1

Handbook of Groundwater 

Protection and Cleanup Policies for 

RCRA Corrective Action

Handbook of Groundwater 

Protection and Cleanup Policies for 

RCRA Corrective Action

Speakers:

Guy Tomassoni, EPA HQ, 703/308-8622

Deborah Goldblum, EPA III, 215/814-3432 

Joel Hennessy, EPA III, 215/814-3390

Welcome to RCRA Corrective Action Internet Briefing

Sponsored by EPAís Technology Innovation Office &

the Corrective Action Programs Branch in the 

Office of Solid Waste
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Purpose of Session Purpose of Session

Introduction to the Handbook

Describe background information, goals 

and key messages

Describe user-friendly format

Summarize key policies 

Describe next steps 

Provide time for Q&A 
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Session Logistics Session Logistics 
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Background Background

Identified in RCRA Cleanup Reforms I

Developed by EPA-HQ and Region III staff

Predominantly based on May 1,1996 ANPR, 

and joint RCRA/CERCLA guidance 

Comment period (May 3-July 2, 2000); 

final posted 10/15/01 on CA web site 

(www.epa.gov/correctiveaction)
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Goals

Help meet reform objectives: faster, 

focused, more flexible cleanups and foster 

creative solutions by ...

Compiling, summarizing and clarifying key Compiling, summarizing and clarifying key 

groundwater policies in one document, and groundwater policies in one document, and 

thus... thus...

Reducing time consuming uncertainties and Reducing time consuming uncertainties and 

confusion

Promote national dialogue on groundwater Promote national dialogue on groundwater 

issues
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Key Messages Key Messages

Conveys importance of groundwater 

resources

Promotes results-based, phased approach 

Highlights flexibility 

Conveys document is guidance, not rule

Emphasizes states as primary implementers 

& decision makers 
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Format

Question/answer, plain language 

Includes rationale for each policy

Includes glossary & extensive references

Over 50 references available via direct ailable via direct 

hyperlinks! hyperlinks!

Internet based with internal/external links 

Easy to update (keep ìevergreenî) as 

policies evolve
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Topics Addressed Topics Addressed

• Overview

• Groundwater protection 

and cleanup strategy* 

• Short-term protection 

goals

• Intermediate 

performance goals*

• Final cleanup goals

• 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

• References

• Internet resources 

• Glossary 

*reflects final version - new sections in response to 

comments
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Key Questions from Overview Key Questions from Overview 

Who should use the Handbook?

What are general roles and responsibilities?

How do the policies apply to States?

Where do the policies come from?

How will I know the policies are current?
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Groundwater Protection and 

Cleanup Strategy

Groundwater Protection and 

Cleanup Strategy

Focus on priority sites 

Control short-term threats

Prioritize actions within facilities

Return usable groundwaters to maximum 

beneficial use

Emphasize clear communication

What, where, when, who, why and how
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Short-Term Goals

control risks to humans, stop 

groundwater problems from 

getting bigger, focus resources, 

help give clearer picture of 

challenges ahead

Intermediate Goals

establish achievable 

milestones when moving 

directly from short-term to 

final goals is particularly 

challenging

Final Cleanup Goals

define what it takes to implement 

a successful final remedy 

RCRA Corrective Action Results

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Short Term Protection Goals

(Environmental Indicators)

Short Term Protection Goals

(Environmental Indicators)

Ensure:

Humans are not being exposed to unacceptable Humans are not being exposed to unacceptable 

levels; and

Contaminated groundwater is not migrating Contaminated groundwater is not migrating 

above levels of concern

Other key messages:

Who evaluates and determines Who evaluates and determines 

Discusses key exposure Discusses key exposure routes (e.g., air and routes (e.g., air and 

groundwater/surface water) groundwater/surface water)

Relationship to intermediate and final goals
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Intermediate Performance Goals Intermediate Performance Goals

Demonstrate progress

Facility specific

EPA encourages intermediate goals to: 

Focus resources Focus resources 

Improve environmental conditions Improve environmental conditions 

Enhance performance of cleanups

Consistent with phased approaches

Examples: source control, off-site plumes
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Final Cleanup Goals Final Cleanup Goals

Three threshold criteria:

Protect human health and environment Protect human health and environment

Achieve ìmedia cleanup objectivesî Achieve ìmedia cleanup objectivesî

Controls sources to the extent practicable

Other key messages: 

Return usable groundwaters to maximum Return usable groundwaters to maximum 

beneficial uses wherever practicable

Long-term containment where appropriate term containment where appropriate 

Streamlined evaluations Streamlined evaluations 
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Groundwater Cleanup Levels Groundwater Cleanup Levels

Chemical concentrations supporting facilityspecific objectives

Use existing cleanup standards Use existing cleanup standards 

when available and appropriate when available and appropriate 

Risk range (10-4 to 10-6) and hazard ) and hazard 

quotient of one applies quotient of one applies 

Lower or higher could be appropriate

Consider Consider gw use designation, use designation, 

exposures, and cross-media transfer media transfer 

(e.g., to surface water and air), and (e.g., to surface water and air), and 

ecologic protection ecologic protection 
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Point of Compliance (POC) Point of Compliance (POC)

Conveys general definition - location to 

measure and meet cleanup numbers 

Different POC options depending on goals, 

e.g., 

Short term Short term - plume boundary plume boundary 

Final - throughout the plume/unit boundary if throughout the plume/unit boundary if 

goal involves returning groundwater to goal involves returning groundwater to 

particular cleanup level particular cleanup level

Intermediate Intermediate - facility specific
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Groundwater 

Flow Direction

Plume Boundary

Property Boundary

Plume boundary point of compliance for short-term 

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 ìcontaminatedî and ìuncontaminatedî 

monitoring wells.
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Groundwater 

Flow Direction

Plume Boundary

Property Boundary

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.
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Groundwater 

Flow Direction

Plume Boundary

Property Boundary

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.

Off-site Plume
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Cleanup Timeframe Cleanup Timeframe

Facility-specific schedule for the groundwater 

remedy

Time to construct remedy Time to construct remedy 

Estimate of time needed to achieve cleanup Estimate of time needed to achieve cleanup 

levels at the POC

Should be reasonable given facility-specific 

conditions

e.g., longer timeframes e.g., longer timeframes may be acceptable where may be acceptable where 

groundwater is not currently being used for groundwater is not currently being used for 

drinking water drinking water
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Source Control Source Control

Removal, treatment, or containment

Source - reservoir for continued reservoir for continued 

migration

Key element for most cleanups

Threshold criterion for final remedies

Balance between treatment and 

containment 

Preference for treatment of ìprincipal 

threatsî

Recognizes when treatment of principal Recognizes when treatment of principal 

threats may not be appropriate
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Groundwater Use Designations Groundwater Use Designations

Based on use, value and 

vulnerability

state-wide system

Examples of factors to consider:

Quantity, quality, and yield Quantity, quality, and yield 

Reasonably expected future use

Other key messages:

Discourages current use as only factor Discourages current use as only factor 

States generally define use

Many states designate all Many states designate all gw as drinking as drinking 

water
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Institutional Controls (ICs) Institutional Controls (ICs)

Administrative controls

Handbook defines general categories and 

examples of ICs 

Recommends ICs go through evaluation, 

selection, implementation and O&M stages

Operation and Maintenance includes ìmonitoringî Operation and Maintenance includes ìmonitoringî

Provides examples for contaminated groundwater

well drilling prohibitions, easements to provide , easements to provide 

access to monitor gw or access to drilling, access to monitor gw or access to drilling, 

enforceable conditions in permits/orders, etc. permits/orders, etc. 
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Monitored Natural Attenuation Monitored Natural Attenuation

Cleanup approach relying on natural 

processes and monitoring

Policy identifies factors where MNA is likely 

candidate:

Capable of achieving cleanup objectives

Degradation is dominant process Degradation is dominant process 

Remedy includes source control Remedy includes source control

Plumes are already stable or shrinking

Used in conjunction wi Used in conjunction with active approaches th active approaches 

or as a follow-up measure
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Technical Impracticability (TI) Technical Impracticability (TI)

Situations where achieving groundwater cleanup 

levels for a final remedy is not practicable from an 

ìengineering perspectiveî

Needs to be technically justified

Mere presence of NAPL not sufficient Mere presence of NAPL not sufficient 

Alternative remedial strategy

POC applies outside TI zone

Can be revisited if cleanup becomes Can be revisited if cleanup becomes 

ìtechnically practicableî in future
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Reinjection of Contaminated 

Groundwater

Reinjection of Contaminated 

Groundwater

Describes exemption to ban on injecting 

hazardous wastes into or above a drinking 

water aquifer

Allows injection of groundwater contaminated Allows injection of groundwater contaminated 

with ìhazardous wastesî back into aquifer with ìhazardous wastesî back into aquifer 

Must be treated to substantially reduce Must be treated to substantially reduce 

hazardous constituents ei hazardous constituents either before injection ther before injection 

or as a result of subsequent in-situ treatment situ treatment

Part of a RCRA or Superfund cleanup

Coordination with State is important!
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Performance Monitoring Performance Monitoring

Periodic measurement of chemical 

and/or physical parameters 

to evaluate whether facility is to evaluate whether facility is 

achieving particular goals

Type, location and frequency should 

be based on monitoring objectives 

and facility-specific factors

Should continue for a specified time 

after facility achieves final cleanup 

goals
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Completing Groundwater 

Remedies 

Completing Groundwater 

Remedies 

Final Handbook recognizes three 

phases of completion

implementing (i.e., construction is implementing (i.e., construction is 

completed and remedy is operating) the completed and remedy is operating) the 

remedy

achieving final cleanup goals with achieving final cleanup goals with 

controls controls 

fulfilling all cleanup obligations fulfilling all cleanup obligations 

including long-term monitoring
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Next Steps Next Steps 

Promote continued open dialogue 

Update Handbook to reflect changes in policies 

and add new topics; e.g., 

site characterization

groundwater / surface water interaction groundwater / surface water interaction 

groundwater to indoor air groundwater to indoor air
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For additional information or questions, 

please call or e-mail:

Guy Tomassoni 703/308-8622

tomassoni.guy@epa.gov

Handbook, fact sheet, cover letter and FR 

notice available at:

http://www.epa.gov/correctiveaction
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Links to related resources