 52.
1

Some States may have specific guidelines, requirements, or restrictions associated with monitored natural

attenuation remedies. For example, some States have specific guidelines for when monitored natural attenuation

would be acceptable, based on: (1) contaminant concentrations, (2) plume location (i.e., off-site), and (3) anticipated

timeframe to clean up the groundwater.

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Monitored Natural Attenuation, Pg. 11.1

Rationale for 

Monitored Natural Attenuation

This policy reflects advancements in

EPA’s understanding of how natural

attenuation processes can be part of an

effective cleanup strategy. Monitored

natural attenuation is not a “no action” 

cleanup option. Appropriate use of

monitored natural attenuation supports

EPA’s cleanup objectives, which include

source control, prevention of plume

migration, and returning contaminated

groundwater to its maximum beneficial

use. 

11. Monitored Natural Attenuation

(September 2001)

What is monitored natural attenuation?

The term “monitored natural attenuation” refers to an approach to clean up environmental contamination

by relying on natural processes and monitoring. Natural attenuation processes include a variety of

physical, chemical, or biological processes that, under favorable conditions, act without human

intervention to reduce the mass, toxicity, mobility,

volume, or concentration of contaminants in

groundwater. 

When is monitored natural attenuation a likely

cleanup option?

Monitored natural attenuation may be an appropriate

cleanup option (EPA, 1996a) when the facility can

demonstrate that the remedy is capable of achieving

facility-specific groundwater cleanup levels in a

reasonable cleanup timeframe. Facilities should

evaluate and justify monitored natural attenuation

remedies using recommended threshold and balancing

criteria discussed in the Final Cleanup Goal section

of this Handbook. Monitored natural attenuation

should be justified on a facility-specific basis and

compared with, where appropriate, other plausible

options. In general, monitored natural attenuation proposals are more likely to be acceptable to

regulators1 when: 

• the facility can demonstrate that monitored natural attenuation will be able to achieve groundwater

cleanup objectives; 

• measures for source control of groundwater contamination are already in place;

• the dominant natural attenuation processes cause degradation or destruction of contaminants as

opposed to those processes that merely dilute contamination or prevent its movement;
2

EPA recommends that proposals for monitored natural attenuation remedies include estimates of the time

needed to achieve groundwater cleanup levels. EPA realizes that such estimates are based on numerous

assumptions, but they are still helpful for comparisons between cleanup options. 

3

 While EPA believes regulators will generally be more likely to approve monitored natural attenuation

remedies that involve other more active source control and treatment measures, we recognize that there will be some

situations where monitored natural attenuation may be sufficient as a stand-alone remedial alternative.

4

 EPA’s policy (EPA, 1999d) on monitored natural attenuation does not distinguish between on-site and

off-site contaminated groundwater. 

5

Some State programs might require formal concurrence of adjacent property owners for monitored natural

attenuation remedies proposed to address off-site contaminated groundwater. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Monitored Natural Attenuation, Pg. 11.2

• the contaminant plume(s) is already stable or shrinking in extent; 

• the estimated cleanup timeframe2 to meet cleanup levels is reasonable considering factors such as

groundwater use and timeframes required for other remedies, and the timeframe is comparable to

that which could be achieved through active remediation (EPA, 1990b - NCP preamble page

8734); and

• the facility uses monitored natural attenuation in conjunction with an active remedial system or as a

follow-up measure.3 

For a more complete list of recommended factors, a list of advantages and disadvantages of monitored

natural attenuation remedies, and additional policy and technical guidance, refer to EPA, 1999d, and

EPA, 1998b. You can also find additional information concerning monitored natural attenuation in

report developed by the National Research Council (NRC, 2000). 

Is monitored natural attenuation acceptable when contaminated groundwater is off-site?

The regulator should determine whether monitored natural attenuation will be acceptable for off-site

contaminated groundwater.4 In making this determination, the regulator should consider facility-specific

circumstances, as well as any applicable Federal and State requirements and guidance. One situation

where a regulator might accept a monitored natural attenuation remedy is where no one is currently

exposed to unacceptable levels of contamination and the plume is not expanding (i.e., the facility meets

EPA’s short-term protection goals). Other very important factors to consider when deciding whether

to rely on monitored natural attenuation for off-site contamination include the thoroughness of public

participation5, the ability to conduct long-term monitoring and prevent exposures, and whether the

facility is controlling the source of the groundwater contamination.

Should monitored natural attenuation remedies include formal contingency measures?

In general, EPA recommends that facilities and regulators evaluating monitored natural attenuation as a

cleanup option should consider the need for identifying one or more contingency remedies (EPA,
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Monitored Natural Attenuation, Pg. 11.3

1999d). A contingency measure (or contingency plan or contingency remedy) is a cleanup approach

specified in a remedy decision document that functions as a “backup” remedy in the event that the

“selected” remedy fails to perform as anticipated. Contingency measures should generally be flexible,

allowing for new information about risks and technologies. Contingency measures are especially

appropriate for a monitored natural attenuation remedy that is selected based primarily on predictive

analyses rather than documented trends of decreasing contaminant concentrations. 

How long should a facility monitor a monitored natural attenuation remedy?

A facility should monitor a monitored natural attenuation remedy until the groundwater cleanup levels

are met at the point of compliance for the final cleanup goals, and longer, where appropriate, for

example where the final remedy involves a component designed for long-term containment. EPA

specifically added the term “monitored” to the name of this cleanup alternative to emphasize the

importance of long-term performance monitoring. EPA’s Policy Directive States, “Performance

monitoring should continue until remediation objectives have been achieved, and longer if necessary to

verify that the facility no longer poses a threat to human health or the environment.” However, the

Directive also emphasizes that it is important to include flexibility sufficient to adjust the frequency (more

frequent or less frequent) of monitoring as the situation warrants. 

References: 

EPA, 1999d. Use of Monitored Natural Attenuation at Superfund, RCRA Corrective Action and

Underground Storage Tank Sites (April 21). OSWER Policy Directive 9200.4-17P. Available at

http://www.epa.gov/swerust1/directiv/d9200417.htm. Other helpful links regarding MNA available at

http://www.epa.gov/swerust1/cat/mna.htm and http://www.epa.gov/swerust1/oswermna/mnalinks.htm 

EPA, 1998b. Technical Protocol for Evaluating Natural Attenuation of Chlorinated Solvents in

Groundwater (EPA/600/R-98/128). Available at

http://www.epa.gov/correctiveaction/resource/guidance/rem_eval/protocol.pdf

EPA, 1996a. Advance Notice of Proposed Rulemaking (61 FR 19432, May 1). Available at

http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/May/Day-01/pr-547.pdf. Particularly relevant

pages: 19451-52. 

EPA, 1990b. National Oil and Hazardous Waste Contingency Plan (55 FR 8666 and 40 CFR 300). 

The preamble is available at

http://www.epa.gov/superfund/action/guidance/remedy/pdfs/ncppreamble61.pdf. The CFR is available

through http://www.access.gpo.gov/nara/cfr/waisidx_00/40cfrv20_00.html.

NRC, 2000. Natural Attenuation for Groundwater Remediation. Committee on Intrinsic Remediation,

Water Science and Technology Board, Board on Radioactive Waste Management, National Research

Council. Available at http://www.nap. edu/catalog/9792.html
1

 For further information regarding challenges associated with groundwater cleanups, refer to Alternatives

for Ground Water Cleanup (NRC, 1994), available at http://www.nap.edu/books/0309049946/html/. Also, you can

find numerous resources concerning cleanup technologies at EPA’s Technology Innovation Office’s Web site

(http://www.clu-in.org/), including the feature called “Technology Innovation Office’s Perspectives”

(http://www.clu-in.org/tiopersp/) where you can view several recent articles summarizing current cleanup technology

practices and developments. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Technical Impracticability, Pg. 12.1

Rationale for 

Technical Impracticability

EPA believes that it is appropriate to recognize

the limitations of current technologies to clean

up groundwater to its maximum beneficial use. 

This policy provides facilities a recommended

framework to technically justify such limitations

and to focus resources on protective alternative

remedial strategies. EPA’s policy concerning

technical impracticability does not, however,

signal a scaling back of efforts to address

contaminated groundwater. Rather, this policy

reaffirms EPA’s commitment to protect human

health and the environment from contamination

associated with RCRA corrective action

facilities. In particular, the policy encourages

regulators to (1) base their technical

impracticability decisions on sound science,

and (2) where technical impracticability is

adequately justified, ensure that facilities

maintain their alternative remedial strategies

(e.g., containment) as long as necessary to

protect both human health and the environment. 

12. Technical Impracticability

(September 2001)

What does technical impracticability mean?

Technical impracticability (TI) for contaminated

groundwater refers to a situation where achieving

groundwater cleanup levels associated with final

cleanup goals is not practicable from an

engineering perspective (EPA, 1996a; EPA,

1995a; and EPA, 1993a). The term “engineering

perspective” refers to factors such as feasibility,

reliability, scale or magnitude of a project, and

safety. For example, a certain cleanup approach

might be technically possible, but the scale of the

operation might be of such magnitude that it was

not technically practicable.

What are the primary factors that might lead

to a technical impracticability

determination?

Reasons for technical impracticability generally

fall into one of two categories1:

(1) Hydrogeologic factors, or 

(2) Contaminant-related factors.

Examples of limiting hydrogeologic factors

include very low-permeable or highly

heterogeneous soils, or complex fractures or solution cavities in bedrock. A contaminant-related factor

could be presence of residual non-aqueous phase liquids (NAPLs). Other contaminant-related factors

could be associated with extensive volume of or limited access to contaminated material. 

EPA expects that poor cleanup performance due to inadequate remedial design would not be sufficient

justification for a technical impracticability determination. Design inadequacies could stem from, for
2

 Additional information and reports concerning NAPL contamination is available at

http://www.epa.gov/oerrpage/superfund/resources/gwdocs/non_aqu.htm See also EPA, 1995b and 1994c. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Technical Impracticability, Pg. 12.2

example, inadequate characterization, selecting inappropriate technologies, or deficiencies associated

with implementing a particular technology.

Is the mere presence of non-aqueous phase liquids (NAPLs) sufficient to justify a technical

impracticability determination?

No. In determining that it is technically impracticable to achieve a set cleanup level, regulators should

not rely solely on the presence of NAPLs2. The presence of NAPL is just one of many factors facilities

and regulators should consider when evaluating technical impracticability. Other factors to consider are

the type, amount, and location of NAPL, as well as the technologies that are available to clean up the

NAPL. Facilities should, therefore, avoid basing their technical impracticability justification solely on

the presence of NAPL or the apparent inability of any one technology (e.g., pump-and-treat). A

technical impracticability evaluation should be based on a comprehensive understanding of

hydrogeologic factors, chemical characteristics, and conventional as well as innovative technologies. 

What should facilities include in a technical impracticability evaluation?

EPA generally expects that technical impracticability determinations would be based on an evaluation

by the facility. EPA’s guidance (EPA, 1993a) on technical impracticability suggests that this evaluation

generally include the following: 

• Spatial area (the TI zone) over which the TI decision would apply;

• Specific groundwater cleanup levels, consistent with the groundwater use designation, that are

considered technically impracticable to achieve;

• Conceptual site model that describes geology, hydrology, groundwater contamination sources,

transport, and fate;

• Evaluation of the “restoration potential” of the TI zone;

• Cost estimates;

• Any additional information EPA or the State program deems necessary; and 

• Description of an alternative remedial strategy.

When should a facility recommend technical impracticability?

Considering technical impracticability early in corrective action (e.g., during facility characterization) is a

good idea if available information suggests that a facility has hydrogeologic or chemical-related cleanup

limitations. The facility should submit a technical impracticability evaluation along with a

recommendation for a final remedy. However, as a general matter, we recommend facilities do not

devote significant resources on a technical impracticability evaluations until they achieve short-term

protection goals (i.e., environmental indicators). 
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Technical Impracticability, Pg. 12.3

Should regulators make technical impracticability determinations prior to a facility’s attempt

to meet groundwater cleanup levels? 

In many case, regulators should make technical impracticability determinations only after facilities

implement pilot or full-scale groundwater cleanup systems because it is often difficult to predict the

effectiveness of remedies based solely on site characterization data. However, in some cases,

regulators could make technical impracticability determinations prior to remedy implementation. 

Regulators should base these pre-implementation or “front-end” technical impracticability

determinations on appropriate site characterization that define the most critical limitations to meeting a

groundwater cleanup level. 

If a regulator makes a formal technical impracticability determination, has the facility

satisfied all of their corrective action obligations for groundwater?

A technical impracticability determination does not override the RCRA statutory obligation that

remedies protect human health and the environment. When the regulator determines that achieving

groundwater cleanup levels associated with final cleanup goals is technically impracticable, the regulator

should select an “alternative remedial strategy” that protects human health and the environment and: 

• is technically practicable;

• achieves short-term protection goals and, if appropriate, intermediate performance goals;

• controls the sources of contamination;

• achieves groundwater cleanup levels outside the TI zone;

• provides for appropriate long-term operation, maintenance, and monitoring; and 

• is consistent with the overall cleanup goals for the facility.

Why should facilities conduct investigations within the technical impracticability zone?

Facilities should characterize within the TI zone to: (1) support the technical impracticability evaluation;

(2) identify sources that they should control, even within the TI zone; (3) evaluate the potential for

cross-media transfer of contamination they may need to manage (e.g., from groundwater to air) as part

of an alternative remedial strategy; and (4) support the development of an alternative remedial strategy

as discussed above. The particular circumstances of the facility will govern the amount of

characterization needed to accomplish these objectives.

 

Why should facilities control sources within the technical impracticability zone?

Source control is typically an important part of an acceptable alternative remedial strategy and is one

EPA’s three recommended threshold criteria associated with final cleanup goals. Source control

prevents the continued input of contamination into surrounding environmental media and can help

improve the likelihood that the alternative remedial strategy will be effective in the long term. 

Controlling sources within the technical impracticability zone will help to limit the amount of
3

Some cleanup programs (e.g., New York State -- see

http://www.clu-in.org/eiforum2000/prez/ppframe1.cfm?id=81) have referred to long-term containment of contaminated

groundwater in terms of “perpetual care” obligations. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Technical Impracticability, Pg. 12.4

contamination facilities will need to address if and when achieving the groundwater cleanup levels

becomes technically practicable in the future. However, as mentioned previously in this Handbook (see

Final Cleanup Goals and Source Control), EPA believes the exact balance between treating, removing,

and containing the source, even in the context of a technical impracticability determination, is best

evaluated on a case-by-case basis. 

How does a technical impracticability determination affect the point of compliance? 

Even when regulators make a technical impracticability determination, they should establish a point of

compliance as necessary to track progress in meeting cleanup goals associated with the alternative

remedial strategy. For example, when an alternative remedial strategy involves returning a portion of

the plume to its maximum beneficial use, regulators should generally establish a point of compliance

throughout the contaminated groundwater outside of the technical impracticability zone. Additionally, if

the alternative remedial strategy involves long-term containment, regulators should generally establish a

point of compliance at the boundary of the technical impracticability zone to verify that the containment

system is working as intended. 

How long should a technical impracticability determination last?

EPA generally recommends that, for RCRA corrective action, technical impracticability determinations

and the responsibility of the facility to maintain its alternative remedial strategy remain in place until

subsequent advances in technology make achievement of the groundwater cleanup levels within the TI

zone technically practicable. Facilities should realize that a technical impracticability determination for

many circumstances could warrant ongoing3 care to ensure long-term protection.

Should regulators and/or facilities revisit technical impracticability determinations? 

Technical impracticability determinations are based on current understanding of capabilities and

limitations of cleanup technologies. Cleanup goals that are technically impracticable today could

become technically practicable at some point in the future. Therefore, EPA’s 1993 guidance on

technical impracticability (EPA, 1993a) recognizes that regulators overseeing RCRA corrective action

may require, where appropriate, facilities to “undertake additional remedial measures in the future if

subsequent advances in remediation technology make attainment of media cleanup objectives

technically practicable.” Examples could include situations where new information or new technologies

become available that indicate the facility could achieve groundwater cleanup levels that were

previously determined to be technically impracticable. Sometimes, the facility might want to revisit the

technical impracticability determination without prompting by the regulator. For example, the facility

might want to try a new technology that has the ability to achieve the original cleanup objectives rather
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Technical Impracticability, Pg. 12.5

than continuing to implement an alternative remedial strategy. Therefore, EPA recommends that both

facilities and regulators periodically re-evaluate the technical impracticability decision as part of routine

performance monitoring. 

References: 

EPA, 1996a. Advance Notice of Proposed Rulemaking (61 FR 19432, May 1). Available at

http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/May/Day-01/pr-547.pdf. Particularly relevant

page: 19451. 

EPA, 1995a. Consistent Implementation of the FY 1993 Guidance on Technical Impracticability of

Ground Water Restoration at Superfund Sites (January). OSWER Directive 9200.4-14. Additional

information available at 

http://www.epa.gov/oerrpage/superfund/resources/gwdocs/tec_imp.htm.

EPA, 1995b. Groundwater Issue: Light Non-Aqueous Phase Liquids (EPA/540/S-95/500). Available

at http://www.epa.gov/ada/download/issue/lnapl.pdf. 

EPA, 1994c. DNAPL Site Characterization (EPA/540/F-94/049). Available at

http://www.epa.gov/oerrpage/superfund/resources/gwdocs/dnapl.pdf. 

EPA, 1993a. Guidance for Evaluating the Technical Impracticability of Groundwater Restoration

(EPA/540/R-93/080, September). Available at

http://www.epa.gov/oerrpage/superfund/resources/gwdocs/techimp.htm.

NRC, 1994. Alternatives for Ground Water Cleanup / Committee on Ground Water Cleanup

Alternatives, Water Science and Technology Board, Board on Radioactive Waste Management,

Commission on Geosciences, Environment, and Resources, National Research Council. National

Academy Press, 1994. Available at http://www.nap.edu/books/0309049946/html/. 
1

 40 CFR 144.13 and 144.23 of the Underground Injection Control (UIC) Program regulations include an

exemption for Class IV wells (wells involving the injection of hazardous waste) similar to that found in RCRA section

3020(b). Under the UIC Program, these Class IV wells are authorized by rule. Prior to construction of such wells,

facilities must notify their state UIC Program and submit inventory information as required by 144.26. You can

access UIC regulations at http://www.gpoaccess.gov/cfr/retrieve.html or

http://www.epa.gov/safewater/uic/uicregs.html. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Reinjection of Contaminated Groundwater, Pg. 13.1

Rationale for

Reinjection of Contaminated

Groundwater

EPA’s policy on reinjection of

contaminated groundwater

encourages facilities and regulators

to consider opportunities for using

in-situ bioremediation and other insitu treatments where such

technologies are protective and offer

advantages over other cleanup

alternatives.

13. Reinjection of Contaminated Groundwater 

(September 2001)

Can facilities reinject groundwater that is contaminated with hazardous wastes back in the

subsurface as part of corrective action?

RCRA section 3020(a) bans hazardous waste disposal

by underground injection into or above a [geologic]

formation that contains (within 1/4 mile of the well used

for such underground injection) an underground source

of drinking water. However, RCRA section 3020(b)

exempts from that ban the injection of groundwater

contaminated with hazardous wastes provided that

certain conditions are met.1

What are the specific conditions facilities have to

meet prior to reinjecting groundwater

contaminated with hazardous waste into the

subsurface? 

The exemption provided by RCRA section 3020(b)

allows facilities to reinject groundwater that is

contaminated with hazardous wastes back into the

aquifer from which it was withdrawn if: (1) the reinjection is part of a response action under section 104 or 106 of the Comprehensive Environmental

Response, Compensation and Liability Act (CERCLA), or part of RCRA corrective action intended to

clean up such contamination; (2) the contaminated groundwater is treated to substantially reduce

hazardous constituents prior to such reinjection; and (3) the cleanup will, upon completion, be sufficient

to protect human health and the environment. 

The second element of the statutory provision in the preceding paragraph means that treatment must

occur prior to reinjection, and the treatment substantially reduces hazardous constituents in the

groundwater either before or after reinjection of the contaminated groundwater back into the aquifer

from which it was withdrawn (EPA, 2000a; also, see EPA, 1989a). 
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Reinjection of Contaminated Groundwater, Pg. 13.2

Does section 3020(b) allow the reinjection of contaminated groundwater after the addition of

nutrients or other in situ treatment products?

Yes. Section 3020(b) allows the reinjection of contaminated groundwater containing these additives as

long as the hazardous constituents in the groundwater are substantially reduced, either before reinjection

or as a result of subsequent in-situ treatment consistent with section 3020(b)(2). The remedy must also

comply with sections 3020(b)(1) and (3) described in the previous question. Furthermore, the

substantial reduction should occur in a reasonable period of time (i.e., in a time period consistent with

the CERCLA and/or RCRA cleanup objectives made for the groundwater) and the regulator should

consider whether hydraulic containment would be appropriate to ensure protection of the groundwater

resource. Also, stakeholders should be aware that while the RCRA statute could allow for such

reinjection, facilities may also have to comply with requirements of State Underground Injection Control

(UIC) programs. Therefore, facilities should coordinate with State regulators to obtain, as necessary,

variances, waivers, construction permits, approvals, etc. 

What if a facility wants to re-inject groundwater that is contaminated with nonhazardous

wastes as part of corrective action? 

The ban on injecting hazardous wastes described in RCRA Section 3020(a) does not apply if the

reinjected groundwater does not contain hazardous wastes. However, injection wells that re-inject

groundwater that is contaminated with nonhazardous wastes are Class V wells and facilities must still

comply with all UIC Program requirements, including notifying the UIC Program prior to construction

of any injection well. Facilities should also consult with their State regulators because many States have

stricter groundwater protection laws that could prohibit the reinjection of any contaminated

groundwater, regardless of whether it is hazardous or not. For more information about State UIC

Programs, refer to http://www.epa.gov/safewater/uic/primacy.html. For information about EPA’s UIC

Program, refer to http://www.epa.gov/safewater/uic.html. 

References: 

EPA, 2000a. Applicability of RCRA Section 3020 to In-Situ Treatment of Ground Water. 

Memorandum from Elizabeth Cotsworth, Director, Office of Solid Waste to RCRA Senior Policy

Advisors (December 27). Available at

http://www.epa.gov/epaoswer/hazwaste/ca/resource/guidance/remwaste/refrnces/pol-mem3.pdf. 

EPA, 1989a. OSWER Directive 9234.1-06, “Applicability of Land Disposal Restrictions to RCRA

and CERCLA Groundwater Treatment Reinjection Superfund Management Review: Recommendation

No. 26,” (November 27). Available at

http://www.epa.gov/epaoswer/hazwaste/ca/resource/guidance/remwaste/refrnces/14_3020b.pdf.
1

For more information, refer to the numerous documents EPA has produced that address groundwater

monitoring (EPA, 1997b; EPA, 1997g; EPA, 1996a; EPA, 1996c; EPA, 1994a; and EPA, 1992b; EPA, 1992c; and EPA,

1992d). 

2

 Such evaluations can also provide information facilities can use to verify or adjust their estimates of

cleanup timeframes. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Performance Monitoring, Pg. 14.1

Rationale for 

Performance Monitoring

Properly designed performance monitoring

programs are especially important for groundwater

cleanups because the concentration and

distribution of contamination in groundwater often

change with time. Likewise, natural and human

factors (e.g., seasonal precipitation or nearby

groundwater usage) can influence the ability of

cleanup actions to control migration of

contaminated groundwater. Performance

monitoring can assess changes in groundwater

so that facilities can modify cleanup actions to

ensure maximum efficiency, protectiveness, and

compliance. Performance monitoring can also

demonstrate whether or not a cleanup action is

performing as expected.

14. Performance Monitoring

(September 2001)

What is performance monitoring?

EPA defines performance monitoring as the periodic measurement of physical and/or chemical

parameters to evaluate whether a remedy is

performing as expected. Facilities should

conduct performance monitoring to evaluate

whether the facility is making progress toward

achieving short-term protection goals,

intermediate performance goals, or final

cleanup goals. 

What should the performance monitoring

accomplish?

Facilities should design performance

monitoring1 programs to, for example:

• detect changes in environmental conditions

(e.g., hydrogeologic, geochemical,

microbiological, or other changes) that

may reduce the efficacy of the remedy;

• identify any potentially toxic and/or mobile

transformation products;

• verify that the plume(s) is not expanding

above levels of concern (either down gradient, laterally, or vertically);

• assess effectiveness of the cleanup or treatment system2;

• evaluate whether advances in technologies or approaches could improve the ability of a remedy to

achieve cleanup goals;

• verify no unacceptable exposure to down gradient receptors;

• detect new releases of contaminants to the environment that could impact the effectiveness of the

remedy;

• demonstrate the effectiveness of institutional controls that were put in place to protect potential

receptors; and
3 Many stakeholders only associate performance monitoring with chemical analysis of groundwater

samples. For some cleanup actions, especially those involving hydraulic containment, facilities can often

demonstrate performance with frequent hydrogeologic measurements (e.g., groundwater elevation monitoring)

supplemented with less frequent groundwater quality measurements. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Performance Monitoring, Pg. 14.2

 • verify attainment of short-term, intermediate, or final goals. 

What should a performance monitoring program include?

Facilities should include the specific approaches they intend to use to periodically assess remedy

effectiveness towards meeting short-term, intermediate, or final goals. The performance monitoring

program should include a description of the location(s), frequency, type3 and quality of samples,

techniques, and measurements that a facility will use to collect information needed to make decisions

associated with a particular cleanup goal. However, EPA urges facilities and regulators to design

performance monitoring approaches to be flexible and easily adaptable to account for changing

conditions and information needs. 

How often should a facility monitor?

The frequency of monitoring should be adequate to detect, in a timely manner, the potential changes in

facility conditions listed above. This means that the rate of groundwater flow and contaminant

movement are important factors to consider when facilities and regulators determine monitoring

frequency. The monitoring plan should include flexibility for adjusting the monitoring requirements over

the life of the remedy. For example, it may be appropriate to decrease the monitoring frequency (e.g.,

semiannually, annually, or for even longer time periods) and number of constituents once it has been

determined that the remedy is performing as expected and very little change is observed from one

sampling round to the next. In contrast, the monitoring frequency may need to be increased, for

example: (1) when unexpected conditions (e.g., plume migration or change in groundwater use) occur,

or (2) to determine the effect of modifications to a cleanup action (e.g., changes in pumping rates). 

How long should performance monitoring continue?

For final remedies that involve restoring contaminated groundwater to its maximum beneficial uses,

facilities should generally continue performance monitoring for a specified period (e.g., 3 years) after the

facility achieves the groundwater cleanup levels at the throughout-the-plume/unit boundary point of

compliance. Extending the performance monitoring to this point helps to verify that the groundwater no

longer poses a threat, and that concentrations of contaminants will not rise (i.e., “rebound”) after the

facility shuts down its active cleanup system. In general, regulators will typically determine how long

performance monitoring needs to continue for any given facility. For final cleanup objectives based on

containment, performance monitoring should continue as long as the containment is necessary to protect

human health and the environment.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Performance Monitoring, Pg. 14.3

References: 

EPA, 1997b. Rules of Thumb for Superfund Remedy Selection (EPA/540/R-97/013). Available at

http://www.epa.gov/superfund/resources/rules/rulesthm.pdf. 

EPA, 1997g. Groundwater Issue Paper: Design Guidelines for Conventional Pump and Treat Systems

(EPA/540/S-97/504). Available at 

http://www.epa.gov/oerrpage/superfund/resources/gwdocs/pmptreat.htm

EPA, 1996c. Presumptive Response Strategy and Ex-Situ Treatment Technologies for Contaminated

Ground Water at CERCLA Sites (EPA/540/R-96/023, October). Available at

http://www.epa.gov/oerrpage/superfund/resources/gwdocs/pum_tre.htm

EPA, 1996a. Advance Notice of Proposed Rulemaking (61 FR 19432, May 1). Available at

http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/May/Day-01/pr-547.pdf. Particularly relevant

pages: 19452-53. 

EPA, 1994a. Guidance for the Data Quality Objective Process (EPA/600/R-96/055, September). 

Available at: http://www.epa.gov/correctiveaction/resource/guidance/qa/epaqag4.pdf.

EPA, 1992b. RCRA Groundwater Monitoring Draft Technical Guidance (November). Available at

http://www.epa.gov/correctiveaction/resource/guidance/sitechar/gwmonitr/rcra_gw.pdf.

EPA, 1992c. Statistical Analysis of Groundwater Monitoring Data at RCRA Facilities -- Addendum to

Interim Final Guidance (July). Available at: 

http://www.epa.gov/correctiveaction/resource/guidance/sitechar/gwstats/gritsstat/download/addendum.

pdf.

EPA, 1992d. Methods for Evaluating Attainment of Cleanup Standards Volume 2: Groundwater

(EPA/230/R-92/014). Available at http://www.clu-in.org/download/stats/vol2gw.pdf
1

This Handbook addresses corrective action completion only in the context of contaminated groundwater

and sources of groundwater contamination. Facilities often have cleanup activities other than those associated with

groundwater that they need to address to fulfill all of their corrective action obligations. This section of the

Handbook was updated from the original September 2001 version to incorporate new Agency guidance (EPA, 2003)

that describes how corrective action can be considered “complete” with or without controls. 

2

EPA’s RCRA data management system (EPA, 1999f; available at

http://www.epa.gov/epaoswer/hazwaste/ca/facility/ca-diction.pdf) describes construction completion as code

CA550 titled “Certification of a Remedy Completion or Construction Completion.” 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Completing Groundwater Remedies, Pg. 15.1

Rationale for

Completing 

Groundwater Remedies

This policy on completing groundwater

remedies is meant to encourage regulators

and facilities to recognize construction

completion as well as achievement of final

cleanup goals for groundwater remedies. 

Recognition of these phases of completion

can demonstrate progress and promote

transfer of ownership of the property and

facilitate reuse of industrial property. This

policy also recognizes that EPA typically

considers groundwater remedies to be

complete when final goals are met, even

though long-term controls are required. 

15. Completing Groundwater Remedies

(January 2004)

What does it mean to complete a groundwater remedy?

EPA generally recognizes two phases of

completing1 a final groundwater remedy:

• implementing the final remedy such that all

components of the remedy are in place and

operating as intended;

• achieving final cleanup goals

What does it mean to complete the

implementation phase of a groundwater

remedy? 

Completing the implementation phase of a final

groundwater remedy means that physical

construction has been completed and the remedy is

operating as designed. At this point, cleanup

objectives have not necessarily been met, but the

remedial measures are in-place and operating as intended. Cleanup activities would typically be limited

to continued operation, maintenance and monitoring of the remedy. 

How does EPA acknowledge when a facility achieves the implementation phases of a final

remedy?

EPA generally uses “Construction Completion” to describe when a facility completed the

implementation phase of its final remedy for all media throughout the site (EPA, 1999f).

2
3 Media cleanup objectives refer to broad cleanup objectives that often include the more specific concepts

of media cleanup levels, points of compliance, and cleanup time frames. In the Overview section of this Handbook,

we explain that you could consider these three concepts as the “what, where, and when” elements of a cleanup. In

the 1996 ANPR (EPA, 1996a), EPA referred to media cleanup objectives as media cleanup standards; we now use

media cleanup objectives to avoid confusion with the term “standard,” which is often associated with just numeric

values.

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Completing Groundwater Remedies, Pg. 15.2

What does it mean to achieve the final cleanup goals for a groundwater remedy?

As conveyed earlier in this Handbook, a facility achieves final cleanup goals for groundwater by taking

actions as necessary to ensure protection of human health and the environment from contaminated

groundwater. As a means to demonstrate achieving this overall statutory and regulatory mandate, EPA

recommends that facilities achieve site-specific media cleanup objectives

3

, and control surface and

subsurface sources (see Source Control) to the extent practicable (see Technical Impracticability) that

would otherwise result in increases of contaminants in groundwater above levels of concern.

For example, for a final remedy designed to return contaminated groundwater to a condition suitable for

a drinking water use designation, this phase of completing a remedy typically means that the facility

achieved drinking water standards at a throughout-the-plume/unit boundary point of compliance and it

has controlled further releases of contaminants that might recontaminate the groundwater. Alternatively,

if the final remedy involves long-term containment, this phase of completion could, for example,

correspond to the facility successfully controlling sources and achieving groundwater cleanup levels at

and beyond an appropriate point of compliance typically located outside but near the containment area. 

How do facilities and regulators typically decide when a groundwater remedy achieves media

cleanup objectives? 

Facilities and regulators often rely on statistical procedures to determine whether a remedy has

achieved specific media cleanup objectives. Interested stakeholders can refer to EPA’s detailed

guidance on this subject contained in “Methods for Evaluating the Attainment of Cleanup Standards

Volume 2: Groundwater” (EPA, 1992d) which is available at

http://www.clu-in.org/download/stats/vol2gw.pdf. Some of the helpful topics and resources addressed

in that guidance include:

• Introduction to statistical concepts and decisions;

• Defining attainment objectives (e.g., cleanup levels);

• Designing the sampling and analysis plan used to determine success of cleanup; 

• Descriptive statistics (e.g., mean and variance) and hypothesis testing;

• Deciding to terminate treatment; and,

• Statistical tables, examples, and blank worksheets.
4

 Institutional controls could, where appropriate, include administrative measures for which the facility

owner /operator and/or some other entity, such as a state or local government, is responsible.

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Completing Groundwater Remedies, Pg. 15.3

How does EPA acknowledge when a facility achieves final cleanup goals for all media?

EPA recommends that regulatory agencies acknowledge when a facility achieves final cleanup goals for

all media with a "Corrective Action Complete with Controls" or "Corrective Action Complete without

Controls" determination (EPA, 2003). In addition, a completion determination might apply to the entire

facility or a portion(s) of a facility. We recommend that individuals review the Final Guidance for

Completion of Corrective Action Activities at RCRA Facilities (68 FR 8757; available at

http://www.epa.gov/correctiveaction/complete.pdf) for more guidance on these two types of corrective

action completion, their use, and procedures for acknowledging corrective action complete

determinations. 

What is the difference between Corrective Action Complete without Controls and Corrective

Action Complete with Controls?

Corrective Action Complete without Controls means that the facility meets the final site-specific cleanup

objectives for all media, and no further activity or controls are necessary on the part of the regulator or

the facility to maintain protection of human health and the environment. Since the facility will not need

to conduct operation, maintenance, or monitoring of a remedy, or any engineered or institutional

controls, it is likely that the facility will be eligible for a release from financial assurances for corrective

action.

In contrast, a Corrective Action Complete with Controls determination means that the facility meets the

final cleanup objectives, but on-going operation, maintenance and monitoring obligations of engineered

controls, and/or compliance with and maintenance of institutional controls are necessary to ensure

continued protection of human health and the environment. Since the facility will often have ongoing

obligations for which they are responsible, continuation of financial assurance for corrective action may

be necessary.

What type of Corrective Action Complete determination can a facility achieve for a final

remedy where groundwater cleanup is a component of the remedy?

The type of Completion determination generally depends on the groundwater cleanup objectives

selected as part of the final remedy. EPA has discovered that the universe of facilities subject to

corrective action requirements includes facilities that vary widely in complexity and level of risk

presented at the facility. To address this wide variation, EPA has developed multiple approaches to

achieving the final remedy goal of “protection of human health and the environment.” However, one of

the key distinctions among remedies is whether they rely upon controls (engineering and/or institutional

4

)

to ensure that they remain protective. 
5

 “Unrestricted use” refers to a walk-away situation, where no further activity or controls are necessary to

protect human health or the environment at the facility. For groundwater, cleaning up to drinking water standards

would generally represent unrestricted use. By comparison containment or cleanup of groundwater to levels in

excess of drinking water standards would usually not be an unrestricted use scenario.

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Completing Groundwater Remedies, Pg. 15.4

In some cases the regulator selects a final remedy that requires cleanup of groundwater and all other

contaminated media to unrestricted use5 levels. Once the facility achieves those unrestricted use levels

for all contaminated media, no controls are necessary to ensure protection; therefore, a corrective

action complete without controls determination would generally be appropriate. In other cases, the

regulator selects a remedy that allows some contamination to remain on site, but relies on engineering

and/or institutional controls to ensure appropriate protection. At sites where final groundwater cleanup

objectives allow contaminated groundwater to remain in place above concentrations suitable for

unrestricted use, a Corrective Action Complete with Controls determination would generally be

appropriate because the remedy would be relying on engineering and/or institutional controls to prevent

future exposure to the contaminated groundwater in such a situation.

References: 

EPA, 2003. Final Guidance on Completion of Corrective Action Activities at RCRA Facilities (68 FR

8757, February 25). Available at http://www.epa.gov/correctiveaction/complete.pdf.

EPA, 1999f. Resource Conservation and Recovery Act Data Element Dictionary - version 7.2.0. 

Available at http://www.epa.gov/epaoswer/hazwaste/ca/facility/ca-diction.pdf. 

EPA, 1996a. Advance Notice of Proposed Rulemaking (61 FR 19432, May 1). Available at 

http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/May/Day-01/pr-547.pdf. Particularly relevant

page: 19453. 

EPA, 1992d. Methods for Evaluating Attainment of Cleanup Standards Volume 2: Groundwater

(EPA/230/R-92/014). Available at http://www.clu-in.org/download/stats/vol2gw.pdf
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

 Appendix 1, Pg. 1

Appendix 1 - References

EPA, 2002. OSWER Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from

Groundwater and Soils (Subsurface Vapor Intrusion Guidance). Available at 

http://www.epa.gov/epaoswer/hazwaste/ca/eis/vapor.htm.

EPA, 2001a. EPA Indian Policy (July 11). Available at

http://www.epa.gov/indian/pdfs/reaffirmindpol01.pdf. 

EPA, 2001b. ECO-UPDATE: The Role of Screening Level Risk Assessments and Refining

Contaminants of Concern in Baseline Ecologic Risk Assessments (EPA/540/F-01/014, June). 

Available at http://www.epa.gov/superfund/programs/risk/ecoup/slera0601.pdf. 

EPA, 2001c. Risk Business (EPA/530/F-00/032, February). Available at

http://www.epa.gov/epaoswer/osw/docs/riskfinal.pdf. 

EPA, 2001d. RCRA Cleanup Reforms Round II -- Fostering Creative Solutions (EPA/530/F-01/001,

January). Available at http://www.epa.gov/epaoswer/hazwaste/ca/reforms.htm.

EPA, 2000a. Applicability of RCRA Section 3020 to In-Situ Treatment of Ground Water. 

Memorandum from Elizabeth Cotsworth, Director, Office of Solid Waste to RCRA Senior Policy

Advisors (December 27). Available at

http://www.epa.gov/epaoswer/hazwaste/ca/resource/guidance/remwaste/refrnces/pol-mem3.pdf. 

EPA, 2000b. Institutional Controls: A Site Manager’s Guide to Identifying, Evaluating and Selecting

Institutional Controls at Superfund and RCRA Corrective Action Cleanups (EPA/540/F-00/005,

September). OSWER Directive 9355.0-74FS-P. Available at

http://www.epa.gov/superfund/action/ic/guide/index.htm.

EPA, 2000c. Proceedings of the Ground-Water/Surface-Water Interactions Workshop (EPA/542/R00/007, July). Available at http://www.epa.gov/tio/tsp/download/gwsw/gwsw_part1.pdf,

http://www.epa.gov/tio/tsp/download/gwsw/gwsw_part2.pdf, and

http://www.epa.gov/tio/tsp/download/gwsw/gwsw_part3.pdf.

EPA, 1999a. Corrective Action for Solid Waste Management Units at Hazardous Waste Management

Facilities (64 FR 54604, October 7). Available at

http://www.epa.gov/correctiveaction/resource/guidance/gen_ca/withdrwl.htm.

EPA, 1999b. Safe Drinking Water Act, Section 1429 Groundwater Report to Congress 

(EPA/816/R-99/016, October). Available at http://www.epa.gov/ogwdw000/gwr/finalgw.pdf. 

EPA, 1999c. RCRA Cleanup Reforms (EPA/530/F-99/018, July). For more information, refer to

http://www.epa.gov/epaoswer/hazwaste/ca/reforms.htm
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

 Appendix 1, Pg. 2

EPA, 1999d. Use of Monitored Natural Attenuation at Superfund, RCRA Corrective Action and

Underground Storage Tank Sites (April 21). OSWER Policy Directive 9200.4-17P. Available at

http://www.epa.gov/swerust1/directiv/d9200417.htm. Other helpful links regarding MNA available at

http://www.epa.gov/swerust1/cat/mna.htm and http://www.epa.gov/swerust1/oswermna/mnalinks.htm 

EPA, 1999e. Interim Final Guidance for RCRA Corrective Action Environmental Indicators (February

5). Available at http://www.epa.gov/epaoswer/hazwaste/ca/eis/ei_guida.pdf . 

EPA, 1999f. Resource Conservation and Recovery Act Data Element Dictionary - version 7.2.0. 

Available at http://www.epa.gov/oswfiles/rcrisbrs/rcris720/ded/ded720.pdf. 

EPA, 1998a. RCRA Orientation Manual (EPA/530/R-98/004). Available at

http://www.epa.gov/epaoswer/general/orientat/index.htm.

EPA, 1998b. Technical Protocol for Evaluating Natural Attenuation of Chlorinated Solvents in

Groundwater (September). EPA/600/R-98/128. Available at

http://www.epa.gov/correctiveaction/resource/guidance/rem_eval/protocol.pdf.

EPA, 1998c. Memorandum from Elizabeth Cotsworth to RCRA Senior Policy Advisors titled, RiskBased Clean Closure (March 16). Available at 

http://www.epa.gov/correctiveaction/resource/guidance/risk/cclosfnl.pdf.

EPA, 1998d. Standards Applicable to Owners and Operators of Closed and Closing Hazardous

Waste Management Facilities: Post-Closure Permit Requirement and Closure Process; Final Rule (63

FR 56710). Available at

http://www.epa.gov/fedrgstr/EPA-WASTE/1998/October/Day-22/f28221.pdf.

EPA, 1997a. Memorandum from Elliott P. Laws and Steven A. Herman to RCRA/CERCLA Senior

Policy Managers titled, “Use of the Corrective Action Advance Notice of Proposed Rulemaking as

Guidance” (January 17). Available at

http://yosemite.epa.gov/osw/rcra.nsf/documents/8BF009F9B3672563852566110072DA71. 

EPA, 1997b. Rules of Thumb for Superfund Remedy Selection (EPA/540/R-97/013). Available at

http://www.epa.gov/superfund/resources/rules/rulesthm.pdf. 

EPA, 1997c. A Citizen’s Guide to Understanding Presumptive Remedies (EPA/540/F-97/019,

October). Available at http://www.epa.gov/superfund/resources/presump/finalpdf/citizen.pdf. 

EPA, 1997d. State Source Water Assessment and Protection Programs Guidance (EPA/816/R97/009, August). Available at http://www.epa.gov/OGWDW/source/swpguid.html.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

 Appendix 1, Pg. 3

EPA, 1997e. The Role of Comprehensive State Groundwater Protection Programs (CSGWPPS) in

OSWER Remediation Programs. OSWER Directive 9283.1-09. Available at

http://www.epa.gov/superfund/resources/csgwpp/role.pdf. 

EPA, 1997f. Exposure Factors Handbook (EPA/600/P-95/002F). Available at

http://www.epa.gov/ncea/exposfac.htm.

EPA, 1997g. Groundwater Issue Paper: Design Guidelines for Conventional Pump and Treat Systems

(EPA/540/S-97/504). Available at http://www.epa.gov/oerrpage/superfund/resources/gwdocs/

pmptreat.htm

EPA, 1996a. Advance Notice of Proposed Rulemaking (61 FR 19432, May 1). Available at 

http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/May/Day-01/pr-547.pdf.

EPA, 1996b. Memorandum from Steven A. Herman and Elliott P. Laws to RCRA/CERCLA Senior

Policy Managers titled, “Coordination between RCRA Corrective Action and Closure and CERCLA

Site Activities” (September 24). Available at

http://www.epa.gov/correctiveaction/resource/guidance/gen_ca/coordmem.pdf. 

EPA, 1996c. Presumptive Response Strategy and Ex-Situ Treatment Technologies for Contaminated

Groundwater at CERCLA Sites (EPA/540/R-96/023, October). Available at

http://www.epa.gov/superfund/resources/gwguide/gwfinal.pdf.

EPA, 1996d. RCRA Public Participation Manual (EPA/530/R-96/007). Available at

http://www.epa.gov/epaoswer/hazwaste/permit/pubpart/manual.htm. Particularly relevant pages: 2.5-

2.7.

EPA, 1996e. Soil Screening Guidance Fact Sheet (EPA/540/F-95/041, July). Available at

http://www.epa.gov/oerrpage/superfund/resources/soil/.

EPA, 1995a. Consistent Implementation of the FY 1993 Guidance on Technical Impracticability of

Ground Water Restoration at Superfund Sites (January). OSWER Directive 9200.4-14. Additional

information available at

http://www.epa.gov/oerrpage/superfund/resources/gwdocs/tec_imp.htm.

EPA, 1995b. Groundwater Issue: Light Non-Aqueous Phase Liquids (EPA/540/S-95/500). Available

at http://www.epa.gov/ada/download/issue/lnapl.pdf. 

EPA, 1994a. Guidance for the Data Quality Objective Process (EPA/600/R-96/055, September). 

Available at http://www.epa.gov/correctiveaction/resource/guidance/qa/epaqag4.pdf.

EPA, 1994b. The RCRA Corrective Action Plan (EPA/520/R-94/004, May). Available at

http://www.epa.gov/correctiveaction/resource/guidance/gen_ca/rcracap.pdf.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

 Appendix 1, Pg. 4

EPA, 1994c. DNAPL Site Characterization (EPA/540/F-94/049). Available at

http://www.epa.gov/oerrpage/superfund/resources/gwdocs/dnapl.pdf. 

EPA, 1993a. Guidance for Evaluating the Technical Impracticability of Groundwater Restoration 

(EPA/540/R-93/080, September). Available at

http://www.epa.gov/oerrpage/superfund/resources/gwdocs/techimp.htm

EPA, 1993b. Waste Management Area and Supplemental Well Guidance (June). Available at

http://www.epa.gov/correctiveaction/resource/guidance/gw/wma_sup.htm.

EPA, 1992a. Final Comprehensive State Groundwater Protection Program Guidance (EPA/100/R93/001). Available at 

http://www.epa.gov/correctiveaction/resource/guidance/gw/csgwpp.htm. 

EPA, 1992b. RCRA Groundwater Monitoring Draft Technical Guidance (November). Available at

http://www.epa.gov/correctiveaction/resource/guidance/sitechar/gwmonitr/rcra_gw.pdf.

EPA, 1992c. Statistical Analysis of Groundwater Monitoring Data at RCRA Facilities - Addendum to

Interim Final Guidance (July). Available at: http://www.epa.gov/correctiveaction/

resource/guidance/sitechar/gwstats/gritsstat/download/addendum.pdf.

EPA, 1992d. Methods for Evaluating Attainment of Cleanup Standards Volume 2: Groundwater

(EPA/230/R-92/014). Available at http://www.clu-in.org/download/stats/vol2gw.pdf

EPA, 1991a. Managing the Corrective Action Program for Environmental Results: The RCRA

Stabilization Effort (October 25). Available at

http://yosemite.epa.gov/osw/rcra.nsf/d8382df2d09b64668525652800519745/27d1baa5c1dbb8f3852

5670f006be76d?OpenDocument.

EPA, 1991b. Protecting the Nation’s Groundwater: EPA’s Strategy for the 1990's. Office of the

Administrator. Washington, D.C. Available at

http://www.epa.gov/superfund/resources/remedy/pdf/21z-1020-s.pdf.

EPA, 1991c. A Guide to Principal Threats and Low Level Threat Wastes. Superfund Publication

9380.3-06FS (November). Available at

http://www.epa.gov/oerrpage/superfund/resources/gwdocs/threat.pdf. 

EPA, 1991d. USEPA’s User’s Guide for the Johnson and Ettinger Model for Subsurface Vapor

Intrusion into Buildings. Available at

http://www.epa.gov/oerrpage/superfund/programs/risk/airmodel/guide.pdf. The model itself can be

downloaded from 

http://www.epa.gov/oerrpage/superfund/programs/risk/airmodel/johnson_ettinger.htm.
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

 Appendix 1, Pg. 5

EPA, 1990a. The Nation’s Hazardous Waste Management Program at a Crossroads: The RCRA

Implementation Study (EPA/530/SW-90/069). 

EPA, 1990b. National Oil and Hazardous Waste Contingency Plan (55 FR 8666 and 40 CFR 300). 

The preamble is available at

http://www.epa.gov/superfund/action/guidance/remedy/pdfs/ncppreamble61.pdf. The CFR is available

through http://www.access.gpo.gov/nara/cfr/waisidx_00/40cfrv20_00.html. 

EPA, 1990c. Corrective Action for Solid Waste Management Units at Hazardous Waste management

Facilities; Proposed Rule (55 FR 30798). 

EPA, 1989a. OSWER Directive 9234.1-06, “Applicability of Land Disposal Restrictions to RCRA

and CERCLA Groundwater Treatment Reinjection Superfund Management Review: Recommendation

No. 26,” (November 27). Available at

http://www.epa.gov/epaoswer/hazwaste/ca/resource/guidance/remwaste/refrnces/14_3020b.pdf. 

EPA, 1989b. National Priorities List for Uncontrolled Hazardous Waste Sites – Final Rule Covering

Sites Subject to the Subtitle C Corrective Action Authorities of the Resource Conservation and

Recovery Act (commonly referred to as the RCRA Deferral Policy). Available in Section V, which

appears on 54 FR 41004-41006. Available at

http://www.epa.gov/superfund/sites/npl/f891004.htm#41000.

EPA, 1989c. Risk Assessment Guidance for Superfund Volume I: Human Health Evaluation Manual

(Part A). Available at http://www.epa.gov/superfund/programs/risk/ragsa/index.htm.

EPA, 1988. OSWER Directive 9283.1-2, “Guidance on Remedial Actions for Contaminated

Groundwater at Superfund Sites,” (December 1).

EPA, 1987. Alternate Concentration Limit Guidance (EPA/530/SW-87/017). Available at

http://www.epa.gov/correctiveaction/resource/guidance/gw/acl.htm. 

EPA, 1986. Guidelines for Groundwater Classification under the EPA Groundwater Protection

Strategy. Available at http://www.epa.gov/correctiveaction/resource/guidance/gw/gwclass.htm.

NRC, 2000. Natural Attenuation for Groundwater Remediation. Committee on Intrinsic

Remediation, Water Science and Technology Board, Board on Radioactive Waste Management,

National Research Council. Available at http://www.nap.edu/catalog/9792.html

NRC, 1994. Alternatives for Groundwater Cleanup / Committee on Groundwater Cleanup

Alternatives, Water Science and Technology Board, Board on Radioactive Waste Management,

Commission on Geosciences, Environment, and Resources, National Research Council. National

Academy Press, 1994. Available at http://www.nap.edu/books/0309049946/html/. 
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

 Appendix 2, Pg. 1

Appendix 2 - Links to Other Helpful Internet Resources 

EPA’s Corrective Action Programs Branch http://www.epa.gov/correctiveaction/

RCRA On-line http://www.epa.gov/rcraonline/

- enables users to locate documents, including 

publications and other outreach materials 

EPA’s Superfund Program http://www.epa.gov/superfund/

EPA’s Enforcement Program http://www.epa.gov/compliance 

EPA’s Office of Underground Storage Tank http://www.epa.gov/swerust1/index.htm

EPA’s Water Program http://www.epa.gov/OW/

EPA’s Technology Innovation Office http://www.clu-in.org/ 

The Training Exchange (TRAINEX) http://www.trainex.org/

S provides a range 

of training information concerning 

hazardous waste management and remediation.

EPA’s Remediation and Characterization

Innovative Technologies (REACH IT) http://www.epareachit.org/index3.html

Government Performance and Results Act http://www.epa.gov/ocfo/planning/gpra.htm

EPA’s Brownfields Homepage http://www.brownfieldstsc.org/

EPA’s Office of Research and Development - 

Subsurface Protection & Remediation Division http://www.epa.gov/ada/

Association of States and Territorial Solid

Waste Management Officials http://www.astswmo.org/

Tribal Association on Solid Waste and 

Emergency Response http://www.taswer.org/

American Indian Environmental Office http://www.epa.gov/indian/

RCRA Hotline http://www.epa.gov/epaoswer/hotline/index.htm
1

The definitions in this Glossary are for the purposes of this Handbook only. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

 Appendix 3, Pg. 1

Appendix 3 - Glossary 

Glossary Internet Links 

Terms of Environment (including a list of common acronyms) produced by EPA’s Office of

Communication, Education and Public Affairs (OCEPA) - available at

http://www.epa.gov/OCEPAterms/ 

Glossary of Integrated Risk Information System (IRIS) Terms - available at

http://www.epa.gov/iris/gloss8.htm

Office of Water Glossary - available at http://www.epa.gov/safewater/glossary.htm

Handbook Glossary of Terms 1

cleanup - The term ”cleanup” or the phrase “cleaning up” refers to the range of activities that could

occur in the context of addressing environmental contamination at RCRA facilities. For example,

cleanup activities could include removing waste or contaminated media (e.g., excavation, and pumping

groundwater), in-place treatment of the waste or contaminated media (e.g., bioremediation),

containment of the waste or contaminated media (e.g., barrier walls, low-permeable covers, and liners),

or various combinations of these approaches. The term cleanup is often used interchangeably with the

term remediate. 

cleanup timeframes - The cleanup timeframe, with respect to groundwater, is an estimate of when

groundwater quality will achieve a certain level at a specified location and/or the schedule developed to

take an action or construct a remedy designed to achieve a particular short-term protection,

intermediate performance, or final cleanup goal. (source - EPA, 1996a)

Comprehensive State Groundwater Protection Program (CSGWPP) - a groundwater

management strategy developed by a State. EPA reviews CSGWPPs and “endorses” those that

successfully meet six strategic activities. EPA established recommended adequacy criteria for each

strategic activity in CSGWPP guidance. In particular, EPA remediation programs review State

guidelines in the CSGWPP to prioritize groundwater based upon use, value, and vulnerability. EPA’s

Office of Solid Waste and Emergency Response issued a directive (EPA, 1997e) encouraging EPA’s

remediation programs to defer, where appropriate, to State determinations of current and future use

when based on an EPA-endorsed CSGWPP that has provisions for facility-specific decisions. (source

- EPA, 1992a)

contamination - describes media containing contaminants in any form (e.g., non-aqueous phase
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

 Appendix 3, Pg. 2

liquids, dissolved in water, vapors, and solids) that are subject to cleanup under RCRA and are

present in concentrations in excess of appropriately protective levels of concern. (source - EPA,

1999e)

contingency plan - (or contingency remedy or a contingency measure) is a cleanup approach specified

in a remedy decision document that functions as a “backup” remedy in the event that the “selected”

remedy fails to perform as anticipated. (source - EPA, 1999d)

dense non-aqueous phase liquids (DNAPLs) - such as chlorinated solvents, creosote-based woodtreating oils, coal tar wastes, and pesticides are immiscible (i.e., they are not dissolved in water) fluids

[most commonly organic] with a density greater than water. (source - EPA, 1994c and EPA, 1995b) 

environmental indicators (for RCRA corrective action) - two corrective action environmental

indicators, Current Human Exposures Under Control and Migration of Contaminated Groundwater

Under Control, are measures of program progress and are being used by the Agency to track whether

it meets the goals set under the Government Performance and Results Act (GPRA). In general terms,

these measures indicate current “environmental conditions”– whether people are currently being

exposed to environmental contamination at unacceptable levels, and whether any existing plumes of

contaminated groundwater are getting larger or adversely affecting surface water bodies. 

Environmental indicator guidance for the RCRA Corrective Action Program is available at

http://www.epa.gov/correctiveaction/eis.htm. (source - EPA, 1999e) 

excess lifetime risk - the additional or extra risk of developing cancer due to exposure to a toxic

substance incurred over the lifetime of an individual (source: Glossary of IRIS Terms available at

http://www.epa.gov/iris/gloss8.htm ).

groundwater use designation - a determination of reasonably anticipated use, resource value (e.g.,

priority), and/or vulnerability of groundwater in a particular area. (source - adapted from EPA, 1992a)

groundwater cleanup levels - facility-specific chemical concentrations in groundwater that regulators

generally establish when defining groundwater cleanup levels for final remedies. (source - adapted from

EPA, 1996a)

groundwater cleanup objectives - includes three components: groundwater cleanup levels, point of

compliance, and cleanup timeframes. (source - EPA, 1996a)

institutional controls - non-engineered instruments such as administrative and/or legal controls that

minimize the potential for human exposure to contamination by limiting land or resource use. (source -

EPA, 2000b).

maximum beneficial groundwater use - within the range of reasonably expected uses, the maximum

(or highest) beneficial groundwater use warrants the most stringent groundwater cleanup levels. (source
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

 Appendix 3, Pg. 3

- adapted from EPA, 1996a) 

monitored natural attenuation - refers to the reliance on natural attenuation processes (within the

context of a carefully controlled and monitored site cleanup approach) to achieve site-specific

remediation objectives within a timeframe that is reasonable compared to that offered by other more

active methods. The natural attenuation processes that are at work in such a remediation approach

include a variety of physical, chemical, or biological processes that, under favorable conditions, act

without human intervention to reduce the mass, toxicity, mobility, volume or concentration of

contaminants in soil or groundwater. (source - EPA, 1999d)

non-aqueous phase liquids (NAPLs) - are hydrocarbons that exist as a separate immiscible phase

when in contact with water or air. Differences in the physical and chemical properties of water and

NAPLs result in the formation of a physical interface between the two fluids which prevent the two

fluids from mixing. NAPLs are typically classified as either light non-aqueous phase liquids (LNAPLs),

which have densities less than that of water, or dense non-aqueous phase liquids, which have densities

greater than that of water. (source - EPA, 1995b). [Note, some professionals have referred to NAPLs

with densities close to that of water as neutrally buoyant non-aqueous phase liquids (NNAPLs).]

presumptive remedies - preferred technologies for common categories of sites, based on historical

patterns of remedy selection and EPA’s scientific and engineering evaluation of how well technologies

perform. You can access EPA’s guidance on presumptive remedies at

http://www.epa.gov/superfund/resources/presump. (source - EPA, 1997c)

principal threats - source materials considered to be highly toxic or highly mobile that generally cannot

be reliably contained or would present a significant risk to human health or the environment should

exposure occur. (Source - EPA, 1997b and EPA, 1991c) 

point of compliance - for groundwater, represents where a facility should monitor groundwater quality

and/or achieve specified levels of groundwater quality to achieve facility-specific cleanup goals. (source

- adapted from EPA, 1996a)

RCRA regulated units - surface impoundments, waste piles, land treatment units, and landfills that

received hazardous waste after July 26, 1982. (source - 40 CFR 264.90)

releases - any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping,

leaching, dumping, or disposing into the environment of a hazardous or toxic chemical, or extremely

hazardous substance. (source - http://www.epa.gov/OCEPAterms/rterms.html) 

remedy expectations - are not binding requirements; rather, they reflect collective experience and are

designed to guide development of remedial alternatives. In effect, remedial expectations allow program

implementers and facility owner/operators to profit from prior EPA experience and focus resources on

the most plausible remedial alternatives. (source - EPA, 1996a, page 19448)
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

 Appendix 3, Pg. 4

source control - Source control refers to a range of actions (e.g., removal, treatment in place, and

containment) designed to protect human health and the environment by eliminating or minimizing

migration of or exposure to significant contamination. (source - adapted from EPA, 1996a)

source materials - material that includes or contains hazardous substances, pollutants or contaminants

that act as a reservoir (either stationary or mobile) for migration of contamination to groundwater, to

surface water, to air (or other environmental media)], or acts as a source for direct exposure. 

Contaminated groundwater generally is not considered to be a source material although non-aqueous

phase liquids (occurring as residual or free-phase) may be viewed as source materials. (source - EPA,

1991c)

stabilization - refers to “stabilizing” a situation so that, for example, the contamination does not

represent unacceptable near-term threats or does not continue to spread. Stabilization used in this

context does not refer to engineered treatment used to “solidify” wastes although such technologies

could be used as a stabilization action. (source - EPA, 1991a)

stakeholders - term used in this Handbook collectively referring to State and EPA regulators, owners

and operators of facilities subject to RCRA corrective action, members of tribal governments, and

members of the public and affected communities. The “public” in the context of RCRA refers not only

to private citizens, but also representatives of consumer, environmental, and minority associations;

trade, industrial, agricultural, and labor organizations; public health, scientific, and professional societies;

civic associations; public officials; and government and educational associations.

technical impracticability (TI) - refers to a situation where achieving groundwater cleanup levels

associated with final cleanup goals is not practicable from an “engineering perspective.” The phrase

“engineering perspective” refers to how factors such as feasibility, reliability, scale, and safety influence

the ability to achieve groundwater cleanup objectives. (source - EPA, 1993a)

usable groundwater - EPA recognizes that “usable” groundwater may serve a variety of purposes. 

Common purposes of groundwater include, for example, drinking water, agricultural irrigation, car

washes, and manufacturing. Groundwater also has less formally acknowledged purposes such as

replenishing adjacent aquifers or surface water bodies. For more guidance regarding groundwater use,

see the groundwater use designation policy in this Handbook.