United States

Environmental Protection

Agency

Solid Waste and

Emergency Response

(5303W)

EPA/530/R-01/015

September 2002*

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. The sole purpose of this September 2002 version is to

update a number of Internet links to ensure that cited references and resources are available to the reader. Note,

however, that each policy section of the Handbook continues to retain the original September 2001 date since no

substantive textural changes were made in this updated version. In the event of substantive changes to a policy

section(s), the date on top of that section will be changed accordingly. 
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 Groundwater Compliance 

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 the two environmental indicators the only short-term protection goals 

facilities should consider? ................................................... 2.7
Table of Contents, Pg. 2

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

What are intermediate performance goals for groundwater? ................................. 3.1

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? ....... 4.4

How thorough of an assessment should facilities conduct when evaluating 

one or more remedial options? ................................................ 4.5

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? .............................. 4.6

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 that should be 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
Table of Contents, Pg. 3

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

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 which 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? . 9.5

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
Table of Contents, Pg. 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

What if a facility wants to reinject 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 completing a groundwater remedy mean with respect to RCRA Corrective Action? ..... 15.1

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

What does it mean to complete a groundwater remedy with respect to achieving final cleanup goals? 15.2

What does it mean to fulfill all cleanup obligations associated with contaminated groundwater 

at a particular facility? ..................................................... 15.2

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

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

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), inplace 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 wellbeing 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.

(EPA, 1999b) 

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/refor

ms.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 timeconsuming 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 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 of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Overview, Pg. ii

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 facilityspecific 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/correctiveaction/facility.htm. 

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 facility-specific 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 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
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Overview, Pg. v

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/charts/charts2pdf 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.

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
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#Remediation Waste . 

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 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/correctiveaction/lists/base_st

a.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 involvement at corrective action facilities. 
7

 Regulated Units are defined in 40 CFR 264.90 (available through

http://www.access.gpo.gov/nara/cfr/cfr-retrieve.html#page1) 

(continued...)

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. 

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 unique to corrective action at RCRA regulated units7. You
7

(...continued)

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

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

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 RCRACERCLA coordination issues, you should refer to “Coordination between RCRA Corrective

Action and Closure and CERCLA Site Activities” (EPA, 1996b) available at

http://www.epa.gov/correctiveaction/resource/guidance/gen_ca/coordmem.pdf and the RCRA-
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Overview, Pg. x

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/F01/001, 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. EPA816-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

http://www.epa.gov/correctiveaction/resource/guidance/gen_ca/coordmem.pdf. 
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Overview, Pg. xii

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-

R-93-001. For more information, refer to 

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? 

EPA’s overall goal with respect to groundwater

is to prevent adverse affects to human health and
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. 

3

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

(continued...)

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Groundwater Strategy, Pg. 1.2

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. 

In the short-term3, EPA believes it is important that facilities take actions as soon as possible to
3

(...continued)

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. 

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 stakeholders. These relationships often foster creative,

results-based approaches that are increasing the overall pace, efficiency and effectiveness of
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

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 facilityspecific 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 place. The third element defines when the facility should implement

and complete an action. 
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

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/epaoswer/osw/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. Excerpts available at

http://www.epa.gov/epaoswer/hazwaste/ca/resource/guidance/gw/gwstr.htm

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 document that 95 percent of the
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

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#eis . 

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
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 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

three-dimensional 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 evaluating environmental
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Short-Term Goals, Pg. 2.5

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

environmental indicators for situations where contaminated groundwater is entering surface water
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. 

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. 2.6

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 short-term, 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 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
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Short-Term Goals, Pg. 2.7

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/R-00/007, 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/osw/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. 

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 sitespecific intermediate performance goals

provides a mechanism to prioritize work

and measure progress toward achieving

long-term 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 of removal, treatment, and containment), plume size reduction, cleaning up off-site

plumes, prioritizing work, and remedy performance enhancements. For example: 
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

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. 
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Intermediate Goals, Pg. 3.4

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, 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 to

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

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 would present a significant risk to human health or the environment should exposure occur. A

(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)

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 throughout the groundwater, may be acceptable as long as the remedy protects
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

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.
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

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

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.
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

How thorough of an assessment should facilities conduct when evaluating one or more

remedial options?

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. 
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Final Cleanup Goals, Pg. 4.6

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

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

(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

facility-specific 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
2

(...continued)

excess cancer risk of 10-4. The numerical estimate means that for people receiving this level of exposure averaged

over a 70-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

between 10-4 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 considered 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 cross-media 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 potential source of drinking water, or has value or uses

other than drinking water.
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

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 nondrinking 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

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
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. 

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

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 facilityspecific 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 contaminant can then be used to calculate contaminantspecific 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).
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.access.gpo.gov/nara/cfr/cfr-retrieve.html#page1. 

Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Groundwater Cleanup Levels, Pg. 5.6

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 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). 
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

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 land use. For

more information on risk based closure, refer to the Risk-Based Clean Closure Memorandum

(EPA, 1998c) and call your overseeing regulator. 
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Groundwater Cleanup Levels, Pg. 5.8

References: 

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,

Risk-Based 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.oscreadiness.org/cec_courses/documents/mar1990.pdf 

The CFR is available 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 throughoutthe-plume/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 compliance (40 CFR 264.100). For more information regarding the point of compliance
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. 

for regulated units, refer to 40 CFR 264.90-100, which are available through

http://www.access.gpo.gov/nara/cfr/cfr-retrieve.html#page1. 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

facility-specific 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

facility-specific 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 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. 
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). 

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

(continued...)

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. 

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 boundary(ies) of the plume8 (EPA, 1999e). Using the general definition of a
8

(...continued)

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. 

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 facility-wide 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/osw/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/index.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, 1990b. National Oil and Hazardous Waste Contingency Plan (55 FR 8666 and 40 CFR

300). The preamble is available at http://www.oscreadiness.org/cec_courses/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 shortterm 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 long-standing 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 intermediate performance

goals used, for example, to demonstrate progress toward achieving final cleanup goals. 
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

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 caseby-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 facility-specific 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.oscreadiness.org/cec_courses/documents/mar1990.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

non-drinking 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 facilityspecific 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 people think about groundwater use,

they often consider only drinking water use; however, there are many other groundwater uses
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) 

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?

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
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

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 to make a groundwater use designation. 
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

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. 
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

How can State groundwater use designations enhance protection and flexibility for RCRA

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/ ) that might otherwise remain unused. 

However, it is important to evaluate various uses of and exposures to groundwater on a facilityspecific 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 
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

type of 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 long-term 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. 
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Groundwater Use Designations, Pg. 9.7

EPA, 1992a. Final Comprehensive State Groundwater Protection Program Guidance

(EPA/100/R-93/001). 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. Excerpts available at

http://www.epa.gov/epaoswer/hazwaste/ca/resource/guidance/gw/gwstr.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.
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 download this document as

well as supporting materials at http://www.epa.gov/epaoswer/hazwaste/ca/guidance.htm#Institutional Controls

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; 

• enforcement tools with institutional control components; and

• informational devices. 
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Institutional Controls, Pg. 10.2

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 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)
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Institutional Controls, Pg. 10.3

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/epaoswer/hazwaste/ca/uidance.htm#Institutional Controls . 

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;

• the contaminant plume(s) is already stable or shrinking in extent; 
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 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 offsite 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, 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
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Monitored Natural Attenuation, Pg. 11.3

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.oscreadiness.org/cec_courses/documents/mar1990.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/default.htm) 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 contaminantrelated 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 example, inadequate characterization, selecting inappropriate technologies, or
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

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 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
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

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 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. 
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Technical Impracticability, Pg. 12.5

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.access.gpo.gov/nara/cfr/cfr-retrieve.html#page1 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 in-situ

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 reinject 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,” (December). 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

 • verify attainment of short-term, intermediate, or final goals. 
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

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/adde

ndum.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. Furthermore, the Office of

Solid Waste is currently developing a new guidance memorandum addressing various administrative issues

associated with completion of Corrective Action at RCRA facilities. That document, when issued, will be available

at http://www.epa.gov/correctiveaction. EPA acknowledges that this Handbook may need to be updated to be

consistent with the new completion guidance memorandum. Also refer to EPA, 1996a for additional guidance

concerning “completion of corrective measures.” 

2 Remedies that rely solely on monitored natural attenuation to address contaminated groundwater would

not typically involve “construction” apart from installing monitoring wells. 

3 EPA’s RCRA data management system (EPA, 1999f; available at

http://www.epa.gov/epaoswer/hazwaste/ca/facility/ca-diction.pdf - page 23 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 encourages regulators and

facilities to recognize various phases or

milestones associated with remedies

designed to achieve final cleanup goals. 

However, EPA also discourages facilities

from prematurely considering that they

have fulfilled all of their corrective action

obligations when further operation,

maintenance, or monitoring is needed to

protect human health or the environment.

15. Completing Groundwater Remedies

(September 2001)

What does completing a groundwater remedy mean with respect to RCRA Corrective Action? 

EPA generally recognizes the following phases of completing1 a groundwater remedy designed to

achieve final cleanup goals: 

• implementing the final remedy (i.e.,

construction is complete and the remedy is

operating as intended); 

• achieving final cleanup goals; and 

• fulfilling all cleanup obligations associated

with the contaminated groundwater including

long-term monitoring.

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

construction2

 has been completed and the remedy

is operating as designed. Further cleanup

activities are limited to continued operation, maintenance, and monitoring of the remedy. 

Sometimes EPA refers (EPA, 1997f) to this phase in the completion of a remedy as Construction

Completion.3
4 Media cleanup objectives refer to broad cleanup objectives that often include the more specific concepts

of media cleanup levels, points of compliance, and cleanup timeframes. 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.

5 EPA’s RCRA data management system (EPA, 1999f; available at 

http://www.epa.gov/epaoswer/hazwaste/ca/facility/ca-diction.pdf - - page 37) describes completion in terms of

satisfying all permit or order requirements for corrective action, and assigns the code CA 999 titled Corrective

Action Process Terminated. This event code can apply to the cleanup of an entire facility or the cleanup of an

individual area or portion of a facility. 

6

 For example, the facility no longer needs to conduct performance monitoring to ensure the

concentrations of contaminants in groundwater do not rebound above levels of concern, or that a long-term

containment remedy is working as designed. Note that 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 

Completing Groundwater Remedies, Pg. 15.2

What does it mean to complete a groundwater remedy with respect to achieving final cleanup

goals? 

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 facilities achieve site-specific media cleanup objectives4,

and control surface and subsurface sources (see Source Control), to the extent practicable, 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 its maximum

beneficial use, this phase of completing a remedy typically means that the facility achieved

groundwater cleanup levels at the throughout-the-plume point of compliance and they have

controlled further releases of contaminants from sources. 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 a point of

compliance located outside the containment area. 

What does it mean to fulfill all cleanup obligations associated with contaminated groundwater

at a particular facility? 

Regulators will generally consider that a facility has fulfilled all of its cleanup obligations5

associated with contaminated groundwater when a facility:

• achieves final cleanup goals; 

• no longer needs to conduct performance monitoring to ensure protection of human health and

the environment6;
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Completing Groundwater Remedies, Pg. 15.3

• is not responsible for maintaining institutional controls; 

• does not need to maintain financial assurances for corrective action activities associated with

the groundwater cleanup;

• fulfills all procedures specified in a permit or order for removal and decontamination of units,

equipment, devices, and structures associated with the groundwater remedy; 

• fulfills public participation responsibilities associated with groundwater remedy decisions; and

• fulfills all other facility-specific permit or order requirements pertaining to the groundwater

remedy. 

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.

References: 

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. . Particularly relevant

pages: 23 and 37.

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, 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/F01/001, 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/epaoswer/hazwaste/ca/resource/guidance/ics/icfactfinal.pdf. 

EPA, 2000c. Proceedings of the Ground-Water/Surface-Water Interactions Workshop

(EPA/542/R-00/007, 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/osw/ei_guida.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, 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,

Risk-Based 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/index.htm. 

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/epaoswer/hazwaste/ca/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/R-93/001). 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/d8382df2d09b64668525652800519745/27d1baa5c1dbb8f38

525670f006be76d?OpenDocument.

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

Administrator. Washington, D.C. Excerpts available at

http://www.epa.gov/epaoswer/hazwaste/ca/resource/guidance/gw/gwstr.htm

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.oscreadiness.org/cec_courses/documents/mar1990.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/cleanup

EPA’s Office of Underground Storage Tanks 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

National Environmental Publications 

Internet Site (NEPIS) http://www.epa.gov/cincl/ 
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/ 

Superfund Acronyms Glossary - available at http://www.epa.gov/superfund/gloss1.htm

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)
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Appendix 3, Pg. 2

contamination - describes media containing contaminants in any form (e.g., non-aqueous phase

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

wood-treating 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).
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Appendix 3, Pg. 3

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 - 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 ) 
Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action 

Appendix 3, Pg. 4

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)

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.